NCD980729602_19901129_Jadco-Hughes_FRBCERCLA FS_Feasibility Study-OCR

I I' l
~StA7l<> ,. '. j ~i I ltt:l"J.
"-:.:::.:;;..• Dt C ~/f/0{)
, " l9, State of North Carolina , o'IJPRJr.. 1990
Department of Environment, Health, and Natural Resourc~NOstr
DMsion of Environmental Management : "'llOtv
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
'Nllliam W. Cobey, Jr., Secretary
George T. Everett, Ph.D.
M E M O R A N D U M
TO:
FROM:
SUBJECT:
November 29, 1990
Lee Crosby, Chief
Superfund Section
Division of Solid Waste Manag'
George T. Everett, Director 1 1 Division of Environmental Man(gemen
Revised Feasibility Study Report
Jadco-Hughes Superfund Site '
Belmont, Gaston County, North Carolina
Project #26
Director
The Division of Environmental Management has reviewed the subject
report as requested. The comments from our Water Quality,
Air Quality and Groundwater Sections are provideh below: ,,
Water Quality Sectio~!
I
The surface water standards in the study report of the subject
site are not consistent with 15NCAC2B, August 1990. Fites Creek
must meet these standards. No additional comments can be offered
at this time. However, if discharge to surface ~ater is anticipated,
appropriate permit(s) will need to be obtained.
Air Quality Section:
The Air Quality Section has no additional comments to offer.
Groundwater Section:
Section 2.3.3. of the subject study report should read "As shown
on table 2.1, Groundwater ARAR's are established !by North Carolina
Administrative Code Section: 15A NCAC 2L 'Classifications and Water
Quality Standards Applicable to the Groundwaters :of North Carolina'".
Section 2.4 contains several inaccurate statemen~s and should be
corrected as follows:
Pollution l'mlendon Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 9l9-7~3-7015
An Equal Opportunity Affirmative Action Employer I
Groundwater Standards
' The state groundwater standards are estab~ished by North
Carolina Administrative Code Section: 15A NCAC 2L Rule .0202
with the intent to protect all groundwaters of the state, not
just permitted facilities, to a level of quality at least
as high as that required by the Standards! It is North Carolina
state law that groundwater quality be restored to the level of
the standards; therefore, the stringency of these standards
can not be subject to argument or discuss~on.
•
I
Request for Variance I
I
Please refer to 15A NCAC 2L Rule . 0106 1
1
to find the pro-
cedures regarding the consideration of a request to
discontinue remedial action and petition for a variance
by the responsible party. [
I
• Points for Compliance ( Compliance Bound'aries)
I
Compliance Boundaries are for use only ~ith facilities
permitted by the State. They would not\ be applicable
to the situation at hand. State ground~ater standards must
be met on-site as well as off-site to the extent possible.
If there
contact,
Regional
is any need for added information
Ms. Chris DeRoller or Ms. Barbara
Office at [phone].
cc: Perry Nelson
Steve Tedder
Lee Daniel
Brenda Smith
Nargis Toma
File
I
or ciarification, please
Chri~tian, Mooresville
•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
4WD-NSRB
September 28, 1990
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Benton R. Leach
:SAS COURTLAND STREET
ATLANTA, GEORGIA 30305
Jadco-Hughes S~eering Committee
RI/FS Coordinator
c/o Uniroyal Chemical Company
Benson Road
Middlebury, Connecticut 06749
Re: Jadco-Hughes Superfund Site
Feasibility Study and Risk Assessment
Dear Mr. Leach:
This letter is written to provide approval of the July submittal of
the Feasibility Study Report. The Superfund Risk Assessment was
revised by the addition of EPA com.~ents. These comments are
incorporated into the report. A copy of this revised version is
enclosed. This version represents the final Superfund Risk
Assessment.
Please contact me if you have any questions. I can be reached at
404/347-7791.
'
Waste Management Division
cc: Reuben Bussey, ORC
Lee Thomas, Groundwater Technology Support Unit
Lee Crosby, NCDEHNR
Jack Butler, NCDEHNR .,,,,---
Bruce Nicholson, NCDEHNR~
II
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
7 August 1990
MEMORANDUM
TO: Perry Nelson, Chief
Groundwater Section
FROM:
RE:
Division of Environmental Management
Lee Crosby, Chief / . ~ /
Superfund Section.~
l/
Revised Feasibility Study Report
Jadco-Hughes Superfund Site
Belmont, Gaston County, North Carolina
William L. Meyer
Director
EPA is in the process of completing a Feasibility Study for the Jadco-Hughes Superfund Site, a National Priorities List site.
Attached is one copy of the Revised Feasibility Study Report for the subject site. This report was prepared by Conestoga-Rovers and Associates for the U.S. EPA. It is requested that this document be forwarded to the appropriate sections of DEM anti
' comments be submitted to the N.C. Superfund Section. The N.C. Superfund Section will be reviewing this document and submitting comments to EPA Region IV in the near fururJ. It is our desire to include the views and permitting requirements of Air Qualitx, Groundwater, and Water Quality Sections of DEM.
If you or your staff have any questions, please call Bruce Nicholson, Jack Butler, or me at [phone].
LC/jo/memos.jb
Law or Regulotion
4. N.C. Air Pollution Control
Regulations
5. N.C. Water Supply Rules
6. Capacity Assurance
Regional Agreement
7. North Carolina
Sedimentation Pollution
Control Act
8. North Carolina
Classification and Water
Quality Standards
Applicable to the
Groundwater of North
Carolina
TABLE 2.1
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
JADCO-HUGiIES RUFS
Refrrmce
lSNCAC 2D, 2H
10NCAC10B
42 USC 9601 at Seq.
NCGS, Chapter 113A,
Article 4
Ambient or Chemical Specific ARAR
Central criteria for air discharges
Rules Governing public water supplies
that are or might be used as drinking
water.
N/A
N/A
15NCAC2H .0100, .0200, Groundwater standards
and .0300
Perfonnance, Design or Action
Specific ARAR
Alternatives involving discharges to air
Alternatives involving discharges to
groundwater.
Alternatives involving off-site treatment
or disposal of hazardous wastes
N/A
Alternative involving groundwater
remediation
Page 5 of 5
Location
Specific ARAR
N/A
N/A
Applicable il1 conjunction
with action specific
ARARs
N/A
To be considered
for groundwater
classification
•
•
•
2.3.2 Surface Water Criteria
North Carolina Water Pollution Control Regulations
15NCAC2H regulate surface water quality. These rules specify that Fites
Creek, Class C, must meet the standards for all freshwaters. Federal Ambient
I
Water Quality Criteria are also considered as criteria to be considered for Fites
Creek. These standards are contained in 15NCAC2B and displayed on
Table 2.2.
2.3.3 Groundwater ARARs
As shown on Table 2.1, groundwater ARARs are
established by Federal Maximum Contaminant Levels. These rules indicate
that a present source of drinking water should meet the standards set out ih
the code.
Standards are distinctly different from criteria. Standards
are regulatory-based values which are enforceable under certain conditionJ.
Standards are used to establish ARARs. Criteria are values developed froJ
research which are not ARARs but are to be considered when establishing
remedial objectives.
Table 2.3 contains a summary of standards and criteria for •
drinking water that are health based. Federal and State drinking water
standards are established for public water supplies.
16
• •
TABLE2.2
SURFACE WATER CRITERIA TO BE CONSIDERED
JADCO-HUGHES RI/FS
Parameters
Arsenic (µg/L)
Barium (mg/L)
Beryllium (µg/L)
Cadmium (µg/L)
Chloride (mg/L)
Chloride, total residual (µg/L)
Chlorophyll a, corrected (µg/L)
Chromium, total (µg/L)
Cobalt (mg/L)
Coliform, fecal (MFFCC/100 ml)
Copper (µg/L)
Cyanide (µg/L)
Dissolved gases
Dissolved oxygen (mg/L)
Fluoride (mg/L)
Iron (mg/L)
Lead (mg/L)
Manganese (µg/L)
MBAS (µg/U
Mercury (µg/L)
Nickel (µg/U
Nitrate nitrogen (mg/L)
Pesticides (µg/L)
Aldrin
Chlordane
DDT
Demeton
Dieldrin
Endosulfan
Endrin
Guthion
Heptachlor
Lindane
Methoxychlor
Mirex
State Criteria for
Fites Creek
50
11.0
2.0 (TR)
230
(TR)
(Nl
50
1.0
1,000 (NC)
15 (AL)
5.0
(N)
5.0 (TR)(SW) (1)
1.8
1.0 9AL)
25 (2)
500
0.20
50 <2>
0.002
0.004
0.001
0.1
0.002
0.05
0.0002
0.01
0.004
0.01
0.03
0.001
Federal Criteria
for Fites Creek
0.0022
1.000
0.0068
10
2P
0.05
50
0.14
13.4
1.0
0.000074
0. 00007 4
0.00046
0.000024
0.
74
l
0.00028
100
Page I of 2
•
TABLE2,2
SURFACE WATER CRITERIA TO BE CONSIDERED
JADCO-HUGHES RI/FS
Parameters
Parathion
Toxaphene
2,4-D
2,4,5-TP (Silvex)
pH (Units)
Phenolic compounds (µg/L)
Polychlorinated biphenyls (µg/L)
Radioactive substances
Selenium (µg/L)
Silver (µg/L)
Solids, suspended
Temperature
Toxic substances
Trialkyltin (µg/L)
Turbidity
Zinc (µg/L)
Notes:
State Criteria for
Files Creek
0.04
0.013
6.0 -9.0 (SW)
(N)
0.001
(N)
10 (3)
10 (AL)
(N)
(N)
(NJ
0.008
(NJ
50 (AL)
Federal Criteria
for Files Creek
0.00071
100
10
~
0.000079
10 so
Standards taken from North Carolina Administrative Code, Title 15, Chapter 2, Section 2B
(N) See 2B.0211 (b) for narrative description of limits
(NC) See narrative description for specific classification
(AL) Values represent action levels as specified in .0211 (b)(4)
Page 2 of 2
(SW) Designated swamp waters may have a pH as low as 4.3 and dissolved oxygen less than
5.0 mg/L if due to natural conditions
(TR) Designated trout waters have cadmium limit of 0.4 µg/L, a total residual chlorine limit of
2.0 µg/L and dissolved oxygen must be at least 6.0 mg/L [
(1) An instantaneous reading may be as low as 4.0 µg/L but the daily average must be 5.0 mg/Lor
more
(2) or is more stringent, 0.01 of the 96-hour LCS0
(3) Selenium limit for ponds, lakes and reservoirs is 5 µg/L
Federal Criteria for Files Creek based on Ambient Water Quality Criteria for water and fish ingestion.
TABLE 2.J Pase3of9 e
rART I: SUMMARY Of DRINKING WATER AND GROUNDWATER STANDARDS
AND CRITERIA AND BACKGROUND
!ADCO-HUGHES Rl/fS
ARAR, at Sita s-"""'!l Otlur St.Wroh aU Criuria
St.ta Watn NC NC Aca,,r.blt Qulity51DS AWQC Driili11,t Gro11UW11,..,. Gro11111luatar IRIS(~ IRIS~ for frt"'"111tn WatnlirfiM w .... . ...,. ... Co..catntio11 C•rri.oJn, Carri..a,nq Ft>h,w/W St.ta (f} S.clc,rrcn,...t ci.-J111ario11 MCL{b) St...,_ro& Cd '" (No.,•C•rri_,,,...H,> 10-S Ritl JHRi1k PMCL(lo) oMCL ,MCL "' (/) IRIS, loJ
ll:11s:ltllc111DI and Add Eltr:Kt,11:!lc '-'mllt!ZIIDdl llt:M.11 l111ll I
bis Q-chloroethyl) etha-03 0.03 ND 0.03 P""'°' 21,000 14,000 1,400 1.0 ND 300 1, 3-dichlorobenzc,e ND 1, 4-dichlorobenune (~1-dkhlcnibmzene) 75 75 5 ND 1,2-dichbobenune 600 3,150 600 ND bu Q-chloroisopropyl) ether 1,400 ND 34.7 benm,odd 140,txKJ ND di-n-cctylphth.uate ND 2-mdhylphe:nol 1,750 ND 4-mdhylphenol 1,750 ND • ~p-ND 1,2,4-trichlorobenune ' ND di-n-butyl phth.uate 3,500 ND 34000 bis Q--ethyhexyl) phthalate 700 30 3.0 3.95 15400
IDRIIIDi, Cammmnd11111a I
Aluminum 11,190 Antimony 10/5• 14 140 14 65 146 Analic so so so 19 so 0.0022 S..rium 1,IXKI 1,IXKI J,000 1,750 18,000 1,800 5,000 96.5 I() Bnyllium I 173 0.063 0.0063 ND II 0.0068 Udrnium 10 10 5 17.5 100 JO 5 • 2.0 (TR) JO Chromium VJ 50 so so 173 1,700 170 100 51 so SO(g) Copp,, 1,000 13,000 IJ!!!! 1,300 1,000 154 80.5 15(AL) Iron 300 300 300 300 16,300 1000 CAL) JOO(el wd 50 so 50 ... ., 5 760 25000(m) SO(el Muiganee 50 n,ooo---7.700 50--50---3]50 50 SO(el Nido. JOO--150 700 7,000 700 82 SO(ml 13.4Ce> Selenium 10 10 10 1,100 110 50 50 ND IO(n) l0(e) Silver 50 so 50 103 1.100 110 ND I0(AL) so Tlullium 2/1' 140 14 ND
lnoqenir Comrmmd, lust! l
Zin,
Chloride, tot;al
Ulcium
Coball
M.1gnciium
Potassium
Sodi=
v....ai=
Notes:
ARAR• ., Siu BoHMry
NC
Driid:i•,t
w ....
MCL/ltJ Sr.Ullrb(c}
5,000
TABLE2.3
FART I: SUMMARY OF DRINKING WATER AND GROUNDWATER STANDARDS
NC
Gro•IIN•llrr
St..Mnfs
"'
AND CRITERIA AND BACKGROUND
JADCO-HUGHES Rl/FS
OrM Sta ...... rd.l 11,ul Critni•
<icuptabl.-
Gro11""11111rn IRIS((! IRIS~
Co.eei.triatio• C•~ C.rci""V'" FClUJWIW
CNo•-C•rri-1!!!,)(eJ 10-5 Rid, ID-6 Risl PMCL(laJ oMCL
7,350 74,000 7,400 5,000
250,000
~100 210
(,1) Total trihalomethana (the 1um ol coroant:ntions ol ~ dibil:nochloromdhule. bR:cnobm and chlwoimm)
(b) MCL-NaticnaJ. Primary OrinkingWataScandards.. Manmum Contffllirl&nt leYeb (Health-baMd), tOCFRIO.
Stat.-W11tn
Q1111liry sms AWQC
forF......,.rn W11rn&Fislr
St.U(i) luictrro-U c, ..... l•1atio•
oMCL (>) ()) CRIS, (oJ
5,000 3,947 SO(Al)
250,00J 25000J
47,500
38 1000
26,500
ND
20,500
50
• MCLmayvaryba,ed a'l•Nlytical IDe1hod used.,saznplevolumie. Uld numba-oi Mmples cdlecti:d pa:month. Als-otwotypea oi MCUexisl -themc.-.1hly avenge and 1he -singleumple". Both are based"" coh/onn density.
le) Rules gOftming pubUc w.iier supplia1 10 NCAC10D .1600.
Id) NC Rule -Haith-hued. NC AdminbltativeCc•k Title 15, 15,Su~2LSe:oon0.0202, Aug. 1, 1989.
ExoeptioN to these sblldu-cb are incorpontal wMSI the 1tand.rd b bsow-the limit ci an.al)'Ucal deta:don or when the a:xnpound 11o1rur.1lly oa:un above the 1tandud.
