NCD122263825_19960709_JFD Electronics - Channel Master_FRBCERCLA RD_Remedial Design 1994 - 1996-OCR

I )la,GERAGHTY
Al"& l\1ILLER, INC.
JI/If Environmental Services
•
Mr. McKenzie Mallary
Remedial Project Manager
USEP A Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
•
a heidemij company
July 9, 1996
RECEl\fF.,3
JUL 12 1996
SUPERFUND SECTION.
Re: JFD Electronics/Channel Master NPL Site: Release of Investigative Derived Wastes
(IDW)
Dear Mr. Mallary:
As we discussed this morning, I have notified the National Response Center (NRC)
concerning the release on July 4, 1996 of approximately 400 gallons of water containing 220 ppb
acetone and 7 ppb chloromethane. The NRC recorded this as event No. 351-003 and notified
USEP A Region IV.
The circumstances of the release are as follows. Drums of IDW liquids were emptied into
a 2,500 gallon polytank on Wednesday, July 3, 1996. Apparently, the tank valve was damaged in
a way that was not readily apparent and did not fully close. The water steadily dripped out of the
tank over a period of 40 to 45 hours onto the ground. The change in water level in the tank was
observed Friday morning, the tank contents removed and the valve replaced. The release
occurred at a location well within the perimeter of the plume of groundwater contamination near
the former lagoon. No release to surface water occurred. Any impacts to groundwater quality
will be addressed with the pump and treat remedial system currently in final design. The State of
North Carolina Groundwater Standard for acetone is 700 ppb. There is no groundwater standard
for chloromethane. Impacts to soil at the point of release are believed to be negligible. The
USEPA Region III health-based soil screen levels for acetone and chloromethane are 7,800,000
ppb and 50 ppb, respectively, well above the concentrations detected in the IDW water.
While the origin of the IDW liquid is not clear, the chemical composition indicates it was
likely decontamination water due to the presence of acetone, a breakdown product of the
isopropyl alcohol used in the 7 step decon process. The acetone had been reported in an
equipment rinsate blank. The source of the chloromethane, a potential human carcinogen, is not
known but could be a breakdown product of chloroform (trichloromethane) which is likely
present in the City of Oxford's water system as a result of disinfection. Neither constituent has
been reported in groundwater at the site.
srd g:\aprojcct\jfdchann\nc0202.002~\mallary3.doc\9-Jul-96 .n.. Crossl'ointe II, 2840 Plaza Place, Suite 350 • Raleigh, North Carolina Z76l2 • [phone] • FAX [phone] .,.,
GERAGHTY & MILLER, IN~ • Mr. McKenzie Mallary
July 9, 1996
Page2
It was agreed to report this release to the NRC as a conservative measure. The need to
report was questionable due to the small concentrations. It was also agreed that no specific
corrective measures for site environmental media other than the measures currently under design
would be needed for this release.
/srd
Enclosure( s)
cc: David Lown, NCDEHNR
Brian Kempner, Unimax Corporation
Lisa Palumbo, Avnet, Inc.
Mark Radecke, Geraghty & Miller
Merle Baldwin, Envirochem
srd g:\aproject~fdchann\nc0202. 002\co!Tcs:pol.rnalla,y 3.doc\9-Iul-96
Respectfully,
William H. Doucette, Jr., Ph.D.
Associate and Coordinator for the
Responsible Parties
State of North cJllina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
• MA , --~ n n m ,0 w;1as James B. Hunt, Jr., Governor March 8, 1996
Jonathan B. Howes, Secretary DEHNR
William L. Meyer, Director
Mr. McKenzie Mallary
Remedial Project Manager
North Superfund Remedial Branch
US EPA Region IV
345 Courtland Street, NE _
Atlanta, Georgia 30365
Subject: Comments on Pre-Final Design Report
Groundwater Remediation
JFD Electronics/Channel Master Superfund Site
Oxford, Granville County
Dear Mr. Mallary:
The North Carolina Superfund Section has received and reviewed this document and
offers the following comments.
I) Page 2.3, paragraph 4 and page 2 of Table 2-3. NCAC !SA: 2D.1104 states that a
facility shall not emit any of the toxic air pollutants listed in the rule in such
quantities that may cause or contribute beyond the premises to any significant
ambient air concentration that may adversely affect human health. The report states
that based on modeling results using SCREEN2, the estimated ambient air
concentrations for trichloroethylene, tetrachloroethylene, and vinyl chloride are less
than the acceptable ambient levels. Modeling results must be confirmed with air
monitoring aft"!r the facility is in operation.
2) Page 3.2, paragraph I. The first sentence of this paragraph is in error. The level of
cyanide in the groundwater is above the remedial action level. On page 4.1 of the
Pre-Final Design Report, it states that cyanide (total) was detected in well CMMW04
at 354 ug/1. NCAC I SA: 2L.0202(g) states, "the standard refers to the total
concentration ... of any constituent in a dissolved, colloidal or particulate form which
is mobile in groundwater." The standard for cyanide is 154 ug/1.
