NCD980729602_19960814_Jadco-Hughes_FRBCERCLA RI_Remedial Investigation 1989 - 1996-OCR

Y State of North·~ · -·, Department ofEr1vironment, • Health and Natural Resources
Division of Solid Waste Management •
•
James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director
Mr. Boyce Hunt
Environmental Health Supervisor
Gaston County Health Department
991 W. Hudson Blvd.
Gastonia, NC 28052
RE: Site Visit
Jadco-Hughes
NCD980729602
Dear Mr. Hunt:
August 14, 1996
David Lilley of the NC Superfund S'ection spoke with you today to notify you that the NC Supcrfund Section will conduct a site inspection of the subject site located in Gaston County, North Carolina. The inspection will be conducted on August 26-November 30, I 996 by Randy McElvcen of the NC Supcrfund Section.
The purpose of the inspection is to conduct a final inspection of remedial operations. You may want to have your representative meet the inspection team at the site. If so, please contact Randy McElvecn at [phone], ext 341 and he will coordinate a meeting.
Ifthc inspection indicates the need for future study of the site, we will contact your office to advise. If you have any questions, please don't hesitate to call David Lilley or me at (919) 733-280 I.
cc: Phil Prete
Doug Holyfield
Pat Williamson
cScott=Ross
David Lilley
Donna Keith
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
Sincer:_ }J;f (_
er Nicholson, Head I -
ederal Remediation Branch
NC Superfund Section
FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
Y. • NPL/DOD •
Trip Notification & Authorization
Today's Date: Q -{ 2--q (a
TO BE COMPLETED BY PROJECT TEAM LEADER (INK ONLY)
Date of Trip: Z -'2.. (,_ T b-xu i1 -3 o -9 l,
If trip changed or cancelled note below:
Trip Date Changed To: ---------Cancelled: -----
NCD#: C/1,D 7 2/'.) (o O 2_
(If none, State ID)
City: Bel V~t.,r County: G-o:-s?t?,:V)
Name of Hotel (Overnight Trip): __________________ _
Hotel Telephone Number: ( ) --
Project Team Leader: If this is a sampling trip, submit a copy of this form to the QA/QC Chemist
To Be Completed by Industrial Hygienist:
County Health Department Contact:_~'--1'-'r--'-._!3,'"""'=,,"'-c"'"e....,tkd:'-'='-'---------------
Title: Gu. f{ec;, r:K, <;;Yfe,rv;>ar
Telephone Number: (7P't ) l?S? -5" ,l,tio
Notes: Health Department Official Contacted: O\r-fio 7ce U:
Back Up Letter Required: Yes _L Nci __
!))of-£.,_J O\r• LJ .n--.. r-1'-f.-1c {DBLJ
Submit this form to the Industrial Hygienist with a copy or the Site Location Map (8½ x 11 paper only)
•
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 30 October 1991
MEMORANDUM
TO:
FROM:
RE:
Bruce Nicholson
Environmental Engineer
Luanne K. Williams, Pharm.D. ~ l,.J
Environmental Toxicologis_t
Jadco-Hughes Site Remediation Objectives
NCD980729602
Belmont, Gaston County, North Carolina
William L. Meyer
Director
After reviewing the Jadco-Hughes Site Remediation Objectives, I
have the following comments:
1. Justification should be provided regarding the deletion of
several soil and groundwater contaminants from the remediation
objectives.
· 2. As a conservative approach, a risk assessment should be
determined assuming worker exposure to surface soil and
groundwater. Surface soil exposure should be assumed in the
risk assessment because the subsurface soil could potentially
be disturbed. Consequently, direct contact could occur.
3. Additivity among the carcinogens and additivity among the
noncarcinogens were not considered in the determination of the
cleanup levels. According to the Environmental Protection
Agency December 1989 Risk Assessment Guidance For Superfund.
Volume I: Human Health Evaluation Manual p. 8-12, and p. 8-
13, carcinogenic effects should be treated as additive and
noncarcinogenic effects should be treated as additive. Dose
additivity is most appropriately applied to compounds that
produce the same effect by the same mechanism of action.
