NCD980840409_20071120_Charles Macon Lagoon Drum_FRBCERCLA RA_Remedial Design Remedial Action 1988 - 2007-OCR

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:t1,\\fO Sr,q,: ----_,1_~_.-_..,---UNITED·STATES-ENVIRONMENTAL:-PROTECTION-AGENCY ____ _ ;,,; ft ·,_ REGION 4
(~o,: ~ ~ \ SAM NUNN ATLANTA FEDERAL CENTER
~ 'f 61 Forsyth Street, S.W.
'f,i,, ,,;," Atlanta, Georgia 30303-3_104
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4WD-SRSEB
Mr. Stuart A. Ryman, P.G.
Project Coordinator
Altamont Environmental, Inc.
50 College Street
Asheville, North Carolina. 28801
November 20, 2007
-I . I SCANl\!ED l \ ·---·. -----i '
FEB 1 7 i'.017
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N.C. Superfund Section
lnl NOV 2 6 2007 UJJ
SUPERFUND SECTION
SUBJ: Comments on CERCLA Remediation System Performance Evaluation Report for the
Chemtronics Superfund Site, Swannanoa, Buncombe County, North Carolina
Dear Mr. Ryman:
The Agency and North Carolina Department of Environment and Natural Resources
(NCDENR) were sent a copy of the CERCLA Remediation System Performance Evaluation on
July 10, 2007. Enclosed are comments from NCDENR dated September 14, 2007.
Below are the Agency's comments and enclosed are comments from NCDENR. The
Agency feels a major component of a system performanc·e evaluation, a capture zone analysis, is
missing from this report. However, in light of the recent site-wide groundwater/surface water
sampling effort, it may make more sense to perform a capture zone analysis on both groundwater
extraction systems at later date, after the potentially responsible parties (PRPs) have had an
opportunity to evaluate the results of this recent sampling effort. However, the Agency feels it is
important that these analyses occur in order to move the groundwater remediation at the
Chemtronics site forward. After the PRPs and Altamont Environmental have had an opportunity
to review and discuss the following and enclosed comments, we need to arrange a conference
call to discuss how to finalize this report. ·
Comments:
I. Page 6, Section 1.4.1 Front Valley, first paragraph, last sentence: This sentence states, "No
such impacts were identified in association with DA I 0/11." However, this paragraph·
implies that this statement is based on data collected during the Remedial Investigation. The
RI was completed back in the mid l 980's. Is there more recent data that can be referred to in
this paragraph? Later on in this report, the text does mention that chemicals of concern
(COCs) were detected in the Unnamed Branch downgradient ofDA-23. Are these
detections attributable to DA-23 or DA I 0/11?
2. Page 7, Section 1.4.2 Back Valley, first para1,,,-aph, fourth sentence: Refer to comment
number I above. Is there more recent data that supports the statement," ... surface water
quality impacts in association with DA 7/8 and/or DA-9"?
• 2
3. Page 7, Section 1.4.2 Back Valley, first paragraph, seventh sentence: Refer to comment
number I above. Is there more recent data that supports the statement, "The ROD concluded
.... tha_t __ surfac_e water remediation of VOCs would not be necessary as groundwater remediation
~ r:·7· iwoulo·addr.ess th_e·soiirce,ofthe VOC ... "? · · , ' I c,_, :L d -"I ·,:' ::J ifl1; ·.'l 1: ·-.-~ -----i,,..;I' , ~-i /Page_ 9, Sect10n 2.1 Gi:qundwater Level Measurements, second paragraph: A short statement 11:,.! should be included if\ tjii~jpara~aph explai11ing why the groundwater level data for these
l 1 )'!:;\<~_) 1<1tes w~r~ use_d in this report. . .
1 :M). • !"jr : , , . , ;F ·-, ,1 .. , i ~ ~.i.~~! .. ';.:-U_ ~lt'f_'..J\f\'• ·,,•c i ,·,;:, ." ! , ·1; · 5. Page 9;Seclion·2: I ·Groundwater Level Measurements, top of page: Based on Figures 7, 8,
and 9, it does not appear that the Front Valley extraction system, extraction wells STW-1 and
. ' DTW-1, is having any .effect on the flow of groundwatei; in the Front Valley (i.e., creating a
sufficient groundwater capture zone laterally or vertically). Refer to commel)t number 32
below.
6: Page 11, Section 2.2 Groundwater Extraction Flow Rates, last sentence: What or how does
the less than expected extraction rate influence the conclusion stated in this sentence? The
limited number, location and/or depths of the extraction wells in the Front Valley also
minimize the capture zone created in the Front Valley._ '
7. Page 12, Section 2.3 S\lrface,Water Measurements, last paragraph, last sentence: This
sentence states, "The reasons for these apparent differences have not yet to been
determined." Are there efforts planned to identify and quantify these differences?
8. Page 15, Section 3.1 Monitoring 'wells, sec~nd paragraph, last sentence: Change this
sentence read, " ... described in detail in the_.QeseTuJ:>~t~2(l0§, Data Summary Report."
9. Page 17, Section 3.2 Treatment System and Extraction Wells, first paragraph, second
sentence: This sentence uses the acronym "NOMA". Although this acronym is included in
the "List of Ac:onyms", what is nitrosodymethylamine and where does it come from?
10. Page 19, Section 4.1 Groundwater Level Measurements, bottom of page: Refer to
comment 4 above.
· 11. Page 20, Section 4.1 Groundwater Level Measurements, top of page: Based on Figures 16,
17, and 18, it does not appear that the Back Valley extraction system is completely capturing
the plume in the Back Valley (i.e., creating a Sl!fficient groundwater capture zone laterally or
vertically).Refer to comment 18 below.
12. Page 22, Section 4.3 Surface Water Measurements, last paragraph, first sentence: A short
statement should be included in this paragraph explaining why the data from this gauging
station (CSW-BV-5) j's the only station graphed.
13. Page 25, Section 5.1 Mon_itoring Wells, first paragraph, last sentence: What happens to the
statistical results if the 2002 analytical data is dropped from database? It appears that there
is justification, at least for running trend analyses, to drop the 2002 data set.
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14. Page 27, Section 5.2 Treatment System and Extraction Wells, last para1,'Taph: This paragraph
discusses sending a letter to the Metropolitan Sewerage District (MSD) about perchlorate. If
a response was received back from MSD, the response should be summarized in this
paragraph. If a no response was received, this should also be included in this paragraph.
(Does the MSD treatment train include an anaerobic digestor which would probably
mineralize the perchlorate?)
15. Page 31, Section 6.1.2 Groundwater and Compound Extraction: Given that the majority of
the volatile organic compounds (VOCs) are removed via the air stripper, does the quantity of
activated carbon used to date in the Front Valley treatment system make sense for the
volume and concentration of contaminants that have flowed through the activated carbon
units?
16. Page 32, Section 6.2.1.1 Air Stripper Replacement: Was not the original air stripping unit
replaced stainless steel? If so, any explanation as to why the stainless steel unit corroded? ls
the new air stripper stainless steel?
17. Page 39, Section 8.0 Summary of Key Findings: I did not see any discussion on monitored
natural attenuation in this report. Is this concept still being considered for areas of the Site?
If so, this idea may want to be captured in Section I 0-Recommendations.
18. Page 39, Section 8.0 Summary of Key Findings: I did not see any discussion on a capture
zone analysis ·for either the Front or Back Valley groundwater extraction systems. This is a
key component of a groundwater extraction system performance evaluation. Refer to
comment number 32 below.
19. Page 39, Section 8.1.1 Evaluation of Hydraulic Performance: Refer to comment number I 8
above.
20. Page 40, Section 8.1.2 Evaluation of Contaminant Concentration and Distribution, last
bullet: This bullet compares the analytical results for two surface water samples collected
from the same stream a number of years apart and at different locations. The UBW-137
sample collected in 2002 was collected approximately 150 feet further down stream than the
RI sample was collected in 1987. The underlying premise inferred in this paragraph for the
change in concentration of 1,2-dichloroethane between these two samples, I 1,000 pg/I
(1987) and 710 pg/I (2002) is the groundwater extraction system in the Front Valley. How
much of this decrease can be attributable to volatilization from the stream over this span_ of
150 feet?
21. Page 40, Section 8.1.3 Evaluation of Remedial Performance, 'first bullet)! would be helpful
if the text in this bullet also compared these concentrations to the concentrations of these
contaminants in the influent at start-up in January 1993._
22. Page 40, Section 8.1.3 Evaluation of Remedial Performance, last bullet: Please include the
beginning and ending dates for the timeframe when this mass of contaminants was removed.
• 4 •
23. Page 41, Section'8.2. I Evaluation of Hydraulic Performance: Refer to comment number 18
above and comment number 32 below.
24. Page 41, Section 8.2.1 Evaluation of Hydraulic Performance, third bullet: This bullet
mentions the surficial aquifer but there is no discussion on either the transition zone or the
bedrock aquifer. ·1n Piedmont geology, where is the greatest amount oflateral groundwater
flow, the surficial.(saprolite) aquifer (zone), the transition zone, or in the bedrock aquifer?
25. Page 42, Section 8.2.2 Evaluation of Contaminant Concentration and Distribution, second to
last bullet: Refer to comment 20 about the difference in concentrations between the two
surface water samples:
26. Page 42, Section 8.2.2 Evaluation of Contaminant Concentration and Distribution, last
bullet: ls the toxicity of methyl-tert-butyl-ether such that we should be paying closer •
attention to the presence of this contaminant?
27. Page 42, Section 8.2.3 Evaluation of Remedial Performance, first bullet: Please add the
beginning and ending date for the term "reporting period".
28. Page 44, Section 9 Conclusions, first paragraph, first sentence: This sentence states,
" ... treatment systems and institutional controls were installed". Please delete the reference
to "institutional controls" as this term was used in a very generic sense in the Record of
Decision (ROD). The ROD did not require any specific institutional control(s).
29. Page 44, Section 9 Conclusions, second paragraph: This paragraph leaves the impression that
the 199 l design was inadequate in its scope.
30. Page 44, Section 9.1 Site Wide Discussion, first bullet: The caps.had two primary purposes.
One purpose, as highlighted in 'this bullet, was to reduce risk to exposure to impacted soils.
The second goal of the caps was to protect the underlying aquifer. Any thoughts/conclusions
on the caps protecting the underlying groundwater? Have the caps prevented precipitation
from percolating through the soil/waste and carrying contamination into the aquifer? The
construction of the caps was completed in 1993, has there been a decrease in contaminant
concentration in monitoring wells immediately downgradient of the capped areas?
31. Page 44, Section 9.1 Site Wide Discussion, second bullet: The effort discussed in this bullet
could also demonstrate that offsite migration is occurring. Can an anticipate date for ·
completing a 'report based on this sampling effort be incorporated into this bullet?
32. Page46, Section l O Recommendation: Conduct a through capture zone analysis for both the
Front and Back Valley groundwater extractions systems. A systematic.approach for capture
zone analysis is highlighted below:
Step l: Review site data, site conceptual model, and remedy objectives
Step 2: Define site-specific target capture zone(s)
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Step 3: Interpret water levels
► Potentiometric surface maps
► Water level pairs (gradient control points)
Step 4: Perform calculations (as appropriate based on site complexity)
► Flow budget ·calculation
► Capture zone width calculation ( can include drawdown calculation)
► Modeling (analytical and/or numerical) to simulate heads, in conjunction
with particle tracking and/or transport modeling
Step 5: Evaluate concentration trends (and potentially tracer tests)
Step 6: Interpret actual capture based on steps I to 5, compare to target capture zone(s),
assess uncertainties and data gaps.
The following is a list of references/guidances:
• "Elements for Effective Management of Operating Pump and Treat Systems,"
November 2002, OSWER 9355.4-27FSA.
• "Methods for Monitoring Pump-and-Treat Performances," June 1994. ORD
Publication EP N600/R-94/l 23, NTIS Order Number PB95-I 25456.
• "Design Guidelines for Conventional Pump-and-Treat Systems," September
1997. ORD and OS WER joint publication EP A/540/S-97 /504, EP A-68-C4-003 l,
NTIS Order Number PB98-l 15389INZ, 44p.
• "Pump-and-Treat Ground-Water Remediation: A guide for Decision Makers and
Practitioners'" July 1996. ORD Publication EPA/625/R-95/005, NTIS Order
Number PB97-154009, 74p.
These documents are available at
http://www.epa.gov/superfund/resources/gewdocs/pum tre.htm
33 Figure I IA: Typo, title ofX axis should read, "Date (yyyy)".
34. Table 2A: If feasible, a groundwater elevation prior to start-up of the groundwater extraction
systems should be included for each well listed in this table.
35. Table 7: The terminology in the last column, '·'Above" and "Below" is very vague. Can
these terms be defined as footnotes? ·
36. Table 7: The number "0.065" under column titled "2004" is in bold type. Is this a typo?
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If you have any questions, please feel to call me at 404-562-8820.
Sincerely,
Jon K. Bornholm
. Remedial Project Manager
Enclosure (I):
I. C01_nments from NCDENR (September 14, 2007)
cc: Beth Hartzell, NCDENR
.(: r,r..., •.
------&§;A---·~--------··---~ --------·-· -·--· -
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director Division of Waste Management Michael F. Easley. Governor
Mr. Jon K. Bomholm
Remedial Project Manager
USEPA
6 I Forsyth Street, SW
Atlanta, GA 30303-3104
William G. Ross Jr., Secretary
September 14, 2007
SUBJ: Comments on the CERCLA Remediation System Performance Evaluation for the
Chemtronics Superfund Site, Swannanoa, Buncombe County, North Carolina
Dear Mr. Bomholm:
The North Carolina Division of Waste Management's Superfund Section has reviewed the CERCLA
Remediation System Performance Evaluation and the draft comments prepared by the EPA. The Superfund
Section has the following additional comments:
I. Page 11, Section 2.2 Ground Water Extraction Flow Rates: How do the lower pumping rates and their
influence on the hydraulic gradient affect the effectiveness of the treatment system?
2. Page 20, Groundwater Extraction Flow Rates: Refer to comment I.
3. Page 27, Section 5.2 Treatment System and Extraction Wells, last paragraph: Include a copy of the letter
sent to the Metropolitan Sewerage District and the memo from ENVIRON Corporation explaining the
significance of the perchlorate detections.
4. Page 33,Section 6.2.1.3 Discharge Line Replacement: Some of the soil samples collected in the area of
the old discharge line detected VOCs at levels higher than the NC Soil Screening Levels. These areas
should be addressed.
5, Page 42, Section 8.2.2 Evaluation of Contaminant Concentration and Distribution: The NC 21 standard
for methyl-tert-butyl-ether is 200 ug/L This is well below the levels (3000ug/l) found in the ground
water samples. Did the effluent samples show detections ofMTBE? lfso, at what levels?
If you have any questions call me at [phone]·or email me at [e-mail].
Sincerely,
Elizabeth A. Hartzell
Cc: Jon Bornholm, USEPA
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] \ FAX [phone] \ Internet hrtp://wasienotnc.org
An Equal Opportunitf ! ?.llirmative Action Employer-Printed on Dua! Purpose Recycled Paper
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4WD-NSMB
Mr. Thomas Wolfe
46 Haywood Street
Suite 212
SAM NUNN ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
December 16, 2002
Asheville, North Carolina 28801
DEC 1 8 2002
-,--: ' . ' ... ,
I! l) , ' 1
SUBJ: Figures Showing Location of Groundwater Monitoring Locations, Contaminants
Detected In Groundwater, Location of Surface Water Monitoring Locations,
Contaminants Detected In Surface Water at the Chemtronics Superfund Site,
Swannanoa, North Carolina
Dear Mr. Wolfe:
Enclosed is the information you requested. The enclosed figures are from the document
entitled, "Phase II Site Investigation Report", dated May 31, 2002. Figure 2, titled "General Site
Features", identifies the Front and Back Valleys, the capped disposal areas, and the surface
streams. Figure 3, titled "Front Valley Details", shows the location of the two Superfund related
disposal areas (DA I 0/ 11 _and DA 23) and t_h~_ lCJi::a_t_ipl}_Qf the grou(ld,water,monitoring wells.and
surface water iiarri'pl'i'n'i(poirii's'in th~ F~~~t Valley: The following defines the acronyms used in
these figures:
SW a saprolite groundwater monitoring well (shallow well)
1W an intermediate depth groundwater monitoring well
BW a bedrock groundwater monitoring well
MW a groundwater monitoring well
OW a deep groundwater monitoring well
P piezometer
Figure 11, titled "Locations of Permanent Wells Installed During the Phase·n SI", is self
explanatory. Figure 14A, titled "Baseline VOC Data Front Valley Monitoring Wells and
Piezometers", lists the concentrations of the volatile organic contaminants (VOCs) detected is
each well in the Front Valley. Figure 14B, titled "Baseline VOC Data Front Valley Surface
Water", lists the concentrations of the volatile organic contaminants detected at each surface
water sampling location in the Front Valley. The contaminants listed in Figures 14A and 14B are
the types of contaminants you should have a groundwater sample from your well analyzed for.
• • 2
If you have any questions, please call me at 404-562-8820 or 1-800-435-9233 (X-28820).
Sincerely,
(______.-----
Remedial Project Manager
Enclosures (5)
cc: David Mattison (NCDENR w/o encl)
Mr. Jon K. Bornholm, Proj. Mgr.
U.S.E.P.A.
Region IV
345 Courtland St., N.E.
Atlanta, GA 30363
NIMMO & CO.
Consultants
P.O. Box 536
Swannanoa, NC 28778
[phone]
Re: Chemtronics CERCLA Site 2nd Arnrnal
Groundwater Extraction System Repo11
Dear Jon:
• ~ r-i r-.., 11fr .
JUN 211995 n
~!..::, .. , I.J i..'.;i u
IPA -.RlCillON IV
ATLANTA,QA
23June 1995
JFS-099-95
Enclosed are three (3) copies of the referenced report. I wish to point out that this
report only covers a nine (9) month period, as per our discussion in April. By only doing
nine (9) months, the 1995 repoll of activities will encompass a whole year from Janua1y
through December.
In preparing this repo11 the engineering group, Rust Environment & Infrastrncture,
the PRP's and the PRP Coordinator utilized the comments received on the first repo11 as a
guideline in preparing and reviewing this repoll prior to submission. It is hoped that we
have addressed all of EPA's concerns in an appropriate manner. If you have any questions
or comments, please contact me
cc: Steering Comminee w/enc.
Terry Standridge, Rust E&I
file
• UNITED.STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA, GEORGIA 30365
July 10, 1995
4WD-NSRB
Mr. Jack Butler
North Carolina Department of Environment,
Health and Natural Resources
Suite 150
401 Oberlin Road
Raleigh, North Carolina 27605
JUL 13 1995
SUPERFUND SECTION
SUBJ: Request to Review June 1995 Annual Report -Second Year
Monitoring -Chemtronics Site Remediation Groundwater
Extraction System
Dear Mr. Butler:
Enclosed for your review and for the State's file is a copy
of the above referenced document. This document communicates the
Potentially Responsible Parties' evaluation of the hydraulic
performance of the groundwater extraction systems installed in
the Front Valley and Back Valley at the Chemtronics Site after
one year of operation. Both the groundwater extraction and
treatment systems were deemed to be on-line in February 1993.
I . Section 2. 7 PERFORMANCE EVALUATION AND TRIGGER MECHANISM of the
December 1994 "Operation land Maintenance Manual" specifies the
timeframe for conducting performance evaluations and the type of
data to be used to assess the hydraulic performance of the
extraction systems. Below summarizes this Section.
Three types of data (extraction flow rate, groundwater
level, and climatic) are to be used to evaluate the hydraulic
performance of the extraction systems. Hydrographs of the water
levels' in the monitoring wells are to be plotted. Each plot is
to include monthly average precipitation and the depth to
groundwater versus time., This should enable an evaluation of the
aquifer's response to climatic changes. Graphs of the discharge
rates versus time will be plotted along with average rainfall.
The objective of these plots is to evaluate the need for periodic
adjustments to flow rates depending upon climatic changes.
The water-level data is to be converted to elevations and
potentiometric maps. These maps will allow an evaluation of
groundwater flow patterns in the subsurface as well as present
the development of the capture zones. The total amount of water
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pumped is to be reported as well as the cumulative discharge from
each extraction well. This data is to be reported in table form
as is the precipitation data.
Specific capacity data is to be used to evaluate the
condition of the extraction wells. This evaluation is to include
plots and graphs, plotted as a function of time, that will allow
an independent assessment of the groundwater extraction systems.
If an abrupt decrease in specific capacity occurs or a decline
greater than expected which cannot be explained by climatic or
other data, then the well should be evaluated for rehabilitation.
The effectiveness of the remedial action is to be evaluated
by interpreting water quality data. Isopleth maps are to be
developed for each contaminant of concern. This information will
be used to model contaminant transport within the aquifers and to
evaluate changes that occurred between performance evaluations.
Concentration versus time curves are also to be developed for
each contaminant at each'monitoring point. These curves will be
used to evaluate changes and estimate when the concentrations
will reach the remediation levels.
i The water quality data will also be reported in table form.
The average concentration for each parameter will be calculated.
The statistical approachiis described in Section 2.7.2 EVALUATION
OF CONTAMINATION CONCENTRATION AND DISTRIBUTION of the December 1994
"Operation and Maintenance Manual".
I ,
Please review the above referenced document. I would
appreciate receiving the:state's comments by Wednesday, August 9,
1995. If you are unable Ito meet this due date or have any
questions, please call mJ at [phone], x-2053.
Sincerely yours,
-r t 6aJ (___,/.
Jon K. Bornholm
Remedial Project Manager
Enclosure
State of North calna
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
Jcfmes B. Hunt, Jr .. Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
23 August 1995
Mr. Jon Bornholm
EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
• _&;'A
DEHNR
Subject: Chemtronics, Inc. (NCD 095 459 392)
Swannanoa, Buncombe County
Dear Mr. Bornholm:
The North Carolina Superfund Section has received and reviewed the Superfund Preliminary
Site Close Out Report dated August 18, 1995, for the subject site. Although the state of North
Carolina agrees as stated in this report that all equipment specified in the Remedial Design has been
installed, it is not ready at this time to declare that this system is operational and functional as
indicated in the last line of Section 5.0 -Activities and Schedule for Site Completion. Before such
an "Operational and Functional" determination can be made, our office would as a minimum like to
see evidence that the problems with sludge build up in the air stripper and grounding problems have
been corrected.
The North Carolina Superfund Section appreciates the opportunity to review this document.
If you have any questions or would like to discuss our comments please contact me at (919) 733-
2801 ext. 286.
Sincerely,
~~
Jack Butler, P.E.
Environmental Engineering Supervisor
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
.. • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
NOV 12 1993
4WD-NCRS
Mr. John Schultheis
Nimmo & co.
P.O. Box 536
Swannanoa, NC 28778
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
RE: summary of the Final Inspection of the(Remedial_Action'lat the Chemtronics superfund Site
Dear Mr. Schultheis:
The Final Inspection of the Remedial Action· (RA) at the Chemtronics Superfund site located in Swallnanoa, North Carolina was conducted on Tuesday, June 22, 1993. The following individuals participated in the Final Inspection.· They are listed alphabetically below along with their affiliation to th_e Site:
Jon Bornholm
Randy McElveen
Bruce Nicholson
John O'Toole
John Schultheis
Terry Standridge
USEPA, Remedial Project Manager NCDEHNR
NCDEHNR
Canonie, RA Contractor
Nimmo & Co., PRP·Coordinator
RUST Environment & Infrastructure, RA Oversight Contractor
The Final Inspection was a follow-up to the February 16, 1993 Pre-Final Inspection. The Agency's Pre-Final Inspection report was sent· to you in a correspondence dated March 4, 1993. Below is a summary of the March 1993 PreL Final Inspection report.
Access to the all disposal areas were controlled by chain-linked fences and secured (locked) gates.
DISPOSAL AREA f6 No visible erosion of cap or toe slopes. Vegetativ~ cover _on cap and slopes well ·established, healthy, and thick.
DISPOSAL AREA #7/8 No visible eras.ion of cap or· toe slopes. Several areas of the cap had sparse to no grass.
DISPOSAL AREA f9. No noticeable erosion of cap or toe slopes. Vegetative cover was thick and healthy except for in the northwest corner of the cap.
ACID PIT AREA Cap had notable erosion, severe in some areas with gullies reaching a depth 5-6 inches. Majority of vegetative cover was sparse.
DISPOSAL AREA fl0/11 . Some erosion was noted in areas of the cap. The vegetative cover ranged from good to non-existent. The worst erosion associated with this area occurred outside of the fenced area, upgradient of the cap.
DISPOSAL AREA f23 (Biolagoon) Vegetative cover of the· cap and gate where it was sparse.
Minimal erosion was observed in the cap. slopes was well established except near the
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II • •
FRONT VALLEY GROUNDWATER EXTRACTIONS AND TREATMENT SYSTEMS Both systems have undergone shakedown and were operational. appear to be working well.
BACK VALLEY GROUNDWATER EXTRACTION AND TREATHBNT SYSTEMS Both systems have undergone shakedo0, and were operational. ~ppear to.be working well.
All systems
All systems
Below is the Agency• s summary of the June 22, 1993 Final Inspection of the RA and the corrective work performed between the Pre-Final Inspection and the Final Inspection.
DISPOSAL AREA #6 No visible erosion of cap or toe slopes. Vegetative cover of the cap and slopes well established, healthy, and thick.
DISPOSAL AREA #7/8 No visible erosion of cap or toe slopes. Some areas of the cap still had sparse grass growth/cover.
DISPOSAL AREA 19 No visible erosion of cap or toe slopes. Vegetative cover of the.cap and slopes well established, healthy, and thick.
ACID PIT AREA Gullies/erosion have been repaired, however, the grass seed sown in the areas restored had not germinated. Parts of cap still had sparse grass growth/cover.
DISPOSAL AREA #10/11 Erosion outside of fenced area upgradient of cap repaired. Areas inside fenced area where growth/cover of grass was noted sparse to non-existing remains the same.
DISPOSAL AREA #23 (Biolagoon) Gullies/erosion have been repaired, however, the grass seed sown in the areas repaired had not germinated. Other parts of cap are in good condition.
FRONT VALLEY GROUNDWATER EXTRACTIONS AND TREATMENT SYSTEMS operating well. Pumps in extraction wells will need periodically.
Both systems are
to be cleaned
BACK· VALLEY GROUNDWATER EXTRACTION AND TREATMENT SYSTEMS Both systems are operating well. Packing in air str_ipper had been washed.
Pending the.germination of the grass seed dispersed on the caps, the RA at the Cherntronics site appears to be posed to move into the operational and maintenance phase of the RA process. Verification that the vegetative cover on the caps noted above will need to be made in late spring/early summer time frame of 1994. -This •will give the grass seed sufficient time to germinate and become established. If the vegetative covers are not well established (i.e., healthy and thick), then additional work on the cap covers may be required.
If you have any questions, please feel free to call me at [phone].
sincerely yours,
/#x:~~
Jon K. Bornholm
Remedial Project Manager
' Enclosure
cc: Bruce Nicholson, NCDEHNR
Terry Standridge, RUST
I I • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
MAR 5 1993
4WD-NCRS
Mr. John Schultheis
Nimmo & Co.
P.O. Box 536
swannanoa, NC 28778
345 COURTLAND STREET. N.E.
ATLAN,:A. GEORGIA 30365
Htt;te.i\VtU
MAR O 9 ll_J:; .,
SUPERRIND SECTION
RE: summary of the Pre-Final Inspection of the Remedial Action
at the Chemtronics superfund site
Dear Mr. Schultheis:
The Pre-Final Inspection of the Remedial Action (RA) at the Chemtronics Superfund
site located in swannanoa, North Carolina was conducted on Tuesday, February 16,
1993. The following individuals participated in the Pre-Final Inspection. These
individuals are listed below alphabetically along with their affiliation to the
Site:
Jon Bornholm
.Jack Butler
Rick Hardy
Randy McElveen
John O'Toole
John Schultheis
Terry Standridge
chuck Travis
USEPA, Remedial Project Manager
NCDEHNR
CDM/FPC, EPA Oversight Contractor
NCDEHNR
Canonie, RA Contractor
Nimmo & co., PRP coordinator
RUST Environment & Infrastructure, RA oversight
contractor
RUST Environment & Infrastructure, RA Oversight
Contractor
Prior to the Pre-Final Inspection, the Agency shared with you, Terry Standridge,
and the state of North Carolina Department of Environment, Health, & Natural
Resources (NCDEHNR) copies of the check list the Agency would employ during the
Pre-Final Inspection.
The Pre-Final Inspection commenced at approximately 1:00 pm on February 16, 1993
and was completed early that evening. The Pre-Final Inspection encompassed
walking over and inspecting the multi-layered caps at Disposal Areas 6, 7/8, 9,
10/11, 23, and the Acid Pit Area, surveying the extraction wells, monitoring
wells, and piezometers and their locations in both the Front and Back valleys,
an examination of the treatment systems housed in treatment buildings in both
valleys, and the metering manhole and sampling and metering equipment for
discharge into the Metropolitan sewer District (MSD) system.
The Agency and the representatives from NCDEHNR compared notes and conversed
briefly on defects observed prior to departing from the Site. The items
identified by both the State and the Agency as components that need to be
addressed, preferably, prior to conducting the Final Inspection are discussed
briefly below and listed on the enclosed Punch List. Once all of the components
on the Punch List are adequately addressed, the Agency will be in a position to
specify that the construction of the RA is complete and that the site is
considered into "Long-Term Remedial Action".
Printed on Recycled P.1per
• •
-2-
During the Agency's previous visit to the Site on January 4-6, 1993, the location
of the former On-site Pond on the unnamed stream in the Front Valley and the
bioassay sampling points were observed. Following a review of the analytical
data for sediment and water column samples collected from the on-site Pond, the
dike creating the pond was breached in accordance to the approved Remedial Design
(RD). The pond was drained and earthwork was done to ensure that the stream does
not pond there in the future. The bioassay sampling points are appropriately
located and tests are conducted on samples collected from these points as
specified in the document entitled "Baseline Biomonitoring study" dated March
1991. The bioassay baseline will be used to evaluate the effectiveness of the
Site remediation.
Summary of the Pre Final Inspection
The Agency is pleased to report that only a minimal number of defects were
observed and that the magnitude of the defects detected were diminutive. Please
refer to the enclosed Punch List for a succinct list of corrective actions that
need to be implemented. Below is a summary of the Pre-Final inspectio.n:
Disposal Area #6
No visible· erosion or gullies were observed in either the cap covering
Disposal Area #6 (DA-6) or in the toe slopes surrounding the cap. The
vegetative cover ( the grass) of the cap and slopes appear to be well
established, healthy, and thick. Access to the DA-6 and the cap are
controlled by the chain-linked fence and secured (locked) gate.
Disposal Area #7/8
No noticeable erosion or gullies were observed in either the cap or
surrounding toe slopes. The swale along the western edge of DA-7/8 appears
to functioning appropriately. However, several areas of the cap have
sparse grass cover or very little to no grass. The middle section of the
cap towards the western side of the cap had a sparse cover of grass while
the northwest corner of the cap had very little to no grass. If the seed
in these areas does not germinate in the upcoming spring, then additional
seeding of these areas will be necessary to prevent erosion of the cap.
Access to the DA-7/8 and the cap are controlled by the chain-linked fence
and secured gate.
Disposal Area #9
No noticeable erosion or gullies were observed in either the cap or
surrounding toe slopes. For the most part, the grass cover is thick and
healthy except for in the northwest corner of the cap. In this corner, the
grass cover is sparse. If the seed in this area does not germinate in the
upcoming Spring, then additional grass seed may need to be sowed in this
area to prevent erosion of the cap. Access to the DA-9 and the cap are
controlled by the chain-linked fence and secured gate.
Acid Pit Area
Of all the caps inspected in both the Front and Back Valleys, the Acid Pit
Area cap had the most wide spread and sever erosion. A primary culprit is
the fact that this was one of the last areas to be seeded. Numerous
• •
-3-
gullies and areas where erosion have occurred can be found across the cap.
The northeast end of the cap appears to have the thickest grass cover.
Some earth work will be needed to repair this cap. The depth of the
erosion and gullies did not extend more than 5-6 inches. In addition to
repairing the eroded areas and the gullies, parts of the cap may also need
to be reseeded. A better evaluation of what areas will need to be reseeded
can be made after cap repair activities are complete. The swales along the
north-northwest edge and the southwest edge of the Acid Pit Area appear to
be functioning appropriately. Some corrective action has been performed on
the toe forming the southeast boundary of the Acid Pit cap. This area
needs to be monitored during and after repairs to the cap itself to insure
this tow is not eroding. Access to the Acid Pit Area and the cap are
controlled by the chain-linked fence and secured gate.
Disposal Area #10/11
Overall, the cap appears to be in good condition especially in light of the
steep terrain in this area of the site. Minor gullies were observed in the
southwest arid southern portions of the cap. Some erosion has occurred in
the northern and northeastern portion of the cap where the erosion control
matts were anchored. No grass was observed underneath a portion of the
northern security fence. The central portion of the cap had a sparse grass
cover. If the seed in these areas do not germinate in the upcoming Spring,
then additional seeding will be necessary in these areas to prevent
erosion. The erosion where the erosion control rnatts are anchored also
needs to be repaired.
The worst erosion associated with DA-10/11 is occurring outside of the
fenced cap, in the swale west of the cap. The gully formed here is at
least a foot in depth and is leading to significant amounts of sediment
being transported downhill. This area and the areas identified above need
to be rectified. Access to DA-10/11 and the cap are controlled by the
chain-linked fence and secured gate.
Disposal Area #23 (Biolagoon)
Overall, the cap appears to be in good condition. Some minor gullies were
observed in the southern central portion of the cap, however, no erosion
was observed. The vegetative cover of the cap and slopes is well
established, healthy, and thick except for the area near the gate. In this
area, the growth of the grass is sparse. This area may need to be reseeded
if the seed does not germinate more substantially this Spring. The swale
along the eastern edge of the disposal area appears to be functioning
appropriately. Access to the DA-23 and the cap are controlled by the
chain-linked fence and secured gate.
Front Valley Groundwater Extraction and Treatment systems
The groundwater extraction system and treatment system in the Front Valley
have undergone shakedown and have been operating for approximately one
month. All systems are working well. Only after additional groundwater
data is collected, will sufficient data be available to determine if the
groundwater extraction ·system is capturing the plume. The treatment system
appears to.performing as designed.
• •
-4-
The treatment system is treating more groundwater than being extracted from
the aquifer, therefore the treatment system is cycling on and off based on
the water level in the equalization tank.
Back Valley Groundwater Extraction and Treatment systems
The groundwater extraction system and treatment systems in the Back Valley
have undergone shakedown and have been operating for approximately one
month. All systems are working well, Due to the low pH in the groundwater
emanating from extraction well EW-2, the computer control program is being
modified to have EW-2 cycle on and off every 10 minutes. This will prevent
the pH adjusting system from being overburdened. The flow rate from some
of the other extraction wells are still being adjusted to reduce the
frequency they cycle on and off.
Presently, insufficient data is available to determine if the groundwater
extraction system is capturing the entire plume, The treatment system
appears to performing as designed as long as extraction well EW-2 is
throttled ba_ck. Additional data is being collected to allow an in-depth
evaluation of the extraction system to ensure that the plume is being
captured by the extraction system.
As in the Front Valley, the Back Valley treatment system is treating more
groundwater than being extracted from the aquifer, therefore the treatment
system is cycling-on and off based on the water level in the equalization
tank. In the event additional extraction wells are needed in either valley
to extend the capture zone, the present treatment systems have sufficient
capacity and therefore, neither system will not need to be modified to
handle the additional flow.
In synopsis, the caps and their surrounding toe slopes appear to be in good
condition, accept where noted above, especially in light of the adverse weather
conditions experienced this Winter. Additional groundwater monitoring data is
essential in order to evaluate the groundwater extraction systems in the Front
and Back Valleys and determine their effectiveness in capturing the plumes in the
perspective valleys.