3) Page 3.2, paragraph 5. This paragraph discusses an off-site plume. The presence of
an off-site plume has not been proved. References to an off-site plume should be
removed from the report.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1 ~ post-consumer paper
• •
Mr. McKenzie Mallary
March 8, I 996
Page 2
4) Page 3.3, paragraph I. The remedial action level for cyanide is 154 ug/1 total
cyanide. This level is exceeded in the groundwater at the site.
5) Page 3.2, paragraph 5. The presence of a plume emanating from the abandoned drum
area has not been confirmed. The relationship of the ratio to plumes has not been
established. While we acknowledge the possibility of a plume source in this area, the
.. _ existenc_e of a secon_d_plume _h~~ not be pr()ved. J~e_ft:r_ellce to _ii!! _off-site_ph1111(: _s~ould __
be removed from the report.
6) Page 5-6 Section 5.2.3 Groundwater Treatment System. Paragraph I and Table 5-2.
Proposed groundwater effluent VOCs concentrations are listed. The levels
permissible in the effluent will be determined by the Water Quality Section under the
NPDES requirements.
7) Page 5-6 Section 5.2.3 Groundwater Treatment System. Paragraph 2. In addition to
influent concentrations, ambient air concentrations must be monitored to determine if
off-gas treatment must be re-evaluated.
8) Page 5-7. P,.,.,graph 3. The last sentence contains a typogrn,!i.ical error.
9) Page 5-9, paragraph I. Estimated ambient air concentrations for trichloroethylene,
tetrachloroethylene, and vinyl chloride must be confirmed by air monitoring after the
process is in operation.
10) Page 5-9, paragraph 3. It is stated in this paragraph that even if all the estimated
cyanide (12 ug/1) is in the form of hydrogen cyanide and volatilized in the air stripper,
the resulting ambient air concentrations will be insignificant. Provide assumptions
and calculations supporting this statement.
11) Page 7.1 Section 7.1 Groundwater Quality Monitoring Program. Report states that
wells will be sampled quarterly the first year and annually thereafter. The wells
should continue to be monitored quarterly after the first year. Annual sampling may
not be frequent enough to monitor changes in groundwater quality. After a few years
of data have been collected and analyzed, the frequency may be reduce.
12) Page 7.1. Section 7.2 Groundwater Recovery and Treatment System. Water levels
in monitoring and recovery wells should be measured quarterly after the first year
instead of an :m,lly as proposed. Recovery wells should be sampled quarterly after
the first year not annually as proposed. Combined influent to the air stripper should
be sampled quarterly after the first year and not semi-annually as proposed. The
frequency of sampling and measuring may be re-evaluated in the future.
Mr. McKenzie Mallary
March 8, 1996
Page 3
• •
APPENDIX H DRAFT PERFORMANCE STANDARD VERIFICATION PLAN
13) Page 2.3 last paragraph. Water-level measurements should include monitoring well
CMMW-26.
14). _P_age ;2.4 third bull_eted item. Water-level measurements should be done quarterly
after the first year of operation.
15) Page 2.5 last paragraph. Cyanide analyses should be for total not amenable cyanide.
I 6) Page 2. 7 paragraph 2. Reference to an off-site plume should be removed from the
text.
17) Page 2.8 paragraph 2. Field parameters measured should include turbidity.
18) Page 2.10 item 7. Field filtering of groundwater samples are not acceptable unless the
results of unfiltered samples are also determined and presented with the filtered result.
Laboratory filtering using method 3030C as specified in the NO groundwater
guidance document is allowable.
19) Page 2. 7 third bulleted item. Groundwater quality sampling should be done
quarterly.
Thank you for the opportunity to comment on this document. If you have any questions,
please contact me at [phone], extension 349.
cc: Grover Nicholson
David J. Lown
Environmental Engineer
Superfund Section
' I State of North Ca.no
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt. Jr., Governor
Jonathan B. Howes. Secretary
William L. Meyer. Director
Mr. McKenzie Mallary
Remedial Project Manager
North Superfund Remedial Branch
US EPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
November 13, 1995
Subject: Division of Environmental Management (DEM)
Comments on the Preliminary Remedial Design Report
JFD Electronics/Channel Master Superfund Site
Oxford, Granville County, North Carolina
Dear Mr. Mallary:
COP\
Attached are comments made by the North Carolina DEM on the Preliminary Remedial
Design for this site. Please call me at [phone], extension 349 if you have any
questions or comments.
Attachment
cc: Jack Butler
Sincerely~--
Qc~~-~~~--
David J. Lown
Environmental Engineer
Superfund Section
P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l a=t post-consumer paper
., ' .,• ..
