NCD122263825_20080902_JFD Electronics - Channel Master_FRBCERCLA FYR_Five-Year Review 2003 - 2008-OCR

North Carolina Department of Environment and Natural Resources
Dexter R Matthews, Director Division of Waste Management Michael F. Easley, Governor
William G. Ross Jr., Secretary
TO:
FROM:
I. No comments.
September 2, 2008
David Mattison
David Lilley '})£ {___
RE: Comments on the Response to Comments on the
Summary Report of Additional Data Collection Related to
5-year Review, JFD Electronics/Channel Master Site,
Oxford, NC
July 31, 2008
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] I FAX [phone] I Internet http://wastenotnc.org
An Equal Opportunity I Affirrna1ive Action Employer -Printed on Dual Purpose Recycled Paper
•
ENSR Consulting & Engineering (NC), Inc.
7041 Old Wake Forest Road, Suite 103, Raleigh, North Carolina 27616
T 919 872 6600 F 919 872 7996 www.ensr.aecom.com
July 31, 2008
Mr. Ken Lucas
U.S. Environmental Protection Agency
Region IV
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303-8960
•
ENSR I AECOM
Subject: Response to Comments on the Summary Report of Additional Data Collection Related to
5-year Review
JFD Electronics/Channel Master Site, Oxford, North Carolina
Project No. 10140-008.1000
Dear Mr. Lucas,
On behalf of the Responsible Parties (RPs), JFD Electronics Corporation and CMSS, Inc., ENSR Consulting
and Engineering (NC), Inc. (ENSR) has prepared the following responses to United States Environmental
Protection Agency (USEPA) comments dated March 19, 2008 on the Summary Report of Additional Data
Collection Related_ to 5-year Review prepared by ENSR in February 2007 (ENSR, 2007) for the above
referenced site (the Site). The following sections outline the USEPA comments followed by responses.
General Comments:
1. In 2002, the USEPA released Subsurface Vapor Intrusion Guidance (USEPA, 2002c) that
recommends a tiered approach for evaluating the vapor intrusion pathway and includes a series of
questions that guides users through a stepwise evaluation of the subsurface vapor intrusion pathway.
The USEPA 's recommended approach for assessment of the vapor intrusion pathway includes the
evaluation of multiple lines of evidence, if available. Once the potential for a vapor intrusion pathway
is established, it is appropriate to evaluate whether the physical and/or chemical processes completed
this pathway and, if so, to evaluate the potential risk to human health. A section should be presented
which includes a discussion of multiple lines of evidence used in the evaluation. This evaluation is
consistent with the USEPA's recommended approach for assessment of the vapor intrusion pathway.
The tiered approach should include the following: Tier 1 -Screening; Tier 2 -Site Specific Data
Evaluation and Tier 3 -Detailed Vapor Intrusion Pathway Assessment. Appendix C of the
Subsurface Vapor Intrusion Guidance contains a flow diagram depicting their tiered approach. Please
revise Section 4 to incorporate the tiered approach. Please revise calculations, corresponding text
and tables.
Response to General Comment 1: The risk assessment conducted to evaluate soil gas results was
conducted in accordance with the Workplan dated January 30, 2006 (Work Plan for Indoor Vapor Migration
Evaluation, Groundwater Discharge to Surface Water, and Evaluation of Source Area Mass Removal
Options, JFD Electronics/Channel Master Site, Oxford, North Carolina prepared by ENSR). The Work Plan
stated that the soil gas results would be evaluated using vapor intrusion models. This point was discussed
in a conference call with USEPA on June 5, 2008, and USEPA agreed that no revision was required on the
basis of this comment.
S :\PU BS\PROJECnC\ChannelMaster\5--Yr Tech_ Strat_lmp ( 1 0140--008 cont'd )\Correspondence\Lucas _ 07-31--08.doc
Mr. Ken Lucas
Page2
July 31, 2008
• •
2. Based on the current data, sampling for soil gas vapors should be conducted quarterly or
semiannually as long as a plume exists at the Site.
Response to General Comment 2: The very conservative screening-level indoor air risk evaluation
performed based on the soil gas data collected at the Site indicates that the predicted risks and Hazard
Indices (His) for a potential resident inside the nearby Oak Ridge Housing buildings are well below USEPA's
acceptable risk benchmarks. As we discussed in our conference call on June 5, 2008, the chlorinated
volatile organic compounds (CVOCs) detected in soil gas are the result of off-gassing (volatilization) from
the underlying groundwater impacted with the same chlorinated compounds. CVOC concentrations in soil
gas are thus direcUy related to the CVOC concentrations in the underlying groundwater. Significant change
in soil gas CVOC concentrations would be preceded or accompanied by a similar significant change in
groundwater CVOC concentrations. We suggest that sampling and analysis for soil gas should be
undertaken only if groundwater CVOC concentrations are found to have increased significanUy.
Groundwater monitoring data from monitoring well CMMW-23, the well closest to the occupied structures
(approximately 50 feet) shows that CVOC concentrations have been relatively stable since the recovery well
system was activated in 2001 (see Figure 1 attached). As the comments below indicate, a soil gas
concentration increase of more than two orders of magnitude (factor of 100) would be needed to reach the
upper end of EPA's acceptable risk range. To be conservative, we suggest that we use a one order of
magnitude increase as a trigger for additional soil gas sampling and analysis. The RPs will continue to
monitor the concentrations of CVOCs in groundwater from well CMMW23 located near the Oak Ridge
Housing buildings as part of the semi-annual groundwater monitoring program. If the monitoring indicates
an order of magnitude increase in specific VOC concentrations (such as TCE), then the RPs will propose
appropriate actions to further evaluate potential indoor air risks.
Specific Comments:
1. Section 4., Dose-Response Assessment
Please change the cis-1-2,Dich/oroethylene inhalation reference concentrations from 3.5E-02 mglm3
to 6.0E-2 mglm3. Given the similarity between the oral values and between target organs, it is
reasonable to use the p-Rfc (EPA-PROV) derived for trans-1,2-Dichloroethylene as a surrogate value
for the cis-1,2-Dich/oroethylene for the expressed purpose of calculating a Hazard Quotient. Please
revise calculations, corresponding text and tables.
2. Section 4.2 Dose-Response Assessment
EPA recommends that the total potential carcinogenic risk be calculated two different ways if TCE is a
COPC: 1) using the upper end of the draft provisional USEPA range of CSF for TCE; and 1) using
the California EPA's Office of Environmental Health and Hazard Assessment (*OEHHA) CSF for TCE:
The IRIS value published in 1989 (6.0E-03 (mg/kg-0)'1) has been withdrawn. In its place, two values
were published by ORD in 2001 in a draft risk assessment that represent a range of slope factors.
The less conservative slope factor is 2.0E-02 (mg/kg-0)'1• ORD did not provide guidance on selecting
from these values. The risk assessment has been reviewed by the National Academy of Sciences
and EPA is in the process of finalizing the draft. The issue of TCE toxicity continues to undergo
review both within EPA and by external groups. In 2002 the State of California (Ca/EPA) published an
inhalation slope factor of 78.0E-03 (mg/kg-0)'1, which is equivalent to a unit risk of 2E-06 (ug/m3)'1,
and the RfC value is 6E-01mg/m3• Ca/EPA values are in the Tier 3 hierarchy of toxicity values for
EPA in the absence of values in IRIS and the Provisional Peer Reviewed Toxicffy Values for
Superfund (PPRTV) database. The Ca/EPA cancer potency factor has undergone extensive peer
review, is consistent with the hierarchy of toxicity criteria defined by OSRTI, and presently being used
by EPA OAQPS as a screening value for air toxics risk assessments. EPA recommends that you take
S:\PUBS\PROJECT\C\ChannelMastef\5--Yr Tech_Strat_lmp (101-40--008 cont'd)\Correspondence\Lucas_07-31-08.d(?C
Mr. Ken Lucas
Page3
July 31, 2008
• •
a site-specific approach that utilizes a range of available cancer potency values. Although this doesn't
constitute Regional or EPA policy, in the interim until the Agency completes the TCE risk assessment
and provides final guidance on recommended toxicity values, EPA suggest using the 2001 draft
cancer potency factors and the Ca/EPA inhalation slope factor value as bounds. Please revise
calculations, corresponding text and tables.
Response to Specific Comments 1 and 2: In accordance with the comments and the discussion with
USEPA on June 5, 2008, ENSR ran the USEPA version of the Johnson and Ettinger indoor air model
(USEPA, 2004 ) using revised toxicity factors for cis-1,2-dichloroetheylene (cis-1,2-DCE) and
trichloroethylene (TCE). USEPA's recommended reference concentration of 6.0E-2 milligrams per cubic
meter ~mg/m3) was used for cis-1,2-DCE, and the unit risk factor of 2.0E-06 (micrograms per cubic meterr'
((ug/m r') and reference concentration of 6E-01 mg/m3 was used for TCE. The TCE values were derived
by CalEPA. A printout of the revised indoor air modeling spreadsheets is enclosed. A revised Table 4-3 is
also included. Table 4-3 presents a summary of chemical-specific cancer risks and noncancer Hazard
Indices (HI) for each soil vapor point. As shown in Table 4-3, the potential cancer risks for the resident
ranges from 8.2x10·• at sample SV-5 to 1.0x10-6 at sample SV-1. These cancer risk results are less than
USEPA's acceptable cancer risk range of 1x10_. to 1x10"'. The total HI for the resident ranges from
0.00005 at sample SV-5 to 0.014 at sample SV-2. These His are well below USEPA's acceptable HI of 1.
If you need more information or have questions, please contact the following at 919-872-6600.
Sincerely,
ENSR Consulting and Engineering (NC), Inc.
Nanjun Shelly, P .E.
Project Manager
Copy:
B. Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
S. Earp, Smith Moore
I. Chaudhuri, ENSR
D. Mattison, NCDENR
William H. Doucette, Jr., Ph.D., P.G.
Project Coordinator
S:\PUBS\PROJ EC1'C\ChanneIMaster\5-Yr Tech_ Stral_lmp ( 1014!HI08 cont'd)\Correspondence\lucas _ 07-31--08.doc
Table 1
Key voes in Well CMMW23
JFD Electronics/Channel Master Site
400
350 •
300
:::; 250 -CD
--cis-1,2 DCE
2-
C 0 ;, 200 f -<>-Vinyl chloride -C .,
" C 150 0 0
100 • 50
0
~~ !o ~ !I.fl ~Oj ~ ~'1, ~'V
Notes:
Concentrations below analytical MDLs/RLs are plotted at half the RL. Date
SV-1 DATA ENTRY SHEET
" .. S ·1G C oncen 00 • trati D ta
ENTER ENTER ENTER
Soil Soil
Chemical , .. , ..
CAS No. ~OC-. OR cone.,
(number1o only, c, c,
no dashesl '""~' tn~mvl Chemical
156592 7.90E+OO I I cis-1,2-Dichloroeth• lene
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER a.,~ Totals must add u11 to value of Ls lcell F24' So~
below grade Soil gas Thickness Thicknass stratum A User-defined
to bottom 5ampling A-g, Thickness of sol of soil scs ""'"mA
ofendosed depth ... of SOil stratum B, stratum C, soil type sou vapor
space noor, below grade, temperature, stratum A, (Enter value or 0) (Enter value or 0) (used to estimata OR permeablity,
L, L, T, h, h, ho sou vapor ,. • '=' '='
_,
'=' '=' '=' n,ormeabmtv1 (an2)
I 15 ' 152,4 15.8 152.4 ' SlCL I I
(60°F)
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER I M~E I Stratum A Stratum A Stratum A Stratum A Stratum B Stratum B Stratum B Stratum B Stratum C Stratum C Stratum C Stratum C
scs so~ d,y ... .,.., soil water-filled scs soil dry aotl total soil water-filed scs SOi1 dry SOil total soil water-filed
sou type bulk density, porosity, porosity,
... _
bulk density, porosity. porosity, ""'""' bulk density, porosity, poro5,ily,
Lookup Sol ' ,. ,, ,: Lookup Sol ,. • ,. ' . ,_,,.. C ,. ," ,:
Paramelen !tanj !unitlessl (an3lan3) Pvamoton (g/an3:l junitklssl (an3lan3:l Paramelen (g/an3) juniUessj (an3/an3:l
SICL 1.37 0.482 0.198
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER
Endosed Endosed Endosed Average vapor I M~RE I """ So~OQ. ... ~ ... ~ Eodooed -·-Indoor now rate into bldg. noo, pressure too, ,.., -~ seam aack air exdlange OR
thickness. differential, -· width, height wk!th, rate. Leave blank to cakulate
'-t,P '• w, "· w ER a..
janj (i!cm-i:1) !an! lcml lcml !an! 11/hl lllml
10 " 1000 1000 366 0.1 0.25 5
ENTER ENTER ENTER ENTER • Averaging Averaging
time for time for Exposure -~~ carcmogens. noncarcinogens, duratioo, frequency,
Ale AT~ EO EF
!el 1ir1ol !el jdat!!:tr.J
70 30 30 350
~
1 of5
CHEMICAL PROPERTIES SHEET
Henry's Henry's Enthalpy of
law coostant law COflstant vaporization at Normal Unit
Diffusivity Diffusivity at reference ,efen,nce the normal boiling Critical Molecula, risk Reference
in air, in water, temperature, temperature, boiling point, point, temperature, weight, factor, cone.,
D, D. H T, ....... T, T, MW URF RIC
(cm2ls) (cm2/s) (atm-m3/moo c·c) (callmol) c·K) (OK) (g/mol) (pg/m3)"1 (mg/mj
7.36E-02 1.13E-o5 4.07E-03 25 7,192 I 333.ss I 544.00 96.94 O.OE+OO 6.0E-02
•
•
2of 5
INTERMEDIATE CALCULATIONS SHEET
Stratum A Stratum B Stratum C Stratum A Stratum A Stratum A Stratum A Floor-
Sou,ce. soi soi soi effective soil soil soi wall Bldg.
Exposure building air.fiDed air•fiDed air.filled total fluid intrinsic relative air effective vapor seam So;J ventilation
duration, separation, porosity, porosity, porosity, saturation, permeability' permeability' permeability' perimeter, gas rate,
L, ... ... •·' s. ~ k., k. """'· cone. a,...,.
jsec! ,cm! jan3/cm3! jan'lcm'! jan'lan'! (an'lcmJ 1an2! 1cm2l 1an2! ,cm! ll!i!m'! (an3IS!
9.46E+08 137.4 0.284 ERROR ERROR 0.276 1.72E--09 0.838 1,44E-09 4,000 7.90E+00 2.54E+04
Area of Stratum Stratum Stratum Total
enclosed c-. Crack Enthalpy of Henry's law Henry's law Vapor A 8 C """""1
spaa, to-total depth vaporization at constant at constant at viscosity at effective effective effective effective Diffusion
below .... below ave. IIOil ave. soil ave. soil ave. soil diffusion diffusion diffusion diffusion path • grade, ratio, g-. temperature. temperature, temperature, temperature, coefficient, coefficient, coefficient, coefficient, length, ,. " ,._ 6H.,rs H,, "" "" o~, o~, o~, o~, L.,
1cm2! ,unitlessl ,cmi !caUrndl jatnHn'lrnd! !unitlessl 1a::~s1 jan2IS! 1cm2/s! jcm2ls! 1cm2/s! 1cml
1.06E+06 3.77E--04 15 71678 2.67E--03 1.13E-01 1.77E--04 4.79E.03 0.00E+00 0.00E+O0 4.796-03 137.4
Exponent of Infinite
Average Crack equivalent ,ou= Infinite
Convection Source vapor effedive foundation indoor "'""" Unn
path vapor Crack flow rate diffusion Area of Pedet attenuation bldg. risk Reference
length, "'"'-· radius, into bldg., coefficient. aaci<. number, coefficient, "'"'-· factor, "'"'-·
L., c_ r_ a,.. □•-'-• exp(Pe1) a c..... URF RfC
!cml h!i!m3! ,cmi (an3lsl 1cm2/s! 1cm2) iunitlessl junitlessl l~m'! j~m'( <!!!2!m')
15 7.90E+o0 0.10 8.33E+01 4,79E--03 4.00E+02 6.50E+188 1.01E--03 7.96E-03 NA 6.0E-02
END
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3 of5
929 Main-E-10-19-04
A
B
C
A*B/C
A/C
A/(1+A)
10*(1+A)
C/B
A/(1+A/C)
Johnson 2002 Evaluation
3.35E-02
4.61E+02
3.28E-03 =Q,o,~Oa
4.71E+03
1.02E+01
0.032396189
10.33480841
7.11E-06
2.99E-03
4 of 5
OK
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•
Cis-1,2-Dichloroethene.xls
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END
RESULTS SHEET
INCREMENT Al RISK CA LC ULA TIONS:
Incremental Haza,d
risk from quotient
vapo, from vapor
intrusion to intrusion to
indoor air, indoor air,
carcinogen noncarcinogen
(unitless) {unitless)
NA 1.3E-04
MESSAGE ANO ERROR SUMMARY BELOW: (00 NOT USE RESULTS IF ERRORS ARE PRESENT)
MESSAGE: Risk/HO or risk-based soil concentration is based on a route-to-route extrapolation.
5 of 5
•
•
SV-1 DATA ENTRY SHEET
" .. 0 • S ·1 G Conce tratioo O ta
ENTER ENTER ENTER
Soil Soil
Chemical , .. ,.,
CAS No. cone., OR cone.,
(numbers onty, c, c,
nodasheal
' __ , ,_ ---.v1 Chemical
79016 2.40E+02 I I Trichloroethylene
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER
lloplh Totals must add uo to value of Ls lcel F24' Soil
below grade SOil gas Thickness Thickness stratum A User-defined
to bottom sampling Average Thickness olsol of soil scs stratum A
ol endosed depth wi ofsoij stratum B. stratum C, sou type soil vapor
space floor, below grade, temperature. stratum A, (Enter val1.1& or 0) (Enter value or 0) (used to estimate OR permeability,
L, L. T, h, ... "" soil vapor k, • '=' '=' ~, '=' '=' '=' oermeabdi"'' (anl)
,, ' 152.4 15.6 152.4 I I SICL I
(60°F)
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER I M~RE I Stratum A . Stratum A Stratum A Stratum A Stratum B Stratum B Stratum B Stratum B Stratum C Stratum C StratLml C Stratum C
scs ... ..., soil total soi water-Med scs soil dry soil total soil water-filled scs soil dry soil total soil water-filed
soi type bulk density. porosity, porosity, ...... bulk density, porosity. porosity, soij type bulk density, porosity, porosity,
Lool<up &, ' o' ,: Lookup Sol • o' ' . Lookup Sol ' o" ,.' P, P, P• Parameta,. (g/cm3j 1unitlessj (cml1an3j Panimet.,. <!i!'an3J junrt1ess1 (an3lcm3) Paramo1on (g/an3} junideul (an31cm3)
SICL 1.37 0.482 0,198
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER
Endosed Eo-.. Endosed Average vapor I M~RE I ... ~ Soil-bldg . ~ ... ~ Enclosed Floor-wal Indoor now rate into bl,;lg. -ore=re ""'' loo, ""'" seam crack air exchange OR
thickneu. difhtrential, ~--wklth, height width, rate; leave blank to calculate
'--"' 4 w, "· w ER a..
!cml (g/cm-s") janl Ian! tanl janj 11nii jllmj
10 40 1000 1000 366 0,1 0.25 5
ENTER ENTER ENTER ENTER • Averaging Averaging
time for time for Exposure Exposure
carcinogens, noncaranogens. duration, frequerw::y,
AT, AT~ ED EF
!el !~rsl lt-sl jda~~l
70 30 30 350
~
1 of5
CHEMICAL PROPERTIES SHEET
Henry's Henry's Enthalpy of
law constant law constant vaporization at Normal Um
Oiffusivtty l>ffUSM!y at reference ..,...,.,. the norma boiling Critical Molecular risk Reference
in air, in water, temperature, temperature, boiling point, point, temperature, weight, factor, cone.,
D, o. H T, 6.H.,b T, T, MW URF RfC
canl/S) (cm1/s) (a1m-m3/mol) CC> (callmol) (Kl ('Kl (Q/mol) (µg/m,)*1 (mg/m3)
7.90E-02 9.10E-06 1.03E-02 25 7,505 I 360.36 I 544,20 131.39 2.0E-06 6.0E-01
•
2 of 5
INTERMEDIATE CALCULATIONS SHEET
Stratum A Stratum B Stratum C Stratum A Stratum A Stratum A Stratum A Aoo,-
Source-soil soil soi effective soil soil soil wall Bldg.
Exposure building air..filled air.filled air-filled total fluid intrinsic relative air effective vapor seam Soi ventilation
duration, separation, porosity, porosity, porosity, saturation, permeability, pem,eability' penneablity, perimeter, gas rate,
L, ... •·' •·' s,. ~ k., k. x.-cone. a-.
{sec) (cm) (cm3/an3) (rm3/cm3) (cm3/cm3) . can'tcmJ (rm2) (an2) (rm2) {an} (uplm') (cm3/s)
9.46E+o8 137,4 0.284 ERROR ERROR 0.276 1.72E-09 0.838 1.44E-09 41000 2.40E+o2 2.54E+04
An,a of Stratum Stratum Stratum Total
endosed Crack-Crack Enthalpy of Henry's law Henry's law Vapor A B C overall
space !<>total depth vaporization at constant at constant at viscosity at effective effective effective effective Diffusion • below "'"" below ave. soil ave. soa ave. soil ave. soa diffusion diffusion diffusion diffusion path
grade, ratio, grade, temperature, temperature, temperature, temperature, coefficient, coefficient, coefficient, coefficient, length, .. " '-• 6t\.rs H,. H',s "" o", o", o", o", L,,
(cm2) 1unitless) (cm) (caltmoll (atm--m3/mol) 1unitless) (a!cm-s) (cm2/s) (cm2/s) (cm2/s) (cm2/s) (cm)
1.06E+06 3.77E--04 15 8,488 6.44E-03 2.72E-01 1.77E--04 5.14E-03 0.00E+O0 0.00E+oo 5. 14E-03 137.4
Exponent of Infinite
Average Crack equivalent source Infinite
Convection Sou,ce vapor effective foundation ;nc1oor source Unrt
path """"' Crack flow rate diffusion Area of Pedet attenuation bldg. risk Reference
length, ccnc., radius, into bldg., coefficient, crack. number, coefficient, cone., factor, cone.,
L,. c_ ,_ Ow 0--exp(Pe') a c--. URF RfC
(cml (uplmJ) (anl (c:m3/s) (cm2/s) (cm2! (unitlessl 1unitless1 (!!i,!m') h.!tm3r1 (mg/m3)
15 2.40E+02 0.10 8.33E+o1 5.14E-03 4.00E+02 9.04E+175 1.06E-03 2,54&o1 2.0E-06 6.0E-01
END
•
3 of 5
929 Main-E-10-19-04
A
B
C
A*B/C
A/C
A/(1+A)
10*(1+A)
C/B
A/(1+A/C)
Johnson 2002 Evaluation
3.59E-02
4.29E+02
3.2sE-03 =a •• ,~a.
4.71E+03
1.10E+01
0.034681167
10.35927162
7.63E-06
3.00E-03
4 of 5
OK
•
•
T richtoroethene.xis
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ENO
RE SUL TS SHEET
INCREMENTAL RISK CALCULATIONS:
Incremental
risk from
vapo,
intrusion to
indoor air,
carcinogen
(unitless)
2.1E-07
Haza,O
quotient
from vapor
intrusion to
indoor air,
noncarcinogen
(unidess)
4.1E-04
MESSAGE AND ERROR SUMMARY BELOW: (DO NOT USE RES UL TS IF ERRORS ARE PRESENT)
MESSAGE: Risk/HQ or risk-based soil concentration is based on a route-to-route extrapolation.
5 of 5
•
•
SV-2 DATA ENTRY SHEET
.. " " • Sail G Gonce tratio D ta
ENTER ENTER ENTER
SoQ sou
Chemical ,., , ..
CAS No. o,oc. OR cone.,
{numbers only, c, c,
no dashes' ·'m' ·--mv1 Chemical
156592 4.50E+02 I I cis-1,2-Dichloroeth, lene
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER I M~RE I o,,~ Totals must add uo to value of Ls I cell F24 I Soil
below grade Soil gas Thickness Thickness '""'"mA User-defined
to bottom sampling A-• Thickness 0l101 ofsoU scs stratum A
of enclosed ... ~ .. ofso~ stratum B, stratum C. ~itype soil V8p0(
spa<;e1100f". below grade, temperature, stratum A, {Enter value or 0) {Enter value or 0) (used to estimate OR permeablity,
L, L. T, ,, ,, he soil vapor k, • '=' '=' fC) '=' '=' '=' oermeabiliM (cm 2,
15 ' 60.96 ' 15.6 60.96 l ' SlCL ' ' {60°F)
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER I M~RE I Stratum A Stratum A Stratum A Stratum A Stratum B Stratum B Stratum B Stratum B Stratum C Stratum C Stratum C Stratum C
scs .. "" soil total soil water-filled scs soil dry SOil total soil water-filled scs .. ,~ SOil total soH water-filled
soil type bulk density, porosity, porosity, """" bulk density, porosity, porosity. $0~ type bulk density. porosity. porosity,
'"""'"" . ,. "' ,: Loolo.<p Sol • P, "' ,.· Loo<Up Sol ' P, "' ' ' P1,.,,-.i~,.. !i!cm3> 1uniUe"I {cm3fcmJ --[ifcm3) juniUessj (cm3fcm3) p.,..,,,.,-(i!cm3> juniUess! (cm3fcm3)
SICL 1.37 0.482 0.198
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER
Enclosed Endosed Endosed Average vapor I M~RE I ""' Soll-bldg. .,.~ ... ~ Endosed Floor-waD Indoor flow rate into bldg.
ftoo< pressure '"'" too< spaca seam crack air exchange OR
thickness. di!lerential. ~c,gth. """'· height width. rate. Leave blank to calculate
'--AP ... w, H, w ER a...
!cm! (i!i;m..s2) jcml lcml [cml !cml !1hll 1um1
10 40 1000 1000 366 0.\ 0.25
ENTER ENTER ENTER ENTER • Averagtng Averaging
time for time for Exposure Exposure
carcinogens, noncaranogens, duration. frequency,
AT, AT Ne ED EF
1:z:rsj !:z:rsl 1:z:rsl jda:z:!:'.:r:r!
70 30 30 350
~
1 of5
CHEMICAL PROPERTIES SHEET
Henry's Henry's Enthalpy of
law constant law constant vaporization at Normal Unit
Diffusivity Diffusivity at reference reference the nonnal boiling Critical Motecular risk Reference
in air, in water, temperature, temperature, boiling point, point, temperature, weight, fad.or, cone.,
D, o. H T, 6!-i,,b T, T, MW URF RIC
(cm2/s) (cm2ls) (atm-m'lmot) (°C) (cal/mot) C'9 CKl (gtmol) (ug/mJ)"1 (mg/m')
7.36E-02 1.13E-05 4.07E-03 25 7,192 I 333.ss I 544.00 96.94 0.0E+OO 6.0E.02
•
•
2af 5
INTERMEDIATE CALCULATIONS SHEET
Stratum A Stratum B Stratum C Stratum A Stratum A Stratum A Stratum A FJoo,.
Soma,. """ """ soa effective """ so,1 soa -Bldg.
Exposure building air-filled air-filled air-fiDed total ftuid intrinsic relative air effective vapor ,earn Soil ventilation
duration, separation, porosity. porosity. porosity. saturation, permeabiity. permeability, permeability, perimeter. gas rate.