The only other concern the Agency has at this time is the rationale used to
select the monitoring wells to monitor the quality of the groundwater in both
valleys. The original list of monitoring wells to be monitored was developed
prior to the drilling of the extraction wells. The list needs to be revised
based of the additional information obtained during the installation of the
extraction wells, piezometers, and additional monitoring wells. In particular,.
the Agency has some concern with the depth and degree to which contamination was
found in the groundwater at location EW-2. The Agency is currently evaluating
the data and may require monitoring wells IW-3 and BW-12 be added to the list of
monitoring wells to be monitored.
As stated previously, it is the desire of the Agency that the identified defects
be corrected prior to the Final Inspection. However, the Agency is well aware
that good weather is a prerequisite prior to bringing any heavy equipment on to
the caps to initiate the repairs.
Based on our telephone conversation on March 3, 1993, RUST Environment &
Infrastructure, is tentatively planning to submit to the Agency on behalf of the
Potentially Responsible Parties for review, the Pre-Final Inspection Report and
Preliminary Closeout Report on March 15, 1993. The preparation and submittal of
the Pre-Final Inspection Report is described in section 4. 3 (paragraph #3 on page
37) of the approved August 1989 Remedial Design/Remedial Action work Plan.
• •
-5-
currently, the Final Inspection is scheduled for Tuesday, March 23, 1993. This
will remain the date unless extenuating circumstances arise between now and then
and require a change in the date.
For your information, I received a copy of the draft "Start-Up Operation &
Maintenance Plan", dated February 1993, on March 2, 1993. This document has been
disseminated to CDM/FPC, EPA HQ -Office of Emergency & Remedial Response,
Division of Hazardous Site Control (OERR/HSCD), and NCDEHNR for review and
comments.
If you have any questions, please feel free to call me at [phone].
Sincerely yours,
~· l:!.~~m
Remedial Project Manager
Enclosure
cc: Jack Butler' NCDEHNR
Rick Hardy, CDM/FPC
Randy McElveen, NCDEHNR
Terry Standridge, RUST Environment & Infrastructure
I
• •
PUNCH LIST
Based on February 16, 1993 Inspection
of the Remedial Action Implemented
at the chemtronics superfund site
Swannanoa, Buncombe county, North Carolina
AREA I CORRECTIVE ACTION TO BE TAKEN
DA-6 None
DA-7/8 If needed, reseed areas where grass growth is
sparse or absent
DA-9 If needed, reseed areas where grass growth is
sparse or absent
Acid Pit Area Repair eroded areas and gullies, reseed where
necessary
DA-10/11 Repair eroded areas and gullies inside and
outside fenced area, reseed where necessary
DA-23 Fill in gullies and reseed where appropriate
Front Valley Groundwater collection of additional data to allow a more
Extraction System in-depth evaluation of capture zone
Front Valley Groundwater None
Treatment system
Back valley Groundwater Collection of additional data to allow a more
Extraction system in-depth evaluation of capture zone
Back Valley Groundwater None
Treatment system
Metering Man-Hole and None
Associated Equipment
Selection of Monitoring Evaluate data collected during Remedial Action
Wells to be Monitored construction to assess deletion/addition of
monitoring wells from groundwater monitoring
strategy
on-site Pond None
Bioassay Monitoring Continue monitoring until based on the Final
Operation and Maintenance Plan (to be approved)
I
ITEM
Average Common Fill Thickness
Average Pirat Select Fill
Thickness
BPDE Liner
Composite Drainage Layer
Toe Drain Construction
Toe Drain Out Fall
Average Second Select Fill Thie knee a
Average Topsoil Layer Thickness
Vegetation Cover
Vertical HPDE Liner aa Biotic Barrier
Average Grade of Cap
Graded ta control surface Runoff+
Eroeion
Erosion of Cap
Erosion Anywhere Else
20 ili ·•· :·
•···.·.
settlement Makara Present
f of Settlement Makara
•
CHEMTRONICS SUPERFUND SITP!
PRB-PIIIAL IHSPRC'TIOB
February 16, 1993
· PUNCH LIST FOR DISPOSAL AREA t_Q_ CAP
Thickneea Paea/ Comments
(inches) Fail
~,\ n I I
17 -/ )_
12 11
N/A ' i
:
N/A
' N/A i
'
' ~--N/A
,\--, .s 1~ \"<., I,____
'>v'f {,, "
N/A (sffcfY:~ -~L
N/A i p~·
: fl,t--l.J.\... .,.1.~
N/A i
\
N/A \v
N/A ~~> ~r,1\1... ~n,,~·
&~> N,...i-r'"' "'"i N/A
m . ··. ··•· •• ·•·
N/A lu~
N/A 3
t-kuc\{L.1
I
Qi ..
•
----------1----
x:t"~ I -------... __ _
• •
ITEM Thicknen Pa1111/ · Comments
(inche11) Fail
Are Settlement Makera Surveyed In? N/A 0,J
(Date)
t?t<tX/\ .,,, .. , ... , .. ;;-.··· .:.,,,,._,,, == · .. -... ::. ' ·::·.-:::,:":':' .-.-,:·:: •·-•··•·· <--••·•••··· \i•.t ·-·•. ·.·
·····
.. _ .. .... ····>·:· . I/<• ·••· . . .. .. .. :·:=::._,._, •,•,•, ••·· ·••·· ......
Installation of Gaa Vents in Cap N/A Iv 1/f
Number of Gaa Vanta Inatalled N/A /v/A
·-•·· \/:.:,_,-:,. ·:·:·· ·:-·-.:-:-· {•:•·:.·-.... :=:·=:::=··-~:)::-:,,<}{·(.:.;, 32••·•··· . •···· ... . .. , ... ,.:;::--::·--::,•··::•,-:::::::·-::-::·:· •·• ·•• ··• ... ••·• .
Installation of Security Fence N/A ~__)
Gate Installed N/A v wJ
v
Gate Secured? N/A '-'2,,_3
:,'.:.:: ::,_.: :,,_:-:filf1ii2t·:::-:., -: '. ··•·. ··•· §ill :::: 1.,:-:_-,:::,:,.,::,,,::::-,:::-: •i-······ ·····••······• .. .•··•·· ~ ·•· j ··••····· •••••• ...
Slope of North Toe of Cap N/A -------1 ,_ ~
~ . Slope of Ea.at Toe of Cap N/A ,. ,o
Slope of south Toe of Cap N/A ~~
:,..c,
slope of Weat Toe of Cap N/A =i I
2o
~ ·•
-~
... ./. ~ .-... ~ _._( •·-.···•··· •·•• ·····••·• ..... 1:.'.::::·.·.:_:\ ,,:-.:-:-.::-:,:::::,,::•--,•,:.•,
Swale(e) Conetructed? N/A ~lo 10-f~-
Swale Working Aa Designed? N/A
Any Erosion of Swale? N/A
COMMENTS· or
CHEMTBCNJCS 12 DISK wp FIIP! P-FIHSPC DRAFT 2/JQ/93 FINAi 2/16/93
•
ITEM
Average Common Pill Thickness
Average First Select Pill Thickness
HPDE Liner
Composite Drainage Layer
Toe Drain Construction
Too Drain Out Pall
.
Average Second Select Pill Thickness
Average Topaoil Layer Thickneoa
Vegetation Cover
Vertical HPDE Liner aa Biotic Barrier
Average Grade of Cap
Graded to Control surface Runoff+ Erosion
Erosion of Cap
Erosion Anywhere Else
•••••• .·.·· ·••··· ··•···
Settlement Makers Present
f of Settlement Makara
Kk
•
CHEHTRONICS SUPERFUND SITE
PRK-FDiAL IBSPBCTIOB
PUNCH
February 16, 1993 / /o
LIST FOR DISPOSAL AREA t-l-(-f:7CAP
Thickness Paaa/ Comments -
{inchea) Pail
~(.J ,ti, ;. (
<l'\'c'' ,tu ~-~ (J .. ,.i~-)
r,-..,. d.,L ch,_,:""' U) r-0 t-(4 v\-,; ..:)1'\ a!>
~: "-"' \.-l'\U >)
'~
V61\[: {: cL. _\ • ' 0 \o 't!_r r ,t.,i.. .........
NIA o+-~ '--0"-<:\
N/A
N/A
-,?tk, ' s~l"'-\:,., "L N/A I "!V •r
• ~ I I _.,,. (<> ~
--:vly (. "
Pv l,, o+ VI' ct' C,,QV\rt,J_ V..J:'J\.__ ~(.,.\..
N/A IA..-,,,.,~~• r "" r .J ~,a1,~ c_.,,yq. r 0.' Q.,. ~ ~L~ , . y--«) \ e. I f"-< ,-,___ c_e-.,·(!_ .-~-V\,,
N/A .11 ~k{-....\-... " ~ I,,.. ~t... -... c.1,-,:., '=
N/A ..-------------1 ti)'
' 7.-.;i •
N/A 'ct, >
) orvt t\lo a<-&§{ .'.l ,r. or 'j,.dw-1
N/A
wt,e..-o\,_s,,,,i .\..
N/A Rt~
l••·••••••••·••·••<••·•··:I••••
.
·.····•··~ ... i f •• ·'
N/A lee;,
N/A -3
• • •
1276
. s 1tf ~ /0 '<-;
~-J}/1 l "-..
I
\
\
•• •
·--
ITEM Thickne88 Paea/ Comments
(inches) Fail
Are Settlement Makers Surveyed In7 NIA t> (Date)
1,.::::··,· ,::.' -.:,:•-::·:·:,;.;:_.::::,:,.::_:,::•=•==-~ ... ·.· ) ·.·•·•· ..... ... . ··•····•·· ·'\·:•. .. :J,· .. . · .. .... · ..... .. . ...
Installation of Gas Vents in Cap NIA } j 'I'&/
Number of Gae Vents Installed NIA I Jnn·1-/
rn ·.·.,· ..... ·· .. · ··.· · ... · .... •···· c . ·. ·•· .. .•.·· . •.> r < ·: /(:)/)( ·:r::<:-? \_, ,:, •,-,' :-·:,::: : ,,,,, .. ,,•.:.::_;:,_.:::·:·,.,:,::-:):: .,,;, .... ·. • ... ... .. •·•• · .... .. . .
Installation of Security Fence NIA res
Gate Installed NIA ti
Gate Secured? NIA \ \
.... :;·:·:,:·=·•:: . ._._. ·: .. · · ... --~-.... < ::::;:::•:·::·:·•:.-::,:,: .. :,:-,:,::.i?\:\._ .. , :·,., . ..
·•
.... ••· .. <Vi• ••·
'rt•O-.. I J-uJ~I, No ti, .. ,v...r J.Jw u,......,...-
Slope of North Toe of Cap NIA I /uG-_ ,Vt: c.., ( l\.i r
·-
Slope of East Toe of Cap NIA ;)/~
. '
Vi. '.,.\\y .,..,~ e.,..')_,,1.-t'I\.\
Slope of South Toe of Cap NIA
Slope of West Toe of Cap NIA
:·:~,>---
.... ...,..., ........... •• ~ ··•· .... ~ .... 2 ~ · .... . -:-:::-:_:,:,:o, .. _.,,;, . ......
') ··-"' · . .,._ wMt-<'M-...A_ <>"' w%+-s:l,... ti,
Swale(s) Constructed? NIA ~&liJ C (v.,w'\O~ f,,-.;.-. ,. ...,_..>.,.:. "\-CAf· 1-;r-...<>-..
Swale Working As Designed? NIA I J:\y ~~ l·)) I . . '
Any Erosion of Swale? NIA GLc.l IP b;,-<. , .. ,~
COMMENT$• h,.l t 1.0 .
;JI Gs u·) ......
&cos/pl\. q J 1i!tC
CHEHTRONTCS 12 DISK wp FTIB1 P-FINSPC DRAFT 2/10/93 FINAI 2/16/93
•
ITEM
Average Common Fill Thickness
Average First Select Pill Tbickne11a
HPDE Liner
Composite Drainage Layer
.
Toe Drain Construction
Toe Drain Out Fall
Average Second Select Fill
Thickne11a
Average Topaoil Layer Thickness
Vegetation Cover
Vertical BPOE Liner 1111 Biotic Barrier
.
Average Grade of Cap
Graded to Control Surface Runoff +
Erosion
Erosion of cap
Eroaion Anywhere Else
·•··•·· •• < ······ <•~
Settlement Kakora Present
f of Settlement Makers
PUNCH
•
CHEMTRONICS SUPERFUND SITE
PRB-FIBAL IBSPBCTIOlil
February 16, 1993
LIST FOR DISPOSAL AREA t-1-CAP
Thickne811 Pa11e/ Comments (inches) Fail
N.J l.v ( Q,~\'"\L :>iv i•l ( J_ ,--.;,~5
'"'-,. .(,_ s-1.». C \ "-'\ C...O -~ "h-""'-' "-" \-) r ~ r--u~ c.~ ·:r (:, L\,._.,i r ,:; "-qcc··~,-Li r. C. '--01 C)\
? ---t7,;, '-'~l'-'l l') .,_,\-~lls u
N/A
N/A ~
N/A \)
N/A l\.-, ~ ~ l..~"' o~ \J«~ \:_
-e-~Ir 18 11
'?""" ty (, {I
;vl.,yt-.\.-CA(r '--0,', .-' <l. V'J .'"M,. +1-.:~l · "'-' (17'
N/A "1,.,.,~ ·,
N/A ?
N/A Slib~
N/A ~5
. N/A
Ji 0,r hlYt> "-iflld Q,cc;!(T :, ,t'-il,I.Q_d.._ U,( Mf <9.~ ... ~ JtrJ.---J;,·0.1(.:J,;-,..__ ,~ C ey../\ ,1,.-L\.._ ,.
~
N/A jJ l) ~
• .. ••·••·· a2r ····••·•~ ..... ...
N/A t},5
· N/A .3
r-
I
\
I I
\ I
I i,'-<,
~0';7 \ I
~/ \
. I \ I
t; i
\ --,., 1,d 9
\ '(~"~ · 1
\ '
~/ oe\
' ry "1_,)Q /' '
" \ r~ • • I ~-
• •
ITEH Thickneu Pass/ Comments
(inches) Fail
Are Settlement Makers Surveyed In? N/A 7 ~ (Date)
h ·. .·•·•··········.: ~ ~ (\.:~ . . ·. -·:-:.' . ': ·;•:::;·. ,: :> '::·/ ':'"\}\ ::: :-· .. :,.; ·•··• ::-:,· :: :.,,,:::,\\:;.: :'-:'::":':' .... ,, :.-:\/.'''••,:,: .. .. •·•··
Inatallation of Gas Vents in Cap N/A
I Jc)
Number of Gas Vents Installed N/A ;VJ,
/ : ::\:/ ~i ...... ..
' ,·_;-; ,·•: ·:·.:•,:,.-.·,:, :·.,, <> : .. ,,,,:)/::!):::::,.
y ,/
Installation of Security Fence N/A <.e, 5
J Li) Gate Installed N/A \
Gate Secured? N/A 1 ~)
?? ... ·•• ·x8wit ...... ::+> . I Y·>U://· ::-,_,_, : ._,_ ~ ········~ .. •::····•·•·:.:·•.·.·•· .. :\
.fi<,11"
Slope of Nor'th ·roe of Cap N/A 2.. I
I <
5 """"'-
Slope o~Eaat Toe of Cap N/A 2.._[: ---' 2_()
1,/~--
~ Slopa of South,AToe of Cap N/A 6
~o
/Joe'(>,, 2-t Slope off.West Too of Cap N/A u,
.... ~ ...... •.• i . ·.·•···. · ~ ~ k ··• · .. · ~ .... >:··· :·?•.· ... :.: .Y
Swale(a) Constructed? N/A ;IJ(k
Swale Working Aa Designed? N/A
Any Erosion of Swale? N/A
COMMENT$• G(<l.S) ::i{, :,} '\-b l-lhr a..,, cR ~ t ~' ,_ 'fL.. s.rivtl-. c...v1,,.,.J
l1/<( L ·• \--> .. YF ...,,___ . ,1/,, er~:)~ O• r1tU '> ..;11,/L-
1> cevX
CHEMTBDNICS 12 DISK wp FITE; P-FINSPC DRAFT 2/JQ/93 FINA! 2/16/93
II • •
CHEHTRONICS SUPERFUND SITE
PRE-PIBAL IBSPBCTIOR A/.
February 16, 1993 -\ z\\
I i.l
PUNCH LIST FOR DISPOSAL AREA t " CAP
ITEM Thickness Pan,/ Comments (inches) Pail
vVQQ,d, st\) (Q.\,:.,.,-~ r-.., {, > ""'V--4,'.0 Average COtm:Don Pill Thickness r -.. kv..r ~ 'JI"\. "~ U.c) •::, -cf\.>-
-t<° ( C :.C,. ~ Vo...f"' ~Q.b_ ' Average First Select Pill
Thickness
BPDE Liner N/A ?
Composite Drainage Layer N/A r
':)
Toe Drain Construction N/A \
\.½.~' "'""' s 'k,~\___ Q" \)c..c'I<-
Toe Drain Out Pall N/A
11
•, ft
Average Second Select Pill .x I f:j Thickness
. .,.. /, 6 I I
Average Topsoil Layer Thickness '-
'
·; " '!,.,J-N>i--4> 't1.-:cl "-.--Ii.,.,.-; J°-e),t ,.._,, Vegetation Cover N/A
Cu()'J. \H:el ~o-. ,e..;, -~:01... "' s/!4CfL .. '"~-C..f-G,-.,, '!'\,:~Is~ ~ "'. NuJ ...,; (. .-. ()
Vertical HPDE Liner 88 Biotic N/A -? ""' ""-, v,,:i Barrier
L.v ~. = ly 't% Average Grade of Cap N/A ' ------a ,rojj <.,#,_,:) .
Graded to Control surface Runoff + N/A ~> Erosion
I -~ , ' --.. ,~,.'i)r.. -i~,,.-., "' "'\\...,,._
Erosion of Cap N/A Cb/. U.-e..o--r r't:" ., ... "" 'r ',,_ s ,. ~-
;:::: ..... ; •'-: ' , : ..,_ . _. -1 . .1.A '"'l ... t-oc. '-'""'C"r ~Li
'~ "'lL-~: .. "--... ~!,. .. .!> ,H-J--SE ""'<>-Erosion Anywhere Blee N/A
~ : /' ~ ·'=.:')\/.,,t"···:: •,_., .: ·••' ~ ' r :.:: ,,, ., ..
V
Settlement Makers Present N/A l,e, 3
t of Settlement Kakera N/A 2-?-
7p9~
' i
I
I'•• I •
----:•)~
,...Q l
+-~---+---+--?>_S __'". :/~!_,
frt)J -~
-......fl,'1sOJ~
( I
/)~ \ ~ )f '/\
. )
/
{
•
/I'>
I (Y
! I
; •
ITEM
Are Settlement Makers Surveyed In?
(Date)
Installation of Gas Venta in Cap
Number of Gaa Vents Inatalled
Installation of Security Fence
Gate Inatalled
Gate Secured?
Slope of
Slope ~·-of fast Toe of Cap
,,,.t
Slope of South\Toe of Cap
I
).,..$',
Slope of1~eat Toe of Cap
Swale(a) Constructed?
Swal.e Working As Designed?
Any Erosion of Swale?
Thickne1111
( inchea)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
COMMENTS• ---;1:$ '> <(l__ Urf,T ur-
fu,.-~ 5~i?;,C"S& -V{65S U(tiC
Paaa/
Fail
2-
•
.Comments
f
o~ J "-"+., :~lw s,"J.. J--
YR> A-~. ,V'JJ 1.u!. (-.. \<a~
(..._.,\,_ ~~ +--.. i.,,,_..., 51,J ... e."".s u.i (L., "-~....-jh.y, .~ ~
e:S
i+ o.Jq; Qbo ~ (/4. wh:.,,l_ ct-c<..o(,,.. ....... b
t-ero>;.:i-O(...,(_.½r6~ (,p 0 "-""J., k'orL
CREHTRONICS 12 DISK wp FTIEt P-FINSPC DRAFT 2/JQ/93 EIHAI 2/16/93
./ •
ITEM
Average Common Fill Thickneaa
Average First Select Fill
Thickness
HPDE Liner
Composite Drainage Layer
Toe Drain Construction
Toe Drain OUt Fall
Average Second Select Fill Thickneaa
Average Topsoil Layer Thickness
Vegetation Cover
Vertical BPDE Liner aa Biotic
Barrier
Average Grade of Cap
Graded to control Surface Runoff+
Erosion
Erosion of Cap
Eroaion Anywhere Ebe
•·•···• · .. i ··•·············
Settlement Makers Present
t of Settlement Maker■
CHEHTRONICS SUPERFUNO SITE
PRE-FINAL IBSPRCTIOII
February 16, 1993
PUNCH LIST FOR DISPOSAL AREA
Thickneee Pass/
I inches) Fail
•
CAP
COIIDll.enta
~l~ ~ ca~r sh, fi lL J " Q. ...... ~
'4.. r ~ ~A r .-..1"\)i--c .... (,/~ti""' v< "it-
4e.rr ~~-ij v .. r:,.l <!.r•,t-:.'--"'111 .
N/A ?
N/A p
N/A ?
N/A ~~r ~ ~ k .(-.,1,._ ,~ ~~~'t-. rt
?c; ly 1/3''
Xly ( '1
' 7\ '. c,\.. .. \\IA l't~y ovtr " t:J ~~r ti0 ~ . "'" N/A ~ . .l ~: r c.,, 0 . 5,n..Q._ c:.(n,c n,1 or~,
<>,-~f••>-L ... re,,v ~,/Ar ')A-0(0~. N/A
N/A (/J,.r \... ~k\t\
N/A ~
.I.... :,.~ ,v~ 't' v,1'1-....tL-eC"),'r,.r-..
N/A
<..-..\ot ,,.,. ..... ff..-.. i,Jt<\.. tit l , ...
Vp ~ro.~ .,~ C..f' -~;,l._ o..i.-
N/A
~ 'l.f"aA..
l .• •.(·••••i'••••••·•J·••It ·•.•.· \ •.•· >"····· Ji ·.··.•. ~ ......... ··••·
N/A ~>
N/A 10
• •
ITEM Thickness Pass/ Comments (inches) Fail
Are Settlement
(Date) Makers Surveyed In? N/A ~
\ ···•• 0{<))) ·C:::C'(,' ,_, .:.:.,·:: :, ,_,:, ••;:, I :-.
:·-cc ,:,: .... ,:-·;.;.:, .... : . ·> \ ( ··•··•·1>,···.•·······•··
·········••·•·•·•······•·
·-·,: : .·:·: •'
•·• . ...... .. \ ........... .:,:.::·: .: =.=: : _ _. .. ·;_c;:::·: ·:·:.:, '" ... ..
~ ~ .
Installation of Gao Vents in Cap N/A
Number of Gao Vents Installed N/A ~A
·••·•·•···•···. ) ···.•.•·····••"••····
...
··.·.·•·•····• .. ·~ \•.·< \\ ..,· )'. ZJ .... •·.· .. .... }) .·· .... < ·••··•••> ··•·· .. .. . .... . .... ..., ..........
Installation of Security Fence N/A ~
Gate Inai,:alled N/A ~)
Gate Secured? N/A (j_,s
::_,· •,•:::::,_:,:;,;:::,:,-· ,', •··••···· <
····•·•·····•······•·••·•··•·•·······
\·. < <.» .. . ••· .............. ····••·•·>· .... •.·.• . ........ >>·.•:_:_-··•::c:·,::,(:''=' :·=:=,.: ··•···· .... ·.,. .. ·,·.·::·:=,:.-,_.··.:::, .... ,.c-.:: _:,:-: . •. ...
U:r~l\y A-o ~<...~ .. C.I' :t-"nl.> i .--OJ Slope of North Toe of Cap N/A
6: l\
Slope of East Toe of Cap N/A 1,~
;i1)
Slope of South Toe of Cap N/A ;~
JD
Slope of West Toe of Cap N/A ,,rfl 2--
• ,,,·>::·/~ j ·.• ~ ;·,,._,::_-· ,•,~ i ·=::::jt:::.:~'::::-:r::·=·=,: : :·= ·:-,_,-:, ,·:,:,:-:::.:::•·•::•·•,•,•.-
~> fo.l o :<:r """"' '. ~ e."' <I.. • i;.. '4 if av,!\"\ • ,l.,.. stt~ <J.
Swale(&) Conatructed? NIA roL.l s.n.1\.. +-ol-0"'"-_ 'I,~ .:,l,, D~ ~ ...
~ bvr~u o~ ~-Swale Working An Designed? N/A
5 ...,., .. l,... (t 0,-....... ,t-e~d-.:,I;.. .w i"''..,\ Any Erosion of Swale? N/A ~ k..tr , r-o,i.,.,!. P..,p'f\.. . .\-'r'I/ '( . ic~~~
l ~ ....
CCHHPNTS• c,,t? ,'h,! f •> N,/.1:71' "' 6' ~"'-e, s,..,,. / / 'd"/~, +-:, e°! r s.,,-I VlThMo.-._ r~1~..:k-S...,,.( t <ti;, "'-'--~+-u+ C 'J f-AJ.tALJ. re~ ,l • .,A,•.,,
3,;. r !:. ::, 1 m h ,,,. !!,, .I.a. r &R-" e,L. lot. f-...., L ' ~,-_,-J.r/1.s ,..,.._. th ....-f..£..o :s ,.,"""
q_r11_ v J_ ~ 6..,_ ",ut k!l, 0,/LV\.-v,~"" !:>~ =
CHEMTPQNJCS 12 DISK WP FIIEt P-FINSPC DRAFT 2/10/93 EINAI 2/16/93
~---------
•
·,
\
\ ,I
I
ITEM
Average Common Pill Thickness
Average First Select Pill Thickness
HPDE Liner
Composite Drainage Layer
Toe Drain Conatructicn
Toe Drain Out Pall
Average Second Select Pill
Thickneaa
•·
Average Topsoil Layer Thickneaa
Vegetation Cover
Vertical HPDE Liner aa Biotic Barrier
Average Grado of Cap
Graded to Control Surface Runoff+ Broaion
Erosion of Cap
Erasion Anywhere Elao
Settlement Makara Preaent
f of Settlement Makara
CHEHTRONICS SUPERFUNO SITH
PRB-PDIAL IBSPBC'l'ICl!I
February 16, 1993
•
PUNCH LIST FOR DISPOSAL AREA ~ CAP
Thicknen Paaa/ inches Fail
Comments
<t-o ~ ,.._d.,..__
r"' v~ bo'{(,,__
~a\\<-t"' l l O"I t-; ~ ~ let,~,'"
1:-., \,,,_ VJtt ._'<._~-I (;.,L
N/A
N/A \
N/A y
N/A ~( It-., ~~to,
¢1/ (9 ((
'y'(/( (, Cl
<jht<-k--;-[ 'fl-y a~ ~t-c:v~ \~r N/A
N/A f
l-/?.
N/A
N/A b"s
N/A I )o!<k. _ . y ( •.,, ~ _ "~-0v0l ~ I r.J...
1/".s .. ,e_ p,eprf" ·
N/A
~~,Js -<fl-.... 11 b~ ~(• w.:+-
N/A
N/A 7
ITEH
Are Settlement Makara Surveyed In?
(Date)
Installation of Gaa Venta in Cap
Number of Gaa Vento Installed
Installation of Security Fence
Gate Installed
Gate Secured?
Slope of ~orth TOe of Cap
Slope of East Toe of Cap
Slope of South Toe of Cap
Slope of West Toe of Cap
Swale(a) Constructed?
Swale Working Ao Designed?
Any Broaion of Swale?
Thicknese
(inches)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
NIA
N/A
N/A
Paaa/
Fail
CHPHTRDNICS 12 DISK wp FTIP1 P-FINSPC DRAFT 2/10/93 ETNA! 2/16/93
•
Comments
.
'
\
'-" . . . 0 ..... · ·.-\. · .
•
•
I
Bxt.raction Gravel Concrete Well
Well Apron Pad Cover
(P/P) (P/P) and
Security
' (P/F)
)f'b••l ,-w-t ~lu ~S, ~s
......... }.), ) cl> 02S ,..,.,.. _,
P/F (Pass or Fail)
CHEMTRONICS SUPERFUND SITE
PRE-FINAL IHSPECTIOH
February 16, 1993
PUNCH LIST FOR GROUNDWATER REMEDIATION
EXTRACTION WELL~ FOR THE FRONT VALLEY
Electrical Control Panel'-. Preaaure Filter Indicator
Gauaee (P/P') Pl=
Gauge Inatalled Auto/Manual Beating First Second (P/P) (P/P) · Power Switch Element (P/F) (P/F)
(P/P) (P/P)
te,,s 'Les iis 1.i5 ~_.I
L, '(",,o I lR,,,)
V r£.S tis tu V ..., V u,__s-<-2-1 -e;, U>
5ThJ-I (s1,.,11 ... ,. 1:6" c.b'<> _\ ,..,o(( ,, ¥ ""' y--, Go ..,... :½ I\ li\.-0::½, ) ( \. I
:t:
I :±s:.z,.h,. ,J-.. ., ~ +e "" •..> :±c:J.;~ :w ,,L (ol Cc I <l"
Pl= Total Leaking Submeraible
Rate Pl= Connoc-Proaaure
(GPM) Heter . tiona Transducer
Gauge
(P/P)
(P/F) (P/P)
~· Yt) Nb ~',
2.. I ~> ;(),) ~>
i) Tl!J -I . > S:y'. <-u.\J .-,..,, {
,,,µ -:r:l. " -wbJ w. Ii/ 0b"
'C-t9±5" ,), •. J_ fs:c2,.,,__ ::th: ~ c:,n:,.,, ~ ~\Q_J.,,. --\-L '"K'Q.+..,_, oii:: ~ y';S Jt 1-h,. ·,ivlf , I
0 r: ... .,-{~. €1\Ch 6-, .. ~;; '0 & J.-li: "-<' b 111 ·boo~ "JJJ sh-,,~ L ;1:;i \J
-
ITEM
Equalization Tank
Equalization Tank Bag Filter
' Stripper Feed Pump
Backup stripper Feed Pump
,
Packed Air Stripper Tower
Blower for Air stripping unit
Acid Rinse system for Packed
Air Striooing Tower
Bag Filter
Carbon Filter Feed Pump
Backup Carbon Filter Feed Pump
Values to control Flow Through
Activated carbon Filters
Three Activated carbon Filters
sampling Port
Lift Station Pump
Control Panel
Computer Control system
warning Lights
Building Ventilation
(P/F) -Pass1Fa1.1.
CHEMTRONICS SUPERFUND SITE
PRE-FINAL INSPECTION
February 16, 1993
PUNCH LIST FOR GROUNDWATER REMEDIATION
TREATMENT SYSTEM FOR THE FRONT VALLEY
INSTALLED OPERATIONAL COMMENTS
(P/F) (P/F)
y y I r,<,,..,,.x-'7 ' <t-.....,,.._,l_ =~ ........ ~ ~-'o. in>-... .:.-\--¾"k.
f
o/
y
p
'Y
p I t½u-" I ~-"<--• >;-~ . .,r;,~.,:i~ ""° "??°"'.' ,-1' -.~; I~ -~ .~ . I
; 0l)'I L \_ \Y-ih'-A-:·ci._ ·~ c.'r sir; M•r "" :tc v I !o • l ·,f\.L-i~vl ,:,~ u._ >o ~• "\L, d., N>°t" \.. .,t J.,, ~-I ,"k.)fQ....
' r. '}tv I"" it ," c.-\v.-.. .L t.1: I I ' ., "' ... ~I........._
? c;:: ,4 (._. ...; ( .\e ' u . {.. I (;,..J..,. j" _.j,._,J fu \J
(_ C,..:c,, ti . ' r b, ..,1c. ii, S" ,,:;0 d\ IC.' J4".--•:<•{-tr -.--~(.;~ ~4-.-\-
~J~-h·""'--J ' +-.,.,...._ _Jl,l-1(\,. .J' ~ c.t. L\A.D Ci..,.c n• I,.-{_,
r ~~:l'\-4\--:,., (-..:,c.,{.:i---__.:, \l,.r. \,~\.
,
I~ I.Ii..-a),, \i~ •. \....., ~~ • U.,.l ,I._, • I I ~ 4W...'"' ,\ ...... n.,({1
\ () V \l I
r
::> /
,) I y
I LOCATION I
Extraction Well High/Low ~· Hark Pressure Transducers o~-,
1!tr-'2
'
Equalization Tank
Air Stripping Tower
Carbon Filter Feed Pwno
Backup Carbon Filter Feed Pumn
Three· Activated Carbon Adsorption
Filters
(P/F) -Pass/Fail
CHEMTRONICS SUPERFUND SITE
PRE-FINAL INSPECTION
February 16, 1993
PUNCH LIST FOR GROUNDWATER REMEDIATION
TREATMENT SYSTEM LOGIC FOR THE FRONT VALLEY
ACTION I P/F I COMMENTS
Low Water Level -Air Stripper Feed v:.1 --t-~ o.~ o?f•" t,.":'7' ¢:a> o b-:,,z i v IL
Pu.mo Off/Extraction Wells On
High Water Level -Air Stripper Feed <i~ :,,~o/ -~. '•> o',. YI,..,-. \.ow ul~ ,._
Pump On 1--;o\, -l,'c\ • ~-\w~l ~~ o•"b;/;+.:,, <> ~
High High Water Level -Air Stripper ~ •t~-~ I;, ..Jc-.l J..".L' o.1.~ ( ..... 1... -...t..-~ , ,,~-{,/f3. Feed Pump On/Extraction Wells Off _'\. r: . ., C DA • -, -' < -·--.2...__ Ci,y:sJ.,., < wurµ J_ \ d.Jl•:y'-' "-High High Water Level -Air d)
Stripper Feed Pump Off/Air Blower On
Blower Fail Safe High -Extraction
Well Pumps Off/Air Stripper Feed
Pump Off r
?
:?
\
rt::
,o 5,
·I I •
.· Monitoring
Point
SW-2
SW-4
BW-4
MW-lS
P-lS
P-lD
P-lB
• CHEMTRONICS SUPERFUND SITE
PRE-FINAL INSPECTION
February 16, 1993
PUNCH LIST FOR GROUNDWATER REMEDIATION
MONITORING SYSTEM FOR THE FRONT VALLEY
Gravel
Apron
(P/F/NA)
Concrete
Pad
(P/F)
Well Cover
and Security
(P/F)
. '
Frequency of
Monitoring
(#/yr)
(P/F/~A) -Pass/Fail/Not Applicable
/),1 IA), '
&U . &, ' yJt ( \ ' (,&✓ti) !:AA L I~\". ~q\,&J clro.~,<2. t')\.¢" \ t \ N
A-{( . ~;e-qpw~r
¢; t9:,,Jed 'f ,//(jVJ . u ✓~<S h,,, y'-, b"
CHEHTRONICS SUPBRFUND SITE
PRB-PIBAL IRSPBCTIOB
February 16, 1993
PUNCH LIST FOR GROUNDWATER REMEDIATION
P!XTRACTION WELLS FOR THE BACK VALLEY
Extraction Gravel Concrete Well Electrical Control Panel Pre•eure Filter Indicator Flow
Well Apron Pad cover · Gauaee
(P/P) (P/P) and
Security Installed Auto/Manual Beatirlg Piret Second (P/F) (P/P) Power Switch Element (P/P) (P/P)
(P/P) (P/P)
~~. AIU d5 0-) ~\ c_../ rr; 'CL~ 'u ~ l15
EW-2 l \ I
EW-3 I
EW-4
,EW-5 I
EW-6 I I ' ' : ., ' ' I ' EW-7 ;
' I EW-8
i I • .,._, I \ I
EW-10 I ) I .
EW-11 I \ \ I ~ \ \' r I e., \l \, V '.'./ \.V \ \ \ .