,-... ' 'i . State of North cc:a1na
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
October 18, 1995
MEMO RANUM
RECEIVED
NOV O 9 1995
SUPERFUND SECTION TO: David Lown
Superfund Section
FROM: A. Preston Howard, Jr., .. 71.,,
SUBJECT: JFD Electronics/Channel
Remedial Design Report
Granville County
Project 1!95-30
The Division of Environmental
review of the subject document and
and recommendations,
Air Quality Section
No comments at this time.
Water Quality Section
Master Site
Management has completed the
offers the following comments
We are concerned that the influent cyanide concentration are
estimated at 12 ug/1, which exceeds the stream standard of 5
ug/1, yet no treatment is proposed. The proposal is to
monitor the cyanide and, if the concentration exceeds 5
ug/1, to dispose of that water by trucking it to a disposal
facility. This is not an appropriate treatment method. We
recommend the system be designed to adequately treat the
groundwater to stream standards prior to discharge, This
treatment is economically justified due to the presence of
the cyanide at levels above the stream standard.
Groundwater Section
we recommend that monitoring well CMMW2 be included with the
regular monitoring schedule. Also, the recovery wells
should remain in operation until analyses from at least four
(4) consecutive sampling events indicate that contaminants
in the groundwater are at/or below the 15A NCAC 2L
standards.
P.O. Box 29535. Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
' • •
If you have any questions, please advise.
APHjr/sbp/JFDSWM.
cc: Arthur Mouberry
Alan Klimek
Steve Tedder
Raleigh Regional Office
Central Files
Groundwater Section Files
I'
. ~.,-GERAGHTY •
"Alli"& MILLER, INC. 1111/ Em-iron mental Services
Mr. McKenzie Mallary
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA 30365
•
a heidemij company
HECEIVED
October 25, 1995
NOV 141995
SUPERFUND SECTION
Re: JFD Electronics/Channel Master NPL Site Off-Site Residential Wells
Dear Ken:
Geraghty & Miller completed a survey of private residence wells in September, as
summarized in the attached Technical Memorandum. One downgradient resident, Dr. C.B. Finch
at 503 Lewis Street (NC Highway I 5), was found to have a private well used for drinking water.
The remaining downgradient residences were no longer using well water. Owners or residents at
three houses reported their well water to be contaminated from nearby sources unrelated to the
JFD Electronics/Channel Master site.
Based·on.this survey, Geraghty & Miller will sample water at the Finch residence. As
indicated by,reports from neighbors, a hydrocarbon release from a gas station may be impacting
groundwater in the vicinity. Results from the Finch well must be carefully evaluated, considering
the poiential for other sources unrelated to the JFD Electronics/Channel Master NPL site. The
well sampling is scheduled for this Friday, October 27, I 995. Analysis and reporting will take
approximately six weeks following "CLP" analysis and data validation requirements.
WHD~bw
Enclosure
cc: . · ·,Brian Kempner, Unimax
Lisa Palumbo, AVNET ,
~David Lown, NCDEHNR
Nanjun Shetty, Geraghty & Miller
Respectfully,
GERAGHTY & MILLER, INC.
J~:!~.~G.
Associate
.#\ ~. 2840 Plaza Place, Suite 350 • Raleigh, Nonh Carolina Z7612 • [phone] • FAX [phone] ••
• • ,. --------------------------Ar-
MEMORANDUM AIV
TO: Leonard Moretz and Bill Doucette (G&M, Raleigh)
FROM: Hennen Cummings (G&M, Raleigh)
DATE: October 20, 1995
SUBJECT: Well Survey for JFD Electronics/Channel Master Superfund Site
A well survey was conducted by Geraghty & Miller Inc. on Wednesday, September 13,
1995 in the vicinity of the intersection of Highway 15 (Lewis Street) and Industrial Drive to
identify water-supply wells. Residents were asked if their drinking water was supplied by the city.
If the resident indicated that well water was provided by a private well, as much information
about status of the well was recovered. Residents also were asked if the property ever had a well
and what the status of that well was. The following residents were contacted during of the
survey. The location of each residence is indicated on the attached figure by the corresponding
reference number.
Reference Number 1
Dr. C.B. Finch
503 Lewis Street (Highway 15)
[phone]
Drinking water supplied by private well.
Remarks: Well in 152 feet deep, last 80 feet is in solid granite. Pump replaced twice in the
last 3 8 years of service. House is in the county while front yard is in the City of
Oxford.
Reference Number 2
Mrs. James Knott
425 Lewis Street (Highway 15)
[phone]
Drinking water supplied by Sole City instead of Oxford.