L, ... •.' •·' s,. ~ ... .. "-· oonc. a..,...,
~sec! ,cmJ ~anl/anl! ~cm3/cm3! ~cm3/cm3! ~cm3/cm3l ~an2! icm2I ~an2I 'cm! h2m3J ian'lsl
9.46E+08 45.96 0.284 ERROR ERROR 0,276 1,72E-09 0.838 1.44E..09 4,000 4.50E+02 2.54E+04
Area of Stratum Stratum Stratum Total
endo,ed Crack-Craci< Enthalpy of Henry's law Henry's law Vapor A B C overall
space t~otal depth vaporization at constant at constant at viscosity et effective effedive effective effective Diffusion • below .,.. below """·""" aw. soa ave. soil aw. soa diffusion diffusion diffusion diffusion path
grade, ratio, grade, temperature, temperature, temperature, temperature, coefficient, coefficient, _coefficient, coefficient, length, ,. " Z,~ ti.H..,1s H,. H",. "" o~, D~, D~, D~, I.,,
ian2! junitlessl jcm! ,ai!mal !atn'HTI '1mo11 junitlessl ji;!cm-sl 1cm2lsj 1cm21s1 1cm2lsl 1cm21s1 1cml
1.06E+06 3.TTE-04 15 71678 2.67E-03 1.13E-01 1.77E-04 4.79E-03 0.00E+00 0.00E+OO 4.79E-03 45.96
Exponent of Infinite
Average Crad< equivalent source Infinite
Convection So,rce vapo, effedive foundation indoor sou,a, Um
path vapoc Craci< flowrate diffusion Area of Pedet attenuation b(dg. risk Reference
length, cone., radius, into bldg., coefficient, crad<. number, coefficient, cone.," fador, cone ..
t,, c_ ,_ Qd o-• "-• exp{Pe') a c-. URF RfC
!cml !l!i!mll 1cml !an3ls! 1cm2lsl 1cm2) junitlessl ,unitless! !~m'I !~a!m'r1 (mglm')
15 4.50E+02 0.10 8,33E+01 4.79E-03 4.00E+02 6.50E+188 1.87E-03 8.41E-01 NA 6.0E-02
END
•
3 of 5
929 Main-E-10-19-04
A
B
C
A*B/C
AJC
A/{1+A)
10*{1+A)
C/B
AJ{1+AJC)
Johnson 2002 Evaluation
1.00E-01
4.61E+02
3.28E-03 =Q.0l0e
1.41E+04
3.05E+01
0.090985823
11.00092854
7.11E-06
3.17E-03
4 of 5
OK
•
•
Cis-1,2-0ichloroethene.xls
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ENO
RE SUL TS SHEET
INCREMENTAL RISK CALCULATIONS:
Incremental Hazaro
risk from quotient
vapor from vapor
intrusion to intrusion to
indoor air, indoor air,
carcinogen non carcinogen
(unidess) (unidess)
NA 1.3E-02
MESSAGE AND ERROR SUMMARY BELOW: (DO NOT USE RESULTS IF ERRORS ARE PRESENT)
MESSAGE: Risl<JHQ or risk-based soil concentration is based on a route-to-route extrapolation.
5 of 5
•
•
SV-2 DATA ENTRY SHEET
Soil Gas Conoentration Data
ENTER ENTER ENTER
Soil Soil
Chemical , .. , ..
CAS No. ro=, OR ro=,
(numbers only, c, c,
no dashesl '··-1m31 ·---» Chemical
79018 9,30E+01 I I Trichloroethylene
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER
Dep~ Totals must add up to value ol Ls fcell F24l So~
below grade Soil gas Thickness Thickness stratum A User-delir'led
to boUom samplirlg A-ge Thickness '""' ''"' scs stratum A
ofendosed depth ~, of so~ stratum B, stratum C, witype soil V&j)Of
space ftOOf, below grade, temperature, stratum A, (Enter value or 0) {Enter value or 0) (used to estimate OR permeability,
L, t. T, h, h, "" SOil vapor " • t=l <=l re, f=l <=I <=I oermeabil1tv) (cml)
' 15 I 60.96 I 15.6 60.96 I I SICL I I
(60"FJ
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER I M~RE I Stratum A Stralllm A Stratum A Stratum A Stratum B Stratum B Stratum B Stratum B Stratum C Stratum C Stratum C Stratum C
scs ''"~ '°''°"" aoil wat&r-lilled scs .. ,~ soil total soil water-filed scs sol dry SOil total soil water-filed
soQ type bulk density. poroSity, poroSity, $011 type bulk density, porosity, porosity, soH type bulk density, porosity, porosity,
lool<up Soi P, • o' ,: LIXlku;,Soi ,.' ,• •." LIXllwp Soi P, ' o' '-' Para!Mlltfl (g/cm~ lunrtlessl (cm3lcm"} --~ !i!cm':l junitlessj (cm3Jcm"} ·--(g/cm"} juni!!essl (cm3Jcm")
SICL 1.37 0.462 0.198
ENTER ENTER ENTER ENTER ENTER ENTER ENTER ENTER
Endosed Endosed Endosed Average vapor I M~RE I ... ., Soil-bldg. ~ ,..., Enclosed FIOOf-wall Indoor flow rate into bldg.
noo, pressure loo, Goo, ,..., seam crack air exchange OR
thickness, diffefential. lerlQth. width, height, wic:th, rate, Leave blank to calc;ulate
'--AP ... w, "· w ER a...
jcml (g/cm-Sl) lcml !cm! jcml jcmj ,,,.,,1 !Lim)
10 40 1000 1000 366 0.1 0.25 5
ENTER ENTER ENTER ENTER • Averaging Averaging
hme !or hme !or Exposure -~re carcinogens, noncaronogens, duration, frequency,
AT, AT~ ED EF
!:t!!! !lrs! ~raj (da;z:!:'.:r;r!
70 30 30 350
~
1 of5
CHEMICAL PROPERTIES SHEET
Henry's Henry's Enthalpy of
law constant law constant vaporization at Nonnal Unit
Diffusivity Diffusivity at reference reference tho normal boiling Critical MolectAar risk Reference
in air, in water, temperature. temperature, boiling point, point, temperature, weight, factor, cone.,
D, o. H T, 6f-\.,b T, Tc MW URF RfC
(an2/s) (an2/s) (Btm-m3/mol) (OC) (cal/mol) (OK) ('K) (glmol) (pg/m3rl (mgtm3)
7.90E-02 9.10E-o6 1.03E-02 25 7,505 I 36o.36 I 544,20 131.39 2.0E-06 6.0E-01
•
•
2 of 5
INTERMEDIATE CALCUlATIONS SHEET
Stratum A Stratum B Stratum C Stratum A Stratum A Stratum A Stratum A Fl00<-
Sou=-""' ""' ""' effective ""' ""'' ""' -Bldg.
Exposu,e building air-filled air-fiDed air-Ried total fluid intrinsic relative air effective vapor seam Soi ventaation
duration. separation, -· -· porosity, saturation, penneabiity, -~lily. permeability, perimeter, gas rate,
L, ... ... •·' s. ~ k,, k. "-· cone. a.....,,
1sec) lcml ,anJ/cm,! ,cm,/cm3! ,cm3/cm3! 'cm'lcm'! ,cm2! 1cm2! 1cm2j 1cml !l!i!m'! 1cm'ls!
9.46E+08 45.96 0.284 ERROR ERROR 0.276 1.72E-09 0.838 1.44E-09 "4,000 9.30E+01 2.54E+04
Area of Stratum Stratum Stratum Total
endosed Crack-Crack Enthalpy of Henry's law Henry's law Vapor A B C overall
,pace ~ .... depth vaportzation at constant at constant et viscosity at effective effective effective effective Diffusion • below area below ave. soil ave. soil ave. soil ave."°' diffusion diffusion diffusion diffusion path
grade, ratio, grade, temperature, temperature, temperature, temperature, coefficient, coefficient, coefficient, coefficient, length,
A., " 2-AH..u H,, ff,. "" D~, D~, D~, D~, L,
!an2! lunitlessj lcml 1ca1mo11 !atm-m'1mo11 !unitlessj la!cm-s1 1cm2/s! 1cm2/sj 1cm2/sj ,cm2/sj 1cml
1.06E+06 3.nE.o4 15 81488 6.44E-03 2.72E-01 1.nE-04 5.14E-03 O.OOE+OO 0.00E+OO 5.14E-03 45.96
Exponent of Infinite
Average Crack equivalent "'"""' Infinite
Convection Sou,ce vapo, effective foundation indoor '°""" Urut
path vapo, Crack flow rate diffusion Area of Pedet attenuation bldg. risk Reference
length, cone., radius, into bldg., coefficient, crack. number, coefficient, cone., factor, cone.,
L, c_ ,_ Ow o-~ exp(Pe') a c.-URF RfC
jcmj ll!i!m'! !cml (cm3/s! 1an2/s! 1cm2! junitlessj junitlessl !l!i!m'l ll!a!m'r1 (mg/m3)
15 9.30E+01 0.10 8.33E+01 S.14E-03 4.00E+02 9.04E+175 1.93E-03 1.79E-01 2.0E-06 6.0E-01
END
•
3 of 5
,.
929 Main-E-10-19-04
A
B
C
A*B/C
AJC
Al(1+A)
10*(1+A)
C/B
Al(1+AJC)
Johnson 2002 Evaluation
1.07E-01
4.29E+02
3.28E-03 =Q,o,~Oe
1.41E+04
3.28E+01
0.096989038
11.07406269
7.63E-06
3.18E-03
4 of 5
OK
•
•
,.
Trichloroethene.xls
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TO'"END"
END
RESULTS SHEET
INCREMENTAL RISK CALCULATIONS:
ll'\Cremental Hazard
risk from quotien1
vapo, from vapor
intrusion to intrusion to
indoor air, indoor air,
carcinogen non carcinogen
(unitless) (unilless)
1.SE-07 2.9E-04
MESSAGE AND ERROR SUMMARY BELOW: (DO NOT USE RESULTS IF ERRORS ARE PRESENT)
MESSAGE: Risk/HQ or risk-based soil concentration is based on a route-to-route extrapotation.
5 of 5
•
•
TABLE 4-3
SUMMARY OF PREDICTED RISKS AND HAZARD INDICES (POTENTIAL RESIDENTIAL SCENARIO) (a)
VAPOR INTRUSION EVALUATION
JFD ELECTRONICS/CHANNEL MASTER SITE
OXFORD, NORTH CAROLINA
Comoound SV-1
Cis-1,2,Dichloroethene NA
T etrachloroethene 7.9E-07
Trichloroethene 2.1E-07
Vinvl Chloride ND
Total Risk/HI (b): 1.0E-06
Notes:
HI -Hazard Index.
NA -Not Available. No dose-response value available.
ND -Compound not detected in this sample.
(a) Only detected compounds shown in this table.
Carclnoaenlc Risk
SV-2 SV-3 SV-4 SV-5 SV-1
NA ND ND ND 0.0001
7.6E-07 1.1E-07 8.9E-08 8.2E-08 0.0005
1.5E-07 ND ND ND 0.0004
5.7E-08 ND ND ND ND
9.7E-07 1.1 E-07 8.9E-08 8.2E-08 0.001
Noncarcinoaenic Hazard Quotient
SV-2 SV-3 SV-4 SV-5
0.013 ND ND ND
0.0005 0.00007 0.00006 0.00005
0.0003 ND ND ND
0.0002 ND ND ND
0.01 0.0001 0.0001 0.0001
(b) Cumulative site risks less than 1E-04 and hazard indices less than 1 are considered acceptable and do not warrant further action (USE PA, 1991 ;2000).
J:~ndl_Service\Project Files\Channel Master\VI Modeling\J&E Models\Revised_Models\Summary_ Table.xlsSummary 6/16/2008
•
•
r • •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
4WD-SRSEB
William H. Doucette, Jr., PhD. L.G.
Senior Program Manager
ENSR International
7041 Old Wake Forest Road
Raleigh, NC 27616-3013
MAR I 9 2008_
Subject: Summary Report of Additional Data Collection
Related to 5-Y ear Review
JFD Electronics/Channel Master Site
Dear Mr. Doucette:
The United States Environmental Protection Agency (EPA) has reviewed ENSR's
February 2007, Summary Report of Additional Data Collection Related to 5-Year Review.
JFD Electronics/Channel Master Site, Oxford, North Carolina. EPA 's comments are
provided in the enclosure.
If you have any questions or require clarifications, do not hesitate to call me at 404-
562-8953.
Branch
Sincerely,
~~V\J~A Ak,~
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial and Site Evaluation
Enclosure
cc: David Mattison, NCDENR, Superfund Section
Dave Jenkins, EPA, SRTSB
Ofia Hodoh, EPA, SRTSB
lnterne: AddrP.ss (URL)• http'/l1MVw ep;,;.gov
Recycled/Recyclabh• • P11;1ted with l/,;g,:;t,;1hle 011 Based lrll'.s on Recycler! Paper (Minimum :',0',,~ Postconsurner)
/ i •
EPA's Comments on the
Summary Report of Additional Data Collection Related to 5-Year Review
JFD Electronics/Channel Master Site, Oxford, North Carolina
General Comments:
I. In 2002, the USEPA released Subsurface Vapor Intrusion Guidance (USEPA,
2002c) that recommends a tiered approach for evaluating the vapor intrusion
pathway and includes a series of questions that guides users through a stepwise
evaluation of the subsurface vapor intrusion pathway. The US EPA 's
recommended approach for assessment of the vapor intrusion pathway includes
the evaluation of multiple lines of evidence, if available. Once the potential for a
vapor intrusion pathway is established, it is appropriate to evaluate whether
physical and/or chemical processes completed this pathway and, if so, to evaluate
the potential risk to human health. A section should be presented which includes
a discussion of multiple lines of evidence used in the evaluation. This evaluation
is consistent with the USEPA's recommended approach for assessment of the
vapor intrusion pathway. The tiered approach should include the following: Tier
1 -Screening; Tier 2 -Site Specific Data Evaluation and Tier 3 -Detailed Vapor
Intrusion Pathway Assessment. Appendix C of the Subsurface Vapor Intrusion
Guidance contains a flow diagram depicting this tiered approach. Please revise
Section 4 to incorporate the tiered approach. Please revise calculations,
corresponding text and tables.
2. Based on the current data, sampling for soil gas vapors should be conducted
quarterly or semiannually as long as a plume exists at the site.
Specific Comments:
I. Section 4.2. Dose-Response Assessment
Please change the cis-1,2-Dichloroethylene inhalation reference concentration
from 3.SE-02 mg/m1 to 6.0E-2 mg/m1. Given the similarity between the oral
values and between target organs, it is reasonable to use the p-RfC (EPA-PROV)
derived for trans-1,2-Dichloroethylene as a surrogate value for the cis-1,2-
Dichloroethylene for the expressed purpose of calculating a Hazard Quotient.
Please revise calculations, corresponding text and tables.
2. Section 4. 2. Dose-Response Assessment
EPA recommends that the total potential carcinogenic risk be calculated two
different ways ifTCE is a COPC: I) using the upper end of the draft provisional
USEPA range of CSF for TCE: and 2) using the California EPA's Office of
Environmental Health and Hazard Assessment (OEHHA) CSF for TCE: The
IRIS value published in 1989 (6.0E-03 (mg/kg-d)" 1) has been withdrawn. In its
place, two values were published by ORD in 200 I in a draft risk assessment that
represent a range of slope factors. The less conservative slope factor is 2.0E-02
1
; ✓ ' •
(rng/kg-dJ-I. while the more conservative value is 4.0E-0 I (mg/kg-dJ-I_ ORD did not provide guidance on selecting from these values. The risk assessment has been reviewed by the National Academy of Sciences and EPA is in the process of finalizing the draft. The issue of TCE toxicity continues to undergo review both
within EPA and by external groups. In 2002 the State of California (CalEPA)
published an inhalation slope factor of 7.0E-03 (mg/kg-dJ-I. which is equivalent
to a unit risk of 2E-06 (ug/m3 )-1, and the RfC value is 6E-0 I mg/m1. Cal EPA
values arc in the Tier 3 hierarchy of toxicity values for EPA in the absence of
values in IRIS and the Provisional Peer Reviewed Toxicity Values for Superfund
(PPRTV) database. The CalEPA cancer potency factor has undergone extensive
peer review, is consistent with the hierarchy of toxicity criteria defined by OSRTI, and presently being used by EPA OAQPS as a screening value for air toxics risk assessments. EPA recommends that you take a site-specific approach that utilizes a range of available cancer potency values. Although this doesn't constitute
Regional or EPA policy, in the interim until the Agency completes the TCE risk assessment and provides final guidance on recommended toxicity values, EPA suggest using the 200 I draft cancer potency factors and the CalEPA inhalation
slope factor value as bounds. Please revise calculations, corresponding text and
tables.
References:
Cal EPA (California Environmental Protection Agency). 2002. Air Toxics Hot Spot
Program.
Risk Assessment Guidelines. Part 2. Technical Support Document for Describing Available Cancer Potency Factors. Sacramento, CA: Office of Environmental Health Hazard Assessment. Available:
http://www.ochha.ca.gov/air/cancer guide/TS!)~ .html#download.
EPA 2002c. Drqft Guidance.for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor Intrusion Guidance). Office of Solid Waste and Emergency Response, FR Notice November 29, 2002.
IRIS, 2008. Integrated Risk and Information System, National Center for Environmental Assessment. Office of Research & Development, USEPA (website jwww.epa.gov/irisJ,
updates added periodically).
EPA-PROV. EPA provisional toxicity values support document available on request
from Tt!chnical Support Section, EPA Region 4.
2
Eiih •
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R Matthews, Director Division of Waste Management Michael F. Easley, Governor
William G. Ross Jr., Secretary
March 29, 2007
TO: David Mattison
FROM:
I. No comments.
David Lilley
RE: Comments on the Indoor Modeling and Risk
Evaluation portions of the Summary Report of Additional
Data Collection Related to 5-Year Review, JFD
Electronics/Channel Master Site, Oxford, NC
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] I FAX [phone] I Internet http://wastenotnc.org
An Equal Opportunity / A.ffimiative Action Employer~ Printed on Dual Pu,1>0se Recycled Paper
• • ENSR ;\l ( '.),\I
Letter of Transmittal
ATTENTION:
Mr. David Mattison
Division of Solid Waste Management
Superfund Section
NCDEHNR
401 Oberlin Road
Raleigh, North Carolina 27605
PROJECT REFERENCE:
JFD Electronics/Channel Master Site
DATE:
2/15/07
PROJECT NUMBER:
10140-008
WE ARE SENDING YOU THE FOLLOWING:
Number of Number of
Originals Copies Description
1 Summary Report of Additional Data Collection Related to 5-Year Review, JFD
Electronics/Channel Master Site, Oxford, North Carolina
REMARKS:
ENSR respectfully submits one copy of the Summary Report of Additional Data Collection Related to 5-Year
Review t prepared for JFD Electronics/Channel Master site in Oxford, North Carolina.
I you have any questions, please do not hesitate to contact me or Nanjun Shelly at [phone].
SIGNATURE:
ENSR Consulting and Engineering (NC), Inc.
Gerald Hornaday, P.E.
Project Engineer
7041 Old Wake Forest Road
Suite 103
Raleigh, NC 27616
[phone]
•
ENSR Consulting & Engineering (NC), Inc.
7041 Old Wake Forest Road, Suite 103, Raleigh, North Carolina 27616
T 919 872 6600 F 919 872 7996 www.ensr.aecom.com
March 29, 2006
Mr. Ken Lucas
U.S. Environmental Protection Agency
Region IV
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303-8960
• ENSR I AECOM
Subject: Response to Comments on the Work Plan for Additional Data Collection, 5-Year Review
JFD Electronics/Channel Master Site, Oxford, North Carolina
Proposal No. 10140-008. 700
Dear Mr. Lucas,
On behalf of JFD Electronics/Channel Master, ENSR Consulting and Engineering (NC), Inc. (ENSR)
prepared this letter summarizing the March 14, 2006 telephone conversation between United States
Environmental Protection Agency (EPA) and ENSR personnel regarding EPA's March 8, 2006 comments on
the January 30, 2006 work plan prepared by ENSR to collect additional data at above referenced site. The
March 8, 2006 letter approved the work plan and requested modifications to the plan and schedule. The
following sections summarize the key issues discussed on March 14, 2006.
Indoor Vapor Migration Evaluation
The work plan proposed collecting four soil gas samples west of the Oak.Ridge Housing Development (Oak
Ridge) property. As discussed on March 14, 2006, the proposed soil vapor sampling locations were revised
as presented in Figure 1 (enclosed). According to Figure 1, two soil gas samples will be collected directly
south of the building located southwest on the Oak Ridge property and the other two samples will be
collected east of recovery well PW-4.
As discussed with EPA, ENSR revised the proposed schedule for the work plan implementation (enclosed).
The revised schedule includes collection and analysis of groundwater samples beneath streams prior to
· collecting soil gas sampling.
Groundwater Discharge to Surface Water
ENSR understands thai the proposed locations of groundwater sampling beneath streams in the work plan
are approximate. Actual sampling locations may be changed based on field conditions. ENSR also
understands that additional samples may be required to fill data gaps based on field analysis of the samples
collected from the proposed locations. As suggested by EPA, an attempt will be made to collect water
levels at each push-point (1/8-inch diameter stainless steel Henry sampler) to estimate vertical hydraulic
gradients. If sufficient vertical hydraulic gradients are present, groundwater samples will be collected under
natural flow conditions without the use of a pump.
S:\PUBS\PROJECT\C\ChannelMaster.5-Yr
Tech_Strategy_tmp (10140-008
C011!'d)\Cofrespondence\Lucas_resp_to_commen1s
_032906.doc
Mr. Ken Lucas
Page 2
March 28, 2006
• •
As proposed in the work plan, 25 percent (up to 5 samples) of samples will be analyzed in a fixed laboratory
to verify concentrations detected by Color-Tee tubes. As recommended by EPA, these samples will include
two samples indicated Color-Tee tubes to be ·non-detect" for volatile organic compounds (VOCs). One of
these "non-detect" samples will be from down stream of the site and one up stream from the site.
As discussed on March 14, it is our understanding that Mr. Dave Jenkins, EPA, will be present during
sampling groundwater beneath the streams. To assist in his scheduling, we have planned this sampling
program for the week beginning April 17, 2006. ENSR will proceed with the implementation of this
additional data collection program in accordance with the revised schedule.
If you need more information or have questions, please contact the following at 919-872-6600.
Sincerely,
ENSR Consulting and Engineering (NC), Inc.
Nanjun Shelly, P .E.
Project Manager
Copy:
B. Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
S. Earp, Smith Moore
G. Hornaday, ENSR
D. Jenkins, EPA
D. Mattison, NCDENR
S:\PUBS\PROJEC1'C\Channe1Master\5-Yr
Tech_ Strategy _I mp ( 10140-008
cont'd),Correspondence\Lucas_resp_to_comments
_032906.doc
William H. Doucette, Jr., Ph.D., P.G.
Project Coordinator
ENSR I AECOM
"' 0 0
0
! I I I '
i I
\ I
I
' ' I
•
1-------------1~ z 0
i
PROPOSED SOIL VAPOR AND
GROUNDWATER SAMPLING LOCATIONS
i JFD [lecff'Onlc•/Chonnal Wairter Site
l":~~:==i=='=''~•"'§·~'~"='"'~·=~="'::';;;;;E,;;;;;;;:::::J r !ICNL, O,,,Tt, -.io;t--
1·-200· 3/ZZ/ot 10UO--00II
•
ENSR I AECOM
0 ◊
()
0
/
u
I
/
◊
Figure 3
Preliminary Schedule of Additional Data Collection
JFD Electronics/Channel Master Site
Oxford, North Caroilna
ID Task Name I Duration IAoril Mav I June Julv
3126 I 412 I 419 I 4116 I 4123 I 4130 I 5(7 I 5114 I 5121 I 5128 I 614 I 6111 6118 I 6125 I 712 I 719
1 Field Work Planning 10 days
I I
10 davs
-·-----" ----2 Groundwater Sampling Beneath 5 days 5 da s
Stream
------·-""" 3 Laboratory Analysis 10 days 10 days • {Groundwater} 41 f-
" --4 ·soil -Gas Probe Installation & 5 days 5 davs
Sampling r-11 ~ 5 Laboratory Analysis (Soil Gas) 10 days 10 davs
~ 6 Evaluation of Vapor Migration 10 days 10 days
into Residential Buildings ,_
7 EvalUatiOrl of SOuie Ai'ea Mass 10 days ~ 10 days
Removal Options
• -~-"~----"" -----8 Report Preparation 10 days 10 days
., I
!
Task I Rolled Up Task I I Project Summary 1'3-lflF:H 4 @
Split Rolled Up Split External Milestone ♦ '''"'''''''''''''''''''''''"""'''' ''''''''''''"''''''''''''''''''''''''
Project: Work.plan_ schd _Mar_ 06 Progress Rolled Up Milestone 0 Deadline 9 Date: Wed 3/29/06
Milestone ♦ Rolled Up Progress
Summary • • External Tasks I I
Page 1
•• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
4WD-SRSEB
William H. Doucette, Jr., PhD. L.G.
Senior Program Manager
ENSR International
7041 Old Wake Forest Road
Raleigh, NC 27616-3013
NOV 2 9 2005
Subject: November 14, 2005 Letter of Response
Technical Memorandum Issues
JFD Electronics/Channel Master Site
Dear Mr. Doucette:
The United States Environmental Protection Agency (EPA) has reviewed ENSR's,
November 14, 2005, response to EPA's September 22nd comment letter. EPA concurs with
ENSR's proposed approach to resolution of the three issues identified; i.e., potential for vapor
intrusion, ground water discharge to unnamed tributaries, and evaluation of source area mass
removal options. You are directed to proceed with the development of a work plan to address
each of these issues.
If you have any questions or require clarifications, do not hesitate to call me at 404-562-8953.
Enclosures
Sincerely, I
\ / \ ~ ''\,'\,'\ ,, 'f'-..\ :/\ ~/ ' V ,_},\._.; \ __ /
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial and Site Evaluation Branch
cc: David Mattison, NCDENR, Superfund Section
Dave Jenkins, EPA, SRTSB
Internet Address (URL)• http:flwww.epa.gov
Recycled/Recyclablo • Printed with Vegetable Oil Based Inks on Recycled Paper (Mlnirnum 30% Poslconsumer)
" • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
,\TlANTA, GEORGIA 30303-8960
SEP 2 2 2005
4WD-SRSEB
William H. Doucette, Jr., PhD., LG.
Senior Program Manager
ENSR International
7041 Old Wake Forest Road
Raleigh, NC 27616-3013
Subject: Technical Memorandum Concerning Issues Raised During Initial 5-Year Review,
JFD Electronics/Channel Master Site
Dear Mr. Doucette:
The United States Environmental Protection Agency (EPA) has reviewed ENSR's, July 15, 2005,
Technical Memorandum Concerning Issues Raised During Initial 5-Year Review, JFD
Electronics/Channel Master Site, O:iford, North Carolina. This document was submitted
pursuant to Sections VII, Vlll, and XXVII of the Consent Decree between the United States of
America and JFD Electronics Corporation and Channel Master Satellite System, Inc., Civil
Action No. 93-650-CIV-56. EPA's review of the submission has revealed concerns regarding
the effectiveness of the current remedy and questions about what additional work may be needed
to evaluate potential modifications.
From the work done by ENSR in support of the five year review, it is evident that significant
contamination remains at the site and may be impacting adjacent property. Recommendations in
the draft five year review report were made to modify the remedial measures identified in the
Record of Decision (ROD). Support for the proposed modifications rely heavily on groundwater
modeling; however, data from actual measurements at the site must confirm the accuracy of the
model in order to provide a basis for remedy modification. If the model is confirmed, an
additional concern arises since the model indicates that significant contamination related to the
JFD site will still be present even after 50 years of pumping. This calls into question conclusions
reached during previous investigations and the overall effectiveness of the existing remedy.
The Technical Memorandum (TM) stated that the plume is naturally contained by discharge to
surface water features within the capture zone boundaries of the extraction wells. As a result of
this conclusion , a recommendation was made to terminate pumping in some down gradient
wells.
Internet Address (URL)• http://www.epa.gov
Recycled1Rec•iclablll • Prin!ed wilh Vegetalil.: Oil BaSl:!d luks on Recycled Paper (Minimum :JO% Pos:c.onsumet)
• •
EPA disagrees with the conclusion and has determined that termination of pumping in the down
gradient wells should not occur before completion of additional investigations. EPA has
determined that the proposed sampling with push-point samplers should be extended up stream
from the locations designated on Figure 1-1 of the TM work plan. The sample locations
presented primarily address the question of groundwater contribution to the contamination of
indoor air, and do not provide sufficient information regarding the effectiveness of the extraction
well capture zones. If the push-point samples show contamination is reaching the streams in
unexpected areas or at unacceptable concentrations, additional monitoring points may need to be
installed. EPA has also concluded that additional monitoring wells should be installed to provide
water level and quality information in the fractured rock beneath the most contaminated portions
of the aquifer.
