NCD003200383_20000512_Koppers Co. Inc._FRBCERCLA RA_One-Year Groundwater Monitoring 1998 - 2000-OCR

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. . • • ThermoRetec Corporation
9 Damonmilt Square, Suite 3A
Concord, MA 01742·2851
.ThermoRetec
March 20, 2000
Ms. Beverly Hudson
Remedial Project Manager
Superfund Branch
Waste Management Division
.RECEIVED
MAR 21 2000
United States Environmental Protection Agrofl!RFUND SECTION
Region IV
61 Forsyth Street, 11 th Floor
Atlanta, GA 30303
Smart Solutions. Positive Outcomes.
[phone] Phone
[phone] Fax
www.thermoretec.com
RE: One-Year Groundwater Remedial Action Monitoring Report -Revised
Koppers Company NPL Site
Morrisville, Wake County
EPA #ILD 000 819 946
Dear iv!s. Hudson:
On behalf of Beazer East, Inc. (Beazer), ThermoRetec is submitting two copies of the
One-Year Groundwater Remedial Action Monitoring Report -Revised for the Koppers
Company NPL site in Morrisville, North Carolina. This document has been revised to
reflect the comments contained in the North Carolina Department of Environment and
Natural Resources's letter of February 14, 2000. The following changes were made in
response to the noted comments:
Comment I. Table 3 has been revised to indicate that the sampling date for well C-27B
was January 23, 1998.
/ Comment 2. Pages 2 and 3 of Table 6 had been inadvertently omitted during copying
and have been inserted in to these complete documents.
/Comment 3. Pages 1 and 2 of Table 7 had been inadYertently omitted during copying
and have been inserted in to these complete documents.
/Comment 4. Page I of the Field Data Sheet in Appendix A for Groundwater Sampling
for the January 1998 groundwater sampling event had been inadvertently
omitted during copying and has been inserted in to these complete
documents.
✓Comment 5. Graphs for 2,,4-dichlorophenol time trends for monitoring wells C-27B, C-
12A, C-11B, C-IOB, C-IOA, C-09B, and C-01B which were omitted during
copying have been inserted in to these complete documents.
A subsidiary of Thermo Terra Tech inc.,
a Thermo Electron company
Ms. Beverly Hudson
March 20, 2000
Page 2
• •
.ThermoRetec
We apologize for these omissions If you have any questions or require additional
information, please feel free to contact me at [phone] or Mr. Mike Slenska at
[phone].
Best regards,
ThermoRetec Consulting Company
Laura A. Kelmar, P.E.
Groundwater Monitoring Program Manager
LK:mvc
Enclosure
cc: D. Mattison, NCDENR
M. Slenska , Beazer (w/o enc)
HP RO J E CTS\0362 4\CORRES'2000\H u<ls03 20. wpd
. . .
JAMES a: HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
• NOR.CAROLINA DEPARTMENT OF
ENVIRONMENT. AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
Ms. Beverly Hudson
Remedial Project Manager
Superfund Branch
Waste Management Division
February 14, 2000
United States Environmental Protection Agency
Region IV
6 I Forsyth Street, I I th Floor
Atlanta, GA 30303
Re: One-Year Groundwater Remedial Action Monitoring Report -Revised
Koppers Company NPL Site
Morrisville, Wake County
Dear Ms. Hudson:
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received the One-Year Groundwater
Remedial Action Monitoring Report -Revised for the Koppers Company National
Priorities List (NPL) Site. The Superfund Section has reviewed this document
and offers the attached comments.
We appreciate the opportunity to comment on this document. If you have any
questions, please feel free to call me at [phone], extension 349.
Sincerely, PJ
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
Attachment
cc: Mike Slenska, Beazer East, Inc. ljllfjj
••·••·• 1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1646
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER• 50% RECYCLE0/10% POST-CONSUMER PAPER
Ms. Beverly Hudson
February 14, 2000
Page I
• •
ONE-YEAR GROUNDWATER REMEDIAL ACTION MONITORING
REPORT -REVISED
Table 3 Summary of Field Purging and Sampling Parameters
I. Table 3 indicates that the sample date for groundwater monitoring well C-27B is January
22, 1998. However, the Field Data Sheet for Groundwater Sampling included in
Appendix A indicates that the sampling date for C-27B is January 23, 1998. Please
clarify this discrepancy.
Table 6 Summary of Equipment Blank Results
2. Page 2 and Page 3 (of three pages) of Table 6 were inadvertently omitted. Please correct
this oversight.
Table 7 Summary of Field Duplicate Results
3. Page 1 and Page 2 (of three pages) of Table 7 were inadvertently omitted. Please correct
this oversight.
Appendix A Field Data Sheets and Chain-of-Custody Forms
4. Page 1 ( of two) of the Field Data Sheet for Groundwater Sampling for the January 1998
groundwater-sampling event was inadvertently omitted from Appendix A. Please correct
this oversight.
Appendix C Pentachlorophenol and 2,4-Dichlorophenol Time Trends
5. The graph of 2,4-dichlorophenol time trends for groundwater monitoring wells C-27B, C-
12A, C-1 IB, C-lOB, C-lOA, C-09B, and C-OlB were inadvertently omitted. Please
correct this oversight.
•
Tanuary 19, 2000
Ms. Beverly Hudson
Remedial Project Manager
U.S. EPA -Region IV, 11 th Fl~ECEI\/En
North Site Management Branch · ---
61 Forsyth Street, SW JAN Z l ZOOO
Atlanta, GA 30303
• ThermoRetec Corporation
9 Damonmill Square, Suite 3A
Concord, MA 01742-2851
.ThermoRetec
Smart Solutions. Positive Outcomes.
[phone] Phone
[phone] Fax
www.thermoretec.com
SUPERFUND SECTION
RE: One-Year Groundwater Remedial Action Monitoring Report -Revised
Koppers Site -Morrisville, NC
Dear Ms. Hudson:
Enclosed please find the revised One-Year Groundwater Remedial Action Monitoring
Report for the Koppers Superfund Site, Morrisville, NC. This revision incorporates the
changes originally submitted to your office by Fluor Daniel-GT! on October 29, 1998.
Should you need additional information regarding this report, please call Mike Slenska
at [phone] or me at [phone].
Sincerely,
ThermoRetec Consulting Corporation
~~L v"' Q CQ~
Laura A. Kelmar, P.E.
Groundwater Monitoring Program Manager
Enclosure
cc: D. Mattison -NC Superfund
M. Slenska -Beazer
f,lprojects\3624\corres\2000\Hudson_0 119.wpd
A subsidiary of Thermo Terra Tech Inc.,
a Thermo Electron company
-'
. ;·: --.
' ,, -· -: :
•., .
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NORTH AROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
August 11, I 999
Memorandum
TO:
FROM:
RE:
Mr. Jay Zimmerman
Division of Water Quality
David B. Mattison, cHMM@
Environmental Engineer
Superfund Section
Proposed Remedial Action Groundwater Monitoring Program
Koppers Company, Inc. NPL Site
Morrisville, Wake County
ThermoRetec Consulting Corporation, on behalf of Beazer East, Inc., has completed
the Proposed Remedial Action Groundwater Monitoring Program for the Koppers Company, Inc. National Priorities List (NPL) site. The document being reviewed is
attached.