Remarks: The house had a well before it was removed completely 2 years ago. Mrs. Knott
stated that the house across the street, which is a day care facility, has city water
supplied by Oxford. Mrs. Knott stated that a gas station used be across the street
and to the left. The property is now a Chinese restaurant. Mrs. Knott stated that
a:'~tjtjfl I t\nc020'1.0JC'.Nrub\wdsffla.doc
Pagel of3
GERAGHTY & MJLLER, INC.
• • ~~ ---------------------------Ar~ .,.
her house was one of the older houses in the immediate vicinity and that the newer
houses were on City water. She stated that there are two monitoring wells on her
property and that the groundwater had been contaminated by the former gas
station. Mrs. Knott drinks only bottled water.
Reference Number 3
Helen Hocket
422 Lewis Street (Highway 15)
[phone]
Drinking water supplied by city.
Remarks: The house once had a well, but it has not been used in years, and it could not be
used in the future. Helen Hocket was not available during the survey, but a man
who lived there stated that the water is contaminated, and the likely source of the
contamination is a former garage for fanning equipment. The garage is between
this property and the Hightower property.
Reference Number 4
W.B. Brooks
708 Lewis Street (Highway 15)
Drinking water supplied by private well.
Remarks: Well may be 40 feet deep. This house is near the Shell station at the intersection
of Highway I 5 (Lewis Street) and Industrial Drive.
Reference Number 5
Katherine Latta
712 Lewis Street (Highway 15)
Drinking water supplied by private well.
Remarks: None
Reference Number 6
Brooks
709 Lewis Street (Highway 15)
Drinking water supplied by city.
Page 2 of3
GERAGHTY & MILLER. INC.
•
Remarks: None
Reference Number 7
James Brooks
706 Lewis Street (Highway 15)
Drinking water supplied by private well.
Remarks: None
Reference Number 8
James Brooks
704 Lewis Street (Highway 15)
Drinking water supplied by private well.
Remarks: None
Reference Number 9
Blue trailer further up Lewis Street (Highway 15).
Drinking water supplied by private well.
Reference Number 10
•
The house is not inhabited. The owner's son, Bennett Hightower, has stated previously that the
former garage for farming equipment had contaminated the on-site well, and it is not is use.
Water is supplied by the City of Oxford. During the survey, the former garage was noted to be on
a ridge. Being on a ridge allows the former garage to impact wells on either side.
Page 3 of3
a.\ap MP I uol..c020'lmcfo\wn:bcna.doc
GERAGHTY & MILLER, INC.
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..A9'GERAGHTY • · A-'& MILLER, INC. ,11,11//1, Environmental Services
Ground Water
DATE: October 25. 1995
FROM: BIT 1 · DOUCETTE
TO: (Include Name and Company)
KENMALLARY
USEPA REGION IV
Pages To Follow: 5
.Message:
•
Hydrocarbon Remediation Education
Fax Number: <404) 347-1695
Charge To: -"-01..,2,.,,02""'02""'-------
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TRANSMISSION REPORT
---. ---
,i04-347----
................................................................... ' .... ' .......................... .
CrossPointe II, 2840 Plaza Place, Suite 350· Raleigh, North Carolina 27612 · [phone] · [phone]
State of North calina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
October 18, 1995
MEMORANUM
RECEIVED
NOV O 9 1995
SUPERFUND SECTION TO: David Lown
Superfund Section
FROM: A. Preston Howard, Jr.,
'?tr-
SUBJECT: JFD Electronics/Channel
Remedial Design Report
Granville County
Project 1195-30
Master Site
The Division of Environmental Management has completed the
review of the subject document and offers the following comments
and recommendations.
Air Quality Section
No comments at this time.
water Quality Section
We are concerned that the influent cyanide concentration are
estimated at 12 ug/1, which exceeds the stream standard of 5
ug/1, yet no treatment is proposed. The proposal is to
monitor the cyanide and, if the concentration exceeds 5
ug/1, to dispose of that water by trucking it to a disposal
facility. This is not an appropriate treatment method. We
recommend the system be designed to adequately treat the
groundwater to stream standards prior to discharge. This
treatment is economically justified due to the presence of
the cyanide at levels above the stream standard.
Groundwater Section
We recommend that monitoring well CMMW2 be included with the
regular monitoring schedule. Also, the recovery wells
should remain in operation until analyses from at least four
(4) consecutive sampling events indicate that contaminants
in the groundwater are at/or below the 15A NCAC 2L
standards.
P.O. Box 29535. Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50'l. recycled/ l 0% post-consumer paper
• •
If you have any questions, please advise.
APHjr/sbp/JFDSWM.
cc: Arthur Mouberry
Alan Klimek
Steve Tedder
Raleigh Regional Office
Central Files
Groundwater Section Files
,41.,GERAGHTY
A.,-& MILLER, INC.