P/F (Pass or Fail)
COMMENTS: c;;-.. v,\ o~u"-> ,,;.\\ 'µ__ ,J(.g,J
~or~. vi+ I" f[,\J-2. N> ·1"~ ,..._.v,. l
-!{.,·,, .SJ,c·, 1
k,,~ ~
frw "fF' ~ 'u" .l,,,,6'6'; ~ , :,, • J
(P/P) Flow Rate Gauge (GPM)
(P/P)
QJ J5 . I' ,.,
\, 'l
I,~ ,.~
\ .1
: I.) ' ' I.
? • L I
\ ;i..,B
I 'i. 0 \
I ,. 8
I " I ;.z__
V \y \ '~.
[\-01,· '15 h...,.
~vu / h-....i-~b
Total Leaking Submereible
Flow Connec-• Pre•eure Meter tione J Transducer
Gauge {P/P) ' (P/F)
(PIP)
L[I (1 0.J,i 'a,7 • GLUD
L1 ':>7'
,s-i::s.r-
1q B'f
3'-1475'
.no,1
.1:5 1}1
'i~ /[59
½~'HI I , • '-11151 \
/01 o \ 'v \J
J,:;, al( 5 ""'ti)~·~
o 'cfL r
I ITEM I
Eaualization Tank
Ennalization Tank Bag Filter
StrinDf'lr Peed Pump
Backuo Stri.., ..... r Peed Pu.me
' Packed Air stri..,n,,,r Tower
Blower for Air Strinning Unit
oB Ad1uatment Solution (NaOB)
pH Ad1uatment pmnn
In-Line Mixer
pB Heter to Control pB Adjustment
Pump
Sampling Port
Acid Rinae System for Packed Air
Strinninq Tover
Control Panel
Computer Control Syatem
Warning Lights
Buildina Ventilation
CHEMTRONICS SUPERFUND SITE
PRE-FINAL INSPECTION
February 16, 1993
PUNCH LIST FOR GROUNDWATER REMEDIATION
TREATMENT SYSTEM FOR THE BACK VALLEY
INSTALLED I OPERATIONAL I COMMENTS
(P/F) (P/F)
H,z V.fl, '(,.' iu.J\y C::-t.~J.a.,~ • ,I·--I-'-,-!,,!J...
of {..~\...
•
!VO • ff"' 'y..A. 't,..,"-\>( OH v,H_ 'I,~: lo ~G' -~.--.. .. ~~· -.... . ~~.
I NaOB Solution Beina Uaed _5b°7o ~v~c...l
. l ... 1..t{Ull-Al ,IJ. 0 tf •. I," ~r,>M 2..S"lo h
JV "J~ . .1,_ Ii l -\..1-.r~-tl-u.L 0• ~Ii. EW-1
S• $y$,j,o,.. .., .... •4-Iv--0 vqI £o..J.. ~ •
'il-..v \..,._ 1 Jo.A ... \\),,-.l \:"' I,, .,
r«..:_,u""\ ?• ... <J. '-J
.
I
I ' I
I . I
V V
I
(P/F) -· Pass/Fa1..L
COMMENTS; ({,\r( f .,Jt\y f I
J:,, 1al-ct.
w1/(s
,J b;
> n-J -2-1
~ I ~i\ ~
_,ill."'"·.,,_1 ,_c1f-. __,,._~='-"· ~--'l"'G'-'~'-.,_,_· '-'"-=-·-~._."-~'--\1.--'---'-'-=;_,_\ _1.,.:.....:,_,_li-4 -+-_-_,_rl..-""--,--.,_\..,...~====-->+''J'-'-J,_,_"'-__ .le'....,2 ._,,.=''-'"' •c:·.;:.,_f.c,/ '--_L_==•"'-'".-· __,,,_,"-", ,__
".\<""-•·~,-.\-• ~"-. V,,~ ,> b~,v <:'JC-h,c-l..Q/ ·1L,~(~,._ ,rz___ 'T•"-<--\-,"--1..,-.,"\-'Y'~;<u.> uA ,a.
0 ·!,
•
•
I LOCATION
Extraction Well High/Low
Mark Preeaure Tranaducera
Equalization Tank
Air Stripping Tower
DB Heter+ DB Adjuat.ment
? IAM\1 fj,•~1.... -1-\-i~ "-. .
• CHEMTRONICS SUPERFUND SIT,.
PRE-FINAL INSPECTION
February 16, 1993
PUNCH LIST FOR GROUNDWATER REMEDIATION
TREATMENT SYSTEM LOGIC FOR THE BACK VALLEY
I ACTION I p/p I COMMENTS
jfW-L High Water Level -Pu.mp On i;7 Wi\lt ~ ro ,.,.,,li,u o-.... ..,..._..
oW -n. ✓ ~-!-;l/ Low Water Level -Pump Off • , "-' Q._.
A J ! _. I.. J.-. \ -__. , ' High Water Level -Pu.mp On " ' -'.\, EW-2
r ::-'t., • ~-~-' • '. \,.\" 'L, Low Water Level -Pu.mp Off
High Water Level -Pump On -'-~.A .. -A ,:, .. lo. ,-'\.fl. ~ EW-3
-¢,_ ' -:1-, ~n Low Water Level -Pump Off lV'\~,--........ ~
High Water Level -Pu.mp On ,.f IS ,i/ o.C:-4 c., .,,c. ~(,, EW-4 ,
Low Water Level -Pump Off
Biab Water Level -Pump On EW-5
Low Water Level -Pump Off
.,._, Biah Water Level -Pump On
Low Water Level -Pu.mp Off
EW-7
High Water Level -Pump On
Low Water Level -Pump Off
Biah Water Level -Pump On
EW~B
Low Water Level -Pump Off
High Water Level -Pump On
EW-9
Low Water Level -Pump Off
BW-10
Biah Water Level -Pu.mp On
Low Water Level -Pump Off
EW-11
Biqh Water Level -Pump On
Low Water Level -Pump Off
DTw-2.
~
Biah Water Level -Pump On
Low Water Level -Pump Off
Low Water Level -Air Stripper Peed 1.-o..., ..,;AA_r \ulu v,J.:) t-t<..) ... Pump "'~ (" J,'"(\11,\D.-ow. Off/Extraction Welle On IOJU
"
I
!ill: I :-+ c.i,QW'oCil.!,'L High Water Level -Air Stripper Peed ~,r\,s " j "" Pumc On
High High Water Level -Air stripper ~,I"'\-"( 1/'f-'(~'!, '-'•~,+-.
Peed Pn,...., On/Extraction Welle Off
High High Water Level -Air Stripper
Peed Pum.D Off/Air Blower on ? I :\ W•l d<2 ...... ".s .,_ ,! • j -
Blower Pail Safe Sigh -Extraction Well
Pumpa Off/Air Stripper Peed Pump Off
Pump Chance in pH Ad.junta Pumping Rate y '?'"'-,~ ....... V-.(\ t.(i 1,u.or~i ..... ..L. a
'"'"' u-K o/L ~-:n ·,-c.l .... '-"'"'\-l o VII""'-•• ,-... \' '"'"i\! I ' ~.....,., -1,.-..,.~_,t "'" (P/F) Pass/Fail ~-'k ~ tki' ,.._ 11-'t \I.,. •
COMMENTS• A,, :~ ':½-s,_ Fr,1.j;-sr.s.J.--... :sl:t--ck tA'tM,j--syJ,I.,...._ ::t-r..Js """ [(l., <i' l> v.. .J .. \)l .1:r-
c..,, &; Of\ ..,__ \.:ie', .,_. ~ vW ; .J.\s., • ~re -st1..__ fc ~ J:-, v ,)1:-t" ' .,
?
•
Monitoring
Point
SW-8
SW-12
SW-13
BW-9
IW-2
H85L9
MW-2D
MW-28
MW-3S
MW-JD
MW-JD
MW-48
MW-5S
8
P-2S
P-2D
P-2B
P-3
P-46
P-4D
P-48
P-55
P-5D
P-58
•-•
P-7S
P-7D
P-78
COMMENTS·
• CHEMTRONICS SUPERFUND SIT-
PRE-FIHAL INSPECTION
February 16, 1993
PUNCH LIST FOR GROUNDWATER REMEDIATION
MONITORING SYSTEM FOR THE BACK VALLEY
Gravel Apron Concrete Pad Well Cover and Frequency of (P/F/NA) (P/F) security (P/F) Monitoring
(f/vr)
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(P/F/NA) Pass/Fail/Not Applicable
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,,;.~ ~~Q.. --. o. 0 ca ✓~( age""· f\s",b,<t"tJ !IJ)L
o,o ..... r . 7 rie3;;9o:,,>.~r~ ~·,4J yelt(]t,J_
• • OSWER Directive 9200.3-01 H-1
Definition of Accomplishment: The date the le~d and support agencies conduct the final
inspection. This date must be entered into WasteLAN with the RA subevent, Final In•
spection and Certification (C310 I =IN). ·
Changes In Definition FY 92-FY 93: New defiriition in FY 93.
' '
Special Plannlng/Reponing Requirements: RA construction completion is reported
site specifically in WasteLAN. This is a STARS reporting n)easure.
FINAL RA NPL SITE CONSTRUCTION COMPLE.TJON
Definition: Final NPL RA site construction is cdmplete when construction activities for
the final OU are complete, a pre-final inspection \has been conducted, and a Preliminar)'
Close-Out Report prepared. This report documeins the completion of physical construc-
tion, summarizes site conditions and construction activities !Ind, as appropriate. provides
the schedule for the joint inspection (required before the start of the O&F phase), ap-
proval of the Operation and Maintenance (O&M) work plan, and the establishment of
institutional controls. The Preliminary Site Close'"Out Report is only required for the final
OU. .
. Definition of Accomplishment: The date that the designated Regional official (Division
Director or above) signs the Preliminary Site Clo'se-Out Report documenting. based on a
pre-final site inspection, that physical constructiqn is complete and only minor inspec-
tion/punch list items remain. The appropriate da(e must be recorded in WasteLAN with
the RA subevent, Preliminary Close-Out Report Prepared (C3 l O l =CC), ' '
Changes In Definition FY 92-FY 93: New defihition in FY 93.
Special Planning/Reporting Requirements: Fi~al RA site'construction completion is
reported site specifically in WasteLAN. A new ~ubevent fof Preliminary Close-Out
Report Prepared (C3 IO l=CC) has been added to WasteLAN. This will be valid for RA
and ROD events. This is a SCAP reporting measure. Final RA NPL Site Construction
Complete is also included in the STARS measur~ S/C-3 NFL Site Construction Comple•
tion. The definition for NPL Site Construction Completion can be found in Section 3:
Response Definitions. · ·
OPERATIONAL AND FUNCTIONAL (O&F)
. Definition: O&F means the activities required to detennine that the remedy is function-
ing properly and is perfonning as designed. O&f activities :are part of RA when a Fund•
financed RA was conducted. Physical construction may be complete before the start of
O&F. EPA funds O&F activities for a period up[to one year after joint inspection by
EPA and the State, or until EPA and the State jointly detemiine that the remedy is func•
tioning properly and is perfonning as designed, whichever is earliest. EPA may extend
the one•year period, as appropriate. ·
Definition of Accomplishment: The completion of O&F is the date upon which the lead
and support agencies agree through a joint Inspection that the remedy is operating in
accordance with the standards contained in the ROD and RD. This documentation is
reported in RA Report. Normally, O&F completion will octur within one year following
completion of construction. ,
A-51
--dswER D~c,;tivc 9200.3-0IH•l • • Change/! In Delinitlon FY 92 • FY 93: O&F only hasia completion date.
Special Planning/Reporting Requirements:
RA COMPLETION
Definition: A first and subs~.quem RA is complete when construcµon activities are complete, a final inspection has been conducted, the remedy is O&F (see definition for O&F), and an RA Report has been prepared. This report summari;es site conditions and construction activities for the OU. · ·
· Definition of Accomplishment: The date that the designated Regional official (Branch Chief or above) signs a letter accepting the RA Report fpr the first or subsequent RA. The contractor's constructibn manager (ARCS, USACE, State, PRP, Federal Facility, etc.) submits a signed RA report to document the completion of alrconstruction activities for that OU, and that the remedy is O&F. · 1n lieu of a report from the contractor's con-struction manager, the Region must prepare a report to cjocument the completion. The appropriate date must be recorded in WasteLAN with the RA event.
Changes In Definition FY 92 . FY 93: The RA Repo& is accept<id by the Branch Chief or above, not the Regional Administrator.
Special Planning/Reporting Requirements: Cornmitri.ents are made on a combined Fund and PRP basis. Federal Facility RA completion commitments are made separately. First and subsequent Federal Facility RA completions is\a SCAP tafget. First, subse-quent and final Fund and PRP RA completions are SCAP targets. (See following defini-tion for final RA completion.) · ·
FINAL RA COMPLETION
Definition: A final RA is complete when:
• Construction for all OUs is complete;
A pre-final inspection has been conducted;
A Preliminary Site Close-Out Report has :been prepared. This report documents the completion of physical coiistruction, summarizes site conditions and construction activities and; as appropriate, provides the schedule for the joint final inspection (required before the start of the O & F phase), approval of the O&M work plari, and establishment of institu-tional control. The date of the Preliminary Close-Odt Report must be reported in WasteLAN with the RA Subevent, Preliminary Close-Out Report Prepared (C3 IO I = CC); .
• A final inspection has been conducted;
• The remedy is O&F;
A letter accepting the RA report has been 1signed by the designated Re-gional official. The date of the letter is entered into WasteLAN as the RA completion date (C2 IO I =RA); and ·
A-52
! .
FROM:
• •
UNITED STATES ENVIRONMENTAL PROTECTiON AGENCY
REGION IV ! '
345 COURTLAND STREET, N,E,'
ATLANTA, GEORGIA! 30365 .
FACSIMILE TRANSMISSION SHEET
NUMBER OF PAGES: -5 ( Includes Cover Sheet)
JON K, BORNHOLM
EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365
N:JM)5g;'(: -2.so I
• .... !'' ,. .. .,-:u;;..:.::;;~~.;.:~ . :.,, •. ; --~-,•-·~·,:~•~
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: ~-;,-'-\.~l.,!;.· -!._ .. _,_._~..," .... -:0:'"~'~::..· -•--':;.;-,:-,::=
PHONi': NllMBER:
FAX NUMBER:
[phone]
(FTS)257-7791
[phone]
(FTS)257-1695
SPECIAL INSTRUCTIONS OR NOTES: __ ~---------
-::I (j t~ .
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Also, ~ Wt~ re.-N~r a\> in···*·.:...:c.-· _-..J_~'--"'-"'~=---=--i.:_2....,.,--'-'-lq...:.;:;qJ
£ ...,,J .1"' s~ ,.1•o.-_ @_. Ch W\~ '"-"'~;~<...$=·~-----
·--· .
• ·. !1\1 ·,,·-w11aaw~1m;;i,t•rt,lJ;l-t(&'J\'I.', · . . : · -{ i~i~~f.hi'~1~~==
,; ,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
NOV 2 5 1991
4WD-NCRS
Ms. Charlotte Jesneck
Superfund Section
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
North Carolina Department of Environment,
Health and Natural Resources
Suite 150
401 Oberlin Road
Raleigh, North Carolina 27605
RE: Safety Training for Remedial Action at the Chemtronics Site
Dear Ms. Jesneck:
A Pre-Work Conference (Pre-Construction) meeting was held at
the Chemtronics site on Tuesday, November 13, 1991. Enclosed
is a summary of the meeting and a list of participants. I have
also enclosed for the State's record notices of award and
notices to proceed from the potentially responsible parties
(PRPs) to Sirrine Environmental Consultants and Canonie
Environmental Services Corp. as the Engineering Oversight
contractor·and General Construction contractor, respectively,
for the Chemtronics Remedial Action {RA).
Highlighted in the meeting summary notes are several key dates,
one of which is the date of the Health and Safety training.
This training (24 hours) will begin on January 6 and run
through January 8. If the State anticipates having somebody
conduct oversight during the RA, it is imperative that this
person receive this training. Otherwise, the PRPs and Canonie
will not allow this person direct access to the construction
site(s). This training will be put on by Sirrine either at the
Site or in the Swannanoa vicinity. Please inform either myself
or John Schultheis, the PRPs coordinator, if any State
person~el wish or plan to attend this training. I will keep
you apprised with specifics on the January 6 training as I
receive them.
Another important date to highlight is December 1, 1991 as the
first date of the 295 day clock. The PRPs anticipate that all
construction activities should be performed within 295 days.
Canonie and Sirrine have committed to completing the
cons_truction within this time frame. Actual field work cannot
• •
-2-
be initiated until after the Health and Safety training is
finished. The first work to be initiated is the installation
of the extraction wells and monitoring wells. This work is
projected to begin the week of January 13. Major earth moving
activities will not begin until late spring.
In addition, I am anticipating receiving the draft RA Health
and Safety Plan from the PRPs on November 26, 1991. A copy
will be sent to you for. review. In order for the PRPs to meet
the January 6 training commitment, I request that you submitted
the State's comments to me by December 19. Please refer to
item k. of page 2 of the meeting summary notes.
If you have any questions, please call me at [phone].
Sincerely yours,
~K~c
Jon K. Bornholm
Remedial Project Manager
Enclosures
cc: Lee Crosby, NCDEHNR
William Meyer, NCDEHNR
NC File
I .
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704 b86 4630
TPAIEi•l I TTED FROM. _"-oo 4630
NIMMO & CO.
Conaullants
po. Box 538
Swennanoa, NC 28778
(70o4) 686-4338
fAClliNIUI D>MBH1N101f
nais1 ___ _
110111 ·
SIINDU:
NJJIIIO
NIMMO
[phone] PAX IIO,, _____ ~
l'IIOIIII IIO, ~ 704) 686-4336
. alUft' UICLUOUIG 018 •AGlll :z'. IOW, !Mill
·COMREL
·.
•
TRANSMITTED FR □M.4 686 4630
PRE-WORK CONfERENCE
Chemtronics Site Wednesday, November 13. 1991
~IT.ENDE!~
SIRRINE
Chris Wyatt
Chuck Travis
Terry Standridge
Tom Champion
Jim Cloonan
Betty Schnee
.OTHERS
Jon Bornholm -EPA
Nancy Baldwin -Northrop David Hedrick -Halliburton
Darrel Campbell -JRC Joe Moore -JRC
Don Higgins -Nimmo
Nancy Schultheis -Nimmo John Schultheis -PRP Coordinator Nillaon & Watts -Surveyors Alexander Construction
Hayes & Lunsford Electric Co. Environmental Monitoring & Testing
CANONIE
Nelson Pelletier
Don Abramowitz
Jim Semple
Robert Lo11an
John ◊'Toole
Eric Mortenson
Bill Goodrich
A pre-work conference meeting was held at the Chemtronics Site on Wednesday, November 13, 1991 with the above named persons in attendance. The meeting convened at 9:00 a.rn.
SUMMARY
1. Introduction and overview -PRP Coordinator
2. PRP Expectations -Nancy Baldwin
3. Introduction of Personnel
4. Responsibility of Action Items:
a. PRP Coordinator to meet with Canonie and Sirrine to work out a formula to share power costs.
b. Canonie to contact Southern Bell for telephone hook-up.
'.
TRANSMITTED FR □M-636 4630 ..(OMREL
Pre-Work Conference meeting pafe 2
c. Temporary F'acility Plan -Canonie will provide the Plan
which will be submitted to PRP Coordinator by November 27
and coordinated with Sirrine,
d. Sirrine will begin Health & Safety training January 6. 1992.
e. Canonie intends to start temporary facilities set up by
Dec. 9.
f. The following Companies will be responsible for traeh
dwnpsters in listed areas;
offico area -dumpster: Sirrine
operating area -labeled drums: Canonie
t land fill trash -dumpsters: Canonie
g. Canonie will submit the Environmental Protection Plan to the
PRP Coordinator and Sirrine by December 4.
h. Environmental fees will be paid by the PRP's.
i. Construction fees will be paid by Canonie.
J. Canonie will submit the grading plan to the PRP Coordinator
by ~ebruary, 1992.
k.· Canonie will provide a Health & Safety Plan. This Plan will
be submitted to the PRP Coordinator and Sirrine by Nov. 25.
The PRP Coordinator will then submit this Plan for
concurrence to Joi Bornholm Nov. 26. Then, EPA will return
this Plan to the PRP Coordinator by Dec. 20. Any
corrections to this Plan will be via an Errata Sheet. This
Plan will define badge usage,
1. Chemical Screening and Cap Construction Plans to be
submitted to EPA by late January or early rebruary, 1992.
m. Well Permits will be the responsibility of Sirrine.
n. Construction Permits will be the responsibility of Canonie.
a. The EPA Oversight Contractor will be Camp, Dresser. McKee.
p. The Critical Path Schedule will be ready by December l·and
will be submitted for 60-day intervals.
q. A Milestone Chart will be submitted to the PRP Coordinator
by Deoember.5.
r. Cash flow requirements will be submitted to the PRP
Coordinator on a monthly basis for the ensuing quarter.
I'
TRHtlSM I TTED FROM. 686 4630 0 ,:QMPEL
Pre-Work Conference meeting page 3
s. Monthly Invoice costs to be submitted to the PRP Coordinator
will include all costs through the last Friday of each
month.
t. Notice to Proceed
PRP Coordinator.
and Jon Bornholm.
will be issued by Friday, Nov. 8 by the
Copies will be sent to Canonle. Sirrine.
u. December 1, 1991 will be the start day for the 295 day
clock.
5. Queotion and answer
The meeting was adjourned at 5:00 p,m.
'.
NIMMO & C(At
Consultants
P.O. Box 536
Swannanoa, NC 28778
[phone]
Mr. Jim Semple, Regional Construction Manager
Canonie Environmental Services Corp.
500 North Gulph Road, Suite 315
King of Prussia, PA 19046
RE: Notice of Award and Notice to Proceed
Dear Jim:
November 14, 1991
JFS-101-91
Attached hereto are the offici.al "Notice of Award" and the
"Notice to Proceed" documents. I have also included Hochest-Celanese'
executed contract signature sheet.
I believe both notices are self-explanatory. However, if you
have any questions, please contact me.
JFS/ns
Best regards,
~-/J; n Schultheis
PRP Coordinator
cc: EPA-Jon Bornholm w/doc.
, . • NOllCE OF AWAAD •
Dated October 15
TO: Canonie Environmental Services Corp.
(BIDDER)
ADDRESS: 500 North Gulph Road, Third Floor, King of Prussia, PA 19406
PAP'S PROJECT NO. _J_-_10_1_0_01 ____ _
PROJECT __ ___.C~h~e~m~tr~o~n~lcs=.,C~E~R~C~LA~~Si~te"-'-'R~em""""ed~i~a~IA~ct=io~n.._ __________ _
PAP'S CONTRACT NO. _N_A _______ _
CONTRACT FOR General Construction Contractor on Chemtronics CERCLA Site
Remediation
Qnsert names or Contract as It appears In the Bidding Documents)
You are notified that your Bid dated October J 4 , 19 91 for
the above Contract has been considered. You are the apparent successful bidder and have
been awarded a contract for all of the construction activities contained in the
bid issued by the PRP's of the Chemtronics CERCLA Site Remediation on 6/21/91
aod classified in meeting of October 2, 1991.
(Indicate total Work, eltemates or sections of Work awarded)
1.0
EPA -REGION IV
ATLP~~!TA, GA.
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• • The Total Contract Price of your contract Is four million, one hundred & sixteen
thousand & three hundred & eighty-three _______________ Dollars($ 4,116,383 ).
Three copies of each of the proposed Contract Documents (except Drawings accompany
this Notice of Award. Three sets of the Drawings will be delivered separately or otherwise made
available to you Immediately.
You must comply with the following conditions precedent within fifteen days of the date of
this Notice of Award, that Is by December 1 , 19 ..2L .
1. You must deliver to the PAP'S via PAP COORDINATOR three fully executed
counterparts of the Agreement Including all the Contract Documents. This Includes
the triplicate sets of Drawings. Each of the Contract Documents must bear your
signature on {the cover) (every) page.
2. You must deliver with the executed Agreement the Contract Security (Bonds) as
specified In the Instructions to Bidders (paragraph 14), and General Conditions
(paragraph 5.1.A).
AWARDED BY: ACCEPTED BY:
John F. Schultheis
(PAP'S) (BIDDER)
BY: ---------(ALJTHORIZED SIGNATURE)
PRP Coordinator
(TITLE) (TITLE)
1.1
• NOTICE TO PROCel
Dated November 11 , 19 91
TO: Canonie Environmental Services Corp.
(CONTRACTOR) ADDRESS: _______ s_o_o_N_o_r_t_h_G_ul_p_h_R_o_a_a_, _T_h_i_r_d_Fl_o_o_r _________ _
King of Prussia, Pennsylvania 19406
PAP'S PROJECT NO. J-10101
PROJECT Chemtronics CERCLA Site Remedial Action
PAP'S CONTRACT NO. __ NA _____ _
CONTRACT FOR General Construction Contractor on Chemtronics CERCLA Site
Remediation
onsen name at Comrae1 as tt appears In the Bidding Documems)
You are notified that the Contract Time under the above contract will commence to run on December 1 , 19 91 . By that date, you are to start performing your obligations under the Contract Documents. In accordance with Paragraph 3.0 of the Agreement the dates of Substantial Completion and Final Completion are September 20 19~, and October 30 , 19 92 , respectively.
Before you may start any Work at the site, Paragraph 2.5.C of the General Conditions provides that you and PAP'S must each. deliver to the other (with copies to PAP'S REPRESENTATIVE) certificates of insurance which each is required to purchase and maintain in accordance with the Contract Documents.
2.0
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• • • Also before~ may start any Work at the site, you must
(add Olher raqulrementa)
Copy to PAP'S REPRESENTATIVE
' (Use Certified Mall,
Return Receipt Requested) John F. Schultheis
(PAP'S)
By ~~ ~
(AUTHORIZED SIGNATURE)
PRP Coordinator:
-(TITLE)
2.1
•
• NIMMO & co~
Consultants
P.O. Box 536
Swannanoa, NC 2bll8
[phone]
!:PA -REGIOI" IV
.a.'!'~_.._:-;: A, GI •.
November 14, 1991
JFS-100-91
Mr. Jim Cloonan, Project Manager
Sirrine Environmental Consultants
P.O. Box 24000
Greenville, South Carolina 29616
RE: Notice of Award and Notice to Proceed
Dear Jim:
Attached hereto are
"Notice to Proceed".
contract signatures
Administrator.
the official ''Notice of
I have also included the
you to pass on to for,
Award" and the
balance of the
your Contracts
I believe both notices are self-explanatory.
you have any questions, please contact me.
However, if
JFS/ns
Best regards,
~Schultheis
PRP Coordinator
cc: EPA-Jon Bornholm w/doc.
• • NOTICE OF AWAAD
Dated October; 15 ,19~
TO: Sirrine Environmental Consultants of North Carolina, P.A.
{BIDDER)
ADDRESS: 3733 National Drive
Dare Building, Suite 120
Raleigh, North Carolina 27612
PAP'S PROJECT NO. J-10101 ----------
PROJECT ___ C~h=e~m=t r~o~n=i cs~C=E=R~C=LA~S=i=t e~R=e m~e =d i=a ~I A~ct=i o~n~-----------
PAP'S CONTRACT NO. _NA ________ _
CONTRACT FOR Engineering Oversight with Chemtronics CERCLA Site
Remediation PRP's for Professional Services
(Insert names Of Comract as tt appears In tne Bidding Documems)
You are notified that your Bid dated October; l 4 , 19 -"-'----for
the above Contract has been considered. You are the apparent successful bidder and have
been awarded a contract for all of the Engineering Oversight activities contained
in the bid issued by the PRP's of the Chemtronics CERCLA Site Remediation on
6/21/91 and the clarifications presented in the meeting of October 2,. 1991.
(Indicate total Work, attemates or sections Of Work awarded)
1.0
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• • The Total Contract-Price of your contract Is 1oi<3l.t Rlolllai;:ea r 1oi<31.to1r fi"'" tol..a11.aRa
_6"-'s"'e""'v,.en"-'-h"'u::..:n::a:.dr"'ed=-.:::&_f:;.;o..:r:...::t..:.Y_-f::.;1:..:· v'-"e'-----Dollars ($ 885 ,. 7 45 • 00).
Three copies of each of the proposed Contract Documents (except Drawings accompany
this Notice of Award. Three sets of the Drawings will be delivered separately or otherwise made
available to you Immediately.
You must comply with the following conditions precedent within fifteen days of the date of
this Notice of Award, that Is by December l , 19 .2!_ .
1. You must deliver to the PAP'S via PAP COORDINATOR three fully executed
counterparts of the Agreement Including all the Contract Documents. This Includes
the triplicate sets of Drawings. Each of the Contract Documents must bear your
signature on (the cover) (every) page.
2. You must deliver with the executed Agreement the Contract Security (Bonds) as
specified In the Instructions to Bidders (paragraph 14), and General Conditions
(paragraph 5.1.A).
AWARDED BY: ACCEPTED BY:
John F. Schultheis
(PAP'S) (BIDDER)
-BY: ·---------(AUTHORIZED SIGNATURE)
PRP Coordinator
(TITLE) (TITLE)
1.1
} ,. • NOTICE TO PROC'fEJ.
Dated November 11 , 19 91 ~~-
TO: Sirrine Environmental Consultants of North Carolina, P.A.
(CONTRACTOR)
ADDRESS: 3733 National Drive
Dare Building,. Suite 120
Raleigh, North Carolina 27612
PAP'S PROJECT NO. J-10101 ---------
PROJECT Chemtronlcs CERCLA Stte Remedial Action
PAP'S CONTRACT NO. __ N_A ____ _
CONTRACT FOR Engineering Oversight with Cherntronics CERCLA Site
Remediation PRP's for Professional Services
(lnsan name of Contract as It appears In the Bidding Documents)
You are notified that the Contract Time under the above contract will commence to run on
December l , 19 91 . By that date, you are to start performing your
obligations under the Contract Documents. In accordance with Paragraph 3.0 of the Agreement
the dates of Substantial Completion and Final Completion are September 20
19 ..2., '. and October 30 , 19 92 · , respectively.
Before you may start any Work at the site, Paragraph 2.5.C of the General Conditions
provides that you and PAP'S must each. deliver to the other (with copies to PAP'S
REPRESENTATIVE) certificates of Insurance which each is required to purchase and maintain In
accordance with the Contract Documents.
2.0 91 · ~
EP -N IV
A'!'!...".~~~ A. GA.
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• • • Also befor:irc,u may start any Work at the site, you must
Copy to PAP'S REPRESENTATIVE
(Use Certified Mall,
Return Receipt Requested)
By
(add 0lhef requirements)
.John F.
PRP Coordinator
(Tlll.E)
2.1
• •
UNITED ST.ATES ENVIRONMENTAL PROTECTION AGENCY
REGION JV
JUN 1 0 1991
4WD-NSRB
Mr. John F. Schultheis
Nimmo & co.
P.O. Box 536
swannanoa, NC 28778
345 COURTLAND STREET. N.E.
ATLANTh. GEORGIA 30365
ffl:.Ct:IVED
J U/,J l 9 1991
SUPtnr., , c;rrrtJND SECT!ON
Re: Agency Acceptance of the Final Remedial Design for the chemtronics
Superfund site
Dear Mr. Schultheis:
The Agency received the errata sheet, dated May 1991, and revised drawings,
dated May 20, 1991, for the Chemtronics Final Remedial Design document
package on June 3, 1991. According to the Agency's records, the Chemtronics
Final Remedial Design document package is comprised of the following
documents:
Final Design Specifications -dated April 1991 -Volume I -Contract
Documents, Bidding Documents, and General Requirements (received by
the Agency on April 13, 1991),
Final Design Specifications -dated February 1991 -Volume II -
Technical Requirements (received by the Agency on March 4, 1991),
Final Design Analysis -dated February 1991 -Volume I -Text (received
by the Agency on March 4, 1991),
Final Design Analysis -dated February 1991 -Volume II -Appendices
(received by the Agency on March 16, 1991),
Final Design Analysis -dated February 1991 -Volume III -Appendices
(received by the Agency on March 16, 1991),
Pre-construction Operation and Maintenance Plan -dated March 1991
(received by the Agency on March 16, 1991),
Full-size drawing -dated and stamped seal on May 20, 1991 (received by
the Agency on June 3, 1991),
Errata Sheet to the Final Design Analysis -dated May 1991 (received by
the Agency on June 3, 1991),
Printed on Recycled Paper
• •
-2-
Addendum to the Pre-Construction Operation and Maintenance Plan -dated
May 1991 (received by the Agency on June 3, 1991), and
Final'Design Modifications -dated May 1991 (received by the Agency on
June 3, 1991).
If this is incorrect, please apprise the Agency as to what documents,
including their dates of origin, should be included as part of the Final
Remedial Design document package for the Chemtronics Superfund site.
The items received on June 30 were in response to comments the Agency sent
the Potentially Responsible Parties (PRPs) and their consultant, Sirrine
Environmental Consultants (SEC), on April 25, 1991 as well as from the final
design review meeting held on May 2, 1991. The April 25 comments included
concerns from the Agency as well as the state of North Carolina and Citizens'
Watch for A Clean Environment.
The Agency has reviewed all of the above documents and concurs with the Final
Remedial Design package as described above. Within ten working days of
receipt of this letter, the PRPs shall submit for the Agency's approval a
schedule _that covers the remaining activities to be conducted at the site.
And for those parties involved in the development and review of the
Chemtronics design, the Agency appreciates your efforts. Please be advised
that· the need for additional monitoring points, surface water and/or
groundwater, will be made after the Remedial Action has been constructed and
in operation for some time. Only then will sufficient data be available to
determine if the existing monitoring system, as defined in the design, is
adequate.
If you have any questions, please contact Jon Bornholm on my staff at
( 404) 347-7791.
cc: Reuben Bussey, ·EPA
Jim Cloonan, SEC
Lynn crosby,'NCDEHNR
Curt Fehn, EPA
Charlotte Jesneck, NCDEHNR
William Meyer, NCDEHNR
Jane Penny, Dynamac
Gary Rowan, Hoechst-Celanese
Gary Serio, Northrop
Ken Skahn, EPA
Bob Watson, CWCE
UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
JUN 1 0 1991
4WD-NSRB
Mr. John F. Schultheis
Nimmo & co.
P.O. Box 536
swannanoa, NC 28778
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
Re: Agency Acceptance of the Final Remedial Design for the Chemtronics
Superfund site
Dear Mr. Schultheis:
The Agency received the errata sheet, dated May 1991, and revised drawings,
dated May 20, 1991, for the Chemtronics Final Remedial Design document
package on June 3, 1991. According to the Agency's records, the chemtronics
Final Remedial Design document package is comprised of the following
documents:
Final Design Specifications -dated April 1991 -volume I -Contract
Documents, Bidding Documents, and General Requirements (received by
the Agency on April 13, 1991),
Final Design specifications -dated February 1991 -Volume II -
Technical Requirements (received by the Agency on March 4, 1991),
Final Design Analysis -dated February 1991 -Volume I -Text (received
by the Agency on March 4, 1991),
Final Design Analysis -dated February 1991 -Volume II -Appendices
(received by the Agency on March 16, 1991),
Final Design Analysis -dated February 1991 -Volume III .-Appendices
(received by the Agency on March 16, 1991),
Pre-construction operation and Maintenance Plan -dated March 1991
(received by the Agency on March 16, 1991),
Full-size drawing -dated and stamped seal on May 20, 1991 (received by
the Agency on June 3, 1991),
Errata sheet to the Final Design Analysis -dated May 1991 (received by
the Agency on June 3, 1991),
Printed on Recycled Paper
. .
-2-
Addendum to the Pre-construction Operation and Maintenance Plan -dated
May 1991 (received by the Agency on June 3, 1991), and
Final'Design Modifications -dated May 1991 (received by the Agency on
June 3, 1991).
If this is incorrect, please apprise the Agency as to what documents,
including their dates of origin, should be included as part of the Final
Remedial Design document package for the chemtronics Superfund site.