The enclosures to this letter will provide more specific comments on the Technical Memorandum
(TM) as well as technical direction on the "Strategy Memorandum" which was included as
Attachment I. If you have any questions or require clarifications, do not hesitate to call me at
404-562-8953.
Enclosures
cc: David Mattison, NCDENR
Sincerely,
~/vVv\.:t! _k-Q~~
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial and Site Evaluation Branch
2
• •
EPA's Comments on the Technical Memorandum
Natural Attenuation
The Tech Memorandum (TM) summarizes North Carolina Department of Environment and
Natural Resources (NCDENR) regulations regarding the applicability of Monitored Natural
Attenuation (MNA) to this site, and concludes that the conditions have been met. The necessary
investigation and documentation which comply with EPA guidelines have not been performed.
Further, EPA does not agree that all of the NCDENR requirements have been met except for the
evaluation of the contaminant capacity to degrade or attenuate. The TM lists IO rules from Title
!SA North Carolina Administrative Code (NCAC) 2L.0106. EPA's concerns regarding seven·of
the conditions are discussed below:
(I) "all sources of contamination and free product must be removed or controlled pursuant to
Paragraph (f) of this Rule;". The TM states on page 3 that sufficient residual
contamination exists within the source area to act as a long term source for groundwater
contamination. Groundwater concentrations in some wells exceed both the I percent and
10 percent solubility limit rules of thumb commonly used to indicate the presence of
residual free-product contamination. Therefore, it is clear that the contamination has not
been removed, and it is not clear that it is being controlled. Therefore, in addition to an
evaluation of natural attenuation, an evaluation of the capture zone created by the existing
extraction wells should be a major element of this work plan as well as an evaluation of
mechanisms for removing the remaining source contamination.
(2) "that the contaminant has the capacity to degrade or attenuate under the site-specific
conditions;" The required site-specific investigation has not been performed. This
investigation is a necessary step to demonstrate that contaminant migration will not result
in any violation of applicable groundwater standards any existing or foreseeable receptor
(condition 4).
(3)
(4)
(5)
"The time and direction of contaminant travel can be predicted with reasonable
certainty;". This may be true, except for areas where no monitoring wells exist in the
vicinity of the extraction wells.
" that contaminant migration will not result in any violation of applicable groundwater
standards any existing or foreseeable receptor". This may be an appropriate conclusion
after the MNA evaluation is concluded.
"that contaminants have not and will not migrate onto adjacent properties, or that: (A)
such properties are served by an existing water supply .... (B) the owners of such
properties have consented ... "The contaminants have already migrated to adjacent
properties, but public water supplies are provided to these properties as specified in
EPA Comments on Tech Memo Page I of 3
• •
Condition SA. However. the prnposal to turn off 3 of 7 wells will increase contaminant
concentrations in a portion of the aquifer, but may not increase the area of contamination.
Whether this increase is acceptable to EPA will depend on the results of further
investigations, including an MNA investigation which follows EPA guidelines {See
Conditions 2, 4, 6 & 7), and investigations which provide field data to prove the
effectiveness of the capture zone created by the other extraction wells which would
remain in service.
(6) "that, if the contaminant plume is expected to intercept surface waters, the groundwater
discharge will not possess contaminant concentrations that would result in violations of
standards for surface waters contained in ISA NCAC 2B.0200". The work plan in the
TM (Figure 1-1) seems to designate the point of compliance for groundwater impact to ·
surface water as being only in the vicinity of the Oak Ridge Housing Development. The
groundwater model results show that the points of compliance should be considered to be
further up stream where groundwater contamination is predicted to discharge to surface
water. The sampling scheme outlined in the TM should be continued up stream to
confirm that surface water violations of ARARs, including ISA NCAC 28.0200 are not
occurring, thereby confirming the validity of the groundwater model with field ·
observations.
(7) "that a person making the request will pt in place a groundwater monitoring program
sufficient to track the degradation and attenuation of contaminants ... at least one year's
time of travel upgradient of the receptor ... ". The existing wells may not be sufficient to
detect the down gradient edge of the plume if the plume expands after termination of
pumping at the 3 off-site extraction wells. If the MN A investigation shows that
contaminant concentrations will decline, the existing monitoring wells {CMMW23 & 24),
plus samples from the unused pumping wells {PW2, 3 & 4) may be sufficient for
pumoses of down gradient monitoring.
Re-Evaluation of the Design & Operation of the Existing Groundwater Recovery
Indoor Air Evaluation
The TM states on page 3 that groundwater transport modeling shows that the JFD source area is
not a potential contributor to indoor air contamination at the Oxford Housing Complex. EPA
agrees that this is what the model shows but the effectiveness of the capture zone created by the
pumping wells has not been conclusively demonstrated based on real field measurements made at
the site. The conclusions of the model must be confirmed with field observations. Note that the
text on page 3 of the TM refers to the Oxford Housing complex, while all of the Figures in the
TM identify this residential area as the Oak Ridge Housing Development.
EPA Comments on Tech Memo Page 2 of 3
• •
Source Area Contamination Contribution to Off-Site Areas
As stated in the Tech Memorandum, there are three potential receptors which might be effected if
the proposal to discontinue pumping the down gradient wells is implemented. These are I.)
drinking water from local wells, 2.) indoor air and 3.) surface water. There are no known
drinking water supply wells in the vicinity of the plumes, but impacts on indoor air quality and
· on surface water require evaluation ..
The Tech Memorandum dismisses concern for impacts on surface water because no impacts on
surface water were detected above ARARs during the Remedial Investigation. The data for this
investigation was collected nearly a decade prior to installation of the extraction wells. The
investigation proposed in-the Tech Memorandum will not confirm these conclusions with current
data. The nearest proposed sample locations shown on Figure 1-1 of the Tech Memorandum are
hundreds of feet down stream from the groundwater discharge areas predicted by the
groundwater model. Geologic cross-sections showing relationships between the plume, the
stream and the monitoring and pumping well screens need to be presented.
The "push-point" sampling effort described in the TM should continue up stream at least to the
vicinity of CMMW0S, due to the high concentrations of VOCs in groundwater from CMMW0S
and CMMW 10. If groundwater from this vicinity is reaching the stream, the capture zones
created by the pumping wells are inadequate. Similarly, if contamination is detected beneath the
streams in areas where contributions from the JFD site seem unlikely, the explanation may be
previously undetected contamination from the Cristex property. Such a detection probably
would favor removing the 3 down gradient extraction wells from the JFD Operation and
Maintenance plan.
Contamination in Bedrock
The TM (p.3) states that information for various monitoring events does not show an increasing
trend in contaminant concentrations in the bedrock. Yet there are only 2 shallow bedrock wells
(CMMW07&18) and one deep bedrock (CMMWI 7) well.in the monitoring well network .. None. ··"
of these wells are on site, and none of these wells are in the vicinity of the source area near the
most contaminated wells. These wells ·are too far from the source area to support the conclusions
presented in the TM.
The overall trend for DCE in CMMW 17 has been upward, and some MCL exceedances for DCE
have been observed. CMMW 17 is a deep bedrock well 600 feet from the source area. The
upward DCE trend maybe proof that natural attenuation is occurring. But contamination is in the
bedrock and the vertical extent of contamination has not been defined. This well has also been
effected by spikes of water more highly contaminated with PCE and TCE. The source of the
contaminated water is unknown. CMMW 17 is beyond the capture zone of PW 1, so
contamination in this area would not be captured and treated, and would discharge to strea_ms if
PW2 is turned off. Historic data for all 3 wells (CMMW07, 16 and 17) in this cluster should be
EPA Comments on Tech Memo Page 3 of 3
• •
plotted at the same scale and evaluated.
CMMW0S and l 0 are the most contaminated wells on the site. The deeper well of this pair,
CMMW0S, is much more contaminated than the shallow well, suggesting that downward
migration of contamination is occurring. There are no bedrock wells in this area. The vertical
extent of contamination has not been determined. Additionally, the PCE and TCE concentrations
in CMMW0S and IO are between I and 11 percent of the solubility limits for these contaminants.
Higher concentrations can be assumed to be present in the aquifer. Total chlorinated VOC
concentrations as high as 166 ppm have been observed in the past (TM p.3). These contaminants
are heavier than water, and typically tend to migrate vertically downward. Contaminants may be
migrating beneath shallow wells, or migrating in fractures before returning to the local streams.
Contamination probably is-present in the bedrock beneath the source area up gradient from the
PW5 wells, but there are no bedrock monitoring wells in this area.
Contribution From Releases At the Cristex Drum Dump
The information provided in the 5-Year Review report and the current Technical Memorandum
show that a second source on an adjacent, but otherwise unrelated property (Cristex), is
contributing to the groundwater contamination being pumped by some of the JFD extraction
wells. Contaminant releases and disposal practices at the Cristex site are presumably unrelated
to the JFD property. However, plumes of contaminated groundwater from both sites discharge to
the same surface water streams in the area making attribution of contamination near the stream to
one source or the other difficult. The conclusions regarding the Cristex plume are based on a
groundwater model. The conclusions of the groundwater model must be confirmed by field
measurements. The model results strongly implicate the Cristex property as the sole and only
party responsible for potential contamination beneath the Oak Ridge Housing Development.
These model results must be confirmed by field observations. If possible, demonstration that
contamination found in the streams and beneath the housing development does not originate on
the JFD side of the stream should be acquired. The graph showing water quality versus time for
well CMMW26 shows that this well was contaminated prior to the initiation of the pump & treat
system in April, 2000, but has been uncontaminated since the second year after pumping began.
Pumping at PW l may have altered groundwater flow directions in the vicinity of CMMW26,
bringing clean water past this well. However, the groundwater flow model results imply that
pumping at PW I should have little impact on CMMW26. The history of contamination and
groundwater flow directions in the area between CMMW05, CMMW13 and CMMW26 should
be interpreted before the field sampling activities described in the TM work plan are initiated. A
preliminary statement regarding whether this contamination was from JFD or Cristex should be
included in a revised site concept model. Any data gaps which would support the preliminary
interpretation, or confirm that the source is not the JFD property should be acquired during the
field investigation. CMMW26 should be monitored and sampled for VOCs, especially if any
changes are made in the pumping system at JFD.
EPA Comments on Tech Memo Page 4 of 3
• •
EPA's comments on Attachment 1 Strategy Memorandum
Technical Direction
General Direction
EPA is directing the Settling Defendants to develop a focused feasability study to evaluate
potential remedial measures for the source zone. Section 5.2 of the draft 5-Year Review
discussed two potential remedial technologies. Electrical Resistance Heating (ERH) was
dismissed for cost reasons. A second technology, Enhanced Reductive Dechlorination (ERO),
was pilot tested at this site. This technology" ... was determined to be ineffective for the
remediation of dense non-aqueous phase liquid (DNAPL) ... " (Draft 5 Year Review Report p. 5-
5). Another technology, which has become-available in recent years, is surfactant flushing and
recovery. This technology relies" ... on mobilizing DNAPL by significantly increasing the
aqueous solubility of DNAPL compo11e11ts and reducing interfacial tension to increase the rate of
DNAPL extraction. The cost-effectiveness oftlze technologies depends, in part, on recovery of the
}lushing solutio11Sfollowillg extractioll" (EPA/600/R-03/143, December 2003). This technology
may be suitable for this site because a pumping recovery system already exists, and because the
hydraulic system has a defined bottom and a surface water discharge area, both of which which
limit the hydraulic system, so the potential for escape of mobilized fluids from the system can be
controlled.
The cost analysis should be re-evaluated for all three of these technologies. The cost of these
technologies should be compared with the cost of the existing remedial measure for periods
longer than 30 years because the available data clearly show that the existing remedial measure
makes little progress in weakening the source area after 50 years. Costs should be calculated for
30, 50 and 100 years.
The following additions are needed to the proposal presented in Attachment I for evaluation of
natural attenuation, sampling of groundwater beneath creeks/unnamed tributaries, and indoor air
quality evaluation.
1.1 Evaluation of Natural Attenuation
Background Well
An appropriate background well should be selected and included in the MNA plan. No
background wells are included in the monitoring proposal. One of the western most wells on the
JFD site should be added to the long-term monitoring well list. Well CMMW09 seems
appropriate based on groundwater flow directions. Information regarding the location of the well
screen relative to the location of the contamination source and the well screens in the monitoring
wells already selected for the MNA investigation must be evaluated prior to selection of this as a
background well. MNA indicator parameters, field chemistry and the depth to water should be
measured in the up gradient well on the same schedule as other monitoring wells.
EPA Comments on Strategy Memo Page I of 3
• •
Monitoring Parameters
The semi-annual monitoring schedule proposed in the TM for the MNA investigation is adequate
given the frequency of monitoring and analysis for VOCs which has occurred since April, 2000.
Measurements of field parameters (depth to water, dissolved oxygen, ORP, pH, temperature and
conductivity) should already be available for each of the historic analyses. Consequently, the
new information collected during this portion of the investigation primarily will be the
"Degradation Byproducts and End Products" and analyses in the "Others" category (TM
Attachment I page 2). Presumably, these groundwater characteristics in the down gradient
portion of the plume are in equilibrium with conditions in the plume. Therefore, the data
evaluation proposed on page 3 should occur after the first year of data is available, not after two
years. The time-series graphs for VOCs in Appendix ·B of the draft 5-Year Review Report
should be up dated as data is available. The field chemistry data should be plotted in map-view.
The electron donor data from each sample event could be plotted in radial plot format (See
References). If these plots are consistent between sample events, and if the VOC trends continue
downward, the site may be ready for an evaluation of MNA after one year, with subsequent
monitoring events scheduled on an annual basis until the next 5-Year Review.
1.2 Groundwater Sampling Beneath Unnamed Tributaries
Regarding sample collection methods and water level measurements, the text states that a
peristaltic pump will be used to collect the groundwater samples from the push point locations.
A pump may not be necessary if the upward hydraulic gradient is sufficient for natural flow into
the sample container. Hopefully, unnecessary expense for equipment decontamination can be
avoided. Peristaltic pumps should not be used until the water level in the tube attached to the
push point has been determined, and the water level and flow rate are observed to be
inappropriate for sample collection without a pump. Water level elevations in the tubing should
be measured to the nearest hundredth of a foot above or below the water surface and recorded on
the sample collection record.
Sampling with push-point samplers should. be extended up stream from the locations designated
on Figure 1-1 of the TM work plan. The sample locations presented primarily address the
question of groundwater contribution to the contamination of indoor air, and do not provide
current information regarding the effectiveness of the extraction well capture zones. The
proposed sample locations may not define all areas where contaminated groundwater is
discharging to surface water. The expanded sampling areas should proceed up stream at least to
the vicinity of CMMW0S.
1.3 Indoor Air Evaluation
The proposed work plan for the Indoor Air Evaluation (TM Section 1.3) doesn't specifically state
that the proposed investigation is a Tier 3 analysis of vapor intrusion to indoor air. But the
second step in the work plan includes use of the Johnson-Ettinger model to evaluate the risk
EPA Comments on Strategy Memo Page 2 of 3
• •
associated with the detected concentrations, which is the basis for evaluating Questions 5 and 6
in the Tier 3 Analysis. The appropriate EPA guidelines for analysis ·of vapor intrusion to indoor
air are cited.
The work plan appears to be appropriate to answer questions regarding whether a pathway
between groundwater contamination and indoor air has been completed, but it isn't clear whether
any site-specific measurements will be made or what sample methods will be used. In other
words, the work plan proposes a 2 step investigation of vapor intrusion to indoor air. Given that
groundwater contaminant concentrations in the vicinity of the housing development exceed the
MCLs by factors between 10 and 50, and given that depths to groundwater probably are less than
5 feet in some portions of the housing development, the work plan should discuss plans for
conducting a Tier 3 analysis should the preliminary steps indicate this to be necessary. The" ...
direct measurement of foundation air and/or indoor air concentrations from a subset of the
potentially affected buildings and complementary site-specific mathematical modeling as
appropriate ... " are recommended for Tier 3 assessments
(http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm ). Methods for collecting these samples should
be described. The plans should be made now rather than waiting for submission of an additional
work plan later.
REFERENCES
Byl, T.D. and S. D. Williams, Biodegradation of Chlorinated Ethenes at a Karst Site in
Middle Tennessee, USGS Water-Resources Investigations Report 99-4285.
http://water.usgs.gov/pubs/wri/wri994285/
(See Figure IO regarding presentation and interpretation of MNA data)
Chapelle, F.H., P.M. Bradley, and C.C. Casey, 2005, Behavior of a Chlorinated Ethene Plume
following Source-Area Treatment with Fenton's Reagent, Ground Water Monitoring &
Remediation, v.25 no.2, pp. 131-141.
Carey, G.R., P.J. Van Geel, T.H. Wiedemeier and E.A. McBean, 2003, A Modified Radial
Diagram Approach for Evaluating Natural Attenuation Trends for Chlorinated solvents
and Inorganic Redox Indicators; Ground Water Monitoring and Remediation, v.23, No.
4, pp75-84.
EPA Comments on Strategy Memo Page 3 of 3
•
November 14, 2005
Mr. Ken Lucas
U.S. Environmental Protection Agency
Region IV
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303-8960
•
ENSR International
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616-3013
PHONE [phone]
FAX [phone]
www.ensr.com
RE: Technical Memorandum Concerning Issues Raise During Initial 5-Year Review
JFD Electronics/Channel Master Site, Oxford, North Carolina
ENSR Project Number 10140-008
Dear Mr. Lucas:
On behalf of the Responding Parties (RPs), JFD Electronics Corporation and CMSS, Inc., ENSR
Consulting and Engineering (NC), Inc. (ENSR) offers a response to your letter of September 22,
2005 for your consideration. We note that the technical issues discussed in your letter can be
generally divided into issues related to performance of the existing remediation system and other
issues related to the RPs' request to consider downsizing the groundwater recovery system. We
suggest that our request to downsize the recovery system be postponed for the time being, while we
address the issues related to performance of the existing remediation system. Trying to tackle all the
issues at the same time would be overly complex. Our response thus focuses on three issues:
1. Potential for vapor intrusion into residential structures down plume,
2. Groundwater discharge to unnamed tributaries, and
3. Evaluation of source area mass removal options.
Other issues related to natural attenuation monitoring, contribution from releases at Cristex and
capture zone evaluation without three recovery wells (including groundwater model confirmation) can
be addressed as may be appropriate once the existing system performance issues are addressed.
Note that we see the questions that your September 22 letter raised regarding bedrock
contamination as relevant primarily to the latter evaluation of whether to turn off the three most down
plume recovery wells.
If you concur, ENSR will prepare a work plan to address the three primary issues set forth above.
The following sections describe the general approach to be used in addressing these issues.
Potential for vapor intrusion into residential structures down plume
As requested by EPA, ENSR proposes to perform a Tier 3 screening level human health risk
evaluation to evaluate the potential impact of VOCs detected in site groundwater (mainly PCE,
TCE and cis-1,2-DCE) that might have the potential to migrate from groundwater to the indoor
air in the apartment buildings located in the vicinity of groundwater well CMMW-23. This
S:\PUBS\PROJECnC\Chann11/Master\5-Yr_Review_lmp(10140008)\Conespondenca\Responss to 22SEPT2005 EPA ttr 11-14-2005.doc
Celebrating 30 Years of Excellence in Environmental Services
,-
November 14, 2005
Mr. Ken Lucas
Page 2
• •
evaluation will assess the potential risks associated with the indoor air inhalation exposure
pathway, to a resident living in the apartment buildings. ENSR will collect soil vapor samples
above the VOC plume at the property line directly upgradient (approximately 50 feet) from the
two residential structures near CMMW-23. We do not propose to take samples on the Oxford
Housing property itself, because the owners of that property have not cooperated with the RPs'
efforts to conduct the remedy and have refused permission to install a recovery well near
CMMW-23. Considering the distance from the source area (approximately 1,000 feet) and the
consistently low concentrations of VOCs in the groundwater throughout the area being
considered, taking soil vapor samples from the property boundary 50 feet away from the
apartment buildings should provide results that are representative of the Oxford Housing
property. Site related VOC concentrations detected in the vapor samples will be used in the
indoor air evaluation.
Compounds detected at concentrations above EPA's target concentrations will be evaluated
further using EPA's most current version of the Johnson and Ettinger model and guidance
(USEPA, 2004 a and b) to predict potential carcinogenic and noncarcinogenic risks associated
with inhaling compounds in indoor air that have volatilized from groundwater. This is a
screening-level model that incorporates both convective and diffusive mechanisms for
estimating the transport of vapors from groundwater at the site into indoor air. This screening
level model uses many default, conservative parameters, and site-specific modifications are
confined to the most sensitive parameters. Default input parameter values provided by EPA will
be used for modeling where site-specific information is unavailable. A report will be prepared
summarizing the details of this evaluation and appropriate recommendations.
Groundwater discharge to unnamed tributaries
As requested by EPA, additional data will be collected to evaluate if the groundwater VOCs are
discharging into unnamed tributaries/creeks at the site as predicted by the groundwater fate and
transport model (ENSR, 2005). ENSR will collect groundwater samples immediately below the
bed of the unnamed tributaries located south and east of the site (see attached Figure 1 ). The
samples will be collected approximately 50 to 100 feet apart in sections of the tributaries located
on Southgate Associates, Oxford Housing and CMSS, Inc. properties. ENSR will utilize driven
wellpoints (e.g., Henry's sampler or push-point sampler by M.H.E. Products) and field screening
for VOCs using ColorTech method. A peristaltic pump will be used to collect groundwater
samples from the wellpoints. It is assumed that a maximum of 15 groundwater samples will be
collected for field screening. Approximately 5 groundwater samples (25 percent) will be sent to
a fixed laboratory for analysis of VOCs using EPA Method 8260 for confirmation. Samples to
be analyzed in the laboratory will be based on the results of field screening using the ColorTech
method.
Groundwater sampling and equipment (including wellpoints) decontamination will be in
accordance with the procedures outlined in the Remedial Design Work Plan (Geraghty & Miller,
1993). The sample locations will be staked and later surveyed by a licensed surveyor.
E"11. nwum,ttt◄
November 14, 2005
Mr. Ken Lucas
Page 3
•
Evaluation of source area treatment options
•
The comments that were attached to your letter of September 22 directed the RPs to conduct "a
focused feasibility study to evaluate potential remedial measures for the source zone."
Confirming my telephone conversation with you, I understand that the purpose of such a study
is to better understand the relative costs of various technologies for source area treatment, not
to initiate a change in the existing remedy. To accomplish this purpose, we believe that a full-
scale feasibility study evaluation is not necessary. We propose a more direct evaluation of the
most commonly used technologies to reduce the mass of solvents in the source area without
the exhaustive screening of potential technologies and without the elaborate comparison of
remedial alternatives against the nine remedy selection criteria in the national contingency plan.
The evaluation will consist of a detailed description of the application of the technology at the
site, estimated costs and comparison of the technologies in terms of relative effectiveness,
implementatability and costs.
If this proposed scope of work is acceptable to EPA, ENSR will prepare a work plan to conduct the
three tasks described above for submittal on January 15, 2006 or 60 days from the date of your
written acceptance, whichever is later.
If you have any questions, please contact me at [phone].
Sincerely,
ENSR Consulting and Engineering (NC), Inc.