Please distribute this document to the appropriate personnel and submit any comments to the NC Superfund Section. We would like to have the views and
permitting requirements of the Groundwater Section by September I, 1999 in order to transmit any comments to the United States Environmental Protection Agency in
an expeditious.manner.
If you or your staff have any questions or comments, please feel free to call me at
[phone], extension 349.
Attachment
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone] AN EQUAL OPPORTUNITY/ Al'"FIRMAT!VE ACTION EMPLOYER· SO% RECYCLED/10% POST-CONSUMER PAPER
07/29/99 08:33 'B'H2 205 8869 BEAZER EAST INC •
BEAZER EAST, INC., ONE OXFORD CENTRE, SUITE 3000, PITTSBURGH, PA 15219
FAX COVER SHEET
DATE: TIME:
PHONE: TO: ;)"-~ i\A.,;,;tt; ~ o -
Nc-.,e.t-17.. FAX: "11 C.., • +Jl · fGf/
FROM M;k (\e,,.._;l,,""
Beazer East, Inc.
PHONE· (412) 208-6~}
FAX: [phone]
RE:
CC·
Number of pages including cover sheet: ..c..i_l _
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~001
07/29/99 08:34 'B'412 208 8869 BEAZER EAST INC •
Responge to Comments by NCDENR.
Former Koopers Suoerlund s·1t@, Morrisville, N::irtti Carolina
RESPONSE TO COMMENTS
•
Page i
October 29, 1998
BY NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL AND NATURAL RESOURCES
DATED AUGUST 27, 1998
le'.) 002
ONE-YEAR GROUNDWATER MONITORING REPO
FORMER KOPPERS SUPERFUNO SITE
MORRISVILLE, NORTH CAROLINA RAFT
Executive Summary
Comment 1: The third and fourth sentences of the sixth paragraph of this section state that
three groundwater samples (collected from groundwater monlton·ng wells C-11B
and C-29B, and pumping well PW-1) exceeded the groundwater protection standard
for pentachlorophenol. However, the laboratory documentation included in
Appendix B indicates that the groundwater sample obtained from groundwater
monitoring we// C -14B contained 20 ug/1 pentachlorophenol (in excess of the
groundwater protect/on standard for pentachlorophenol). Please clarify this
discrepanc;y.
Response· The laboratory provided analytical data in two formats, 1) a hard copy (i.e, the contents of
Appendix B) and 2) electronic date format (i.e. diskette) Electronic data was transferred
into Fluor Daniel GTl's GIS/KEY d.itabase. This database was used to create the
analytical data tables The electronic data provideded by the laboratory reported a non
detected concentration for pentachlorophenol. Review of the instrument raw data
indicates that pentachlorophenol was detected at a concentration of 20 ug/L in the
groundwater sample obtained from monitoring well C-14B as provided in Appendix B.
The si)(!h paragraph of the Executive Summary has been revised as well as the locations
in the report referenced in Comments 6, 7, 9, 18, ·, 9 and 33.
Comment 2: The fifth sentence of the sixth paragraph of this section states that the
pentach/orophenol conc;entrations have decreased at groundwater monitoring
we/ls C-11B and C-29B, and pumping well PW-1. However, monitoring we/I C-29B
exhibited a significant increase in pentachlorophenol concentrations during the
January 1998 sampling event. Please clarify this discrepancy.
Response: The fifth sentence, of the sixth paragraph of this section states:
"Compared with the overall historical concentrations at these three wells [C-11 Band C-
29B, and pumping well PW-1 ], the pentachlorophenol concentrations have decreased in
each of the wells samples."
Beazer recognizes that the concentration of pentachlorophenol in the sample from well M-
29B has increased from the March 1996 sampling event to the January 1998 sampling
evenl However, the statement refers to an overall review of the groundwater quality data
from 1990 to 1998. The pentachlorophenol concentrations in lhe samples collected
during 1990 from well C-29B were 591 ug/L (July 1990) and 968 ug/L (October 1990)
compared to the January 1998 concentration of 170 ug/L. Based on this overall
07/29/99 08:34 'B'412 208 S8G9 BEAZER EAST INC •
Response to Comments by NCDENR
FT ea,.,
Former Koooers Suoertund Site, Morrisville, North Carolina October 29, 1998
cnrnparison the concentration of pentachlorophenol in the samples collected from
monitoring well C-29B has decreased significantly.
Table of Contents -Figures
Comment 3: The Table of Contents states that the title of Figura 6 is "Penta<:hlorophenol
Conc;entration In Monitoring Wells." However, the title of Figure 6 is
"Penta<:hlorophenol Concentration -January 1998.'' Please clarify this
discrepancy.
Response The Table of Contents has been revised to reflect the title of Figure 6 verbatim.
Comment 4: Figura 7 was inadvertently omitted. Please corroct this oversight.
Response: The revised report includes a copy of Figure 7 showing 2,4-dichlorophenol concentrations
for the January 1998 groundwater sampling event
Table of Contents -Tables
Comment 5: The Table of Contents states that the title of Table 8 is "Comparison of Historical
Groundwater Quality Data and Six-Month Groundwater Quality Data." However, the
title for Table B is "Historical Groundwater Quality Data for Constituents of
Interest." Please clarify this discrepancy.
Response: The Table of Contents has been revised to state the title of Table 8 verbatim.
Section 4.1 One-Year Groundwater RA Monitoring Analytical Results
Comment 6 : The first paragraph of this section states that "pentachlorophcno/ concentrations
exceeding the maximum contaminant /eve/ (MCL) of 1 microgram per liter (ugll)
were roported from groundwater samples from two monitoring wells (C-11B and C"
29B)." However, the laboratory documentation included in appendix B indicates
that, besides groundwater monitoring we/ls C-11 B and C-29B, the groundwater
sample obt~ined from groundwater monitoring well C-146 contained 20 ug/1
pentach/orophenol. Please clarify this discrepancy.
Response Section 4.1 has been revised to indicate that pentachlorophenol was detected at a
concentration of 20 ug/L in the sample collected from groundwater monitoring well C-146.
Refer to the response to Comment 1 above.
Section 4.2 Comparison of Historical Groundwater Quality Data
Comment 7: The seventh sentence of the second paragraph Of this section states that
"pentachlorophenol was not detected above the detection limit (1 ug/J) in the
samples col/ec;ted from wells C-14A and C-14B during the One-Year groundwater
RA monitoring event." However, the laboratory documentation included In
Appendix B indicates that the groundwater sample obtained from groundwater
~003
07/29/99 08:35 'B'H2 208 8869 BEAZER EAST INC •
Response to Cornrnents by NCDENR
D~AFT ._,
Fornier Kopper-s Superiu:,d Sile, Morrisville. North CerolinJ October 29, 1998
monitoring well C-14B contained 20 ug/I pantachlorophenol. Please clarify this
discrepancy.
Response: Section 4 2 has been revised to indicate that pentachlorophenol was detected at a
concentration of 20 ug/L in the sample collected from groundwater monitoring well C-14B.
Refer to the response to Comment 1 above.