Therefore, chemicals producing similar health effects or
critical effects should be grouped together to take into
account additivity of the effect. These assumptions are made
to help prevent an underestimation of carcinogenic risk (risk
of cancer) or noncarcinogenic risk (risk of harmful effects
other than cancer).
An Equal Opponunity Affirmative Action Employer
Bruce Nicholson
30 October 1991
Page 2
• •
4. Additive carcinogenic and noncarcinogenic effects for soil and
groundwater exposure should also be considered in the
determination of the cleanup levels. Additivity among
exposure media is considered to prevent an underestimation of
carcinogenic risk or noncarcinogenic risk.
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
AUG 9 1990
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:
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'
By this letter, the U.S. Environmental Protection Agency is approving
the July 19, 1990 Remedial Investigation (RI) Report as the final
document. No further modifications are necessary. This is in
accordance with the terms identified in Administrative Order on
Consent, No. 86-21-C, Section VIII, Paragraph H.
Please do not hesitate to contact me if you have any questions
concerning the site. I can be contacted at 404/347-7791.
Respectfully,
/4' ·· · / · · sc-'..--/~ lf '.'.t /(-~.,-,_ -\.' -
.-Barbara H. Benoy
Remedial Project Manager
cc: Joe Claypool, COM
Rueben Bussey, EPA
Lee Thomas, EPA
Rebecca Fox, EPA
Jack Butler, NC-DEHNR
Charles Tisdale, King & Spalding
Steve Quigley, CRA
• •
16 July 1990
TO: File
FROM: Jack Butler
SUBJECT: Jadco-Hughes, NCD980729602
Mr. Jimmy Kirkland, King and Spalding (404/572-3533), contacted our office 13 July
1990 concerning the subject site. Mr. Kirkland was faxed ( 404/572-5100) a copy of the
Division of Environmental Management Review comments dated 25 June 1990 on the Draft
Remedial Investigation. Mr. Kirkland and I also discussed clean up standards for the site
including vinyl chloride which is present in groundwater at 68,000 parts per billion (ppb ).
The drinking water standard for vinyl chloride is 2 ppb and the groundwater standard is
0.015 ppb. When asked, Mr. Kirkland was informed that the groundwater standard would
have to be met at the site.
JB/ds/wp.2
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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. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
Remedial Project Officer
US EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
10 July 1990
Subject: Draft Remedial Investigation
Jadco-Hughes, NCD980729602
Belmont, Gaston County, NC
Dear Ms. Benoy:
William L. Meyer
Director
Enclosed please find comments from the North Carolina Division of Environmental
Management concerning the subject document. These comments are in addition to the
comments previously submitted by the North Carolina Superfund Section. If you have any
questions, please contact me at [phone].
JB/ds/wp.1
Enclosure
Sincerely,
~~
Jack Butler
Environmental Engineer
Superfund Section
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey. Jr .• Secretary
George T. Everett. Ph.D.
Director
June 25, 1990
I
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MEMORANDUM i ~· I ··v-
TO:
\.1' ~r-7 .-<..:-·,_,:_) ' ( ',:'/
William L. Meyer, Director ',,,.; .,,· .;.•·:,-:/
Division of Solid Waste Manageme · t·'"-·-/".,.:-·· ---
FROM:
Division of Environmental Manage ent
, (
SUBJECT:
George T. Everett, Director v.1:,,; (
Review of Draft Remedial Investigatioh-•·
Jadco-Hughes NPL Site,
Gaston County
The subject study has been reviewed by Division staff. The
comments from each Section are detailed below:
Water Quality Section
1. On page 25 of Volume 1, Section 4. 2 Surface Water, the
Catawba River is shown to be classified as WS-II. This
appears to be incorrect, and the Catawba River is classified
WS-III at the point where Fites Creek enters the river.
2. According to the RI, surface water contamination by voes was
identified and characterized as originating from
contaminated groundwater (from an on-site culvert). The
study revealed that " ... voe contamination essentially
dissipates immediately downstream of the site."
It appears that impact to surface waters is not significant
at thi~ time; however, groundwater and sedim~~t
contamination could impact surface waters if conditions
should change.