,., Environmental Services
•
Mr. McKenzie Mallary
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA 30365
•
RECEIVED
OCT 121995
SUPERFUND SECTIO~!
a heidemij company
October 9, 1995
Re: JFD Electronics/Channel Master NPL Site
Dear Ken:
We are currently scheduled to provide the prefinal design on October 24, 1995.
This schedule is no longer possible. Several key aspects of the prefinal design require
USEPA approval of the preliminary design submitted in July. We have performed those
aspects of the prefinal design which can be performed without concern for "redesigning"
should EPA not approve the preliminary design. We are very concerned about the cost of
having to redo any work. For this reason we are essentially ceasing work until the
preliminary design is described. We will immediately start work after approval and expect
to take 3 to 4 weeks to provide a submittal depending upon the nature of any changes in
the design, if any.
WHD/mmj
cc: Brian Kempner, Unimax
Lisa Palumbo, AVNET
David Lown, NCDEHNR
Douglas Adair, Bechtel
Nanjun Shelty, G&M
Respectfully,
GERAGHfY & MILLER, INC.
w~~ff -~~uA(
William H. Doucette, Jr., Ph.D.
Associate and Project Coordinator
for the Responsible Parties
Crossl'ointe II, 2840 Plaza Place, Suite 350 • Raleigh, North Carolina 27612 • [phone] • FAX [phone] U
~8'GERAGHTY
Al'cl MILLER, INC.
., Enriro11111ental Serrices
• RECEl~D
OCT 16 1995
A Heidemij company
Mr. McKenzie Mallary
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA 30365
SUPERFUND SECTIO~I
October 5, 1995
RE: Revised Recovery Well PW-4 Location, JFD Electronics/Channel Master NPL Site
Dear Ken:
As we discussed in our letter on September 13, 1995, Oak Ridge Housing Development
has denied access to install the recovery well PW-4 on their property. Therefore, PW-4 is
proposed to be relocated on Southgate Associates' property. Figure 1 presents the proposed
location of PW-4. This scenario was re-modeled using MODFLOW to estimate the recovery
well capture zones. The revised capture zones of the proposed recovery wells presented in
Figure l, demonstrate that the plume will essentially be captured. This scenario will be used
to develop the pre-final design.
If you have any questions, please contact me at [phone].
/smp
Enclosure
Sincerely,
GERAGHTY & MILLER, INC.
\.Jj_L._+t.~
William H. Doucette, Ph.D., P.G.
Associate/Project Officer
cc: Brian.Kempner, The Unimax Corporation
Lisa Palumbo, AVNET, Inc.
Greg Rorech, Geraghty & Miller
Nanjun Shetty, Geraghty & Miller
David Lown, DEHNR
Douglas Adair, Betchel
CrossPointe II. 2840 Plaza Place. Suite 350 • Raleigh. !\onh Carolina 2761c • (919) Sil-1662 • FAX [phone] y
owe OAT[: 27SEP95 PR.JCT NO.: NC0202.080 FlLE NO.: CHANNEL 0RA'lr1NG: SI TE2-I 2 CHECKED: N. SHETTY APPROVED: L MORETZ
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4" Environmental SenJices
JFD ELECTRONICS/CHANNEL MASTER
OXFORD, NORTH CAROLINA
DRAFTER: A. WARREN
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-
•
•
State of North calna
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt. Jr .. Governor
Jonathan B. Howes. Secretary
William L. Meyer. Director
Mr. McKenzie Mallary
Remedial Project Manager
North Superfund Remedial Branch
US EPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
August 2, 1995
• •
RA
DEHNR
COPY
Subject: Comments on Predesign Data Acquisition Report-June 1995
and the Preliminary Design Report-July 1995
JFD Electronics/Channel Master Superfund Site
Oxford, Granville County, North Carolina
Dear Mr. Mallary:
The North Carolina Superfund Section has received and reviewed these documents.
The following are general comments about the Predesign Report.
The TCE and PCE detected near the drum dump is probably from the source at the
Channel Master Main Building. The high TCE/PCE ratio is characteristic of the groundwater
contamination in source area; however, lower concentrations away from the main source area do
not have a similar ratio. (See the analytical results for CMMWI I and CMMW26.) The change
in the ratio does not prove another source area. If the drum dump is a source for TCE and PCE,
the lower levels found in monitoring well CMMW20 suggest that it is minor compared to the
contamination from the Channel Master Main Building.
Based on an interpretation of pumping test data, the saprolite zone is believed to have
higher hydraulic conductivity than the weathered bedrock and the bedrock zones. This is
contrary to most published descriptions of Piedmont groundwater hydrology and to other
observations from the site (lithologic descriptions and slug test results). Different hydraulic
P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
• •
Mr. McKenzie Mallary
August 2, I 995
Page 2
scenarios should be investigated using MODFLOW simulation to find the possible impact on the
recovery system design.