Comment 8: The fourth sentence of the fourth paragraph of this section states that
"pentachlorophenol concentrations at the extraction well PW-1 and monitoring well
C-29B have also shown an overall decreasing trend." However, monitoring well C-
29B exhibited a significant Increase in pentach/orophenol concentrations during
the January 1998 sampling event. Please clarify this discrepancy,
Response: Beazer recognizes that the pentachlorophenol concentratbn in the sample from well M-
29B has increased from the March 1996 sampling event to the January 1998 sampling
event. However, this document provides an overall review of the analytical data from
1990 to 1998. Pentachlorophenal concentrations in samples collected during 1990 from
well C-29B were 591 'Jg/L (July 1990) and 968 ug/L (October 1990) compared to the
January 1998 concentration of-, 70 ug/L. Based on an overall comparison of the
analytical data pentachlorophenol concentrations in the samples collected from
monitoring well C-29B have decreased significantly
Conclusions and Recommendations
Comment 9: The second sentence of the second paragraph of this section states that
"pentachlorophenol is below the MCL in all wells except C-11B, C-29B and PW-1 ..
. " However, the laboratory documentation included in appendix B indicates that
the groundwater sample obtained from groundwater monitoring well C-148
contained 20 ugll pentachlorophenol. Please clarify this discrepancy.
Response: Section 5, 0. Conclusions and Recommendations, has been revised to indicate that
pentachlorophenol was detected at a concentration of 20 ug/L in the sample collected
fncrn groundwater monitoring well C-14B. Please refer to the response to Comment 1
above.
Comment 10: The second to last sentence of this section should state " ... Beazer will re-
evaluate the groundwater monitoring program ... " Please correct this oversight.
Response: The report has been revised.
Table 1 Summary of Groundwater Elevations -October 21, 1997
Comment 11: Table 1 indicates that the depth to groundwater was not measured for groundwater
pumping well PW-1 and groundwater monitoring wells C-1BC, C-21C, C-23C, C-24C
and M-9. Please provide justification for not collecting depth to groundwater
measurements at these we/ls.
1//i 004
07/29/99 08:35 'B'412 208 8869 BEAZER EAST INC •
ResponS8 to Comrnents by NCDENR
Fomier Koooers Superfund Site, Morrisville. North Carolina
Response: As stated in the Field Sampling Plan -Pertonmance Standards Verification for tr,e
Remedial Action (Remedial Action Work Plan, Volume 2, Cummings Riter, May 1995),
water levels ar., to be measured in the on-site and near-offsite monitoring wells, which are
shown on Figure 1A of the report. Water level measurements in the on-site and near-
offslte monitoring wells are used to assess the influence of pumping at well PW-1,
Because the offsite deep monitoring wells (i.e.,C-18C, C-21C, C-23C, C-24C) would not
exhibit influence by the groundwater extraction at well PW-1, due to the distances to
these wells and anIsotrop1c influences of the bedrock, there is no need to measure water
levels at these wells.
Monitoring well M-9 was destroyed during the soil remedial action, This monitoring well
wil! be removed from the groundwater monitoring table as well as those affsIte deep wells
that are not measured.
Several attempts were made to obtain a water level measurement at well PW-1 an
October 21, 1998. However, the electrical cables and wires associated with the high and
low level water sensors in well PW-1 interfered with the collection of the water level
measurements
Table 2 Summary of Groundwater Elevations -Janua,y_21, 1998
Comment 12: Table 2 indicates that the depth to groundwater was not measured for groundwater
monitoring walls C-18C, C-21C, C-23C, C-24C and M-9. Please provide justification
for not collecting depth to groundwater measurements at these groundwater
monitoring walls.
Response: As stated in the Field Sampling Plan -Performance Standards Verification for the
Remedial Action (Remedial Action Wark Plan, Volume 2, Cummings Riter, May 1995),
water levels are to be measured in the on-site and near-offsite monitoring wells shown on
Figure 1A Water level measurements in the on-site and near-offsite monitoring wells are
used to assess the influence of pumping at well PW-1. Because the offsite deep
monitoring wells are not influenced by the groundwater extraction at well PW-1, due ta
distance to these wells and the anisotropic infiuences of the bednock water-bearing zone,
there is no need to measure water levels at these wells
Monitoring well M-9 was destroyed during the sail remedial action This monitoring well
will be removed from the table as well as those offsite deep wells that are not measured
for depth to groundwater.
Table 3 Summary of Field Purging and Sampling Parameters
Comment 13: Table 3 lndic;ates that well depth for groundwater monitoring well C-14B is 65.33
feet (ft), However, the Field Data Sheet for Groundwater Sampling inc;luded in
Appendix A indicates that the well depth for C-14B Is 65.93 ft. Please clarify this
discrepancy,
Response: The well depth for C-148 listed in Table 3 was incorrectly reported. The value listed on
the Field Data Sheet is correct. Table 3 has been corrected,
Ii!] 005
07/29/99 08:36 '6'412 208 8869 BEAZER EAST INC •
Response to Comments !:iy NCDENR
Fon'l"ler Koppers Supj,!rfund Site, Morrisvills, North Carolina
Comment 14: Table 3 indicates that the depth to water before purging for groundwater
monitoring well C-27B is 36.95 ft. However, the Field Data sheet for Groundwater
Sampling inc;luded in Appendix A indicates that the depth to water before purging
for C-27B Is 34. 95 ft. Please clarify this discrepancy.
Response: The depth to water in well C-27B before purging was incorrectly reporte,d Table 3 has
been c:orrected.
Comment 15: Table 3 Indicates that the sample date for groundwater monitoring well C-27B is
January 22, 1998. However, the Field Data Sheet for Groundwater Sampling
included In Appendix A lndicatf/s that the sampling date for C-27B is January 23,
1998. Please clarify this discrepancy.
Response: Table 3 has been corrected as referenced in the comment
Comment 16: Table 3 indicates in the section entitled, Comments, that the groundwater sample
for groundwater monitoring well C-11 e was clear and had an odor. However, the
Field Data Sheet for groundwater Sampling included in Appendix A that the
groundwater sample for C-11 B was cloudy. Please clarify this discrepancy,
Response: Table 3 has been corrected to state "Clear. then cloudy at 3 well volumes."
Comment 17: Table 3 Indicates in the section entitled, Comments, that the groundwater sample
for groundwater pumping well PW-1 was c/e;;ir. However, the Field Data Shoot for
Groundwater Sampling included in Appendix A that the groundwater sample for
PW-1 was clear and had an odor. Please clarify this discrepancy.
Response: The comment is ambiguous about which sampling date is being referenced Table 3
states that on January 22, '1998, tne water from well PW-1 was "Clear" withe "sweet
odor". which is what is written on the Field Data Sheet for \his groundwater sampling
event. The sample collected on February 11, 1998 had an odor. The information has
been added to Table 3.
Table 4 Summary of Groundwater Analytical Results for Constituents of Interest
Comment 18: Table 4 indicates that the groundwater sample obtained from groundwater
monitoring well C-14B contained no detectable concentrations of
pentachlorophenol at a laboratory quantltation llmit of 1 ug/I. However, the
laboratory document.ation included in Appendix B indicates that the groundwater
sample obtilined from groundwater monitoring well C-14B contained 20 ug/I
pentachlorophenol. Please clarify this discrepancy.