William H. Doucette, Jr., PhD, LG
Project Coordinator for the Responding Parties
Enclosure
cc: Brian Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
Nanju Shetty, ENSR
David Mattison, NCDENR
Steve Earp, Smith Moore
Fw: Franklin's and Alan's Signature -RESEI •
I of 4
Subject: Fw: Franklin's and Alan's Signature -RESEND
From: [e-mail]
Date: Mon, 26 Sep 2005 13:40:59 -0400
To: [e-mail]
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
U. S. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone: [phone]
fax : [phone]
Forwarded by Ken Lucas/R4/USEPA/US on 09/26/2005 01:40 PM-----
Gwendolyn
Arnold/R4/USEPA/
us
09/14/2005 10:05
AM
To
R4 WASTE Division -10th Floor,
Abby Rhodes/R4/USEPA/US@EPA, Al
Cherry/R4/USEPA/US@EPA, Amy
McLaughlin/R4/USEPA/US@EPA,
Angela Miller/R4/USEPA/US@EPA,
Angela Stevens/R4/USEPA/US@EPA,
Anita Davis/R4/USEPA/US@EPA, Ann
Mayweather/R4/USEPA/US@EPA,
Annette Woods/R4/USEPA/US@EPA,
Annette
Patterson/R4/USEPA/US@EPA, Archie
Lee/R4/USEPA/US@EPA, Art
Smith/R4/USEPA/US@EPA, Barbara
Dobson/R4/USEPA/US@EPA, Barbara
Schuster/R4/USEPA/US@EPA, Barbara
Scott/R4/USEPA/US@EPA, Benjamin
Franco/R4/USEPA/US@EPA, Beth
Walden/R4/USEPA/US@EPA, Betty
Winter/R4/USEPA/US@EPA, Beverly
Stepter/R4/USEPA/US@EPA, Bill
Denman/R4/USEPA/US@EPA, Blake
Sterling/R4/USEPA/US@EPA, Bob
Bittinger/R4/USEPA/US@EPA, Bob
Rosen/R4/USEPA/US@EPA, Brad
Jackson/R4/USEPA/US@EPA, Brandi
Jenkins/R4/USEPA/US@EPA, Brenda
Lane/R4/USEPA/US@EPA, Brenita
Richardson/R4/USEPA/US@EPA, Brian
Farrier/R4/USEPA/US@EPA, Brook
Bass/R4/USEPA/US@EPA, Carman
Mickles/R4/USEPA/US@EPA, Carmen
Santiago-Ocasio/R4/USEPA/US@EPA,
Carol Jackson/R4/USEPA/US@EPA,
Carol Monell/R4/USEPA/US@EPA,
Caroline
Robinson/R4/USEPA/US@EPA, Carolyn
Callihan/R4/USEPA/US@EPA, Carolyn
Haugabook/R4/USEPA/US@EPA,
Carolyn McCall/R4/USEPA/US@EPA,
Carter
Williamson/R4/USEPA/US@EPA,
Charles Swan/R4/USEPA/US@EPA,
CharlesL King/R4/USEPA/US@EPA,
Charlie
11/14/2005 10:44 AM
Fw: Franklin's and Alan's Signature -RESEI
2 of 4
• Fitzsimmons/ESC/R3/USEPA/US@EPA,
Charlotte
Whitley/R4/USEPA/US@EPA, Chris
Militscher/R4/USEPA/US@EPA, Chris
Russell/R4/USEPA/US@EPA, Chuck
Eger/R4/USEPA/US@EPA, Cindy
Gurley/R4/USEPA/US@EPA, Craig
Zeller/R4/USEPA/US@EPA, Curt
Fehn/R4/USEPA/US@EPA, David
Derokey/R4/USEPA/US@EPA, David
Keefer/R4/USEPA/US@EPA, Dean
Ullock/R4/USEPA/US@EPA, Debbie
Jourdan/R4/USEPA/US@EPA, Debbie
Vaughn-Wright/R4/USEPA/US@EPA,
Denise Bland/R4/USEPA/US@EPA,
Derek Matory/R4/USEPA/US@EPA, Don
Oberg/R4/USEPA/US@EPA, Don
Rigger/R4/USEPA/US@EPA, Donna
Bledsoe/R4/USEPA/US@EPA, Donna
Webster/R4/USEPA/US@EPA, Dora
Johnson/R4/USEPA/US@EPA, Dorothy
Rayfield/R4/USEPA/US@EPA, Felicia
Barnett/R4/USEPA/US@EPA, Felicia
Jackson/R4/USEPA/US@EPA, Femi
Akindele/R4/USEPA/US@EPA,
Fernando Rivera/R4/USEPA/US@EPA,
Franklin Hill/R4/USEPA/US@EPA,
Galo Jackson/R4/USEPA/US@EPA,
Giezelle Bennett/R4/USEPA/US@EPA,
Gordon Goff/R4/USEPA/US@EPA, Greg
Armstrong/R4/USEPA/US@EPA, Harold
Taylor/R4/USEPA/US@EPA, Hazel
Winborne/R4/USEPA/US@EPA, Helen
Scott/R4/USEPA/US@EPA, Henrietta
Coombs/R4/USEPA/US@EPA, Herbert
Miller/R4/USEPA/US@EPA, Heyward
Johnson/R4/USEPA/US@EPA, Humberto
Guzman/R4/USEPA/US@EPA, Jackie
Dendy/R4/USEPA/US@EPA, Jackie
Harvey/R4/USEPA/US@EPA,
Jacqueline
Curtis/R4/USEPA/US@EPA, James
Webster/R4/USEPA/US@EPA, Jamey
Watt/R4/USEPA/US@EPA, Jan
Rogers/R4/USEPA/US@EPA, Janice
Thomas/R4/USEPA/US@EPA, Jeffery
Crowley/DC/USEPA/US@EPA, Jenny
Holbrook/R4/USEPA/US@EPA,
Jennifer Wendel/R4/USEPA/US@EPA,
Jim McGuire/R4/USEPA/US@EPA, Jim
Miller/R4/USEPA/US@EPA, Joe
Alfano/R4/USEPA/US@EPA, John
Nolen/R4/USEPA/US@EPA, John
Zimmerman/R4/USEPA/US@EPA, Johnny
Morgan/R4/USEPA/US@EPA, Jon
Bornholm/R4/USEPA/US@EPA, Jose
Negron/R4/USEPA/US@EPA, Joyce
Brittian/R4/USEPA/US@EPA, Karen
Buerki/R4/USEPA/US@EPA, Karen
Knight/R4/USEPA/US@EPA, Katrina
Jones/R4/USEPA/US@EPA, Kay
Wischkaemper/R4/USEPA/US@EPA, Ken
Lucas/R4/USEPA/US@EPA, Ken
Mallary/R4/USEPA/US@EPA, Kerri
Sanders/R4/USEPA/US@EPA, Kevin
Misenheimer/R4/USEPA/US@EPA, Kim
Vandiver/R4/USEPA/US@EPA, Leo
11/14/2005 10:44 AM
Fw: Franklin's and Alan's Signature· RESEI
3 of 4
• Francendese/R4/USEPA/US@EPA,
Libby Holcomb/R4/USEPA/US@EPA,
Loften Carr/R4/USEPA/US@EPA, Luis
Flores/R4/USEPA/US@EPA, Maher
Budeir/R4/USEPA/US@EPA, Margaret
Roth/R4/USEPA/US@EPA, Mark
Fite/R4/USEPA/US@EPA, Marsha
Humphries/R4/USEPA/US@EPA, Mary
Starr/R4/USEPA/US@EPA, Maryjo
Bragan/R4/USEPA/US@EPA, Matt
Robbins/R4/USEPA/US@EPA, Matt
Taylor/R4/USEPA/US@EPA, Matthew
Monsees/R4/USEPA/US@EPA, Mel
Rechtman/R4/USEPA/US@EPA, Melissa
Waters/R4/USEPA/US@EPA, Michael
Arnett/R4/USEPA/US@EPA, Michael
Norman/R4/USEPA/US@EPA, Michael
Taylor/R4/USEPA/US@EPA, Michael
Townsend/R4/USEPA/US@EPA, Nestor
Young/R4/USEPA/US@EPA, Olga
Perry/R4/USEPA/US@EPA, Pam
Scully/R4/USEPA/US@EPA, Patricia
Goldberg/R4/USEPA/US@EPA, Paula
Batchelor/R4/USEPA/US@EPA, Paula
Walraven/R4/USEPA/US@EPA, Philip
Vorsatz/R4/USEPA/US@EPA, Ralph
Howard/R4/USEPA/US@EPA, Randall
Chaffins/R4/USEPA/US@EPA, Randy
Bryant/R4/USEPA/US@EPA, Randy
Jackson/R4/USEPA/US@EPA, Ray
Strickland/R4/USEPA/US@EPA,
Rhonda Foucher/R4/USEPA/US@EPA,
Richard Jardine/R4/USEPA/US@EPA,
Robert Morris/R4/USEPA/US@EPA,
Robert Stern/R4/USEPA/US@EPA,
Robert West/R4/USEPA/US@EPA,
Roberta Runge/LV/USEPA/US@EPA,
RobertG Stewart/R4/USEPA/US@EPA,
Rosemary Patton/R4/USEPA/US@EPA,
Rowena Sheffield/R4/USEPA/US@EPA,
Ruth Davidson/R4/USEPA/US@EPA,
Samantha
Urquhart-Foster/R4/USEPA/US@EPA,
Scott Sudweeks/R4/USEPA/US@EPA,
Shane Hitchcock/R4/USEPA/US@EPA,
Shea Jones/R4/USEPA/US@EPA,
Sherryl
Carbonaro/R4/USEPA/US@EPA, Steve
Spurlin/R4/USEPA/US@EPA, Steven
Sandler/R4/USEPA/US@EPA, Ted
Walden/R4/USEPA/US@EPA, Terrence
Byrd/R4/USEPA/US@EPA, Terry
Stilman/R4/USEPA/US@EPA, Terry
Tanner/R4/USEPA/US@EPA, Timothy
Neal/R4/USEPA/US@EPA, Tina
Davis/R4/USEPA/US@EPA, Tony
Moore/R4/USEPA/US@EPA, Vicki
Haley/R4/USEPA/US@EPA, Wanda
Carson/R4/USEPA/US@EPA, Warren
Dixon/R4/USEPA/US@EPA, Wes
Hardegree/R4/USEPA/US@EPA,
William Joyner/R4/USEPA/US@EPA,
William
Wilkerson/R4/USEPA/US@EPA,
YvonneO Jones/R4/USEPA/US@EPA
cc
11/14/2005 10:44 AM
Fw: Franklin's and Alan's Signature -RESEI
The signature block should read
Franklin E. Hill
Acting, Division Director
Waste Management Division
Superfund and Emergency Response
Alan Farmer
Acting, Division Director
Waste Management Division
• Subject
Franklin's and Alan's Signature -
RESEND
RCRA, Federal Facilities and Brownfields
4 of 4 11/14/2005 10:44 AM
RE: Jfd Electronics/Channel Master Site D,-Year Review Report •
l of 3
Subject: RE: Jfd Electronics/Channel Master Site Draft 5 -Year Review Report
From: "Steve Earp" <[e-mail]>
Date: Fri, 23 Sep 2005 08:37:29 -0400
To: "Doucette, Bill" <[e-mail]>, <[e-mail]>
CC: <[e-mail]>, <DA YID.MA [e-mail]>, "Shelly, Nanjun"
<[e-mail]>, <[e-mail]>
Ken, my primary worry about institutional controls is a practical one that involves
the difficulties that would be inevitable with off-site property owners. I have
talked with Dave Mattison about the peculiar circumstances there, and he can fill you
in, or I would be happy to talk with you about it at any time. Thanks for your
consideration of this. Steve
-----Original Message-----
Frorn: Doucette, Bill [mailto:[e-mail]]
Sent, Thursday, September 22, 2005 4,20 PM
To: [e-mail]
Cc, [e-mail]; [e-mail]; Shetty, Nanjun;
[e-mail]; Steve Earp
Subject: RE: Jfd Electronics/Channel Master Site Draft 5 -Year Review
Report
Ken: Thanks for considering our comments. We fully appreciate EPA has
considerable latitude in deciding remedial actions at the site,
including institutional controls. From our perspective the report should
provide a solid basis for the consideration of institutional controls at
this time and it does not. Considering institutional controls as a me~ns
to add protectiveness based on our analysis of the time to achieve ARARs
is very different than stating that the remedy will not be protective
without such controls or implying that such controls were mandated in
the ROD.· It makes sense that the issue should be framed around
evaluating the applicability and effectiveness of such controls as a
means to add protectiveness. A blanket statement that institutional
controls must be implemented is premature regardless of one"s reading of
the ROD. We believe the questions we raise in our letter of comment will
have to be answered before an institutional control, if any, can be
decided.
Thanks again for considering our comments.
William H. Doucette, Jr., Ph.D., P.G.
Project Coordinator for the Responding Parties, and
Regional Program Manager for
Integrated Site Closure Services
ENSR International
7041 Old Wake Forest Rd.
Raleigh, NC 27616
[phone]
-----Original Message-----
From: [e-mail] [mailto:[e-mail]]
Sent, Thursday, September 22, 2005 2,03 PM
To, Doucette, Bill
Cc: [e-mail]; [e-mail]; Shetty, Nanjun;
[e-mail]; [e-mail]
Subject: Re: Jfd Electronics/Channel Master Site Draft 5 -Year Review
Report
Bill,
11/14/2005 10:43 AM
RE: J fd Electronics/Channel Master Site Dr--Year Review Report •
2 of 3
Thank you for your input.
I've looked into the institutional controls language in the original
ROD. In Section X the ROD says, "EPA may require measures involving
long-term management for an indefinite period of time .
institutional controls may be provided/maintained to restrict access to
those portions of the aquifer which remain above remediation levels
. The decision to invoke . may be made during a periodic review of
the remedial action.
Since the work that ENSR did in support of the five year review revealed
that the system, as it is, will not restore the aquifer even for the
foreseeable future the recommendation to apply institutional controls
seems appropriate.
I will review the wording in the revised draft prior to its
finalization.
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
U. s. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone:
fax :
404-562-8953
404-562-8788
"Doucette, Bill 11
<BDoucette@ENSR.
com>.
09/22/2005 10:52
AM
Ken Lucas/R4/USEPA/US@EPA
[e-mail],
[e-mail],
[e-mail],
"Shetty, Nanjun"
<[e-mail]>,
[e-mail]
To
cc
Subject
Jfd Electronics/Channel Master
Site Draft 5 -Year Review Report
Ken, our comments on the institutional control issue. (See attached
file: Comments to Draft 5-Year Report 9-22-05.pdf)
IRS CIRCULAR 230 NOTICE: To ensure compliance with the requirements of IRS Circular
230, we inform you that any U.S. tax advice contained in this communication or
attachment hereto is not intended or written to be used and cannot be used for the
purpose of avoiding penalties under the Internal Revenue Code or for promoting,
marketing or recommending to another party any transaction or matter addressed in
this communication or attachment.
11/14/2005 10:43 AM
RE: Jfd Electronics/Channel Master Site Dw-Year Review Report •
3 of 3 l l/14/2005 10:43 AM
RE: Jfd Electronics/Channel Master Site D,-Year Review Report • ,·
l of 2
Subject: RE: Jfd Electronics/Channel Master Site Draft 5 -Year Review Report
From: "Doucette, Bill" <[e-mail]>
Date: Thu, 22 Sep 2005 16:19:38 -0400
To: <[e-mail]>
CC: <[e-mail]>, <DA YID.MA [e-mail]>, "Shetty, Nanjun"
<[e-mail]>, <[e-mail]>, <[e-mail]>
Ken: Thanks for considering our comments. We fully appreciate EPA has
considerable latitude in deciding remedial actions at the site,
including institutional controls. From our perspective the report should
provide a solid basis for the consideration of institutional controls at
this time and it does not. Considering institutional controls as a means
to add protectiveness based on our analysis of the time to achieve ARARs
is very different than stating that the remedy will not be protective
without such controls or implying that such controls were mandated in
the ROD. It makes sense that the issue should be framed around
evaluating the applicability and effectiveness of such controls as a
means to add protectiveness. A blanket statement that institutional
controls must be impleniented is premature regardless of one's reading of
the ROD. We believe the questions we raise in our letter of comment will
have to be answered before an institutional control, if any, can be
decided.
Thanks again for considering our comments.
William H. Doucette, Jr., Ph.D., P.G.
Project Coordinator for the Responding Parties, and
Regional Program Manager for
Integrated Site Closure Services
ENSR International
7041 Old Wake Forest Rd.
Raleigh, NC 27616
[phone]
-----Original Message-----
From: [e-mail] [mailto:[e-mail]
Sent: Thursday, September 22, 2005 2:03 PM
To: Doucette, Bill
Cc: [e-mail]; [e-mail]; Shetty, Nanjun;
[e-mail]; [e-mail]
Subject: Re: Jfd Electronics/Channel Master Site Draft 5 -Year Review
Report
Bill:
Thank you for your input.
I've looked into the institutional controls language in the original
ROD. In Section X the ROD says, "EPA may require measures involving
long-term management for an indefinite period of time ...
institutional controls may be provided/maintained to restrict access to
those portions of the aquifer which remain above remediation levels
. The decision to invoke ... may be made during a periodic review of
the remedial action.
Since the work that ENSR did in support of the five year review revealed
that the system, as it is, will not restore the aquifer even for the
foreseeable future the recommendation to apply institutional controls
seems appropriate.
11/14/2005 10:43 AM
~: Jfd Electronics/Channel Master Site Dw-Year Review Report • I will review the wording in the revised draft prior to its
finalization.
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
u. S. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone:
fax:
404-562-8953
404-562-8788
"Doucette, Bill"
<BDoucette@ENSR.
com>
09/22/2005 10:52
AM
Ken Lucas/R4/USEPA/US@EPA
[e-mail],
[e-mail],
[e-mail],
"Shetty, Nanjun"
<[e-mail]>,
[e-mail]
To
cc
Subject
Jfd Electronics/Channel Master
Site Draft 5 -Year Review Report
Ken, our comments on the institutional control issue. (See attached
file: Comments to Draft 5-Year Report 9-22-05.pdf)
2 of 2 11/14/2005 10:43 AM
Re: Jfd Electronics/Channel Master Site Dr,-Year Review Report • . -
l of 2
Subject: Re: Jfd Electronics/Channel Master Site Draft S -Year Review Report
From: [e-mail]
Date: Thu, 22 Sep 2005 14:03:20 -0400
To: "Doucette, Bill" <[e-mail]>
CC: [e-mail], DA YID.MA [e-mail], "Shetty, Nan jun"
<[e-mail]>, [e-mail], [e-mail]
Bill:
Thank you for your input.
I've looked into the institutional controls language in the original
ROD. In Section X the ROD says, "EPA may require measures involving
long-term management for an indefinite period of time ..
institutional controls may be provided/maintained to restrict access to
those portions of ·the aquifer wfiich remain above remediation levels
. The decision to invoke ... may be made during a periodic review of
the remedial action.
Since the work that ENSR did in support of the five year review revealed
that the system, as it is, will not restore the aquifer even for the
foreseeable future the recommendation to apply institutional controls
seems appropriate.
I will review the wording in the revised draft prior to its
finalization.
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
u. s. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone:
fax :
404-562-8953
404-562-8788
"Doucette, Bill"
<BDoucette@ENSR.
corn>
09/22/2005 10:52
AM
Ken Lucas/R4/USEPA/US@EPA
[e-mail],
[e-mail],
[e-mail],
"Shet ty, Nanj un 11
<[e-mail]>,
[e-mail]
To
cc
Subject
Jfd Electronics/Channel Master
Site Draft 5 -Year Review Report
11/14/2005 10:41 AM
Re: Jfd Electronics/Channel Master Site Dr--Year Review Report • ,•
Ken, our comments on the institutional control issue. (See attached
file, C_ommen_ts_to_Draft 5-Year Report 9-?2-05,pdf) . __
I Content-Type: application/pd]
Comments to Draft 5-Year Report 9-22-05.pd.f I C . b 64 . ontent-Encodmg: ase
L __ .. --~-______________ ~ _ _ __ l_ -----. __ _
2 of2 11/14/2005 10:41 AM
• •
E~.
t¾Wfoti4"4?UM ENSR International
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616-3013
September 22, 2005
Mr. Ken Lucas
U.S. Environmental Protection Agency
Region IV
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303-8960
RE: Draft Five-year Review Report, Groundwater Remediation
JFD Electronics/Channel Master Site, Oxford, North Carolina
ENSR Project Number 10140-008
Dear Mr. Lucas:
PHONE [phone]
FAX [phone]
www.ensr.com
On behalf of the Responding Parties, JFD Electronics Corporation and CMSS, Inc., ENSR
Consulting and Engineering (NC), Inc. (ENSR) offers comments for your consideration in finalizing
the report. We very much appreciate the opportunity to participate in the 5-Year Review and to
review the draft report provided by Mr. David Mattison of North Carolina Department of Environment
and Natural Resources (NCDENR). Our comments are focused on the issue of Institutional controls.
We are particularly concerned with statements in the report that would lead a reader to Incorrectly
conclude that institutional were necessary under the Record of Decision (ROD) and that they should
have been implemented.
The draft report states in several places that "Institutional controls have not been implemented."
While true, this statement combined with another statement on page 8 leaves the improper
impression that the ROD remedy called for such controls to be implemented and that someone
failed to implement them. On page 8 of the draft report is a statement to the effect that the ROD
calls for the implementation of institutional controls. As you know, that is not the case. Institutional
controls are clearly addressed in the ROD at page 96 as a contingency measure to be considered in
the event that the selected remedy fails or is determined to be not protective. Based on the first 5
years of operation, it would be inappropriate to conclude that the remedy for this site has failed or is
not protective. Therefore, under the language of the ROD, institutional controls are not mandated.
In addition the Site Inspection Checklist at page 4 repeats this error. The "NO" box is incorrectly
checked for "Specific requirements in deed or decision documents have been mer. Since
Institutional controls are not mandated, the correct box is "N/A". "The checklist also is in error for
two other items: Reporting is up-to-date" and "Reports are verified by the lead agency". ·
C"DoaJmet'Jtl end ~oaJI s«tin9,S',Tempo,a,ylrhmfl Fk\ClK~ ondral 5YR Repott_09_21_05.doc
Celabf8ting 30 Years of Excellanca in Environmental Se/Vices
EN:R. t6¼¥ttwf@
September 22, 2005
Mr. Ken Lucas
Page 2
• •
It is our understanding that the U.S. Environmental Protection Agency (EPA) desires as a matter of
policy to implement institutional controls at this site in the absence of remedy failure or other
circumstances triggering a contingent remedy. The Responding Parties are able to record land use
restrictions for the site itself, but implementation of institutional controls on other properties would be
a major problem. The Responding Parties cannot force a private party property owner or unit of
government to implement institutional controls. If off-site institutional controls are to be made an
issue in this report. then the Responding Parties believe that EPA must acknowledge that the issue
of institutional controls is unrelated to the protectiveness and performance of the remedy at this site.
It is incumbent on EPA to provide the real basis for making institutional controls an issue, a new
policy, not the ROD.
The wording of protectiveness statement should be as much a concern for EPA and the public as it
is to the Responding Parties. The current draft wording allows a reasonable person to conclude that
the remedy will not be protective in the future without institutional controls. We know of no technical
basis for such a conclusion and none is presented in the 5-Year Review Report. If EPA intends to
include such a statement in the 5-Year Review Report, then please provide us the site specific
rationale supporting this conclusion.
In summary, listing institutional controls as an issue in the 5-Year Review Report raises a number of
questions that are not answered in the draft report as written and we believe cannot be answered In
the time frame to complete the review. Based on current wording of the draft these questions report
include:
o Why implement institutional controls if such controls were not mandated in the ROD?
Has the remedy failed or been determined to no longer be protective? The draft 5-Year
Review Report provides neither a justification nor analysis for why such controls are needed
and how they would be protective.
o Which institutional controls are to be implemented? The range of institutional controls is very
broad; from deed restrictions to protective zoning. Has EPA conducted an evaluation of the
availability and effectiveness of institutional controls for this site?
o Where will these controls be implemented? Is EPA concerned with the former JFD
Electronics/Channel Master Property only?
o Who will be responsible for implementing and maintaining such controls?
• ;
IEl'CR. IXWiM&Mft◄
September 22, 2005
Mr. Ken Lucas
Page 3
• •
We believe institutional controls should not be identified as an issue until these questions are
answered. At best the information at hand can only support a recommendation that institutional
controls be evaluated for added protectiveness. If you have any questions, please contact me at
[phone].
Sincerely,
ENSR Consulting and Engineering (NC}, Inc.
w ft,__ ti ~;J:A/
William H.Doucette, Jr., Ph.D., P.G.
Project Coordinator for the Responding Parties
Enclosure
cc: Brian Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
Nanjun Shelly, ENSR
David Mattison, NCDENR
Steve Earp, Smith Moore
EPA Comments on Tech Memo • •
l of l
Subject: EPA Comments on Tech Memo
From: [e-mail]
Date: Thu, 22 Sep 2005 15:46:01 -0400
To: [e-mail]
CC: DA [e-mail], [e-mail]
You can add this as an attachment
(See attached file: jfd.pdf)
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
U. S. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone: [phone]
fax: [phone]
i, ,
1
Content-Type: application/pdf ,
IJfd.pdf ' ' , , Content-Encodmg: base64
I ---·-·. --·--·--···---
l l/14/2005 10:42 AM
JFD Electronics/Channel Master • •
I of l
Subject: JFD Electronics/Channel Master
From: [e-mail]
Date: Mon, 19 Sep 2005 10:10:09 -0400
To: [e-mail], [e-mail]
CC: [e-mail]
Stephanie
Here is all the information that I tried to leave on your voicemail - I
think I got cut off :0). Anyway, here are the notes from the interview
with Mr. Spurr. All of the questions on the questionnaire did not
pertain to the community. So, I improvised and used the questions that
did. There were two other community members that agreed to a phone
interview, but I was never able to get back in touch with them and they
never returned my calls.
Finally, the section in the five year review pertaining to the ad in the
paper can be deleted (Section 6.2 Community Involvement). You can add
that community members were contacted via telephone based on previous
contact from Public Meetings regarding the five year review. I have
attached a copy of what was sent to the Oxford Ledger. When I called
for the affidavit and a copy of the tier sheet, they said that they
never published it. Another Public Notice will be sent to them upon
completion.
O.K. here's what you've been asking for :0) :0) :0) :
(See attached file: JFD Electronics CM PN - 5 yr Rvw.doc) (See attached
file: JFD 5 YR Questionnaire Mr. Spurr.doc)
Thanks-A-Bunch :0) :0) :0)
Tonya
L'Tonya Spencer
Public Affairs Specialist
EPA -Region 4
61 Forsyth Street
Atlanta, GA 30303
404-562-8463 Phone
800-564-7577 Toll Free
404-562-8896 FAX
[e-mail]
I, ii . Content-Type: application/msword
!iJFD Electromcs CM PN -5 yr Rvw.doc• C
:1 • ontent-Encoding: base64 L. ----I ~-
Content-Type: application/msword
[JFD 5 YR Questionnaire Mr. Spurr.doc Content-Encoding: base64
11/14/2005 10:39 AM
RE: JFD Comments on Tech Memo • • ,-
I of 3
Subject: RE: JFD Comments on Tech Memo
From: [e-mail]
Date: Fri, 16 Sep 2005 09:53:42 -0400
To: [e-mail]
CC: [e-mail], [e-mail]
Thanks for the comments Dave. I've reviewed the SYR report. It looks
good. I've got one change.
For the signature page we've been notified that the signature block for
Superfund should be
Franklin E. Hill
Acting, Division Director
Waste Management Division
Superfund and Emergency Response
Also, I spoke to L'Tonya yesterday about the changes/additions to the
community relations section.
She said she would send her writeup to Stephanie Grubbs. Once that's
done we can go forward.
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
U. S. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone: [phone]
fax : [phone]
Ken,
Two typos -
DAVID.MATTISON@n
email.net
09/16/2005 09:20
AM
Please respond
to
david.mattison@n
email.net
To
Ken Lucas/R4/USEPA/US@EPA, Dave
Jenkins/R4/USEPA/US@EPA
cc
Richard Campbell/R4/USEPA/US@EPA,
Ken Lucas/R4/USEPA/US@EPA
Subject
RE: JFD Comments on Tech Memo
1. Correct spelling of word "put" in the first sentence of the 7th item
given under the heading Natural Attenuation, EPA's Comments on the
Technical
Memorandum.
11/14/2005 10:38 AM
RE: JFD Comments on Tech Memo • •
2 of 3
2. Delete second unnecessary period at end of first paragraph of
section
, Source Area Contamination Contribution to Off-Site Areas.
Seem to have covered all the points. I do have concern about issuing
this
response prior to receiving ENSR comments on the 5-Year Review Report.
Bill
has already expressed great concern over the inclusion of institutional
controls
for LTRA when it was not explicitly cited as a integral part of the
remedial
action as given in the ROD. I've informed Bill that this is EPA policy
and
will be included as an Issue/Recommendation in the 5-Year Review Report,
but Bill was definitely not pleased. I just don't want to give Bill any
fuel for slowing the 5-Year Review Report down and potentially not
meeting
our timeline.
Keep me posted and let me know what you think.
Dave
--Original Message --
Date: Thu, 15 Sep 2005 12:13:19 -0400
From: [e-mail]
Subject: JFD Comments on Tech Memo
To: [e-mail], [e-mail]
Cc: [e-mail], [e-mail]
Dave/David:
I've just completed drafting a letter to ENSR about the proposals in
their July 15th Tech Memo. If you have time look it over and let me
know 1) If I missed anything, and 2) if you think that it will be okay
to send this letter to them prior to our finalization of the Syr review
report. In my letter I've made statements about the effectiveness of
the remedy, not the performance so I think its okay but let me know how
you see it.
I'd like to send this out by COB tomorrow.
Thanks
(See attached file: 5yrcom-supp.pdf)
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
U. S. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone:
fax :
404-562-8953
404-562-8788
Attachment: Syrcom-supp.pdf
11/14/2005 10:38 AM
RE: JFD Comments on Tech Memo •
David Mattison
Environmental Engineer
·,1 NC DENR Superfund Section
Federal Remediation Branch
[phone]
•
3 of 3 I 1/14/2005 10:38 AM
l • •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
4WD-SRSEB
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
1646 Mail Service Center
Raleigh, NC 27699-1646
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
Date DRAFT
SUBJECT: Five-year Review Report
JFD Electronics/Channel Master Site
Dear Mr. Mattison:
The purpose of this letter is to provide EPA's comments on the draft Five-year Review
Report for the JFD Channel Master site.
(1) The Executive Summary -In the discussion about the various RODs and ESDs it is not
clear what changed. This should be redone such that the identified modification is
followed by a description of the change as compared to the remedy prior to the change.
Also in the next to the last paragraph the basis for the review is mis-stated. According to
the description of the modified remedy all soil and sludge was removed. Therefore the
review is being done based on EPA policy because the groundwater remedy will take
more than five years to complete.
(2) Site Chronology - A line should be added which addresses the enforcement mechanism
that was used to initiate the RI/FS. The dater for the PCOR needs to be checked. The
completion date in the table is October 12, 2000, however, the trigger date for the five
year review is September 29, 2000. The date of the PCOR and the trigger date for the
five year review should be the same.
(3) Section 4.0 Remedial Actions -Should be a summary of the ROD as modified, i.e., the
remedy that was actually implemented.
( 4) Section 4.2, Groundwater Remedy Implementation - A sub-heading should be added prior
to the discussion of the evaluation of the need to treat for metals contamination.
(5) Section 4.3, System O&M, Soil -The original soil remedy should not be included be
• •
included in the discussion because it was never implemented.
(6) Section 6.3, Document Review -The work that ENSR completed to evaluate the remedy
performance and optimization potential should be acknowledged here or in Section 6.5
Data Review.
If you have any questions please do not hesitate to call me at [phone].
Sincerely,
Draft
Kenneth Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
2
~e: JFD Electronics/Channel Master NPLI First 5-Year Review •
I of2
Subject: Re: JFD Electronics/Channel Master NPL Site First 5-Year Review
From: [e-mail]
Date: Thu, 25 Aug 2005 09:57:30 -0400
To: [e-mail]
CC: [e-mail], 1 ucas.ken@epamai l .epa.gov
Dave:
Below and attached is a draft of the comments that I have put tother on the draft FYR. I
have more comprehensive comments in the margin notes. I'll be by your office around 11 to
share them with you and Stephanie.
SUBJECT: Five-year Review Report
JFD Electronics/Channel Master Site
Dear Mr. Mattison:
The purpose of this letter is to provide EPA?s comments on the draft Five-year Review
Report for the JFD Channel Master site.