The following are specific comments on the Predesign Report:
2)
3)
4)
5)
6)
7)
Page 2-2, last paragraph and page 2-3, first paragraph refer to a clay layer in the
upper IO feet of the water table and state that the residual soil coarsens downward.
These factors eased the collection of groundwater samples with depth. The
observations contradict the interpretation (higher permeabilities in the saprolite
zone and lower permeabilities with depth) made based on the pump test data.
Page 3-9. The lineament analysis shows that a major orientation is N 00°-09°,
not randomly oriented as said in the last sentence of paragraph 2. During the
pump test"no observation wells were located to the south or north of the pumping
well to test this observation.
Page 4-3, paragraph 3. Contrary to stated here, sh;illow well/deep well pairs
CMMW14/15 and CMMWI 1/12 show higher concentrations ofVOCs at depth.
This suggests that permeability increases with depth.
Page 4-5, last paragraph. The North Carolina 2L groundwater standard for
cyanide is 154 µg/1, based on total concentration, not amenable cyanide.
Page 4-7, paragraph I. The drum dump may be a source of PCE and TCE, but
this has not been confirmed. The soil sample collected from the drum dump did
not contain these compounds. The concentrations of PCE and TCE are not
decreasing away from the drum dump; the water from the well closest to the
drum dump, CMMW20, contains only 323 µg/1 total VOCs. The concentrations
increase to the north (1,109 µg/1 total VOCs in TW-24), in the direction of the
Channel Master plume.
Page 4-9, paragraph 2. The ratio ofTCE to PCE in well CMMW26 (9J/51) is
similar to the ratio in CMMWI I (52/110). The decrease in the TCE/PCE ratio
may not be the result of differing sources, but may depend on the different
physiochemical properties of these compounds, timing of releases, or the
heterogeneity of the site geology.
Page 4-9, paragraph 3 and page 4-11, last paragraph. The concentrations ofTCE
and PCE at this location (260 µg/1 and 31 µg/1 respectively) are also compatible
with the known source at the Channel Master building.
• •
Mr. McKenzie Mallary
August 2, 1995
Page 3
8) Page 4-9, last paragraph. The groundwater sample from CMMW26 was filtered.
Sample filtration in the field is not permitted by the NC Division of
Environmental Management for any analyses being used to determine compliance
to NC.groundwater regulations. For metal analysis, the Standard Method 3030C,
Preliminary Treatment for Acid Extractable Metals is the only accepted method
for rrietals analysis.
8) Page 4-14, paragraph I. Whatever the source of the metals (background or
contamination) any treatment effluent must meet the substantive requirements of
an NPDES permit.
9) Page 6-1, Conclusions:
A) Dissolved metals are not present in the groundwater at concentrations
above the remedial action levels specified in the ROD: Previously
detected metals in the groundwater were likely the result of turbid and/or
grout contaminated samples.
Comment: As stated in Comment #8, whatever the source of the metals,
any treatment effluent should meet the substantive requirements of an
NPDES permit.
B) The horizontal extent of the VOCs has generally been defined as shown in
Figure 4-5 ...
Comment: The horizontal extent has not been defined in the direction of
CMMW26, between CMMWI l and CMMW20, and is not defined to the
south if the drum dump is not a source for TCE and PCE.
C) ... The concentrations decrease vertically downward ...
Comment: As indicated in Comment #3 above, contaminant levels
increase downward in monitoring well pairs CMMWl4/l5 and
CMMW!l/12.
D) VOCs were detected above established action levels in the bedrock
zone . . . The bedrock has low hydraulic conductivity and few
fractures ...
Comment: The nature and density of fractures beneath the site have not
been characterized.
t' • •
Mr. McKenzie Mallary
August 2, I 995
Page 4
E) The site's VOC plume is characterized by a high TCE to PCE ratio ...
Comment: The decrease in the TCE/PCE ratio may not be the result of
differing sources, but may depend on the different physiochemical
properties ofTCE and PCE (Comment #6).
The drum dump may be a source ofTCE and PCE, however, until another
source is confirmed, the contamination from the Channel Master Main
Building is the most likely source for TCE and PCE in the area.
F) ... Hydraulic conductivity was highest in the saprolite at I 0. 7 ft/day and
lowest in the weathered rock zone at 2.45 ft/day. Bedrock showed a
hydraulic conductivity of less than 0.1 ft/day.
Comment: The hydraulic conductivities determined in the pump test are
not consistent with observations from the site. Based data from Table 3-2
the geometric mean of the weathered rock,zone is 2.26 ft/day and the
geometric mean for saprolite is 1.20 ft/day. The hydraulic conductivity for
the saprolite zone may be overestimated by an order of magnitude.
The hydraulic conductivity estimated for the bedrock is appropriate
lacking fractures; however, unless the geology of the Channel Master site
is different from the rest of the Piedmont, the bedrock under the site is
fractured.