Response: Table 4 has been revised to indicate that pentachlorophenol was detected at a
concentration of 20 ug/L in the sample collected from groundwater monitoring well C-14B.
Refer to the response to Comment 1 above.
li1J 006
07/29/99 08:37 °B'412 20S S869 BEAZER EAST INC •
R.esoonse to Comments by NCDENR
Former Koppers Superfund Site, Morrisville, North Caro!i,1~
Table B Summary of Historical Groundwater Quality Data for Constituents of Interest
Comment 19: Table B indicates that the groundwater sample obtained from groundwater
monitoring well C-14B in Janvary 199B contained no detectable com:entrations of
pentachlorophenol at a laboratory quantitatlon limit of 1 ug/I. However, the
laboratory documentation included in Appendix B indicates thiJt the groundwater
sample obtained from groundwater monitoring well C-14B in January 1998
contained 20 ug/I pentach/oropheno/. Please clarify this discrepancy.
Response: Table 8 has been revised to indicate that pentachlorophenol was detected at a
concentration of 20 ug/L in the groundwater sample collected from monitoring well C-14B.
Refer to the response to Comment 1 above.
Figure 1 On-Site and Near Off-Site Monitoring Well Locations
Comment 20: Figure 1 does not indicate the location of groundwater monitoring wells C-16C, C-
17C, C-18C, C·19C, C-20C, C-21C, C-22C, C-23C, C-24C, and C-32C. Please revise
Figure 1 or include an additional figure to depict the locations of all groundwater
monitoring wells.
Response: The above well locations have been provided on Figure 1 B. Tne text has been revised to
include this Figure. The ten deep offsite wells were placed at locations to encircle the site
to determine whether constituents of Interest had migrated to these distant offsite
locations. These wells will not be influenced by the pumping at well PW-1.
Figure 2 Groundwater Elevation Contours. Shallow Wells -October 21. 1997
Comment 21: Figure 2 does not indicate tha location or groundwater elevation of groundwater
monitoring we// C-30A. Please revise Figure 2 to depict the location of
groundwater monitoring well C-30A.
Response Despite the designation of well C-30A as an A-level well, monitoring well C-30A has
always been considered an intermediate level monitoring well, as discussed in the
Remedial Investigation (RI) Report (Keystone, September 1992). The following is a
summary of the explanation as provided in the RI report.
The borings drilled at all but three of the 38 on-site and near offsite monitoring well
locations (as shown on Figure 2-2 of the RI report, which ts reproduced as Figure 1A of
the One-Year Groundwater Remedial Action Dato Summary Report) were completed
using air drilling methods. Only the borings for monitoring well locations C-14A, C-27 A.
and C-28A were completed using 6 114-inch l.D, hollow stem augers because
groundwater was encountered in the weathered bedrock. The total depths of the borings
far these three monitoring wells were 28.5 feet bgs, 28 feet bgs and 26 feet bgs,
respectively. After encountering auger refusal at monitorir.g weli location C-30A prior to
reaching the water table (eventually encountered within a fracture at 30 to 31 feet bgs).
and based on anticipated depths to water and information regarding depth to bedrock
derived from borings installed prior to the RI, the decision was made to complete all
remaining wells using air nctary or air percussion drilling methods
lilJ 007
07/29/99 08: 37 'B'412 208 8869 BEAZER EAST INC •
Response to Ccrriments by NCDENR
Page 7
Cber 29, 1998
f=orrner Ko pers Superfund Site, Morrii;;ville, North Carolina
The initial borehole for monitoring well C-30A was advanced to a depth ol 25 feet bgs
where augec refusal was en~ountered. No groundwater was observed in the borehole
during installation. This borehole remained open for 12 days. Since no groundwater
entered the borehole during the period that it was open, the borehole was abandoned. A
subsequent borehole was advanced for monitoring well C-30A using air drilling methods,
and a water-bearing fracture in competent bedrock was encountered between 30 and 31
feet bgs. Static water levels in this well were measured at depths ranging rrom 1 0 to 13
fee:. Because the static water levels were considerably above the depth at which
groundwater was encountered, well C-30A has been considered an intermediate level
well.
Please refer to Figures 4 and 5 for the location of well C-30A and its gmundwater
elevations, which are representative al an intermediate monitoring well.
Figure 3 Groundwater Elevation Contours. Shallow Wells -January 21, 1998
Comment 22: Figure 3 indicates th;,t the groundwater elevation for groundwater monitoring well
C-BA is 348.92 ft., mean sea /eve/ (ms/). However, Table 2 indicates that the
groundwater elevation for C-BA is 348.52 ft., ms/. Please clarify this discrepancy.
Response The value listed on Figure 3 has bE!en changed to "348.52" (!Bet msl). This minor
difference in groundwater elevation does not affect the groundwater elevation contours in
an area where the contours are marked to be inferred.
Comment 23: Figure 3 does not indicate the location or groundwater elevation of groundwater
monitoring well C-30A. P/e;,se revise Figure 3 to depict the location of
groundwater monitoring well C-30A.
Response: See response to Comment 21 above.
Figure 4 Groundwater Elevation Contours, Intermediate/Deep Wells -October 21, 1997
Comment 24: Figure 4 does not indicate the location or groundwater elevation of groundwater
monitoring wells C-1B, C-9C, C-12C, C·17C, C-19G, C0 20C, C-22C, C-33C orC-34G.
Please revise Figure 4 or include an additional figure to depict this data.
Additionally, please provide justification for the inclusion of groundwater elevation
data for one groundwater monitoring well over another in those instances in which
groundWater monitoring well clusters have been installed.
Response: Please refer to the response to Comment 20 above regarding the deep offsite wells cited
111 this comment. as well as the discussion in the RI report for an understanding of the
occunnence of groundwater in several of the listed wells during monitoring well drilling and
groundwater monitoring and the temporal changes in groundwater elevation observed in
the monitor,ng wells during the pumping test completed in February 1991. In reviewing
the RI report, please be cognizant that the C-level wells were required for the purpose al
vertical delineation and were found to be unrepresentative in terms of groundwater fiow in
the fractured bed.ock (specifically, bedrock that is not an "aquifer").
~008
07/29/99 08:38 °6'412 208 8869 BEAZER EAST INC •
Response to Comment5 oy NCDENR
Former Koppers Superfund Site, Morrisville, Nonh Carolina
As discussed on page 3-35 of the RI report, water levels ,n wells C-16, C-1 OB and C-12C
have always been considerably lower than in the other B and C series wells. At these
well locations. no water-bearing fractures were encountered during drilling after the
surface casing was set. N; seen from the groundwater elevation data for October 21,
1997, well C-12B had a depth to water of 15.79 feet yielding a groundwater elevation of
359.96 feet ms\, while the adjacent well C-12C had depth to groundwater greater than 100
feet. On January 21, 1998, the depth to water in wells C-12B (15.75 feet) and C-12C
( 123-73 feet) resulted in groundwater elevations of 350 00 feet msl and 252,38 feet msl,
respectively, The low yield of groundwater in well C-12C is caused by the groundwater
elevation being more than 100 feet lower than the adjacent intermediate level well.
Because of this low yield of groundwater, monitoring well C-12C is not used in
groundwater elevation contouring. Similarly, the groundwater elevation for monitoring well
C-1 OB on October 21, 1997 was greater than 1 DO feet, and this groundwater elevation is
not representative of groundwater in the intermediate zone since there were no
groundwater fractures encountered at this well.