PoUudon Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
"-r-,,~1 r\,.,,.,..,.,-....+,,nih, Affil'TYl,,,N\,.,. Artinn rmnlnvPr
, • •
Air Quality Section
It does not appear that the air quality of the surrounding
neighborhood will be adversely affected during the proposed
clean-up activities except possibly through wind-blown
particulate matter when the contaminated soil at the site is
being disturbed. If this becomes a problem during the
project, the soils may need to be wetted periodically to
minimize the fugitive off-site emissions.
Groundwater Section
The delineation of the contaminant plume(s) needs to include
the vertical component of plume geometry superimposed on the
aquifer cross sections.
cc: Perry Nelson
Steve Teddar
Lee Daniel
Brenda Smith
Jack Floyd
Bill Reid
,. • • lj.Jl ~; { • \I.,, IV ED u ,,..,;,,,bl
JUL fl 1990
SUPERHIND SECTION
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 .. Secretary
George T. Everett, Ph.D.
Director
June 25, 1990
MEMORANDUM
FROM:
SUBJECT: Review of Draft Remedial Investigatio
Jadco-Hughes NPL Site,
Gaston County
The subject study has been reviewed by Division staff. The
comments from each Section are detailed below:
Water Quality Section·
1 . On page 25 of Volume 1, Section 4. 2 Surface Water, the
Catawba River is shown to be classified as WS-II. This
appears to be incorrect, and the Catawba River is classified
WS-III at the point where Fites Creek enters the river.
2. According to the RI, surface water contamination by voes was
identified and characterized as originating from
contaminated groundwater ( from an on-site culvert). The
study revealed that " ... voe contamination essentially
dissipates immediately downstream of the site."
It appears that impact to surface waters is not significant
at this time; however, groundwater and sediment
contamination could impact surface waters if conditions
should change.
Polludon Prew!ndon Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
.. • •
Air Quality Section
It does not appear that the air quality of the surrounding
neighborhood will be adversely affected during the proposed
clean-up activities except possibly through wind-blown
particulate matter when the contaminated soil at the site is
being disturbed. If this becomes a problem during the
project, the soils may need to be wetted periodically to
minimize the fugitive off-site emissions.
Groundwater Section
The delineation of the contaminant plume(s) needs to include
the vertical component of plume geometry superimposed on the
aquifer cross sections.
cc: Perry Nelson
Steve Teddar
Lee Daniel
Brenda Smith
Jack Floyd
Bill Reid
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
4WD-NSRB
JUN ;~ G 1990
SUPERFUND SECTION
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 the final comments on the revised Remedial
Investigation (RI) Report. These comments are essentially repeated
comments from the first set of EPA comments. Any additional comments
are direction to delete or reword text as appropriate. All comments
are to be incorporated into the text ·of the RI Report as specified.
The second Revised RI Report is due to the Agency no later than July
3, 1990. A copy of the floppy disk(s) containing the text of Volume
1 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,
/'1
j/-,1, ,.: ./ ·, /:· ,
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Barbara H. Benoy
Remedial Project Manager
cc: Joe Claypool, CDM
Lee Thomas, EPA
Rebecca Fox, EPA
Jack Butler, NC-DEHNR ✓
Charles Tisdale, King & Spalding
Printed on Recycled Paper
, . • Jadco-Hughes Revised RI
Final Agency Comments
Page 2
1) Page ii, Executive Summary, third paragraph, delete last
sentence, "This objective has been achieved."
2) Throughout the report, delete references to "contaminant
masses".
3) Phase II test pits must be renamed since no analytical samples
were collected. Rename to observation pits in name as well as
codes used to locate and describe.
4) Substantiating evidence has not been provided to indicate that
the groundwater strongly discharges to culvert. All language
must acknowledge that strong groundwater discharge to culvert
is a potential or possibility.
5) Provide difference between prime farmland and state important
farmland.
6) Executive Summary must: define acronyms prior to their use,
provide accurate and very brief pre-RI data summary. Use !!Q
subjective adjectives. Provide only factual .information.
Delete all information concerning contaminant masses.