The items received on June 30 were in response to comments the Agency sent
the Potentially Responsible Parties (PRPs) and their consultant, Sirrine
Environmental Consultants (SEC), on April 25, 1991. as well as from the final
design review meeting held on May 2, 1991. The April 25 comments ·included
concerns from the Agency as well as the state of North Carolina and Citizens'
Watch for A Clean Environment.
The Agency has reviewed all of the above documents and concurs with the Final
Remedial Design package as described above. within ten working days of
receipt of this letter, the PRPs shall submit for the Agency's approval a
schedule that covers the remaining activities to be conducted at the site.
And for those parties involved in the development and review of the
Chemtronics design, the Agency appreciates your efforts. Please be advised
that the need for additional monitoring points, surface water and/or
groundwater, will be made after the Remedial Action has been constructed and
in operation for some time. only then will sufficient data be available to
determine if the existing monitoring system,-as defined in the design, is
adequate.
If you have any questions, please contact Jon Bornholm on my staff at
[phone].
Sinc~[~ly yours,i
(\ \ ,-\
/:,~ -'-'--" ,!
Donald Guinyard I .,:,_,. \ Acting Dir".c
1
tor
Waste Management Division
cc: Reuben Bussey, EPA
Jim Cloonan, SEC
Lynn Crosby, NCDEHNR
Curt Fehn, EPA
Charlotte Jesneck, NCDEHNR
William Meyer, NCDEHNR
Jane Penny, Dynamac
Gary Rowan, Hoechst-Celanese
Gary Serio, Northrop
Ken Skahn, EPA
Bob Watson, CWCE
State of North Carolina
Department of fnviroriment, 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
Mr. Jon K. Bornholm
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
10 April 1991
RE: Comments on the Chemtronics NPL Site
Final Analysis and Specifications and the
Preconstruction Operations and Maintenance Plan
Dear Mr. Bornholm:
William L. Meyer
Director
The above documents have been reviewed and the following comments are offered:
1. Page 3 of the Final Design Analysis indicates only the North Carolina 10
September 1990 DEHNR comments were addressed. Comments were also
sent on 30 July 1990 and 22 August 1990 which should be addressed. Some,
but not all, of these comments have been addressed. I have attached copies
of these comment submittals.
2. The groundwater remediation levels supplied on Table 4.3 exceed the NC
Title 15A Subcbapter 2L groundwater quality standards. We feel the NC
standards should be considered as applicable remediation goals.
3. The Final Design Analysis does not include any extraction wells in the area
of DAl0-11. Our office does not have a copy of the Remedial Investigation
Report and we, therefore, could not determine whether the groundwater in
this area has been adequately assessed. If possible, we would like to obtain
a copy of the Remedial Investigation Report.
4. I would like to reiterate a concern that capping of the sit" is not a permanent
remedial alternative and will require indefinite monitoring.
Mr. John Bornholm
10 April 1991
Page 2
5. The past disposal of containers at the site now in various stages of decay will
continue to provide a source of groundwater contamination for an unknown
number of years. Groundwater treatment may need to continue indefinitely.
The NC Division of Environmental Management is reviewing the Baseline
Biomonitoring Study. We will forward their comments to you as soon as we receive them.
If you have any questions concerning these comments, please contact me at [phone].
Sincerely, ii
Chr:::!;:,r,J
Superfund Section
CVJ/acr
Enclosures
•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
MEMORANDUM
DATE: MAR O 4 1991
SUBJECT: Review and Comment on the Final Design Analysis and
Final Design Specifications for the Chemtroriics
Superfun~~
Jon K{Bornholm FROM:
Remedial Project Manager
TO: Addressees
Attached are the above referenced documents. These documents
were revised based on comments the Agency sent to the
Potentially Responsible Parties (PRPs) on the Prefinal Remedial
Design documents. Although the PRPs have not obtained a
discharge permit from the Metropolitan Sewerage District of
Buncombe County, this submittal was based on their anticipation
of receiving a discharge permit in the near future.
Please review and comment-on these documents by
March 22, 1991. If you are unable to get your comments to me
by this date, please call me and let me know when you will be
able to submit your comments.
If you have any questions, please contact me at 347-7791.
Addressees:
William_Bokey, ESD.
'.Le-e Crosby, NCDEHNR (w/o · ~ttachmentl) }
Bernie Hayes, G-WTU
Charlotte Jesneck, NCDEHNR
Jane Penny, Dynamac
Winston Smith, APTMD
Camellia Warren, RCRA
Bob Watson, Citizens' Watch
Printed on Recycled Paper
20 February 1991
MEMORANDUM
TO:
FROM:
RE:
File
Charlotte Jesneck
Superfund Section
Chemtronics NPL Site
Review of the Final Design Analysis
•
I telephoned Jon Bornholm with EPA at [phone] today to inform him that our
office would not be able to review the above document by 22 March 1991. I told him that
we would try to complete our review by the first week in April, but that it may take longer.
Jon said that the delay would not be a problem.
CVJ/acr
• • Ji,
UNITED STATES ENVIRONMENTAL PROTECTION AGE~t~
REGION IV _('1, ..toy '/fl~
4WD-NSRB 345 COURTLAND SlREET. NE ""' <f 6' 'U
/\Tl.ANTA GEORGIA 30365 ~b~ l.9.9o
Mr. John F. Schultheis
Nimmo & Co.
P.O. Box 536
Swannanoa, NC 28778
~Q,i,
RE: Comments from the Citizens' Watch for A Clean Environment on the
Potentially Responsible Parties' Responses to Comments on the
Prefinal Remedial Design for the Chemtronics Superfund Site
Dear Mr. Schultheis:
· Enclosed, for your information,:is a copy of the comments I received
from Bob Watson on November 13, 1990. In Mr. Watson's cover letter, he
refers to comments from Jim Kawecki and Greg Richardson. Only comments
from Greg Richardson were enclosed with his letter.
I believe the revised Operation and Maintainance (O&M) Plan will
address a number of the identified concerns. Some of the other issues
are professional interpretations of methodology and the Agency is not
interested in pursuing an academic debate. The most important element
is to begin the remediation. As we have discussed previously, the
burden of proving that 1) the groundwater extraction system in each
valley is adequately capturing the plumes of contamination and 2) the
remediation has accomplished the set goals rests on the Potentially
Responsible Parties (PRPs). It is my understanding that the revised
O&M plan will identify the necessary monitoring points to allow the
assessment. of the groundwater extract.ion systems as well as the
frequency of collecting groundwater samples for analytical analyses.
If you have any questions, please call me at [phone].
Sincerely yours,
Jon K. Bornholm
Remedial Project Manager
Enclosure
cc: ·Lee Crosby, NCDEHNR
William Hamner, NCDEHNR
Jeff Impens, Sirrine
Charlotte Jesneck, NCDEHNR
William Meyer, NCDEHNR
Jane Penny, Dynmnac
Bob Watson, Citizens' Watch (w/o encl)
f'ri11ted on Recycled Paper
•
CITIZENS' WATCH FOR A CLEAN ENVl[RONMENT
November 12, 1990
Jon Bornholm
US EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365
Post Office Box 956
Swannanoa, North Carolina 28778
Re: Chemtronics NPL site
Dear Mr. Bornholm:
I enclose comments authored by Gary Chirlin, Jim Kawecki and Greg Richardson
in response to the PRPs' comments (October 2, 1990 document) on Chirlin's (et al.)
critique of the 95% design document for remedial action at the Chemtronics site
(see Chirlin's August 11, 1990 document). Dr. Chirlin, and through him Kawecki
and Richardson, as you know are technical consultants hired by Citizens' Vl'atch for
a Clean Environment with a technical assistance grant from Region_ IV EPA.
Citizens' Watch for a Clean Environment strongly urges you and yom· colleagues to
carefully study the enclosed. There are a number of areas of deficiency in the
remedial design which have not been adequately addressed by the PRPs. Dr.
Chirlin's and his colleagues' technical assessments enclosed are fully endorsed by
Citizens' Watch for a Clean Environment.
In addition to the enclosed, Citizens' \Vatch will be sending comments under
separate cover. We assume that the original October 19 deadline for this round of
comments is invalid; CWCE received the PRP document on October 18.
Thank you, Mr. Bornholm, for your continuing efforts to effect an adequate
remedial l_lClion for this Superfund site in our neighborhood. ·
Sincereu •
Ow ~r Bob Watson 1
• Chirlin & Associates, Inc.
, : .-':,.:'"c.,. Consulting
,•Engineering and Hydrogeology }ii1f {\:·'. : .. : +, ..
:;:· r.i· -.-.:=,-~ •. :;'..'i'.,,,:-_,, ·:•'\,
i~:ir;::.:::;;~'.\·,·;:,tt~'.~1f ~:\:'1{ttWi:I;trittf f /' ···
• 18 Anamosa Court• Rockville, MD 20855
[phone]
November 6, 1990
, .\ -
,.
•
Chlrlln ~ Assoclates, Inc.
Rockvllle, Maryland
November 2, 1990
REVIEW OF
''RESPONSE TO CITIZENS WATCH FOR A CLEAN ENVIRONMENT
PREFINAL (95%) REMEDIAL DESIGN
CHEMTRONICS ~IT~ REMEDIATION
·ocTOBER 2, 1990
SIRRINE ENVIRONMENTAL CONSULTANTS
Comm~nts from CWCE (CHIRLIN)''
These comments follow the same Item numbering scheme as that used
In both my original ( 11 ·August· 1990) c·omments and the PRP ( 2
October· 1996> response (herein "Responie").'· ·-
GENERAL
My original review of the Prefinal Desl~n Analysis <PFDA> and
precursor documents found the field lnve~tlgatlons Inadequate to
.de'fine' the extent of contamin~tion,·:'and·:ti1°e p·roposed monitoring
-lnsuffl6)en~ to confirm containment oi'f1iariup of groundwater
contamination. The Response do.es.'somei,hat· expand the original
monlto~lng plan, although details are 'sketchy. Hoi,ever, I : ; . ~ :c#,fi't,;;p-}.~ ,_to:,be l i eve , tpa:t ,_thii_-'P,1".0P?seg° ;a.'6fipns may not con ta In all
····contamination onslte·and i,111.·riot resolve:the·fate of all known , ·,·~•'""'.,.·" .. -' .. •,-. .. ,.... :~"·\'·• •··::·_or: s_us·pec·te'd c·on tam i nan ts.-·,. -· · ,_-,_;._:·:,,.;,--.--•. -·· ·. -~'.."'.?/.-:.,:Jf;\r .<-.. ·: -~---. · -,--:~----·~·~:-__ ..... -.... i! ·:<: ·~-\t~•~_:_,
The_·Response ·proposes.~everal change~ Jn_the monitoring program.
·A.new-operation and maln·t'e'na'r1ce manua1';,1s;_fn preparation which
.'will describe these chari:ges ,and.which V1'i1··differ substantially
.from ·1:h·a't .'.Included ·with the PFDl\;·.·-Because·.of the critical role of
mo.riltor·ln:g at this site·, I u'rge· EPA ·to submit that document to
CWCE:~~d other lntereited partlej·for tlmeli fevlew .
. \ ~-:~~ ·_..,.J/' -. .<r ·--. ""• . -· . -_; ...... :1;,::
~ . : ' .. . ' . ITEMS '"
1 .. Of course one Is not comforted by blinket statements such as .
"No waste materials were placed beneath the .water table during
· · .disposal"· or "l\ny leachate w111 ··be -collected.and treated .through
· .· the_gi:--ci_u:1.~1;1a_ter, remediation sVst_em.;'~NeJther'·;s1rrlne, nor the PRPs.
are .in a position to know whether these·statements are true:.· . . .. , .
The RI, through Its test pit explorations, -defined minimum ... -.
depths-tci-waste:at three (Dl\-10/11,;,7/8,,:and.6) of.the .four :c--;.,
disposal areas k·nown to have received so'lld ·or·.con·talnerized
wastes (see 'RI tables 2.1-1 t~rough :.·2·.·1'-}f and Append ii: K) .. Two
. . 1 . ..... ·.
•
Chirlin & Associates, Inc.
Rockv 111 e, Maryl and
•
November 2, 1990
other areas, DA-23 and the Acid Pits, are presumed to have
received only liquid waste. Now that the drought Is over, the
PRPs should not find It unreasonable to once again measure depth
to water In existing wells near to the DAs, and to compare these
.observations to the depth to waste. This Is not a burdensome
task, yet It could reveal Important Information. PRP reluctance
Is akin to the argument "If I don't look for lt, It isn't there".
As an example, the depth to waste In DA-9 has ncit been
established, although It did receive solid waste Including drums
. <e.g.; FS Tables 1.2 and 1.3 and page 11). From chemical anilyses
·of_ boring soil samples, the RI concludes that wastes were
"apparently placed In a trench or pit having a bottom surface 10-
15 feet ·below the existing ground sutface" (RI pg 3-89). In
drought year 1986 ground water was 8.6 to 10 feet below land
surface (bls) at adjacent well SW-9 (RI Appendix F-1), 7 to 14
feet bls .at __ adjacent wel 1 S\~-8 (RI Appendix F-1), 15 feet bls at
.· ·interior boring DA9 7 2 <RI Appendix C) and 16 feet bls at Interior
~-· .b6itrig DA~~1\_(RI .. A~pendlx C). Depth to ground water Is probably
-. shallowe~ n6~. and the possibility of submerged waste at DA-9
. . appears to be_ h I gh . . ~ .. ·> .. : ... ::,ii, :i ... ~2' •·:.·-.\ .. •' .. ('\,. '.< ·!• ,: .·•• . •• .. ' ..
:·~·'}1{ti:M'.1~i"f;-~~-R~·SpQnst::ci}Je'~:~ ian ·:~ndocu men ted 'f Ind Ing that ground 11a ter
·.:-: i._':';./_.)1,'":'e_le_vat_lci'n_·at_-M85_I2 ;"_actually decl lned" since ·1986. Of course,
·~-;:.:?.·-~.i\:Ji~'i;;~:(.tJ:\o'ut r-ffe"rence':or access.to the dat·a It ls lrnposslble for any
:.· . .;'_-:;,-:),;,;fo-;.·.r.evle,wer -~o._dlrectly judge this statement. However, the RI
_1_,•,:i,·tks:.•.,<~ppendl_x --p-1, _.where _this well Is l lsted as M85L12) shows [!.Q.
,.-· ... :•.·.,_-,·· .. ,,•.::readlngs ·pt_.water lev_el measurement at M85I2 In 1986, and the CDM
: '.';·:\:·;,:_-.> Work Plari ·c 1985) .Table 3-3· footnote states that 1185!2 had not
.. : .· ~-·.:·.'.'.'\i:ieen sampled since June o·f 1983. So there Is a posslbll lty that _;·_.:7_·.·'.:j:_\' .. th_e PRPs have·mlstal<enly compared data from two different wells.
,~.·~-~{~rJin any.'case M85I2 Is not within the watershed of any of the
'J't'::::.J/.,{\'d)spo·s_a_l ,;areas. Even lf the PRPs Irresponsibly chose to examine
·'.': ., ·:·_:., .only one .we11· on this· Issue, M85I2 would ·certainly not be a
. . , .. representative. selection . . . . . ~ -: -. ,.,_.
. _ .· ... i 2 .. I applaud EPA's dec!.slon to take a surface-water sample at
_\;J;:_.~;:;;/B_f:-?.i .... ~A;-,~:.~~nd B11:-4 for TCL/TAL parameters·. The _Chemtronlcs
:' ,.,:;.:.,,·. ,.Superfund .site Is very unusual and offers a tremendous • ., ••• _ . •. i ri;!i,: ,·or .,r,r ~--•• •.--• • -~ _, . . · •'.· ·:, .. ·opportunlty·for accurate measurement of offslte transport of
water-borne contarninants. This Is so beciuse most contaminated
ground water collects naturally onslte Into small, accessible
•:,;.,,"c:":;,,,,,, .• ,'surfa:s:e-\v.ati,r-str.eams .. · ... ·····-.· ...
':''·'·,'.:_::'-."fti'e :t1te ·br;les·out for routine ~hemlcal ·sampling of these
•
Chirlin & Associates, Inc.
Rockville, Maryland
•
November 2, 1990
streams. A great amount of uncertainty can be removed by
routinely monitoring the streams for the Contaminants of Concern.
Questions on placement and number of monitoring wells <which can
"miss" all or part of the multi-contaminant plume, laterally or
vertically), existence/location of unidentified disposal areas,
'depth of wastes (are they at times within the saturated zone?),
and performance of the cap and pump & treat systems all become
less critical when surface-water contaminant transport from the
site Is adequately monitored.
Once again, as the Response acknowledges to KAWECKI, the
bioassays do not serve to monitor potential health risks for
humans., The bioassays do not in any sense replace chemical
monitoring of the surface waters.
3. In the RI, bis(2-ethylhexyl)phthalate is reported in soil
samples from borings at DA-9 and this occurrence is attributed to
waste.containing the compound (RI pg 3-91). When nearby (SW-9,
BW-8) ground water also contains this compound, it is ascribed to
well installation or laboratory contamination <RI pg 3-97); this
dismissal is also made for other wells adjacent to the Acid Pits
<RI pg 3-74). The more straightforward interpretation is at least
equally plausible: the contaminant was found at DA-9 and
therefore probably also exists at the Acid Pits (although not
detected there in soil samples), and has contaminated the nearby
ground water. Another round of sampling could resolve this issue.
I found no description of "QA/QC procedures used to validate the
RI data (which] determined the bis(2-ethylhexyl)phthilate found
In groundwater analyses was not site-related." The RI statements
cited above are data interpretations, not QA/QC data validation
procedures.
4. This comment is so unresponsive that I need not address it
further.
5. I reiterate,.there is no presentation of any existing
contaminant plume In the RI or other site documents. The modeling
exercises cited by the Response show only prediction~ of cross-
sectional contaminant transport after 25 and 50 years, and these
models depend on several questionable assumptions. I state again
that any rational site assessment and clean-up design must
include an estimate of the distribution of existing
contamination. And If such an e~timate cannot be presented in
defensible planview and cross~s~~tlonal diagrams, then eith~r the
3
•
Chirl in & Associates, Inc.
Rockville, Maryland
November 2, 1990
underlying monitoring data or the analyst is woefully inadequate.
This particular shortcoming of the site work is embarrassing and
beyond any excuse: ·
6. I accept this ~esponse, presuming that SW-2 and BW-2 will be
• selected for long-term monitoring.
7. For the most part I accept this response, presuming that
monitoring will continue throughout the design period of 30
years. However, I would much prefer sampling more frequently,
both to obtain better resolution and to avoid aliasing. For
instance, by sampling every 9 months the sampling time would
change season from ~ne year to the next, so that over each 4-year
cycle every season would be sampled.
8. I apologize for my shorthand; throughout my comments (both
!!Aug and these) I use "BZ" to indicate both the parent compound
and its degredation.products.
To the best of my knowledge, the only Front Valley wells sampled
in 12/89 were STW-1 and DTW-1 (PFDA TAble 3. I), arid these samples
were each taken at the close of an aquifer test which pumped
those wells. First, this type of sample .Is not comparable with
one taken from a monliorlng well using standard purge-and-sample
pro6edures, in part be6ause the pumped well· Integrates over a
much larger are~. Thus concentrations may be diluted or
strengthened depending on contamination in the contributing
volume. Second, STW-1 and bTW-1 were not previously sampled
anyway, so there is no history over which to make comparisons. If
the Response is comparing two different wells In order to
establish a temporal decrease from 1/89 to 12/89, It should
certainly state this! Using two well; to define changes over time
is a very dubious procedure (a model of contaminant transport
between the wells is required, explicitly or ,otherwise). If in
the present case those two wells are (as .. I s~spcct) SW-4 in 1/89
(BZ/benzophenone=3400 ug/1) and STW-1 ih 12/89 (BZ/benzophenone =
2200 ug/1), th~n the so-called decrease may actually Indicate
increased migration down-gradient, and climbing BZ levels at both
well locations. The Response statement on declining BZ levels ls
at best very misleading, and should be ignored. ·
Concerning the argument that Increases In BZ may be attributed to
laboratory .variability, I appeal to the same QA/QC procedures
Invoked by the Response in Item 3. Lacklrig'evldence to the
contrary, an unbiased observei•~ust presume .that the apparent
4
., ... '.
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Chirlin & Associates, Inc.
Rockville, Maryland
trend is real.
•
November 2, 1990
More to the p6int of my original comment, I continue to believe
that sampling for·CS and BZ products was Inadequate in the
surface waters of'Front Valley. I continue to support additional
sampling, Including but not limited to that being conducted this
autumn by EPA at BA-2, 3, and 4. DA-23 is a perfect example of a
site where BZ products probably enter the surface waters, but
surface water monitoring is inadequate to detect it. Routine
sampling of Unnamed Branch adjacent to DA-2:t~would provide the
opportunity to confirm ground-water containment by the cap and
_ pump & treat systems, by showing that contaminant seepage to the
stream in that vicinity had ceased.
9. Pleas~ allow CWCE to comment upon the PRPs' planned piezometcr
distribution prior to acceptance by EPA.
10. The Response is .Irrelevant. My comment 10 concerns ground-
water quality :moni taring. The Response's Item 9 concerns
piezometers foi·zone-of-capture estimation. Please allow CWCE to
comment upon the PRPs' planned water quality monitoring network
prior to acceptance by EPA. . . . ··-
' 11. !he Response is again irrelevant, again for the same reason.
. . :: t
·12. Y accept that samples of pumping wells are not readily
comparid to .those from monitoring wells. Nevertheless the pumping
well samples •do provide useful, and unique, data because they·
in~egrate·over an area much larger than the "streamtube" sampled
by a mori'i tor.ing w'el 1. I agree to the plan to sample the pumping
wells when•~he 0 remedy is felt to be complete, providing that
"complete" ·means that contaminant levels in monitoring wells have
dropped below"·remediation levels. Concentrations in the pumping
wells sSo~ld then also ~eet remediation levels in order to
justify cessation of pumping.
13. There is little doubt that the Response has deliberately
misinterpreted my comments. I object to the "evaluation of
contaminant distribution" procedure not because it proposes
·isopleth maps, but because the monitoring program takes
insufficient data to draw these maps. I continue to urge that
sufficient water quality monitoring wells be installed to define
the extent of contamination! An adequate monitoring well network
will make it possible to draw tµe Isopleth maps proposed by the
. PO&M.
5
•
Chirlin & Associates, Inc.
Rockv i 11 e, /1aryl and
•
November 2, 1990
I accept the revised plan to use the site Contaminants of
Concern, rather than other indicator parameters, in Interim
analyses of ground water, and full scans prior to proposed
shutdown.
14. I tiontinue to urge routine surface water monitoring as a
component of the operations and maintenance plan.
15. I strongly disigree that the proposed bioassay monito~ing
will adequately characterize surface waters at this location or
elsewhere.
I continue to urge sampling of the intermittent stream from
DAI0/11, should it reappear during the life of the cleanup.
Frankly, one water quality sample (6/6/86) of one shallow well
CSW-2) and an immediately adjacent deeper well CDW-2) does not
provide a strong argument th~~ no leachate is moving into the
ground water from DA-10/11. A well samples a narrow corridor of
flow. Either mor·e monitoring wells or perhaps (as I suggested
earlier) pumping of the existing wells to widen their sampling
zone would provide needed spatial cover~ge. And once again,
routine chem !cal sampl Ing of Unnamed Br-anch ··would prov Ide bottom-
1 ine information which ~ould reduce _the risk of shortcomings in
the well monitbr!ng ne~iork.'
I find the Response's depth to waste argument for DA-10/11
encouraging, but would be more confident if water elevations were
obtained from wells adjacent ,to DA-10/11. Water levels in
hillslope wells (such as those next to DA-10/11) tend to vary
much more widely than in wells near to a discharge area (such as
the four ~ells cited in the ~esponse).
I leave interpretation of • incidental dep_osition" to EPA.
16. I thank EPA ~or thi~ change.
17. I presume that Sirrine took notes on the conversations or
observations leading to better definition of the waste areas.
These notes should be part of the public re6ord, and should be
produced when, as in the present case, they have b~en requested.
A typo_graphical error exists in_.my original comments. Not TCE,
but rather DCA increased between RW-12 (230 ug/1).and RW-10 (400
6
•
Chirlin & Associates, Inc.
Rockville, Maryland
•
November 2, 1990
ug/1) downstream of all known disposal areas. Unidentified
sources exist on this property (e.g., RI section 3.4.11.1), and
the best way to keep tabs on the net offsite impact of these
uncontrolled sources is to routinely monitor surface water
chemistry.
18. My comment refers not to the region around DA-23, but rather
to the Front Valley as a whole, given the apparent existence of
unidentified sources <see original comment 17, as corrected by 17
above).
The Response does not state which wells are the "strategically
located monitoring wells ,, , downgradient of DA-23". If these
refer to the proposed DA-23 monitoring wells (SW-1, BW-4, and
hopefully M85L4 and M85L10), then the wells are not in the area I
discuss. If on the other hand, the Response refers to wells along
the lower Unnamed Branch (BW-~. IW-1, M85Lll, BW-13) then I have
two comments. First, .this group does not include any shallow
wells, and at this site the shallow wells reveal most of the
contamination. Second, this is th~ first indication that these
wells may be routinely sampled, as must be the case if they are
to "ever indicate that contamination is present." I do welcome
,·-,.~};;;r,i,::.::.the ~-13p~· ~iU ingness to monitor these wells and loo!< :orward to
__ :.•._-,:;>-·-:i•,_conf1rmat1on and details. I must note, however, that 1n the past
·,,::--,-,_:·:·.·::.the_ appearance of contamination at one of the 1·1ells < 170 ug/1 of
-:.·,:_.'/;·_ ·.· ·:TCE at M85L11) did not lead to any action. There'fore a change of
.... ·_-.··_-•attitude 1i'ill be required,
..
' -:.;-~.
19. I stand by the original comment.
,, .• -~ :.•·,' .. _ I '. '20. stand .,·., I by the original comment.
" ·, ·',•'•'·· ,. '
·.:->-.. -J,;;i: -.'21.. I ·stand by my comments. The width of the capture zone is . • _,. ··i, , .. -. .
,.•J'c:.t,·,-. overestlma·ted by the method _of the PFDI\. This is the case because
the two wells are so close together (17 f~et laterally and 15
feet vertically) that drawdown induced bV one will also reduce
head at the other. In particular, drawdown in the shallow well
STW-1 was alreadi 63% of available drawdown and within the screen
'-· ··.during the·STW-1 pump test. When both wells are pumped, drawdown
. .,-. in STW-1 will be even deeper at the same yield, and 1iill induce
less regional drawdown due to the thinning of the saturated
thickness. The upshot of all this is that in order to create the
_predicted zone of capture, the system will have to pump more
_water than the total pumped in the two tests. This is possible,
-but the necessary yield should be quantified so that adequate
7
• •
Chirlin & Associates, Inc. November 2, 1990
Rocl<ville, Maryland
treatment capacity is assured. I note that RESSQ will not perform
the required calculations because the third (vertical) dimension
is probably significant and cannot be modeled by RESSQ.
I too enders~ careful monitoring of the capture zone development
during system startup. As discussed in ftem 9 by the Response and
myself, additional piezometers will be required to make such an
assessment.
22. I stand by my comments.
23. At the least, analyses should be performed which separately
quantify the two principal forms of dissolved chromium, namely
trivalent and hexavalent chromium. The latter Is a much more
toxic form and would not be attributable to the background.
24. Actually, it would help to know what chemical compounds occur
in the fire retardant wastewater. And I repeat, what volume of
fluid escaped?
25. The Response is not responsive to most aspects of my original
comment. I continue to believe that the extent of the plume
. downgradient of the Acid Pit is undefined and may be entering
Beetree Creek. The single .well BW-ii ls.uiieless ·as·a monitoring
'.well for ill of the rcas~ns I cited (not only the Injected water
problem); ·
Although I could wait until after. the two monitoiing wells are
Installed down~ra~ient of the extraction system,· I am fairly
confident that those two wells will show contamination at their
proposed locations (Response 29). Why not get on with It and
install the natural water quality monitoring pointi (Keely 1989)
needed to detect out-of-control conditions for this plume and
remedial ·method.
26. I accept this comment. I urge EPA to consider my original
comment when particulars are proposed by the PRPs, and to submit
these plans to CWCE foi timely review.
27. I welcome a monitoring program for DA-1/8. The (ncluslon of
SW-8 for this purpose ls less welcome, principally because it
does not sample ground water from DA-7/8 at all. SW-8 is located
on the far side of the "drain" (Unnamed Branch) from DA-7/8, and
immediately downgradient (I suspect) of DA-9. There ls presently
no well appropriately positione"d to monitor ground-water qual lty
8
•
Chirlin & Associates, Inc.
Rockville, Maryland
from waters passing beneath DA-7/8.
•
November 2, 1990
28. I was incorrect in my original comment 28, having misread
PFDA Table 3.2.
·29. I stand by my ol'.'iginal comments.
I would welcome comments by the PRP or interpretation by EPA
concerning the function of the pl'.'oposed wells MW-I and MW-2. Are
they to be wells within the plume ([internal) plume monitoring
points> which must clean up pl'.'iol'.' to system shutdown, ol'.' are they
to be wells beyond the edge of the plume <natural i;ater quality
monitoring points) which pl'.'ovide out-of-control detection? The
same well cannot serve both functions. I urge that both functions
be provided by adding additional wells as necessary.
30. I accept this response, and urge that CWCE be given
opportunity to review the pal'.'ticulars.
31. I accept this correction.
32. See Item 12 . . ·: ~f.;;t;·~=-.~ ;:;. ... ~
· ;:/['.)):\.-33_: See (tern 2.
. ~·· , ..
-_ 34 .. I st~nd by my comments here and in Attachment A. I agree to
,·. field confirmation of system pel'.'fol'.'mance. Please allow CWCE to
review such system start-up performance data in a timely manner .
:-•··::.-:t .... ,
·•-;",;
-··.)
9
'\_,:•'
•
October 31, 1990
Gary Chirlin
Chirlin'& Associates
18 Anamcia Coi.u:t
Rockville, MD 20855
Dear Gary:
COiiPORATION
_.Ai,;_. pe~, YC>)J.r request, · I have reviewed pages ·:12 . and 13 of Sirrine
Env::irorunental Consul tan.ts (SEC) . response to. in:{ earlier review of
.. : their des·ign of the· Cli.emtronics Caps. rn:'.general it appears that
:_: SE_C has .. done ·a 'veiy::·c:"o.riscienticnis revie\f~of :•my ··co_mments and have
.,-, (or ···already had) .. j:Jrcivided .,.desi.gri' changes'' ·to ·meet. my specific
·concerns. Two specific items· remain that you may wish to clarify:
1) Composite Barrier: The current ·RCRA Technical Guidance
Document on :Final ·covers. for Hazardous ·.waste Landfills
· and Sur'face·'Iinp6un'c!ments· (EPA/5·30.:.:sw-80-"04 7 )' .requires the
:·"i(o'ii?':'c'cirnponeht {iti:i ',hiive',ia''?p,/m~~bilitY :i'es·s . than 10-7
'' ., ·. : ··•cm/ sei::/>•··:·Actg.?, tionai_ly ,,'.,'.r._}'~m'~:cVf:re·ntly ', ·.'eai ting . a EPA
. manual ·f_o_r cJ.osure ;.of°"CER_CLA la"i-id_fj_lls ... that is generally
, . ., , a·dOptiiig :·:tl1is~;·c'i.-{t,!iria· ;°,:,:;;The· /intent '.of 1RCRA is not to
., .. ,:.I: •· .'.·.:. ·.:: '.:aiio~i")iic:r11·:c·erin~'ahliit'"l~'6l1i?,:::1:o-:l'l:ie 1·i'i.sec:1 :,-iiL'i:.lie· ca . if :·:~;~ :· . , ~.r .-· ,,,.,,.,.,._!t',".:~:· •,,:;)~~r-~;::~':f,,"' ,.-::,-, ~-p•.,Ys.-;.'l,.., .......... t,;'?'•••-.1,;.;..,,.,...~~:, ..... ~,:~1-:1.,1~ ·-• P .
-~. :,1-... :·,-: ,I ~:·' /1~:~.:2.i,;_~-~qh.~7_~,R~~} .. ~ .. \!i~}:'?~t:.~~~1¢~? :i1?~JJ?qf,11 ;2!~~-~~r~~~~st;:~';·~f/0'..I.!1, fact 'the
· '"· · · .. . . ._ .'.:'_:':,; •.t.;-P_I,~SJ~C:,,e,.,1?_(_;-,.h.l._gh}:p~rmea):>.1.J.1. ty-nto~_l_s_ [_b_E!_I}§lat):i t)1e waste , '·.· ·'-"·· >.' ~--.. \:v~~.1-~ i'.i!.af,f_i!_Ye.yfn\m,ft:e}l,mperaft.y,f)_:.h~f;thei.:',c'?i'nPDSi te. cap .. 0::,/ ... ~-: .; :. -'. · ;:·· /,;m~Il_!i:rii_z,~.i ~!i:f: i_l:t:10}(tign ;:int:,o. /th~.~~1t§.te/,,.i; To .. : !,)e · candid, I :\. •, '--~ .:.i;·/t .. : ~-~;. hav_e::,;;i,~i;j:>\0<'!:,i,s~d,~•:i1.¢,9n,c~,r,1\j: .. regaf~.ii:i_g 1,:;<th~ ") long . term -• .. ,·• · ... ::. survivability:,cif :,10-?, i:so"ils :ln ·capi"i";and .would prefer 10-s ~ ~ '. ': ... ~;\.:'. ·: .;;,: -: · '{:to "'._"i0\~ . ~·sci'ili(\.\i-,l t~'"' fricreasea.-,~'.CQA:':'¢'of -1,,the .'membrane . :•/·<. • . ' . -·· -~-... "···'-1' , •.. --~·•,,,., .,.,...,, '{ .,. • ·---~ .. '. ' .. ·~'-•·. . '.. .... . . ::/;'_;i_n·st?l_latio,~,::. ,'Thu~·.r. j·l?:'.1.d. be·_.c,:~mf9,:it_able with the SEC
, .. :··· .. ,. · .. ,.);~'.~;: c_ap ·1,tr.th_!j?Y.'~an.·.d~mqf!s..trate even_":this :increased level of ·· ·': f!-·:::~!. ,'.~.:; : :·: ~-?~?:0 i. \~.::~:~~1~~?.J;!fJr..qt'.;i~('.;~:t; ; ' '?:'.~f &~tit(}.f /;' · ·:-· · .
( 2) ... Dif feiontial Settleme'nts: ,'. :·.AllOwable limits on
differential .settlements should be ·established at this
. . ··.time·: .•" · Such allowable' ·differential· -settlements are
... :;_ \ · .• :: .; . ,,,~;,.,;::: !:YPl~.~xl :Y:/ ~:;,n~rci~.J,.<i,do . ~Y:>;::he. )!3~():i~-f:c_cmip:m,ent . of . the
: ... ·., ,;. ·,._.,: ;· , , .. .:bJ.~ !~ c'?n.ipos ,::.\~,:,bar:t' 1.er ._-,/A ;tyj)tcal _r_i.\~ge_09.t._:~cl._x:unum allowable
.-·-···•':-::_.?. ,.; d1.fferent1.al settlements :base :on· ,the soil component is 1-
. . . 2%,. Ad<:li t_ionally'/' the''repair 'proce'dure to be _used in
·.·· .. ,:_.the __ event .o.f. excessive differential :set_tlements must be
.;:·.>.,establiBhed ·at this time·,,-.... ,; •. ,.,, .... t,· .. : .. ,\/,;:,;, .. •· ...... ·,·. , ... :, '.' .. ' ' ' ' ;;";;I .· ·: t!,~ !;} .' ' '{ ·'.~";\i?~ilf './ii '' '
.·-·· ~.::~~-.Ti Os ·01d· l:h(;:~\_:f ~:iii~· iicl. ~ ·1·figi1'\l;i;-;i'~ 1"~1(. '/f}~:iIJ::M:~r~-~$~8~:.1~~~1':!a'.x ~}~:882-7958
____________ ,_ .. , ·.··,c .. -·------
\ '" E'NVII'O","Il''-'"';,: C:,'f"'JC'•' co· 0MP .. ANY0
.... t.,'\ '-JI~ ... 1 .... ••··•"-" ,...,
,:::-:GINEERING • :\S,;1-:s.•;:.1!-::-:r • SITE REMEDIA110N :
Gary Chirlin
Chirlin & Associates
'November 1, 1990 Page 2 . .