~ Bued. on publilhed risk r-eknn:z d0e1 (RFD) b non~. Integrated Rilk Wonn.etic.1 Systan (IRJS), April 1990
(70 kg penori.. 30 yan ~-
IO IRIS, can:tnogms • Cf'OWldwata mntaminmt ~d miuired to yidd 1 -10(-5) additiC.W lildime cancer-Rik b.Md on puhlbhed anar •k>p<t: f.ldon (CSF), Integrated Ruk lnfonlloltion SY?trm CIRlS)1 April 1990 (70 lr.g person.
30r-nerpcaure) .
.!&_ Same u above, uRllg 10(-6) addJtiuw c:anccr rin.
l!!L_ PMCL -Propaw:d Muhnum Ca,,tarinaJ11 Ln,m, 54FR 22062, May 22. 198'J
Propoa,ed MCL fw lmd and coppe-from PropoMd Rule, Feder.al Regista. August 18, 1968.
J!l_ Feder&! SOWS -f,ed~ Sea..ctuy Orinlr.ing Water Standards <Non-Hwth-based), 40 CFRIO.
JiL.__ NC Rules -,-. hedth-baed.
ill_ BKkground Is aYa"ageci detected 0CJU\f>O'IM• found in MW-I.
•
•
(I) Standards taken from North Carolin.aM~A~d~mlnl,it .. :•-:eoo::~~T:•~·~·~"~-~°'":':''"'.':~~z':.:":-:·:· '~·~·---------------------------------------------------------Im) or is mare stringent, 0.01 ci the 96-~ LCSO.
------'_!!'L Sdenium"liml1·1ur porid,:lika and rmervoln I• 5 µa:/L
M_IRIS: EPA lntegr.1ttd Risk Information l).i,1al.se; April 1990 .
.!Pl_ USEPA Quality Critierl.1 forWattt 11186 EPA 440/5-86-001Mly8651 Fe:ta-.al Regbta 0665; upd.1teSq>tnnbcr fIJ. JsL. This v.aiue Is for He:uvalent Chromium.
(Al) V.alue:s rq,reent adion kvdt u spedfied in .02ll(b)(4).
ITR) De:sigrwted trout Wollen h.1~ admium limit ol0.411-g/L.. ,1 tot,1I raidu;alchk>rinelimit ol 2.0µg/L .1nd. di»olved oxygn-o must be .11 lctsl 6.0 mg/L.
Yolerilc Pr11nic Compound a IYPvl lus/1 I
m<= ,__
an>(lfl tmach!oride
duorob.nun,
duorof-
1, 1-diduon::iethane
I, 2-dichlon>ethane
1, l-diduoroethene
tran.-1, 2-dJchloro:thme
cis-1, 2-didllorodheM
l ;J.-dichloropropuie
ethylbenz.ene
mdhylene chloride
1, 1, 2. l-1t:tnchlororthane
letrachl~
I, I, 1-lrichloroethane
I, 1, 2-trichboethane
tridllcn:.ethene
toluene
vinyl chloride
lykncs
2-bl.uanone IMO:)
c.1ri>on disulfide
chloroethane
2-he1<.1none
4-mdhyl 2 pmtanone
MCL (!,J
100
100{a)
5
7
100
70
5
700
5
5
200
5
5
2,000
2
10,000
NC
DriMi•& w .....
St11114•r4s (d
5
5
100M
5
7
200
5
TABLE 2.3
rART I: SUMMARY OF DRINKING WATER AND GROUNDWATER STANDARDS
AND CRITERIA AND BACKGROUND
JADCO.HUGHES Rl/FS
NC Acc'7'Llblir
Gro•...tw•tn Gro•UW•kr IRIS (fl. IRIS!J!
St...ulu4, Co..cnibwtia11 c .. m-1 ... c .. m-p:,u f#4ffalW ,,, (No11-C•rd..a&ni,Hir> J0-5 Ri,li JO-li Rid, PMCL(loJ oMCL
3,500 35,000 3,500 700
l IO I 5
03 24.5 3 03 5
300 700 0400 9'0 100
0.19 350 60 6.0 ,.200 3.8 0.38
0.38 0.4 5
7 315 06 0.06
70 700 100
70 70
0.56 5
29 3,500 35.000 3,500 700
5 2,100 50 5.0 u 0.18
07 350 690 69 5
200 3,150 32,000 3.200 200
140 6.1 0.61
28 32 3.2 5
1,000 10,500 110,(()() 11.000 ~000 oms 0.15 0.015 l
400 70,000 3,500 350 10,00J
170 1,750
3,500 35,000 3.500
1,750
Page 1 of 9 •
SLltir Warn
QHlityS1DS AWQC
for frtr~•kr Wd"bfW,
St..tir(fJ Backpw.ul ci.-1,.,.,.tia11
oMCL ,., (I) IRIS, (oJ
NO
ND 66 NO 0.4
ND ...
1.0 o.191el NO
0.48 0.94
ND 0.033
048
0.48 • ND
ND 1400
0.97 0.19
ND 0.17
ND 0.8 NO 18400
NO 0.6
ND 2.7
ND 1000
ND 2( )
0.66
ND
ND
ND
ND
ND
Compound
Volatile Orunic Compounds IYOCs)
acetone
benzene
carbon tetrachloride
chlorobenzene
chloroform
l, 1-dichloroethene
1,2-trans-dichloroethene
ethylbenzene
TABLE2.3
PART II, CRITERIA TO BE CONSIDERED· CONTINUED
HEALTH EFFECTS ASSESSMENT SUMMARY,
CHRONIC TOXICITY (OTHER THAN CARCINOGENICITY)
Otha Standards ,11,d Criteria -HEAST (1)
Exposure
0ml
100 mg/kg/day
for 90 days by gavage
NA
1 mg/day, 5d/week
for 12 weeks.
(0.71 mg/kg/day)
27.3 mg/kg/day by
capsules for 90 days
15 mg/kg, 6 d/wk
for 7.5 years
(12.9 mg/kg/day)
50 ppm in drinking water
for 2 years (9mg/kg/day)
0.1 mg/ L in drinking water
for 90 days (17 mg/kg/day)
136 mg/kg, 5 d/wk for
182 days (97.1 mg/kg/day)
Spuies
Or&JI
rat
NA
rat
dog
dog
rat
mouse
rat
Effect of Concern
Oral
increased liver and
kidney weight
nephrotoxicity
NA
liver lesions
liver and kidney
effects
liver lesions
liver lesions
increased serum
alkaline phosphatase
hepatotoxicity
and nephrotoxicity
Uncertainty Factor
Oral
1000
NA
1000
1000
1000
1000
1000
1000
Page 4 of 9
Reference Dose
Oral
(Acceptable Daily lntakt)
(mglkglday)
IE-l(a)
NA
7E-4(a)
2E-2(a)
1E-2(a)
9E-3(b)
2E-2(a)
lE-l(a)
•
•
TABLE2.3 Page5of9
PART JI: CRITERIA TO BE CONSIDERED. CONTINUED
HEALTH EFFECTS ASSESSMENT SUMMARY:
CHRONIC TOXICITY (OTHER THAN CARCINOGENICITY)
Other Standards and CriUria -HEAST O)
Refett11u Dose
Oral
Exposure Species Effect of Concern Uncertainty Factor (Acceptable Daily Intake>
Com ound 0ml o,.al Oral Oral (mg/kg/day)
methylene chloride 24 month drinking water ,at liver toxicity 100 6E-2(a)
study [5.85 mg/kg/ day
(males) 6.47 mg/kg/day
(females))
tetrachloroethene 20mg/kg, 5 days/wk mouse hepatotoxicity 1000 1 E-2(a)
fo,6 weeks (14 mg/kg/day)
1, 1,1-trichlorethane 500 ppm (2730 mg/ m3) guinea pig hepatotoxicity 1000 9E-2(a),(c)
7 hrs/day for 6 months
(90 mg/kg/day) (j)
1, 1,2-trichJoroethane 3.9 mg/kg/day by mouse clinical chemistry 1000 4E-3(a)
drinking water for alterations
90days
toluene 300 ppm (1130 mg/ m3) rat Central Nervous 100 3E-1 (c),(b) • 6 hrs/day, 5 days/wk System (CNS) effects
for 24 months (29 mg/kg/day)
xylenes 250 mg/kg mixed xylenes rat hyperactivity 100 2E+0(a)
5 days/wk for 103 weeks decreased body
(179 mg mixed xylenes/kg/ weight and increased
day) mortality at higher
dosage
2-butanone (MEK) 235 ppm (693 mg/m3) rat fetotox.icity 1000 SE-2(, ),(c),(d),(e)
7 hrs/day, 5 days/wk
for 12 months (46 mg/kg/day)
I, 1-dichloroethane 500 ppm (2025 mg/m3) ,at 1000 0:1
6 hrs/day, 5 days/wk
for 13 weeks (mg/kg/day)
Compound
4--methyl-2-pentanone
TABLE2.3
PART II: CRITERIA TO BE CONSIDERED· CONTINUED
HEAL TH EFFECTS ASSESSMENT SUMMARY:
CHRONIC TOXICITY (OTHER THAN CARONOGENICITYI
Other Standards and CriUriti -HEAST 0)
f.rposure
O,al
SO mg/kg/day by
gavage for 13 weeks
Species
Oral
ral
Effect of Concern
Oral
liver and kidney
effects
Uncertainty Factor
Oral
1000
Base/Neutral and Acid Extractable Compound, fBNA,)
phenol
1,4-dichlorobenze:ne
1,2-dichlorobenzene
benzoic acid
naphthalene
1,2,4-trichlorobenzene
bis(2-ethylhexyl)phthalate
60 mg/kg/day by gavage
during organogenesis
NA
125 mg/kg/day, 5 days/week
for 13 weeks (89 mg/kg/day)
per capita daily dietary
intake of benzoic acid
equivalent to 312 mg/day
10-20 mg/day in diet
6 days/wk for -700 days
(41 mg/kg/day)(K)
20 mg/kg/day by gavage
for 90 days
0.04% of diet for one year
(19 mg/kg/day)
ral reduced fetal body JOO
weight
NA NA NA
rat liver effects 1000
hwnan irritation, malaise
ral ocular and 10000
internal lesions
ral increased liver-to-body 1000
weight ratio
guinea pig increased relative 1000
liver weight
Page6of9
Refuence Dose
Oral
(Acceptable Daily Jntake)
(mglkglda'()
SE-2(a)
6E-J(a),(d)
ND
9E-2(a)
4E+O(a)
4E-3(f)(g)
2E-2(h)
2E-2(a)
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Compound
looq;anic Comounds
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium {VI)
Copper
Iron
Lead
Manganese
TABLE2.3
PART II: CRITERIA TO BE CONSIDERED. CONTINUED
HEALTI-1 EFFECTS ASSESSMENT SUMMARY:
CHRONIC TOXICITY (OTI-IER TI-IAN CARCINOGENICITY)
Other Standards and Criteria -HEAST (1)
Exposurl!
Oro/
NA
5 ppm Sb from antimoney
potassium tartrate in
drinking water, lifetime
(0.35 mg Sb/kg/ day)
1 µg/kg/day
100 ppm Ba from BaCl 2
(5.1 mg Ba/kg/day) in
drinking water for < 16 months
5 ppm in drinking water
for lifetime (0.54 mg/kg/day)
NA
25 ppm Cr VJ in drinking
water for 1 year (2.4 mg/kg/
day)
Species
Oral
NA
ral
hwnan
ral
rat
human
ral
human
Data inadequate for quantitative risk assessment)
1 mg MnCl2 •4 1-120 >2 years rat
(22 mg Mn/kg/day) in drinking water
Effect of Concern
Oral
NA
reduced lifespan
altered blood
chemistries
Kerstosis and
hyperpigmentation
increased blood
pressure
renal damage
local gastrointestinal
irritation
CNS effects
CNS effects
Uncertainty Factor
Oral
NA
1000
100
100
JO
500
NA
100
Page7of9
Reference Dose
Oral
(Acceptable Daily Intake)
(mg/kg/day)·
NA
4E-4(a)
1E-3(h)
SE-2(b)
5E-3(a)
1 E-3(/ood)(a)
SE-4.(water)
5E-3(a)
1.3 mg/I (i)
0.2
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Compound
Nickel
Selenium
Silver
Thallium (insoluble salts)
Zinc
Chloride, total
Calcium
Cobalt
Magnesium
Potassium
Sodium
Vanadium
TABLE2.3
PART II, CRITERIA TO BE CONSIDERED-CONTINUED
HEAL TH EFFECTS ASSESSMENT SUMMARY,
CHRONIC TOXICITY (OTHER THAN CAR□NOGENICITY)
Othn Standards and Criteria -HEAST (1)
Exposure
0 .. 1
100 ppm Ni from nickel
sulfate in diet for 2 years
(5 mg Ni/kg/day)
3.2 mg/day from diet of
seleniferous food stuffs
(0.046 mg/kg/day)
NA
0.20 mg thallium/kg/day
(from thallium sulfate) for
91ldays
2.14 mg/kg/day
therapeutic dosage
NA
NA
NA
NA
NA
NA
5 ppm vanadium from
vanadyl sulfate
in drinking water for
lifetime (0.7 mg/kg/day)
Species
Oral
rat
human
NA
rat
human
NA
NA
NA
NA
NA
NA
mt
Effect of Concern
Oral
reduced body and
organ weight
hair and nail loss,
dermatitis
NA
increased SCOT
and serum LDA
liver, alapicia
anemia
NA
NA
NA
NA
NA
NA
Uncertainty Factor
Oral
300
15
NA
3000
IO
NA
NA
NA
NA
NA
NA
100
Page8of9
Referrnce Dou
Oral
(Acceptable Daily Intake)
(mglkglday)
2E-2(a)
3E-3
NA
7E-5
2E-1
NA
NA
NA
NA
NA
NA
7E-3(0
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Notes
SCOT =serum gluthamine oxidase transferase
LDt-t =lactate dehydrogenase
TABLE2.3
PART II: CRITERIA TO BE CONSIDERED· CONTINUED
HEAL TH EFFECTS ASSESSMENT SUMMARY:
CHRONIC TOXICITY COTHER THAN CARCINOGENICITY)
(a) verified, available on IRIS. -IRIS source on Part I of table.
(b) the oral RFD, while still available in IRIS, is being reconsidered. by the RFD workgroup.
(c) Specifically related to organoleptic threshold and potential foe respiratory tract irritation,
not to systemic toxicity.
(d) CRAVE -verified as a CAG Group D substance.
(e) developmental effects have been used as the basis of calculation.
(0 Under review by RFD work group.
(g) A minor calculation error in estimation of transformed dose in 1986 HEEP is corrected here.
(h) Withdrawn from IRIS.
(i) Current drinking water standard of 1.3 mg/L; Drinking Water Criteria Document ooncluded toxicity
dala were inadequate for calculation of an RFD for copper.
(j) based on route-to-route extrapolation.
(k) these values differ from those in lhe HEA (U.S. EPA 1984) because of the sludy chosen as the
basis for the inhalation RID derived in a more recent HEEP (U.S. EPA 1986).
NA = not applicable or not available
ND = not determined.
Sour=
(1) Health Effects Assessment Summary Table, (HEA U.S. EPA); Fourth Quarter FY 1989;0ctober 1989.
Page 9 of 9
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2.1_ SPECIFIC REMEDIAL OBJECTIVES FOR GROUNDWATER
Table 2.3 presents a summary of drinking and
groundwater standards and criteria which were considered for use in
establishing groundwater remedial objectives. Federal water quality crite -ia -I
and maximum contaminant level goals (MCLGs) were also considered. Since
I maximum contaminant levels have been established for most constituents,
the use of Federal water quality criteria would not be relevant and approdriate
for a current or potential drinking water supply. Criteria are generally
established for the protection of aquatic life. North Carolina has promulgated
drinkin water and roundwater standards. The roundwater standards lre
in some cases more stringent than the North Carolina drinking water
standards or federal MCLs. The State groundwater standards were intended
to apply to permitted facilities rather than unpermitted Superfund sites.