Paragraph 4, page iii, concerning PCBs in soil must read, "A
surface area no less than 440 square yards." Page iv, top of
page, first paragraph, delete the first word "Little".
7) Delete third full paragraph, page 6. This information is
subjective and inaccurate. Lends nothing to the report.
8) Delete first, second and third paragraphs, page 7.
9) Delete last sentence on page 7.
10) Page 37, first paragraph in Section 5.2, change text to read
"Surface water is used as a municipal drinking water supply
from the Catawba River for the City of Belmont.
11) Page 84, delete last sentence in Section 8.1.1.
12) Section 4.4 must identify the depths that groundwater was
encountered when boring. (Reference original comments# 79).
13) Page 5 and 6, Section 1.5.1, delete all text in first paragraph
after first sentence.
NOTE TO STEERING COMMITTEE: Although the criteria and
proposed standards in Table 1.1 are not regulations, they
are health· based. The discussion of water quality criteria
is inaccurate for several reasons and not appropriate for
this section. Firstly, Table 1.1 does not contain any
• • Jadco-Hughes Revised RI
Final Agency Comments
Page 3
surface water quality criteria numbers. All of the categories in
this table refer to numbers that are based on human consumption or
use of groundwater. Secondly, water quality criteria are not only
established for the protection of aquatic life. Ambient Water
Quality Criteria are also developed for the protection of human
health via consumption of water and aquatic organisms.
14)
15)
Delete last paragraph on page 8 through the end of Section
1.5.2.
Table 1.1, in addition to IRIS, the Health Effects Summary
Table (HEAST) must be consulted for cancer potency factors
(CPF) and reference doses (RfD). A copy of these tables can be
obtained from the Superfund Docket (202-382-3046). In addition
to the health based numbers contained in this table, the
following chemicals have toxicity numbers from which health
based numbers must be calculated.
1,2-dichloropropane
tetrachloroethene
1,1,2-trichloroethane
trichloroethane
1,1-dichloroethane
1,4-dichlorobenzene
arsenic
carbon tetrachloride
chlorobenzene
1,2-dichloroethane
1,2-dichlorobenzene
naphthalene
barium
cadmium
manganese
selenium
thallium
vanadium
The health based numbers for noncarcinogens must also reflect
exposure to the chemical from sources other than consumption of
site contaminated groundwater. If relative source contribution
is not available for a chemical, EPA estimates the contribution
from drinking water to be 20 percent of the total exposure.
Therefore, the groundwater cleanup criteria in this table
should be multiplied by 20 percent to reflect the relative
source contribution.
Due to structural similarity and a common cancer potency
factor, the MCL for 1,2-dichloroethane should be used for
1,1-dichloroethane.
16) As previously requested and in addition to Appendix M, Section
8.2 must contain a brief discussion of the sampling depths and
the equation(s), (including any and all assumptions and the
i . • Jadco-Hughes Revised RI
Final Agency Comments
Page 4
•
respective rationale) used to calculate average
concentrations.
17) All calculations determining total concentrations, average
concentrations, representative concentrations must be
provided.
18) Delete first paragraph on page 97.
19) Tables 8.9 and 8.11 must be consistent with Table 1.1
20) Table 9.2 indicates that amounts of contaminants that could be
released would be negligible to low amounts. This is
incorrect. Delete "and Amount" in right column head and all
references to amounts in right column.
21) Table 1.1 must include the proposed MCLs for
1,2-dichlorobenzene (600 ug/1) and chromium (100 ug/1).
22) Table 8.1 states the site background for chromium incorrectly
as 79 to 525 mg/kg. It should be 7 to 52 mg/kg.
23) Table 8.9 -There is no proposed MCL for total
1,2-dichloroethene. There are proposed MCLs for cis-and
trans-of 70 ug/1 and 100 ug/1 respectively. Similarly, there
is not a proposed MCL for 1,1-dichloroethene of 170 ug/1.
However, there is an MCL of 7 ug/1. Include· in Table 8.9.
24) Table 8.13 -Change assessment criteria of lead to the proposed
MCL of 5 ug/1.
25) Figure 3.1 requires a table explaining the samples collected in
addition to Appendix~, locations, dates, etc. (Reference
original comments# 59 and 67).