..... -..
·/ '-/::.J·;
•{:;}\~\' .
should be considered by
if you or · CWCE have gii:esti~ns . :. ~-:;• . -. .
P.E.
MEMORANDUM
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
DATE: OCT O e !SSO
SUBJECT: Review the :Potentially Responsible Parties Responses
to Comments on the 95 Percent Prefinal/Remedial
(Design fof the Chemtronics Superfund Site
.(11 i< h_:,y,..,:. ,____
Jen K. Bornholm FROM:
Remedial Project Manager
TO: Addressees
Attached for your review is a copy of the Potentially
Responsible Parties (PRPs) response to the Agency's comments on
the Prefinal (95%) Remedial Design for the Chemtronics
Superfund site. The Agency's comments included a compilation
of comments from various Region IV EPA programs, North Carolina
Department of Environment, Health and Natural Resources
(NCDEHNR), and comments received from a local citizen group,
Citizens' Watch for A Clean Environment. The citizen group are
recipients of a Technical Assistance Grant (TAG). Please
review the PRPs' response(s) to your comments, as appropriate.
If I do not hear from you by Friday, October 19, 1990, then I
will assume that the PRPs have adequately addressed your
concern/comment.
If you have any questions, please contact me at 347-7791.
Addressees:
Bill Bokey, ESD
Lee Crosby, NCDEHNR
Bernie Hayes, G-WTU
Charlotte Jesneck, NCDEHNR
Bill Meyer, NCDEHNR
Jane Penny, Dynamac
Winston Smith, APTMD
Camellia Warren, RCRA
Bob Watson, Citizens' Watch
Printed on Recycled Paper
•
October 2, 1990
Mr. Jon K. Bernheim
Superfund Project Manager
U.S.E.P.A.
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30363
NIMMO & CO.
Consultants
P.O. Box 536
Swannanoa, NC 28778
[phone]
•
tP A -JltGION IV
ATI.ANTA, GA.
Re: Responses to Citizens' Watch for a Clean Environment Comments on the
Chemtronics Site RD Pre-Final Design Submission of 95% Design.
Dear Jon:
Attached herewith are the responses to the Chemtronics Pre-Final Design submitted on
27 June, 1990. These responses are directed at the comments transmitted to the
PRP's by EPA's letter of 24 August, 1990, which only included the comments by the
Citizens' Watch for a Clean Environment technical advisor.
If you have any questions on this submission, please feel free to contact me or Mr. Jeff
lmpens of Sirrine Environmental Consultants at [phone].
Sincerely,
J.1: ~ £. Schultheis
PRP Coordinator
cc: Ms. Nancy Baldwin -Northrop
Mr. Joe Eggelston -JRC
Mr. Gary Rowen -Hoechst Celanese
Mr. Craig Bromby, Esq.
Mr. Jim Wrathall, Esq.
Mr. Tony Young, Esq.
Mr. Jeff lmpens -Sirrine
J-10101 file
• •
RESPONSE TO
CITIZENS WATCH FOR A CLEAN ENVIRONMENT
PREFINAL (95%) REMEDIAL DESIGN
CHEMTRONICS SITE REMEDIATION
OCTOBER 2, 1990
SIRRINE ENVIRONMENTAL CONSULTANTS
GREENVILLE, SOUTH CAROLINA
El'A -RtGJON IV
ATLANTA.GA.
• • Comments from CWCE (CHIRLIN)
GENERAL COMMENT: The following statements refer to the groundwater monitoring
program, its current status and overall philosophy. First of all, there is a strong commitment
by all parties concerned to take appropriate and necessary steps to adequately remediate
groundwater contamination and prevent further contamination from occurring. In order to
accomplish these objectives, we recognize the necessity of developing adequate monitoring
programs in conjunction with the extraction systems, and monitoring the dynamics of the
groundwater flow as the cones of depression and capture zones are developed. This
monitoring will yield the best possible data for the evaluation of the performance of the
groundwater extraction systems. If this information indicates that adjustments need to be
made, then they will be implemented based on a more extensive data base. This will allow
for the most strategic additions, to both extraction and monitoring systems, if indeed they
are necessary. Therefore, extraction and monitoring are dynamic processes. The
processes are used in conjunction with each other so that with careful evaluation, the
appropriate measures can be implemented to make the remediation both efficient and
effective.
The operation and monitoring manual is currently under development and the existing
document is only preliminary. Several items are under development and were not included
in the preliminary manual. These include monitoring the performance of the caps and the
need for additional monitoring wells and for piezometers. These and other issues will,
adequately, be addressed in the finalized plan.
Item
1.
2.
Response
No waste materials were placed beneath the water table during disposal. Any
leachate will be collected and treated through the groundwater remediation
system. Data are available for wells M85L4, M85L 10, SW-4 and BW-4 in the
Front Valley. The maximum fluctuation was 9.75 feet, which indicates that the
water levels have not risen into waste in that area. Data are also available for
M85I2 in the Back Valley. The water level in this well has actually declined since
1986. Long-term groundwater monitoring down gradient of capped areas will
be conducted as part of the groundwater remediation effort.
A total of 14 surface water samples were collected and analyzed during the RI.
The majority of analyses were below detection limits and all surface water
concentrations were below Federal Ambient Water Quality Criteria. All analyses
taken off-site (on Bee Tree Creek} were below detection limits. The surface
water sampling was conducted under low flow conditions (base flow) and
therefore reflects the greatest potential site concentrations. Based on this
general absence of chemical presence and compliance with protective aquatic
standards, no further sampling of surface waters is warranted. However, to
address potential concerns of the community and as an additional level of
protectiveness, EPA has agreed to analyze surface water samples at BA-2, BA-
3, and BA-4 for TCL.ffAL parameters. Periodic bioassays will also be
conducted to evaluate the effectiveness of remedial efforts.
1
3.
4.
5.
• •
Response
The quality assurance and quality control (ONOC) procedures used to validate
the RI data determined the bis(2-ethylhexyl)phthalate found in groundwater
analyses was not site-related. No further sampling is required.
In each area where the cap was extended, Section 5.0, Cap Design; more
particularly Section 5.1, General Design Considerations; of Prefinal Design and
Analysis, all referred to a more detailed visual inspection of the site and
additional interviews with employees who were present when the site was being
used.
The contaminant plume is implicitly presented in RI document. During RI
significant modeling effort was vested to predict the migration of the
contaminants. Appendix I of the RI present the results of the numerical
modeling by using U.S.G.S. solute transport model.
The extraction wells have been placed at strategically important locations down
gradient of the contaminant plume as identified in the RI. These are important
locations in remediating the most heavily contaminated areas of the site.
Monitoring wells are planned in locations down gradient of the extraction system.
The performance of the extraction system will be evaluated periodically by
utilizing the water quality/water level data obtained from the monitoring wells.
Any deviation from the design performance of the system will be addressed by
appropriate corrective action. The corrective action may consist of adding more
monitoring· wells or piezometers and extraction wells.
6. The Preliminary Operations and Maintenance Plan submitted for review was
incomplete with respect to groundwater monitoring of capped areas. The Final
Operations and Maintenance Plan will specify groundwater monitoring of wells
below DA-10/11 for the chemicals identified in the ROD. It should be noted that
CS was only found in one soil sample from DA-10/11 and at a low concentration
(1.5 ppm), that BZ, CS and their degradation products have limited mobility in
soils and groundwater, and that no site-related chemicals have been detected
in SW-2 or BW-2.
7. As stated in the General Comment, the monitoring program is in the preliminary
stage of development and cap monitoring has not yet been included. We
agree that Well SW-2 will be and BW-2 may be included in the monitoring
program. Additional monitoring points will be considered if contamination is
detected at these locations. The purpose of these monitoring wells is to
demonstrate the effectiveness of the cap. Therefore, these wells will be sampled
annually for the chemicals of concern specified in the ROD.
2
8.
• •
Response
BZ was never detected in any media at the site. The BZ degradation products
benzophenone and benzylic acid were detected in monitoring wells
downgradient of DA-23 at low concentrations. The latest sampling downgradient
of DA-23 (12/89) found that the concentrations of BZ degr_adation products had
decreased from the previous sampling (1/89). The differences in concentration
noted at SW-4 are slight and most likely attributable to the use of different
analytical laboratories. Benzophenone and benzylic acid analyses are not
standard and some variability among laboratories is to be expected.
However, in response to potential public concerns, EPA will sample the
Unnamed Branch at Station BA-2 (coinciding with RI Station RW-12) for CS and
its degradation products and BZ degradation products.
9. The finalized monitoring plan of the Operation and Maintenance Plan will include
a sufficient number of piezometers to properly demonstrate the effectiveness of
the remediation system.
10. See response to Item 9.
11. See response to Item 9.
12. The pumping well effluents will be sampled for the chemicals of concern when
the remediation is nearing completion_ Until this time, sampling of these wells
will not provide any additional meaningful data relative to groundwater
remediation.
13. a) Agreed. The preliminary operation and maintenance plan is modified to
state that: "The effectiveness of the remedial action system will be
evaluated by interpreting water quality data. Concentration versus time
curves will be developed for each contaminant at each monitoring point
These will be used to evaluate changes and estimate when concentrations
will reach the remediation levels.
b) · The finalized manual will use those chemicals specified in the ROD as the
monitoring parameters. Full scans will be performed on samples from
wells immediately downgradient of the site just prior to system shutdown.
3
• •
Item Response
14. The surface water sampling conducted during the RI was performed under base
flow conditions, as directed by the comment, and therefore is representative of
site conditions. Per Response No. 2, no further surface water sampling is
warranted.
However, EPA is preparing to sample the Unnamed Branch in the Front Valley
and Gregg Branch in the Back Valley. Full analytical scans will be run on these
samples as well as for the constituents ROX, TNT, CS and it's degradation
products and the degradation products of BZ. The samples will be collected
at locations BA-2, BA-3 and BA-4 as defined in the Bioassay Monitoring Plan.
This sampling effort will occur during baseflow conditions.
15. The "intermittent stream" from DA-10/11 has not been observed for five years.
Construction of the cap will further reduce the potential for emergence of the
stream. While sampling of the "intermittent stream" will not be possible, Front
Valley surface waters will be adequately characterized through samples collected
at Station BA-2 on the Unnamed Branch.
There is no indication that groundwater contamination is present under DA
10/11. A monitoring program for this area is under development. This long
term sampling data will provide a better indication of the water quality than by
pumping these wells. In addition, pumping these wells may reverse the natural
gradients and draw contamination away from the extraction wells, reducing their
effectiveness. These wells will be monitored after system startup.
The soil concentration of 1, 2-dichloroethane detected in DA-10/11 at 20-22 feet
was 0.032 ppm. This low concentration is indicative of leachate from waste
materials, not the waste itself. 1,2-Dichloroethane has not been detected in
groundwater in the wells monitoring DA-10/11.
Wells M85L4, M85L 10, SW-4 and BW-4 are located in the DA 23 area which is
near DA 10/11. Water levels in these wells have been monitored quarterly since
1986. Analysis of this data has revealed that the .maximum water level
fluctuation during this period was 9. 75 feet. If it is assumed that this range of
fluctuation is applicable to the area around DA 10/11, then the depth to the high
water table is 22.25 feet, since the water was at 32 feet during the RI. If the
range of fluctuation is assumed to be 20 feet (over double), then the high water
level is 12 feet. The maximum depth of the debris is 8 feet. Therefore, based
on the above analysis, the water level will not rise into the waste.
4
• •
Item Response
Drums and debris were buried in shallow pits (8 feet deep or less). The test
pitting logs indicate that waste materials are therefore not in the saturated zone
and their only potential impact on groundwater is through leachate production.
The cap will eliminate infiltration and hence leachate. Monitoring wells analyses
will be used to evaluate the effectiveness of capping.
The "high" total cyanide concentration of 1.5 mg/kg referenced in the comment
is significantly lower than the RCRA action level of 2,000 mg/kg (55 FR 30798).
Boring DA-10/11-5 is outside of the areas of waste disposal and the low cyanide
level represents incidental deposition. Capping of this area is therefore not
necessary.
16. Per EPA's letter of September 13, 1990 from Mr. Jon Bornholm to the CWCE,
stream monitoring Station BA-2 will be moved downstream to coincide with
sampling point RW-12 of the RI.
17. Modifications in cap coverage were made because the locations of former
waste disposal were better defined, not because the locations "are not fully
known" Moreover, the concentration of TCE decreases from surface water
Station RW-12 (0.010 mg/I) to RW-10 (not detected). Monitoring wells will be
sampled on a regular basis, per the Final Operations and Maintenance Plan, to
assess the overall remediation of the Front Valley.
18. Strategically located monitoring wells are already in place downgradient of DA-
23. The installation of additional wells will be considered if samples from these
wells should ever indicate that contamination is present.
19. Results of the bioassay program will be used to evaluate the effectiveness of
remedial operations and therefore will be incorporated into the remedial review
process. Per Response No. 2, EPA will also be conducting chemical analyses
of on-site surface waters.
20. Per Response No. 2, site surface waters are in compliance with Federal Ambient
Water Quality Criteria and concentration of chemicals in the sample taken in Bee
Tree Creek were below detection limits. Accordingly, remediation of site surface
waters is not necessary.
21. The drawdowns, from pumping two wells independently, can be added together
to get the resultant drawdown (when both the wells will be pumped
simultaneously at the respective pumping rates) for unconfined aquifer with
sma,11 drawdowns and for confined aquifer under all conditions (Freeze, R.A. and
Cherry, J.A., Groundwater, Page 34; Bear, J., Hydraulics of Groundwater, Page
159).
5
Item
• •
Response
We agree that there will be considerable interference between the wells. We,
however, disagree with the comment that the width of the capture zone created
by simultaneous pumping will be less than created by pumping either well.
When the wells are not placed on a line parallel to the direction of flow, the
width of the capture zone will always be larger than that created by a single
well. And this fact can be demonstrated by modeling (RESSQ).
The effectiveness of the capture zone development will be carefully monitored
during system start up. Therefore, we do not find it necessary to do a two-
well pumping test.
22. Aquifer test data were analyzed by several methodologies, not all of which were
presented in the report. Both water-table conditions and dewatering effects
were considered during the analyses. Although not all the assumptions inherent
to the methods were met, conservative estimates of transmissivity, capture zone
width, and stagnation point were used in the design. While some uncertainty
exists in the test data analyses, it does not affect the validity of the design. For
example, if indeed the transmissivity is less than those used in the design, then
the capture zone width and stagnation point distance will be greater than
predicted. Therefore, the contaminant plume will be captured and the flow rate
will be less than predicted. Hence, the public health is protected. If the
transmissivity is higher than estimated, then a higher flow·rate will be necessary
to generate the necessary capture zone. The extraction and water treatment
system is designed to handle the extra flow rate. Therefore, the public health
is protected. Hence, further consideration of the theoretical aspects of aquifer-
test analysis is not warranted. It should be noted that, although the Citizen's
Watch consultant used a different method of aquifer test analysis, their
conclusion with regard to design, i.e., maximum well spacing, is the same.
23. The assertion that there is "widespread chromium contamination in (the) Front
Valley" is incorrect. The great majority of wells contained chromium below the
detection limit and/or the remediation level (0.05 ppm). The referenced well,
IW-1 is the furthest from the disposal areas and therefore is not felt to be related
to disposal activities but rather particulate matter in the sample, as discussed
in the RI. Background chromium levels are fairly high, such as the 58 ppm in
the sediment sample at RW-12. The resulting water value at RW-12 of 0.10 ppm
is representative of background conditions and within Federal Ambient Water
Quality Criteria. Chromium levels at the Site are naturally occurring and do not
require remediation.
6
• •
Item Response
24. Wastewater from the production of a fire retardant was the only material placed
in the original biolagoon prior to its failure. Total organic carbon analyses were
conducted in the groundwater monitoring wells immediately downgradient of the
biolagoon to determine the level of any organic contamination. The low levels
of TOC detected (7 mg/I) reflect previous use of a drain field in the area and
indicate little impact from the biolagoon failure. Any contaminants present in the
groundwater due to the biolagoon failure will be removed by the activated
carbon treatment system.
25. We have reviewed all of the available data on the RI sampling of well BW-11.
Based upon this review, we do not believe that the results were influenced by
the contamination of the sample with drilling fluid or water from the pressure
tests. The following discussion presents our rationale for this conclusion.
According to the sampling data, 75 gallons of water (1.5 casing volumes) were
evacuated before the well went dry. The well was sampled the following day
and the water was reported to be clear, indicating that no drilling fluid was
present. In addition to this, the well was drilled using air rotary drilling
techniques and there is no indication of any water having been added during
the drilling or installation.
Careful records on the quantities of water added during the pressure testing
were kept during the RI. These data indicate that less than one gallon of water
was lost during these tests. Since 1.5 casing volume was evacuated,
approximately 25 gallons was formation water. Therefore much more water was
evacuated than was introduced.
Two clusters of monitoring wells are proposed downgradient of the extraction
system. The need for additional wells will be evaluated based upon the
sampling of these clusters following system startup.
26. As stated in the GENERAL COMMENT, the monitoring program is not yet
complete. The monitoring program for the DA6 area is under development and
will be included in the Final O & M Plan.
27. A monitoring program for DA 7/8 is under development. At present, it is
intended that SW-8 will be added to the finalized monitoring program.
28. BZ has never been detected at the site. CS has never been detected in
groundwater. Benzophenone was found at 19 ug/I (not mg/I) in the aquifer test
groundwater from DTW-2.
7
• •
Response
Since the detection limit of benzophenone is 10 ug/I, levels in Gregg Branch
and beyond will be below detection levels. No further chemical analyses of site
surface waters is warranted. The bioassay wil_l be used to evaluate any impacts
on aquatic life.
29. The wells MW-1 and MW-2 will be moved further downgradient (approximately
45 feet) in the final design and monitoring program documents in order to allow
for the conservative approach to estimating the stagnation points.
30. The addition of several piezometers to the finalized monitoring program is
currently being considered. The number of water-level measuring points
included will be sufficient to demonstrate that the predicted capture zone is
being developed (see the GENERAL COMMENT).
31. A typographical error has caused this confusion. The well BW-3 is indeed in
the Front Valley. The O & M Plan will be revised accordingly.
32. The extraction wells, and the monitoring wells immediately downgradient of the
disposal areas will be sampled for full scans (TCL/TAL) and degradation
products of BZ and CS near system shutdown.
33. See response to Item 2.
34. As stated in response 22, an overestimated value of transmissivity leads to a
conservative spacing of the extraction wells and is therefore useful in designing
a system protective of the public health. The finalized monitoring program will
be sufficient to demonstrate that the system is effective.
Attachment A See Response to Item 22.
8
• •
Comments from CWCE (KAWECKI)
The Hazardous Substance List (HSL) referenced in the comments has been replaced by
the Target Compound List and the Target Analyte List.
2.0 CONTAMINANT IDENTIFICATION
As indicated by Chirlin, BZ, CS and their degradation products have low mobilities and
hence limited potential to impact groundwater. The only compounds in this group found
in groundwater were trace levels (approximately 1 ppm) of benzophenone and benzylic acid
in DA-23. The source of these compounds was a former drainfield designed to discharge
to groundwater. The potential for any BZ, CS or their degradation products to impact
groundwater in the Gregg Valley is minimal and has been confirmed by the representative
sampling conducted in the RI.
Volatile organics formerly had common use as degreasers and septic tank cleaners and
any presence in off-site wells could not be ascribed to site activities. EPA was therefore
correct in sampling only for compounds specifically related to the site. Of more importance,
monitoring well analyses and modeling projections indicate that VOCs have not migrated
off-site. Under worst-case conditions and without any remedial efforts, the RI concluded
that off-site groundwater concentrations would not exceed protective health-based levels for
at least 25 years. Since voes have not left the property and cannot have entered any off-
site wells there is no need for additional sampling.
Application of drinking water standards (MCLs) to surface waters (unnamed branch) is
inappropriate where the water is not used for human consumption. The referenced
concentration of 11 mg/I of 1,2-dichlorethane at RW-7 does not exceed Federal Ambient
Water Quality Criteria and is therefore protective of the environment. The concentration of
1 ,2-dichloroethane at the next downgradient station, RW-12, was considerably reduced
(0.23 mg/1). All voes are below detection limits in Bee Tree Creek.
2.1 Indicator Chemicals
It is not standard practice to perform full TAL/TCL (formerly HSL) analyses at several stages
in the RI. Full TAL/TCL scans are conducted at the most concentrated source areas during
initial sampling to develop indicator parameters for subsequent sampling events. The
investigatory work done at the site is thorough and sufficient for remedial design. Additional
sampling is not warranted and will only serve to delay the onset of remedial efforts for an
extended period.
9
• •
3.0 ROUTES OF EXPOSURE
The RI risk assessment evaluated potential risks due to ambient air. Because of the
extensive ground cover, distance to potentially exposed populations, limited volatility of site
compounds, and low surficial soil concentrations, there are no significant health risks posed
by ambient air. Air modeling was conducted to assess potential air impacts under worst
case conditions associated with operation of the air strippers (Prefinal Design Analysis,
Appendix N). Air stripper emissions will be well within North Carolina ambient air quality
standards and will pose no risks to human health.
The risk assessment evaluated baseline conditions at the site. Under baseline conditions,
there will be no significant release of volatile organics to the environment and hence no
risks. The possibility of a fire impacting buried residuals is highly unlikely and does not
require further consideration.
3.2 Ingestion
Chemicals in groundwater at DA-23 have not left the site and therefore are not available for
ingestion by any receptors. Without an exposure pathway there can be no risk to human
health.
Groundwater remediation will remove and treat groundwater contaminants, preventing any
off-site migration in the future.
4.0 EVALUATION OF TOXICOLOGICAL DATA
Adopting the drinking water lifetime health advisory level of 2 ug/1 for TNT and ROX is not
warranted. TNT was detected near the remediation level in only one monitoring well located
approximately one-half mile upgradient of the property line during the RI (1986}. TNT was
not detected in the remaining 42 site wells. The limited presence of TNT in site
groundwater is considered isolated and not significant.
ROX was detected at low levels in six of the 43 monitoring wells sampled during the RI.
ROX was not detected during sampling of select wells during the October 1987 confirmation
sampling and the December 1989 Remedial Design sampling. The absence during
consecutive sampling events indicates that ROX is not a concern for human health or a
designated parameter for remova! during remediation.
Any TNT or ROX in site soils will be contained by the caps, thereby preventing any potential
for human exposure.
10
• •
5.0 LONG-TERM MONITORING
The statements in the first paragraph of the review comments appear to be out of context.
As implied, the ultimate objective of toxicological testing is to identify substances that might
injure humans. Aquatic toxicology, as expressed through proposed bioassay testing of
aquatic species, was never intended as a measure of potential effect on human health nor
as a substitute for chemical-specific water quality analyses. The bioassay testing, as
proposed, would be used to document that acute (mortality) or chronic (survival, growth,
reproduction) effects on aquatic organisms were not impacting surface water biota or that
impacts, if present during baseline monitoring, were eliminated or being diminished by site
remediation.
Regarding additional surface water sampling, a total of 14 surface water samples were
collected and analyzed during the RI. The majority of analyses were below detection limits
and all surface water concentrations were below Federal Ambient Water Quality Criteria.
All analyses taken off-site (on Bee Tree Creek) were below detection limits. The surface
water sampling was conducted under low flow conditions (base flow) and therefore reflects
the greatest potential site concentrations. Based on this general absence of chemical
presence and compliance with protective aquatic standards, no further sampling of surface
waters is warranted.
11
• •
Comments from CWCE (ENSCI)
Slope Stability
The stability analyses for slopes were performed by using friction angle values obtained
from published literature (Martin, Koerner and Whitty, 1984).
Currently, we are in the process of reviewing our slope stability analysis and evaluating the
validity of using published data. Depending upon the outcome of this review, we may
conduct special shear box tests to determine the interface angle of friction under different
normal loads and at various moisture contents. The experimentally determined values will
then be used in performing stability analyses of the slopes. All the related computations
will be presented in the final design analysis.
It is to be noted that to add to the stability of the slopes we are replacing the 40 mil HOPE
and geotextile cushion composite by 60 mil textured HOPE and reinforcing steep slopes by
geog rids.
Composite Barrier
The 12 oz geotextile used beneath the HOPE liner for DA-6, 9, 23 and the Acid Pits will be
removed (refer to slope stability response). Additionally, all liners are to be 60 mil textured
HOPE. The maximum allowable particle size in the select fill shall be 1/4" as recommended
by the HOPE manufacturer, considering the angular quartz crystals identified during the soil
borrow survey.
RCRA requires that the soil component permeability be equal to or less than the
permeability of the subsoils present. The borrow soils to be used during construction are
located on site and have basically the same soil descriptions as soils indicated from
disposal area soil borings. These soils, along with the low permeability 60-mil textured
HOPE liner, will prevent infiltration of water to the disposal areas. The caps at Chemtronics
all exceed s· slope and contain a highly transmissive synthetic drainage layer.
Evapotranspiration and drainage through the drainage layer will prevent any water head
above the liners which provides additional water infiltration protection. Any leaching of
water through the disposal areas will be intercepted by the downgradient groundwater
extraction systems.
Drainage Layer
Toe drains to remove water from the drainage layer have been designed but were not
included in the 95% submittal. These details will be included in the final design.
12
• •
Biobarrier
A 12 oz geotextile ring will be installed between the No. 57 stone and the bentonite to
further eliminate bentonite migration into the gravel. Details will be included in the final
design on drawing C-12.
It is agreed that the HOPE geomembrane boot can not be extrusion welded to the PVC vent
pipe. This pipe should be of HOPE construction and will be modified in the final design.
A mechanical connection of the boot to the vent pipe is also an approvable connection
detail. The contractor, during construction, may wish to propose a mechanical connection
method as an alternate to the extrusion welding method. Should the mechanical method
be proposed, the engineer will evaluate it at that time.
No additional protection will be utilized for the gas vent pipes. Site access is controlled by
fencing and the vents will have adequate stick-up to be avoided during mowing operations.
Differential Settlements
The potential for significant settlement based on the collapse of intact drums is considered
minimal. The drums occupy a limited portion of the capped areas in DA-6, 7/8, 9 and
10/11 and none of the area in DA-23 or the Acid Pits. The majority of drums contain solid
materials, not liquids, and would be resistant to compression. Test pitting conducted in the
RI found that less than 25 percent of the drums appeared intact (personal communication,
Mr. Chris Haggar, Metcalf and Eddy). The potential for subsequent compression and
differential settlement following cap construction is therefore minimal. As a protective
measure, the Final Operation and Maintenance Plan will require an initial survey of each
cap to establish a detailed topographic map. The caps will be surveyed annually thereafter
to determine if settlement has occurred and the appropriate maintenance will be conducted.
13
•
September 28, 1990
Mr. Jon K. Bornholm
Superfund · Project Manager
U.S.E.P.A.
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30363
NIMMO & CO.
Consultants
P.O. Box 536
Swannanoa. NC 28778
(704) 6813-4336
Re: Responses to Comments on Chemtronics Site
Pre-Final Design Submission of 27 June, 1990
Dear Jon:
•
EPA -~l:G10N IV
ATLANTA. G11.
Attached herewith are the responses· to the comments received on the Chemtronics
Site Pre-Final Design submitted on 27 June, 1990. As you are aware, the comments
were presented to the PRP's in three different sections, i.e., EPA letter of 3 August,
1990 containing Region \V's CERCLA group comments, the comments of the state of
North Carolina Superfund Section as FAXed to my attention on 10 September, 1990,
and finally, the comments of the Technical Advisor to the Citizen's Watch for A Clean
Environment which was transmitted to the PRP's by EPA's letter of 24 August, 1990.
The responses attached are addressing the comments presented by Region \V's
CERCLA group and the state of North Carolina Superfund Section. Responses to the
Citizens' Watch comments are only approximately 85% complete at this time. It is
anticipated that these responses will be completed and forwarded to you on Tuesday
2 October, 1990.
It should be noted that the responses to Region IV CERCLA group Comments 27 and
28 also respond to Paragraph 3 of EPA's letter of 24 August, 1990.
Mr. Jon Bornholm
September 28, 1990
Page Two
• •
If you should have any questions on this submission, please feel free to contact me or
Mr. Jeff lmpens of Sirrine Environmental Consultants at [phone].
J.F. Schultheis
PRP Coordinator
cc: Ms. Nancy Baldwin -Northrop
Mr. Joe Eggelston -JRC
Mr. Gary Rowen -Hoechst Celanese
Mr. Craig Bromby, Esq.
Mr. Jim Wrathall, Esq.
Mr. Tony Young, Esq.
Mr. Jeff lmpens -Sirrine
J-10101 file
• •
RESPONSE TO EPA REGION IV AND
STATE OF NORTH CAROLINA
PREFINAL (95%) REMEDIAL DESIGN
CHEMTRONICS SITE REMEDIATION
SEPTEMBER 28, 1990
SIRRINE ENVIRONMENTAL CONSULTANTS
GREENVILLE, SOUTH CAROLINA
•
Comments from USEPA CERCLA
Item Response
1. Benzophenone and benzylic acid are the only compounds to be removed by
carbon adsorption. As shown in Table 3.2, the levels of both of these
compounds in the Front Valley groundwater were brought below detection limits
using the lowest applied carbon dosage. Accordingly, there was not sufficient·
data to prepare an isotherm. The treatability testing did prove that
benzophenone and benzylic acid are readily removed by activated carbon. The
activated carbon canisters are approximately 55 gallon drum size and contain
150 lbs of virgin TIGG 5D 124D carbon adsorbent, with a bulk density of 27
lb/cu. ft, for an empty bed volume of 5.6 cu. ft. They will be operated in a
series of three canisters and in a sequential mode so that when saturation has
occurred within the lead column, the next column becomes the lead, and so on.
The canisters shall provide an empty bed contact time between 10 and 20
minutes. Further design data is presented in Appendix B of the Prefinal Design
Analysis (Volume 11, June 1990).
Actual carbon usage rates will be determined in the field to establish a schedule
for carbon replacement. Samples will be collected at the carbon system influent
and after each column on a regular basis and analyzed for benzophenone,
benzylic acid and TOC. Breakthrough of the columns will be monitored to
establish maximum loading rates such that the effluent meets discharge ;
standards. Carbon replacement schedules will be based on influent chemical
loadings.
2. The reference to Table 3.3 for Microtox results is incorrect and should be
omitted. Microtox results were presented in Appendix 8.3 of the Concept
Design Review Submittal (Volume 11, February 1990). There is no missing table.
3. Data on the contaminant concentrations are presented in the RI report. A brief
discussion follows.
In the Front Valley, according to the RI, contaminants in the saprolite aquifer
have migrated downgradient of DA 23 and appear to be discharging into the
northern tributary of the unnamed branch. During the pilot study, elevated
concentrations of 1,2-dichloroethane (10,000 ug/I), and methylene .chloride
(1,300 ug/I) were detected in samples from well STW-1 collected in December
1989.
2
Item
• •
Response
Contaminants in the bedrock aquifer were detected only in BW-4 and BW-5
during the RI. 1,2-dichloroethane (530 ug/1) and chloroform (30 ug/1) were
detected in well BW-4, and 1,2-dichloroethane (150 ug/1) was detected in well
BW-5. According to potentiometric maps presented in the RI, well BW-5 is not
downgradient of DA 23 because the major flow direction is approximately parallel
with the unnamed branch. However, contamination may have migrated from DA
23 through fractures to the vicinity of BW-5. The absence of 1,2-dichloroethane
and chloroform in BW-6 suggests the contaminant plume is of limited extent.
Therefore contamination in the bedrock aquifer downgradient of DA 23 appears
to have migrated less than 800 feet from DA 23 as of June 1986.
In the Back Valley, eight of the wells sampled during the RI were contaminated.
These include wells M85L5, M85L8, M85L9, SW-11, X-2, X-3, IW-2 and BW-9,
indicating that contamination _has spread vertically, as well as horizontally, into
all three hydrogeologic units monitored. However, only samples from one
bedrock well, BW-9, were contaminated. Rock wells BW-11, -12, and -14 are
located further downgradient indicating that the plume had not migrated to those
locations. Well DTW-2 was sampled in 1989 and the analY1ical results indicated
that contamination was present. The contaminants detected in samples
collected during the RI include: 1,2-Dichloroethane, Trichloroethylene, Methylene
Chloride, Trans-1,2-Dichloroethene, Benzene, Chloroform, Bromoform, Picric
Acid, and RDX, though not all constituents were detected in each well.
Three of the acid pit monitoring wells (SW 11, IW 2 and BW 9) were resampled
in 1987. Samples from these locations indicated continued contamination. The
results of the various sampling events are included on Table 4.6 and 4.7 of the
30% design submittal.
Three monitoring wells (X-4S, SW-8, and BW-14) are located downgradient and
provide information on contaminant migration from DA 7/8. During the RI
samples only from SW-8, a shallow well, showed contamination. Elevated
concentrations of 1,2-dichloroethane, methylene chloride, trichloroethylene, and
trans 1,2-dichloroethene were detected in this well.
Four monitoring wells (X-4D, SW-9, BW-8, and BW-14) are located downgradient
and provide information on contaminant migration from DA 9 (Tables 4.6 and
4. 7). Elevated concentrations of trichloroethylene and 1,2-dichloroethane were
detected in well SW-9, a shallow well, and trichloroethylene was detected in well
BW-8, a bedrock well, during the RI. None of the analyses detected in BW-8,
BW-9, or in the surficial wells of Gregg Valley were detected in BW-11, BW-12,
or BW 14. This indicates that contaminants from the acid pits, DA 7/8, and DA
3
• •
Response
9 had not migrated this far (approximately 600 feet to BW-12 and 900 feet to
BW-11) at the time of the RI. Elevated concentrations of metals detected in
several wells were not attributed to waste disposal activities.
A map showing the horizontal ex1ent of the plume, based upon the RI, was
included in the 30% design submittal. The information depicting this will be
included on Figure 4.4 of the 100% design document.
4. The sentence introduces the subsections of Section 4.1 where groundwater
chemical concentrations and ex1raction rates are presented. For clarification the
following sentence shall be added after the second sentence: "These elements
are discussed below."
5. As shown in Table 4.1.1 (Page 43) the concentrations for lead and chromium,
for all the sampling episodes, are below MCL. So the paragraph will be
rewritten as follows:
"Chromium and lead concentrations for all three test wells were significantly
below MCL."
6. An introductory paragraph will be added to Section 4.2. It will read as
"Three alternatives were considered for treated groundwater discharge.
These are:
• infiltration gallery,
• discharge to Buncombe County Metropolitan Sewerage district, and
• discharge to Bee Tree Creek.
7. Jet Research Corporation (JRC) is not the owner of the property. Mistakenly
JRC was named as the owner in Section 4.2. It is to be noted that JRC is the
operator of the facility and Chemtronics Inc. is the owner.
The third sentence of the first paragraph of Section 4.2 (page 49) is hereby
modified as follows:
"Prefinal design of the infiltration gallery required more complete delineation
of infiltration locations and any accompanying access restrictions from Jet
Research Corporation (JRC), the current facility operator."
4
Item
8.
•
Response
The first sentence of the paragraph will be replaced by the following:
"Bee Tree Creek water is classified as Class C under North Carolina Water
Laws. Class C waters are fresh waters protected for secondary recreation,
fishing and aquatic lives including propagation and survival".
9. Additional piezometers will be added to the monitoring well network to monitor
the groundwater surface elevation so that the hydraulic effectiveness of the
extraction well system can be sufficiently evaluated. The finalized monitoring
plan of the "Final Operation and Maintenance Plan" will include a program of
water-level measurements sufficient to demonstrate the effectiveness of the
system.