(l)The Executive Summary -In the discussion about the various RODs and ESDs
it is not clear what changed. This should be redone such that the identified
modification is followed by a description of the change as compared to the
remedy prior to the change. Also in the next to the last paragraph the basis for
the review is mis-stated. According to the description of the modified remedy all
soil and sludge was removed. Therefore the review is being done based on EPA
policy because the groundwater remedy will take more than five years to
complete.
(2) Site Chronology - A line should be added which addresses the enforcement
mechanism that was used to initiate the RI/FS. The dater for the PCOR needs to
be checked. The completion date in the table is October 12, 2000, however, the
trigger date for the five year review is September 29, 2000. The date of the PCOR
and the trigger date for the five year review should be the same.
(3) Section 4.0 Remedial Actions -Should be a summary of the ROD as modified,
i.e., the remedy that was actually implemented.
(4) Section 4.2, Groundwater Remedy Implementation - A sub-heading should be
added prior to the discussion of the evaluation of the need to treat for metals
contamination.
(5) Section 4.3, System O&M, Soil -The original soil remedy should not be
included be included in the discussion because it was never implemented.
(6) Section 6.3, Document Review -The work that ENSR completed to evaluate the remedy
performance and optimization potential should be acknowledged here or in Section 6.5 Data
Review.
11/14/2005 10:36 AM
~e: JFD Electronics/Channel Master NPL I First 5-Year Review •
2 of2
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
U. S. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone: [phone]
fax : [phone]
[e-mail] wrote:
To: Ken Lucas/R4/USEPA/US@EPA, Samantha Urquhart-Foster/R4/USEPA/US@EPA,
"Shetty, Nanjun" <[e-mail]>, Bill Doucette <[e-mail]>
From: [e-mail]
Date: 08/18/2005 12:42PM
cc: "Stephanie Grubbs (home)" <[e-mail]>, La Tonya
Spencer/R4/USEPA/US@EPA
Subject: JFD Electronics/Channel Master NPL Site First 5-Year Review
Please find attached the DRAFT First Five-Year Review Report for the JFD
Electronics/Channel Master NPL Site. Please note that this DRAFT First Five-Year
Review contains only the text of the report. Upon review by EPA and ENSR
{representing the PRPs), the report will be revised by the NC DENR and all
tables, figures, etc. will be inserted into the report.· Upon completion
of these tasks, the revised First Five-Year Review Report will be submitted
once again for EPA and ENSR review. Due to the short timefrarne presented
by the September 29, 2005 due date, please submit your comments (and interview
forms if applicable) via email to my attention no later than September 8,
2005 such that the First Five-Year Review Report can be revised and resubmitted
for your review on September 15, 2005. Please feel free to contact me if
you have any comments or questions.
Thanks,
Dave
David Mattison
Environmental Engineer
NC DENR Superfund Section
Federal Remediation Branch
1919) 508-8466
[attachment "JFD Electronics-Channel Master 1st 5-Year Review.doc" removed by Ken
Lucas/R4/USEPA/US]
I. . Content-Type: application/octet-stream;
'Jfd Dave Matt1son.wpd , ' Content-Encoding: base64
11/14/2005 10:36 AM
~ Fw: JFD Comments
\
I of 2
Subject: Fw: JFD Comments
Date: Tue, 02 Aug 2005 12: 12: 17 -0400
From: [e-mail]
To: [e-mail]
Dave:
These Dave Jenkins' comments are attached
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
U. S. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone:
fax :
404-562-8953
404-562-8788
•
Forwarded by Ken Lucas/R4/USEPA/US on 08/02/2005 12:11 PM-----
Hi Ken,
Dave
Jenkins/R4/USEPA
/US
07/26/2005 12:00
PM
To
Ken Lucas/R4/USEPA/US@EPA
cc
Scott Sudweeks/R4/USEPA/US@EPA
Subject
JFD Comments
Here are some comments regarding the latest Tech Memorandum from ENSR
for the JFD Channel Master site.
(See attached file: 0504_5YR review2.wpd)
This comment memo is 17 pages long!!!!!!!!!!!!!!!!!!
Review #1 was 9 pages long.
Please let me know if this is a wasted effort or if this is just too
elaborate to be useful. My comments are longer than the Tech Memo from
the consultant. It seems I have written another work plan from scratch.
Ground~ater contamination in one of the on-site wells is 24,000 times
the MCL for TCE.
And they want to turn off some of the containment wells.
The demonstration of capture zones is not convincing.
Even after we met ENSR at the site, the TM doesn't go far enough to
allow the Agency to approve the 3 proposals made in the 5-Year Review.
These proposals will change the ROD significantly. It seems to me that
there should be some detailed studies required for changing an approved
remedy when so much groundwater contamination remains at the site.
ENSR is right that one of the sources of contamination has nothing to do
08/03/2005 4: I I PM
Fw: JFD Comments • •
'
2 of 2
with this site. The Cristex source might be the major source of
contamination beneath the Oak Ridge Housing Development.
However, I get the impression that ENSR or the PRPs are under estimating
the problems associated with this site. Part of the bulkiness of my
comments are to help your understanding of the issues. There are lots
of loose ends at this site and their proposal is to pump fewer wells for
the next 50 years and see where we are then! Hopefully all of this
background info will help you make the case to the PRP.
CALL ME when you have questions!
Dave
~0504 5YR review2.wpd
Name: 0504_5YR review2.wpd
Type: WordPerfect 7 Document
( appl ication/x-unknown-content-type-WP7Doc)
Encoding: base64
Download Status: Not downloaded with message
08/03/2005 4: 11 PM
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4
4WD-TSS
SUBJECT:
61 Forsyth Street
Atlanta, Georgia 30303-3104
July 26, 2005
MEMORANDUM
Tech Memorandum dated July 15, 2005,
FROM:
JFD Electronics/Channel Master Site, Oxford, NC
David N. Jenkins, Environmental Scientist
CC:
TO:
Ken,
Technical Services Section, Waste Management Division
Scott Sudweeks, Chief Technical Services Section,
Waste Management Division
Ken Lucas, Remedial Project Manager, Waste Management Division
I have reviewed the Technical Memorandum (TM) dated July 15, 2005 produced by
ENSR, Inc. for the JFD Channel Master site as you requested. These comments follow
others submitted to you on April 29 and June 8, 2005 concerning the 5-Year Review for
this site. The Tech Memorandum from ENSR is a result of discussions with you and
the PAP consultants, Bill Doucett~ and Nanjun Shetty, at the site during our meeting
and inspection on June 2, 2005. Please call me at 404-562-8462 if you have any
questions.
The document reviewed is titled:
ENSR, 2005, Technical Memorandum Concerning Issues Raised During Initial 5-
Year Review, JFD Electronics/Channel Master Site, 620 West Industry Drive,
Oxford, NC, ENSR Consulting & Engineering, (NC) Inc, 7041 Old Wake Forest
Road, Suite 103, Raleigh, NC 27616
The TM supplements the 5-Year Review Report. Therefore, these comments also refer
to the 5-Year Review Report:
ENSR, 2005, Draft Five-Year Review Report, Groundwater Remediation, JFD
Electronics/Channel Master Site, 620 West Industry Drive, Oxford, NC, ENSR
Consulting & Engineering, (NC) Inc, 7041 Old Wake Forest Road, Suite 103,
Raleigh, NC 27616
GENERAL COMMENT:
The work plan in the TM addresses some of the issues discussed in previous
comments and during our site visit on June 2, 2005. However, it may not have been
clear that the proposals in the 5-Year Review Report change the conditions in the ROD
for this site. Consequently, additional information are needed beyond what is proposed
in the 5-Year Review and the subsequent TM.
Significant groundwater contamination remains at the site and may be impacting
adjacent property. The 5-Year Review Report shows that contaminant concentrations
in monitoring well CMMW05 remain 24,000 times greater than the MCL for TCE
Page 1 August 3, 2005 (4:12PM) C:\TEMP\0504_5YR review2.wpd
• •
(120,000/Sµg/L). The 5-Year Review contain 3 proposals to change the remedial
measures identified in the ROD. The Agency must insure that changes to the ROD will
not impact the protectiveness of the remedy. Consequently, if these 3 proposals are to
be considered, they must be investigated throughly.
Support for the 3 proposals and predictions of the consequences presented in the 5-
Year Review Report rely heavily on a groundwater model. This model may be perfectly
accurate and correctly represent conditions at the site, but data from real
measurements at the site must be presented to confirm the accuracy of the model
before changes to the ROD can be approved. The proposals may change the potential
exposure pathways or the all exposure pathways may not have been identified. The
contaminant concentrations in CMMW0S and the history of contamination migration off-
site explain why this review is so extensive.
The 5-Year Review Report and subsequent TM accomplish many of the goals for a 5-
Year Review, but in this case, additional questions are being asked beyond whether the
remedy is simply protective. The proposals would change the remedy. Specifically:
(1) a proposal has been made to stop pumping from 3 of 7 pumping wells which
were installed to recover contaminated groundwater and contain the
plume of contaminated groundwater, even though water pumped from
those wells remains contaminated in excess of the MCLs;
(2) a proposal has been made to change the remedy for a portion of the plume
from pump and treat (containment) to natural attenuation;
(3) a proposal has been made that the JFD property is not responsible for
pumping the Cristex plume, which had been thought to be captured by the
wells of the existing pumping system.
Approval of these 3 proposals significantly alter the remedy selection decisions made in
the ROD. In the" ... National Contingency Plan (NCP), EPA states its policy that it will
not reopen remedy selection decisions contained in RODs ... "(EPA 540-R-01-007
OSWER No. 9355.7-03B-P, June 2001, p.4-6). The 3 proposals are worth
consideration. However, if the ROD is to be reopened at the request of the
Responsible Party, additional information should be provided. The work plan presented
in the Technical Memorandum addresses some of the important issues, but must be
expanded to address other questions stemming from these 3 proposals.
The Tech Memorandum covers these primary topics:
I. Natural attenuation
II. Design & operation of the existing groundwater recovery system
Ill. Contamination of Indoor Air
IV. Contaminant migration to off-site areas
V. Bedrock contamination
VI. Contamination from the Cristex site
Page 2 August 3, 2005 (4:12PM) C:ITEMP\0504_5YR review2.wpd
• •
These issues are all interrelated, and all effect the 3 ROD changes proposed in the 5-
Year Review Report, so summarizing the Tech Memorandum and generating point-by-
point comments is difficult. The comments in this memo generally follow an outline
dictated by these primary topics in the TM.
Lastly, the ROD was signed in 1993. The investigations on which the ROD was based
are older. Much information has been obtained since the ROD was signed, and this
data may alter or invalidate assumptions and conclusions reached by previous
consultants. However, I have seen only the Draft 5-Year Review Report and the latest
TM report, and have seen none of the reports by previous consultants. The
groundwater modeling report (Appendix F) shows that contamination related to the JFD
site will still be present after 50 years. Even if some of the proposals in the 5-Year
Review Report are approved, the cost of pumping contaminants in the vicinity of PW1
and the PW5 wells over many decades will be high and after decades of expense, the
problem will still be there. Further, the data currently available makes some of the basic
assumptions and conclusions reached by previous consultants questionable, the
effectiveness of the existing remedy may be questionable. Many of the questions and
issues raised in this memo are focused on verifying that the concept model on which
the remedial efforts are based is correct, and that the remedial efforts are as effective
as possible. Good answers for these questions may already be available in earlier
reports, or may become available following investigations conducted in response to this
memo, but the prospect of pumping contamination for the next few decades, and then
finding the aquifer is not remediated is unattractive to all parties. Therefore, the
questions in this memo should be asked at this time even though they may challenge
basic assumptions and decisions derived from older reports.
CONCLUSIONS:
The 3 pumping wells proposed for removal from the JFD recovery system should not be
turned off until the issues identified in this memo are addressed. Regardless of other
considerations, termination of pumping in the down gradient wells should not occur
before completion of the MNA investigation. As proposed in Attachment 1 of the TM,
the MNA investigation has a duration of 2 years. The elapsed time for this investigation
might be reduced to one year as described later in this memo, depending on the results
of the investigation.
Sampling with push-point samplers should be extended up stream from the locations
designated on Figure 1-1 of the TM work plan. The sample locations presented
primarily address the question of groundwater contribution to the contamination of
indoor air, and do not provide current information regarding the effectiveness of the
extraction well capture zones. The proposed sample locations may not define all areas
where contaminated groundwater is discharging to surface water.
Groundwater samples should be collected and analyzed with ColorTec tubes to identify
all areas where chlorinated solvents in groundwater are reaching surface water. This
information should prove the conclusions in the 5-Year Review that the existing
Page 3 August 3, 2005 (4:12PM) C:\TEMP\0504_5YR review2.wpd
• •
groundwater recovery system effectively captures most contamination from the JFD
site. Information from this sampling effort will provide information regarding
contaminant flux to the streams by providing lengths of contaminated stream, hydraulic
gradients to the stream and approximate average concentrations in the contaminated
segments. This investigation should be done in a dry or low-flow season.
If the push-point samples show contamination is reaching the streams in unexpected
areas or at unacceptable concentrations, additional monitoring points should be
installed to provide water level data in the vicinity of the contaminant recovery wells to
confirm the effectiveness of the pump & treat system. The effectiveness of capture
zones can not be reliably determined using pumping well data only. Small diameter
piezometers would be adequate for this task. Additional analytical sampling at these
locations would not be necessary because groundwater near the extraction wells is
expected to be contaminated and the quality will be similar to that collected from the
pumped well.
Additional monitoring wells should be installed to provide water level and quality
information in the fractured rock beneath the most contaminated portions of the aquifer.
Additional analytical sampling at these locations would be necessary. ·
Topic I -COMMENT #1 Regarding Natural Attenuation:
The Tech Memorandum summarizes North Carolina regulations regarding the
applicability of Monitored Natural Attenuation to this site, and concludes that the
conditions have been met. While the Agency does agree that natural attenuation
probably is occurring at this site, the necessary investigation and documentation which
comply with EPA guidelines have not been performed. Further, the Agency does not
agree that all of the NC requirements have been met. The TM lists 10 rules from Title
15A North Carolina Administrative Code (NCAC) 2L.0106. Comments regarding some
of these circumstances are provided in the next paragraphs.
Condition 1 states that all sources of contamination and free product must be removed
or controlled (TM page 2). However, the TM states on page 3 that the 5-Year Review
acknowledges that sufficient residual contamination exists within the source area to act
as a long term source for groundwater contamination. Groundwater concentrations in
some wells exceed both the 1 percent and 10 percent solubility limit rules of thumb
commonly used to indicate the presence of residual free-product contamination (TM
Appendix G). Clearly the contamination has not been removed. Consequently, a key
issue is whether the extraction wells control the plume. Therefore, in addition to an
evaluation of natural attenuation, an demonstration of the capture zone created by the
existing extraction wells should be a major element of this work plan. Evaluation of a
capture zone is discussed in other responses in this memo.
Condition 2, a demonstration of degradation or attenuation potential which complies
with EPA guidelines, has not been performed at this site. Based on experience from
other sites, these contaminants are likely to be found to degradable under the
Page 4 August 3, 2005 (4:12PM) C:\TEMP\0504_5YA review2.wpd
• •
conditions existing at this site, but the required site-specific investigation has not been
performed. This investigation is a necessary step for the determination specified in
Condition 4 that contaminant migration will not result in any violation of ARARs at any
existing or foreseeable receptor. A monitored natural attenuation evaluation is
proposed in Attachment 1 of the TM. Given that contaminant trends already have been
defined (5-Year Review Appendix B), the MNA investigation probably can be shortened
to 1 year, rather than 2 years as proposed in the TM. Additional comments regarding
the MNA plan are included elsewhere in this memo.
Condition 3, the time and direction of contaminant travel probably can be predicted with
reasonable certainty, except where no monitoring wells exist in the vicinity of the
extraction wells confirm the effectiveness of the capture zone. Evaluation of a capture
zone is discussed in other responses elsewhere in this memo.
Condition 4. See the response to Condition 2 & 7. A monitored natural attenuation
evaluation is proposed in Attachment 1 of the TM.
Condition 5. Contaminants have already migrated to adjacent properties, but public
water supplies are provided to these properties as specified in Condition 5A. The
proposal to turn off 3 of 7 wells will increase contaminant concentrations in a portion of
the aquifer, but may not increase the area of contamination. Whether this increase is
acceptable to the Agency will depend on the results of the MNA investigation (See
Conditions 2, 4 & 7).
Condition 6. The work plan in the TM (Figure 1-1) seems to designate the point of
compliance for groundwater impact to surface water as being only in the vicinity of the
Oak Ridge Housing Development. The groundwater model results presented in the 5
Year Review Report (Figure 10) shows that the points of compliance should be
considered to be further up stream where groundwater contamination is predicted to
discharge to surface water. The sampling scheme outlined in the TM should be
continued up stream to confirm that surface water violations of ARARs, including 15A
NCAC 2B.0200 are not occurring, thereby confirming the validity of the groundwater
model with field observations.
Condition 7. See the response to Condition 2. A monitored natural attenuation
evaluation is proposed in Attachment 1 of the TM. However, additional review of the
NC requirements may be needed to determine if additional down gradient monitoring
wells are required. Contamination is detectable in all of the existing monitoring wells.
The existing wells may not be sufficient to detect the down gradient edge of the plume if
the plume expands after termination of pumping at the 3 off-site extraction wells. If the
MNA investigation show that contaminant concentrations will decline, the existing
monitoring wells (CMMW23 & 24), plus samples from the unused pumping wells (PW2,
3 & 4) may be sufficient for purposes of down gradient monitoring. As described
elsewhere in this memo, there are other issues regarding the groundwater flow system
which should be solved first.
Page 5 August 3, 2005 (4:12PM) C:\TEMP\0504_5YR review2.wpd
• •
Topic I -COMMENT #2 Regarding Natural Attenuation:
The activities for the MNA evaluation proposed in Attachment 1 are said to be limited to
" ... evidence that intrinsic biodegradation is occurring ... " The wells proposed to be
monitored include CMMW07, 17, 19, 20, 21, 22A, 23 and 24. Two other nearby wells
(CMMW 16 and 18) are included for monitoring during the first 2-year period.
No background wells are included in the monitoring proposal. One of the western most
wells on the JFD site should be added to the long-term monitoring well list. Well
CMMW09 would seem the most appropriate candidate based on groundwater flow
directions (5-Year Report Figure 5-1 ). However, no monitoring well construction
information is presented in the 5-Year Review Report. This data probably is contained
in previous reports, but a recommendation for an up gradient, background well can not
be made without information regarding the location of the well screen relative to the
location of the contamination source and the well screens in the monitoring wells
already selected for the MNA investigation.
An appropriate background well should be selected and included in the MNA plan. This
well may not need to be sampled regularly for VOCs, depending on the historic
analyses available. Presumably, VOCs have not been detected in the up gradient
wells, but no results are shown on Figure 5-2. MNA indicator parameters, field
chemistry and the depth to water should be measured in the up gradient well on the
same schedule as other monitoring wells.
Topic I -COMMENT #3 Regarding Natural Attenuation:
The semi-annual monitoring schedule proposed in the TM for the MNA investigation is
adequate given the frequency of monitoring and analysis for VOCs which has occurred
since April, 2000. Measurements of field parameters (depth to water, dissolved oxygen,
OAP, pH, temperature and conductivity) should already be available for each of the
historic analyses. Consequently, the new information collected during this portion of the
investigation primarily will be the "Degradation Byproducts and End Products" and
analyses in the "Others" category (TM Attachment 1 page 2). Presumably, these
groundwater characteristics in the down gradient portion of the plume are in equilibrium
with conditions in the plume. Therefore, the data evaluation proposed on page 3
should occur after the first year of data is available, not after two years.
The time-series graphs for voes in Appendix B of the 5-Year Review Report should be
up dated as data is available. The field chemistry data should be plotted in map-view.
The electron donor data from each sample event could be plotted in radial plot format
(See References). If these plots are consistent between sample events, and if the VOC
trends continue downward, the site may be ready for an evaluation of MNA after one
year, with subsequent monitoring events scheduled on an annual basis until the next 5-
Year Review.
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• •
If the MNA investigation shows that MNA will contain the plumes within their existing
boundaries, and if the MNA investigation indicates that contaminant concentrations
from the JFD site are likely to continue to decline, if the MNA investigation, modeling
and push-point investigation show that contaminant loading to the stream will not
increase to unacceptable levels, it may be appropriate to turn off the 3 down gradient
contaminant recovery wells. Water level measurements should be made in all available
wells just before the pumps are turned off, and at 30 and 60 days afterward. These
data should be plotted, and groundwater flow directions before and after pumping was
terminated should be evaluated to confirm that the existing monitoring wells are in
locations for monitoring the plume under post-pumping conditions. Gaps in the
monitoring well network caused by turning off the pumps should be closed by installing
additional monitoring wells.
Topic II -COMMENT #1 Regarding Design & operation of the existing groundwater
recovery system /Capture Zone Evaluation):
"Interpretations of capture from potentiometric surfaces are highly dependent on the
availability of representative water levels at or near pumping wells ... Best data are
provided when piezometers are located in immediate vicinity of extraction wells. Using
water levels measured in pumping wells that are subject to well losses may lead to an
over estimate of capture ... Not using any water levels near pumping wells may lead to
an under estimate of capture. Capture effectiveness is primarily evaluated based on
field obtained data. Using "converging lines of evidence" adds confidence in the
conclusions of the capture zone evaluation. It is not enough to assume capture is
sufficient because the design indicated it would be. The actual capture zone must be
evaluated because it may be different than assumed or estimated during the design of
the remedy' (http://clu-in.org/siteopVproceedings_04/track_a/wedl07/capture_zone_analysis.pdf)
The existing pumping wells are influenced by entrance losses inside the wells. OW1 is
near PW1 and CMMW06 is near PW2. CMMW05&10 are near PW5C. But there are
no monitoring wells in the vicinity of extraction wells PW3, 4, SA, & 58, and no
monitoring well between PW5C and the stream, which can be used to document
drawdown in the aquifer. Therefore, additional monitoring points (piezometers) should
be installed. Water levels in all monitoring wells, piezometers and pumping wells,
should be measured and recorded during each sampling event, regardless of whether a
particular well is sampled during that event.
Topic II -COMMENT #2 Regarding Design & operation of the existing groundwater
recovery system
There seem to be two key problem areas which should be resolved in the investigations
of the JFD site. The relationships between groundwater contaminant plumes and the
Oak Ridge Housing Development are addressed elsewhere in this memo. The second
problem area concerns explanations for contaminant concentration trends at CMMW0?
and CMMW17. These wells seem to be critical to understanding the effectiveness of
the capture zones, the groundwater relationship to the surface water streams, and
maybe the relative contaminant contributions from the JFD and Cristex property.
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CMMW07&17 are not on JFD property.
PCE concentrations are increasing in CMMW07.
Unexplained spikes of PCE and TCE contamination appear in CMMW17.
CMMW07& 17 are on the JFD side of the main stream draining the area, but very
close to the stream.
Under natural (non-pumping) conditions, the stream would be expected to be a
hydraulic boundary for dissolved contamination between the JFD and
Cristex property. Contamination from the Cristex property would not be
expected to reach CMMW07& 17 under non-pumping conditions.
CMMW07&17 are down gradient from PW1 located JFD property. Figure 5-1
shows that PW1 should be capturing contamination from the JFD property
before it reaches CMMW07&17.
If PW1 is effectively capturing contamination from the JFD property, where is the
contamination at CMMW07&17 coming from?
If PW2 is turned off the contamination at CMMW07& 17 will eventually go to the
steams. But the streams drain the shallow aquifer and CMMW07& 17 are
both bedrock wells. To which part of the stream will the contamination in
CMMW07&17 go if PW2 is turned off and what will the concentrations in
the stream be?
The increase in PCE concentration in CMMW07 (5-Year Review Report Appendix B)
may be due to the effects of pumping at PW2 bringing contamination toward PW2. But
Figure 5-1 of the 5-Year Review Report and Figure 10 of the Groundwater model report
show that contamination from the JFD source area should have been captured in PW1,
and should not get to CMMW07 or PW2. This may be sufficient reason not to turn off
PW2 as proposed, but the distribution of contamination in the aquifer is not known
sufficiently well to make a conclusion at this time. We should know whose
contamination this is before deciding about termination of pumping.
Also, statements in the TM and the 5-Year Review Report regarding the effectiveness
of the capture zone created by PW1 and the PW5s are in question while the
contaminant trends at CMMW07& 17 are unexplained. Specifically, the response to
"Question A: Is the remedy function as intended by the decision documents?' (5-Year
Review Report p.5-1) which says the plume is contained is questionable.
The rise in PCE concentrations in CMMW07 must be occurring either because JFD
source area contamination has not been captured by PW1, or because contamination
from the Cristex property has crossed the stream. If JFD site contamination is not
captured by PW1, the statements on page 3 of the TM regarding Source Area
Contamination Contribution to Off-Site Area are incorrect because both CMMW07 and
PW2 are off the JFD site.
The push-point sampling program proposed in this memo for the up-stream area may
help clarify this situation. Also, the use of direct push technology to answer this
particular type of question was recommended in previous comments for this site, but
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not utilized in the TM. This probably is because the sampling program defined in the
TM focused only on the Oak Ridge Housing Development, and did not address
groundwater/surface water relationships in the up-stream area. Direct push sampling
on the stream banks may be necessary to determine which bank of the stream is
contributing the contamination detected in the stream bed. The push-point technique
may not be able to reach the water table out-side of the cut-banks of the stream bed.
The work plan should plan to utilize direct push technology in areas where it is
necessary to prove that the contamination observed in the stream does not originate on
the JFD side of the stream. Finding clean samples on the JFD side of the stream would
be conclusive at some critical locations.
Please see additional comments regarding CMMW07& 17 in the discussion regarding
geologic cross-sections and in the discussion of bedrock contamination.
Topic II -COMMENT #3 Regarding Design & operation of the exjsting groundwater
recovery system
Neither the 5-Year Review or the TM contain cross-sections through the site and down
gradient area showing the geology, monitoring well screen elevations, extraction well
screen elevations, water level elevations, interpretation of vertical hydraulic gradients,
contaminant concentrations and interpretation contamination distribution. These figures
likely were presented in reports for earlier investigations using the data which was
available, but would be useful tools for interpretation of current data.
Geologic cross-sections should be presented in future reports for this site. Besides
aiding the interpretation of the data, these tools will help define gaps in the monitoring
well network, particularly in regard to contamination in the bedrock. Some gaps in the
monitoring network only may be visible in cross-section, not map view. For example,
well construction information are not provided in the 5-Year Review or TM, so the
relationships between well screens in bedrock wells CMMW07& 17 to PW2 can not be
determined.
Geologic cross-sections showing the data described above should be created for the
reports presenting the results of studies described in the TM and in this memo. These
cross-sections and the investigation data should be interpreted to identify locations for
additional bedrock monitoring wells.
Topic Ill -COMMENT #1 Regarding Contamination of Indoor Air
The issue of groundwater contribution to indoor air contamination is strongly interrelated
with all of the other issues in this memo. The TM makes numerous statements
regarding this issue. The Agency does not agree with all of these statements. The TM
states on page 3 that groundwater transport modeling shows that the JFD source area
is not a potential contributor to indoor air contamination at the Oxford Housing
Complex. The Agency agrees that this is what the model shows, but as stated
elsewhere, the effectiveness of the capture zone created by the pumping wells has not
been conclusively demonstrated based on real field measurements made at the site.
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The conclusions of the model must be confirmed with field observations as described in
other comments of this memo.
Topic Ill -COMMENT #2 Regarding Contamination of Indoor Air
Note that the text on page 3 of the TM refers to the Oxford Housing complex, while all
of the Figures in the TM and the 5-Year Review Report identify this residential area as
the Oak Ridge Housing Development.
Topic Ill -COMMENT #3 Regarding Contamination of Indoor Air
The proposed work plan for the Indoor Air Evaluation (TM Section 1.3) doesn't
specifically state that the proposed investigation is a Tier 3 analysis of vapor intrusion to
indoor air. But the second step in the work plan includes use of the Johnson-Ettinger
model to evaluate the risk associated with the detected concentrations, which is the
basis for evaluating Questions 5 and 6 in the Tier 3 Analysis. The appropriate EPA
guidelines for analysis of vapor intrusion to indoor air are cited.