26) The water supply code must be defined (as requested in original
comment # 73).
27) Delete third sentence of first paragraph on page 119 through
the end of paragraph.
28) Delete first sentence of# 12 on page 122.
29) Add the words "no less than" to# 10 just prior to 440 square
yards.
30) Delete# 14 from page 122.
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
U.S. EPA Region IV
345 Courtland Street
Atlanta, GA 30365
• •
January 22, 1990
Subj: Comments on the Remedial Investigation Report
Jadco-Hughes NPL Site
Belmont, Gaston County, North Carolina
Dear Ms. Benoy:
William L. Meyer
Director
The NC Superfund Section is pleased to offer these comments on
the Jadco-Hughes Site Remedial Investigation (RI) Report 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. As you know, we did not
receive the RI report until December 29, 1989. However, given both
of our schedules we hope these comments have been provided in a
timely manner and that they will be incorporated into the revised
RI report.
We offer the following specific comments:
1. Page 19, Section 2. 3. This section presents Table 2. 1, A
summary of potentially contaminated areas. Table 2. 1
indicates "Geophysical Data Anomalies" were found on site.
What are these anomalies? Nothing is mentioned in Section 2.3
about them.
2. Page 24, paragraph 4. The report states that there is a fence
remaining on site. Does this fence surround the site, and is
it a complete barrier to entry or not?
3. Page 25, paragraph 1 & 2. When discussing land use in the
site area it would be useful to add whether or not the
industrial/commercial sites mentioned share the same drainage
or not. It would also be useful to present a map and locate
the sites discussed, particularly if they share the same
drainage.
• •
4. Page 25, Section 4. 2. When discussing the surface water
pathway it would be useful to present a figure such as Figure
5.3 in this section. Figure 4.1 does not adequately cover the
entire discussion. Also, additional information should be
presented in this section including the stream-miles from the
site to the Catawba River, the Belmont City intake, and the
other intakes of concern shown on Figure 5.3. Tributary A,
discussed in the text, does not appear to be labeled on Figure
4. 1.
5. Page 26, Section
evaporation rate
presented in this
4. 3. It
and the
section.
would be useful to
net precipitation to
add annual·
the ·data
6. Page 26 and 27, Section 4.4. Discussion of ground water flow
in more sp·ecific terms may be useful here. The information
presented in this section is very sparse. I know it is
discussed in more detail in Section 7, but having a mental
picture of the ground water flow pattern prior to the
discussion of the investigations undertaken would be useful.
Therefore, a figure such as Figure 7.4 (perhaps without the
monitoring well locations) would help this section and would
not be redundant.
7. Page 29, paragraph 2. The report states, "The Pre-RI data [of
residential wells) are shown in Table 5.2. These data did not
exhibit evidence of groundwater contamination from the site in
1985." This statement is somewhat misleading and should be
removed or modified. It should be noted that there is no
organic contaminant data on the pre-RI samples which were
taken in 1985. The statement "did not exhibit evidence ... ",
while true, is misleading because there is no data concerning
the main contaminants at the site, VOC,s.
8. Page 29, paragraph 5. The North Carolina Department of
Natural and Economic Resources, Office of Water and Air
Resources, Ground Water Division is currently the North
Carolina Department of Environment, Heal th, and Natural
Resources, Division of Environmental Management, Ground Water
Section.
9. Page 33, paragraph 3. The discussion in this section is
unclear to the cold reader and raises many unanswered
questions. What is the significance of the clay layer
encountered at MW-5? Was clay encountered at other wells? Is
this the reason only a single monitoring well was installed
for MW-·5? If so, why? If not, why was only one well placed
at MW-5? What is so important about the fact that the bedrock
is deeper than expected? How deep? (I know only after reading
later sections that this meant that all of the deep wells were
still in the saprolite, and there were no wells placed in the
bedrock. This point needs to be emphasized here.).
• •
10. Page 39, paragraph 2. Concerning the "metallic survey"
conducted on site, is there a survey report, memorandum, or
logbook that describes the findings? If so, this would be a
useful addition to the Appendix. Also, is this the source of
the "geophysical data anomalies" found at TP' s 4, 5, 6, and 8
indicated in Table 2. 1 to be a potential areas of
contamination? (see Comment 1).