As discussed in the RI report, the pumping test completed in February 1991 revealed that
\here was anisotropic groundwater fiow in the water-bearing bedrock underlying the site.
The cumulative information collected during the RI indicates that the interval that
produced the most water was 30 to 55 feet in depth where fractures were encountered.
For example, while well C-9B had 1.37 feet of drawdown observed during the pumping
test, monitoring well C-9C had no drawdown observed. In terms of deter.mining the
effects of groundwater extraction at well PW-1, well C-9B is used due to the extent of
capture demonstrated during the RI pumping test.
An example of the disparity in groundwater elevations and unreliability of the groundwater
elevation data between the Band C level wells can be seen in comparing the C-33B and
C-33C groundwater elevations. The gnoundwater elevations for wells C-33B and C-33C
were 347.57 feet msl and 314,80 feet msl, respectively. In comparison to the
groundwater elevations for other wells in the area, the elevation for well C-33C is clearly
not representative of the intermediate zone and therefore, not used in groundwater
elevation contouring.
Figure 4 shows a dashed line for the 342-feet ms\ groundwater elevation contour line
indicating an inferred groundwater elevation between well C-25B ,ind well C-32C, as the
C-32C groundwater elevation is considered less reliable,
Comment 25: Groundwater monitoring well C-30A was inadvertently included in Figure 4, Please
remove C-30A from Figure 4 and place In Figure 2.
Response: Please refer to the response to Comment 21 above.
Figure 5 Groundwater Elevation Contours. Intermediate/Deep Wells -January 21. 1998
Comment 26: Figure 5 does not indicate the location or groundwater elevation of groundwater
monitoring wells C-1B, C-9C, C-12C, C-17C, C-19C, C-20C, C-22C, C-33C or C-34C.
Please revise Figure 5 or include an additional figure to depict this data.
Additionally, please provide justification for the inclusion of groundwater elevation
i//J 009
07/29/99 08:J8 'B'412 208 8869 •
Resconse to Comments by NCOENR
Former Koppers Superfund Slt0, Morrisville, North Carolina
BEAZER EAST INC ,, ·;;a--•
r
age 9
October 29, 1998
data for one groundwater monitoring wall aver another in those instances in which
groundwater monitoring well clusters have been installed.
Response: Please refer to response to Comment 24 above.
Comment 27: Groundwater monitoring well C-30A was inadvertently included in Figure 5. Please
remove C-30A from Figure 5 and place in Figure 3.
Response: Please refer to the response to Comment 21 above.
Figure 6 Pentachloropheno/ Concentration -January 21, 1998
Comment 28: Please provide arrows to indicate which groundwater monitoring wells are
associated with the corresponding pentachlorophenol concentrations.
Response: A line from the data boxes to the individual wells has been added to Figure 6.
Comment 29; Figure 6 indicates that the groundwater sample obtained from groundwater
monitoring well C-148 contained no detectable concentrations of
pentachloropheno/ at a laboratory quantltation limit of 1 ug/1. However, the
laboratory documentation included in Appendix 8 indicates that the groundwater
sample obtained from groundwater monitoring well C-14/3 contflined 20 ugl/
pentachlorophenol. Please clarify this discrepancy.
Response: Please refer to the response to Comment 1 above.
Appendix A Field Data Sheets and Chain-of Custody Forms
Comment 30: The copy of the field log book pages that include depth to water measurement for
the nine-month remedial action monitoring event conducted on Oc;tober 21, 1997
were inadvertently omitted. Please correct this oversight.
Response: The depth to water level measurements have been included in Appendix A.
Comment 31: The copy of the field log book page that contains the depth to water measurements
for the one-year remedial action monitoring event conducted on January 21, 1998
indicates that multiple depth to water measurements were made for groundwater
monitoring wells C-11B, C-13A, C-13B, C-14A, C-14B, C-15B, C-27A, C-27B, C-28A,
C-28B, C-29B, PW-1 and M-4. Please provide the rationale used In collecting this
dat;,, a discussion of the accuracy ;,nd precision of the data collect/on for all of the
depth to water measurements, and the rational used in determining which data is
included in Table 2. Please amend the appropriate sections of this report to
include this inrormation.
Response: Because of the low sustainable yield of the fractured Triassic bedroc!<, the pump in well
PW-1 is not able to operate continuously. Rather, is it controlled by high and low water
!i/1010
07/29/99 08:39 'fi'H2 208 8869 BEAZER EAST INC • h , ,, ::~,;~';
'
Response: to Comments by NCDENR
D~P f.·.:.·:i/..7-1"""
:L age 10
Former Koppers Superfund Site, Morrisville, North Carolina October 29, 1998
level sensors in well PW-1 that activate and terminate pumping. Once the primary
porosity of the fractures is drained, tM secondary porosity of the bedrock does not
contribute to the groundwater yield. The effect of limited secondary porosity and
permeability causes groundwater extraction to occur in a "pulsed" rnanner.
When the pump started on the January 21, 1998 event, multiple water level
measurements were collected from wells located within the hydraulic infiuence cf we!!
PW-1 to determine the influences pumping operations have on groundwater elevations.
Collection of multiple water level measurements while the pump in well PW-1 was
operating allowed the determination of groundwater level Ructuation at select monitoring
wells in proximity to well PW-1. Since the maximum depth to woter measurement was
used in constnuct,ng the groundwater contours for January 22, 1998, these contours
depict the likely maximum hydraulic infiuence of well PW" 1 at each monitoring well
location.
The above discussion was included in Section 2,0 of the report,
Comment 32: The Field Data Sheets for Groundwater Sampling are Incomplete. The Field Data
Sheets should include the date and start time for purging actlvives, the estimated
water volume required for purging i!IS well as the pH, specific conductivity and
temperature measurements collected prior to purging and immediately fol/owing
the purging of each well volume purged. A portion of this information has been
Included in Table 3. However, please provide copies of the field tog boo/< which
document the groundwater sampling activities and the collection ot this data.
Response· The format of the Field Data Sheet in this report is the same format as presented in the
Quality Assurance Project Plan (OAPjP, Chester, June 1993) contair.ed in the Remedial
Action Work Plan, (Cummings Riter, May 1995). The water volume required for ourg,ng
each well was calculated using the well's water column height in feet multiplied by the
volume of water contained in the well casing (gallons per foot) for a specific well diarr,eler
Appendix C
by a factor of three. ·
The date, start and end time of purging, lime of sample collection and the pH, specific
conductivity and temperature measurements collected during purging are provided on the
attached copies of the logbook pages.
There are no measurements recorded for groundwater indicator parameters before the
initiation of purging, since this water is stagnant and not representative of actual
groundwater conditions as indicated by the groundwater quality indicator parameters
listed. It is for tnis reason that groundwater is purged from a. monitoring well prior to
collection of groundwater samples Furthermore, the collection of field measurements
prior to purging listed In this comment do not agree with tl1ose listed in the EPA Region IV
Environmental Investigations Standard Operating Procedures and Quality Assurance
manual (EISOPQAM, May 1996).