The work plan appears to be appropriate to answer questions regarding whether a
pathway between groundwater contamination and indoor air has been completed, but it
isn't clear whether any site-specific measurements will be made or what sample
methods will be used. In other words, the work plan proposes a 2 step investigation of
vapor intrusion to indoor air. Given that groundwater contaminant concentrations in the
vicinity of the housing development exceed the MC Ls by factors between 10 and 50,
and given that depths to groundwater probably are less than 5 feet in some portions of
the housing development, the work plan should discuss plans for conducting a Tier 3
analysis should the preliminary steps indicate this to be necessary. The" ... direct
measurement of foundation air and/or indoor air concentrations from a subset of the potentially
affected buildings and complementary site-specific mathematical modeling as appropriate ... "
are recommended for Tier 3 assessments
(http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm ). Methods for collecting these samples
should be described. The plans should be made now rather than waiting for
submission of an additional work plan later.
TM Work Plan Section 1.2 Comment #1 Regarding Groundwater Sampling beneath
Surface Water Tributaries
The text in Attachment 1 Section 1.2 -Groundwater Sampling beneath Surface Water
Tributaries states that approximately 5 samples would be sent to a laboratory for
confirmatory analysis. This number of samples may sufficient even for the expanded
investigation recommended in this memo, depending on the success in defining the
extent of contamination using the ColorTec tubes. The purpose of this effort is simply
to define the areas where contamination enters the streams. The effort should result a
reasonable estimate for the length of contaminated stream bottom, which will be useful
for contaminant flux estimates to the stream. A small number of laboratory analyses
will be sufficient for estimating the concentration in the contaminant flux to the streams.
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TM Work Plan Section 1.2 Comment #2 Regarding Groundwater Sampling beneath
. Surface Water Tributaries
Regarding sample collection methods and water level measurements, the text states
that a peristaltic pump will be used to collect the groundwater samples from the push
point locations. A pump may not be necessary if the upward hydraulic gradient is
sufficient for natural flow into the sample container. Hopefully, unnecessary expense
for equipment decontamination can be avoided.
Peristaltic pumps should not be used until the water level in the tube attached to the
push point has been determined, and the water level and flow rate are observed to be
inappropriate for sample collection without a pump. Water level elevations in the tubing
should be measured to the nearest hundredth of a foot above or below the water
surface and recorded on the sample collection record.
TM Work Plan Section 1.2 Comment #3 Regarding Groundwater Sampling beneath
Surface Water Tributaries
Sampling with push-point samplers should be extended up stream from the locations
designated on Figure 1-1 of the TM work plan. The sample locations presented
primarily address the question of groundwater contribution to the contamination of
indoor air, and do not provide current information regarding the effectiveness of the
extraction well capture zones. The proposed sample locations may not define all areas
where contaminated groundwater is discharging to surface water. The expanded
sampling areas should proceed up stream at least to the vicinity of CMMW05. See the
comment regarding Topic IV regarding contaminant migration to off-site areas.
Topic IV -'COMMENT Regarding Contaminant migration to off-site areas
The Tech Memorandum interprets the 5-Year Review Report contends that PW2, 3 and
4 can be turned off because" ... pumping these wells had little long term benefit'. This
interpretation is based on modeling results which are said to show no difference in
plume shape with and without pumping. The model does show that the shape of the
plume don't change, but the contaminant loading down gradient from the extraction
wells would change if the wells were off. This is because the local streams are the
discharge area for groundwater. Contamination which doesn't pass through the pumps
goes to the streams.
As stated in the Tech Memorandum, there are three potential receptors which might be
effected if the wells are turned off. These are 1.) drinking water from local wells, 2.)
indoor air and 3.) surface water. There are no known drinking water supply wells in the
vicinity of the plumes, but impacts on indoor air quality and on surface water require
evaluation. Comments regarding the proposed evaluation of Indoor Air are presented
elsewhere in this memo.
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The Tech Memorandum dismisses concern for impacts on surface water because no
impacts on surface water were detected above ARARs during the Remedial
Investigation. The data for this investigation was collected nearly a decade prior to
installation of the extraction wells. The investigation proposed in the Tech
Memorandum will not confirm these conclusions with current data.
The likely areas for groundwater discharge to the streams are shown in Figure 10 of the
5-Year Review Report. The JFD plume on Figure 10 intersects the stream in the
vicinity of CMMW04, SW02 and maybe in the vicinity of PW4. Farther up stream, the
plume flowing toward PW1 actually passes beneath the stream for about 50 percent of
the total flow path to the extraction well. The nearest proposed sample locations shown
on Figure 1-1 of the Tech Memorandum are hundreds of feet down stream from the
groundwater discharge areas shown by the groundwater model. As stated elsewhere in
this memo, geologic cross-sections showing relationships between ttie plume, the
stream and the monitoring and pumping well screens are not presented in these
reports.
The "push-point" sampling effort described in the TM should continue up stream at least
to the vicinity of CMMW05, due to the high concentrations of VOCs in groundwater from
CMMW05 and CMMW 1 o. If groundwater from this vicinity is reaching the stream, the
capture zones created by the pumping wells are inadequate and not as effective as
claimed in the TM. Similarly, if contamination is detected beneath the streams in areas
where contributions from the JFD site seem unlikely, the explanation may be previously
undetected contamination from the Cristex property. Such a detection probably would
favor other proposals in the 5-Year Review, specifically to remove the 3 down gradient
extraction wells from the JFD O&M plan. Relationships to contamination at the Cristex
property are discussed in other points of this memo.
Topic V -COMMENT #1 Regarding Contaminant migration to Bedrock
The TM (p.3) states that information for various monitoring events does not show an
increasing trend in contaminant concentrations in the bedrock. Yet Figure 5-2 of the 5-
Year Plans shows that there are only 2 shallow bedrock wells (CMMW07&18) and one
deep bedrock (CMMW17) well in the monitoring well network. None of these wells are
on site, and none of these wells are in the vicinity of the source area near the most
contaminated wells. These wells are too far from the source area to support the
conclusions presented in the report.
Topic V -COMMENT #2 Regarding Contaminant migration to Bedrock
The graph in Appendix B showing water quality in CMMW 17 shows that this well has
exceeded the MCL for PCE and TCE on at least 5 occasions since pumping began.
The overall trend for DCE has been upward, and some MCL exceedances for DCE
have been observed. CMMW17 is a deep bedrock well 600 feet from the source area.
The upward DCE trend maybe proof that natural attenuation is occurring. But
contamination is in the bedrock and the vertical extent of contamination has not been
defined.
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The graph in Appendix B showing water quality in CMMW17 shows that this well has
been effected by spikes of water more highly contaminated with PCE and TCE. The
source of the contaminated water is unknown. The spikes may occur again. Figure 5-1
show that CMMW17 is beyond the capture zone of PW1, so contamination in this area
would not be captured and treated if PW2 is turned off. The contamination probably
would discharge to the streams if PW2 is not pumping.
Oddly, the graph in Appendix B showing water quality in CMMW07 shows that this
shallow bedrock well is not effected by the spikes at the same time as deep bedrock
well CMMW17, which is just a few feet away. The PCE spike in CMMW17 (deep
bedrock) which occurred between day 36,800 and 37,000 arrived before the peak
occurs in CMMW07 (shallow bedrock). The PCE spike in CMMW17 (deep bedrock)
which occurred between day 37,600 and 37,800 arrived when the PCE concentration in
CMMW07 (shallow bedrock) was at the lowest point plotted on the graph.
Subsequently, PCE concentrations in CMMW07 (shallow bedrock) began an upward
trend which continues to the most recent sample event. These data suggest that
contamination in the bedrock arrives at this pair of monitoring wells in the deeper well
first.
No data for shallow well CMMW16 is presented in Appendix B. CMMW16 should be
sampled in the next sample event. Historic data for all 3 wells (CMMW07, 16 and 17) in
this cluster should be plotted at the same scale and evaluated.
Topic V -COMMENT #3 Regarding Contaminant migration to Bedrock
CMMW05 and 10 are the most contaminated wells on the site. The deeper well of this
pair, CMMW05, is much more contaminated than the shallow well CMMW10 (5-Year
Review Figure 5-2), suggesting that downward migration of contamination is occurring.
There are no bedrock wells in this area. The vertical extent of contamination has not
been determined.
Topic V -COMMENT #4 Regarding Contaminant migration to Bedrock
The PCE and TCE concentrations in CMMW05 and 10 are between 1 and 11 percent
of the solubility limits for these contaminants. Higher concentrations can be assumed
to be present in the aquifer. Total chlorinated VOC concentrations as high as 166 ppm
have been observed in the past (TM p.3). These contaminants are heavier than water,
and typically tend to migrate vertically downward. Contaminants may be migrating
beneath shallow wells, or migrating in fractures before returning to the local streams.
Contamination probably is present in the bedrock beneath the source area up gradient
from the PW5 wells, but there are no bedrock monitoring wells in this area.
Topic V -COMMENT #5 Regarding Contaminant migration to Bedrock
The TM (p.4) cites the contaminant concentration trends in CMMW07, a shallow
bedrock well, as evidence that there is no problem in the bedrock. CMMW07 is more
than 600 feet from the most contaminated well on site (CMMW05). The contaminant
concentration trends in CMMW07 (5-Year Review Report Appendix B) show that TCE
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concentrations have decreased about 15 percent since pumping began, but surprisingly
the PCE concentrations have increased about 50 percent since pumping began.
Comparison of percent change in contaminant concentrations are simple, but not the
best way to evaluate the progress of remediation. The figure in Appendix B clearly
show that PCE concentrations are increasing in CMMW07, and that TCE
concentrations will remain high for a long time if the trend observed since pumping
began continues. The MNA investigation and the recommended plots of MNA. indicator
parameters may help explain why PCE is not degrading in this portion of the aquifer.
Topic VI -Comment #1 Regarding Contamination from the Cristex site:
The information provided in the 5-Year Review report and the current Technical
Memorandum show that a second source on an adjacent, but otherwise unrelated
property (Cristex), is contributing to the groundwater contamination being pumped by
some of the JFD extraction wells. The contribution and consequence of this second
source greatly complicates this 5-Year Review.
Contaminant releases and disposal practices at the Cristex site are presumably
unrelated to the JFD property. However, plumes of contaminated groundwater from
both sites discharge to the same surface water streams in the area making attribution of
contamination near the stream to one source or the other difficult. The conclusions
regarding the Cristex plume are based on a groundwater model. As stated elsewhere
in this memo, the conclusions of the groundwater model must be confirmed by field
measurements.
The results of the groundwater model shown in Figure 10 of the 5-Year Review Report
best illustrate the relationship of the Cristex property source to the JFD property. The
model results strongly implicates the Cristex property as the sole and only party
responsible for potential contamination beneath the Oak Ridge Housing Development.
These model results must be confirmed by field observations. If possible,
demonstration that contamination found in the streams and beneath the housing
development does not originate on the JFD side of the stream should be acquired.
Topic VI -Comment #2 Regarding Contamination from the Cristex site:
The graph showing water quality versus time for well CMMW26 (5-Year Review
Appendix B) shows that this well was contaminated prior to the initiation of the pump &
treat system in April, 2000, but has been uncontaminated since the second year after
pumping began. Pumping at PW1 may have altered groundwater flow directions in the
vicinity of CMMW26, bringing clean water past this well. However, the groundwater
flow model results (Figure 10) imply that pumping at PW1 should have little impact on
CMMW26. The particles simulating the Drum Dump source area on the Cristex
property do not appear to show the slightest diversion toward PW1. Figure 10 indicates
that it is very unlikely that contamination in CMMW26 is from the Cristex Drum site.
CMMW26 is located south of the Oxford Printing Building, and on the other side (south)
of the drainage channel between Oxford and JFD property. CMMW26 is on the Cristex
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property side of the surface water drainage. The curious thing about this well is not that
CMMW26 became clean when pumping began, but where did the contamination come
from in the first place?
No water quality data prior to April, 2000 are presented for CMMW26, so pre-pumping
water quality trends in this well are not shown. No water level data prior to April, 2000
are presented in the 5-Year Review Report, so pre-pumping groundwater flow
directions are not shown. The pre-pumping groundwater flow direction probably was
toward the east, suggesting that contamination in CMMW26 may not have been from
the JFD property, unless CMMW26 is connected to the JFD property by bedrock
fractures. Bedrock contamination is discussed in other responses of this memo.
No water quality data are presented in Appendix B for wells CMMW2, 3, 11, 12 or 13,
which are located between PW1 and CMMW26. Data collected from these wells before
and after pumping began may help clarify the source of contamination in CMMW26,
and therefore, the lateral and vertical extent of contamination related to the JFD
property. These data probably are available in earlier reports for this site.
The history of contamination and groundwater flow directions in the area between
CMMW05, CMMW13 and CMMW26 should be interpreted before the field sampling
activities described in the TM work plan are initiated. A preliminary statement regarding
whether this contamination was from JFD or Cristex should be included in a revised site
concept model. Any data gaps which would support the preliminary interpretation, or
confirm that the source is not the JFD property should be acquired during the field
investigation.
Contaminant concentration trends in CMMW26 can not be explained at this time.
Because CMMW26 has been uncontaminated since the second year of pumping and
the original source of the contamination is unknown, CMMW26 should be monitored
and sampled for VOCs, especially if any changes are made in the pumping system at
JFD.
COMMENT REGARDING RE-EVALUATION OF REMEDIATION OPTIONS:
The data presented in Appendix B of the 5-Year Review show that at the degradation
rates observed during the last 5 years, the pump and treat remedy will not restore the
aquifer for many decades. The groundwater modeling report (Appendix F) shows that
contamination related to the JFD site will still be present after 50 years. The cost of
pumping contaminants in the vicinity of PW1 and the PW5 wells over many decades
may be greater than the cost of some remedial measures available using current
technology.
Appendix G of the TM describes a comparison between two remedial measures. One
option considered is continued operation of the 7 existing pumping wells with on-site
treatment by air stripping for 30 years. Electrical resistance heating is the second
option considered, with continued operation of the pump and treat system for 30 years.
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The section of Appendix G titled Comparison of Alternatives concludes that Alternative
2 would not offer a significant benefit over the current P&T remedy. Appendix G
doesn't clearly state that at the rate of contaminant degradation which has been
observed to date, the operation of the existing P&T system will be required for far
longer than 30 years. The selection of a 30 year period is for cost comparison only.
P& T is a long-term remedy and the true cost of this option will be much greater after 30
years.
Studies in the last few years have concluded that P& T can be an effective contaminant
containment measure. Containment can be a reason sufficient to make a remedy
protective of human health and the environment, but is ineffective as a clean-up
remedy. The TM is already proposing Monitored Natural Attenuation for portions of the
existing plume which have concentrations of the same order of magnitude as which are
those estimated to remain after implementation of an electrical resistance heating
remedy. Therefore, electrical resistance heating followed by monitored natural
attenuation is an option which should considered and compared.
A third option, enhanced reductive dechlorination (ERO) , is mentioned in Appendix G,
but dismissed based on the results of a pilot test performed in 2000. The pilot test
indicated that enhanced reductive dechlorination effectively destroyed the plume, but
not the ONAPL source. However, the description of the ERO test in Section 3.4 of the
5-Year Review Report sounds favorable in many ways. A 66-94 percent reduction in
PCE and TCE sounds very promising (p.3-3).
Perhaps it is time to re-evaluate the strategy for this site. For example, one way to
interpret data from a recent publication {Chapelle and others, 2005) is that a chemical
remediation of a source area may be effective at some sites as a kind of "chemical
containment", as opposed to physical containment by pumping. That study showed
that while some residual contamination may remain in the source area following
chemical treatment, the plume in down gradient areas can be greatly weakened or
destroyed. The study also suggests that natural attenuation rates maybe increased in
some situations.
Most importantly, the study concludes that data collected over a 6-year period shows
that some source area treatments can lead to significant contraction of chlorinated
ethane plumes. Four years after then end of the treatment period, contaminant levels
in down gradient wells remained 1-2 orders of magnitude lower than pre-treatment
concentrations. If this could be accomplished at the JFO site, there would be no
contamination to pump from the down gradient wells. MNA maybe sufficient for a
remedial measure in the down gradient areas. If additional treatments were needed or
appropriate in a second 5-year period at JFO, the injection wells, monitoring wells and
other infrastructure would be in place. Over the next few decades, it may be cheaper to
destroy the plume down gradient from the source than to pump the contamination to the
treatment plant.
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The Agency's primarily concern is limited to insuring the protectiveness of the remedial
measure. But if a more economical means of insuring protection is available, the
Agency should consider approving such a measure. The current remedy is said to
contain the contamination, it does not accomplish remediation. And as stated in this
memo, the effectiveness of containment is questionable. We should be reluctant to
accept the conclusion (p.5-6) that the current remedy is the most cost effective for the
next 30 years, because the data in Appendix B shows the problem will still be there in
30 years. There is no conclusively proven scientific method for evaluating potential
remedial measures or combinations of remedial measures in various zones of the
plume. But-if the effort to change the ROD is to be made, this is the time to consider
other alternatives.
REFERENCES
Byl, T.D. and S. D. Williams, Biodegradation of Chlorinated Ethanes at a Karst Site in
Middle Tennessee, USGS Water-Resources Investigations Report 99-4285.
http://water.usgs.gov/pubs/wri/wri994285/
(See Figure 10 regarding presentation and interpretation of MNA data)
Chapelle, F.H., P.M. Bradley, and C.C. Casey, 2005, Behavior of a Chlorinated Ethane
Plume following Source-Area Treatment with Fenian's Reagent, Ground Water
Monitoring & Remediation, v.25 no.2, pp. 131-141.
Carey, G.R., P.J. Van Geel, T.H. Wiedemeier and E.A. McBean, 2003, A Modified
Radial Diagram Approach for Evaluating Natural Attenuation Trends for
Chlorinated solvents and Inorganic Redox Indicators, Ground Water Monitoring
and Remediation, v.23, No. 4, pp75-84.
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INTERNATIONAL~
July 15,2005
Mr. Ken Lucas
U.S. Environmental Protection Agency
Region IV
Waste Management Division "
61 Forsyth Street, SW
Atlanta, GA 30303-8960 .
•
ENSR International
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616-3013
PHONE,(9.19 872-6600
--,,,---;::~~,n"'~ 1-~Fil 1F:t-J<~•~'(9;19) 872 7996
IE) .~(<; _L~~]U""'ro•
1\fil\ ~~-~-~ 7~G~S>•T
surEJ:;f\JilD >'i:t"" '.I ION
RE: Technical Memorandum Concerning Issues Raised During Initial 5-Year Review, JFD
Electronics/Channel Master Site, Oxford, North Carolina.
ENSR Project Number 10140-008-0600
Dear Mr. Lucas:
On behalf of JFD Electronics Corporation and CMSS, Inc., ENSR Con~ulting and Engineering (NC),
Inc. (ENSR) submits this Technical Memorandum to address the issues raised during the recently ' completed Five-Year Review. Enclosure 2 of your letter dated May 31. 2005 identified two major
issues, the first concerning natural attenuation and the second concerning design and operation of
the groundwater recovery system. The purpose of this memorandum is to provide technical
clarification concerning the merits of the issue and to propose the scope of work described in
Attachment 1. If our proposal meets with your approval we will prepare the appropriate planning
documents and initiate the work.
Natural Attenuation
The Five-Year Review recommended termination of pumping at the three off-site extraction wells.
PW-2. PW-3 and PW-4 (see Figure 1-1 in Attachment 1), based on groundwater transport modeling
results which showed that pumping these wells had little long-term benefit. Modeling results
indicated no difference in shape or concentrations of the plume of contaminated groundwater
between pumped and not pumped scenarios. The explanation for this observation is that the plume
is naturally contained by discharge to surface water features within the capture zone boundaries of
the extraction wells. The proposal to terminate pumping at the three downgradient extraction wells
S:\PUBSIPROJEC1'0.Channe/Maslet\5-Yr _Review_lmp(1014(}(}()8)\Sfl8/egy MemorandumU.ucas_ Strategy letter 7-15-2005.doc
Celebraling 30 Years of Excellence in Environmen/a/ Services
July 15, 2005
Mr. Ken Lucas
Page 2
• •
was determined to have merit if no there were no unacceptable exposures and an evaluation of
natural attenuation was positive.
The primary potential exposure pathways for the off-site portion of the plume are drinking water,
indoor air and surface water. The presence of public water in the vicinity of the plume mitigates the
potential for drinking water exposure. As proposed in a later section of this Technical
Memorandum, the potential for unacceptable indoor air exposure will be evaluated. Site data did
not demonstrate an unacceptable exposure in surface water during the Remedial Investigation (RI).
Pumping the subject extraction wells reduces the discharge of the plume to those surface waters,
and the pre-pumping sampling results indicated the lack of surface water impacts above standards.
Since the 1991 Record of Decision (ROD) North Carolina has revised its rules to allow for natural
attenuation remedies under certain circumstances. The applicable rules at Title 15A North Carolina
Administrative Code (NCAC) 2L.0106 Corrective Action allow for a natural attenuation remedy
where the following can be demonstrated:
(1) that all sources of contamination and free product have been removed or controlled
pursuant to Paragraph (f) of this Rule;
(2) that the contaminant has the capacity to degrade or attenuate under the site-specific
conditions;
(3) that the time and direction of contaminant travel can be predicted with reasonable
certainty;
(4) that contaminant migration will not result in any violation of applicable groundwater
standards at any existing or foreseeable receptor;
(5) that contaminants have not and will not migrate onto adjacent properties, or that:
(A) such properties are served by an existing public water supply system
dependent on surface waters or hydraulically isolated groundwater, or
(B) the owners of such properties have consented in writing to the request;
(6) that, if the contaminant plume is expected to intercept surface waters, the
groundwater discharge will not possess contaminant concentrations that would result
in violations of standards for surface waters contained in 15A NCAC 2B.0200;
(7) that the person making the request will put in place a groundwater monitoring
program sufficient to track the degradation and attenuation of contaminants and
contaminant by-products within a.nd down gradient of t~e plume and to detect
contaminants and contaminant by-products prior to their reaching any existing or
foreseeable receptor at least one year's time of travel upgradient of the receptor and
no greater than the distance the groundwater at the contaminated site is predicted to
travel in five years;
(8) that all necessary access agreements needed to monitor groundwater quality
pursuant to Subparagraph (7) of this Paragraph have been or can be obtained;
July 15, 2005
Mr. Ken Lucas
Page 3
• •
(9) that public notice of the request has been provided in accordance with Rule .0114(b)
of this Section; and
(10) that the proposed corrective action plan would be consistent with all other
environmental laws.
Site conditions have been demonstrated to meet the above 2L requirements except for an
evaluation of contaminant capacity to degrade or attenuate under the site-specific conditions. A
monitored natural attenuation evaluation (study) is proposed in Attachment 1.
Re-Evaluation of the Design and Operation of the Existing Groundwater Recovery
System
The components of this re-evaluation listed in Enclosure 2 involve uncertainties related to potential
off-site indoor air quality impacts, continued source area contribution to off-site impacts,
contamination in bedrock groundwater and contribution from releases at the Cristex Drum Dump.
Comment 2.c. also requested the MNA evaluation proposed in Attachment 1. In some cases
existing site information is sufficient to prepare a response. For the remaining issues an evaluation
is proposed as described in Attachment 1.
Indoor Air Evaluation
The groundwater transport modeling results indicated that portions of the dissolved contaminant
plume will continue to be present under some residential structures at the Oxford Housing complex
near well CMMW-23 over a relatively long time period. An evaluation of the potential for volatile
contaminants to impact air quality within those structures will be conducted as described· in
Attachment 1.
Source Area Contamination Contribution to Off-Site Areas
The Five-year review report acknowledges that there is within the source area sufficient residual
contamination in the aquifer to act as a long-term source of dissolved contaminants to groundwater.
The expressed concern was for continued migration of dissolved contaminants from the source
area to the vicinity of residential areas, primarily the Oxford Housing complex. Groundwater
transport modeling presented in the Five-Year Review Report indicates the existing remedy is
effective in preventing such migration. Dissolved contamination migrating from the source area is
hydraulically contained within the capture zone of on-site recovery well PW-1. No action is needed
at the source area to address this issue.
Contamination in Bedrock
Information from the various site monitoring events does not show an increasing trend in
contaminant concentrations in bedrock nor is there an indication that bedrock groundwater quality is
a major source of uncertainty in plume concentration downgradient of well PW-1. The referenced
July 15, 2005
Mr. Ken Lucas
Page 4
• •
statement in Appendix G of the Draft Five-Year Review Work Plan (ENSR, 2005) at page 5-2
concerning increasing concentrations in bedrock is an interpretation of simulated groundwater
concentration results from the groundwater transport model and not actual site data. Actual site
data for bedrock monitoring well CMMW-07 located downgradient of well PW-1 and approximately
in the middle of the plume shows that trichloroethene (TCE) concentrations have decreased since
November 2000 while tetrachloroethene (PCE) and cis-1,2-dichloroethene (cis-1,2-DCE)
concentrations have been relatively stable. In well CMMW-17, PCE and TCE concentrations have
decreased while the degradation product cis-1,2-DCE has proportionately increased. Simulation
models are not perfect replicas of actual site conditions and thus there can be differences between
model results and actual data. Where there are differences the actual site data takes precedence.
The 1995 Predesign Data Acquisition (PDA) program data did not indicate a downward increasing
trend in dissolved contaminant concentrations in the aquifer as would be expected if dense non-
aqueous phase liquid (DNAPL) had sunk from the surface to the bedrock some 60 feet below. 1995
PDA data at the well cluster nearest the source show the shallow well CMMW-10 screened at 8 to
18 feet below land surface (bis) to have significantly higher total volatile organic compound (TVOC)
concentrations (166,315J micrograms per liter [ug/L]) compared to well CMMW-05 (42,257J ug/L)
screened at an intermediate depth from 35 to 45 feet below land surface (bis). No deeper wells
were installed at this well cluster. Since 1995 TVOC concentrations in well CMMW-05 have
significantly increased as a result of pumping well PW-1. It is believed that pumping the more
transmissive intermediate saprolite zone at well PW-1 causes vertical downward movement of
contaminants from the overlying less transmissive and more contaminated shallow saprolite zone.
TVOC concentrations in well CMMW-10 have decreased in the same period as a result of the
enhanced reductive dechlorination (ERO) pilot study. Therefore the recent data from this well
cluster provides little insight into source geometry or potential bedrock impacts.
The most complete depth interval sampling over time is available at the cluster of wells immediately
downgradient of recovery well PW-1. 1995 PDA data show the intermediate depth well CMM04 to
have roughly 4 times the TVOC concentrations of shallow well CMMW16, 6,103J ug/L and 1,284J
ug/L, respectively. 1995 TVOC Concentrations in bedrock well CMMW-07 (362J ug/L) were more
than an order of magnitude less than the intermediate zone well CMMW-16 (1,284J ug/L). Deeper
bedrock TVOC concentrations in well CMMW-17 (114 ug/L) were less than those in well CMMW-07.
Since 1995, TVOC concentrations are relatively unchanged in wells CMMW-04 and CMMW-07. In
well CMMW-17, PCE and TCE concentrations show a decreasing trend while cis-1,2-DCE has
increased. Well CMMW-16 has not been sampled since 1995. These data are not consistent with
the presence of major bedrock impacts at the source area. If there were significant bedrock
contamination at the source area, then TVOC concentrations at wells CMMW-07 and CMW-17
should have been more in line with the TVOC concentrations in the intermediate zone well CMMW-
04 or the shallow well CMMW-16.
Et.~. ti @·? Z.@n ?Al
July 15, 2005
Mr. Ken Lucas
Page 5
• •
Contribution From Releases At The Cristex Drum Dump
Without commenting on the need for action at the Cristex Drum Dump, it should be clear that
releases at that source are not the responsibility of the JFD Electronics/Channel Master responding
parties. It was important to include the Cristex Drum Dump in the groundwater transport model in
the Five-Year Report to evaluate its potential contribution to groundwater and surface water impacts.