11. Page 44, Section 6 .1. 4. It states that soil samples were
collected from "the 5 exploratory boreholes (Figure 6. 2) . "
However, six boreholes are shown on Figure 6.2.
12. Page 44, Section 6.1.5. The report states that the backhoe
was decontaminated between test pits to prevent cross
contamination. Was this cleanup water part of the ·water
collected and stored on site? If so, can the collection
procedure be described briefly.
13. Page 45, paragraph 2. It states, "Although full sample sets
were collected, only select additional samples were requested
for voe analysis." The meaning of this statement is not
clear.
14. Page 48, paragraph 3. It is noted that all equipment was
cleaned on the ''decontamination pad''· What is this pad? Is
it an existing structure on the site? If any water was
collected, state the procedures used.
15. Page 56, paragraph 3. It states that due to the level of
organic vapors personnel upgraded protection to Level c. What
were the voe levels detected, and how far above action levels
were the readings?
16. Page 56, paragraph 4. It states one buried 55-gallon drum was
found that contained a purple-red liquid. What was' the
material? If it was not sampled, why? The report should at
discuss the likelihood (or unliklihood) of other drums that
have yet to be found. This appears to be a potential so.urce
of contaminants which is not presented in Table 2.1 or
anywhere else in the report. This RI is leading to a remedial
action at a site where there used to be more than 10,000
drums. Unless there is a reason yet unstated in the report,
it is almost inconceivable that when a buried drum is found,
it is apparently not sampled, and it gets little more than a
passing mention in the report. The NC Superfund Section can
only conclude that the remedial action being planned does not
account for or even consider the possibility of other drums
buried on site.
17. Page 57, paragraphs 1-4. It seems that it would be useful to
describe, where possible, which test pits delineate each
source area as was done for the landfill area described in the
first paragraph. If the test pits did not define the area it
would be useful to so state. For example, in paragraph 3,
• •
TP-21 to TP-24 covers a very large area. Where is the actual
pit? Can its location be delineated? How are the facts
presented "consistent" with the record of the pit closure?
It was noted in Section 2.2.2 that the decant pits may have
been larger than described in the record. What do we know from
the test pits as to the si_ze and location of the decant pits?
18. Page 58, paragraph 1. It states, "The analytical· results from
these two wells (MW3D and MWl0D) were utilized to determine
the need for installation of additional contingent wells."
More explanation is needed here. How do the analyses from
these two particular wells establish the need for more w_ells?
The report states that MW13D was installed based on a positive
chromium analysis. In what well was the chromium detected?
How was the location for MW13D established? What was the
rationale behind it?
19. Page 59, paragraph 3. The first sentence states the data were
"qualified" because of a high matrix spike recovery. The
meaning of this is not clear.
20. Page 60, paragraph 2. It states that sediment samples were to
be collected in six locations (with two others added by the
field staff). It would be useful to give the sample numbers
an·d refer the reader to Figure 6.5 as was done below it in
paragraph 4.
21. Page 62, paragraph 2. The report describes finding the drum
in TP-3 6. Our comment here is the same as in Comment 16
above.
22. Page 68,
Saprolite
A and B.11
paragraph 2. It states, " ... groundwater flow in the
Unit is influenced by the buried culvert Tributaries
The word "and" should be placed after "culvert".
25. Page 77 paragraph 3, Table 8.4, and Page 80, last paragraph.
Concerning the estimated contaminant masses presented in Table
8.4, the report presents no rationale and supporting evidence
for choosing the areas and depth of contamination. More
importantly, the presentation of the data in Table 8.4 as an
estimated contaminant mass is not technically sound and is
subject to misinterpretation. The limited samples taken of
the contaminated areas are not statistically representative of
the contamination in these areas as a whole, and, therefore,
the average concentration cannot be used to estimate a
contaminant mass. At best, it can be used as a relative
measure of severity and magnitude of one contaminated area to
another and to show the locus of a specific contaminant group.