Pentachloropheno/ and 2,4-D!chlorophenol Time Trends
Comment 33: The graph of pentach/oropheno/ time trends for groundwater monitoring well C-
148 indicates that the groundwater sample obtained from groundwater monitoring
~011
07/29/99 09:30 'B'H2 208 8869 BEAZER EAST INC • •
BEAZER EAST, INC, ONE OXFORD CENl?,E, SUITE 30C{), PITTSBURGH, PA 15219
FAX COVER SHEET
DATE:
TO: }).,,""-M .. +h ~ "~
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FROM: M: V..q_, .(\e,,.,,_;V""
Beazer East. Inc.
RE:
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PHONE: [phone]'o(.}-
FAX: [phone]
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•
Re~po~se to Comments by NCDENR DRAFT .. ,.,,
Former Koppers Sucerfuna site, M□rTisv1l1e, North Carolina Ociober 29, 1998
Response:
well C-148 during the January 1998 sampling event contained no detectable
concentrations of pentachlorophenol at a laboratory quantitation limit of 1 ug/1.
However, the laboratory documentation included in Appendix B indicates that the
groundwater sample obtained from groundwater monitoring well C-148 during the
January 1998 sampling event contained 20 ugll pentachlorophenol. Please clarify
this discrepancy.
The time vs pentachlorophenol concentration trend for well C-14B has been revised to
indicate that pentachlorophenol was detected at a concentration of 20 ug/L in the January
1998 sample collected from groundwater monitoring well C-14B. Refer to the response to
Comment 1 above.
JNI LS\'3 M3Z\/38 oc:50 66/6,llO
i,ORT •,SUP E RFU ND iD: JUL 27'99 • • UNITED STATES ENVIFIONMENTAL PROTECTION AGENCY REGION 4
4WD-NSMB
Mr. Michael Slenska
Beazer Eaet,Inc,
ATLANTA FEDERAL CENTER
e1 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
July 27, 1999
One Oxford Centre, Suite 3000 Pittsburgh, PA 15219
10:35 No.003 P.02
SUBJ: One-Year Groundwater Remedial Action Monitoring Report and Proposed Remedial Action Groundwater Monitoring Program for the Koppers Superfund Site.
Dear Mr. Slenska:
The Environmental Protection Agency and the North Carolina Department of Environmental and Natural Resources has conditionally approved the above mentioned documents. Please note the following comment and any previous co1m1ents submitted to you by the State of North Carolina. Also, please accept comments submitted to you by the State of North Carolina regarding the Work Plan for Toxicity Reduction Evaluation dated August 11, 1998.
1) Executive Summary, pg iii. The MCL for 2,3,7,8-TCDD is 0.00003ug/l not 30ug/l.
We appreciate the opportunity to review the groundwater reports. If you have any questions, please do not hesitate to contact me at [phone] or Dave Madison at (919) 733·2801.
cc: Dave Madison, NC
S.incerely,
r y T. Hudson
Management Division
lntomot Addroos (URL)• h1lp:/lwww.opa.gov
Reoyclod/Recyclal)lt • Ptlnled w~h V&f,16\~IB OIi Based In~ on Aocyciad f'aper (Minimum 2:ig/. f'oSlonsumer)
i-JORT'' SUPERFUi,D ID: JUL 27'99 10:36 No .003 P.01 -~
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OFFICE:
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United states Environmental ~ote.ction Agency
.W~ M'•nagement Division
North Site Management Branch
61 Ponyth Street, SW
Atlanta, Ocorp, 30303 ·
'
DATE: ,iz7/9? ll'f'lad is cf'\ TELEPHONE#: cq l'I) 13 ?i-' .2?0 I .
FAX PHONE II:
(919)133-4%'11.
FROM: 'oc-1 e,~ l+u d.:, o/"I TELEPHONE I:
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OfflCE: Nu,--\h ~ix._ A,\o.~o.j e..m er+-P-,n_,__~ch PAGE 1 OF 2-PAGES
INCLUDINO COVU SHBBT
'
RETURN FAX II: (404) 562-87ss
•
BEAZER EAST, INC., ONE OXFORD CENTRE, SUITE 3000, PITTSBURGH, PA 15219-6401
July 22, 1999
Beverly Hudson
Remedial Project Manager
United States Environmental Protection Agency -Region IV
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303-8909
✓David Mattison, CHMM
Environmental Engineer, Superfund Section
North Carolina Department of Environment and Natural Resources
Division of Waste Management
401 Oberlin Road, Suite 150
Raliegh, North Carolina 27605
Re: Site Meeting
RECEI\/El)
JUL 2 21999
SUPERFUND SECTION
Former Koppers Company, Inc. Site
Morrisville, North Carolina
Dear Ms. Hudson and Mr. Mattison: ·
This letter is written in anticipation of our scheduled July 29, 1999 meeting at the Former
Koppers Company, Inc. Superfund Site located in Morrisville, North Carolina. Beazer
East, Inc. (Beazer) believes that there are several significant issues to discuss at that
upcoming meeting. These issues are briefly summarized below:
• One-Year Groundwater Remedial Action Monitoring Report, June 4, 1998, Fluor
Daniel GT!, Inc. -This report provides a summary of the groundwater monitoring
program activities, and the corresponding findings, conducted from April 1997
through February 1998. The North Carolina Department of Environmental and
Natural Resources (NCDENR) provided comments on the report on August 27, 1998.
To date Beazer has not received comments from USEPA regarding this report.
• . Proposed Remedial Action Groundwater Monitoring Program, July 20, 1998,
ThermoRetec -This report described a proposed groundwater monitoring program
and recommended a future operation and monitoring plan for the groundwater
extraction system. These recommendations were based on the results and ·conclusions
of the monitoring activities described in the above-listed report. NCDENR provided
Ms. Hudson and Mr. Mlson
July 22, 1999
Page 2
•
comments on this proposed monitoring program on September I 0, 1998. To date
Beazer has not received comments from USEPA.
• Work Plan for Toxicity Reduction Evaluation (TRE), August 11, 1998, ThermoRetec
-This work plan was prepared to describe the work that Beazer intended to conduct
in an attempt to determine the source of periodic toxicity in the Site's groundwater
treatment plant effluent. Since the August 11, 1998 work plan submittal, only the
January 1999 effluent sample failed the toxicity test. NCDENR provided comments
on this proposed TRE work plan on September I 0, 1998 and September 16, 1998. To
date Beazer has not received comments from USEPA.
• Domestic Well Sampling -Beazer understands that the USEPA has conducted two
dioxin sampling events of numerous domestic wells located near the Site. Beazer
would like to discuss the locations of these wells, the sample collection methods, the
analytical methods used test the well samples, and the subsequent results.
Beazer looks forward to meeting with you and representatives from the NCDENR on July
29, 1999 at 12:30 p.m. to discuss the above issues and any other pertinent topics related
to the Site. If you should have any questions or require additional information, please
contact me at [phone].
8;;:ljJLL__
Michael Slenska, P.E.
Environmental Manager
cc: Ben Genes, ThermoRetec
JAMES B. HUNT JR ..
GoVERNOR
( '. . •" .. . WAYNE MCDEVITT,.; • ,.