There is no apparant basis for requiring cleanup to a more stringent standard
than health-based drinking water standards. Accordingly, a technical
im racticabilit waiver of the North Carolina roundwater standard would be
warranted since compliance with this state standard is not technically
practicable at this Site from an engineering perspective. Health-based MGLs
and State drinking water standards should be considered as primary AJRs
for groundwater.
The development of remedial objectives must also
consider the existing and potential use of the aquifer. Groundwater off Site is
considered a Class II!!. Aquifer since it is sometimes used as a private driJking
water source (USEPA, 1988, Guidance on Remedial Actions for ContamiAated
Groundwater on Superfund Sites).
17
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The restoration of on-Site groundwater quality for use as a
potential source of drinking water is unlikely due to technical
impracticability. For example, the maximum concentration of vinyl chloride
on Site is 68,000 µg/L, whereas the State Groundwater Standard is 0.015 µJ/L.
This would require 99.99997% removal of vinyl chloride from groundwa/er
which may not be achievable using current aquifer restoration technologiles.
Similarly, benzene, 2-butanone, carbon tetrachloride, chloroform,
1,2-dichloroethane and methylene chloride require greater than 99.9%
removal on-Site to meet the State Groundwater Standard. Given that Site
groundwater is not a water supply and there is readily available access to 1
municipal watermain, restrictions for on Site groundwater use are
appropriate under the circumstances.
Groundwater and drinking water regulations allow for
the establishment of variances, waivers and the establishment of a point lof
com liance. In the case of the adco-Hu hes Site the oint of com liancJ
should be the downgradient property limit. Hence, State and Federal
drinking water standards would be met at the Site boundary while on-Site
groundwater concentrations would not be required to meet State or Fede~al
Standards. Appropriate groundwater use restrictions should be establish~d
for on-Site groundwater.
Given the above discussion, the remedial objectives for
I for groundwater are based on health-based federal MCLs. These groundwater
I
remedial objectives are applied to off-Site groundwater only with the point of
compliance being the Site boundary.
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FIELD INVESTIGATION LETTER
JADCO-HUGHES SITE
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
AUGUST 1, 1985
DOCUMENT CONTROL NUMBER
170-WPl-EP-BHTN-l
***COMPANY CONFIDENTIAL***
This document has been prepared for the U.S. Environmental Protection
Agency under Contract No. 68-01-6939. The material contained herein is not
to be disclosed to, discussed with, or made available to any person o~
persons for any reason without the prior expressed approval of a
responsible official of the U.S. Environmental Protection Agency.
REM II
Atlanta, Georgia
29/30
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environmental engineers, scientists.
planners, & management consultants
August 1, 1985
Mr. Jim Orban
U.S. Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30365
Ms. Thu Kim Dao
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30365
Project: REM II -EPA Contract No. 68-01··6939
Document Control No.: 170-WPl-EP-BHTN-l
• CAMP DRESSER & McKEE INC.
1945 The Exchange, N. w., sLe 290
Atlanta, Georgia 30339 I
404 952-8643
I
Subject: Recommended Activities and Sampling Locations for the
Limited Field Investigation at the Jadco-Hughes Site
Work Assignment No.: 68-4LG8
Dear Mr. Orban and Ms. Dao:
This letter expands upon the information contained in our July 29, 1985
letter regarding the cost of a limited field investigation at the I
Jadco-Hughes site. We have considered the activities suggested in the
July 29 letter in greater detail and have developed specific I
recommendations for field activities which we feel will help define and
limit the scope of work required for a Remedial Investigation/Feasibility
Study (RI/FS).
Completion of the geophysical investigations is strongly recommended .. An
EM survey originally scheduled for completion by NUS in March of 1983 was
I not completed because of inclement weather. Consequently, a report of
buried drums in the area along the western site fence has not been
confirmed. The presence of buried drums may affect the placement of
future monitor wells. Therefore, location of any buried drums at this
stage in the investigation will guide the selection of monitor well
locations for the RI/FS. Because there is little existing data
describing the stratigraphy in the site vicinity, resistivity soundings
are recommended.
The existing surface water and sediment sampling database contains
several discrepancies, many of which may be attributed to the sampling
location selected. For example, upstream sediment sample JmHo2s-tUF
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CfB-t8he:osne
Tributary B contains several organic compounds. However,
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Mr. Jim Orban
Ms. Thu Kim Dao
August 1, 1985
Page Two
• CAMP DRESSER & McKEE INC.
are either polynuclear aromatic hydrocarbon (PAH's) compounds commonly
associated with asphalt that may be present in runoff from Cason Street
or naturally occurring fatty acids that may be associated with vegetation
in the area. I
In addition, the locations previously selected do not allow isolation of
a particular source of contaminant inflow. Sample JH2-UFCA-5 was taken
downstream of Cason Street on Tributary A and sample JH2-UFC-9 was t.iken
at the confluence of Tributaries A and B. Conclusions cannot be made
regarding the potential flow of contaminants from the north face of the
site into Tributary A because sample JH2-UFCA-5 may be affected by runoff
from Cason Street, and sample JH2-UFC-9 also contains inflow from
Tributary B.
Finally, previous investigations were not designed to define the extent
of contamination. Sediment sample JH2-UFC-9 contains several
contaminants. However, no samples were collected from additional
downstream points to determine the extent of contaminated sediments in
Fi tes Creek.
Surface water and sediment sampling at the 12 locations listed in Tab
1
le 1
and shown on Figures 1 and 2 is highly recommended. These samples should
all be analyzed for the full priority pollutant scan. The objectives of
sampling at these locations include:
• ·Isolation of potential routes of contaminant migration.
• Confirmation of suspected contaminant migration into the culvert
passing through the site. I
• Investigation of the extent of downstream contamination of Fites
Creek.
Proposed Sample Collection Stations
Sample JH3-UFCA-l will be collected from a point further west to
determine upstream conditions in Tributary A away from any runoff from
Cason Street. Samples JH3-UFCA-2 and JH3-DFCA-3 wi 11 be collected to\
isolate any contaminant migration from the north face of the site.
Sample JH3-UFCB-4 represents upstream conditions in Tributary B away from
any runoff from Cason Street. Samples JH3-·UFCB-5 and JH3-DFCB-6 will [be
collected to isolate any contaminant migration into the buried culvert
passing under the site. Comparison of the August 1983 results of [
laboratory analyses for samples JH2-UFCB-8 and JH2-M indicates that the
culvert passing under the site is not securely sealed, and existing
onsite contaminants are migrating into this culvert.
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Ms. Thu Kim Dao
August 1, 1985
Page Three
• CAMP DRESSER & McKEE INC.
Samples JHJ-DFCB-6, JHJ-DFCB-7, JHJ-DFCB-8, and JHJ-DFCB-9 will be
collected to isolate contaminant migration from the east face of the
northern portion of the site. Sample JHJ-DFCAB-10 will be collected on
the upstream side of SR 2036 about 800 feet downstream of the site in an
attempt to define the limit of downstream sediment contamination. \
Samples JHJ-S-1 and JHJ-DS-2 will be collected to isolate any contaminant
migration into the stream flowing from the spring to Tributary B.
We feel that this proposed field investigation will help limit the
sampling required during the RI/FS through the isolation of sources of
contaminant migration. In addition, the extent of contaminant migration
in Fites Creek will be more clearly defined.
Table 2 contains a revised cost estimate for the limited field
investigation. Notable changes include an increase in the labor cha~ges
for surface water and sediment sampling. Addition of 2 more sampling
locations as well as the collection of both surface water and sediment
samples will require an additional day in the field. A contingency ~or
inclement weather halting field activities has been added. Labor cha,rges
for summary and evaluation of the data are included. This activity does
not include a review of the information collected regarding private wells
in the site vicinity. We propose that completion of this task be
deferred until the work plan preparation phase.
Equipment charges have been increased to reflect samp 1 e shipping charges
that will be incurred if use of a contract laboratory is required.· W,e
are currently investigating the availability of lab slots for the week of
August 25, 1985, and will advise you of our findings. Charges for I
lodging and meals have been increased to accomodate an extra day in the
field. I
The estimated total cost for the limited field investigation is $14,500.
We currently have $10,000 available in the Forward Planning Study budget.
It is our feeling that while adjustments can be made to accomplish the
recommended field activities at a cost of $10,000, this does not allo~
any flexibility to compensate for inclement weather or any other I
unforeseen delays. Furthermore, a thorough summary and evaluation of the
data obtained would not be possible. For these reasons we recommend ~n
increase of $5000 and 100 LOE hours in the interim authorization for this
work assignment.
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Ms. Thu Kim Dao
August 1, 1985
Page Four
• CAMP DRESSER & McKEE INC.
If you have any questions or comments, please call us.
Very truly yours,
CAMP DRESSER & McKEE INC.
12n~ =;J c(;eQ__~
/). ~ohn L. Roberts, P.E. r Manager
'
Richard C. Johnson,
Region IV Manager
JLR:RCJ/jmp
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I JH3-UFCA-2:
I JH3-DFCA-3:
JH3-UFCB-4: I
JH3-UFCB-5:
m JH3-DFCB-6:
g JH3-DFCB-7:
D JH3-DFCB-8:
H JH3-DFCB-9:
I JH3-DFCAB-10:
JH3-S-l:
D JH3-DS-2:
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TABLE 1
RECOMMENDED SURFACE WATER AND SEDIMENT SAMPLING
LOCATIONS AT THE JADCO~HUGHES SITE
Tributary A west of Seaboard Coast Railroad Tracks and
upstream of site.
Tributary A west of Cason Street and upstream of site.
Downstream of the northern face of the site and upstrlam
of confluence with Tributary B. I
Tributary B south and upstream of the site away from Cason
Street. I
Previously known as JH2-UFCB-8. Tributary B south and
upstream of the site, but downstream of JH3-UFCB-4. \
Previously known as JH2-M. Tributary B just downstream of
the culvert running under the site. \
Tributary B downstream of location JH3-DFCB-6 and just
upstream of confluence with flow coming from the spring.
Previously known as JH2-DDU-10. Tributary B downstrealm of
confluence with spring flow.
Tributary B upstream of confluence with Tributary A.
Approximately 800 feet north of the confluence of
Tributaries A and Bon the south side of SR 2036.
Previously known as JH2-XXS2. Spring east of the site.
Flow from the spring upstream of confluence with Trib)tary
B.
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UFCA-1 ~
FORMER MOBILE
TANKER LOCATION
LANDFILL AREA
IO ..,
0
N
a:
Cl)
POSSIBLE BURIED
DRUMS-----+-l-j_
NOTE:
1-
111
II.I a:
1-
0)
.z
0 a,
<
0
DFCB-7
I
DFCB-9
Ill
> a: < 1-. ::::,
:111
a:
I-
DFCB-8
DS-2
tFCB-5
-1
~ DFCAB-10 I (further down tream)
SPRING
FORMER BULK STORAGE
TANKS LOCATION I
FORMER LOCATION OF
DISTILLATION EQUIPMENT
CULVERT
0 100 200 ~-I SCALE IN FEET ALL SAMPLE LOCATION IDENTIFICATIONS UFCB-4
ARE PREFIXED BY JH3-. ~ ( further upstream)
CAMP DRESSER & McKEE INC.
WASTE STORAGE AND DISPOSAL AREAS
JADCO-HUGHES SITE
BELMONT, NORTH CAROLINA
FIGURE NO.
1
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<'v~ ', ~;,..,
<:f' .
. '·
)
.-'.":.....:
CAMP DRESSER & McKEE, INC. FIGURE NO.
LOCATION MAP
JADCO-HUGHES SITE
BELMONT, NORTH CAROL.INA
2
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TABLE 2
REVISED COST ESTIMATE FOR LIMITED FIELD INVESTIGATION
AT THE JADCO-HUGHES SITE
Labor Costs
Task
1. Equipment Preparation
2. Geophysical Investigations
EM Survey
Resistivity Soundings
3. Surface Water and Sediment
Sampling at 12 locations
4. Contingency for Inclement
Weather
5. Summary and Evaluation
of Data
Total Labor Costs
Other Direct Costs
Equipment (expendable items
only, and shipping)
Travel
Lodging/Meals
Total Other Direct Costs
TOTAL COSTS
Number of
Days to
Complete
3
3
3
1
5
Number of
Personnel Labor
Required Dollars
1 $ 1,200
2 2,400
3 3,600
5 2,000
l 2,000
$11,200
$ 600
9001 '
1,aoa2
$ 3,300
$14,500
1. Assumes 3 round trip airfares Atlanta, GA to Charlotte, NC; rental I car
for 4 days; and 1 round trip by car from Raleigh, NC to Belmont, NC.
I 2. Assumes 5 people requiring lodging and meals for 4 days at a per diem
of $90.
C~A
Consulting Engineers
July 19, 1990
JUL :~1/ 1990
SUPERHIND SECTION
¥s-Barbara H. Benoy
~uperfund Project Office
CONESTOGA-ROVERS & ASSOCIATES LIMITED
651 Colby Drive,
Waterloo, Ontario, Canada N2V 1 C2
[phone]
Reference No. 2427
"\)nited States Environmental Protection Agency
Region IV
I {\ir and Waste Management Division
345 Courtland Street
I • {\tlanta, Georgia
U.S.A. 30365
Dear Ms. Benoy:
I Re: Jadco Hughes Superfund Site
I Revised Feasibility Study (FS) Report
I This letter has been written to submit supplemental comments on the FS on behalf
?f the Jadco-Hughes Steering Committee. EPA Comment No. 4 states 'The FS must
identify the contaminant levels acceptable to the POTW. Without these
levels/ standards identified by the POTW, this discharge alternative will not be
tonsidered."
I ,The FS has identified the following three remedial technologies for treated
groundwater disposal: discharge to surface water; discharge to POTW; and on-site
aischarge via infiltration. The on-site discharge via infiltration technology is not
kcceptable to the State of North Carolina. The remaining groundwater discharge
klternatives are protective of human health and the environment and will comply
rith all applicable ARARs.
jfhe requirement to identify contaminant levels acceptable to the POTW is not
supported by the National Contingency Plan, 40 CFR Part 300 et seq. and is
premature at this stage. The level and degree of treatment of the extracted
'groundwater will depend on the ultimate discharge point of the water and the level
'of contaminants in the extracted groundwater. The USEPA should defer the
:decision on the groundwater disposal until the most cost effective combination for
l
the point of discharge and degree of treatment can be determined in the Remedial
Design stage. The Record of Decision (ROD) should reflect this approach. The
IUSEP A has used this approach in other RODs. A copy of the Caro lawn ROD is
enclosed as an example.
July 19, 1990
-2-
CONESTOGA-ROVERS & ASSOCIATES LIMITED
Consulting Engineers
Reference No. 2427
Sections 2.3.3 and 2.4 and Tables 2.1 and 2.3 of the FS which are enclosed have been
revised to correct errors which were discovered after submittal of the FS to the
USEP A. These corrections are associated with the incorrect reference to and
consideration of North Carolina Groundwater Standards as drinking water
standards.
If you have any questions, please call our office.
Yours truly,
CONESTOGA-ROVERS & ASSOCIATES
SMQ/ec/76
Encl.
cc: B. Nicholson, State of North Carolina
A. Webster, City of Belmont
Jadco-Hughes Steering Committee
R. Shepherd, CRA
R. Frehner, CRA
M. Mateyk, CRA
SllMMARY OF REMEDIAL ALTERNAT:rvB SELECTION
CAROLAWN SITE
FORT LAWN, CHESTER COUNTY
SOOTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA GEORGIA
DECLARATION FOR THE RECORD OF DECISION
-_ ,:c. SITE NAME and-LOCATION
Fort _.I.awn·, Chester County, South carolina
STATEMENT OF BASIS AND PURPOSE
Thie decision document represents the selected remedial action for the
Carolawn site in Fort Lawn, south carolina chosen in accordance with CERCLA,
I as amended by SARA and, to the extent practicable, the National Contingency
Plan. Thie decision is based upon the administrative record for the Carolawn
Site.