However, the benefits of using the technique for this purpose
are outweighed by the possibility that the data could be
easily misinterpreted as an accurate estimate or even fact.
Therefore, the NC Superfund Section supports removing all
contaminant mass estimates from the report, including the
conclusions section.
• •
23. Page 78, paragraph 2. This section and Figure 8.1 discuss the
contaminant distribution in the landfill area. It is noted
that the landfill area in Figure 8 .1 does not contain TP-13
through TP-15. However, page 57 states that TP-13 contains
similar sludges to TP-2 and TP-3, and that TP-14 and TP-15
delineate the eastern extent of the landfill. These sections
should be made consistent. Also, it would be useful to draw
the outline of the suspected landfill area on Figure 8.1.
24. Page 79 and 80. It is noted that there are
compounds found in the area, most of which
polynuclear aromatic hydrocarbons (PAH's). Is
in the record to indicate the source of these
they burn products?
numerous BNA
appear to be
there anything
compounds? Are
· 2 6. Page 81, Section 8. 2. 3. · The report states, "The south decant
pit is estimated to have been 100 feet by 20 feet by 15 feet
deep ... " How was this estimate developed? The only previous
mention of the pi ts size is on page 15, where it says the
reported size was 20 feet by 8 feet by'an unknown depth. To
what is this difference attributed? The estimated outline of
the pit is not labeled on Figure 8. 3. Was the decant pit
location determinable from the evidence gathered with the
boreholes and test pits (from physical appearance of the soil
and sampling data)? Given the spacing of the boreholes in the
area and the possibility that the pit was as small as 20 feet
by 8 feet, is it possible that the pit was missed?
2 7. Page 8 3, Section 8. 2. 4. As above in Comment 2 6, there is a
large discrepancy in the reported north decant pit size of 6
feet by 12 feet (page 15) and the estimate presented in ,this
section of 20 feet by 175 feet by 15 feet deep. What is the
rationale for such a large pit? A pit 175 feet by 20 feet by
15 feet would hold approximately 390,000 gallons and the other
pit, 100 feet by 26 feet by 15 feet, would hold 220,000
gallons. This is more than the entire capacity of the 550·, 000
gallons iri the 11,000 or so drums on site (that is, if the
drums were all full). The record indicates that these pits
were used to hold chemicals temporarily until they were pumped
out and trucked off site. Such large pits would not' be
necessary, would be too costly to excavate and line, and
indeed could not possibly function as a decant pit as
described in the record [By unloading the contents of the
drums into pits of this size it would take forever to have
enough standing liquid in the bottom to pump · into a tank
truck.]. Thus, without additional evidence presented in the report
we are not inclined to believe the pits are that large.
• •
28. Page 101, paragraph 1. It states, ''Two significant zones of
ground water contamination can be attributed to known releases
of past activities.'' What are these zones?
The NC Superfund
provide these comments.
me at [phone].
Section appreciates the opportunity to
If .you have any questions please contact
Sincerely, ~-¼/J__
BIN/let/jadricom
cc:
Lee Crosby
Perry Nelson
Bruce Nicholson
Chemical Engineer
Superfund Section
• • UNITED STATES ENVIRONMENTAL PROTECTION AGEiji
REGION IV CfE!VfEt'h
345 COURTLAND STREET NE Of C 19 198911,,,11
ATLANTA. GEORGIA 30365
~-ON 4WD-SFB
DEC 1 4 1989
Lee Crosby
North Carolina Department
of the Environment, Health & Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Subject: Jadco-Hughes Superfund Site
Draft Remedial Investigation Report
Dear Ms. Crosby:
The Remedial Investigation (RI) field work for the Jadco-Hughes NPL site has
been completed. The Draft RI Report has been received and has been
forwarded under separate cover to Jack Butler for state review. Please
return all review comments to my attention no later than January 14, 1989.
This allows approximately 4 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
them.
Thank you for your attention to this matter. Please do not hesitate to
contact me at 404/347-7791 if you have any questions.
Barbara H. Benoy
Remedial Project Manager
Enclosure
Q°3\;t:i~~'tri
\!i~I U \. 'J 30
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• •
.,_::.. , -· • •
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
David T. Flaherty, Secretary
Ronald H. Levine, M.D., M.P.H.