The following specific comments are on the Preliminary Design Report:
I) Page 2-1, last paragraph. While an NPDES permit is not required, the substantive
requirements of a permit must be met.
2) Page 2-4, paragraph 6. The ROD requires the installation of a control device for the
vapor emissions. Any deviation from this requirement will require notification of
the public and concurrence by the state ofNorth Carolina.
3) Page 3-2 SUMMARY OF PREDESIGN GROUNDWATER QUALITY
INVESTIGATIONS RESULTS. The conclusions of the Predesign Report were
discussed above .
. 4) Page 4-2, paragraph 2. Unless low-flow purging techniques are used for recovery
pumps, metals precipitation/filtration may be necessary before effluent is discharged.
Discharged effluent will meet the requirements of an NPDES permit.
• •
Mr. McKenzie Mallary
August 2, 1995
Page 5
5) Page 5-1, last paragraph. Step-drawdown tests should be used to determine the best
pumping rate for each recovery wells. Based on the step-drawdown test results, the
recovery system should be simulated with MODFLOW to test capture zone.
6) Page 5-6, paragraph 3. If discharged to a stream, VOC concentrations must comply
with the requirements of an NPDES permit.
7) Page 5-7 Effluent Discharge. For compounds not listed in NCAC Title 15A,
Section 2B.021 l, the NCDEM uses 40 CFR Part 131 EPA's Section 304 (a) Criteria
for Priority Toxic_ Pollutants.
8) Page 8-1 GROUNDWATER QUALITY MONITORING PROGRAM. Add the
following wells to the list of proposed monitoring wells: CMMW26, CMMW15,
andCMMW20.
9) Page 8-2 EFFLUENT MONITORING. Based on the requirements ofan NPDES
permit, DEM may modify the analytical requirement~ and the reporting frequency
shown in Table 8-1.
Thank you for the opportunity to comment on this document. Please call me at
[phone], extension 349 if you have any questions or comments.
cc: Jack Butler
Sincerely,
David J. Lown
Environmental Engineer
Superfund Section
• • \
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
, REGION IV
Mr. Tommy Marrow
Town Manager
City of Oxford
300 Williamsboro Street
Oxford, NC 27565
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA ·30365
July 18., 1995
Subject: Effluent Disposal to POTW
JFD Electronics/Channel Master Site
Oxford, Granville County, North Carolina
Dear Mr. Marrow:
RECEIVED
JUL 211995
SUPERFUND SECTION
The purpose of this letter is to request permission to discharge
effluent from the proposed groundwater treatment system at the
JFD Electronics/Channel Master Site to the City of Oxford's
publicly owned treatment works (POTW). EPA-Region IV and the
North Carolina Superfund Section agree that discharging the
treated groundwater to the POTW is the preferred discharge
option. The other option would require that the treated
groundwater be discharged to an intermittent creek located
adjacent to the Site. Your cooperation in approving this request
would be greatly appreciated. You can reach me at [phone]
(VMX 2038) if you have any questions regarding this matter.
Thank you for your continued assistance.
cc: David Lown, NCDEHNR
Bill Doucette, G&M
Sincerely,
1,itf(~u~ /1,{µe!J;cr'
McKenzie Mallary ·
Remedial Project Manager,
North Superfund Remedial Branch
Printed on Recycieq Paper
•
State of North ca!na _
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes. Secretary
William L. Meyer, Director
COPY
July 17, 1995
·Mr.Tommy Marrow
Town Manager
City of Oxford
300 Williamsboro Street
Oxford, NC 27565
Re: Effluent Disposal to POTW, JFD Electronics/Channel Master Site,
Oxford, North Carolina
Dear Mr. Marrow:
This letter follows a request made to you by Geraghty & Miller (letter from Mr. Nanjun
V. Shetty dated May 18, 1995) to discharge treated water to the City-owned water treatment
plant (publicly owned treatment works -POTW). We are asking that you honor their request.
Groundwater and soil contamination at the JFD Electronics/Channel Master Site are
being cleaned up under the Superfund program. The groundwater at the site is contaminated
with cyanide and volatile organic compounds, specifically trichloroethene, tetrachloroethene, and
1,2 dichloroethene. As outlined in the letter from Geraghty & Miller, cleaning the groundwater
will involve pumping contaminated water out of the ground, treating the water with an air
stripper and discharging. The treated water will either be discharged to the Oxford POTW or to
an on-site creek under the requirements of a National Pollution Discharge Elimination System
(NPDES) permit. We prefer that the treated water go to the POTW.
Table I from the May 18, 1995 letter ( enclosed) gives the expected effluent discharge.
Approximately, 50,000 gallons of effluent are expected to be generated per day. The cleanup
could last as long as 30 years.