10. The ground water samples will be analyzed for the contaminants of concerns
as listed in Table 3 page 20, of the "Amendment to the Enforcement Record
of Decision" (Table 4.1.3, Page 48, of Prefinal Design and Analysis report).
The sentences originating at the 4th line and the 6th line of the 2nd paragraph
of page 60 will be replaced by the following:
''The collected ground water samples will be analyzed for the contaminants
of concern as listed in Table 4.1.3 (page 48). However, if one of the
contaminants of concern is not detected in two consecutive sampling
events, it may not be analyzed for in the subsequent sampling events."
11. This concern will be addressed in the final version of the "Operation and
Maintenance Plan".
12. The second paragraph of page 60 states that the wells will be sampled quarterly
during the first year, semi-annually through the fifth year and annually thereafter.
It is the extraction system's effectiveness evaluation that will be done semi-
annually for the first year and annually through the third year. It is to be noted
that the system evaluation will be based on the analyses of the ground water
samples collected at the prescribed frequency.
Based on the outcome of the effectiveness evaluation for the extraction system,
additional wells may be sampled.
13. Well development will be performed in general accordance with the applicable
procedures described in "EPA Region IV Engineering Support Branch Standard
Operating Procedures and Quality Assurance Manual". Specifically, the
proposed methods for developing extraction wells include hydraulic jetting, air
5
• •
Response
lifting, hydraulic vacuuming and/or bailing. More detailed descriptions of these
methods are presented in the Prefinal Design Specifications. The Prefinal
Design Analysis shall be modified as follows: Section 4.3.2, paragraph 21, first
sentence, change "Upon completion, each well will be developed by an
appropriate method." to "Upon completion, each well will be developed by
hydraulic jetting, air lifting, swabbing, and/or bailing."
14. See response to Item 10.
15. Alternating the collection of samples from the deep and shallow monitoring wells
were proposed to keep the cost of sampling and analysis to a minimum yet
gathering enough information, over the thirty-year pumping period, to evaluate
the effectiveness of the extraction system.
16. The Prefinal Design Analysis is hereby modified as follows (Section 4.3.2, last
paragraph): change ''Wells BW-8 and X-4d will be abandoned because they are
both located in the area of DA 9 to be capped." to ''Wells BW-8, X-4d, and SW-
14 will be abandoned because they are located in disposal areas to be capped."
Also in section 4.3.2, last paragraph, after last sentence add, ''Wells BW-7, X-
1, SW-10, M85I2, BW-10, and SW-13 will be abandoned because they will
provide neither ground water quality data nor water level data that can be used
to evaluate the effectiveness of the proposed extraction system. Also, wells K-
1, M85I2, X-45 and X-4D were installed prior to the RI and exact well
construction details are not known."
17. The hydrochloric acid supplied by the manufacturer is supplied in polypropylene
drums. The word "polypropylene" will be inserted in the seventh line of the first
paragraph of page 81, Section 4.4.2 to read "A 55 gallon polypropylene drum
of acid ... ".
18. We agree that the used carbon that is determined to be hazardous should be
disposed of as a hazardous waste at a RCRA hazardous waste facility.
However, benzophenone and benzylic acid are the only compounds to be
removed by carbon adsorption, and they are not RCRA-listed substances.
Spent carbon is therefore not expected to be hazardous.
19. The 55 gallon canisters are modified canisters that are sold commercially to
withstand the applied pressure. The pressure ratings of these canisters will be
specified in the final design.
6
•
Item Response
20. The design drawings show an automatic valve sequence that will allow the
operator to manually select the lead carbon column using a selector switch.
When the No. 1 canister is the lead, No. 2 will follow with No. 3 last. When
the No. 2 canister is the lead, No. 3 will follow with No. 1 last. When.the No.
3 canister is the lead, No. 1 will follow with No. 2 last. The effluent line from
each canister will be switched accordingly as well to correspond to this
sequence. Sample ports are provided on the effluent line from each canister
so that samples can be taken and sent for analysis. Three canisters have been
provided in the design since there will be a time lag between the taking of the
samples and the availability of the analysis results. Even if breakthrough is
missed by a few days, the second canister will still adsorb the contaminants
with the third canister providing an additional polishing step. After the initial 1
or 2 cycles of canister sampling and changeout, the operator should also be
able to accurately gauge the expected life from a canister and plan changeout
accordingly. Sampling and analytical procedures will be specified in the 95%
Operation and Maintenance Plan.
21. As discussed in Section 4.2 of the Prefinal Design Analysis, monitoring
parameters and frequency will be established in the discharge permit.
22. Breakthrough of the carbon columns will be established during startup to
establish a schedule for carbon replacement. Since there will be two polishing
columns, the carbon column effluent will be assured of meeting discharge
requirements and there will be no need for reprocessing. The given design has
been proven at numerous groundwater remediation sites.
23. The stack from the air stripper extends completely through the roof so that the
exhaust from the air stripper will be clear of the building. An exhaust fan and
louvers have been provided in the building's design to provide forced air
ventilation in the building. Thus, no air monitoring equipment inside the building
is deemed necessary.
Proper protective clothing, eye protection and hand protection will be specified
in the 95% Operation and Maintenance Plan.
24. Gas vents will only be required in the Acid Pits Disposal Area. There is no
indication that biodegradable wastes are present in the other disposal areas.
The comment is noted and will be incorporated into the final design.
25. All common fill will be compacted to 95% of standard proctor (ASTM D698-78).
This is indicated in the specifications, Division 2(2050-3). This will also be
indicated on drawing C-9169-C-11 in the final design.
7
•
Item Response
26. The contractor is responsible for submitting an Equipment Decontamination
Facilities Plan prior to construction in accordance with Section 01450 of the
design specifications.
27. The Unilateral Administrative Order, dated March 22, 1989, issued to the PRP's
of the Chemtronics Site states in Section V, paragraph C., "Requirements for
Work:", which includes sub-paragraph 2.a on multi-layer caps for all areas
including DA-23. Sub-paragraph 3 defines the multi-layer caps as meeting at
the minimum the standards specified under 40 CFR 264, Sub-parts K-N. Sub-
paragraph 4, under paragraph C of Section V is titled, "On-Site Pond" and
provides direction for disposal of wastes under the Cap of DA-23, if necessary.
This direction of disposal of waste in DA-23 by the Administrative Order is in
contradiction with the comment.
In addition, the Amended Record of Decision, dated April 26, 1989, on page
23 states: " ... capping DA-23 will also satisfy the post closure requirements
imposed upon the owner/operator of the facility by the Resource, conservation
& Recovery Act (RCRA) program of the Agency, and the North Carolina
Department of Human Resources."
The following paragraph, also from page 23 of the Amended Record of
Decision, clarifies the intent of CERCLA closure:
"Under RCRA, when a business or individual stops operating a solid
waste management unit (SMU) the SMU needs to be closed out
according to RCRA regulations. Capping DA-23 and pumping and
treating the groundwater will meet RCRA's requirements."
In summary, it is clear from the language of the Administrative Order and the
Amended Record of Decision that CERCLA closure of Area DA-23 would meet
the intent of RCRA Closure and the RCRA post-closure monitoring plan would
be implemented by the owner/operator. The complete adherence to the RCRA
Closure Plan for area DA-23 was not the intent of the Administrative order or
the Amended Record of Decision. Thus, this comments is not germane to the
final design for the CERCLA remediation of the Chemtronics Site.
28. See response to Item 27.
29. The venting system for the Acid Pits Disposal Area will be discussed in the final
design.
30. Data missing from Appendix H will be incorporated in the final design.
8
Item Response
31. Figure 1 of the Gas Vent Survey will indicate sampling locations in the final
design analysis.
32. Noted and incorporated.
The 95% Design Submittal is hereby modified as follows: Section 01010, page
01010-1, "1.2 DESCRIPTION" has replaced heading "2.2 DESCRIPTION".
33. Noted and incorporated.
The 95% Design Submittal is hereby modified as follows: Section 01020, page
01020-1, after paragraph 2. 1 add the following paragraphs
"2.2 The Contractor or his subcontractors shall not enter, occupy or use
buildings or structures used by Jet Research, Inc. within the boundaries
of the Chemtronics site without prior written approval from the Facility
Operator."
"2.3 The Contractor shall maintain all construction activities, including
personnel access to and from work areas, a minimum of 50 feet from all
buildings or structures on site unless prior approval is granted in writing
by the Facility Operator."
34. The 95% Design Submittal Material Handling Plan, Section 01470, page 01470-
3, paragraph 2.3 reads "The Contractor shall make the proper and appropriate
arrangements for the disposal of all contaminated and non-contaminated waste
materials."
The 95% Design Submittal is hereby modified as follows: Section 01020, page
01020-3, paragraph 8.1, line 5 after "other refuse remaining from the
construction operations" add "in accordance with the Contractors Material
Handling Plan (Section 01470)."
9
•
Item Response
35. Air monitoring issues are addressed in the 95% Design Submittal Safety, Health
and Emergency Response, Section 01400.
The 95% Design Submittal is hereby modified as follows: Section 01400, page
01400-5, paragraph 5.1.A, line 3 after the line "contaminants of airborne
transport of contaminated soil particles." add "The air monitoring program shall
include contingency plans for on and off-site responses to unexpectedly high
concentrations of airborne contaminants. Contingency plans shall include
notification and evacuation procedures for all persons within Chemtronics
boundaries and all adjoining properties and notification of local emergency
response personnel."
Additionally, Section 01400, page 01400-8, paragraph 5.3.1, line 3 after the line
"stations, the Contractor shall" add 'initiate the appropriate contingency
response and shall".
36. Noted and Incorporated
The 95% Design Submittal is hereby modified as follows: Section 01300, page
01300-3, paragraph 9.0, the entire paragraph including paragraph header will
be deleted.
Section 01300, page 01300-3, paragraph 10.0, the paragraph header "10.0 I
EROSION CONTROL" will be modified to read "9.0 EROSION CONTROL".
Section 01300, page 1300-4, paragraph 11.0, the paragraph header "11.0
CORRECTIVE ACTION" will be modified to read "10.0 CORRECTIVE ACTION".
Section 01300, page 1300-4, paragraph 12.0, the paragraph header "12.0 POST-
CONSTRUCTION CLEANUP OR OBLIGATION" will be modified to read "11.0
POST-CONSTRUCTION CLEANUP OR OBLIGATION"
Section 01300, page 01300-1, INDEX will be modified as follows: Line 9 "9.0
DUST CONTROL" will be deleted. Line 10, "10.0" will be changed to "9.0". Line
11, "11.0" will be changed to "10.0". Line 12, "12.0" will be changed to "11.0".
A new section, Section 01310, DUST CONTROL PLAN, will be added to the
95% Design Submittal following Section 01300, Environmental Protection, and
before Section 01400, Safety, Health and Emergency Response. This new
section is included in the Appendix.
Section 01230, page 01230-1, paragraph 1.1 modify line 5, "and (7) Shop
Drawings, Product Data, and samples." to read "(7) Shop Drawings, Product
Data and Samples, and (8) Dust Control Plan."
10
Item
•
Response
Section 01230, page 01230-2, paragraph 1.8, line 1, replace "1.8" with "1.9".
Section 01230, page 01230-2, after paragraph 1.7.B and before paragraph 1.9,
add the following paragraphs:
1.8 DUST CONTROL PLAN
A. The Contractor shall submit the Dust Control Plan to the Owner's
Representative within 21 calendar days after the contract award date. The
Owner's Representative shall review the Dust Control Plan within 5 days
after receipt and shall return the plan to the Contractor, if necessary, for
revisions. The Spill Control Plan shall be approved before the Notice to
Proceed.
B. The Dust Control Plan shall contain all of the items specified and
discussed in Section 0131 o, Dust Control Plan."
37. Air monitoring issues are addressed in the 95% Design Submittal Safety, Health
and Emergency Response, Section 01400.
The 95% Design Submittal is hereby modifie,d as follows: Section 01460, page I
01460-1, paragraph 3.1.B.2, line 4, after "recommendations of the CIH." add "If
necessary, initiate the appropriate high airborne contaminant contingency
response in accordance with the Contractors air monitoring program."
38. Noted and incorporated.
The 95% Design Submittal is hereby modified as follows: Section 01460, page
01460-1, after paragraph 1.5, the following paragraph will be added "1.6 The
Contractor shall be responsible for providing all required SARA (Superfund
Amendment and Reauthorization Act) Title Ill information on all applicable
chemicals stored on site."
39. Noted and incorporated.
Section 02040, paragraph 2.2C of the 95% Design Submittal is hereby modified
as follows: "The earthen wall shall be completely graded to conform with the
natural grades and contours of the surrounding terrain and shall be graded to
prevent any further ponding. Should additional fill material be required to
prevent ponding, as approved by the Engineer, fill requirements shall be as
specified in Section 02035."
11
•
Item Response
40. The facility operator will be consulted concerning site restoration and this input
will be the basis for amendment of the specifications (Section 02200), which will
indicate the proper method for restoration of the borrow areas.
41. The last sentence of the first paragraph will be modified as follows:
''The Field Representative will explain the necessity of such modification
to EPA. Once EPA agrees on the proposed modification, the Field
Representative will ask the contractor to implement it."
42. The Prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-3, section 2.2, first paragraph, after only sentence, add "The
decontamination water will then be containerized for proper disposal."
43. The well to be installed will screen the upper portion of the saprolite aquifer
which is not screened by DTW-2 and therefore will not sit at the top of the rock.
This well should increase the influence of pumping on saprolite and create a
larger capture zone in the saprolite. The blank casing at the bottom of the well
will act as a sump to collect any fine particles that may infiltrate through the
screen.
44. The monitoring well screened intervals were originally select~d to monitor water
quality and ground water hydraulics. Since downgradient water quality data is
needed, the Prefinal Design Specifications, Volume I, is hereby modified as
follows: Page 02660-9, section 3.0, the screen interval for MW-1S will be 38-
53 feet and for MW-2S will be 47-62 feet. A vertically downward hydraulic
gradient exists in the Back Valley, therefore, fifteen feet of screen at the lower
portion of the saprolite should intercept the zone of highest contaminant
concentrations. This solution does not provide any monitoring of ground water
hydraulics. Therefore, two piezometers will be added to the monitoring system.
These will be 4-inch PVC and will screen the saturated thickness of the
saprolite's transition zone. They will be installed for water level measurements
only, and located between extraction wells -one between wells EW-3 and EW-
4 and the other between EW-7 and EW-8.
45. The prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-9, section 3.1, part A., change "Saprolite drilling shall be
accomplished by conventional hydraulic (mud) rotary methods using fresh water
and sodium bentonite drilling fluid." to "Saprolite drilling will be accomplished by
hollow stem augering. If problems are encountered with rock layers or
boulders, hydraulic (mud) rotary methods using . fresh water and sodium
bentonite drilling fluid may be used, upon EPA approval".
12
I
• 0
Item Response
46. The Prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-9, section 3.2, change "All equipment and materials will be
thoroughly steam cleaned prior to installation and between boreholes." to
"3.2 Equipment Decontamination
All equipment shall be decontaminated in accordance with the following
procedures:
Equipment used for drilling and monitoring well installation and development will
be decontaminated in accordance with the following procedure:
1. Backhoes, drill rigs, and all support equipment shall be free from excess
grease, oils, and caked-on soils from previous work prior to arrival at the
site. Equipment which leaks fuel, coolant, and lubricants shall be removed
from the site and repaired prior to use.
2. All down-hole drilling equipment and the backhoe bucket will be sand
blasted prior to their arrival on-site.
3. Clean with tap water and phosphate-free laboratory detergent (Uquonox
or equivalent), using a brush if necessary to remove particulate matter and
surface films.
4. Rinse thoroughly with tap water.
5. Rinse thoroughly with deionized water.
6. Rinse two times with pesticide grade isopropanol solvent and allow to air
dry for as long as possible.
7. Rinse thoroughly with organic-free water if it is necessary to reuse the
equipment before solvent drying is complete.
8. Wrap sampling equipment completely with aluminum foil, shiny side out,
to prevent contamination if equipment is to be stored or transported.
Equipment or materials not used immediately after decontamination will be
placed on a plastic sheet, covered with plastic and secured to avoid potential
contamination. Additionally, clean, disposable gloves will be worn while
handling equipment or materials during the final stages of decontamination. A
solvent rinse will not be applied to any PVC development equipment.
13
I
Item
47.
•
Response
3.2.1 Disposal of Excess Cuttings and Drilling Fluids
Water rinsate from the decontamination process will be collected and stored on-
site pending completion of analyses to determine the appropriate disposal
alternative. lsopropanol rinsate will be segregated from water rinsate and
allowed to evaporate.
If mud rotary drilling is required, drilling water and mud will be collected and
stored on-site pending completion of analyses to determine the appropriate
disposal alternative.
Excess soil cuttings or sample material from borings will be placed back in the
borehole. Any additional excess soil cuttings and excess soil cuttings from
monitoring well borings will be collected and held pending completion of
analyses to determine the appropriate disposal alternative."
The Prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-10, section 3.4, paragraph A, change "During the drilling, cuttings
will be collected by the Well Contractor on 1 0 feet intervals to the anticipated
screen interval. The mud rotary samples shall be collected from the mud ditch,
or from a suitable sample collection box." to 'During the drilling, split spoon
samples will be collected on 5 feet intervals to the anticipated screen interval."
48. The Prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-10, section 3.4, paragraph D, third sentence, change to "A 3-foot
thick bentonite seal will be placed through a tremie pipe above the filter pack
and allowed to hydrate for 8 hours. All references to the installation of neat
cement in the well annulus will be modified to reflect the use of a
cemenVbentonite slurry (2 percent bentonite by weight).
49. The Prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-11, section 3.6, third sentence, change to: ''The use of drilling fluid
additives, if necessary, shall be approved by the EPA."
50. The Prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-11, section 3.7, paragraph A, first sentence change to: "The well
casing shall be new stainless steel casing."
51. The Prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-12, section 3.8, after first sentence add: "The pellets will be allowed
to hydrate for 8 hours prior to grouting."
14
I
•
Item Response
52. The Prefinal Design Specifications, Volume I, is hereby modified as follows:
Page 02660-13, section 3.11, first sentence, change to: ''The top of the casing
shall be fitted with a vented cap." After second sentence add: "A weep hole
will be drilled at the bottom of the protective casing to drain accumulated
moisture."
53. The Amended Record of Decision, which the Administrative Order is issued to
enforce, contains Table No. 3 titled 'Groundwater Remediation levels and Cited
References". The cited references do not refer to "Classifications and Water
Quality Standard Applicable to the Groundwaters of North Carolina". The
remediation levels were established in the ROD and NOT by the PRP's or their
Engineering Contractor. In Table 2.4.1 (page 19) of the "Preliminary Operation
and Maintenance Plan", the remediation level for benzylic acid has been
incorrectly typed as 0.21 mg/L. In the final version of the "Operation and
Maintenance Plan" this will be corrected to the appropriate 0.021 mg/L.
54. See response to Item 9.
55. The second paragraph of page 29 will be replaced by the following:
"The collected ground water samples will be analyzed for the contaminants /
of concern as listed in Table 2.4.1 (Page 19)."
56. Procedures to determine water level depths in a well has been discussed in
page 13 under 'Water Level and Flow Rate Monitoring" (Section 2.3.2).
Duplication of the procedure in section 2.4.5 is not necessary.
57. Noted and incorporated.
The equation will be rewritten as:
V = 7.48 ,r2h
where V = volume of water in a well (gallons).
• = 3.14159
r = radius of the well (ft)
h = height of the water column in a well (ft)
15
Item
58.
8
Response
Since all enforcement litigation or evidentiary data will be generated by
laboratories under EPA's Contracting Laboratory Program (CLP) and since CLP
Laboratories have an in-place program for equipment calibration including
specific procedures and frequency, it is not necessary to include it in this
document.
As described in the last paragraph of page 63, the field equipments will be
calibrated in accordance with the manufacturers specifications or documented
requirements in terms of the procedure and frequency.
At this moment, it is not possible to identify the manufacturers. Hence the
suggested incorporation of the field calibration techniques and frequency of
calibrations is not possible. However, after these selections have been made,
calibration procedures and frequencies will be_ added to the Final Operation and
Maintenance Plan.
59. Rinsate blanks are not required for each field cleaning event. In accordance
with "EPA Data Quality Objectives for Remedial Response Activities", field
blanks, alternatively called rinsates, should be submitted at the rate of one field
blank/matrix/day or one for every 20 investigation samples, whichever results in
fewer samples [Page C-12, EPA 540/G-87/003]. However, as Mr. Jon Bornholm
indicated, the Region IV manual (Standard Operating Procedures and Quality
Assurance Manual, April 1, 1986) takes precedence over other QNQC
manuals/guidances.
In accordance with Region IV's manual, the contractor will be required to bring
sufficient equipment that has been properly decontaminated and wrapped to
the site so that the need for deconing equipment in the field is held to a
minimum. For QNQC purposes, one rinsate will be collected for every 20
investigation samples. The Final Operation and Maintenance Plan will be
revised accordingly.
Please note that these changes will be incorporated in the final version of the
"Operation and Maintenance Plan."
16
60.
•
Response
The second paragraph of Section 3.4.4 of page 90 will be replaced by the
following:
"The collected ground water samples will be analyzed for the contaminants
of concern as listed in Table 2.4. 1 (Page 19)."
61. The biological solids from the biological reactor will be disposed as a non-
hazardous waste. Testing the sludge for contaminants will not be necessary.
The only hazardous contaminants of concern in the Back Valley are volatile
organics which will be removed to non-hazardous levels by the air stripper.
Biological sludges result from degradation of the acetic acid which is non-
hazardous.
17
•
Comments from North Carolina DEHNR
Water Quality
The PRP Coordinator and Sirrine met with representatives of the Asheville DEHNR office on
August 14th to discuss options for the discharge of treated groundwater. The DEHNR then
met with the Buncombe County Metropolitan Sewerage District (MSD) to determine the
feasibility of discharging site groundwater to the sewer. The MSD subsequently agreed to
accept an application for Permit to Discharge Industrial Wastewater from the Chemtronics
site. Sirrine is currently preparing the permit application and will keep the Asheville DEHNR
office advised of its status.
Groundwater
As required by CERCLA, the Prefinal Design Analysis references the remediation levels
presented in the Record of Decision. North Carolina groundwater standards will be
considered as long-term remediation goals.
Air Quality
The air dispersion modeling presented in the Concept Design Analysis determined that
maximum potential air stripper emissions would not violate North Carolina air quality
standards. This information was necessary to establish design requirements. The air
modeling information will be submitted to the Western Carolina Air Pollution Control Agency
and they will be kept advised of the construction and operation of the air stripping units.
• •
APPENDIX
•
SECTION 01310
DUST CONTROL PLAN
INDEX
1.0 CONTRACTORS RESPONSIBILITIES
2.0 DUST SUPPRESSANTS
3.0 SUBMITTALS
1.0 CONTRACTORS RESPONSIBILITIES
•
1.1 The Contractor shall conduct operations and maintain the project site so as to
minimize• the creation and dispersion of dust. Dust control shall be used
throughout the work at this site, especially during removal, backfilling, grading
and placement of final soil cover.
1.2 The Contractor shall develop, implement, maintain, supervise, and be
responsible for a Dust Control Plan. This plan shall provide procedures and
equipment requirements necessary to minimize dust on-site. The Contractor
shall submit the Dust Control Plan to the Owner's Representative within 21
calendar days after the contract award date. The Owner's Representative shall
review the Dust Control Plan within 5 days after receipt and shall return the plan
to the Contractor, if necessary, for revision. The Dust Control Plan shall be
approved before the Notice to Proceed.
2.0 DUST SUPPRESSANTS
2.1 Water
A. Water which has been collected during the work, tested, and found to be
clean can be used for on-site dust control in any area. To supplement
these sources of water the contractor must provide clean water, free from
salt, oil and other deleterious materials.
B. Water must be applied in such a manner as to prevent movement of water
beyond site boundaries or create nuisance conditions including ponding.
C. Water application must not interfere with working personnel.
2.2 Calcium Chloride
A. The Contractor may use calcium chloride that conforms to ASTM D98.
•
B. Calcium chloride must not be allowed to enter surface waters.
2.3 Chemical dust suppressants used in place of calcium must be approved by the
Owner's Representative.
3.0 SUBMITTALS
The Dust Control Plan shall be submitted as specified in this section and in
accordance with Section 01230, submittals.
END OF SECTION
'
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
AUG 3 o 1S90
4WD-NSRB
Charlotte Jesneck
Superfund Section
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
North Carolina Department of Environment,
Health, and Natural Resources
P.O. Box 27687
Raleigh, NC 27611-7687
·8'ftGt~~IED
SEP O 7 1990
SUPERFnND SECT/ON
RE: Suspending the Requirement for A NPDES Permit
With Respect to the Chemtronics Superfund Site
Dear Ms. Jesneck:
This letter is to give the State early notice that the Agency
will not require the Chemtronics P.otentially Responsible
·P-arties (PRPs) to obtain a National Pollution Discharge
Elimination System (NPDES) permit in the event that the PRPs
need to discharge treated groundwater to Bee Tree Creek. I
attended a meeting in Asheville, North Carolina between the
PRPs and the North Carolina Department of Environment, Health,
and Natural Resources (NCDEHNR). The meeting was held to
discuss the options the PRPs have for discharging treated
groundwater. Attending this meeting on the States behalf were
Roy Davis, Don Link, and Forrest Westall.
The State clearly expressed that the preferred discharge
alternative was to the local publicly owned water treatment
(POTW) system. Presently, the POTW is resisting accepting the
treated groundwater from the Chemtronics Superfund site. In
·the 8vent that tlie POT"w cannot accept the treated groundwater,
the Agency will allow the PRPs to discharge to Bee Tree Creek
without obtaining a NPDES permit.
The Agency has this authority under CERCLA Section 12l(e).(l).
This section reads "No Federal, S.tate, or local pennit shall be
required for the porti9n of any removal or remedial action
conducted entirely onsite, where such remedial action is
selected and carried out in compliance with this section." As
can be clearly seen, the intent of this language is to allow
the Superfund Program to proceed expeditiously with the
remedial program and avoid the delays created by administrative
requirements. Although the PRPs will not need to satisfy the
administrative requirements of the NPDES program, they will,
however, need to meet the substantive, technical requirements
of a NPDES permit.
-2-
I have enclosed a letter from South Carolina Department of
Health and Environmental Control (SCDHEC) and the response from
the Agency that addressed this issue earlier this year. I am
sharing these correspondences with you to illustrate that EPA,
Region IV is being consistent with this approach.
If you have any questions, please call me at [phone].
Sincerely yours,
tKK~~~
Remedial Project Manager
Enclosures
cc: Lee Crosby
Roy Davis
Don Link
Bob Watson
Forrest Westall
Soutillltrolina Department Miealth
and Environmental Control // .
/~
. , (~ 2600 Bull St=t ! .: . . V Columbia, s.c.-29201 Board
,.
I
. Co~missioner
. Michael D. Jarrett :
llr .. Patrick II. Tobin, Director
Waste.llanagement Division
US EPA, · Region · IV
345 Courtland Street
Atlanta, GA /30365
!larch 8, 1990
R~-State'Permits and RODs for NPL Sites
Dear llr. Tobin:
Toney Graham, Jr .. M.D., Chairman
Henry S. Jordan, M.D., Vice-Chairman
.... John B. Pate, M.D., Secretary
' 1 • ··-;: William E. Applegate
:? ; ·::.(: .:" ··:; Oren L. Brady, Jr.
John Hay Burriss
Euta M. Colvin, M.D.
This letter is written to expres~ the Department's concern regarding
the need to obtain State permits for activities and treatment uni,s at NPL
sites. I feel that obtaining appropriate permits is the best way for EPA
to demonstrate·that the technical requirements have been met. I ~nderstanc
that EPA is concerned that the administrative requirement for obtaining
such permits may delay implementing the remedial action alternative. Let
me assure you that the Department will rake every effort to insure that the
administrative process does not delay jmplementing the appropriate remedia!
action alternative selected in the Record of Decision <HOD). There are
currently two (2) NPL sites, Palmetto Wood and SCR&D Dixiana, where eno~gh
data has been gathered to begin completing appropriate State permit
applications. Therefore, it is 1re~uested that the required permit
applications be completed so that th~ Dep~rtrr.e~t can begin proce3si~; the~.
I In reference to RODs for NPL sites, the Department is concer:ied that
EPA is, in an attempt to expedite the Superfund process, writing RODs vith
multiple alternatives and deci~in; :on a final -~em~dy only a!ter gathe:in;
additional data during the remedial ,gesign phase. The Remecia:
Design/Feasibility Study <RI/FSV phase is ~where the necessary data for
selection of singl~ rem~clial-·,i~tion, alternative should be gathered. The
Department is reluctant to concur with any ROD which lists multiple
alternatives for remedial action. Currently there are two !2l NPL sites,
SCR&D Bluff Road and Sangamo, which appear to be nearing a ROD decision
vi th multiple alternatives for remedial action and·· discharge of treatec
effluent. I encourage E?A to insure that enough data is gathered for these
sites and all NPL sites during the RI/FS so that the ROD can specifically
state a single remedial action alternative.
EWT/njv
cc: Levis Shai,,·
Jim joy
Ly:;n ~2:-t:..:1
Keit~ L:.nc'le:-
~e!vin E!ackwel!
please feel free to call rne at
H~:-~sill W. Trueedale, Chief
E:.;:-eau of Solid ar.d Hazardous Waste
Management
i
(
Mr. Hartsill W. Truesdale, Chief
Bureau of Solid & Hazardous Waste Management
South Carolina Dept. of Health and
Environmental Control
2600 Bull Street
Columbia, South Carolina 29201
i RE: SC State Permits and RODs for NPL Sites
Dear Mr. Truesdale:
This letter is written in response to your March B, 1990 letter
in which you requested that EPA obtain State permits for
activities and treatment units at National ~riorities List (NFL)
Sites in the State of South Carolina. The Agency appreciates
your assurance of timeliness of the administrative process, and
also recognizes your concern that the technical requirements of
a permit are met.
However, as much as the Agency would like to accommodate your
requests, CERCLA clearly states in Section 12l(e)(l) that "No
Federal, State, or local permit shall be required for the
portion of any removal or remedial action conducted entirely
onsite, where·.such .remedial action is selected and carried out
in compliance with this section." The obvious congressional
intent of this language is that the Superfund Program be allowed
to proceed smoothly and expeditiously during the remedial
process. Certainly, the intention was to shield the remedial
program, to the extent possible, from administrative delays.
The clear intent of Congress would be defeated if EPA were
required to obtain permits (to conduct remedial activities) at
the Federal, State, and local levels.
We will, however, continue to meet all the standards and
technical requirements of a permit, and will continue to work
with your Department, but we cannot commit to requesting a
permit. EPA will provide SCDHEC with all draft ~emedial design
work plans and reports for your Department's comments. On the
two sites that you referenced, Palmetto Wood and SCRDI Dixiana,
if you will provide the particular technical requirement that
concerns you, we will be happy to provide you with evidence of
compliance.
•
-2-
In reference to the RODs for NFL Sites, as you know, the 1986
amendments to CERCLA (SARA) state that where possible, the
Agency will focus on new innovative technologies. Testing these
new technologies through treatability studies or pilot plant
studies takes time and the process can be quite lengthy. Along
these same lines, the decision on discharge points often depends
on local POTW's setting discharge limits or on obtaining a NPDES
discharge permit for off-site disposal. While the Agency makes
every effort to obtain as much information as possible during
the RI/FS, many parameters of disposal and treatment are
fi~alized during the Remedial Design phase at the conclusion of
the treatability study.
The Agency will, however, make every effort to obtain the
necessary information to choose one remedy with one discharge
option that is protective of human health and the environment
and that is cost effective.
Please be aware that the State's role in the project does not
end when EPA issues a ROD. Your Department is involved
th:;-oughout t.he. development of the remedial design and the
implementation of the remedial action ..
I hope that this letter satisfactorily addresses your concerns.
Please call me if you have any questions.
Sincerely,
/s/ P;;t:id: M. Tobin
Patrick M. Tobin
Director
Waste Management Division
, • •
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
William L. Meyer
Director
Mr. Jon K. Bornholm
Remedial Project Manager
22 August 1990
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Chemtronics NPL 95% Prefinal Remedial Design
Additional Comments
Dear Mr. Bomholm:
We have reviewed comments generated by the technical consultant for Citizen's
Watch for a Clean Environment concerning the Chemtronics 95% Remedial Design. These
comments emphasize inadequate characterization of groundwater and surface water. The
Remedial Design Plan should provide a thorough description and depiction of
contamination at the site. Comments submitted by our office on 30 July also stated that
drawings in cross section and plan showing the extent of contamination should be provided
in the Remedial Design. Actual well sample data should be depicted on these maps and
drawings. Sufficient well data has not been presented to satisfactorily define the extent of
groundwater contamination.
We would like to re-emphasize that remediation levels should be within the North
Carolina Water Quality Standards NCAC Title 15, Subchapter 2L. As is mentioned in the
comments provided by the Citizen's Watch for a Clean Environment, final samples before
closure of remediation should include the entire TCL/TAL scans and Level 5 analysis.
\
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Mr. Jon K. Bornholm
22 August 1990
Page 2
Comments from the North Carolina Division of Environmental Management are
expected to be submitted in about one week. If you have any questions, please contact me
at [phone].
0/acr
Sincerely,
u~{c~
Charlotte Jesneck
Superfund Section
• '•
UNITED STATES ENVIRONMENTAL PROTECTIO~t:ltll\£Y
REGION IV 4u 11!;,Utfo
345 COURTLAND STREET G 2 0
ATLANTA, GEORGIA 30315 S/Jpllii 1990
'Fl!No SEtrtoN
MEMORANDUM
DATE: AUS 16 19~
SUBJECT: Please Review and Comment on the Attached Comments on
the 95 Percent Prefinal Remedial Design for the
Cherntronics Superfund Site from the TAG Recipient
FROM:
A 6.n,,,J. L..-J0d K. Bornholm
Remedial Project Manager
TO: Addressees
Attached is a copy of the comments I received from the Citizens• Watch for a
Clean Environment. This group is a recipient of a Technical Advisory Grant
(TAG) under CERCLA. These comments are on the 95 Percent Prefinal Remedial
Design for the Chemtronics site. The comments zero in on the existing
groundwater monitoring system, the proposed groundwater monitoring system,
the proposed groundwater extraction system, the Risk Assessment conducted as
part of the RI, and the proposed caps to be built o~er the disposal areas.
Please provide me with an assessment of the attached comments. As we are
closing in on the end of the fiscal year, I would appreciate receiving your
evaluation by Friday, August 24, 1990.
If you have any questions, please contact me at 347-7791.
Addressees:
Elmer Akin, Health Assessment Officer
Bernie Hayes, G-WTU
Charlotte Jesneck, NCDEHNR
Dennis Manganiello, RCRA
Jane Penny, Dynarnac
Winston Smith, APTMD
Chirlin & Associates, Inc. 18 Anamosa Court• Rockville, MD 20855-..
; '.
Consulting
Engineering and Hydrogeology
[phone] -··. :,,·-~ ...
August 11, 1990
.,· .. Hr. Robert B. Watson, President
Citizens' Watch for a Clean Environment
PO Box 956
. : ,_ .. :·. -~ ·;1 '·
Swannanoa, NC 28778 .. •·''
RE.: Preflnal Design Analysis, Chemtronlcs Site Remediation,
Swannanoa, North Carolina, June 1990 (3 vols>,
Preflnal Design Speclflcatlons, Chemtronlcs Site
Remediation, Swannanoa, North Carolina, June 1990 (2 vols>, and
Preliminary Operation and Maintenance Plan, Chemtronlcs Site
Remediation, Swannanoa, North Carolina, June, 1990 <I vol>
Dear Hr. Watson:
Thank you for the opportunity to review the referenced
documents. The attached comments were prepared by
Dr. James Kaweckl, consulting toxicologist, Dept. of
Community and Family Medicine, Georgetown University Medical
Center, Washington, DC <toxicology and risk assessment>;
Or. Gregory Richardson, PE, Executive VP, ENSCI, High Point
NC, an Instructor In the EPA course "Design and Construction
of RCRA/CERCLA Final Covers" (cap design/construction>: and
Dr. Gary Chlrlln, PE, President, Chlrlln & Associates, Inc.,
· consulting hydrologist (contaminant plume characterization,
ground-water extraction, and water quality monitoring>.