The State of South Carolina has concu=ed on the selected Remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances fr0111 the Carolawn site,
if not addressed by implementing the response action selected in this Record
I of Decision, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF THE SEIJ!!CTED REMEDY
MIGRATION CONTROL (Remediation of contaminated Groundwater)
Installation of a groundwater interception and extraction system at the
I site. The level and degree of treatment of the extracted groundwater will
I depend on l) the ultimate discharge point of this water and 2) the level of
contaminants in the extracted groundwater. Three wate , discharge I
alternatives for the treated groundwater are l) the lc:al sewer ~stem,
(i.e., Publicly OWned Treatment works), 2) Fishing creek via a National
I Pollution Discharge Blimination System permit or, 3) on-site irrigation. A
fourth discharge possibility is groundwater injection. The range 1\of
treatment for the extracted groundwater includes air stripping,
biodegradation, filtration through activated carbon filter and metal
I removal. The moat cost effective combination for the point of discharge
I and the degree of treatment will be datermined in the Remedial Design
stage. The discharged water will meet all ARAR•a. Concurrence on\ the
final design will be requested from the State of South Carolina. Comments
will also be solicited from the public on the final design.
Review the existing groundwater monitoring system to insure proper
monitoring of groundwater. If deemed necessary, additional monitor wells
will be installed to mitigate any deficiencies in the existing gro~ndwatsr
monitoring system.
Appropriate institutional controls (deed restrictions) will be
implemented.
Open the condemnation of the adjacent contaminated private, potable wells
by the county of Chester, these -110 will be plugged in accordance· to
South carolina Department of Health and Environmental control regulations.
SOURCE CONTROL (Remediation of contaminated Soils)
Due to the effectiveness of the removal actions, no source of contamination
I remains within the fenced area of the site. However, additional field work
I is required in the disposal area north of the fenced area. This field work
I will consist of the installation of confirmatory soil borings to verify the
' presence or absence of contamination in this area. If no contamination is
I found, there will no source control remediation required at the C&rolawn
site, however, if contaminated soil is found, a second Record of Da.!:ision
will be necessary to address this source of contamination.
GENERAL SITE CLEANUP ACTIVITIES
The two inactive incinerators will be inspected and any remaining residue
will be sampled and analyzed. Also, wipe samples will be collectedland
analyzed. The results of the analyses will determine the method of
disposition for the incinerators. The two remaining drums will also be
sampled and analyzed to determine bow they will be disposed. In addition,
I site cleanup will include closing of the equipment decontamination area
used during Phase I RI activities.
DECLARATION
The selected remedy is protective of human health and tha environment,
' complies with Federal and State requirements that are legally applicable or
I relevant and appropriate to the remedial. action, and is cost-effective. Thie
I remedy util.izee permanent solutions and al.ternative treatment technologies to
the maximum extent practicable and satisfies the statutory preferancelfor
remedies that employ treatment that reduces toxicity, mobility, or volume ae
I a principal element. Since this remedy may result in hazardous substances
' remaining on-site above health-based levels, the five-year review will apply
to this action.
SEP ! 7 1!!99
Date Greer C. Tidwell
Regional Administrator
I.
July 19, 1990 Reference No. 2427
Note:
Insert these pages after Page 4 of 5 of Table 2.1.
Remove Page 5 of 5 from Table 2.1 and the rest of text and Tables up to Page 19.
UNITED STATES ENVIRONMENTAL PROTECTION AGENc;)}JN 2 (i 19, Q
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
4WD-NSRB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Benton R. Leach
Jadco-Hughes Steering Committee
RI/FS Coordinator
c/o Uniroyal Chemical Company
Benson Road
Middlebury, Connecticut 06749
Re: Jadco-Hughes Superfund Site
RI/Fs·
Dear Mr. Leach:
Enclosed please find EPA and North Carolina comments on the
Feasibility Study Report for the Jadco-Hughes NPL site. All comments
are to be 1Il~orporated into the text of the existing document as
specified. The Revised Feasibility Study Report is due to the Agency
no later than July 6, 1990. All changes in the text of the report
must be underscored. A copy of the floppy disk(s) containing the
text of the Feasibility Study Report must be submitted to the Agency
in additional to the required hard copies of the report.
Please do not hesitate to contact me if you have any questions
concerning the site. I can be contacted at 404/347-7791.
Respectfully,
Barbara H. Benoy
Remedial Project Manager
cc: Joe Claypool, COM
Lee Thomas, EPA
Rebecca Fox, EPA
Jack Butler, NC-DEHNR .----,
Charles Tisdale, King & Spalding
Ron Frehner, CRA
•
Printed on lecycled Paper
,. •
Jadco-Hughes Feasibility Study Report
Agency Comments
Page 2
1) Remove all references to contaminant masses. Volume
estimations, when calculated must be accompanied by derivation
equations, defining all assumptions, and providing all
calculations
2)
3)
4)
Groundwater clean-up ARARs for the site are incorrect. The
contaminated aquifer is a Class IIB aquifer; therefore clean-up
must be to MCL, North Carolina drinking water standards, MCLGs,
or proposed MCLs. Where promulgated or proposed standards do
not exist other criteria based upon the protection of human
health must be used as groundwater protection standards. Be
advised that where new MCLs have been proposed they will take
precedence over the existing MCLs since the site must be
remediated to standards that are current when remediation is
completed.
Delete all of Section 2.0 as presented. The tables in this
section may be incorporated into text of report. See comment
2, and comment 21.
The St~ering Committee has presented Alternative 9 as their top
prefSrence for the recommended remedy. Alternative 9 consists
of Soil vapor extraction, soil flushing, groundwater
extraction, treatment and discharge (to POTW). This
Alternative must be expanded to include NPDES discharge to
local surface water, and onsite discharge via infiltration as
well as discharge to POTW. The groundwater discharge criteria
must meet:
MCLs, PMCLs and Health based levels for onsite discharge via
infiltration,
NPDES permit discharge requirements,
contaminant levels acceptable to POTW.
All the above criteria, with the specific levels of
contaminants detailed,· must be identified in the revised FS
report for each of these three discharge alternatives. The FS
must identify the contaminant levels acceptable to the POTW.
Without these levels/standards identified by the POTW, this
discharge alternative will not be considered.
The approach for using groundwater cleanup standards in the
application of soil remediation is unacceptable. The FS has
made no attempt to properly determine site specific action
levels. Therefore, the only technically defensible soil
cleanup goals in the absence of site specific evaluations and
action levels are background concentrations.
•
Jadco-Hughes Feasibility study Report
Agency Comments
Page 3
5) Page 18, 19 and all discussions of soil remediation -
Subsurface sampling of soils must be conducted during and after
soils remediation to confirm the reduction in soil contaminant
levels and to be sure that the soils will no longer be sources
of groundwater contamination.
6) All descriptions of the various technologies should include
limitations as they pertain to the site. For example, which
compounds can and cannot be expected to be removed, (i.e.,
will soil flushing eliminate the PAH compounds found in the
soils, etc.)?
7) Volatilization of compounds is not an eliminating factor.
8)
Monitoring and emission control systems must be included with
alternatives.
Delete page 105, first paragraph, top of page.
ARARs are MCLs, PMCLs, and Health Based number.
must be rewritten.
Groundwater
This section
9) Table . 2. 3
Include PMCLs for 1,2-dichlorobenzene (600 ug/1) and chromium
(l00ug/1).
10) Page 5
Any groundwater samples which contain contaminants in excess of
the ARARs, (MCLs, PMCLs, etc.), are considered "significant".
11) Page 17
Cadmium is the only constituent that is found in the background
well at levels higher than the groundwater ARAR established.
Change text to reflect.
12) Page 20
Figure 1.0 is not provided.
13) Executive Summary, Page iii, Paragraph 3
The EPA document entitled•Draft Guidance on Selecting Remedies
for Superfund Sites with PCB Contamination, September 22, 1989,
recommends a soil cleanup level of 1 mg/kg for an unrestricted
access site for a 10-6 risk level. The 10 mg/kg level
discussed in the TSCA PCB Spill Cleanup Policy requires for the
remediated area to be covered with 10 inches of clean fill The
Superfund guidance will be considered when establishing soil
remediation levels for PCBs.
14) Table 2.1, Item 3
RCRA land disposal Restrictions (LDRs), apply not only to
landfilling of hazardous wastes but also when waste is removed
from an area of contamination, treated and returned to the same
or different area. Please correct table and text.
Jadco-Hughes Feasibility Study Report
Agency Comments
Page 4
15) Table 2.2
The Freshwater Ambient Water Quality Criteria for Aquatic Life
for Chloride is 230 mg/1.
16) Page 27, paragraph 2-
The TCLP rule has added 25 organic chemicals to the existing
list of constituents regulated under RCRA. If TCLP is deemed
appropriate for soil testing for this site, all current
constituents will be considered when classifying the
decontaminated soil.
17) Page 46, Item 4
Iron could be precipitated from the water before it is run
through the carbon absorption.
18) Page 50, section 3.2.7
19)
Providing an alternate water supply does not addresS the
contaminated aquifer.
Page 109, Long Term Effectiveness and Permanence Section must
contain groundwater remediation goals to be accompanied by a
discusSion on how and when these goals will be met. (MCLs,
PMCL, and Health Based levels).
20) Page 115, Section 5.5.1 and Page 119, paragraph 1
This section must address potential exposure to emission from
the onsite incinerator.
21) The following outline will be used for Section 2.0 of the
report.
Section 2.0 IDENTIFICATION AND SCREENING OF REMEDIAL
TECHNOLOGIES
2.1 REMEDIAL ACTION OBJECTIVES
2.2 GENERAL RESPONSE ACTIONS
2.3 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
2.3.1 Applicable requirements
Applicable requirements are specific to the conditions
present on the site for which all of the jur~sdictional
prerequisites of the law or requirement are satisfied.
Applicable requirements are cleanup standards, standards of
control, and other substantive environmental protection
requirements, criteria, or limitations promulgated under
Federal and State law that specifically address a hazardous
substance, pollutant, contaminant, remedial action, location,
or other circumstance at a CERCLA site.
•
• Jadco-Hughes Feasibility Study Report
Agency Comments
Page 5
2.3.2 Relevant and Appropriate Requirements
Relevant and appropriate requirements are cleanup standards,
standards of control, and other substantive environmental
protection requirements, criteria, or limitations promulgated
under Federal and State law that, while not "applicable" to a
hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstances at a CERCLA site, nonetheless
address problems or situations sufficiently similar to those
encountered at the CERCLA site such that their use is well
suited to the particular site.
2.3.3 Guidelines to be Considered
Non-promulgated advisories or guidance issued by federal or
state government when determining cleanup levels. Such
criteria are known as "to be con~idered" guidelines. Such
guidelines would be applied when no promulgated ARARs exist to
address a particular situation adequately.
2.3.4 Types of ARARs
Guidance for the determination of ARARs is presented in the
USEPA guidance document entitled "Interim Guidance on
Compliance with Applicable or Relevant and Appropriate
Requirements", dated August 27, 1987. The above-referenced
guidance document identifies several types of ARARs which may
have to be considered during .the RI/FS process. These include:
1) Chemical Specific ARARs:
These requirements consider specific concentration
limits of hazardous constituents detected in the
various environmental media. For this group of
requirements the more stringent ARARs would be
considered for determination of an acceptable cleanup
level of the specific hazardous constituent. Examples
of ARARs which fall under this category include:
Federal Maximum Contaminant Levels (NCLs), Federal
Ambient Water Quality Criteria (AWQCs), North Carolina
Primary Drinking Water Standards, and North Carolina
Surface Water Qualtiy Criteria.
•
• •
Jadco-Hughes Feasibility Study Report
Agency Comments
Page 6
2) Action Specific ARARs:
This group of requirements considers ARARs which are
action specific for the management of hazardous
substances such as: Resource Conservation and Recovery
Act (RCRA) regulations for hazardous waste management
facility clsures; RCRA incineration standards; Clean
Water Act pretreatment standards for discharges to
Publicly owned Treatment Works (POTWs). In most cases,
these ARARs are considered at the time of the remedial
alternative evaluation during the FS.
3) Location specific ARARs:
These requiremnts are generally considered in the FS
where restrictions due to the site characteristics or
the surrounding environment exist. Examples include:
Federal and State siting laws for hazardous waste
facilities, sites on National Register of Historical
Places.
The ianguage used in section 1.4 of the FS should be included
in Section 2.1 and 2.2 as provided above. All other language
provided above will be used as provided above.
22) Table 2.1
2. RCRA is an applicable location specific ARAR. Change
table to include as an ARAR.
3. RCRA Land Disposal Restrictions (LDRs) are applicable
for location specific ARARs. Change table to include.
4. Federal Manifest for Transposrt of Hazardous Waste is
applicable for location specific ARARs. PRPs have
proposed to transport PCB contaminated soils off site.
Change table to include.
9. Clean Air Act is applicable. Review of the report
indicates that soil venting is being considered which
dictates that the Clean Air Act is applicable. Include
for location specific and action specific
10. National Environmental Policy Act is relevant. A copy
of the reference sited in the statement "CERCLA FS
guidance states that CERCLA actions are exempt" may be
submitted for consideration. This appears to be taken
out of context.
•
• Jadco-Hughes Feasibility Study Report
Agency Comments
Page 7
19. Hazardous Materials Regulations are applicable as
chemical specific and location specific ARARs. Include
in Table.
20. Conservation of Wildlife Resources must be included on
Table 2.1 for location specific ARAR. Change table to
include.
State of North Carolina
6. Capacity Assurance Regional Agreement is certainly a
location specific ARAR that is relevant. Change table
to include.
8. Include NC Groundwater Standards, an obvious ARAR, in
this Table.
9. NC has an archaelogical preservation law/regulation
which may be an ARAR for the site.
23) Table 3.1
Add ~~~am stripping and incorporate as appropriate.
24) Specifically, evaluation criteria for groundwater remediation
must be evaluated as follows:
First criteria, (threshold criteria), to be used in remedy
selection are:
Overall protection of human health and the
environment: Will the remedy achieve clean-up levels?
Are all exposure pathways controlled; e.g., discharge
points, points of use?
Compliance with ARARs: Will the remedy attain MCLs or
state standards in potentially drinkable groundwater or
justify a technical impracticability waiver? Are ARARs
met for the treated groundwater and any treatment
residuals that are generated?
Second criteria, (balancing criteria), to be used in remedy
selection are:
Long term effectiveness and permanence: Remedies that
achieve the cleanup levels will be comparable with
respect to this criteria. For remedies that will not
restore groundwater, how reliable are the-engineering
or institutional controls used to prevent exposure?
Reduction of mobility, toxicity, and volume: What
reductions are achieved through treatment in any phase
of the remediation process? This includes initial
treatment of groundwater and
•
• Jadco-Hughes Feasibility Study Report
Agency Comments
Page 8
•
subsequent treatment of resulting residuals. Special note should
be given to remedies that transfer contaminants from groundwater
to air without treatment of the air releases, especially if risk
through the air pathway exceeds 10 -G.
Short-term effectiveness: What is the restoration time frame?
What cross-media impacts occur as a result of groundwater
treatment or construcion of a containment facility? How much
farther will the plume spread before the remedy is completed?
Implementability: What permitting requirements must be met for
discharge of treated groundwater? Are there access problems with
installation of the remedy--e.g., extraction wells and slurry
walls--in terms of resources required? Are there capacity
limitations on POTWs receiving discharge waters? What
uncertainties exist with the treatment process considered?