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NORTH !ROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Ms. Beverly Hudson
Remedial Project Manager
Superfund Branch
Waste Management Division
August 27, 1998
United States Environmental Protection Agency
Region IV
61 Forsyth Street, 11th Floor
Atlanta, GA 30303
Re: One-Year Groundwater Monitoring Report
Koppers Company NPL Site
Morrisville, Wake County
Dear Ms. Hudson:
DIVISION OF WASTE MANAGEMENT
The Superfund Section of the North Carolina Department of Environment and
Natural Resources (NC DENR) has received One-Year Groundwater Monitoring
Report for the Koppers Company National Priorities List (NPL) Site. The
Superfund Section has reviewed this document and offers the attached
comments.
We appreciate the opportunity to comment on this document. If you have any
questions, please feel free to call me at [phone], extension 349.
Attachment
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
cc: Mike Slenska, Beazer East, Inc.
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX 919•715-3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -SO% RECYCLED/I 0% POST-CONSUMER PAPER
Ms. Beverly Hudson
August 27, 1998
Page 1
•
ONE-YEAR GROUNDWATER MONITORING REPORT
Executive Summary
•
1. The third and fourth sentences of the sixth paragraph of this section state that three
groundwater samples (collected from groundwater monitoring wells C-llB and C-29B,
and pumping well PW-I) exceeded the groundwater protection standard for
pentachlorophenol. However, the laboratory documentation included in Appendix B
indicates that the groundwater sample obtained from groundwater monitoring well C-
14B contained 20 µg/1 pentachlorophenol (in excess of the groundwater protection
standard for pentachlorophenol). Please clarify this discrepancy.
2. The fifth sentence of the sixth paragraph of this section states that the
pentachlorophenol concentrations have decreased at groundwater monitoring wells C-
llB and C-29B, and pumping well PW-1. However, monitoring well C-29B exhibited
a significant increase in pentachlorophenol concentrations during the January 1998
sampling event. Please clarify this discrepancy.
Table of Contents -Figures
3. The Table of Contents states that the title of Figure 6 is "Pentachlorophenol
Concentration in Monitoring Wells." However, the title of Figure 6 is
"Pentachlorophenol Concentrations -January 1998." Please clarify this discrepancy.
4. Figure 7 was inadvertently omitted. Please correct this oversight.
Table of Contents -Tables
5. The Table of Contents states that the title of Table 8 is "Comparison of Historical
Groundwater Quality Data and Six-Month Groundwater Quality Data." However, the
title for Table 8 is "Historical Groundwater Quality Data for Constituents of Interest."
Please clarify this discrepancy.
Section 4.1 One-Year Groundwater RA Monitoring Analytical Results
6. The first paragraph of this section states that "pentachlorophenol concentrations
exceeding the maximum contaminant level (MCL) of I microgram per liter (µg/1) were
reported from groundwater samples from two monitoring wells (C-llB and C-29B)."
However, the laboratory documentation included in Appendix B indicates that, besides
groundwater monitoring wells C-llB and C-29B, the groundwater sample obtained
from groundwater monitoring well C-14B contained 20 µg/1 pentachlorophenol. Please
clarify this discrepancy.
Ms. Beverly Hudson
August 27, 1998
Page 2.
• •
Section 4.2 Comparison of Historical Groundwater Quality Data
7. The seventh sentence of the second paragraph of this section states that
"pentachlorophenol was not detected above the detection limit (1 µg/1) in the samples
collected from wells C-14A and C-14B during the One-Year groundwater RA
monitoring event." However, the laboratory documentation included in Appendix B
indicates that the groundwater sample obtained from groundwater monitoring well C-
14B contained 20 µg/1 pentachlorophenol. Please clarify this discrepancy.
8. The fourth sentence of the fourth paragraph of this section states that
"pentachlorophenol concentrations at the extraction well PW-1 and monitoring well C-
29B have also shown an overall decreasing trend." However, monitoring well C-29B
exhibited a significant increase in pentachlorophenol concentrations during the January
1998 sampling event. Please clarify this discrepancy.
Conclusions and Recommendations
9. The second sentence of the second paragraph of this section states that
"pentachlorophenol is below the MCL in all wells except C-l lB, C-29B and PW-I ..
. " However, the laboratory documentation included in Appendix B indicates that the
groundwater sample obtained from groundwater monitoring well C-14B contained 20
µg/1 pentachlorophenol. Please clarify this discrepancy.
10. The second to last sentence of this section should state " ... Beazer will re-evaluate
the groundwater monitoring program ... " Please correct this oversight.
Table 1 Summary of Groundwater Elevations -October 21, 1997
11. Table 1 indicates that the depth to groundwater was not measured for groundwater
pumping well PW-1 and groundwater monitoring wells C-18C, C-21C, C-23C, C-24C
and M-9. Please provide justification for not collecting depth to groundwater
measurements at these wells.
Table 2 Summary of Groundwater Elevations -January 21, 1998
12. Table 2 indicates that the depth to groundwater was not measured for groundwater
monitoring wells C-18C, C-21C, C-23C, C-24C and M-9. Please provide justification
for not collecting depth to groundwater measurements at these groundwater monitoring
wells.
Ms. Beverly Hudson
August 27, I 998
Page 3
• •
Table 3 Summary of Field Purging and Sampling Parameters
13. Table 3 indicates that well depth for groundwater monitoring well C-14B is 65.33 feet
(ft). However, the Field Data Sheet for Groundwater Sampling included in Appendix
A indicates that the well depth for C-14B is 65.93 ft. Please clarify this discrepancy.
14. Table 3 indicates that the depth to water before purging for groundwater monitoring
well C-27B is 36.95 ft. However, the Field Data Sheet for Groundwater Sampling
included in Appendix A indicates that the depth to water before purging for C-27B is
34.95 ft. Please clarify this discrepancy.
15. Table 3 indicates that the sample date for groundwater monitoring well C-27B is
January 22, 1998. However, the Field Data Sheet for Groundwater Sampling included
in Appendix A indicates that the sampling date for C-27B is January 23, 1998. Please
clarify this discrepancy.
16. Table 3 indicates in the section entitled, Comments, that the groundwater sample for
groundwater monitoring well C-llB was clear and had an odor. However, the Field
Data Sheet for Groundwater Sampling included in Appendix A that the groundwater
sample for C-llB was cloudy. Please clarify this discrepancy.
17. Table 3 indicates in the section entitled, Comments, that the groundwater sample for
groundwater pumping well PW-I was clear. However, the Field Data Sheet for.
Groundwater Sampling included in Appendix A that the groundwater sample for PW-1
was clear and had an odor. Please clarify this discrepancy.
Table 4 Summary of Groundwater Analytical Results for Constituents of Interest
18. Table 4 indicates that the groundwater sample obtained from groundwater monitoring
well C-14B contained no detectable concentrations of pentachlorophenol at a laboratory
quantitation limit of 1 µg/1. However, the laboratory documentation included in
Appendix B indicates that the groundwater sample obtained from groundwater
monitoring well C-14B contained 20 µg/1 pentachlorophenol. Please clarify this
discrepancy.