The groundwater transport model indicates the plume from releases at the Cristex Drum Dump also
migrates under the Oxford Housing complex and discharges to the same unnamed tributary. The
Cristex plume according to the model moves parallel to and immediately east of the JFD
Electronics/Channel Master plume. A concern was expressed that the model may not accurately
simulate the groundwater transport pathway for the Cristex plume. Data from the PDA and
monitoring at well PW-4 indicated no impacts east of well PW-4. EPA requested additional data
collection to confirm the pathway shown in the model. Specifically, the request was to sample
groundwater immediately below the bed of the unnamed tributary using driven wellpoints and field
screening analysis. A proposed field evaluation program is described in Attachment 1.
We believe this Technical Memo and the attached evaluations scope of work addresses the
issues raised in Enclosure 2. If you have any questions or comments, please contact us at
[phone].
Sincerely,
ENSR Consulting and Engineering {NC), Inc.
Nanjun V. Shetty, P.E.,
Project Manager
Enclosures
Cc: B. Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
S. Earp, Smith Moore, LLP.
D. Mattison, NCDENR, Superfund Section
w~--4~0(
William H. Doucette, Jr., Ph.D., P.G.
Project Coordinator
•
INTERNATIONAL"
ATTACHMENT 1
STRATEGY MEMORANDUM
FIVE-YEAR REVIEW
•
JFD ELECTRONICS/CHANNEL MASTER SITE
As discussed in the strategy memorandum, the following sections provide a brief description of
the proposed plan for evaluation of natural attenuation, sampling of groundwater beneath
creeks/unnamed tributaries, and indoor air quality evaluation at the Oxford. Housing
Development.
1.1 Evaluation of Natural Attenuation
The 5-year review recommended termination of groundwater recovery from off,site recovery
wells (PW-2, PW-3 and PW-4) as the modeling results indicated no difference in shape or
concentrations of the plume of contaminated groundwater between pumping and non-pumping
scenarios. As requested by the United States Environmental Protection Agency (EPA) at the
June 1, 2005 meeting, ENSR, on behalf of the Responsible Parties, proposes to perform
natural attenuation evaluation of the off-site volatile organic compound (VOC) plume (mainly
tetrachloroethene [PCE], trichloroethene [TCE] and degradation products). Typically, natural
attenuation processes include adsorption, desorption, dispersion, dilution, biodegradation and
volatilization. This MNA evaluation will generally follow the procedures outlined in Technical
Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Groundwater (EPA,
1998). The proposed MNA evaluation is limited to off-site groundwater plume ..
Several lines of evidence are used to evaluate if natural attenuation is occurring at the Site.
These lines of evidence typically include: 1) decreasing trends of VOCs in monitoring wells or
evidence that plume is shrinking; 2) evidence that intrinsic biodegradation is occurring
(presence of electron acceptors and degradation products); 3) laboratory treatability studies of
intrinsic biodegradation; and 4) groundwater fate and transport modeling. Abiotic processes
(adsorption, desorption, dispersion and dilution) were included as part of the groundwater fate
and transport calculations performed as part of the Five-Year Review report prepared by
ENSR. In addition, groundwater trends in the monitored wells were included as part of the
Five-Year Review report. Therefore, the proposed action would be limited to collection of
groundwater data to evaluate if intrinsic biodegradation is occurring in the aquifer at the site.
No treatability study is proposed.
Additional Groundwater Data Collection
The proposed MNA evaluation program includes monitoring of selected wells in the
unimpacted and impacted areas of the off-site plume. Groundwater VOCs will be monitored in
wells CMMW7, CMMW17, CMMW-19, CMMW20, CMMW21, CMMW22A, CMMW23, and
CMMW24. These wells are part of routine groundwater monitoring (semi-annual) at the site. In
addition, wells CMMW16 and CMMW18 will also be sampled for VOCs semi-annually for two
years (the proposed MNA evaluation period). VOCs will be analyzed using EPA Method
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8260B. In addition, wells CMMW16, CMMW7, CMMW17, CMMW18, CMMW22A, CMMW23
and CMMW24 will sampled for biogeochemical parameters (electron acceptors and
degradation. products) listed in Table A-1 semi-annually for two years. Typically, MNA
· evaluation involves quarterly sampling of groundwater for 1 year to evaluate the effects of
seasonal changes on site contaminants (i.e., VOCs). However, quarterly sampling was
performed for three years after the remediation system startup (year 2000). It is assumed that
this information would be sufficient to provide the seasonal fluctuations of VOCs at the site.
Therefore, the proposed MNA monitoring will involve semi-annual groundwater sampling for
two years. This sampling will be performed in conjunction with the routine semi-annual
sampling (April and October). The biogeochemical sampling will include the following
parameters.
• Field Parameters -The field parameters are measured at each of the wells using
field instruments, and include indicator parameters that can be used to assess if
conditions in the groundwater system can support the instrinsic biodegradation.
These field parameters include dissolved oxygen (DO), oxidation-reduction
potential (redox), pH, temperature, and specific conductance. A portable
multiparameter meter will be used for measuring these parameters in the field.
• Electron Acceptors -Analysis for electron acceptors provide information on the
oxidation-reduction status of the aquifer. Such information is useful in
estimating which biogeochemical reactions might be occurring including which
types of respiration (and attending electron acceptor) is likely to be important.
These compounds include sulfate, nitrate, ferric iron, and manganese. The
analytical methods to be used are included in Table A-1.
• Degradation Byproducts and End Products -Analysis for the typical degradation
byproducts and end products indicate the relative levels of compounds formed
by the biodegradation. The presence of such materials can be indicative of on-
going degradation and therefore indicate reductive conditions in concert with
other observations. These byproducts and end products include ferrous iron,
dissolved manganese, sulfide, nitrite, nitrogen, carbon dioxide, hydrogen,
chloride, and methane. The analytical methods to be used are included in
Table A-1.
• Others -Other parameters to be analyzed will include: chemical oxygen
demand (COD), biological oxygen demand (BOD), total organic carbon (TOC),
ammonia, and voes. The COD, BOD, and TOC analyses all measure the
presence of organic carbon in the groundwater and will be used to assess if
sufficient substrate is present for the degradation reactions to occur. voes
analyses will allow for an evaluation of the constituents degradation. The
analytical methods to be used are included in Table A-1.
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Groundwater samples will be collected via low-flow sampling using a low-flow pump (peristaltic
or submersible pump). Groundwater sampling will be performed in accordance with the
procedures established in the Remedial Design Work Plan (Geraghty & Miller, 1993) for the
site. The quality assurance/quality control (QNOe) sampling will include collection of one
equipment blank, one -trip blank and one field duplicate sampled during each sampling event.
The field duplicate sample will be analyzed for all specified parameters.
Data Evaluation
MNA evaluation will be performed using historical voe data and additional biogeochemical
data. The biogeochemical and voe data will be used to evaluate intrinsic biodegradation is
likely occurring at the site. Analytical parameters will be used in weighting for preliminary
screening for anaerobic biodegradation processes as outlined in the EPA guidance (EPA,
1998). The geochemical data will be summarized in the routine semi-annual reports.
At the end of the proposed study period (i.e., two years), an MNA evaluation report will be
prepared. As part of this report, historical groundwater data will be reviewed to evaluate if
contaminant concentrations are decreasing within a well and also with distance (concentrations
vs. time and concentration vs. distance). This information will be graphically depicted.
Groundwater data will be used to estimate natural attenuation rates. Since groundwater fate
and transport modeling performed as part of Five-Year Review predicted the plume behavior
under pumping and non-pumping conditions, no additional modeling is currently proposed.
This evaluation will be summarized in a report. Based on this evaluation, recommendations
will be made regarding long-term monitoring.
1.2 Groundwater Sampling Beneath Unnamed Tributaries
As requested by EPA, additional data will be collected to evaluate if the groundwater voes are
discharging into unnamed tributaries/creeks at the site as predicted by the groundwater fate
and transport model (ENSR, 2005). ENSR will collected groundwater samples immediately
below the bed of the unnamed tributaries located south and east of the site (see attached
Figure 1 ). The samples will be collected approximately 50 to 100 feet apart in sections of the
tributaries located on Southgate Associates, Oxford Housing and e[v1SS, . Inc. properties.
ENSR will utilize driven wellpoints (e.g., Henry's sampler or push-point sampler by M.H.E.
products) and field screening for voes using eolorTech method. A peristaltic pump will be
used to collect groundwater samples from the wellpoints. It is assumed that a maximum of 15
groundwater samples will be collected for field screening. Approximately 5 groundwater
samples (25 percent) will be sent a fixed laboratory for analysis of voes using EPA Method
8260 for confirmation. Samples to be analyzed in the laboratory will be based on the results
of field screening using the eolorTech method.
Groundwater sampling and equipment (including wellpoints) decontamination will be in
accordance with the procedures outlined in the Remedial Design Work Plan (Geraghty &
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'INTERNATIONAL~,
Miller, 1993). The Sample locations will be staked and later surveyed by a licensed surveyor.
The QA/QC sampling will be as discussed in Section 1.2.
1.3 Indoor Air Evaluation
Groundwater sampling results indicate that portions of the dissolved contaminant plume are
likely present under some residential structures at the Oxford Housing complex near well
CMMW-23. Groundwater fate and transport (ENSR, 2005) indicated that this plume likely will
continue to be present over a relatively long period. As requested by EPA, ENSR, on behalf of
the Responsible Parties, proposes to perform a screening level human health risk evaluation to
evaluate the potential impact of voes detected in site groundwater (mainly PCE, TCE and cis-
1,2-dichloroethene [cis-1,2-DCE]) that may migrate from groundwater to the indoor air in the
apartment buildings located in the vicinity of groundwater well CMMW-23. This evaluation will
assess the potential risks associated with the indoor air inhalation exposure pathway, to a
resident living in the apartment buildings. VOC concentrations detected-in groundwater in the
last semi-annual groundwater monitoring event in well CMMW-23 will be used in the following
steps of the indoor air evaluation.
The first step of the indoor air evaluation will be to compare maximum detected concentrations
of compounds in groundwater to screening criteria provided in the EPA Draft Guidance for
Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (EPA, 2002)
(Vapor Intrusion Guidance). This guidance provides target concentrations for groundwater
data. Target groundwater concentrations based on a risk of 1 x 10·5 for carcinogens and a
hazard quotient of 1 for noncarcinogens will be used for this screening. Compounds with
detected concentrations below the target concentrations will be assumed to not pose
unacceptable risks and will not be evaluated further.
Compounds detected at groundwater concentrations above EPA's target concentrations will be
evaluated further using the EPA's most current version of the Johnson and Ettinger model and
guidance (USEPA, 2004 a and b) to predict potential carcinogenic and noncarcinogenic risks
associated with inhaling compounds in indoor air that have volatilized from groundwater. This
is a screening-level model that incorporates both convective and diffusive mechanisms for
estimating the transport of vapors from groundwater at the site into indoor air. This screening
level model uses many default, conservative parameters, where site-specific modifications are
confined to the most sensitive parameters. Default input parameter values, provided by EPA,
will be used for modeling where site-specific information is unavailable. A report will be
prepared summarizing the details of this evaluation and appropriate recommendations.
References
ENSR, 2005, Five-Year Review Report, Groundwater Remediation, JFD Electronics/Channel
Master Site, Oxford, North Carolina, June 2005
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INTERNATIONAL•
EPA, 1998, Technical Protocol for Evaluation of Natural Attenuation of Chlorinated Solvent
Sites, EPA/600/R-98/128, United States Environment Protection Agency, Office of
Research and Development, Washington DC, September 1998.
EPA, 2002. Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from
Groundwater and Soils (Subsurface Vapor Intrusion Guidance). United States
Environmental Protection Agency. Office of Solid Waste and Emergency Response.
November 29, 2002.
EPA, 2004a. USEPA Version of the Johnson and Ettinger Model. GW-SCREEN, Version 3.1.
February, 2004.
EPA, 2004b. User's Guide for Evaluating Subsurface Vapor Intrusion Into Buildings. United
States Environmental Protection Agency. Office of Emergency and Remedial Response.
Revised February 22, 2004.
Geraghty & Miller, 1993, Remedial Design Work Plan, JFD Electronics/Channel Master Site,
Oxford, North Carolina, November 30, 1993.
@ Over 30 Years of Excellence in Environmental Se1vices
INTERNATIONAL'/:
NOTES:
• •
Table A-1
Proposed Biogeochemical Monitoring
JFD Electronics/Channel Master Site
Oxford, North Carolina
Sampling Parameter Analytical Method
Field Parameters
Dissolved Oxygen Horiba U-22
Redox Horiba U-22
pH Horiba U-22
Temperature Horiba U-22
Specific Conductance Horiba U-22
Electron Acceptors
Nitrate USEPA 353.2/300.0
Ferric Iron USEPA 6010
Manganese USEPA6010
Sulfate USEPA 375.3/300.0
Degradation/End Products
Ferrous Iron Field: HACH Kit
Dissolved Iron EPA 6010
Dissolved Manganese EPA6010
Sulfide Field: HACH Kit and/or EPA 276.2
Nitrite EPA 353.2/300.0
Nitrogen EPA 351.2
Ammonia EPA 350.1
Carbon Dioxide MOD EPA 3810
Chloride EPA 9056/300.0
Ethene MOD EPA 3810
Ethane MOD EPA 3810
Methane MOD EPA 3810
Hydrogen AM-20GAX
Alkalinity EPA 310.1
Others
Chemical Oxygen Demand EPA410.1
Biological Oxygen Demand EPA405.1
Total Organic Carbon EPA 9060
Volatile Organic Compounds* EPA 8260
EPA United States E~vironmental Protection Agency
SM Standard Methods
AM Microseeps Laboratory method.
-Biogeochemical monitoring will be performed semi-annually for two years as part of the monitc
natural attenuation.
-Proposed biogeochemical monitoring (semi-annual) will be performed on wells CMMW-16, CM I CMMW-17, CMMW22A, CMMW-23 and CMMW-24.
• voes will be collected from wells CMMW-7, CMMW-17, CMMW-20, CMMW-21, CMMW-22A
CMMW-23 and CMMW-24 as part of the routine semi-annual sampling. In addition, VOCs wil
monitored semi-annually in wells CMMW-16 and CMMW-18
@ Over 30 Years of Excellence in Environmental Services
CONCRETE
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8505078
•
INTERNATIONAL,
June 30, 2005
Mr. Ken Lucas
U.S. Environmental Protection Agency
Region IV
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303-8960
•
ENSR International
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616-3013
_,_J;HON~(9~jl)·~j2-6600
1-0---\i~. ~;;:-:LI:: ::;''ij~'!!
SUPERf-UI\\D 'SEC1\0\\\
RE: 5-Year Review Document, JFD Electronics/Channel Master Site, Oxford,
North Carolina.
ENSR Project Number 10140-008-002
Dear Mr. Lucas:
On behalf of JFD Electronics Corporation and CMSS, Inc., ENSR Consulting and Engineering (NC),
Inc. (ENSR) submits this 5-Year Review Report in electronic format. Consistent with your letter dated
May 31, 2005 the attached CD contains the document text in Microsoft Word, tables in Excel and
figures in PDF. It's our understanding the EPA/DENR may make changes to the text and in that case
a draft of those changes will be provided ENSR for comment.
We are working on the Technical Memorandum also requested in you May 31,2005 letter for submittal
on July 15, 2005. If you have any questions .or comments, please contact us at [phone].
Sincerely,
ENSR Consulting and Engineering (NC), Inc.
Nanjun V. Shetty, P .E.
Project Manager
Enclosure
cc: Brian Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
Gerald Hornaday, ENSR
David Mattison, NCDENR
Steve Earp, Smith Moore, LLP
\~l~~o:c:tt~~~
Project Coordinator
Celebrating 30 Years of Excellence in Environmental Services
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
MAY 3 1 2005
4WD-SRSEB
William H. Doucette, Jr., PhD., L.G.
Senior Program fy'lanager
ENSR International
7041 Old Wake Forest Road
Raleigh, NC 27616-3013
Subject: Draft Five-Year Review Report JFD Electronics/
Channel Master Superfund Site, Oxford, North Carolina
. Dear Mr. Doucette:
The United States Environmental Protection Agency (EPA) has reviewed the Draft Five-Year
Review Report for the JFD Electronics/Channel Master National Priority List (NPL) Site. This
document was submitted pursuant to Sections VII, VIII, and XXVII of the Consent Decree
between the United States of America and JFD Electronics Corporation and Channel Master
Satellite System, Inc., Civil Action No. 93-650-CIV-56.
In July 2003, EPA requested that the Settling Defendants initiate studies which will form the
basis for EPA's Five-year Review of the JFD Electronics/Channel Master Superfund Site, as
required by Section 12l(c) ofCERCLA, and in accordance with the "Comprehensive Five-Year
Review Guidance", OSWER Directive 9355. 7:03B-P, dated June 2001. In keeping with that
request, EPA is directing Settling Defendants to provide additional documentation to facilitate
EPA's finalization of the Five-year Review Report. The items required, their format, and
delivery schedule are discussed below:"
I. Transmit the electronic files that constitute the Draft Five-Year Review Report in the
following format within 30 days of the supplemental Five-year Review site inspection
which is currently scheduled for June 2, 2005:
a. Document text in MS Word
b. Table in Microsoft Excel
c. Figures in Adobe Acrobat PDF
lnleniel Address (UAL)• http://www.epa.gov
Hecycled/Recyclable • Printed with Vegetable Oil Based Inks on RecycJed Paper iMl1,!_imum 30% Postconsumat)
• •
2. Comments enclosed with this letter are related to correcting errors in the draft report as
well as obtaining information to support recommendations for optimization of the
remedy. Within 30 days of the supplemental Five-year Review site inspection which is
currently scheduled for June 2, 2005, you are directed to develop a technical
memorandum which will:
a) Respond to the issues raised by EPA in the enclosure.
b) Correct identified errors in the draft report
c) Propose a strategy for resolving the uncertainties associated with the predictive
model and a work scope to resolve data gaps.
If you have any questions or require clarificatio11s, do not hesitate to call me at 404-562-8953.
Enclosures
cc: David Mattison, NCDENR
Sincerely, \ (~\
~'v'\/v~'d\ ft\!,;\.A.J .. ,, ""J
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial and Site Evaluation Branch
2
•
Enclosure 1 -Specific Comments
Table of Contents
•
I. Please correct the Draft Five-Year Review Report and the Table of Contents to indicate
that the titles of Section 3.3 and Section 4.0 are "Soil/Sludge Remedy Implementation"
and "Five-Year Review Process", respectively.
2. Please correct the Draft Five-Year Review Report and the Table of Contents to indicate
that Section 8.0 is located on page 8-1.
3. Please correct the Table of Contents to indicate that the title of Figure 2-1 is "Site
Layout".
4. Please correct the Table of Contents to indicate that the titles of Table 2-1 and Table 5-1
are "Site Chronology" and "Annual System Operation and Maintenance Costs",
respectively.
5. Please correct the Draft Five-Year Review Report and the Table of Contents to indicate
that the titles of Appendix B, Appendix E, and Appendix G are "VOC Trends in
Monitoring Wells", "Photographs Documenting Site Conditions" and "Review of
Source Area Treatment Technologies", respectively.
Section 1.0 Introduction
6. Please correct the last two sentences of Section 1.0 to indicate that Section 6.0 contains
information regarding any issues noted during the five-year review process, Section 7.0
contains recommendations and follow-up actions regarding the remedy, and Section 8.0
contains various references that were used in the preparation of this document.
Section 2.0 Site Chronology and Background·
7. Please correct the spelling of the word "system" in the first sentence of the fourth
paragraph of Section 2.0.
Section 2.2 History of Contamination
8. Please correct the second sentence of Sectio_n 2.2 to state 'Throughout the operation of
the various processes at the facility, solvents were reportedly used for cleaning and
degreasing."
• •
Section 4.5 Site Inspection
9. Please revise this section to provide much greater detail regarding the site inspection,
including who conducted the inspection, when the site inspection was cond~cted, how the
inspection was conducted, the remediation system components inspected, the inspection
of the former sludge drying beds area, etc. The "Five-Year Review Site Inspection
Checklist", found as Appendix Din the Comprehensive Five-Year Review Guidance
(USEPA, June 2001), should be used as a guide for conducting the site inspection and
attached to this document as a separate appendix.
I 0. Please correct the last sentence of Section 4.5 to state "Photographs taken during the site
inspection are contained in Appendix E."
Section 4.7 Groundwater Modeling
11. Please provide the source of the groundwater recharge value given in the second bullet
item in Section 4.7.
Appendix B VOC Trends in Monitoring Wells
12. The following modifications should be made to the graphs in prior to sumbission of
electronic files to EPA:
a. X-axes should be formatted as dates. Some of the graphs are formatted as numeric
days elapsed.since January I, 1904, which is the date Microsoft EXCEL uses to
begin counting calendar dates (for example, SEE Well CMMW04). The axes of
the graphs with numeric formats are in 200 day increments. These notations are
not relevant to season or traditional time increments like months or years.
b. · . · X-axes should be formatted as dates beginning on January I of the year of the
oldest sample, and should end on December 31 of the year of the youngest
sample. This will aid in visual examination for seasonal patterns in the data. All
graphs should cover the same time periods to simplify comparisons between
wells. Many of the graphs begin at Day 36,400 which is equivalent to August 28,
1999. But some graphs begin on April 4, 2000, and others begin on Day 36,600.
As stated in recommendation I, this is partially a formatting problem, forcing all
graphs to the same scale beginning on the same date at the beginning of the same
calendar year facilitates examination ofthe data for both seasonal and long-term
trends.
c. Use of a logarithmic should be applied for the Y axes of these graphs. A range of
1-1 million:g/L may be appropriate on the Y-axes (see TCE concentrations in
2
•
• • .. 4. ••.:·•
CMMW05 and CMMWI Oas justification for the I-million :g/L upper Y-axis
limit). The log-axis will tend to smooth variations in contaminant concentrations
and make long term trends more apparent. Using a constant axis range for all
graphs will readily identify wells with high or low contaminant concentrations.
d. All 4 CVOCs (PCE, TCE, DCE & VC) should be.plotted on one graph per well
using a logarithmic scale. The individual CVOCs should be identified by color or
symbol. This presentation will facilitate demonstration of degradation of the
chlorinated solvents. This presentation could increase the length of each Y-axis if
only one graph is used per page, making Recommendation #3 a bit more
functional.
e. MCLs for each CVOC should be plotted in the same color and symbol as the
contaminant concentrations. These can be plotted as a concentration on the first
and last date of the graph X-axis (Recommendation #2), which will result in flat
lines across the graph at the appropriate MCL concentration.
f. There is a graph in Appendix B for well CMMW20A, but the location of this well
is not shown on Figures 5-1 or 5-2. Wells CMMW22 and CMMW22A are shown
on Figure 5-2. Were is CMMW20A, and are there wells 20B or 20C as with
PW5A, B&C?
3
• •
Appendix C Historic Recovery Well and In fluen't VOCs
13. Please revise all of the graphs given in Appendix C to provide the date as is shown on the
graphs for monitoring well CMMW-20 and CMMW-21 in Appendix B.
Appendix F Groundwater Fate and Transport Modeling
Table of Contents
14. Please revise the Table of Contents of Appendix F to clearly indicate the page number
where Section 6.1.3 is located.
List of Tables
I 5. Please correct the List of Tables of Appendix F to reflect the actual table titles for Table
2.1, Table 4.1, Table 4.2 and Table 5.3.
I 6. Please correct the List of Tables of Appendix F to indicate that the title of Table 5.1 is
"Historical and Average Pumping Rates".
List of Figures
17. Please correct the List of Figures of Appendix F to reflect the actual figure titles for
Figure 1, Figure 12, Figure 14A, Figure 14B, Figure I 5, Figure 16, Figure 17, Figure 18,
Figure I 9, and Figure 20.
Section 1.0 Introduction
18. Please correct the third sentence of the second paragraph of Section 1.0 to state "The
work plan outlines the details of the proposed modeling approach."
19. Please correct the third bullet item in the third paragraph of Section 1.0 to state
"Selecting a computer program that can best represent the conceptual transport model
and meet the project objectives."
Table 2-1 Comparison of Measured Groundwater Elevations (November 1992) with
Calibrated Models
20. Please define the "Average Absolute Value of Residual" given in Table 2-1.
4
• • •• .1,, . .. :
Enclosure 2 -Remedy Optimization/Model Results
1) Studies to predict the natural attenuation of the down gradient contamination
should be performed to justify the proposal for turning of down gradient recovery
wells.
The report presents a digital groundwater model, and a proposal to stop pumping from three of
seven pumping wells which were installed to recover contaminated groundwater and contain the
plume of contaminated groundwater. The four remaining wells are pumping the most
contaminated water. The wells proposed for removal from service are down gradient and are
pumping less contaminated water. However, down gradient from the capture zone of the wells
proposed to remain in service is contaminated in excess of the MeLs. If the three down gradient
recovery wells are turned off, some of this contamination will flow toward potential receptors.
The graphs in Appendix B show that the water quality from many of the monitoring wells which
would not be captured if the proposed wells were turned off greatly exceeds the MeLs for one or
more of the chlorinated voes. Down gradient receptors include a surface water stream and
residential areas where shallow contaminated groundwater will be beneath residential living
spaces
2) The model results presented in the report show that the design and operation of the
contaminated groundwater recovery system should be re-evaluated.
The model appears to be suitable to help evaluate the " ... ramifications of remediation of the on-
site source area (residual contamination/hot-spot) ... " etc. But the evaluations are impacted by
uncertainties about the status and distribution of contamination in the source area. The
contaminant plume already is present beneath private residential areas, therefore, the effects of
volatile organic contamination (VOes) in shallow groundwater on the indoor air of these
residential areas must be considered. The figures in Appendix F indicate that contamination .
migration will continue beneath the residential areas unless something is done near the sources.
These figllfes also show that if the down gradient wells are turned off, contamination from the
main source area will migrate down gradient toward the streams, and maybe toward the
residential areas. The primary areas of uncertainty regarding the model and the future of this
plume are, uncertainty regarding contamination in the bedrock, uncertainty and lack of studies
regarding natural attenuation, and uncertainty regarding the impact of voe contamination in
shallow groundwater on indoor air spaces in residential areas. The re-evaluation of the recovery
system should take the following into account:
a. The drum dump source (eristex) area must be addressed -This source appears to be a
secondary source area which was not included as part of the original groundwater
recovery/plume containment remedy. The model results (Appendix F Figure I 0) show
• •
that under the current configuration of the recovery system, this secondary source is a
threat to indoor air in the local residential areas.
b. The contaminant concentrations remaining in the bedrock beneath the main source area
needs to be defined. -Contaminant concentrations may be diminishing at the down
gradient recovery wells (PW2, 3 and 4), but there is uncertainty that this trend will
continue because contaminant concentrations in the bedrock beneath the main source area
are not defined. The report states that contaminant concentrations may be increasing in
the bedrock (Appendix F p.5-2), and that uncertainty regarding concentrations in a source
area are always a potential cause of discrepancies in groundwater models (Appendix F
p.4-5).
c. Monitored Natural Attenuation studies should be performed. -While indications of
natural attenuation are present, Monitored Natural Attenuation studies which follow EPA
guidelines have not been performed. Therefore, degradation rates of the contaminants can
not be predicted. The model presented in the report should be modified to consider
contaminant degrad_ation.
d. · The approach to addressing the main source area must be reevaluated. -The recovery
·system could be made more efficient to control the current configuration of the plume.