These comments describe a number of serious conceptual and
lmplemental shortcomings In the PRP's planned site remedy. Based
on our training and experience, Including at numerous other
Superfund sites, at the Chemtronlcs site
<I> chemical sampling ls too sparse, Infrequent, and
unrepresentative to properly assess migration of contaminants
in surface and ground-waters:
(2) the proposed long-term monitoring ts Inadequate to
character_lze performance of the remedy or dlj!tec:~_ future.-·11(,;t;~'-.':,.·
Increases In risk, even by the most likely· pathwaysJ,. and ·:;:-:;· .. •. _
<3> the remedy Itself has. potentially serious 'design;'.,!'' ·:ii/;/':'.'~--· def lclencles. · ·,_ .. ·· '. --'· .,._. ·<-,,_-_,•·,i.;""'.-,:,'·--
•• w , '"''J ~ • lf,., 1' i
We hope that EPA will require the PRPs to tak_e corrl!,c::t!Y,Et;;,:,;;,_,,
measures. Some suggest l ons are made l_n our comments. ·rurt.her;ll!or~,,
lf substantial changes are made ln-the remedial plans, ·then'•we:· _,:
would be happy to conduct a timely review of the revlsed:·plans:.--': . · ... ~> ; ; : : ., \~ ~;~:';;_:;·::,~.
Respectfully submitted, ,,i: · · :··_ , , '.?':";1::;\.
·f•.--~ f.
: ,••'~•-.1 .....
.. .-~ ~; ..
., ....... ;_~.
.. ' . ''·t: . .:.-•
. :_ .•.\,;.~·
-~ .. J~ 5;~:-
• -1:il~r-
C&:!:,~~f~NC:• .... ,,•r. --.•·1~: _:,.::·1 .· ;>" •
.,. ·Jr~-,.-:-,
'··,
Gary R. Chlrlln, President ., . : ' ..
. :· ---~::::(;/~::
CI'fIZEI'{_S9' A'fCII FOR A CLEf\TVIRONMENT
· Post Office Box 956
Swannanon, North Carolina 28778
By: Chlrlln & Assoc/ates, Inc. ('lugust JI, 1990
Rockville, Maryland
COMMENTS ON PREFINAL DESIG~ ANALYSIS,
DESIGN SPECIFICATIONS, AND PRELIMINARY O~M PLAN
CHEMTRONICS SITE REMEDIATION, S~ANNANOA, NC
JUNE, 1990
GENERAL
t. A survey of all existing wells for ground-water eleyat\on \n
a non-drought, non-summer period Is needed. This CERCLA site Is
In Final Design yet has only one complete round of water level
readings. Even RCRA facilities measure quarterly. This will
permit verification of ground-water flow direction under more
normal conditions. It will ·also reveal whether any known wastes
are now below the water table. (The findings of the RI are
Inconclusive In this respect). Wastes below the water table would
not be contained by a cap.
2. I find It remarkable -and regrettable -that only a single
round of surface water quality sampling has been performed during
the entire course of the field Investigations at this site.
Particularly In light of the unusual drought conditions during
the RI, and also for quality assurance purposes, one should
resample the surface water stations at the Chemtronics site. This
data would offer an applicable (non-drought) baseline against
which Improvements could be measured as source controls are
Implemented. Such a survey could be Implemented as a part of a
surface water monitoring program which would parallel the ground-
water sampling program of the PreFlnal Design Analysis <PFDA>.
3. Bis (2-ethylhexyl) phthalate was detected _In several wells In
both valleys, yet Is dismissed is a well Installation or
laboratory contaminant. If the former, then time <since 1985.) and
proper well purging procedures shouid ell.mlnate the problem. If
the latter, then laboratory quality control must be examined,
because bis (2-ethylhexyl) phthalate Is not a common laboratory
contaminant. Wells affected by bl~ <2-ethylhexyl) phthalate
should be resampled, If bis <2-ethylhexyl> phthalate persists In
the analyses, then measures should be taken to contain or extract It. .
4. I applaud the additional effort made by the PRP's contractor
which ultimately led to an Increase In coverage of several of the
disposal area caps. Unfortunately, no Information or data was
provided In the reviewed documents allowing one to 1udge the
appropriateness or adequacy of these reyls!ons. This Information
Chirlin & Associates, Inc.
Rockville, Maryland
should be made available for reylew.
August 11, 1990
5. Nowhere In six years' worth of documents (Work Plan/RI/FS/
ROD/Conceptual Deslgn/PFDA/PreFlnal Speclflcatlons/PO&M> does
there appear any sketch of the extent of ground-water
contamination for any chemical. One might fairly ask after all
these studies, "Where are the contaminant plumes?" There Is. no
answer principally because of the paucity of monitoring wells at
each of the Disposal Areas of the Chemtronlcs site. Several of
the following comments address this matter. EPA may also wish to
compare the Chemtronics monitoring network to that of another
Superfund Site with a similar industrial history: the Aerojet
General Corporation site near Sacramento, CA.
FRONT <PICRATE> VALLEY
A. Monitoring to Assess Contaminant Distribution
6. Although DA-10/11 Is k~own to have received BZ and CS wastes,
and although CS wastes were found in test pit soil, nevertheless
well SW-2 was not sampled for CS and BZ contaminants. Given that
SW-2 is the principal well being used to demonstrate lack of
migration from DA-10/11, this Is a serious oversight. Well SW-2
should be sampled for CS and BZ.
7. Area DA-10/11 was Included in the FS principally because It
Is felt to pose a threat of future releases to the ground water
(e.g., FS Table 3.1). Nevertheless, the proposed monitoring
program of the conceptual and prefinal design documents does not
specify any observations which could reveal onset of leakage from
DA-10/11. In addition to a program of surface water monitoring
related to this site (see related comments below), wells SW-2 and
BW-2 should be Included In the ltsi of monitoring wells In
section 2.4.3 of the Preliminary Operation and Maintenance Plan
<PO&H>, Furthermore, one new monitoring well cluster should be
Installed ENE of DA-10/11 because ~his Is the direction of
ground-water flow In the bedrock <RI Table 3.2-3). I also suggest
that a second cluster'be Installed further downgradtent, behind
Building )04 southwest of the drainage channel. Both new clusters
should be part of the PO&M ground-water sampling program. Since
these are detection -rather than quantification -measures,
composite samples or analyses could be performed to reduce costs.
8. BZ was present In several wells CSW-4, BW-4, M85LIO)
.downgradlent of DA-23. BZ concentration has been Increasing at
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August 11, 1990
all wells where repeated observations were made Cat SW-4, BZ
concentration was 0.49 mg/1 In 6/86, 1.2 mg/1 in 10/87, and 3.4
mg/1 in 1/89). Nevertheless, the stream sample CRW-7) near to DA-
23 was not analyzed for BZ or CS. In fact, only one surface water
sample In Unnamed Valley was analyzed for BZ and cs CRW-10, which
Is 400 feet upstream of well H85Lll).
Thus BZ Is Increasing (n the groundwater which drains to
Unnamed Branch. The Impression that BZ (or CS) is not migrating
offslte In surface waters rests on analysis of a single sa~ple
taken at RW-10 on June 12th, 1986. I suggest that Unnamed Branch
be resampled for BZ and CS at several points. Including stations
RW-7 and RW-10.
B. Monitoring for Remediation Performance Evaluation
I recommend review of the attached excerpt from the EPA
Ground Water Issue paper Performance Evaluations of Pump-and-
Treat Remediations by Joseph F. Keely, Superfund Technology
Support Centers for Ground Water, October 1989. It describes the
types and functions of ground-water monitoring during a remedial
period. I Introduce terminology from that paper in some of the
following comments.
9. There are insufficient monitoring wells to observe the effect
of the proposed ground-water extraction system near DA 23. The
proposed wells Include only 3 clusters which will be useful for
definition of the zone of capture, namely S/BW-4, H85L4/IO, and
S/BW-5. In order to assess whether the system Is Indeed creating
the desired capture zone, several <say. 4) additional plezometer
clusters will be required. and unlike the existing set they
should not be collnear. In Keely's terms these plezometers are
gradient control points, and at least some should be located just
outside the plume. They are necessary to meet the third
("evaluate contaminant plume containment") and fourth ·c•determlne
the need for extraction well networK modifications") data quality
objectives described In PO&H Sectt'on 2.4.2. Without additional
plezometers In the area around the pumping wells, It Is futile to
attempt the "hydraulic performance assessment• of PO&M section
2.5.1.
10. In the terminology of Keely (1989), the proposed monitoring
plan for Front Valley completely lacKs natural water quality
monitoring points, whose purpose Is to "Indicate out-of-control
conditions when a portion of the plume escapes the remedial
action". At this site, a surface water sample Just downstream of
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August 11, 1990
DA-23 would provide a natural water quality monitoring point for
shallow ground-water flow. <Comment #xx also recommends this
sampling location). One or more deep Cbedrock-saprollte contact)
natural water quality monitoring points Is also appropriate.
However, before one can specify Its locatlon(s), the extent of
the existing plume must be determined (see comment #5).
11. The proposed ground-water,,'.sampl Ing locations during
remediation are SW4 and BW4 only. In Keely's terms, they are
[internal] plume monitoring points. The Conceptual Design
Analysis also Include~ M85L4 and M85L10 as !Internal] plume
monitoring points; these were deleted In the Preflnal Design
Analysis CPFDA> without explanation. Based on the RI data, SW4
and BW4 are Indeed highly contaminated wells. However, SW4 and
BW4 water quality should not be the sole determinant of whether
DA-23 has ceased to contaminate the ground water, For Instance,
In 1986 plcric acid was detected in M85Ll0 and was not found in
SW4 or BW4; M85LIO clearly taps Into a different source area
within DA-23, and therefore It, too, should be routinely
monitored. The same can be said of M85L4 based on the singular
presence of Trans-1,2-dlchloroethene.
12. During remediation, effluent from STW-1 and BTW-I will
provide an unparalleled opportunity to measure most of the
contamination leaching from DA-23 Into the ground water;
therefore pumping well effluents should at a minimum be monitored
using the same schedule and parameters as SW4 and BW4 1 and clean
effluent should be one criterion for halting pumping. Be aware
that in using a suberslble pump to obtain the samples, volatile
organics will tend to be underestimated. Nevertheless, positive
readings will still have considerable Information value. It Is
unclear from PO&M section 2.4.3 which parameters would be
measured In extraction well effluent, and at what detection
limits. The PO&M (pg. 29) refers to·"selected operational
parameters· after the first year. This terminology Is vague
enough to suggest to a skeptic that the analysis may be of no use
In assessing progress of the remediation. The PO&M should clearly
state the water quality monitoring requirements for pumping well
effluent. I would strongly urge that effluent from the two
pumping wells be analyzed annually for the ·contaminants of
Concern• of PO&M Table 2.4.1.
It should also be recognized that clean effluent will not
demonstrate complete recovery of ground-water contaminants,
because of both the dilution effect of captured streamflow from
Unnamed Branch and the effects of any fugitive NAPL or uncapped
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wastes (which causes concentrations to rise upon cessation of
pumping (Mackay and Cherry 1989, ES&T 23(6):6301>.
13. The planned •evaluation ol conta1lnant dl5trlbution• (PO&M
section 2.5.2) requires:
a) "Isopleth maps for each contaminant of concern•. However,
it Is patently lmposslbl• to develop meaningful Isopleth maps
using a single monitoring location (S/BW-4). Furthermore,
without a natural water quality monitoring point (Keely,
1989) just downgradlent.of the existing plume, one cannot
Intelligently draw the critical •zero• contour on such a map.
Finally, under the proposed plan after the first year only
Indicator parameters will be analyzed; this suggests that
most contaminants of concern will not be measured and
therefore will not be mapped (see next comment);
b) •concentration versus time curves for each contaminant at
each monitoring point·. However, after the first year only
Indicator parameters will be analyzed (pg. 29) and therefore
the concentration of most contaminants of concern may not be
determined -or graphed -even though they were detected
during the first year.
These PO&M monitoring plans are vague (what Is an Indicator
parameter anyway? TOK?)-and may be nearly useless. I urge that
additional monitoring wells be established <see related comment>
and that all monitoring wells be analyzed annually for the
"Contaminants of Concern· of PO&M Table 2,4,1, If a contaminant
does not occur for several years, then it may be deleted.
However, det~cted contaminants should be individually quantified.
The final samples before closure of the remedial system should
once again Include the entire TCL/TAL scans and Level 5 analysis.
14. Because the water quality of baseflow In Unnamed Branch
directly reflects ground-water quality, and because Unnamed
Branch collects most ground-water flow from beneath Disposal
Areas 10111 and 23, the routine monitoring program should Include
chemical analvses of surface water samoles from uostream and
downstream of these Disposal Areas. Care should be taken to
sample during periods of baseflow. Such surface water samples
integrate ground-water flow from an entire sub-basin and thus can
detect contamination regardless of the circuitous route
contaminants may follow through the ground. Samples from
monitoring wells characterize only a single •streamtube" and are
easily bypassed by contamination, especially If the wells are
close to the source as is the case at this site.
For Instance, It would be Informative to sample Unnamed
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Chirlin & Associates, Inc.
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Aurust JI, 1990
Branch baseflow just upstream and just downstream of the discharge zone of DA-23. The -stream Is presently a drain for
contamination emanating from DA-23, and will continue to receive
DA-23 wastes If the source control Is inadequate. To demonstrate
that the cap and extraction system are effective source controls,
one should require that stream samples show no Incremental
contamination from DA-23. (Also see J. Kaweck! comments on the
limited value of proposed bl&assay monitoring).
15. During preparat!OQ of the Workplan (COM 1985) a small stream
Issued from the DA-10/11 valley. In the drought of 1986 there was
an "Inadequate source of water to sample" In this channel <J. F.
Schultheis letter to Jon Bornholm dated 10/21/86). A recent
(7/22/90) site visit indicated that at least in the mid-summer,
flow ls still negligible. However, the PO&M sets out a thirty-
year monitoring plan. There will be periods like 1985 once again,
with baseflow in the !nterm!tient stre~ms. The chemical quality
of this stream segment could-reveal any leakage of contaminants
from DA-10111. When present. the baseflow of this DA-\0/1\ stream
should be analyzed as part of routine monitoring for the complete
set of contaminants of concern <PO&M Table 2.4,\>. This
measurement will be an Important contribution to the presently
sketchy assessment of leakage from DA-10/11. In addition, I
suggest that wells SW2 and MW2 be pumped for some time to gather
tn any nearby contam\nat\on. and then resampled. At DA-10/11 the deepest soil samples submitted for analysis
were 20-22 feet below land surface, and one of these [DA-10/11-21
contained 1,2-dlchloroethane. Contamination may be deeper. The
water table In DA-10/11 was as little as 32 feet below land
surface during the 1986 drought and may presently be higher. If
waste sits In the saturated zone, a cap will not control leachate
formation and migration. I also note that bor\ng DA!0/\1-5 was
high In total cyanide yet lies outside of the new cap boundary.
16. Proposed bloassay sampling point BA-2 (PO&M Fig. I.I.I) Is
located upstream of any surface water discharge from DA-10/11. It
should be shifted downstream to Include this basin; I suggest
plac\ng BA-2 across from the BW-6/IW-\ well cluster.
17. Modifications in cap coverage <the PFDA made several) occur
because the location and extent of Chemtronlcs disposal areas are
not fully known. This uncertainty Is the principal argument for
regular, comprehensive chemical monitoring of Unnamed Branch,
which collects ground waters from all portions of Front Valley.
Data reported In the RI Indicate that -several reaches of the
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Rockvllle, Maryland
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stream are receiving chemical contaminants, Including In
Intervals where no disposal area has been Identified. e.g.:
RDX at RW-3 upstream of all known dlsposal areas: note that
the ROD lncorrectlv labels ROX as Chloroform at Rw-3;
an Increase In TCE between RW-12 and RW-10 downstream of all
known dlsposal areas: and
unexplained and uncontrolled contamination at wells SW5, BW5
and spring #I across Unnamed Branch from DA-23, well SW6
upgradlent from DA-23, and well M85LII near building 140.
It ls clear from this and other evidence that there are sources
of ground-water contamination In Front Valley in addition to the
two Disposal Areas Identified In the Work Plan and RI.
18. In light of the uncertainty of the location of dumping
grounds, It would be appropriate to Install and routinely sample
a lJne of monltorlns weII·s across the mouth of Front Yallev,
Several (say, 4 to 6) additional wells -would be advisable,
situated more or less northeast and south of well M85LII. These
wells would serve to demonstrate lack of offslte migration of
ground-water contamination now and during the course of
remediation and post-remediation monitoring.
19. The bloassay monitoring plan In both valleys Is not a
substitute for surface water and ground-water chemical monitoring
programs, As proposed, the bloassay program runs Independently as
an interesting, research-like data acquisition program. We do not
advocate deleting the bloassays, but favor Incorporating
potential findings into the declslDn-maklng process. At present,
a "kill" does nothing more than sl~ply extend the bloassay
monitoring Itself. Also see comments by J. Kaweckl.
C. Ground-water Extraction System ~eslgn
20. It would be practical to use the natural Front Valley drain -
the Unnamed Branch -as a component of the ground-water
extraction system. One could continuously treat the flow of
Unnamed Branch In order to remove dissolved and suspended
contamination. This would alleviate the bleed of contaminants to
Beetree Creek. (A single round of surface water samples in 1986
Is Inadequate to evaluate long-term contaminant loading to the
creek. See earlier comment). Even near DA-23, the extraction
wells may not capture all contamination leaching to the creek.
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For example, the concentration of 1,2-dichloroethane was higher
In the adjacent stream sample <RW-7) than in either proposed
extraction well.
A stream diversion/Intake for treatment would best be located
as far downstream as possible, on or near to the property line.
This would capture and treat contaminants such as ROX and Picric
Acid, 1,2 Dlchloroethane, Tr~chloroethene, and Chloroform, all·of
which were detected In down's'tream water samples RW-12 and/or RW-
10. The average flow of Unname~ Branch Is about 107 gpm <RI pg.
3-24), which Is a workable flow rate for continuous treatment.
Stormflows could be ~~ffered In a holding pond.
21. The proposed extraction wells srw-1 and DTW-t w111 capture
ground water flow In a zone substantially narrower than <perhaps
one half as wide as> that predicted )n the conceptual and
preflnal design documents. This Is true because the analysis
incorrectly assumes that drawdowns from tests of the two pumping
wells may be added together. In fact, there can be considerable
Interference between the two wells, and both wells pumping
together may create a zone of capture which differs little from
that of either one alone. The only way to determine the true zone
of capture Is to begin pumping both wells and to monitor drawdown
In several new plezometers distributed throughout the desired
capture zone <see comment I). A two-well test should be done
Prior to finalizing the number and location of extraction wells
needed to capture ground-water flow from beneath DA-23.
22. Based on a detailed review of analogous calculations for the
Back Valley <see comments In Appendix A>, It Is likely that the
pump test analyses and capture zone calculations for the Front
Valley were performed Incorrectly. All related calculations
should be examined and appropriate ~hanges made In extraction
system design.
D. Water Treatment
23. There ls apparently widespread chromium contamination In
Front Valley. Contamination outside of the DA-23 area will not be
addressed, even though the cleanup criterion in the ROD requires
remediation to a level of 0.05 mg/1. For Instance, well IW-1
contained 0.44 mg/1 of chromium In 1986, and Unnamed Creek
conveyed 0.10 mg/1 at station RW-12. How will chro~lum
contamination be contained throughout the valley?
24. What were the liquids which entered the ground water when the
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original b!olagoon at DA-23 failed !n 1979? What compounds did
they contain? What volume of liquid escaped? Where Is It now? CA
PRP consultant, Environ, Inc., asked similar questions !n a March
31, 198 letter to EPA, attached to the ROD). This unresolved
matter should be addressed prior to finalizing number and
location of extraction wells, and treatment processes.
. ' BACK <GREGG> VALLEY
A. Monitoring to Asse~s Coniam!nant Distribution
25. The downstream extent of the contaminant plume emanating from
the Acid Pit and DA-9 is not known. There are no wells In the
approximately 800 ft by 500 ft area which may contain the front
of the plume. It remains credible that the plume has reached
Beetree Creek. The single downgradlent monitoring well (BW-11) is
approximately 1000 feet from the Acid Pits and was sampled only
once. The analytical results for the sample from BW-11 are of
virtually no diagnostic value because: '
a) BW-11 is cased (not open) to the upper 75 feet of
saturated thickness and therefore does not characterize the
shallower depth interval where most contamination is found
throughout the site;
b) well BW-11 Is in virtually impermeable rock, and therefore
ls hydraulically isolated from local ground-water flow. A
sample from BW-11 (if a valid one can be obtained> does not
characterize the quality of the migrating ground waters In
the area, not even over the well's deep uncased interval. In
both packer tests reported in the RI (Appendix Mand Table
3.2-5) It was concluded that BW-11 has "essentially no
permeability in that no water was taken by the bedrock under
various pressures during packer tests· (RI pg 3-42); and
c) the sampled water from BW-11 was probably not aquifer
water. Because of the nonconductlve materials tapped by BW-
11, the RI could not properly purge three borehole volumes
from the well prior to sampling on 6/2/86. In fact •static
water level and therefore purge volume could not be
determined due to very low permeability of aquifer In this
area• (RI Appendix M). Therefore the well was pumped dry and
.the (partially recovered?) water column was sampled the next
day. This water was likely a mix of drilling water which had
been In the well since Its construction/development and a
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small amount of packer test water, both well-aged.
In short, BW-11 ls definitely not a useful well to characterize
local aquifer water quality. As a sentry to detect contam!nant
migration from the Acid P!ts/DA-9, BW-\\ has virtually no value,
And no other existing well fulfills this role either.
Based on a pore water vel.o,cl ty of 148 ft/yr (Conceptual
Design Analysis Table 4.9 ana:,~ESSQ modeling) and assuming
contamination began at the Burning Ground In 1952, mobile
contaminants will have_ migrated over 5600 feet from the Acid
Pits. Even assuming that contamination began In 1975 when
Chemtronlcs Inc. reportedly started to dispose of liquid acidic
wastes, mobile contaminants will have moved over 2200 feet
downgradlent.
The proposed extraction wells have a predicted downgradlent
range ("stagnation point• distance> of 20 feet according to the
PFDA and 64 ft according to my calculations. In either case it is
likely that the proposed extraction system w111 not recover most
of an existing body of contaminated ground water downgradlent of
the Acid Pits and DA-9. I would advise adding monitoring wells to
define the extent of the Acid Plts/DA-9 plume, and as necessary
adding or shifting extraction wells to contain and recover the
entire plume.
26. DA-6 was Included In the FS principally because It Is felt to
pose a threat of future releases to the ground water (e.g., FS
Table 3.1). Nevertheless, the proposed monitoring program of the
PFDA does not specify any observations which could reveal onset
of leakage from DA 6. In addition to a program of surface water
monitoring related to thls slte (see related comments), wells SW-
12 and sw~13 should be added to the list of monitoring wells In
section 2.4.3 of the P0&M. Bedrock ls shallow here; bedrock wells
should be added adjacent to sw-12 and SW-13. Furthermore, one new
monltorln·a well should be installed rnldwav between these two
wells to fill a large gap In the monitoring network. Since these
are detection -rather than quantification -measures, composite
samples or analyses could be performed to reduce costs. li
necessarv, add extraction wells to recover 6ontamJoatton found to
be emanatlna from DA-6-
27. An analogous comment applies to DA-7/8. There, however, the
llst of potential leachate contaminants Is much longer (ROD,
Table No. 4) and there Is only one existing downgradlent
monitoring well, X-4s. Well X-4s Is 14 feet deep, of unknown
screen Interval (RI Appendix F-1), and was not reported as purged
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Chirlin & Associates, Inc.
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during sampling CRI Appendix M). It Is Immediately adjacent to
Gregg Branch and appears to be upstream of much of the ground-
water flow beneath DA-7/8. Therefore, the water sample from X-4s
ls not adequate to conclude that DA-7/8 does not leak. I would
install and sample a long-screen monitoring well or a well
cluster 50 to 75 feet southeast of the center of the southeast side of DA-7/8. If the well<s> proved to be contaminated, then
ground-water extraction would be appropriate.
28. BZ (19 mg/1) was present In ground water recovered from the
eastern portion of the Acid Pits during the DTW-2 pump test CPFDA
Table 3.2). Ground water In this area drains to the middle limb
of Gregg Branch (northeast of DTW-2). The nearest downstream
surface water sample CRW-21) was not analyzed for BZ Cor CS). In
fact, only one surface water sample in Gregg Valley was analyzed
for BZ and CS CRW-24, which Is adjacent to well SW-9 on the south
limb of Gregg Branch).
Thus BZ Is In the groundwater which drains to the middle limb
of Gregg Branch. The Impression that BZ Cor CS) Is not migrating
offslte In surface waters rests on analysis of a single sample
taken at RW-30 In Beetree Creek beyond the confluence with Gregg
Branch. I suggest that Gregg Branch be resampled for BZ and CS at
several points. Including at a minimum stations RW-21, BA-3 <see
PO&M Fig. 1.1.1 >. and RW-28.
B. Monitoring for Remediation Performance Evaluation
29. The remedial monitoring program will not provided sufficient
lnformatlon to assess the nroaress of the remedlatlon, In the terminology of Keely (1989),
a) the proposed monitoring plan for Back Valley completely
lacks natural water quality monitoring points, whose purpose
ls to "Indicate out-of-control conditions when a portion of
the plume escapes the remedial action". Even the
"downgradlent" monitoring wells MW! and MW2 are within the
zone of capture and therefore not actually downgradlent of
the extraction system. (Stagnation point offset x. ls
estimated to equal 64 feet for a single pumping well and will
be even larger due to Interference between wells. See
Attachment A>. Thus MW-I and MW-2 will not satisfy their
stated purpose "to evaluate water quality downgradlent of the
system" <PO&M pg. 90>. Shift the HW-J and HW-2 clusters further downgradlent. Furthermore, there should be at least
one CI would recommend two) additional monitoring well
cluster(s) located between MW-I and MW-2. (Examine PFDA
I I
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Chirlin & Associates, Inc.
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August 11, 1990
blueprint drawing G-9169-C-13 for perspective>.
b) the proposed monitoring plan has an Inadequate
distribution <number and location) of gradient control
monitoring points. These are used to determine the capture
zone established by the extraction system. (See next
comment>.
30. The "flow net• approach of the PFDA, when based on adequate
field data, Is the best method of designing, assessing, and
optimizing an extraction system. A reasonable network of
plezometer clusters <say, 6 to 10 more> should be Installed In
the vlc1nltv of the extraction wells ln order to measure the
sbace of the olezometr\c surface durlna extraction ooeratlons. If
the shape Indicates that all flow converges to pumping wells,
then the system Is satisfactory (and In fact certain pumps may be
seen to be unnecessary>. If not, then additional extraction wells
will be required.
31. Well BW-3 Is proposed for water level monitoring during
remedlat1on of Back Valley CPFDA pg. 150). However, BW-3 Is not
In the Back Valley. It Is In the Front Valley.
32. I made earlier Front Valley comments concerning the PO&M
plans to monitor only "Indicator parameters· at monitoring wells
and "selected operational parameters• at extraction wells, and
concerning the "evaluation of contaminant distribution and
extraction· (Sect. 2.5.2). These comments also apply to the Back
Valley. I urge that all extraction and monitoring wells be
sampled annually for the Contaminants of Concern In PO&M Table
2,4.1. If a contaminant does not occur for several years, then It
may be deleted, but detected contaminants should be Individually
quantified. The final samples before closure of the remedial
svst~m should once aaaln include the entire ICL/TAL scans and
Level 5 analvsts-
33. Because the water quality of baseflow In Gregg Branch
directly reflects ground-water quality, and because It collects
most ground-water flow from beneath Disposal Areas 6, 7/8, 9, and
the Acid Pits, the routine monitoring program should Include
chemical analyses of surface water samples from upstream and
downstream of these Disposal Areas. Care should be taken to
sample during periods of baseflow. Such surface water samples
Integrate ground-water flow from an entire sub-basin and thus can
detect contamination regardless of the circuitous route
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Chirlin & Associates, Inc.
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August 11, 1990
contaminants may follow through the ground. Samples from
monitoring wells characterize only a single •streamtube· and may
be bypassed by contamination, especially If the wells are close
to the source as Is the case at this slte.
For Instance, the RI found that volatile organics are
leaching from DA-7/8 and/or DA-9 Into Gregg Branch (sample RW-24
and RI pg. 3-149). The proposed extraction system will not
Intercept any ground-water flow traveling from DA-7/8. It ls also
very unlikely to Intercept flow between DA-9 and Gregg Branch
upstream of RW-24. In other words, the source of Gregg Branch
contamination upstream of RW-24 probably will not be contained by
the proposed remedy. Therefore I would suggest that as part of
routine monitoring during remediation, sample Gregg Branch
baseflow just upstream and just downstream of the discharge zone
of these two disposal areas. To demonstrate that the cap and
extraction system are effective source controls, one should
require that stream samples show no Incremental contamination
from DA-7/8 and DA-9. <Also see J. Kaweckl comments on the
limited value of the proposed bloassay monitoring).
C. Ground-water Extraction System Design
34. The principal function of the DTW-2 pump test was to provide
a technical basis for designing the horizontal spacing and
vertical open Intervals (screen and/or open hole) of the proposed
extraction wells. Unfortunately, the PFDA makes several serious
technical errors In the analyses of the test at DTW-2, and In the
application of both methods of capture zone analysis (·flow-net
and ·theoretical·>. Errors range from choice and application of
pump test methods to neglect of well interference to the use of
Incorrect values In formulas. Because of the dry and lengthy
nat1i're of supporting explanations, they are relegated to
Attachment A.
The PFDA errors lead to an overestimate of the transmlsslvlty
from the DTW-2 pump test and an unfounded estimate of the width
of the capture zone, Glyen the PFDA's Incomplete understanding of
ground-water hydraulics, EPA should take particular care In
establishing a plezometrlc monitoring network for the extraction
area. It must be adequate to determine -using field data -the
horizontal and vertical extent of the capture zone, The PFDA-
proposed network needs revisions <see related comments>.
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Ch/rlln & Assoc/ates, Inc.
Rockville, Maryland
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August 11, 1990
ATTACHMENT A. HYDRAULIC ANALYSIS OF THE
BACK VALLEY EXTRACTION SYSTEM
Al. Although the PFDA did not recognize It. the pump test at DTW-
2 was strongly Influenced by water table (or vertical leakage)
effects. This Is clear from several pieces of evld_ence.
First, the water level In ~umping well DTW-2 fell below the
top of screen at approximately 70 minutes Into the test. In
fact, by 1300 minutes the entire upper screen was dewatered.
Thus, the test began with a partially penetrating pumping
well, but soon converted to water table conditions.
Second, water levels within observation wells X-3 and SW-II
were below top of screen throughout the test. Well X-3 has a
short saturated screened Interval (1.99 feet on 8/26/86) and
showed a 0.12 foot drawdown during the pump test. This
demonstrates that effects of the test reached the water
table. Well SW-II has a longer saturated screened Interval
(32 feet), and probably acted as a short-circuit between the
mid-level saprollte and the water table, thus reducing
drawdown.
Third, the strong vertical gradient In drawdown at the well
cluster SW-11/IW-2/BW-9 Is typical of dewaterlng (see
attached Fig. A).
Fourth, the three clustered wells <BW-9, IW-2 and SW-II)
yield estimates of transmlsslvlty from the Theis •type curve
solution• (Revised Table 2.2) which Increase monotonically
from 7 ft' /d (deep well> to 34 ft2/d (middle well) to 55 ft 2 /d
(shallow well). This trend Is just as would be expected when
the Theis model Is Inappropriately applied to a setting with
water table/vertical leakage effects. Normally, three
adjacent wells would be expected to yield the same
transmlsslvity estimate (Indeed, have essentially Identical
drawdown data) under the Theis assumption of full
penetration. That they do not Indicates that the Theis model
should not be applied to the data.
The high storage coefficient associated with the water table
acts to reduce drawdown compared to tests In a confined setting.
The PFDA assumes confined conditions. A lesser drawdown Implies a
greater transmlsslvlty (all else being equal). Therefore, tl.Y.
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Chirlin & Associates, Inc.
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August 11, 1990
Ignoring water table/vertical leakage effects, the PFDA analysis
overestimates transmlsslylty In the vicinity of the Acid Pits.
This error affects estimates based on every one of the
observation wells, during pumping and during recovery, and for
all the PFDA methods of Interpretation. In particular,
transmlsslvlty estimates based on analysis of all wells other
than BW-9 are unfounded and should not be used.
In passing, It follows that the "apparent recharge effect"
discussed In the PFDA <Vol. I, p. 13) Is actually a water table
effect (or equivalently, a vertical leakage effect), and not due
to partial penetration. Interpretations based on partial
penetration <e.g., pg. 16) should be revised.
A2. The PFDA rightly cautions that early time pump test data Is
affected by pumping wellbore storage (pg. II>. The PFDA then
ignores·lts own warning and erroneously Interprets early time
data using the Theis Type Curve Solution (pg. 13-14: Revised
Table 2.2). During this early time period the pumping rate "felt"
by the aquifer is Increasing from Oto the actual pumping rate of
1.4 gpm. An appropriate method to analyze such data Is given by
Papadopulos (1967) CDrawdown distribution around a large-diameter
well, IN Proc. Nat. Symp. on Ground-Water Hydrology, AWRA, San
Francisco, CA, Nov. 6-8, pp. 157-1681.
For well BW-9, the Papadopulos (1967) type curve yields a
transmlsslvlty estimate of 10 ft'/d with a storage coefficient of
10-•. The type curve matches the log-log data perfectly for time
up to approximately 220 minutes. (The PFDA Indicates
dissatisfaction with its match; see pg. 13). Beyond 220 minutes,
the drawdown Is less than the Papadopulos type curve would
predict, as would be expected when water table/vertical leakage
effects begin.
A3. It Is Important to analyze the early data from monitoring
well BW-9 In the DTW-2 test because of the confounding Influence
of the water table Cor vertical leakage) on later data. In !ts
semi-log analyses, the PFDA mistakenly uses later data without
recognizing that water table/vertical leakage effects are
present, and therefore overestimates the transmlsslvlty of BW-9
<Revised Table 2,2).
From the Papadopulos (1967) analysis, the break In semi-log
slope In the B-9 well data at 220 minutes Is now seen to be due
to a factor other than wellbore storage, and most likely reflects
15
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Chirlin & Associates, Inc.
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August 11, 1990
a water table effect. Data for time greater than 220 minutes
therefore should not be used for the Jacob (semi-log) analysis.
The reported estimate of 22 ft'/d Is therefore Incorrect. An
estimate of 11 ft'/d based on the first slope (80-220 minutes> Is
appropriate, and Is consistent with that developed from the
Papadopulos (1967) type curve match. The later slope break at 813
minutes Is emphatically not due to wellbore storage, as
erroneously stated and calculated In the PFDA (Vol. !, pg 16 and
Vol. 3, Appendix G3: Casing Storage Effects).
A4. Because of the connectivity and vertical flow between the
bedrock and the saprollte throughout the DTW-2 test, none of the
monitoring data Is appropriate to estimate a separate "Saprollte
transmlssivlty". Representations of this quantity In the PFDA
(e.g., Revised Table 2.2) are unfounded. The value of 68 ft'/d In
Table 2.2 Is an artifact of an analysis which neglects water
table effects and ignores the vertical flow from the saprollte to
the bedrock during the test. And _from a practical point of view,
vertical hydraulic conductivity of the saprollte, and not
saprollte transmlsslvlty, is of principal concern In a design
which seeks to drain contaminants downward to deeply-screened
extraction wells. Vertical hydraulic conductivity was not
estimated by the PFDA.