• •
Ms. Beverly Hudson
August 27, 1998
Page 4
Table 8 Summary of Historical Groundwater Quality Data for Constituents of
Interest
19. Table 8 indicates that the groundwater sample obtained from groundwater monitoring
well C-14B in January 1998 contained no detectable concentrations of
pentachlorophenol at a laboratory quantitation limit of I µg/1. However, the laboratory
documentation included in Appendix B indicates that the groundwater sample obtained
from groundwater monitoring well C-14B in January 1998 contained 20 µ.g/1
pentachlorophenol. Please clarify this discrepancy.
Figure 1 On-Site and Near Off-Site Monitoring Well Locations
20. Figure 1 does not indicate the location of groundwater monitoring wells C-16C, C-
17C, C-18C, C-19C, C-20C, C-21C, C-22C, C-23C, C-24C, and C-32C. Please
revise Figure 1 or include an additional figure to depict the locations of all groundwater
monitoring wells.
Figure 2 Groundwater Elevation Contours, Shallow Wells -October 21, 1997
21. Figure 2 does not indicate the location or groundwater elevation of groundwater
monitoring well C-30A. Please revise Figure 2 to depict the location of groundwater
monitoring well C-30A.
Figure 3 Groundwater Elevation Contours, Shallow Wells -January 21, 1998
22. Figure 3 indicates that the groundwater elevation for groundwater monitoring well C-
SA is 348.92 ft, mean sea level (ms!). However, Table 2 indicates that the
groundwater elevation for C-8A is 348.52 ft, ms!. Please clarify this discrepancy.
23. Figure 3 does not indicate the location or groundwater elevation of groundwater
monitoring well C-30A. Please revise Figure 3 to depict the location of groundwater
monitoring well C-30A.
• •
Ms. Beverly Hudson
August 27, 1998
Page 5
Figure 4 Groundwater Elevation Contours, Intermediate/Deep Wells -October 21,
1997
24. Figure 4 does not indicate the location or groundwater elevation of groundwater
monitoring wells C-lB, C-9C, C-12C, C-17C, C-19C, C-20C, C-22C, C-33C or C-
34C. Please revise Figure 4 or include an additional figure to depict this data.
Additionally, please provide justification for the inclusion of groundwater elevation
data for one groundwater monitoring well over another in those instances in which
groundwater monitoring well clusters have been installed.
25. Groundwater monitoring well C-30A was inadvertently included in Figure 4. Please
remove C-30A from Figure 4 and place in Figure 2.
Figure 5 Groundwater Elevation Contours, Intermediate/Deep Wells -January 21,
1998
26. Figure 5 does not indicate the location or groundwater elevation of groundwater
monitoring wells C-lB, C-9C, C-12C, C-17C, C-19C, C-20C, C-22C, C-33C or C-
34C. Please revise Figure 5 or include an additional figure to depict this data.
Additionally, please provide justification for the inclusion of groundwater elevation
data for one groundwater monitoring well over another in those instances in which
groundwater monitoring well clusters have been installed.
27. Groundwater monitoring well C-30A was inadvertently included in Figure 5. Please
remove C-30A from Figure 5 and place in Figure 3.
Figure 6 Pentachlorophenol Concentrations -January 21, 1998
28. Please provide arrows to indicate which groundwater monitoring wells are associated
with the corresponding pentachlorophenol concentrations.
29. Figure 6 indicates that the groundwater sample obtained from groundwater monitoring
well C-14B contained no detectable concentrations of pentachlorophenol at a laboratory
quantitation limit of 1 µg/1. However, the laboratory documentation included in
Appendix B indicates that the groundwater sample obtained from groundwater
monitoring well C-14B contained 20 µg/1 pentachlorophenol. Please clarify this
discrepancy.
Ms. Beverly Hudson
August 27, 1998
Page 6
• •
Appendix A Field Data Sheets and Chain-of-Custody Fonns
30. The copy of the field log book pages that include depth to water measurements for the
nine-month remedial action monitoring event conducted on October 21, 1997 were
inadvertently omitted. Please correct this oversight.
31. The copy of the field log book page that contains the depth to water measurements for
the one-year remedial action monitoring event conducted on January 21, 1998 indicates
that multiple depth to water measurements were made for groundwater monitoring
wells C-llB, C-13A, C-13B, C-14A, C-14B, C-15B, C-27A, C-27B, C-28A, C-28B,
C-29B, PW-I and M-4. Please provide the rational used in collecting this data, a
discussion of the accuracy and precision of the data collection for all of the depth to
water measurements, and the rational used in determining which data is included in
Table 2. Please amend the appropriate sections of this report to include this
information.
32. The Field Data Sheets for Groundwater Sampling are incomplete. The Field Data
Sheets should include the date and start time for purging activities, the estimated water
volume required for purging as well as the pH, specific conductivity and temperature
measurements collected prior to purging and immediately following the purging of each
well volume purged. A portion of this information has been included in Table 3.
However, please provide copies of the field log book which document the groundwater
sampling activities and the collection of this data.
Appendix C Pentachlorophenol and 2,4-Dichlorophenol Time Trends
33. The graph ofpentachlorophenol time trends for groundwater monitoring well C-14B
indicates that the groundwater sample obtained from groundwater monitoring well C-
14B during the January 1998 sampling event contained no detectable concentrations of
pentachlorophenol at a laboratory quantitation limit of 1 µg/1. However, the laboratory
documentation included in Appendix B indicates that the groundwater sample obtained
from groundwater monitoring well C-14B during the January 1998 sampling event
contained 20 µg/1 pentachlorophenol. Please clarify this discrepancy.
L • •
BEAZER EAST, INC, ONE OXFOIU) CENTRE, SUITE 3000, PITTSBURGH, PA 15219-6401
R
June 4, I 998
Beverly Hudson
Remedial Project Manager
United States Environmental Protection Agency -Region IV
Atlanta Federal Center
JUN O 5 1998
SUPERFUNu ;:itCTION
61 Forsyth Street, SW
Atlanta, Georgia 30303-8909
Re: One-Year Groundwater Monitoring Report
Former Koppers Company, Inc. Site
Morrisville, North Carolina
Dear Ms. Hudson:
Please find enclosed four copies of the One-Year Groundwater Remedial Action Monitoring
Report (Report) for the Former Koppers Company, Inc. site located in Morrisville, North
Carolina. Fluor Daniel GT!, Inc. prepared this report on behalf of Beazer East, Inc. (Beazer) in
accordance with the requirements of the Unilateral Administrative Order (USEP A Docket 93-
09C) and the USEPA-approved Remedial Action Work Plan prepared pursuant thereto.
The enclosed Report provides a summary of the groundwater monitoring program activities, and
the corresponding findings, conducted from April I 997 through February I 998. Based on the
results and conclusions of these monitoring activities, and in accordance with the USEP A-
approved Operations & Maintenance Plan, Beazer will re-evaluate the groundwater monitoring
program and propose a recommended future operation and monitoring plan for the groundwater
extraction system.
Beazer's recommended future operation and monitoring plan will be submitted by July 20, 1998.
If you should have any questions or require additional information, please contact me at (412)
208-8867 or Ms. Mary Anna Babish with Fluor Daniel GT!, Inc. at ( 412) 823-5300.
s:;;:el' f /1 /; ' :11(2'!:f~;l,,/L-----
Michael Slenska, P E
Environmental Manager
Enclosure
cc: Dave Mattison, NCDEH (2 copies)
Mary Anna Babish, FOGT! (w/o enclosure)