We feel that there is less chance for adverse environmental impact if the water is
discharged to the POTW rather than a creek. We are requesting that you allow the effluent from
the groundwater treatment system go to the Oxford water treatment plant.
P.O. Box 27687. Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
f
Mr. Tommy Marrow
July 17, 1995
Page 2
• •
Your assistance is greatly appreciated. If we can answer any questions please call me at
[phone], extension 286 or David Lown, Superfund State Project Manager, at extension
349.
Enclosure
cc: Ken Mallary, USEPA
Sincerely,
~%~~
Jack Butler, PE
Environmental Engineering Supervisor
Superfund Section
William Doucette, Geraghty & Miller
• •
Table 1. Estimated (Preliminary) Influent and Effluent Concentrations of the Groundwater
Treatment System, JFD Electronics/Channel Master NPL Site, Oxford, North Carolina
Estimated Influent
Compound Concentration
Trichloroethene 1465
Tetrachloroethene 335
1,2 Dichloroethene (total) 1640
Chromium (total) 8
Nickel 10
Barium 60
Lead 1
Iron (total) 1410
Cyanide (total) 1
Copper 10
Zinc 40
Arsenic
Notes: -All concentrations in micrograms per liter (ug/1)
-Below method detection limit.
-• Primary Drinking Water Standards.
Estimated Effluent
Concentration
<5a
<5a
<100°
8
10
60
1
1410
1
10
40
1
June 6, 1995
Memorandum
TO:
FROM:
RE:
•
Abandoned Drum Dump
JFD Electronics/Channel Master Site
Oxford, Granville County
•
The following people accompanied me on a visit to this site on May 31, 1995:
Ken Mallary
William Doucette
Nanjun Shetty
Lawrence Hosmer
Leonard Moretz
USEPA
Geraghty & Miller
"
"
"
In addition to reviewing recent predesign data we toured the site. As part of the tour, we
examined an abandoned drum dump which was reported to EPA by Geraghty & Miller during
data acquisition activities during 1994. The drum dump was examined by NCDEHNR
Hazardous Waste Section personnel, Terry Waddell and Joe Cole, in August of 1994. Waddell
and Cole reported that there was no environmental threat from the drums (Hazardous Waste
Section Activity Report 8/25/94 & 8/26/94).
During the visit on May 31, the drum dump was found to extent to the fence surrounding
the adjacent Cristex property. A locked gate and a dirt road extended from the Cristex facility to
the drums. During our examination, an area of hummocky topography was noted near the gate
through the Cristex fence. Woodchuck holes dug into one of the humps revealed a number of
upright drums with a few inches of soil covering the tops of the drums. These drums had not
been reported previously.
After the visit, on June 6, 1995 I telephoned Ken Mallary to find what action he had taken
regarding the drums. Mr. Mallary indicated that he had not taken any action yet, but that he
would talk to his supervisor, Curt Fehn.
On this day, Jack Butler phoned _Curt Fehn and requested that the site be considered for a
removal action. Mr. Fehn indicated that the drum dump had been referred to a Removal
Assessment Team Site Assessment Team (RA TSA T) for further evaluation.
cc: Jack Butler
May 17, 1995
Memorandum
TO:
FROM:
RE:
•
Phone call from Ken Mallory, RPM
Remedial Design
JFD Electronics/Channel Master
Oxford, Granville County
Mr. Mallory called to tell me that a meeting is scheduled at the site on May 31. The
PRP's contractor, Geraghty and Miller, wants to present the results of their recent site
investigation. A Remedial Design for this site should be submitted some time next month.
I told Mr. Mallory that I planned to attend the meeting.
cc: Jack Butler
State of Nort&rolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt. Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
DEHNR
October 13, 1994
Mr. McKenzie Mallary
Remedial Project Manager
North Superfund Remedial Branch
US EPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Subject: NC Hazardous Waste Section Field Report on Abandoned Drums
JFD Electronics/Channel Master Superfund Site
Oxford, Granville County, North Carolina
Dear Mr. Mallary:
Attached is the field report on the abandoned drums at Channel Master. I was
waiting for a set of prints to send you with the report. Now I'm not sure that I'll be getting
the prints. If I do I'll send them to you.
Did the sample results from this area show anything?
Call if you have any questions or comments.
cc: Jack Butler
~.~
David J. Lown
Environmental Engineer
Superfund Section
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
, .•. · D~PARTMENT O~NVIRONMENT, HEALTH and Nflilj;.URAL RESOURCES
I« · 1. · . DI.ON OF SOLID WASTE MANAG9ENT ·
. HAZARDOUS WASTE SECTION
ACTIVITY REPORT
Subject (lf;enked ~s ~ ~ d
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Address .I~rle //:}i,
Date 8-2,S-9<1 'f 8-u-'i</:
Time spent 8/tA. r 4h,,,,,
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