Installation of additional pumping wells in the main source area, possibly combined with
collection galleries, impermeable or semi-permeable barriers may be more appropriate for
stopping contamination migrating from the source area. Appendix F Figure IO clearly
shows that contamination is escaping from the main source area. Recovery wells PW2, 3
and 4 appear to have been effective-in reducing the size of the plume down gradient from
the source area. If the source area is controlled further and if natural attenuation studies
show that down gradient contamination will attenuate prior to reaching potential
receptors, a schedule for discontinuing pumping from PW2, 3 and 4 might can be
developed.
e. Capture-of the plume should be accomplished in the vicinity of the PWS wells. -With
respect to both source areas, reducing the volume of contaminated water leaving the
sC>Grces, and reducing the hydraulic gradient by pumping, allows more time for natural
attenuation to be effective before the contaminated water reaches the streams or the
residential areas. The text on page 6-1 states that the majority of groundwater is captured
by the recovery wells, but a small percentage of contaminated water by-passes the wells
and arrives at the creek above PW3. This is indicated by observation of the number of
particles introduced into the source area which arrives in the streams, simulated as water
and contaminant sinks in the model. Most of the particles are captured at PWl. there are
some escapees w, niost of which are captured at PW2, but some particles go all the way
to the streams. A number of particles escape past PW5A, 5B and SC.
2
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
4WD-SRSEB
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
1646 Mail Service Center
Raleigh, NC 27699-1646
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
Date DRAFT
SUBJECT: Five-year Review Report
JFD Electronics/Channel Master Site
Dear Mr. Mattison:
The purpose of this letter is to provide EPA's comments on the draft Five-year Review
Report for the JFD Channel Master site.
(I) The Executive Summary-In the discussion about the various RODs and ESDs it is not
clear what changed. This should be redone such that the identified modification is
followed by a description of the change as compared to the remedy prior to the change.
Also in the next to the last paragraph the basis for the review is mis-stated. According to
the description of the modified remedy all soil and sludge was removed. Therefore the
review is being done based on EPA policy because the groundwater remedy will take
more than five years to complete.
(2) Site Chronology - A line should be added which addresses the enforcement mechanism
that was used to initiate the RI/FS. The dater for the PCOR needs to be checked. The
completion date in the table is October 12, 2000, however, the trigger date for the five
year review is September 29, 2000. The date of the PCOR and the trigger date for the
five year review should be the same.
(3) Section 4.0 Remedial Actions -Should be a summary of the ROD as modified, i.e., the
remedy that was actually implemented.
(4) Section 4.2. Groundwater Remedy Implementation - A sub-heading should be added prior
to the discussion of the evaluation of the need to treat for metals contamination.
(5) Section 4.3, System O&M, Soil -The original soil remedy should not be included be
• •
included in the discussion because it was never implemented.
(6) Section 6.3, Document Review -The work that ENSR completed to evaluate the remedy
performance and optimization potential should be acknowledged here or in Section 6.5
Data Review.
If you have any questions please do not hesitate to call me at [phone].
Sincerely,
Draft
Kenneth Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
2
• &i;h •
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director
Mr. Ken Lucas
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, ll th Floor
Atlanta, Georgia 30303
Division of Waste Management
May 16, 2005
RE: Draft Five-Year Review Report
JFD Electronics/Channel Master NPL Site
Oxford, Granville County
Dear Mr. Lucas:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received the Draft Five-Year Review Report for the JFD Electronics/Ch_annel
Master National Priority List (NPL) Site. The Superfund Section has reviewed this document and
offers the following attached comments.
Thank you for the opportunity to comment on this document. If you have any questions, please
feel free to contact me at [phone].
Attachment
Sincerely, 12 fi,!:!( .1iJ,
Environmental Engineer
NC DENR Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] I FAX [phone] I Internet http://wastenotnc.org
An Equal Opportunity/ Affirmative Action Employer-Printed on Dual Purpose Recycled Paper
Mr. Ken Lucas
May 16, 2005
Page I
• •
JFD ELECTRONICS/CHANNEL MASTER NPL SITE
Draft Five-Year Review Report
GENERAL COMMENTS
The Draft Five-Year Review Report, as currently written, does not provide a comprehensive
review of the JFD Electronics/Channel Master National Priorities List (NPL) Site (the Site), and
does not follow the template given in the Comprehensive Five-Year Review Guidance (United
States Environmental Protection Agency (USEP A), June 2001 ). The Draft Five-Year Review
Report provides a thorough review of the site chronology, background and remedial actions for
the groundwater contamination at the Site but does not adequately describe, review or evaluate
the remedy for contaminated soil/sludges at the site. Therefore, a thorough description, review
and evaluation of the soil/sludge remedy must be included in this Draft Five-Year Review
Report. Please revise the Draft Five-Year Review Report accordingly.
As currently written, the Draft Five-Year Review Report, does not explicitly follow the template
given in the Comprehensive Five-Year Review Guidance (US EPA, June 2001) (the Guidance).
Collaboration between the US EPA and the North Carolina Department of Environment and
Natural Resources (NC DENR) Superfund Section on other five-year reviews at other sites has
yielded much experience, including the position from US EPA headquarters management that all
five-year reviews be conducted in strict accordance with the Guidance and that the format of the
reports shall follow the template given in the Guidance. Because of the multitude of entities that
shall receive a copy of this Draft Five-Year Review Report and shall have the opportunity to
review and comment on this document, including the public and various management levels
within the regulatory environment, experience has shown that the most comprehensive, yet
simplest, method of reporting the results of the five-year review process is to explicitly follow the
format of the five year review report, as given in Appendix E of the Guidance. Although the NC
DENR Superfund Section shall be responsible for finalizing the Draft Five-Year Review Report
(i.e., developing the statement of protectiveness for the Site), the intent of the July 22, 2003
"Request to Initiate Studies and Investigations for the Five-Year Review" was for the Settling
Defendants to perform a five year review, and document in the form of the Draft Five-Year
Review Report, in accordance with the Guidance. As currently written, this document does not
satisfy this requirement. Please make the appropriate modifications to the Draft Five-Year
Review Report and provide copies of the Final Five-Year Review Report in both paper and
electronic format (i.e., Microsoft Word) upon its completion.
Mr. Ken Lucas
May 16, 2005
Page 2
•
SPECIFIC COMMENTS
Table of Contents
•
1. Please correct the Draft Five-Year Review Report and the Table of Contents to indicate
that the titles of Section 3.3 and Section 4.0 are "Soil/Sludge Remedy Implementation"
and "Five-Year Review Process", respectively.
2. Please correct the Draft Five-Year Review Report and the Table of Contents to indicate
that Section 8.0 is located on page 8-1.
3. Please correct the Table of Contents to indicate that the title of Figure 2-1 is "Site
Layout".
4. Please correct the Table of Contents to indicate that the titles of Table 2-1 and Table 5-1
are "Site Chronology" and "Annual System Operation and Maintenance Costs",
respectively.
5. Please correct the Draft Five-Year Review Report and the Table of Contents to indicate
that the titles of Appendix B, Appendix E, and Appendix G are "VOC Trends in
Monitoring Wells", "Photographs Documenting Site Conditions" and "Review of
Source Area Treatment Technologies", respectively.
Section 1.0 Introduction
6. Please correct the last two sentences of Section 1.0 to indicate that Section 6.0 contains
information regarding any issues noted during the five-year review process, Section 7 .0
contains recommendations and follow-up actions regarding the remedy, and Section 8.0
contains various references that were used in the preparation of this document.
Section 2.0 Site Chronology and Background
7. Please correct the spelling of the word "system" in the first sentence of the fourth
paragraph of Section 2.0.
Section 2.2 History of Contamination
8. Please correct the second sentence of Section 2.2 to state "Throughout the operation of
the various processes at the facility, solvents were reportedly used for cleaning and
degreasing."
Mr. Ken Lucas
May 16, 2005
Page 3
• •
Section 4.5 Site Inspection
9. Please revise this section to provide much greater detail regarding the site inspection,
including who conducted the inspection, when the site inspection was conducted, how the
inspection was conducted, the remediation system components inspected, the inspection
of the former sludge drying beds area, etc. The "Five-Year Review Site Inspection
Checklist", found as Appendix Din the Comprehensive Five-Year Review Guidance
(USEPA, June 2001), should be used as a guide for conducting the site inspection and
attached to this document as a separate appendix.
I 0. Please correct the last sentence of Section 4.5 to state "Photographs taken during the site
inspection are contained in Appendix E."
Section 4.7 Groundwater Modeling
11. Please provide the source of the groundwater recharge value given in the second bullet
item in Section 4.7.
APPENDIXB voe TRENDS IN MONITORING WELLS
12. Please revise all of the graphs given in Appendix B to provide the date as is shown on the
graphs for monitoring well CMMW-20 and CMMW-21 in Appendix B.
APPENDIXC HISTORIC RECOVERY WELL AND INFLUENT voes
13. Please revise all of the graphs given in Appendix C to provide the date as is shown on the
graphs for monitoring well CMMW-20 and CMMW-21 in Appendix B.
APPENDIXF
Table of Contents
GROUNDWATER FATE AND TRANSPORT MODELING
14. Please revise the Table of Contents of Appendix F to clearly indicate the page number
where Section 6.1.3 is located.
List of Tables
15. Please correct the List of Tables of Appendix F to reflect the actual table titles for Table
2.1, Table 4.1, Table 4.2 and Table 5.3.
16. Please correct the List of Tables of Appendix F to indicate that the title of Table 5.1 is
"Historical and Average Pumping Rates".
Mr. Ken Lucas
May 16, 2005
Page 4
List of Figures
• •
17. Please correct the List of Figures of Appendix F to reflect the actual figure titles for
Figure 1, Figure 12, Figure 14A, Figure 14B, Figure 15, Figure 16, Figure 17, Figure 18,
Figure 19, and Figure 20.
Section 1.0 Introduction
18. Please correct the third sentence of the second paragraph of Section 1.0 to state "The
workplan outlines the details of the proposed modeling approach."
19. Please correct the third bullet item in the third paragraph of Section 1.0 to state
"Selecting a computer program that can best represent the conceptual transport model
and meet the project objectives."
Table 2-1 Comparison of Measured Groundwater Elevations (November 1992) with
Calibrated Models
20. Please define the "Average Absolute Value of Residual" given in Table 2-1.
APPENDIXG ALTERNATIVE TECHNOLOGIES FOR SOURCE AREA
REMEDIATION
21. Please correct the tenth sentence of the first paragraph of Appendix G to state
"Experience with similar site geology is that the DNAPL smears into pore spaces and is
sequestered."
INTERNATIONAL,-
December 12, 2003
Mr. Ken Lucas
U.S. Environmental Protection Agency
Region IV
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303-8960
••
ENSR International
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616-3013
PHONE [phone]
FAX [phone]
RE: Revised Groundwater Modeling Workplan, Five-Year Review of the Groundwater
Remediation System
JFD Electronics/Channel Master Site, Oxford, North Carolina
ENSR Project Number 10140-007-0001
Dear Mr. Lucas:
On behalf of JFD Electronics Corporation and CMSS, Inc., ENSR Consulting and Engineering (NC),
Inc. (ENSR) is submitting a revised groundwater modeling workplan associated with the five-year
review of the groundwater remediation system at the JFD Electronics/Channel Master site. The
revised plan addresses the United States Environmental Protection Agency (USEPA) comments
dated October 17, 2003 (sent via electronic mail). The key comment by the USEPA reviewer on the
groundwater modeling workplan was to establish performance criteria. As noted by the reviewer,
the evaluation of calibration using statistical methods can be difficult and time consuming. Therefore,
ENSR proposes evaluation of model calibration by comparing the simulated concentrations with the
observed concentrations prior to the activation of the pumps. As suggested by the reviewer, ENSR
proposes comparing figures (from previous studies and reports) that show chemical concentrations
and plume extents with model-predicted concentrations, gradients, and plume extents. As
discussed before, the transport modeling will simulate three key constituents of concern at the site,
tetrachloroethene, trichloroethene and cis-1,2-dichloroethene. Additional details in the modeling and
calibration are provided in the attached workplan (revised).
SJPUBS\PROJECTIC\ChanneMaster.5-Year Review Wak PlanlEPAJev_mod-12· 12-03.doc
December 12, 2003
Mr. Ken Lucas
Page2
• •
If you have any questions, please contact us at [phone].
Sincerely,
ENSR Consulting and Engineering (NC), Inc.
Nanjun V. Shetty, P.E.
Project Manager
Enclosure
cc: Brian Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
William H. Doucette, Jr., ENSR
David Mattison, NCDENR
Steve Earp, Smith Moore
Maya Desai, ENSR
William H. Doucette, Jr., Ph.D., L.G.
Project Coordinator
EN31.. • V:@·?t-fiW&@ Memorandum
To:
From:
RE:
Bill Doucette, Nanjun Shetty
Elizabeth Perry, Maya Desai
JFD/CM: Revised Modeling Workplan
Date:
File:
CC:
•
December 12, 2003
On-going remediation at the JFD/Channel Master site consists of groundwater pumping from several pumping
wells to remove VOCs and contain migration. The 5-year review of the remedy is to be completed in 2004.
Solute transport modeling will be used as part of the 5-year review to aid in evaluating the effectiveness of
potential changes to operation of the groundwater pumping system. Specifically, the modeling will be used to
evaluate potential migration of VOCs under conditions where pumping is discontinued at one or more of the
pumping wells. The purpose of the modeling is to evaluate how far and at what concentrations the VOCs may
migrate under these conditions.
The modeling will consist of the following tasks:
Conceptual Model -Existing site information will be reviewed to develop a conceptual model for the fate and
transport of the VOCs at the site. Types of information to be considered includes source area(s) and source
conditions, current and pre-pumping concentration distributions, and attenuation processes (retardation,
degradation, dispersion, etc.). Significant data gaps, if any, will be identified.
Numerical Models -Groundwater flow modeling was previously performed at the site to evaluate and design the
current pump and treat system. The modeling was performed using MODFLOW, developed by the USGS. This
numerical model will serve as the basis for the modeling to be performed to support the 5-year review. In
addition, MT3D, developed under contract to the USE PA, will be used for the transport modeling. MT3D uses
groundwater flow information generated by MODFLOW.
Groundwater Flow Model -The existing groundwater flow model (MOD FLOW) will be refined to support transport
modeling.
• The model will be transferred to the GMS platform - a pre-and post-processor for MODFLOW and MT3D,
• The model will be adjusted to ensure it properly interfaces with GMS,
• The model grid will be refined (i.e., smaller cell size) in anticipation of the transport modeling, and
• The model will be run to ensure that the refined/updated model simulations are the same as the model
completed by Geraghty & Miller, Inc. (1995).
It is assumed that the previous hydraulic characterization remains adequate and no changes to these values or
additional calibration will be required.
Flow Simulations -The refined groundwater flow model will be used to perform simulations of groundwater flow
fields for up to five different pumping scenarios, each representing potential future changes in operation of the
system. Simulations may include simulating the head field with existing pumping rates, no pumping at all, and
on-site pumping only. Other simulations will be defined later and may include changing the number of pumping
wells. The head fields generated by the flow model will serve as input to the transport model.
Transport Modeling -The transport modeling will be performed using MT3D, as noted above. The purpose is to
predict future migration of constituents at the site under various changes in operation of the groundwater
pumping system. Transport modeling will include set-up, calibration, and simulation.
• The setup phase will include establishing initial and boundary conditions for the transport, inputting source
terms, and inputting fate and transport parameters (retardation, dispersion, etc.). The model will be set up
S:\PUBS\PROJECl\C\ChannelMaster\5-Year Review Work
Plan\model plan-revised-12-12-03.doc
EN:11. f2¼·?dm/Kti • • December 12 2003
and calibrated assuming two source terms -one on site and one off site. ENSR will model transport of
trichlorethylene (TCE), tetrachloroethylene (PCE), and cis-1,2 dichloroethylene (DCE), the primary chemicals
of concern. ENSR assumes that no degradation of the contaminants will be modeled, based on limited field
evidence for degradation. This approach is conservative as it will tend to overpredict concentrations.
• In the calibration phase, ENSR will adjust input parameters (hydrogeology, attenuation, source conditions)
until the predicted (modeled) results adequately represent observed conditions (in this case, concentrations)
as discussed in detail below. The model will be calibrated to concentration data measured before the
remediation system went into operation. The initial time for the model will be in the past, when the releases
first reached groundwater. The model will then be run to generate the pre-pumping concentration
distribution, which will serve as the basis for calibration.
• Prior to calibration, performance criteria for the modeling will be established. The performance criteria will be
used as a benchmark by which calibration can be measured. The performance criteria will be met before the
calibration is considered adequate, at which point the simulations can begin. As noted by the EPA reviewer,
the evaluation of calibration using only statistics can be difficult and "not particularly intuitive." Instead, as
suggested by the reviewer, the calibration will be evaluated using a comparison of simulated concentrations
to observed concentrations as presented on a plume map or figure. For this project, ENSR will focus the
calibration effort on simulating chemical concentrations downgradient of the source area consistent with what
was observed in the downgradient wells in April 2000 (baseline data collected prior to startup of the
groundwater remediation system). Other plume maps and historical data may also be considered during the
calibration process. ENSR may evaluate the calibration by considering the following factors: the total mass of
chemicals both measured and simulated, site-wide average concentrations, concentration gradients, and
professional judgement. In general, ENSR will consider the model calibrated when the model captures the
extent and approximate concentration of downgradient observations of TCE, PCE, and DCE. The modeled
plume will be compared to the observations on Figure 4-2 as noted above, The wells to be considered in
calibration include: CMMW-04, CMMW-06, CMMW-07, CMMW-14, CMMW-15, CMMW-16, CMMW-17,
CMMW-18, CMMW-19, CMMW-21, CMMW-22, CMMW-23, and CMMW-24.
As is common in such situations, constituent concentrations in the source area have been observed to be
variable. For this reason, the calibration for the source area will be completed primarily to assure that
downgradient concentrations are well represented. The source area will be simulated to conceptually match
what is known about the historical disposal practices but no attempt will be made to capture short-term
temporal variation.
• Once the model is adequately calibrated to pre-pumping conditions, the simulation of groundwater extraction
via the pumping wells will be completed to simulate present and future conditions.
• ENSR will model contaminant transport into the future under the various pumping scenarios generated by the
groundwater flow model discussed above. The results will predict chemical concentrations over time under a
maximum of five different scenarios. The future conditions will be simulated up to 50 years into the future. ·
Reporting -The model set up information and results will be included as an appendix to the 5-year review
document.
$:\PUBS\PROJECnC\ChannelMaster\5-Year Review Work
Plan\modelplan-revised-12-12--03.doc Page 2
-···•·------' • • ',\ f:: :::._,;) [)-,
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, I ,-~, ·. , I I I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYi l
REGION 4 i.., l:
! ii OCT -2 2003 ! .. :J
4WD-SRSEB
Via Federal Express
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
SEP 3 0 2003
William H. Doucette, IL, PhD., LG,
Senior Program Manager
ENSR International
7041 Old Wake Forest Road
Raleigh, NC 27616-3013
l .• --·--· .. _J
Subject: "Work Plan to Perform Five-Year Review of the Groundwater Remedial System"
JFD Electronics/Channel Master Site, Oxford, North Carolina
September 17, 2003
Dear Mr. Doucette
The purpose of this letter is to approve the work plan for the Five-Year Review of the
JFD Electronics/Channel.Master site, which was submitted by ENSR Consulting and
Engineering (NC) Inc., on behalf of JFD Electronic Corporation. This approval is conditioned
upon acceptance, by the Potentially Responsible Parties (PRPs), of the considerations identified
in the comments below,
General Comment
Although some of the contaminants of potential concern (COPCs) identified in the 1992
Record of Decision (ROD) were eliminated from screening after the startup of the groundwater
remedial action, sampling, analysis, and modeling should cover all COPCs, not just VOC's. The
five-year review may ultimately result in a recommendation for the modification of these
requirements. The rationale for this is based upon review of the following citation is from
Section IX of the 1992 ROD,
". . . Groundwater shall be treated until the following levels are attained at the extraction
wells:
Benzene 5 ppb
1,2,-Dichloroethane 0.38 ppb
I; I, ~Dichloroethenl 7 ppb
1,2,-Dichloroeihene 70 ppb.
Tetrachloroethene 0. 7 ppb
Internet Address (URL)• http://www.0pa.gov
Aecycled/Aecyclable • Pnn!ed with Vegetable OB Based Inks on Recycled Paper \Minimum 30'% Postconsumer)
•
1,1, 1, -Trichloroethane 200 ppb
Trichloroethene 2.8 ppb
Vinyl Chloride 0.015 ppb
Barium 1,000 ppb
Chromium 50 ppb
Copper 1,000 ppb
Lead 20 ppb
Nickel I 00 ppb
Zinc 500 ppb
Cyanide 154 ppb
•
The goal of this remedial action is to restore groundwater to its beneficial use as a drinking
water source. Based on information collected during the RI and on a careful analysis of ail
remedial alternatives, EPA and the State of North Carolina believe that the selected
groundwater remedy will achieve this goal. The ability to achieve remediation levels at all points
throughout the area of the plume cannot be determined until the extraction system has been
implemented, modified as necessary, and plume response monitored over time. If the
implemented groundwater extraction system cannot meet the specified remediation levels, at any
or all of the monitoring points during implementation, the system performance standards
and/or the remedy may be re-evaluated. Such contingency measures will, at a minimum, prevent
further migration of the plume and include a combination of containment technologies and
institutional controls. These measures are considered to be protective of human health and the
environment, and are technically practicable under the corresponding circumstances. For cost
estimating purposes, groundwater extraction was projected for a period of 5 years, during which
time the system's performance will be carefully monitored on a regular basis. Monitoring may be
adjusted as warranted by the performance data collected during the initial operation of the
system. Modifications shall be approved by EPA prior to implementation, andmay include any or
all of the following:
. ·alternating pumping at wells to eliminate stagnation points;
. pulse pumping to allow aquifer equilibration and to allow adsorbed
contaminants to partition into groundwater;
. installation of additional extraction wells to facilitate or
accelerate remediation of the contaminant plume; or
. discontinue pumping at individual wells where remediation levels have
been attained, only after analytical confirmation. "
Specific Comments
l. Section 1.2 Objectives
... To evaluate the potential migration of the dissolved VOC plume if offsite groundwater
pumping is discontinued.
2
• •
EPA Comment -This evaluation process is consistent with the objectives stated in the
Comprehensive Five-Year Review Guidance (CFYRG) Exhibit3-3: Contents ofa Five-Year
Review Report, VII. Technical Assessment Question 8:
Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RA Os) used at the time of the remedy still valid? ... expected progress
towards meeting ROA 's. The Five-Year Review Report should follow the format of
this Exhibit 3-3 where appropriate.
However, this evaluation must also include a discussion of issues which may affect current or
future protectiveness. Please include in the five-year review, an assessment of how the
contaminant plume emanating form the adjacent Cristex site will factor into these
determinations. '"
2. Section 2.3 Surface Water Sampling
EPA Comment -Sediment samples must be collected as well. A separate Field Sampling and
Analysis Plan (FSAP), and a Quality Assurance Project Plan (QAPP) must be submitted and
approved by EPA prior to this event. In order to accommodate the October 2003 schedule,
please submit the FSAP and QAPP within 15 days of your receipt of this letter. For your
reference the following citation was excerpted from the 1992 ROD:
" E. Environmental (Ecological) Risk
Potential risks to environmental receptors at or near the Site were
evaluated based on Site sampling data and a review of the toxicity of the
chemicals of potential concern to ecological receptors .... the Jams of the ecological assessment
was on the intermittent creeks east and south of the site and the small low-lying area south of the
railroad tracks ..... It is also possible that some sensitive aquatic invertebrates could be
adversely affected by chromium, nickel, and some PAHs present in the sediment al sample
locations such as CMSD06 .... "
3. Section 2.4 Groundwater Modeling
EPA Comment -Groundwater modeling should include an evaluation of the data that has been
collected over the entire monitoring period. The actual progress of the contaminant plume from
the source areas to potential discharge points and other receptors should be compared to results
from the modeling. Additional consultation with EPA will be necessary for the successful
implementation the ground water modeling. EPA will review the documentation provided in
Appendix A of the work plan and provide a separate comment/approval letter.
3
• •
4. Section 2.5 Evaluation of Alternatives for Hot-Spot Remediation
EPA Comment -The results of the enhanced reductive dechlorination (ERD) pilot test should be
incorporated into the evaluation of the potential migration of the dissolved VOC plume, if
offsite groundwater pumping is discontinued.
5. Section 2.6 Report Preparation
... Protectiveness Statement.
EPA Comment -EPA will make the protectiveness determination in consultation with
NCDENR. The report should reflect this process. The actual five year review report will be
finalized by the State of NC and then submitted to EPA for review of accuracy, and the-'" '
protectiveness determination. When the final draft is submitted to EPA and NCDENR, no
statement of protectiveness should be included. You may included recommendations as
indicated in the format for Section IX. Refer to FYRG Section 3.7.3 How is a State ... report
submitted? Section X of the five year review report should refer to the protectiveness
determination being made by EPA.
Please carefully review the comments provided above and confirm your acceptance of
these conditions for approval of the five-year review work plan within five working days of your
receipt of this letter. If you have any questions, you may contact me at [phone].
cc: David Mattison, NCDENR
Remedial Proj eel Manager
North Site Management Branch
4
•
INTERNATIONAL
September 17, 2003
Mr. Ken Lucas
U.S. Environmental Protection Agency
Region IV
Waste Management Division
61 Forsyth Street, SW
Atlanta, GA 30303-8960
ENSR International
. 7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616-3013
PHONE [phone]
__.,.\;:::\. FAX [phone]
· \ • www.ensr.com
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RE: Work Plan to Perform Five-Year Review of the Groundwater Remediation System
JFD Electronics/Channel Master Site, Oxford, North Carolina ·
ENSR Project Number 1014007,0001
Dear Mr. Lucas:
On behalf of JFD Electronics Corporation and CMSS, Inc., ENSR Consulting and Engineering (NC),
Inc. is pleased to submit one original and two copies of the Work Plan to Perform Five-Year Review
of the Groundwater Remediation System at the JFD Electronics/Channel Master site in Oxford, North
Carolina. This work plan was prepared in response to your letter dated July 22, 2003 requesting a
work plan to conduct the five-year review. A copy of the work plan was transmitted to Mr. David
Mattison, North Carolina Department of Environment and Natural Resources.
If you have any questions, please contact me at [phone].
Sincerely,
ENSR Consulting and Engineering (NC), Inc.
-v'-~
Nanjun V. Shetty, P.E.
Project Manager
Cc: Brian Kempner, The Unimax Corporation
S. Alan Lazar, Avnet, Inc.
William H. Doucette, Jr., ENSR
David Mattison, NCDENR
Steve Earp, Smith Moore
S:\PUBS\.PROJECnC\ChannelMasfer\.S. Year Review Wcrl PlanU.xas091703.doc
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
4WD-NSMB
· WilliamH. Doucette, Jr., PhD., L.G.
Senior Program Manager
ENSR International
7041 Old Wake Forest Road
Raleigh, NC 27616-3013
JUL :c 2 ZOIJJ
10) lE ~ lE ~ w lE ITT\
ml\ JUL2 a 21lW \ 1111
SUPERFUND SECTIOn
Subject: Request to Initiate Studies and Investigations for the Five-year Review
JFD Electronics/Channel Master Superfund Site, Oxford, North Carolina
Dear Mr. Doucette
This notice is being provided pursuant to Sections VII, VIII, and XXVII of the Consent
Decree between the United States of America and JFD Electronics Corporation and Channel
Master Satellite System, Inc., Civil Action No. 93-650-CIV-56.
The United States Environmental Protection Agency (EPA) is requesting that the Settling
Defendants initiate studies which will form the basis for EPA's Five-year Review of the JFD
Electronics/Channel Master Superfund Site, as required by Section 12l(c) ofCERCLA, and in
accordance with the "Comprehensive Five-Year Review Guidance", OSWER Directive
9355.7-03B-P, dated June 2001. The guidance document is enclosed with this letter.
Within 60 days of your receipt of this notice, please submit a work plan for the conduct or
the Five-year Review. If you have any questions, you may contact me at [phone].
Enclosure
Sincerely, . I
\ I I \ i -~-\ -·~ ,.. I \ ••••• \ . X\', .. \ \. \ \,_ ·-• .. 1
K:~~neth A. Lucas
I (
,i '--
"
Remedial Project Manager
North Site Management Branch
cc: David Mattison, NCDENR
:nt,m1et Address (URL)• http:/lwww.epa.gov
fhicy..:!edifi~qd;.,lJII.'. f"nnt&d Ni!h -✓e~etatile Oil Based Inks on Recyded Pttper (Minimum :10% Poslconsurmit)