Cost
Final criteria, (Modifying criteria):
State acceptance
Community acceptance
If the alternatives will achieve the same long term goals, the
primary balanceing criteria will be implementability, cost and short
term effectiveness.
Elaboration is provided above for groundwater, but the above criteria
are commonly known as the 9-Point Criteria which must be the
substantiated criteria used in remedy selection for all remedial
actions taken at Superfund sites.
•
• ;r··";SiA'r't;'~-.. ..
/'._.,"'' ~•' ,o ,,,, ~~>
t.:xz-r;-~ " S\
!,, .:., ~,1··1~. '."•;;;..· o\ :5 "1! _·,_. •, ), :
\'I ::13 ; f ·: . 8! ... :, .... 3/ '~~-:..:~:.: .. .-•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
March 30, 1990
Superfund Branch, Waste Management Division
U.S. EPA Region IV
345 Courtland Street
Atlanta, GA 30365
Subj: NC DEM Comments on the
Draft Feasibility Study
Jadco-Hughes NPL Site
Belmont, Gaston County, North Carolina
Dear Ms. Benoy:
William L. Meyer
Director
The NC Superfund Section of the NC Division of Solid Waste
Management has submitted comments to you on the above referenced
documents. As described in my 13 M~rch 1990 letter, the Jadco
Hughes Feasibility Study were also submitted to the NC Division
of Environmental Management (DEM) for their review and comment.
We have received the comments from NC DEM today. Copies of their
comments are attached.
If you have
[phone].
BIN/let/jhdemsum
attachments
any questions please
Bruce Nicholson
Chemical Engineer
Superfund Section
contact me at
•
State of North Carolina
Department of Environment, Health, and Natural Resources
DMsion of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretaiy March 30, 1990
M E M O R A N D U M
TO:
FROM:
SUBJECT:
Lee Crosby, Head
Superfund Section ,
Perry E. Nelson, Chief ~
Groundwater Section
Draft Remedial Investigation Study Report
National Starch Chemical Corporation Site
Operable Unit 2
Salisbury, Rowan County, North Carolina
R. Paul Wims
· Director
The Division has completed review of the subject
document.
Attached please find the comments by the Air Quality,
Water Quality, and Groundwater Sections.
If you have any questions, please advise.
Attachment
PFN/SJA/hl
cc: George Everett
Perry Nelson
Brenda Smith
Sholeh Azar
Central Files
Groundwater Files
Pollution rre.cntlon Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
•
DIVISION OF ENVIRONMENTAL MANAGEMENT
Air Quality Section
Mar.-ch 15, 1990
MEMO R ,, ~ ll UM
TO: Sholeh J. Azar, Groundwater
FROM:
SUBJECT:
Lee A. Daniel, Chief __L,
Comments on Nationk-;;;Jrch
Sites
National Priority List Sites
emical and Jadco-Hughes Superfund
Thank you for allowing us the opportunity to comment on the proposed
Draft Feasibility Study for the Jadco-Hughes Superfund site located in
Belmont, Gaston County, North Carolina and the proposed Draft Remedial
Investigation Study Report for National Starch Chemical Superfund site located
in Salisbury, Rowan County, North Carolina.
My staff has reviewed the draft documents and has no specific comments
about the reports. However, I would like to express once again our concerns
about EPA's review procedures which does not provide this Section with
sufficient information for review regarding a particular project to assure
that all state or local air pollution standards are being protected. Although
an air discharge permit may not be required for a Superfund project, this
Section would appreciate an opportunity to review and comment on a project
prior to any remedial operations to determine compliance with any applicable
ambient standards including our toxic standards. Consequently, without an
opportunity to review all aspects of a Superf_und project, this Section can not
make such a finding. Any support from the Division of Solid Waste Management
in obtaining more complete information (not one report or investigation at a
time) from the EPA for our review and comment regarding a Superfund project
would be greatly appreciated.
sup2.sup
cc: Keith Overcash
_,
MEMO TO:
FROM:
SUBJECT:
•
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 7, 1990
~/ll~h J. Azar, Groundwater Section
~::~Mills, Water Quality Section
Draft Remedial Investigation Study Report
Natural Starch Chemical Corporation Site
Operable Unit No. 2
Rowan County
The Subject document has been reviewed for water quality
concerns. It is not expected that the project will have result
in Water Quality Standard violations. It should be noted that
Section 3.1 indicates that the metals analyses are in ppm;
however Table 3-2 indicates that the metals were in ppb. Table
4-1 indicates metals are in mg/1, this probably should have been
ug/1. These inconsistencies need to be corrected.
BM/jho
cc: Rex Gleason
azar.m/d-1
..,; •
MAA 16 19ro
GROUNOWA i ck SECTION
RALEIGH, NC
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 15, 1990
MEMORANDUM TO: Sholeh J. Azar
FROM:
SUBJECT:
D. Rex Gleason
Draft Remedial Investigation Study Report
National Starch Chemical Corporation Site
Operable Unit No. 2
Based on Water Section's review of the subject material, the
following comments are offered:
Surface water sampling results indicate that the surrounding
tributaries are not impacted by groundwater contamination. The
northeast tributary showed minor 1,2 dichloroethane
contamination, source unknown, but possible surface water runoff
from the plant. National Starch has constructed a dike to
contain the runoff and is conducting a study to determine how to
pump or redirect the runoff to the wastewater lagoons.
Further evaluation of surface waters and remedial action to
prevent contamination appears to be necessary, as relates to
runoff.
If you have questions, please advise.
DRG:se
MEMORANDUM TO:
THROUGH:
FROM:
SUBJECT:
•
Sholeh Azar
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 26, 1990
Barbara Christian l~
Jeff Lautier c;~s ' \ \_; Pi I Jr;H NC Draft Remedial Investigation Study ~ePol't
National Starch Chemical.Corporation Site
Operable Unit 2
Rowan County, North Carolina
The Groundwater Section of the Mooresville Regional Office has
reviewed the subject report and has determined that the soil
remediation plan, if conducted as described, will be adequate to
achieve the desired soil cleanup levels.
If you have any questions, please advise.
JCL/bb
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
March 13, 1990
· Superfund Branch, Waste Manage_ment Division
U.S. EPA Region IV
345 Courtland Street
Atlanta, GA 30365
Subj: Comments on the Draft Feasibility Study
Jadco-Hughes NPL Site
Belmont, Gaston County, North Carolina
Dear Ms. Benoy:
William L. Meyer
Director
The North Carolina Super fund Section is pleased, to offer
· these comments on the Jadco-Hughes Site Feasibility Study (FS)
prepared by Conestoga-Rovers and Associates for the Jadco-Hughes
Steering Committee. We appreciate your working with us to
provide these comments on a reasonable time frame. Please note
that we have forwarded the FS to the North Carolina Division of
Environmental Management for their review also. Their comments
will be forthcoming as soon as possible.
The North Carolina Superfund Section offers the following
specific comments:
1. Table ES-2, Executive Summary. For clarity and consistency
with Alternative 1, the descriptions of alternatives-9 and
11 at the top of each column should not have bullets besides
them. It is also noted in this table that both Alternatives
9 and 11 "reduce future potential risks of human contact.
with contaminated soil 11 • HOl•lever, it should be noted in
this table that the incineration technique (Alternative 11)
would be more effective at reducing contaminant levels, and
would therefore reduce potential risks to a greater degree
than Alternative 9. On page 3 of this table in the third
paragraph of the far right hand column ''tthree'' should be
"three".
These comments also pertain to Table 6.1 on page 120.
2. Page 4 and 5. As we commented earlier on the Draft Remedial
Investigation the NC Superfund Section suggests the removal
of all references to contaminant mass estimates. There is
no statistically sound basis for these estimates, and we see
there inclusion as potentially misleading. Please refer to
our 19 January 1990 RI comments for a more detailed
rationale for this.
I •
Jadco-Hugh.ite
FS Comments, page 2
3. Figures 1.8 and 1.9. The landfill area is not labeled
as such.
4. Page 6, Section 1.2. The NC Superfund Section strongly
supports the interim remedial measures that are
outlined in this section. We would further ask the
question, is there a schedule for these actions?
Also, this section states that the cleanup will be
conducted which satifies the U.S. EPS PCB Spill Cleanup
Policy (40 CFR 761). In addition to the 10 ppm cleanup
level it establishes, this policy states that the
excavated soil (minimum of 10 inches) will be replaced
with clean soil and then vegetative cover will be
restored (40 CFR 761 10694). As descrbed in the·Spill
Cleanup Policy, the report should state that clean soil·
will be used as · backfill an then vegetative cover
restored.
5.
6.
Table 2.1. In the fourth column, row 5 for the Toxic
:substances Control Act there are typographical errors.
For State ARAR's the Table does not mention North
Carolina Ground Water Standards as set forth in Section
.0202 of Title 15 of the North Carolina Administrative
Code (see Comment 6 below).
Page 15, Section 2. 1. 3. The ARAR' s for ground water
should consider North Carolina Ground Water Quality
Standards in addition to the North Carolina Drinking
Water Act (NCDWA) . The NCDWA mirrors the levels set
forth by Federal MCL's. However, the report does not
consider the ground water standards set forth in
Section .0202 of Title 15 of the North Carolina
Administrative Code, which in some cases are more
stringent than the MCL' s. A copy of this code is
attached. Enforceable standards exist for many of the
contaminants that are present in the ground water on
site. In fact, in many instances the site is in
violation of these standards .. [ Please note that. further
comments on this FS are forthcoming from the NC
Division of Environmental Management which is the
agency charged with upholding the ground water
standards. They may have additional comment on this
subject.]
7. Page 16, paragraph 1. The last sentence states that
MCL' s and State drinking water standards should be
considered as the primary ARAR's for ground water. We
feel that the State ground water quality standards
described above should be the ARAR's in cases where the
ground water standards are more stringent than the
drinking water standards. [ Please note that further
comments on this FS are forthcoming from the NC
Division of Environmental Management which is the
agency charged with upholding the ground water
standards. They may have additional comment on this
subject.]
fr I i .{
1
\ I ·.1 ;
i
Jadco-Hugh.Site
FS Comments, page 3
Also, what will be the ARAR or remedial goal for
the numerous compounds for which there are no MCL' s
drinking water standards, or ground water standards?
Will Proposed MCL's be considered if there are no
MCL's?
Also, this section is too general. After reading
the section it is unclear as to what the cleanup levels
will be. It states that MCL' s "should" .be considered
as the primary ARAR's not "shall". No specific cleanup
criteria are presented. The Superfund Section needs to
see specific cleanup criteria before supporting the
Feasibility Study.
8. Page 17, paragraph 4. The·report states that the·MCL's
for some contaminants wi11· be below background levels
and in these cases.the background levels should then be
the remedial objective. Cadmium is given as one
example, but more specifics are needed. What are the
others·, what are the levels they propose as
"background", and how do the "background" · levels
compare to the MCL's. This again goes back to
Comment 6 and the fact that specific remedial
objectives are not presented fan each contaminant
9. Page 17, paragraph 1. The report states that
"restrictions on Site [sic) groundwater use are not
appropriate under the circumstances." The North
Carolina Superfund Section believes that restrictions
should be considered if appropriate remedial objectives
are not ultimately met by the remedial actions taken.
This should be stated here.
10. Page 18 and 19, Section 2.3. The report proposes that
if no ground water contamination is observed after a
period of soil remediation (soil vapor extraction (SVE)
followed by soil flushing in the selected alternative)
the soils must be "clean". We do not support. this
theory. We strongly recommend subsurface sampling be
conducted during and after the SVE and soil fiushing to
confirm the reduction in soil contaminant levels and to
be sure that the soils will no longer be a source of
ground water contamination.
11. Page 19, Section 2.4. This section describes the PCB
cleanup criteria taken from the U.S. EPA' s PCB Spill
Cleanup Policy (40 CFR 761) as 10 mg/Kg. Again, as
stated in Comment 4 above, this policy decribes clean
backfill and cover replacement which should .be
described in this section.
12. Table 2. 4. On page 2 of . this table the contaminant
category in the first column is given as "Pesticides/
PCB's''. Only one row of data is presented. Is it for
pesticides or PCB's? What specific pesticides or
PCB's?
Jadco-Hugh.Site
FS Comments, page 4 ·•
13. Page 22, Section 3. 1. 3. It is noted that the
construction of a cap requires excavating soils in the
former operations areas. This would be cause for voe
air emissions. This is not mentioned in Table ES-2 in
the executive summary for all of the alternatives that
propose a cap. However, air emissions of voe' s are
mentioned for those alternatives that propose
excavating soils for disposal. It is noted that there
is apparently no proposal for remediating residual soil
contamination in the decant pit areas. This issue is
dealt with in more detail in Comment 29.
14. Page 27,· paragraph 1. The report states that inorganic
contaminants are.not removed·by incineration and remain
in the decontaminated soil. This is not entirely true
in the case of arsenic which does appear to be present
on site. Arsenic can volatilize in an incinerator.
15. Page 31, section 3. 1. 7. 4. This section describes "soil
washing" as a remedial technology. • It states that
"soil washing would be conducted in-situ ... " This is
customarily referred to as "soil flushing" whereas soil
washing is soil removal followed by a washing unit
operation. In fact, elsewhere in the report, the term
"soil flushing" is used (it is part of the selected
alternative). Therefore, it appears that this section
should be entitled "Soil Flushing" consistent with the
rest of the report.
If this is the case, then a new section describing
and screening soil washing technology should be added.
16. Page 3 2, paragraph 2. The report mentions that soil
washing [flushing] is often conducted with surfactants
to help remove organics and nutrients/oxygen to promote
in situ biodegradation. These principles were not
explored or described anywhere in the report. Is it
proposed to use surfactants? Is it possible that they
would help remove certain contaminants that might
otherwise be difficult to remediate? Why not add
nutrients and oxygen to · enhance bidegradation at the
same time? If an infiltration system is set up to
flush the soil it would be very little additional·
expense to attempt to enhance in-situ biodegradation.
Given the type of contaminants, this site seems well
suited to in-situ biodegradation for ground water
remediation and it is given only a cursory discussion.
Is it possible to include in situ biodegradation in the
analysis of the alternatives?
1 7. Page 3 4, Section 3. 1. 7. 6. The report presents Table
3.5, a treatability evaluation for soil venting. What
is the basis for the data presented in the Table?
Treatment costs are presented as "$50/ton". The
question here is per ton of what?
Jadco-Hugh.Site
FS Comments, page 5
The limitations of this technique as it pertains
to this site are not presented. What specific
contaminants can and cannot be removed by this
technique. For example, it is not expected to remove
most PAH compounds. Is this a problem for this site?
There are PAH compounds present in the soils. If they
are not removed by venting is it a problem or can
another technology be employed to remove them. It is
this type of analysis that is lacking throughout all of
Section 3.
18. Page 40, paragraph 2. The report· describes the
rainfall total for "Greensboro, South Carolina"·. Is
this correct? Should this be North Carolina? If so, I
suggest using meteorological data for Charlotte or
Gastonia instead.~ These cities are much closer to the
site.
19. Page 45, section 3. 2. 5. 4. It is suggested that the
last sentence be changed to read, "The subsurface tile
are applicable only to the extraction of shallow
groundwater, whereas extraction wells are applicable to
the extraction of shallow ·groundwater, contaminant
pockets, and deep groundwater."
20. Page 45-48, Section 3.2.6.1. The ground water remedial
technologies. discussed do not include in-situ
biodegradation. This technology appears to hold
promise at this site. As stated in the report on page
33, most of the principal site contaminants could be
successfully bioremediated. Considering the fact that
soil flushing is the selected technology for soils
remediation, it would be logical to also attempt
in-situ biodegradation.
Also, on page 46 it states that one of the reasons
that on-site fixed film biodegradation was screened out
is the lack of organic nutrients in the· ground water.
They can be added easily.