9 March 1989
Ms. Barbara Benoy
Remedial Project Manager
United states Environmental
Protection Agency
Region IV
345 Courtland Street
Atlanta, GA 30365
State Health Director
SUBJECT: Comments on the RI for the Jadco-Hughes NPL Site,
Gaston County, North Carolina
Dear Ms. Benoy:
The Phase I Report for the Jadco-Hughes RI/FS has been
reviewed and the following comments are offered:
(1) We concur with the proposed areas targeted for
further investigation, in particular, the storage
tank area. Samples collected from monitoring well
MW-6S; located in the storage tank area, had the
highest concentrations of total VOC's and BNA's in
the shallow groundwater on-site. It would be prudent
to collect soil samples via a boring as is proposed
for Phase II of the RI. This area may be a source
area for contamina~t releases through leaking storage
tanks. These tanks may require excavation.
( 2) A preliminar.y list of technologies for soil
remediation is presented on Table 5.1. Our
recommendation is that the list should be expanded
initially to be more comprehensive. Bioremediation,
on-site incineration, fixation/stabilization, and
soil washing could be added. At this point the list
should be broader and then be narrowed during the
Feasibility Study process.
Ms. Barbara Benoy
9 March 1989
page 2
•
We appreciate this opportunity to offer comments and lo'ok
forward to continued involvement with RI/FS activities. Please
contact Charlotte Varlashkin or me at [phone] if you
have questions concerning these comments.
LC/acr
Sincerely,
f) r'.
,~/2_.,{_,, \__)'>-ob~
Lee Crosby, Head
Superfund Branch
• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
MEMJRANDUM
Date: FEB 2 7 1989
Subject: Jadco--Hughes NPL Site
34!5 COUR-rl.ANO STREET
ATLANTA, GEORGIA 303G!
Dr.aft Phase I RI Repor.t
Fr.om: Bar.hara H. Benoy, RPM /j i /2
Supe.r.fund Br.anch iD:J1_)
To: Addr.essees
Attached is a copy(s) of the Dr.aft Phase I Repor.t for. the Jadco--Hughes NPL
Site. Please have an appr.opr.iate staff member. r.eview the d=urnent. All
ccmments should be r.eceived no later. than Mar.ch 20, 1989. Please contact me
at 404/347-7791 if you have any questions. Your. attention to this matte.r. is
gr.eatly appr.eciated.
· Addr.essees: Winston Smith
Chuck Pietr.osewicz
Doug Lair.
Attachment
Rueben Bussey
Jim Kutzman
Lee Cr.osby
Elmer. Akin
R. Paul Wilms
James Lee
Air., Toxics and Pesticides Division
ATSDR
ESD
ORC
Water. Division (3 copies)
NCDNRl
EPA Waste Mgmt. Division
NCDNR-CD
Dept. of the Inter.ior.
• /.'~~STAT£-;:•~
(f_~:~~·;;1·;~::~~~\; \'< .. ,·. r. .. ~
~'-' ~ . Ii, " 'B V,;;-'._I .. 1 .J:.<' ". ""••·••'" . ; -~t~~::::::::._ ...
•
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
January 11, 1989
MEMORANDUM
To: Mr. Perry Nelson, Chief
Groundwater Section
Division of Environmental Management
From: Lee Crosby, Chief· 0. o_,,
Superfund Section~
Division of Solid Waste Management
William L. Meyer
Director
RE: Review and Comments on the Draft Remedial_ Investigation Report
for the Jadco-Hughes NPL Site, Belmont, Gaston County
Two copies of the Draft Remedial Investigation Report for the
Jadco-Hughes site in Belmont, Gaston County are enclosed for your
review and the review of the appropriate regional office. Please
return comments, if any, to this Section so that we may submit one
package to the U.S. Environmental Protection Agency. We anticipate
that the Feasibility Study will be forwarded to us next month. We
will again forward that document to you when received.
If you have any questions please contact Bruce Nicholson or me
at 733-2801. We appreciate your working with us on this site.
LC/acr/jadcodem
Enclosures