On page 48,. ultraviolet oxidation is described.
It should be noted that this will require pretreatment
for iron removal as stated in ~able 3.6.
21. Page 51, paragraph 4. We suggest that the word "even"
be deleted.
22. Page 52, Section 3.2.9. The title of this section may
be more accurately described as "Culvert Lining/
Replacement". Can the slip lining technique be
described a little more?
23. Page 53 , Table 3.6. For soil treatment technologies,
the comments are not clear for soil washing. The
comments concerning oxygen and nutrients appear to be
more related to in-situ bioremediation. Also, Soil
Flushing is not presented in this table.
Jadco-Hugh.Site
FS Comments, page 6 •
For ground water treatments, in-situ
bioremediation has not been evaluated (see Comment 19,
above). Also, reverse osmosis . is described as
applicable to the treatment of inorganic wastes which
therefore make it inapplicable to the site. This is
incorrect as reverse osmosis can be used to remove many
organic contaminants as well.
24. Page 57 and 58. Concerning the extraction of ground
water, the report states that the extraction wells will
extract ground water at the rate of 1 gallon per minute
(GPM). How was this rate selected? What was the
rationale? How would this rate affect flow patterns
and prevent future migration? , Without the analysis
present in the report we can only say that this rate
seems entirely to"o low. There are hot spots where
there are high contaminant levels that ar8 acting
almost as a point source. To prevent further problems,
it would seem logical to remove these hot spots
quickly. The total system flow rate of 14 GPM also
seems low.
What is the contaminant depth as determined by the
'RI. Is it definite that the subsurface drains will cut
off the contamination at the property line or is there
deep contamination that may pass through. A thorough
analysis of the flow patterns and contaminant cut off
to support the basic design· of the extraction system
should be included here. This same comment also
applies to Section 4.4.9 on pages 89 and 90.
25. Page 58, Table 4.2. The wells should be sampled more
frequently, particularly those at or just beyond the
property boundary. All of the wells should be sampled
quarterly for years and then annually thereafter. For
those wells at or just beyond the property line (MW-14,
MW-12, MW-5, and the subsurface drain) they should be
sampled quarterly for 5 years and annually thereafter. ,
· 2 6. · · Page 59, paragraph 1. There should be a statement at
the end of this paragraph that new monitoring wells
would be installed if the flow patterns change enough
to warrant monitoring in new locations.
27. Page 62, paragraph 3. .This paragraph mentions a
manhole sump for the collection of annular space ground
water. Is it possible to show this sump on Figures 4.2
and 4.3?
28. Page 73, paragraph 1. The report mentions an ozone
pretreatment system to remove iron. Is it possible ·to
show this system of Figure 4. 7? Why would an ozone
pretreater be required? Could the pretreatment -be
simple water softening or pH adjustment?
Jadco-Hugh.Site
FS Comments, page 7 •
29. Page 74-77, Section 4.4.5. The proposed SVE and soil
flushing would not remediate the two decant pits areas.
Can a rationale be presented for not remediating these
areas? Also, many of the site contaminants will not be
remediated by the SVE/soil flushing. Can a discussion
be included that covers these compounds and whether or
not leaving them as a residual will be a problem. This
discussion may best be suited for Section 4.4.5.1.
This comment is also pertinent to Section 5.4 on page
106.
31. Page 86, paragraph 2. voe emisiions are~ concern ..
Therefore, this and other alternatives that require
excavation should include{ air moni taring, for. voe' s and
, contaminated · pa'rticulate·;, in · the analysis. 'of . each
alternative. It . is agreed · that .. a'ir emissions are a
concern, but the public health can'be' protected with an
air monitoring program during operations. W~ do not
see this .. as an overriding reason · to eliminate
alternatives with excavation.
32. Page 105, paragraph 1. The report states, "At present,
groundwater ARAR' s are met." This,, is not correct as
the site currently violates State ground water
standards. As described in the NC Administrative Code
Title 15, subchapter 2L, Section .0202, there are
ground water standards for the state regardless of
aquifer use.
3 3. Appendix B. Most of the tables presented in this
section are unreadable due to the poor photocopy
quality. Also, it would be of great benefit to the
reader to present summary tables of the VOC's and
BNA's.
34. Appendix C. In-situ biodegradation is not evaluated·
as a remedial technology.
The -North Carolina
opportunity to provide
questions please contact
BIN/let/jadcofs
attachment
Superfund Section appreciates this
these comments. If you have any
me at [phone].
Bruce Nicholson
Chemical Engineer
Superfund Section
~'
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TABLE OF CONTENTS
SUBCHAPTER 2L
•
GROUNDWATER CLASSIFICATIONS AND STANDARDS
.010 l
.0102
.0103
.0104
. 0105
.0106
.0 l 07
.0108
.0109
.0110
.0111
.0112
.0113
.0201
.0202
.0301
.0302
.0319
SECTION: .0100 GENERAL CONSIDERATIONS Page
AUTHORIZATION ..................................................................................... f
DEFINITIONS ............................................................................................. I
POLICY ......................................................................................................... 2
RS DESIGNATION ...................... : .............................................................. 2
ADOPTION BY .REFERENCE (REPEALED) ......................... : ................ 3 .
CORRECTIVE ACTION .................................................. :.: ........................ 3
COMPLIANCE BOUNDARY .................. , .............................. , .................. 4
REVIEW BOUNDARY .............................................................................. -4
DELEGATION ............................................................................................. 4
MONITORING ............................................................................................ 5
REPORTS ............................................................ ~ ................... : ..................... 5
ANALYTICAL PROCEDURES ................................................................. 5
VARIANCE .......................................................................................... : ...... 5
SECTION: .0200 -CLASSIFICATION AND
WATER QUALITY STANDARDS
GROUNDWATER CLASSIFICATIONS ..................................... 8
Class GA waters; usage and occurence .................. 8 . . . '
Class GSA waters; usage and occurrence ............... 8
Class GC waters; usage and occurrence ................. 8
WATER QUALITY STANDARDS .............................................. 8
Class GA Standards ........................................................ 9
.Class GSA Standai-cls ...................................................... l 0
Class GC Waters ............................................................... 1.0
SECTION .0300 -ASSIGNMENT OF UNDERGROUND WATER
CLASSIFICATIONS
CLASSIFICATIONS: GENERAL. .................. , ............................. 11
STATEWIDE ................................................................................... l 1 ·
RECLASSIFICATION. . .................................................... 1 3
l
EHNR -ENVIRONME L MANAGEMENT • TIS: 02L .0100
SUBCHAPTER 2L -GROUNDWATER CLASSIFICATION AND STANDARDS
SECTION .!llOO -GENERAL CONSIDERATIONS
.!!!DI AUTHORIZATION
(a) N.C. General Statute 143-214.1 directs that the Commission devc!op and adopt after proper study
a series of classifications and standards which will be appropriate for the purpose of classifying each of
the waters of the state in such a way as to promote tht.: policy and purposes of the act. . Pursuarit tO
this statute, the mies in this Subchapter establish a series of classifications and water quality standards
applicable to the groundwaters of the state ..
(b) These mies arc applicable to all activities or actions, intentional or accidental, which contribute
to the degradation of groundwater quality, regacdless of any permit issued by a governmental agency
authorizing such action or activity. except ·an innocent landowner who is a bona fide purchaser of
property which contains a source of groundwater contamination, who purchased such property without
knowledge or a reasonable basis for knowing ~hat groundWatcr contarnination had occurred, or a per-
. son whose int~rcst or ownership in the property is based or derived from a security interest in the
prope11y, shall not be considered a responsible party ..
History Note: Statutory Authority G.S 143-214.J; 143-2/4.2, 143-215.J(a)(I); 143B-282;
Eff June JO, 1979;
Amended Elf-August 1, 1989; July/, 1988; September 1, 1984;-December 30, 1983 .
. 0102 DEFINITIONS
The definition of any word or phrase used in these rules shall be the same as given in G.S. 143-212.
and G.S. 143-213 except that the following words and phrases shall have the following meanings:
(!) "Bedrock" means any consolidated rock ·encountered in the place in ,vhich it was formed or de-
posited and which cannot be readily excavated without the use of explosives or power equipment..
(2) "Commission" means the Environmental Management Commission as organized under.Chapter
14313 of the General Statutes.
(3) "Compliance bo.undary" means a boundary around a dispQ.sal system at and beyond which waier
quality standards may not be exceeded and only applies lo facilities which have received a pennii
from the Division of Environmental Managemcnt'undcr G.S. 143-215.1, or for disposal systems
pennitted by the Department of 1-luman Resources.
( 4) "Director" means Director of the Division of Environmental Management.
(5) "Fresh groundwaters" means those groundwaters having a chloride conce.ntration equal to or less
than 250 milligrams per liter.
( 6) "Groundwaters" means those waters in the saturated zone of the earth.
(7) "Hazardous substance" means any substance as dcfmcd by Section IO l( 14) of the Comprehensive
Envi.ronmentai Response, Compensation and Liability-Act of 1980 (CERCLA). . . · .
(8) "Limit of.detectability" means the method detection limit established for the U.S. EPA approved
test procedure providing the lowest method detection limit for the substance being ~onitored.
(9) "Natural conditions" means the physical, biological, chemical and radiological conditions which·
occur naturally. · ·
( 10) "Potable waters" means those waters suitable for drinking, by humans.
(11) "Review boundary'.' means a boundary around a pennitted disposal facility, midway between a
waste boundary and a compliance boundary al which groundwater monitoring is required.
( 12) "Sal.inc groundwaters" mean~ those grouml~vaters having a ch.iorjdc concentration o( more than
250 mg/I. · · ·
( 13) "Saturated zone" means that part of the subsurface below the water table iri wltich all the
inlerconnccted voids are filled with water under pres.su,rc at or greater than atmos{)hcric. • Il docS ·
not include the capillary fringe.
(14) "Suitable for drinking" mc,ms a quality of waler which docs not contain substances in concen-
trations which, either singularly or i·n combination if 'ingested into. the human body, ma:Y cause
death, disease, behavioral abno1malities, congenital defects, genetic mut3.tions, or result in an in-
cremental lifetime cancer risk in excess of lxIO·', or render the water unacceptable due lo aesthetic
qualities, including taste, odor m appearance.
NORTH CAROLINA ADMINISTRA TJVE CODE 08/04/89 Page 1
EHNR -ENVIRONME MANAGEMENT T/5: 02L .0100
( 15) "Waste boundary" means the perimeter of the permitted waste disposal area.
(16) "Water table" means the surface of the saturated zone below which all interconnected voids are
filled with water and at which the pressure is atmospheric.
History Note: Statuto,y Authority C.S. 143-2/4.J; /43-2!5(a)(I); !43/J-282;
£ff June JO, 1979.
Amended E(f August I. 1989; July I. /988; March I, /985; September I, 1984 .
. 0103 POLICY
(a) The rules established in this Subchaptcr arc intended to maintain and preserve the quality of the
groundwaters, prevent and abate pollution and contarnination of the waters of the state, protect public
health, and permit management of the groundwaters for their best usage by the citizens of North
Carolina. It is the policy of the commission that the best usage of the groundwaters of the state is as
a source of drinking water. These groundwaters generally arc a potable source of drinking water
without the necessity of treatment. It is the intt:nt of these Rules to protect the overall high quality
of North Carolina's groundwaters and to enhance and restore the quality of degraded groundwaters to
the level established by the standards ..
. (b) It is the intention of the Conunission to-protect all groundwaters to a level of quality at least as
high as that required under the standards established ITT Ruic .0202 of this Subchapter. In keeping with
the policy of the Commission to protect, maintain, and enhance water quality withITT the State of North
Carolina, the Conunission will not approve any disposal system subject to the provisions of G.S.
143-215.l which would result in:
(I). the significant degradation of grnundwaters of which the cxislITTg quality is better than the as-
signed standard, unless found to be economically and socially justifiable, or
(2) a violation of a ,vater quality standard beyond. the boundaries of the property on which the
source of pollution is located, or
(J) the impairment of existing groundwater uses or an adverse impact on the public health, safety
or welfare.
(c) Violations of groundwater quality standards resulting ffom groundwater withdrawals which arc
in compliance with water use permits issued pursuant to G.S. 143-215.15, shall not be subject to the
corrective action requirements of Rule .0106 of this Subchapter. ·
(d) No person shall ·conduct or cause to be conductCd, any activity which causes the concentration
of any substances to exceed. that specified in Rule .0202 of this Subchapter, except as authorized by the
rules of this Subehaptcr.
History Note: Statutory Authority C.S. /43-2/4, 143-2/4./; 143-2/4.2; /43-215.J(ej;
/43-2/5.J(a)( I), /4313-282;
Eff June JO, /979;
Amended £ff August I, 1989; July I, /988; September I, /984; December 30, /983 .
. 0104 RS DESIGNATION
(a) The Director is authorized to designate GA or GSA groundwaters as RS under any of the fol-
lowing circumstances: ·
(I) Where) as a result of man's activities, groundwaters col1.tain concentrations of substances in ex-
cess of the groundwater quality standards cstablishe11 under this Subchapter, and remedial action
to restore groundwater quality has been required, or
(2) Where a statutory vaiiance has been granted as provided ITT Rule .0114 of this Subchapter.
(b) The RS designation serves as a warning that groundwater so designated may not be suitable for
use as a drinking.water supply without treatment. The boundaries of areas designated RS may be ap-
proximated in the ·absence ;1f analytical data sufficient to define the extent of groundwaicr degradation.
The designation is tempor;cry ,u1d will be removed by 1hc Director upon a detennination that the
quality of the groundwater so designated has been restored to the level of the applicable standards or
when reclassified GC.
Histo,y Note: Statuto,y Awhority C.S. /43-214./; 143-2/5.J(a)( I); /4313-282(2);
Eff June JO, 1979;
Ari,ended Elf August I, /989; December 30, /983.
NORTH CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 2
EllNR -ENVIRONME. MANAGE1WENT
.0105 ADOPTION BY REFERENCE
I-lis10,y Nole: Slalu/Ory Awhorily G.S. 143-2/4./;
£ff December JO. 1983;
Repeoled [fl Augusl I. /989 .
. 0106 CORRECTIVE ACTION
• T/5: 02L .0100
(a) The goal of actions taken to restore groundwater quality shall be restoration to the level of the
standards, or as close thereto as is econornica1ly and technologically feasible.
(b) Any person conducting or controlling an activity which rcsUlts in the discharge of a waste or
hazardous substance or oil to the groundwaters of the state, or in proximity thereto, shall take imme-
diate action to terminate and control the discharge, mitigate any hazards resulting from exposure to the
pollutants and notify the Department of the discharge.
(c) Any person conducting or controlling an activity which results in.an increase in the concentration
of a substance in excess of the groundwater standard:
( 1) ~s the result of activities, other than agricultural operations, not permitted by the state, shall.
assess the cause, significance and_ extent of the violation; subrnit a plan for cli.rninating the source
of contarnination and for restoration of groundwater quality; and iinplcmcnt the plan in ac-
cordance with a Special Order by Consent or a Special Order of the Commission.
(2) as a result of activities conducted under the authority of a permit issued by the state, shall, where
such concentrations arc detected: ·
(A) at or beyond a review boundary, demonstrate, through prcdictiv_e calculations or modeling,
that natural site conditions, facility design and operational controls will prevent a violation of
standards at the compliance boundary; or submit a plan for alteration of existing site coi1ditions,
facility design or operational controls that will prevent a violation at the compliance boundary,
and implement that plan upon its approval by the Director.
(13) at or beyond a compliance boundary, shall, assess the cause, significance and extent of the
violation of groundwater quality standards and submit the results of the investigation and a plan
for gr_oundwatcr quality restoration to the Director. Upon approval by the Director, the
permittec shall implement the plan in accordance with _a Special Order by Consent or a Special
Order of the Co,runission.
(d) In the evaluation of remedial action plans, the Director shall consider the extent of any violations,
the extent of any threat to human health or safety, the extent of damage to the environment, technology
available to accomplish rcstorati0n and the public and economic benefits to be derived from
grounqwater quality restoration.
(e) The Director may authorize the discontinuance of re.medial action to restore groundwater quality
to the level of the standard upon a demonstration by the responsible party to the Director that con-.
tiriuance would not result in significant reduction in the concentration of conta1ninants. In the con-
sideration of a request to discontinue fcmeclial actions, the Din~ctor shall consider the duration and
degree of success of remedial efforts, the feasibility of other treaiment techniques which could result in
furthef red.uction of contaminant levels, and the effect on groundwater users if containinants remain at
levels existing at the time of tennination of remedial action.
(f) Upon a determi.n~tion by the Director that continued remedial actions would result in no signif-
icant reduction in contaminant concentrations, the responsible party shall petition for a variance or a
reclassification of the impacted groundwaters.
-(g) . Where groundwater quality standards are exceeded as a result of the application of pesticides or
other agricultural chemicals, the Director shall request the Pesticide 13oard or the Dcpa.i1mcnt of Agra-
culture to assist the Division of Environmental iV1anagement in determining the cause of the violation.
lf the violation is detennined to have resulted from the use of pesticides, the Director shall request the
Pesticide 13oard to take appropriate regulatory action to control the use of the che,nical or chc,nicals
responsible for, or contributing to, such violations, or to discontinue their use.
I-lislory Nole.· SlalulOry Au1horily G.S. /43-2/5.2; 143-2/5.J(a)( I); /4313-282,
£fl Augus1 I, 1989 .
. 0107 COi'vlPUA;>;CE BOUNDARY
NORTH CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 3
EHNR -ENVIRONME.L MANAGEMENT • T/5: 02L .0100
(a) For disposal systems permitted prior to December 30, 1983, the compliance boundary is estab-
lished at a horizontal distance of 500 feet from the waste boundary or at the property boundary,
whichever is closer to the source. .
(b) For disposal systems permitted on or after December· 30, I 983, a compliance boundary shall be
established 250 feet from the waste boundary, or 50 feet within the property boundary, whichever point
is closer to the source.
(c) The boundary shall be established by the Director at the time of pemut issuance. Any sale or
transfer of property which affects a compliance boundary shall be reported immediately to the Director
and the compliance boundary re-established accordingly.
(d) The boundary shall form a vertical plane extending from the water table to the maximum depth
of saturation.
(e) For ground absorption sewage treatment and disposal systems which are permitted under IO
NCA,C I OA .1900, the compliance boundary shall be established at the prope1iy boundary.
(f) Penalties authorized pursuant to G .S. ! 43-2 l 5.6(a)( I )a. will not be assessed for violations of water
quality standards within a compliance boundary'unlcss the result of violations of pernut conditions or
negligence in the management of the facility.
(g) The Director shall rcqutre:
(1) that permits for all activities governed by G.S .. 143-215.l be written to protect the quality of
groundwater established by applicable standards, at the compliance boundary;
(2) that recommendations be made to ensure compliance with the applicable level of standards at
the compliance boundary on all permit applications received for review from other state agen-
cies;
(J) that necessary groundwater quality monitoring shall be conducted within the compliance
boundary; and
( 4) that a contravention of standards within the compliance boundary resulting from activities con-
ducted by the permitted facility be· remedied through clean-up, recovery, containment, or other
response when any of the following conditions occur: '
(A) a violation of a11y standard in adjoining classified waters occurs or can be reasonably predicted
-to occur considering hydrogeologic· conditions, modeling, or other available evidence;
(13) an imminent hazard or threat to the public health or safety exists or can be predicted; or
(C) a violation· of any standard in groundwater occurring in the bedrock other than limestones
found in the C6astal Plain sediments.
History Nole: Sta/u/Ory Authority G.S. /43-215./(b); /43-2/5.](a)(/); /43B-282;
£ff. A ugusl I, I 989 .
. 0108 REVIEW BOUNDARY
A review boundary is established around any disposal system midway between the compliance
boundary and the waste boundary. When the concentration of any substance equals or exceeds the
standard at the review boundary as c)etennined by monitoring, the pennittee shall take action in ac-
cordance with the provisions of Rule .0 I 06(c)(2)(A) of this SubchapteL
History Note: Statuiory Authority G.S. /43-215./(b); /43-2/5.J(a)(I); !43B-282;
£ff Augusl i, 1989. ·
.0109 DELEGATION
(a) The Director is delegated the authority to enter into consent special orders under G.S. 143-215.2
for violations of the water quality standards. ·
(b) The Director is delegated the authmity to issue a ;Jroposcd special order without the consent of
the person affected and to notify the affected person of the procedure set out in G.S. 1.5013-23 to contest
the proposed special order. · . . ·
(c) The Director shall give public notice of proposed special orders and consent special orders.
History Nole: S1a1wory Awhority G.S. /43-2/5.2, !43-2/5.](a)(I); /43-2!5.3(a)(4),
Eff Augusl I, /989 .
. 0110 MONITORfNG
NORTH CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 4
El-INR -ENVIRONME MANAGEMENT T/5: 02L .0100
(a) Any person subject to the provisions of G.S. 143-215.1 who causes, permits or has control over
any discharge of waste, shall install a monitoring system, at such locations, and in such detail, as the
Director may require to evaluate the effects of the discharge upon the waters of the state, including the
effect of any actions taken to restore groundwater quality, as well as the efficiency of any treatment fa-
cility.
(b) iv1onitoring syskms shall be operated in a manner that will not result in the contamination of
adjacent groundwaters of a higher quality.
(c) Monitoring shall be conducted and results reported in a manner and at a frequency specified by
the Director.
History Note: Statutory Authority G.S. /43-215./(b); !43-2!5.3(a)(I); 143-2/5.65;
143-2/5.66; /43B-282;
Eff August I, /989 .
. 0111 REPORTS
Any person subject to the provisions of G.S. 143-215.1 and to the requirements for corrective action
specified in Rule .0 l 06 of this Subchaptcr shall submit to the Director, in such detail as the Director
may require, a written report that describes:
(l) the results ofthe·investigation specified in Paragraphs (c)(l) and (c)(2)(B) of Rule .0106, including
but not limited to:
(a) a desc_ription of the sampling procedures followed and methods of chemical analyses used; and
(b) all teclmical data utilized in support of any conclusions drawn or determinations made.
(2) the results of the predictive calculations or modeling, including a copy of the calculations or model
runs and all supporting technical data, used in the demonstration required in Paragraph (c)(2)(A)
of Rule .0106; and
(3) the propo·sed methodology and timetable associated with the restoration of groundwater quality
for those situations identified in Paragraphs (c)(l) and (c)(2)(B) of Rule .0106.
History Note: Statutory Authority G.S. /43-2/5.!(b); !43-2!5.3(a)(l); 143-2/5.65; !43B-282,
Eff August I. 1989 .
. 0112 ANALYTICAL PROCEDURES
Tests or analytical procedures to determine compliance or noncompliance with the water quality
standards established in Rule .0202 of this Subchapter will be in accordance with: ·
( l) The following methods or procedures for substances where the selected m<;thod or procedure
provides a method detection limit value at or less than the standard:
(a) Standard methods for the Examination of Water and Wastewater, 16th Edition, 1985, published
jointly by American Public Health Association, American Water Works Association and Water
Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection
Agency publication number EPA-600/4-79-020, as. revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S.
Environmental Protection Agency publication number SW-846;
(d) Test Procedures for the Analysis of Pollutants Und.r the Clean Water Act, Federal Register Vol.
49, No. 209, 40 CFR Part 136, October 26, 1984;
(e) Methods or procedures approved by letter from the Director upon application by the regulated
source.
(2) A method or procedure approved by the Director for substances where the standard is less than
the Limit of detcctibility. ·
History Note: Statutory Authority G.S. 143-2/5.J(a)(I); /43B-282;
Eff August I, /989
.0113 VARIANCE
(a) The commission, on its own initiative or pursuant to a request ur,der G.S. 143-2l5.3(e), may grant
variances to water quality standards and the compliance boundary. Persons subject to the provisions
of G.S. 130A-294 may apply for a variance under this Section.
NORTH CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 5
EHNR -ENVIRONME1. MANAGEMENT • T/5: 02L .0100 (b) Requests. for variances arc filed by letter from the applicant to the Environmental Management Commission. The application should be mailed to the chairman of the Commission in care of the Director, Division of Environmental Management, Post Office Box 27687, Raleigh, N.C. 27611. (c) The application should contain the following infonnation: ( I) Applications fucd by counties or municipalities must include a resolution of the County lloard of Commissioners or the gOvcming board of the municipality requesting the variance from water: qualitv standards which apply to the area for which the variance is requested. (2) A description of the past, existing or proposed activities or operations .that have or would result in a discharge of contaminants to the groundwaters. · · (3) Description of proposed area for which a variance is requested. A detailed location map, showing the orientation of thC facility i potential for groundwater contarninant 1nigration, as well as the area covered by the variance request, with reference to at least two geographic references (numbered roads, named streams/rivers, etc.) must be included. .(4) Supporting infonnation to establish that _the varianc.e will not endanger the public health and safety, including health and cnvirorunerital effects from exposure to the groundwater contam-. inants. (Location of wells and other water supply sources including details of well construction within 1/2 mile of site must be shown on a map): (5) Supporting in.formation to ~stablish tl1at standards cannot be achieved by providing the best available technology economically reasonable. This information must identify specific technol-ogy considered, changes in quality of the contaminant plume as demonstrated through predictive calculations approved by the Director, and technological constraints which limit restoration to the level of the standard. ( 6) Supporting information to establish that compliance wciul.d produce serious hardship on the applicant. (7) Supporting information that compliance would produce serious hardship without equal or greater public benefit. (8) A copy of any Special Order that was issued in connection with the contaminants in the pro-posed area and supporting infonnation that applicant has complied with the Special Order. . (9) A list of the names and addresses of any property owners within the proposed area of the vari-ance as well as any property owners adjacent to the site covered by the variance. (d) Upon receipt of the application, the Director will review it for completeness and request additional infonnation if necessary. When the application is complete, the Director shall give public notice·ofthc appl.ication and schedule the matter for a public hearing in accordance with G.S. 143-215.4(b) and the procedures set out below. (c) Notice of Public Hearing. (I.) Notice of public hearing on any variance application shall be circulated in the geographical areas of the proposed .variance by the Director at least 30 days prior to the date of the hearing: (A) by publishing the notice one time in a newspaper having general. circulation in said county; (B) by mailing to the North Carolina Department of Human Resources, Division of Health Ser-vices, and appropriate local health agency; (C) by mailing to any other federal, state or local agency upon request; . (D) by mailing to the local govcmmental unit or units having jurisdiction over the geographic area covered by the variance; . (E) by mailing to any prnperty owner within the proposed area of the variance, as well as any property owners adjacent to the site covered by the variance; and (F) by mailing to any person or group upon request. (2) The contents of public notice of any hearing shall include at least the following: (A) name, address, and phone number of agency holding the public hearing; ( 13) name and address of each applicant whose application will be considered at the meeting; (C) brief summary of the proposed standard variance or modification of the perimeter of com-pliance being requested; (D) geographic description of a proposed area for which a variance is requested; (E) brief description of the activities or operations which have or will result in the discharge of contaminants to the groundwaters described in the variance.application; (F) a brief reference to the public notice (ssued for each variance application; (G) information regarding the time and location for the hearing; (!-1) the purpose of the hearing; NORTE-[ CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 6
EflNR -ENVIRONME MANAGEMENT T/5: 02L .0/00
(I) address and phone number of premises at which interested persons may obtain further infor-
mation, request a copy of each application, and inspect _and copy forms and related documents;
and
(J) a brief description of the nature of the hearing including the rules and procedures to be fol-
lowed. The notice shall also state that additional information is on file with the Director and
may be inspected at any time during normal working hours. Copies of the information on file
will be made available upon request and payment of cost or reproduction.
(f) All comments received within 30 days following the date of the public hearing shall be made part
of the application file and shall be considered by the Commission prior to taking final action on the
application.
(g) In determining whether to grant a variance, the Commission shall consider whether the applicant
has complied with any Special Order, or Special Order by Consent issued under G.S. 143-215.2.
(h) lf the Commission's final decision is unacceptable, the applicant may file a petition for a contested
case in accordance ·with Chapter 15013 of the General Sta.lutes. If the petition is not filed within 60
days, the decision on the variance shall be final and binding.
(i) A variance shall not operate on a defense to an action at law based upon a public or private nui-
sance theory or any other cause of actio,n: ·
Hislory Nole: Sla/Ulory Authorily G.S. 143-215.J(a)(/); 143-215.J(a)(]); /43-2!5.3(a)(4);
143-215.J(e); 143-215.4; ·
£ff August I, 1989.
NORTH CAROLINA AD,vl/N/STRATIVE CODE 08/04/s°9 Page 7
EHNR -ENVIRONME1 MANAGEMENT • Tl 5: 02L .0200
SECTION .0200 -CLASSIFICATIONS Ai\'D WATER QUALITY STANDARDS
.0201 GROUi\DWATER CLASSfflCA TIONS
The classifications which may be assigned to the groundwaters will be thosl: spccifo.:<l in the following
series of classifications:
( n Class GA waters: usage and occurrence:
'(~) Best Usage. E;isting or potential source of drinking water supply for humans.
(b) Conditions Related to Best Usage. This class is intended for those groundwaters in which
chloride concentrations arc equal to or less _than 250 mg/I, and which are considered suitable for
drinking in their natural state, but which may require treatment to improve quality related to
natural conditions.
(c) Occurrence. In the saturated zone.
(2) Class GSA waters; usage and occuffence: •
(a) Best. Usage. Existing or potential source of water supply for potable mineral water and con-
version to fresh waters.
(b) Conditions Related to Best Usage. This class is intended for those groundwaters in which the
chloride concentrations due to natural c6nditions is in excess of 250 mg/1, but which otheiwise
may be considered suitable for use its potable water after treatment to reduce concentrations of
naturally occurring substances.
(c) Occurrence. lit the saturated zone.
(3) Class GC waters: usage and occurrence:
(a) Best Usage. Source of water supply for purposes other than drinking.
(b) Conditions Related to Best Usage. Th.is class includes those groundwaters that do not meet the
quality criteria of waters having a higher classification and for which efforts to restore in-situ to
a higher classification would not be technologically feasible, or not in the best interest of the
public.
(c) Occurrence. In the saturated zone, as determined by the commission on a case by case basis.
Ilislory Nole: S1a11110ry Au1hori1y G.S. /43-214.!; /4jB-282(2);
Eff J11ne /0, 1979; .
Amended Eff A11g11sl /, 1989, Sep/ember I, /984; December 30, /983 .
. 0202 WATER QUALITY STANDARDS
(a) The water quality standards for the groundwaters of the state are those specified in th.is Rule.
They are the maximum allowable concentrations resulting from any discharge of contaminants to the
land or waters of the state, which may be tolerated without creating a threat to human health or which
would otherwise render the groundwater unsuitable for i_ts intended best usage. Where groundwater
quality standards have been exceeded due to man's activities, restoration efforts shall be designed to
restore groundwater quality to the level of the standard or as closely thereto as is practicable.
(b) The maximum allowable concentrations for contaminants specified in Paragraphs (g) and (h) of
this Rule shall be as listed, except that: · .
(I) Where the maximum allowable concentration of a substance is less than the limit of
detectability, the substance shall not be permitted io detectable concentrations.
(2) Where two or more substances exist in combination, the Director shall consider the effects of
chemical interactions and may establish maximum concentrations at values less than those es-
tablished in accordance with Paragraphs (c) and (g) of this Rule. In the absence of information
to the contrary, the carcinogenic risks associated with carcinogens present shall be considered
additive and the toxic effects-associated with non-carcinogens present shall alsc be considered
additive. · ·
(3) Where naturally occurring substances exceed the established standard, the standard will be the
naturally occurring concentration as dctennined by the Director.
(c) Substances which are not naturally occurring and for which no standard is specified shall not be
permitted in detectable concentrations in Class GA ·or Class GSA groundwaters. Any person may
petition the Dlfector to establish an interim. maximum allowable concentration for an unspecified
substance, however, the burden of demonstrating those concentrations of the substance which corre-
spond to the levels described in Paragraph (d) of th.is Rule rests with the petitioner. The petitioner shall
submit al] toxicolog1cal and epidemiological data, study results, and calculations necessary to establish
NORTH CAROLINA ADM!NISTRA TIVE CODE 08/04/89 Page 8
EHNR -ENVJRONME,. MANAGEiHENT • T/5: 02L .0200
a standard in accordance with the procedure prescribed in Paragraph (d) of this Ruic. Within· three
months after the establishment of an interim maximum allowable concentration for a substance by the
Director, the Director shall initiate action to consider adoption of a standard for that substance.
(d) Maximum allowable concentrations for substances in Class GA and Class GSA waters arc es-
tablished as the lesser of:
(I) Systemic threshold concentration calculated as follows: [ Reference Dose (mg/kg/day) x 70 kg
(adult body weight) x Relative Source Contribution (.10 for inorganics;-.20 for organics)]/ [2
liters/day (avg. water consumption)];
(2) .Concentration which coffesponds to an incremental lifetime cancer risk of Ix Io·' ;
(3) Taste threshold limit value;
( 4) Odor threshold limit value;
(5) Maximum contaminant level; or
( 6) National secondary drinking water standard.
(e) The following references, in order of preference, shall be used in establishing concentrations of
substances which correspond to levels described tn Paragraph (d) of this Rule.
( I) Integrated Risk Information System (U.S. EPA).
(2) Health Advisories (U.S. EPA Office of Drinking Water).
(3) Other health risk assessment data published by U.S. EPA.
(4) Other appropriate, published health risk assessment data.
(f) Water quality standards specified in Paragraphs (g) ,me! (h) of this Rule and interim maximum
allowable concentrations established pursuant to Paragraph (c) of this Rule shall be reviewed on a
biennial basis. Appropriate modifications to established standards will be made in accordance with the
procedure prescribed in Paragraph (d) of this Rule where modifications are considered appropriate
based on data published subsequent to the previous review. ·
(g) Class GA Standards. Where not otherwise indicated, the standard refers to the total concentration
in milligrams per liter of any constituent.
(I) acrylamide (propenamide): 0.0000 I
(2) · arsenic: 0.05
(3) barium: 1.0
( 4) benzene: 0.00 I
(5) bro mo form (tribromomcthane): 0.00019
( 6) cadmi_um: 0.005
(7) carbofuran: 0.036
(8) carbon tetrachloride: 0.0003
(9) chlordane: 2. 7 x Io·'
(10) chloride: 250.0 ·
(11) chlorobenzene: 0.3
( I 2) chlorofo1m (trichloromethanc): 0.00019
( 13) 2-chlorophcnol: 0.000 I
(14) chromium: 0.05
( 15) cis-1,2-dichloroethcne: 0.07
(16) coliform organisms (total): I per 100 milliliters
( 17) color: 15 color. units
( I 8) copper: 1.0
( 19) cyanide: 0. i 54
(20) 2, 4-D (2,4-dichlorophenoxy acetic acid): 0.07
(21) l,2-dibromo-3-chloropropanc: 2._5 x 10·'
(22) dichlorodifluoromcthanc (Frcon-12; Halon): 0.00019
(23) 1,2-dichlorocthanc (ethylene dichlo1idc): 0.00038
(24) I, 1-dichlorocthylene ( vinylidene chloride): 0.(•07
(25) 1,2-dichloropropane: 0.00056
(26) p-dioxane ( 1,4-diethylcnc dioxide): 0.007
(27) dioxin: 2.2 x 10·"
(28) dissolved solids (total): 500
(29) endrin: 0.0002
(30) epichlorohydrin ( l-chloro-2,J-epoxypropanc): 0.00354
(31) ethylbcnzene: 0.029
(32) ethylene dibromidc (EDl3; 1,2-dibromoethane): 0.05 x 10·'
NORTH CAROLINA AD,11INISTRA TIVl:.CODE 08/0.//89 Page 9
E/INR -ENVIRONME.L MANAGEMENT
(33) ethylene glycol: 7.0
(34) flouride: 2.0
• TIS: 02L .0200
(35) foaming agents: 0.5
(36) gross alpha particle activity (including radiurn-226 but excluding radon and uranium): 15 pCi/1
(37) hcptachlor: 7.6 x 10·5
(38) heptachlor epox.idc: 3.8 x 10"5
(39) hexachlorobenzene (perch]orobenzene): 0.00002
( 40) n-hexane: 14.3
(41) iron: 0.3
( 42) lead: 0.05
( 43) lindane: 2.65 x 10·5
(44) manganese: 0.05
( 45) mercury: 0.00 I I
( 46) metadichlorobenzene ( 1,3-dichlorobenzene): 0.62
(47) methoxychlor: 0.1 · •
(48) methylene chloride (dichloromethane): 0.005
(49) methyl ethyl ketone (MEK; 2-butanone): 0.17
(50) nickel: 0. I 5
(51) nitrate: (as N) 10.0
(52) nitrite: (as N) 1.0
(53) orthodichlorobenzene ( 1,2-dichlorobenzene): 0.62
(54) oxa.myl: 0.175
(55) paradichlorobenzene ( 1,4-dichlorobenzene): 0.0018
(56) pentachlorophenol: 0.22
(57) pl{: 6.5 -8.5
(58) radium-226 and radiurn-228 (combined): 5 pCi/1
(59) selenium: 0.0 l
( 60) silver: 0.05
(61) styrene (cthenylbenzene): 1.4 x 10·5 _
( 62) sulfate: 250.0
( 63) tetrachloroethylene (perchloroethylene; PCE): 0.0007
(64) toluene (methylbenzene): 1.0
(65) toxaphene:-3.1 x 10·5
(66) 2, 4, 5,-TP (Silvex): 0.01
(67) trans-1,2-dichloroethene: 0.07
( 68) I, l, I-trichloroethane (methyl chloroform): 0.2
(69) trichloroethylene (TCE): 0.0028
(70) vinyl chloride (chloroethylene): 1.5 x 10·5
(71) xylenes (o-, m-, and p-): 0.4
(72) zinc: 5.0
(h) Class GSA Standards. The standards for this class shaU be the same as those for Class GA except
mfo~m: -.
(I) chloride: allowable increase not to exceed 100 percent of the natural quality concentration.
(2) total dissolved solids: I 000 mg/l.
(i) Class GC Waters.
(I) The concentrations of substances which, at the time of classification exceed water quality
standards, shall not be permitted to increase. For all other substances, concentrations shall not
be_ caused or penn.ittcd to exceed the established standard.
(2) The concentrations of substances which, at the time of classification, exceed water quality
standards shall not cause or contribute to the contravention of groundwatf:r or surface water
quality standards in adjoining waters of"a different class.
(3) Concentrations of specific substances, which exceed the established standard at the time of
classification, shall be listed in Section .0300 of this Subchapter.
Histmy Note: Statutmy Authority C.S. /43-2/4.I; !43!J-282(2);
Eff .lune JO, 1979;
Amended EJJ. August I, 1989; September I, /984; December 30, /983.
NORTH CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 10
EllNR -ENVIRONME.L MANAGEMENT • TI 5: 02L .0300
SECTION .0300 -ASSIGNMENT OF UNDERGROUND WATER CLASSIFICATIONS
.0301 CLASSIFICATIONS: GENERAL
(a) Schedule of Classifications. The classifications arc based on the quality, occurrence and existing
or contemplated best usage of the groundwaters as established in Section .0200 of this Subchaptcr and
arc assigned statewide except where supplemented or supplanted by specific classification assignments
by major river basins.
(b) Classifications and W atcr Quality Standards. The classifications and standards assigned to the
groundwaters arc denoted by the letters GA, GSA, or GC. These classifications refer to the classifica-
tions and standards established by Ruic .0201 of this Subcha1,ter.
Hisrory Nore: Sratutory Authority G.S. 143-2/4./, /43B-282(2);
Elf December JO. 1983;
Amended Eff August I, 1989 .
. 0302 STATEWIDE
The classifications assigned to the groundwaters located within the boundaries or un'dcr the
extraterritorial jurisdiction of the State of North Carolina arc:
(1) Class GA Waters. Those groundwaters in the state naturally containing 250 mg/I or less of
chloride arc classified GA.
(2) Class GSA Waters. Those groundwaters in the state· naturally containing greater than 250 mg/I
chloride are classified GSA.
(3) Class GC Waters. Those groundwaters assigned the classification GC in Rules .0303 -.0318 of
this Section.
History Note: Statutory Aurhority G.S. 143-214./; /43B-282(2);.
Elf December 30, 1983,
Amended £ff August I, 1989 .
. 0303 BROAD RIVER BASIN
No classification assignments other than those specified in Ruic .0302 arc made for the river basin.
History Nore: Statutory Authority G.S. 143-214./;
Eff December 30, 1983 .
. 0304 CAPE FEAR RIVER BASIN
No classification assignments other than those specified in Rule .0302 are made for the river basin.
History Note: Starutory Aurhority G.S. 143-214.J;
Elf December 30, 1983 .
. 0305 CATAWBA RIVER _BASIN ..
No classification assignments other than those specified !'1-Rule .0302 arc made for the river basin.
History Note: Statutory Auihoriry G.S. 143-214./;
Elf December 30, 1983 .
. 0306 CHOW AN RIVER BASJN
No classification assigruncnts other than those specified in Rule .0302 arc·madc for the river basin.
Hisrory Note: Statutory Authority G.S. 143-214./;
Elf December 30, 1983 .
. 0307 FRE:'\CH BROAD RIVER BASl0<
No classification assignments other than those specified in Rule .0302 arc made for the river basin.
/-/istory Note: Statutory Authority G.S. 143-214./;
/\'ORTH CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 11
EHNR -ENVIRONME1~& MANA_GEMENT • -----~-------'----'------"-· -----TI s: on .0100
Eff December 3{), 1983 .
. 0308 IHW ASS EE RfVER BASIN
No classification assignments other than those specified in Rule .0302 are made for the river basin.
History Note: Stalulory Au1hori1y G.S. 113-214./;
E(( December 30, /983._
.0309 IXITLE TENNESSEE RIVER BASIN
No "classification assignments other than those specified in Rule .0302 are made for the river basin.
History Note: Sta/Utory Authorily G.S. 143-2/4./,'.
Eff December 30, 1983 .
. 0310 SAVANNAH RIVER.BASIN.
No classification assignments other than those specified in Rule .0302 are made for the river_ basin.
Hislory Nole: S1a1u1ory Authorily G.S. 143-2/4./;
tff December 30, 1983.
.0311 LUMBER RfVER BASIN
No classificatioa assignments other than those specified in· Rule .0302 are made for the river basin.
Hislory Nole: S1a1utory Authorily G.S. /43-_214.l;
Eff December 30, 1983 .
. 0312 NEUSE RIVER BASIN
No classification assignments other than those specified in Rule .0302 are made for the river basin.
Hislory Nole: S1a1utory Authorily G.S. 143-214./;
Eff December 30, /983. ·
.0313 NEW-WATAUGA RfVER BASIN
No classification assignments other than those specified i.n Rule .0302 are made for the river basin.
History Note: StatUlory Authority G.S. /43-214./;
Eff December 30, 1983 .
. 0314 PASQUOTANK RfVER BASIN
No classification assignments other than those specified in Rule .0302 are made for the river basin.
History Note: S1a1utory Awhority G.S. /43-214.1;
Eff December 30, 1983 .
. 0315 ROANOKE RiVER BASIN.
No classification assignments other. than those specified in Rule .0302 are made for the river basin.
History. Note: S1a1utory Authority G.S .. 143-2/4./;
Eff December 30, 1983 .
. 0316 TAR PAMLICO RfVER BASIN
_No classification assignments other than those specified in Rule .0302 are made for the river basin.
History No:e: Sla/Utory Aul/writy G.S. /43-214./;
Eff December JO; /983 .
. 0317 WHITE OAK RIVER BASIN .
No classification assignments 0th.er than those specified in Rule .0302 _are made for the river basin.
NORTH CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 12
\ ,.
·'
EHNR -ENVIRONME. MANAGEMENT • T/5: 02L .0300
History Note: Statutory Authority G.S. 143-214.1;
· Eff December 30, 1983 .
. 0318 YADKIN-PEE DEE RIVER BASIN
No classification assignments other than those specified in Ruic .0302 arc made for the river basin.
History Note: Statutory Authority G.S. 143-214_.I;
EJJ December JO,. 1983 .
. 0319 RECLASSIFICATION
The groundwater classifications as assigned may be revised by the Commission following public-notice
and subsequent public hearing. Changes may be to a higher or lower classification. Reclassification
_ requests may be submitted to _the Director.
History Note: Statutory Authority G.S. 143-214.l; 143-215.J(e); 143B-282(2);
Eff December 30,, 1983; _ .
Amended £ff August 1, 1989.-
NORTH CAROLINA ADMINISTRATIVE CODE 08/04/89 Page 13 '
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•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Marlin, Governor
William W. Cobey, Jr., Secretary
MEMORANDUM
TO:
FROM:
RE:
27 February 1990
Perry Nelson, Chief
Groundwater Section
Division of Environmental Management
Lee Crosby, Head
Superfund Section
Draft Feasibility Study Report
Jadco-Hughes Superfund Site
Belmont, Gaston County, North Carolina
EPA is in the process of completing a Feasibility Study for
the Jadco-Hughes Superfund Site, a National Priority List site.
Attached are three copies of the Draft Feasibility Study
Report for the subject site. This report was prepared by
Conestoga-Rovers and Associates for the U.S. EPA. It is
requested that these documents be forwarded to the appropriate
sections of DEM and comments be submitted to the N.C. Superfund
Section. The N.C. Superfund Section will be reviewing this
document and submitting ·comments to EPA Region IV in the near
future. It is our desire to include the views and permitting
requirements of the Air Quality, Groundwater, and Water Quality
Sections of DEM.
If you·or your staff have any questions, please call Bruce
Nicholson, Jack Butler or me at [phone].
LC/db
Attachment
William , L. Meyer
Director
\
•--~>~ I I ,' •
\, ~d,l~-:''
,; .·,. .>;,:-•,•.':-·
MEMOR.AED;_:!-;
SUBJECT:
FROM:
'!'O:
..
.,
D::.-i;;.ft Feasibility study Report!,"')
Jadco-Hughes Superfund Site
Belmont, North Carolina .--, . .,
~ ~ ·, --...
,,--,. \ I Barbara H. Beno~.:-=-:~---
Remedial Project~Manager
Addressees
•·
·t(tt:/i:JVf(l
FEB 2 6 1990
SUPERFUND SECTION
Attached for your review is a copy of the draft Feasibility Study
Report for the Jadco-Hughes Superfund site located in Belman~, North
Carolina. Please return your comments to my attention no later than
March 13, 1990. This allows approximately 3 weeks for review. If
you are unable to meet this due date, please inform me as soon as
possible as to when I may expect your comments.
If you have any suggestions or comments concerning this site, please
do not hesitate to contact me. I can be reached at 404/347-7791.
Addressees: Winston Smith, ATPMD
Elmer Akin, WasteMD
Chuck Pietrosewicz, ATSDR
Lee Crosby, NCSFB
Jack Butler, NCSFB /
Doug Lair, ESD
Bernie Hayes, WD
Reuben Bussey, ORC
Candice Wingfield, HQ