Furthermore, drawdown data from the shallow and mid-level
wells SW-II and IW-2 Imply that vertical flow persists at least
1300 minutes Into the pump test <Figure A). Therefore, It Is
Incorrect to Interpret drawdown data from these two wells as
measurements from a fully-or partially-penetrated confined
aquifer. Neither the Theis <type curve) or Jacob (semi-log)
methods should have been applied. I suspect that these wells
measure head within an aqultard of sorts -an Interval of
moderately lower conductivity overlying a conductive bedrock-
saprollte contact.
In summary, all of the DTW-2 pump test analyses In the PFDA
are faulty, and the net result Is an overestimate of
transmlssivlty from the available data. This Is one of the errors
made by the PFDA when calculating the capture zone for an
extraction well. The next comment addresses this matter.
A5. The PFDA misuses the Bear (1979) formulas for stagnation
point and capture zone width. The analyst may not have understood
the definition of q 0 , the uniform discharge per unit area. The
value of q b was not <and rarely Is) measured directly, but . .
16
Chirlln & Assoc/ates, Inc.
Rockville, Maryland
August 11, 1990
should have been calculated by using Darcy's Law. The relevant
relation Is q 0 b=TI, where T Is transmlsslvlty (available from the
pump test) and I Is the hydraulic gradient <available from a
plezometrlc surface map of the area downgradient of the Acid
Pits, and not one off to the side as used In Figure 2.3). Using
T=IO ft 2 /d and I=0.067 ft/ft <I determined •r• by plotting
hydraulic head data from nearby wells sampled on 8/26/86 and Acid
Pit borings sampled on 10/21/86 and then drawing head contours>,
the "theoretical" stagnation point offset x =64 ft. and capture
zone width 2Y,=400 feet. These "theoretical" values are 3.2 times
larger than those miscalculated In the PFDA. (Warning to
reviewers: do not set design well spacing based on my
calculations. As Technical Advisor to CWCE I will not and cannot
assume liability for third party uses of my analyses>.
Furthermore, It Is Important to recognize that well spacing
should be reduced to accommodate Interference between wells and
heterogeneity In hydraulic conductivity. Most Importantly, a
network of new plezometers Is required to observe the performance
of the system. See related comments.
AG. The PFDA's "flow net· method, which offers a second estimate
of capture zone width, yields a smaller width (80 feet> than the
theoretical estimate (originally 125 ft, corrected to 400 ft).
More than anything else, this discrepancy reflects the nearly
total absence of monitoring wells necessary to apply a flow net
approach. One could have obtained almost any value for the
capture zone width using flow net analysis on the available data.
The •estimated capture zone· line on Figure 2.3 and associated
capture zone width (80 feet> are quite arbitrary and
undefenslble. In essence, there Is only one well cluster which
contributes a single drawdown value to Figure 2.31 The shape of
the "end of test• contours clearly cannot be defined by one
point. This shape In turn determines the shape of the estimated
captured zone, which Is simply a line begun at the stagnation
point and then drawn perpendicular to the "end of test· contours.
(Figure 2.3 Is also In error In not passing Its capture zone
lines through the stagnation point).
A7. For design purposes the PFDA used a capture zone width of 80
feet for the Acid Pit area. Accepting this value Implies that, at
the most, lnterwell spacing should be 80 feet. Indeed, as
projected on a line across the valley, the extraction wells are
about 80 feet from each other. However, Interference between the
extraction wells will reduce the width of each capture zone. I.he..
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Chirlin & Associates, Inc.
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August JI, 1990
result will be a requirement for closer spacing of extraction
wells. During design. Interference effects should be assessed by
an experienced analyst using an appropriate multi-well model.
During operation, the extent of the capture zone should be
determined by an adequate plezometrlc monitoring network.
Ignoring Interference will create passageways between the wells
along which contaminants can proceed down-valley.
AS. A single pump test was used to design the spacing between
extraction wells. If one were to perform 1-day pump tests In
several wells throughout the Acid Plts/DA-9 area, natural
geologic heterogeneity would probably lead to over an order of
magnitude variation In estimated transmlsslvltles. This was the
case in the low volume pump tests of the RI (Table 3.2-6), which
found the hydraulic conductivity at BW-9 (0.1 ft/d) to be one
tenth that at BW-8 (1.0 ft/d). These wells are on the two
downgradlent corners of the Acid Pits. Transmlsslvlty Is an
Inverse factor In the calculation of the capture zone, so an
Increase by a factor of 10 causes a decrease In the predicted
capture zone, In the present case from 400 ft (based on BW-9) to
40 ft. Thus on the basis of heterogeneity alone. It Is
appropriate for the PFDA to use a design lnterwell spacing of
less than 100 ft (It uses 80 ft).
18
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•
•
.&EPA
liilildStatas
!9onmantal Protection
Agency
Ottlca of
Research and
Development
Office of Solid Wasta
aAmargancy
~nse
EP A/54014-89/005
October 1989
Ground Water Issue
Performance Evaluations of
Pump-and-Treat Remediations
Joseph F. Keely
•,
Superfund Technology Support Centers for Ground Water
Robert S. Kerr Environmental
Research Laboratory
Ada, OK
Monllorlng for Remediation Performance
Evaluations
Ground-water data are conected durtng remediations to evaluate
progress towards goals specified In a ROD. The key controls
on the quality of these data are the monitoring criteria that are
selected and the locations IJt'Whfch those crlterta are to be
appfled. Ideally, the crttarla and the locations would be
selected on the basis of a detailed site characterization, from
which transport pathways prtor to remedlatlon could be ldentlfled,
and from which the probable pathways durtng remediation
could be predicted.
The monitoring crtterta and focatlons should also be chosen In
such a way as to provide Information on what Is happening
both downgradfent of the plume boundary and Inside the
plume. Monitoring within the plume makes It possible to
determine which parts of the·plume are being effectfvafy
remedlated and how quickly. This facllltates man.agement of
• the remediation wellfleld for greatest efficiency; for example,
by reducing the flowrates of extraction wells that pump from
relallvely clean zones and Increasing the flowrates of extraction
wells that pump from zones that are highly contaminated. By
contrast, the exclusive use of monitoring points downgradlent
of the plume boundary does not allow one to gain any
understanding about the behavior of the plume during
remediation, except to Indicate out-of-control condlllons when ·
contaminants are detected.
There are many kinds of monitoring criteria and locations In
use today. The .former are divided Into three categories:
chemical, hydrodynamic, and administrative control. Chemical
criteria are based on standards reflecting the benellclal uses
ol groundwater (e.g., MCL's or other health-based standards
for potential drinking water). Hydrodynamic monhorlng crtterla
are such things as:
(1) prevention of Infiltration through the .
unsaturated zone,
(2) maintenance of an Inward hydraullc gradient
at the boundary of a plume of ground-
water contamination, and
(3) providing minimum flows In a stream.
Administrative controls may bo codllled governmental rules
and regulations, but also Include:
(1) eflectlve Implementation of drilling bans
and other access-llmltlng administrative
orders,
(2) proof of maintenance of site socurlly, and
(3) reporting requirements, such as frequency
and character of operational and post-
operational monitoring.
Combinations of chemical, hydrodynamic, and administrative
control criteria are gene rally necessary for speclllc monitoring
points, depending on location relative to the source of
contamination.
Natural Water Quality Monitoring Points
Natural water quality (or "background'') sampling locations
are the most widely used monitoring points, and are usually
. po_sltloned a short distance downgradlent of the plume. The
exact location Is chosen so that:
(1) It Is neither In the plume nor In adjacent
areas that may be affected by the
remediation,
(2) It Is In an uncontaminated portion of the
aquifer through which the plume would
migrate H the remediation falled, and
(3) Its location minimizes the posslblllty of
detecting other potential sources of
contamination (e.g., relevant to the target
site only),
Data gathered at a natural water quality monitoring point
Indicate out-of-control conditions when a po it Ion of the plume
escapes the remedial action. The criteria typlcally specified
for this kind of monitoring point are known natural water
quality concentrations, usually established with water quality
9_a_ta_fr~~-~Us located upgradlent of the source. ---
-~•---------'-
Pub/le-Supply Monitoring Points
Publlcwater supply wells located downgradlent of a plume are
another kind of monitoring point. The locations of these points
are not negotlable; !hey have been dr!lled In locations that are
suitable for water supply purposes, and ware never Intended
to serve as plume monitoring wells. The purpose of sampling
these wells Is to assure the quality of water delivered to
consumers, as related to specific contaminants associated
with the target site. The criteria typically specllled for this kind
of monhorlng point are MCL's or other health-based standards.
Gradient Control Monitoring Points
A third kind of off-plume monhorlng point frequently established
Is one fordetermlnatlons of hydraulic gradients. This kind may
be comprised of a cluster of small diameter wells that have
very short screened Intervals, and Is usually located Just
outside the pertmater of the plume. Water level measurements
are obtained from wells that have comparable screened
Intervals and are then used to prepare detailed contour maps
from which the directions and magnitudes of local horizontal
hydraulic gradients can be determined. n Is equally Important
to evaluate vertical gradients, by comparison of waler level
measurements from shallow and deeper screened Intervals,
because a remediation welttleld may control only the uppermost
portions of a contaminant plume If remediation wells are too
shallow or have Insufficient flow rates.
[Internal] Plume Monitoring Points
Less often utilized Is the kind of monitoring point represented
by monitoring walls located within the perimeter of the plume.
Most of these are Installed during Iha site Investigation phase,
prior to the remediation, but others may be added subsequent
to lmplemanlallon of Iha remediation; they are used to monitor
the progress of Iha remediation within Iha plume. These can
be subdivided Into on-site plume monitoring points located
within the property boundary of the facility that contains tho
source of the contaminant plume, and off-site plume monitoring
points located beyond the facility boundary, but within the
boundary of the contamination plume.
Interdependencies of Monllorlng Point Crllerla
Each kind o/ monitoring point has a speclnc and distinct role to
.play In evaluating the progress of a remediation. The Information
gathered Is not llmhed to chemical Identities and concentrations,
but Includes other observable or measurable Items that relate
:. to specific remedial activities and their attributes. In choosing
~ · .. specific locations of monitoring points, and criteria appropriate
to those locations, It Is essential to recognize the Interdependency
of the criteria for dllferent locations. ·
In addition to the foregoing, one must decide the following:
Should evaluallons ol monitoring data Incorporate allowances
for statlstlcal variations In the reported values? If so, then
what cut-on (e.g., the average value plus two standard devlaUons)
should be used? Should evaluations consider each monitoring
point Independently or use an average? Anally, what method
should be used to Indicate that the maximum clean-up has
been achieved? The zero-slope method, for example, holds
that one must demonstrate that contaminant levels have
stabng~ at their lowest values prior to cessation of remediation
-and that they will remain at that level subsequently, as
shown by a fiat (zero-slope) plot of contaminant concentrations
versus time.
, {loNW•':,'IJ,-..
-.l' ---'I, • .":' .
ii--ll!li.1/'i.-li) KAWECKJ ASSOCIATES
-z_ ,,1,1 ~ ~ Ii: I }'
• I I! : I I I •
"'tsEAJlt,: Gary Chi rl in
Chirlin & Associates
18 Anamosa Court
Rockville, HD 20855
•
August 9, 1990
SUBJECT: Comments and Recommendations--on Background Material
Related to the Chemtronics Superfund Site in Swannanoa,
North Carolina.
Uear Dr. Chirlin:
The environmental consulting firm of KAWECKI ASSOCIATES
1s pleased to submit this evaluation and recommendation on
n1aterials related to the Chemtronics site in North Carolina.
This cover letter summarizes key findings of our review.
Contaminant Identification:
The extent and degree of on-site contamination has not been fully
assessed. For example, in the entire Gregg Valley area, a known
depository for BZ/CS, only four sampling points were tested, one
of which was a bedrock well 800 feet downstream in essentially
impermeable rock. Also, the selection of indicator chemicals was
based on an insufficient chemical characterization of this site.
Tl,e standard procedure of doing multiple HLS scans during the
RI/FS and subsequent steps was not followed, as was as the need
to reevaluate indicator chemicals during analysis of remedial
alternatives.
We recommend that additional groundwater sampling be conducted at
various locations on site for the full HSL chemical scan
I including BZ, CS, TNT, and RDX), In addition, ambient air
sampling of particulate matter and gases along with chemical
characterization of the particles for known site chemical
constituents should also be conducted.
Routes of Exposure:
The principal groundwater plumes are characterized by their high
VOC content; yet voes were not characterized for off-site wells.
The air pathway has received even less attention. In addition to
transport of volatiles to downwind receptors, the deposition and
inhalation of primary chemicals (and metabolites) released from a
fire, explosion, or during ground-surface disturbance has not
been assessed. Transport and deposition on food crops,
2121 Wisconsin Avenue, NW • Suite 220 • Washington, DC 20007 • [phone]
• •
including grazing lands, and biomagnification through the food
chain in aquatic organisms has not been tested.
We recommend sampling and complete HSL chemical analysis of off-
site wells. For the air pathways, source emission factors should
be developed for air quality modeling to assess risks via
inhalation and to estimate particle deposition on crops off site.
Also, terrestrial wildlife (e.g., squirrels and rabbits, whose
diets may contain heavy metals from vegetative bioaccumulationl
and aquatic organisms (fish and frogs! should be tested for the
preser1ce of key contaminants, i.e. heavy metals and organics.
Toxicological Data:
Revised Health Advisories (HAI levels for TNT and RDX are an
order-of-magnitude less than the levels used in the Rl/FS and ROD
reports.
We recommer1d that these revised lower levels be incorporated into
the anaJ~·sis.
Long-Term Monitoring:
Aquatic toxicity testing 1s not an appropriate monitoring
procedure to estimate low:level chemical conceritrations or to
reflect performance of remediation activities. As proposed, the
use of this procedure to replace chemical testing will provide
virtually no useful information regarding the effectiveness of
site treatment or contaminant containment activities.
We recommend that actual chemical analyses for a possibly revised
list of indicator chemicals at various ''downstream'' locations be
conducted as part of the long-term monitoring plan.
And last, based on an incomplete site characterization, the
analytical data generated thus far may not reflect the severity
of the contamination at this site. Another series of chemical
sampling and analysis activities, which should include a complete
range of chemicals, will help the PRPs evaluate the performance
of the proposed remedial activities and will provide the public
with an increased level of confidence regarding the health risks
associated with this site.
Sincerely, 1
;KAWECKI ASSOCIATES
I
James M. Kawecki, PhD
Principal
• •
1.0 INTRODUCTION
This review focuses on four general areas relating to the
assessment of health risks associated with the Chemtronics site:
o Contaminant Identification and
Selection of Indicator Chemicals;
------
0 Routes of Exposure,
o Evaluation of Toxicological Data, and
o Long-Term ~onitoring Off Site.
2.0 CONTAMINANT IDENTIFICATION
The extent and degree of on-site contamination has not been
fully assessed. There is a pattern of ''selective sampl{ng'' in
the RI such that certain contaminants are avoided in areas where
they are most likely to be detected. Considerable bias has been
introduced into the data as a result; .we believe that it has also
led to faulty conclusions on the part of EPA. For example, the
past history of the site indicates that disposal areas in the
Gregg Valley have received large volumes of ''decontaminated" BZ
and CS. The FS estimates up to 2200 55-gallon drums and several
thousand smaller volume drums of BZ/CS were placed in the near-
surface en,·ironment. Clearly the BZ/CS degradation products are
contaminants of concern in that area. Yet only a single shallow
well (SW-8) in the entire Gregg Valley was tested for BZ/CS. The
monitoring network in that area consists of 7 shallow wells in
the surficial aquifer, 6 deep wells in the bedrock aquifer, 2
intermediate wells, and 5 designated "existing w~lls'' of unknown
screened interval (see April 1988 ROD Tables 9-12 and RI Appendix
• •
F-1 l. One intermediate well (X-2) and two bedrock wells IBW-11,
BW-14 I were also tested , for ·sz;cs. The RI's (and thus EPA's) '
conclusions as to the extent and degree of BZ/CS contamination of
groundwater 1n the Gregg Valley is thus based on 4 sampling
points, one of which (BW-141 is located 800 feet downgradient in
-------essentially impermeable rock (see G; Chirlin comments).
Another example of
sampling of private wells.
''selective sampling'' is the off-site
Ten residential wells were sampled
during the RI; however, the PRPs refused to analyze for volatile
organics (even though the principal groundwater plumes from site
activities are characterized by their high VOC content). Only
contaminaJl___t.,s that could be unequivocally attributed to site
activities: BZ, CS, RDX, TNT, and picric acid were analyzed.
None of these contaminants was detected. The ATSDR Health
Assessment (March 1988) noted this problem, stating that
"Analyses for trichlorethylene, 1,2-dichloroethane, and other
volatile organics which are the site related contaminants of
concern should have been included in the analysis program.'' They
recommended follow-up sampling of area residential wells for
VOC's as a precautionary measure. As of this date, the
recommended sampling has not been carried out.
We recommend on site and off site sampling for the complete
HSL chemicals.
Both the RI and the FS stress that volatiles are the most
widespread contaminants around DA-23. Volatile organics are
found above drinking water standard levels in both surface water
• •
and groundwater. Concentrations of 1,2-dichloroethane in
groundwater downgradient of DA-23 range from 0.15 to 7.4 mg/1.
Both the surficial and the deep (bedrock) aquifer have been
affected. The highest concentration for 1,2-dichloroethane in a
bedrock well
------
is 0.53 mg/1 at BW-4. The highest surface water
concentration is given as 11 mg/1 (the MCL is 0.005 mg/1). We
believe that the volatile organics are the contaminants of
concern at DA-23. They are mobile, present in high
concentrations in a variety of media, and have been detected
close to potential human exposure (downgradient in both surface
streams and groundwater). The BZ degradation products are less
mobile in the subsurface environment (Kd values greater than 10).
Only a few groundwater samples in the immediate vicinity of DA-23
showed elevated levels. In Appendix B of the FS, modeling of
contaminant mobility and groundwater transport indicated that
benzylic acid/ benzophenone should show considerable retardation
as it migrates through the subsurface (retardation factors close
to 50). The model predicted that it would take over 100 vears
for the BZ products to migrate 600 feet downgradient of DA-23; by
contrast, the volatile organic trichloroethylene was predicted to
take only 9 years. We agree with the March 1988 ATSDR Health
Assessment that with respect to public health implications, "The
wastes of primary concern are the VOC's."
2.1 Indicator Chemicals
According to U. s . EPA (1988), "indicator chemicals are
chosen to represent the most toxic, persistent, and/or mobile
• •
substances among those identified that are likely to contribute
significantly to the overa~l risk posed by a site ... Although the
use of indicator chemicals serves to focus and streamline the
assessment on those chemicals that are likely to be of greatest
concern, final check(s) will need to~e made during remedy
selection and the remedial action phase to ensure that waste
management strategy being implemented addresses risks posed by
the range of contaminants found at the site."
It is standard procedure to do a full HSL (Hazardous
Substance List) scan at several points in the RI/FS and decision-
making stages. The initial HSL helps the RI investigators
deter111-i,ne their indicator chemicals. As the RI proceeds, new
wells are sunk, unexpected areas of contamination are discovered,
and additional scans might be run to ensure the indicator
chemicals are still appropriate and that no new substances have
been found. During the FS, another HSL might be indicated if,
for example, soil incineration was a viable alternative and there
had been no full scan of the soils in a particular disposal area.
The Superfund Public Health Evaluation Manual (Oct. 1986) also
discusses the need to reevaluate indicator chemicals during the
detailed analysis of alternatives: "Chemical classes that were
not important in the baseline evaluation may become important.
In addition, some remedial alternatives will control or release
different chemicals than others,"
Since it does not appear that anything further than an
initial HSL scan has been done at this site, we recommend that a
complete chemical analvsis be conducted at various locations and
• •
that the current list of indicator chemicals be reevaluated and
revised accordinglv.
3.0 ROUTES OF EXPOSURE
The EPA guidance document for RI/FS activities notes that
once the sources and release mechanisms have been identified, an
analysis of the environmental fate and transport ~f the
contaminants is conducted. "This analysis considers the
potential environmental transport ( eg. groundwater migration,
airborne transport); transformation leg, biodegradation,
hydrolysis, and photolysis); and transfer mechanisms leg.
sorption, volatilization) to provide information on the potential
magnitude and extent of environmental contamination. Next, the
actual or potential exposure points for receptors are identified.
The focus of this should be on those locations where actual
contact with the contaminants of concern will occur or is likely
to occur. Last, potential exposure routes that describe the
potential uptake mechanism (eg, ingestion, inhalation, etc.) once
a receptor comes into contact with contaminants in a specific
environmental medium are identified and described." WHile these
topics were mentioned in the available materials, they were not
adequately addressed, i.e., standard tools such as ambient air
models, biological sampling, and complete off-site well
contaminant characterizations were not analytically explored.
3.1 Inhalation
The air pathway seems to have gotten very little attention
• •
during the RI and all subsequent phases. Since one proposed
remedy will involve groundwater pumping and treatment which will
transfer volatile contaminants to air, it is important to have a
picture of the baseline health risk from that pathway. As far as
we can determ-i-n.e, the only "air monitoring" that occurred on-site
was part of the health & safety protocol during test pit
excavation. The "action level" for field personnel was set at 5
ppm as measured with an HNu detector. This level represents an
indicator of total volatile organics, and is useful for screening
or health & safety purposes only. That action level was exceeded
during several test pit excavations.
According to the Endangerment Assessment ( Feb. 1988 l,
''Volatilization and subsequent release into the atmosphere
appears to be an important fate for the chlorinated hydrocarbons
found at the site. When released to the atmosphere, 1,2-
dichloroethane and chloroform will degrade by reaction with
hydroxyl radicals with half-lives from one to several months," It
is utterly amazing that no risk assessment has been made of this
exposure pathway to the human population downwind of the site.
No air ARARs were identified in the ROD, although both benzene
and beryllium are found in elevated levels in environmental media
on-site. These are classified by EPA as hazardous air pollutants
under section 112 of the Clean Air Act and thus subject to the
national emission standards of 40 CFR Part 61, Appendix A
contains several methodologies which can be used to estimating
dose and risks form inhalation routes,
In addition, the possibility of a fire on site during periods
• •
of drought or from accidental ignition of flammable or
''explosive'' materials may cause _significant acute exposures to
individuals on or near the property, or residents downwind of the
property, depending on meteorological conditions.
A multimedia compartment model developed to screen potential
risks from exposure to TNT, RDX, and benzene associated with a
disposal site was reported by McKone and Layton (1986). The
purpose of the model was to provide a relative ranking of various
toxic chemicals based on multimedia exposure parameters. The
authors concluded that based on ''a comparison of predicted dose
rates with 'virtually safe dose rates,' TNT had the highest risk --ranking. followed by benzene and RDX." This type of information
points up the need to reevaluate the potential risks on public
health based on exposure routes other than ingestion.
3.2 Ingestion
The water table at DA-23 is much closer to the surface than
at other disposal areas and thus, as noted in the FS, ''a smaller
buffer zone is created.'' Contaminants have already entered the
groundwater and are migrating away from the disposal area, both
horizontally (discharging to a surface water stream and within a
surficial aquifer plume) and vertically (along a bedrock fracture
to the deep aquifer).
will not stop it.
Capping may slow the migration, but it
We recommend sampling and complete HSL chemical analysis of
off-site wells. For the air pathways, source emission factors
• •
should be developed for air quality modeling to assess risks via
inhalation and to estimate particle deposition on crops off site.
Also, terrestrial wildlife (e.g., squirrels and rabbits, whose
diets may contain heavv metals from vegetative bioaccumulationl
and aquatic organisms (fish and frogs) should be tested for the
presence of key contaminants, i.e. heavv metals and organics.
4.0 EVALUATION OF TOXICOLOGICAL DATA
4,1 TNT
The lifetime Health Advisory of 2 ug/1 should be used in the
assessment of risks and remediation objectives on which the ROD --in the Chemtronics site is based. This section summarizes a
recent report by Ross and Hartley (1990) comparing water quality
criteria and health advisories for 2,4,6-trinitrotoluene.
As background material, the U. s. Environmental Protection
Agency (1989) defines a chemical health advisory (HA) as the
concentration in drinking water at which adverse health effects
would not be anticipated; it includes a margin of safety so as to
protect the most sensitive members of the population at risk. As
data permit, HAs are determined for short term, longer-term, and
lifetime exposures for noncarciriogenic endpoints of toxicity,
according to the following formula:
HA (mg/1) = (NOAEL or
( UF) X
where
LOAEL) X (BW)
(liters/day)
NAOEL or LOAEL =no-or lowest-observed-adverse-effect level (in
mg/kg body wt/day)
BW = assumed body weight of a child (10kg) or an
• •
adult (70 kg)
UF = uncertainty factor in accordance with National
Academy of Sciences/USEPA Office of Drinking
Water Guidelines.
liters/day= assumed daily water consumption of child (1
liter/day) or an adult (2 liters/day)
For TNT, ''suitable data were not available for calculating 1-day
------or 10-day health advisories. Longer-term Health Advisories (7-
year) utilized a 26-week study in dogs by Levine et al (1983) in
which a LOAEL of 0.5 mg/kg/day was determined. The effects at
this level were trace to mild liver lesions, described as
hepatocytomegalia and hepatocytic cloudy swelling. The
uncertainty factor for this study should be 1000, for a study of
appropriate duration in animals, and when applied, the UF yields
a value equivalent to the drinking water equivalent level IDWEL)
of 20 ug/liter. Therefore, the U. S. EPA suggests using the DWEL
as a conservative estimate for the longer-term HA for both the
10-kg child and 70-kg adult.
''In deriving a lifetime HA, three steps.are required:
1. determine the reference dose (RfD),
2. calculate the DWEL by multiplying the RfD by the
assumed body weight of an adult (70kg) and dividing by
the daily assumed water consumption (2 liters) of an
adult,
3. determine the lifetime HA from the DWEL.
The (DWEL) is multiplied by a relative source contribution (RSC)
factor which is assumed to be 20% in the absence of actual
exposure data. The RSC accounts for the percentage of total
exposure to a chemical from drinking water. Additionally, for
chemicals designated as U. S. EPA Group C (possible human
carcinogens) such as TNT, U. S. EPA policy requires that an
• •
additional uncertainty factor be used to 'account for equivocal
evidence of carcinogenicity.
For TNT, "the lifetime HA equals 0.00175 mg/1; this is
rounded to 2 ug/1."
4.2 RDX
The lifetime HA for RDX of 2 ug/1 should be used in
assessments related to the ROD at the Chemtronics site. ln
deriving the ambient RDX water quality criteria (WQC) for the
protection of human health, a concentration of 105 ug/liter has
been proposed for drinking water alone (Etnier, 1989). However,
the U. S. EPA Office of Drinking Water (ODW) concurrently
reported a lifetime drinking water health advisory (HA) of 2
ug/liter (U. S. EPA).
As shown in its previous HA calculation, Etnier and Hartley
(1990) derived the following HA for RDX:
1. Determination of reference dose
where
RfD = 0.3 mg/kg/day= 0.003 mg/kg/day
100
0.3 mg/kg/day= NOAEL, based on increased incidence of
suppurative inflammation in the
prostate of males receiving 1.5
mg/kg/day
(Levine et al, 1983)
100 = uncertainty factor chosen in accordance
with U. S. EPA guidelines using a NOAEL
from chronic study (lOX for
interspecies variation and lOX
intraspecies variation).
2. Determination of drinking water equivalent level
• •
where
DWEL = (0.003 mg/kg/davl(70 kg) = 0.105 mg/liter
(2 liters/day)
0.003 mg/kg/day= RfD
70 kg= assumed body weight of an adult
2 liters/day= assumed adult daily water consumption
3. Determination of the Lifetime Advisory
where
Lifetime HA= (0.105 mg/literl(0.2) = 0.002
10
= 0.002 mg/day
0.105 mg/liter= DWEL
0.2 = relative source contribution
assumption of 20%
10 = ODW policy, to account for equivocal
evidence of carcinogenicity for USEPA
Group C (Possible Human Carcinogen)
chemicals.
It.can be seen that the WQC of 105 ug/liter is the same as
the DWEL calculated by u. s. EPA (step 2' above), Based on the
Group C classification and consistent with ODW policy, the
additional uncertainty factor of 10 is applied to the DWEL to
derive the lifetime HA and. results in a value of an order of
magnitude lower than that derived using the WQC approach.
''The RSC concept approach assumes that an individual will
receive exposure to a chemical via many pathways, including food,
drinking water, and inhalation, To account for other sources of
exposure, U. S. EPA estimates that only 20% of total exposure
comes from drinking water; thus, an RSC of 0.2 is applied to the
DWEL. U. S. EPA makes it clear in their HA document (USEPA,
19881 that if the site exposure information indicates that there
• •
are no other sources of exposure, an RSC of 100% may be
appropriate. This may be the case for RDX contamination at U. S.
Army facilities that are generally restricted areas, precluding
public exposure to any other media than contaminated groundwater.
-----In such instances, an HA of 10 ug/liter would be appropriate.
"In summary, the application of a factor to account for
exposure via several pathways results in a lifetime drinking
water HA that is 50 times lower than a WQC calculated from the
same data. If one assumes that exposure to RDX is via the
drinking water pathway,
factor of 10."
the HA will differ from the WQC by a
We recommend that these revised lower levels be incorporated
into the ROD analvses.
5.0 LONG-TERM MONITORING
A "bioassay'' monitoring plan described as ''seven day renewal
chronic toxicity test'' is proposed for testing the surface water
at various sampling locations. Ultimately, the purpose of
toxicological testing is to characterize the potential adverse
effects of a chemical on humans through the use of laboratory
animals or in vitro systems. The ultimate objective is to
identify those substances that might injure humans who might come
into contact with them. The most fundamental concept in
toxicology is that a relation exists between the dose of an agent
and the response that is produced in a mammalian system· (Rand and
Petrocelli, 1985). With this thought in mind, the proposed
• •
approach of relying solely on aquatic toxicology'as a substitute
I
I
for extensive analytical testing of toxic chemicals, rather than
as an supplement to testing, is inadequate.
Aquatic toxicity tests are used to evaluate the
------con cent rations of the chemical and the duration of exposure
required to produce the criterion effect in aquatic organisms.
The effects of a chemical may be of such minor significance that
the aquatic organism is able to carry on its functions in a
normal manner and that only under conditions of additional stress
(e.g., changes in pH,
chemically induced
dissolved oxygen,
effect be detected --
and temperature)
(Paustenbach,
can a
1989 I.
Additionally, some sublethal effects may have little or no effect
on the organism because they are rapidly reversible or diminish
or cease with time (e.g., growth may be reduced early in the
toxicity study, but may not be significantly different from that
in the controls by the end of the study). The only way to study
sublethal toxicity in aquatic organisms is by using long-term
exposures (Paustenbach 1989).
Aquatic toxicity testing is not an appropriate monitoring
procedure to estimate low-level chemical concentrations or to
reflect performance of remediation activities. As proposed, the
use of this procedure to replace chemical testing will provide
virtually no useful information regarding the effectiveness of
site treatment or contaminant containment activities.
We recommend that actual chemical analyses for a possibly
revised list of indicator chemicals at various ''downstream''
locations be conducted as part of the long-term monitoring plan.
• •
6.0 BIBLIOGRAPHY
Brett, S. M., J. S. Schlesinger, D. Turnbull and R. J. Machado
<1989). Assessment of the Public Health Risks Associated with the
Proposed Excavation of a Hazardous Waste Site. IN Paustenbach, op
cit.
Etnier, E. L. (1989). Water Quality Criteria for Hexahydro-1,3,5-
trlnltro-1,3,5-trlazlne <ROX). Regulatory Toxlcoloty and
Pharmacology 9:147-157.
Etnler, E. L. and Hartley (1990). Comparison of Water Quality
Criteria and Health Advisories for ROX. Regulatory Toxicology and
Pharmacology 11.
McKone, TE. and D. W. Layton (1986). Screening the Potential
Resks of Toxic Substances Unslng a Multimedia Compartment Model:
Estimation of Human Exposure. Regulatory Toxicology and
Pharmacology 6:359-380.
Paustenbach, D. J. (1989). The Risk Assessment of Envlronental
and Human Health Hazards: A Textbook of Case Studies, John Wiley
and Sons, New York.
Rand, G. M. and S. R. Petrocelli (1985). Fundamentals of Aquatic
Toxicology. Hemisphere Publ. Co., Washington, DC
Ross, and Hartley (1990). Comparison of Water Quality Criteria
and Health Advisories for 2,4,6-Trlnltrotoluene. Regulatory
Toxicology and Pharmacology 11.
USEPA (1988). Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA, Interim Final. EPA/540/G-
89/004.
USEPA (1988). Guidance on Remedial Actions for Contaminated
Ground Water at Superfund Sites. EPA/540/G-88/003.
USEPA (1986). Superfund Public Health Evaluation Manual CSPHEM>.
EPA/540/1-86/060. OSWER Directive 9285.4-1.
Assessment or .blic Health Risks Associated with tht ProA
Excnation or I Hazardous Wost< Site
Susan M. Brett. Joyce S. Schlesinger. Duncan Turnbull,
and Ranjil J. Machado in Paustenbach, 1989
APPENDIX A: METHODOLOGY FOR DOSE AND RISK
ESTIMATION
A.I Inhalation or Chemical Vapor and P1rticulates-Sakhrooic
A.1.1 Estimation of lif,iimt Artragt Daily Dou (LADD) atl Uppa-Bo,,11tl
Canctr Risk. For each chemical treated "' a potential carcinogen. the LADD is
-..........._ calculated based-.Q._n the estimated air concenlrations at each receptor site. together with --......_
the estimated human intake or air and duration of exposure. LADDs arc calculated
separately for the c:.,cava1ion of i:ach former lagoon for both chemical vapor and
chemicals on dust particles. These two estimates of LADD (cast lagoon vapor and dust.
west lagoon vapor and dust) arc then added to derive the total LADD. Each individual
LADD is calculated as
I co nee n t rat ion II volume inspired)( a bsorption JI con tact/)
LADD= (in air) (per hour) (from air) (lifetime)
!days per lifetimellbody weigh()
For an adult female,
LADD= I< mg/m')I0.875 m',hJ(l1(20 hiday x 60 days)
__ 1365 days/yr x 77 yr/life)(58 kg)
= (6.44 x 10-··11cJ1mg,ikg·dayJ
for any concentration c of chemical in the air. where c is in unitso(mg/m 3 air. Since upper-
bound risk is the product of LADD and UCR, for illustrative purposes the upper-bound
lifetime risk from exposure to any concentration (cl of tctrachlorocthylcnc is calculated as
follows:
upper-bound risk= (16.44, 10-•11cJmS,1\g·day]((0.0017)(mgikg·dayJ-1]
=11.IOx JO"')(cJ
for any concen1ration c or 1etrachloroethylcnc.
The predicted average air concentration of tctrachloroethylenc in the rorm ol vapor
and dust at the closest residence during 1hc excavation of the casl and west lagoons is
7.87 x 10·' mg/m'. Therefore, the upper-bound lifetime risk from this expo<ure for adult
women is
upper-bound risk= I I.IO x 10-6)(7.87 x IO-'J
=8.62 X 10-1•
For a preschool child, the calculation would be the same, except that the child's b<o.athing
rate (0.333 m' ;bland body weight (I 7 kg) would be used in the equation of LADD in place
of the adult female values.
A,J .2 £J1imati011 of htragt Daily Dou (ADD) atl ADD/ ADI Ratio. For
noncarcinogcns and noncarcinogenic effects of carcinogens. 1hc ADDtADI ralio ~ves an
• •
indication of whether individuals exposed to the ADD arc at risk. If the ratio is greater
than I, tben some risk is assumed to exist. The ADD differs from the LADD in tbat it is not
averaged over a lifetime; rather, it is the average daily dose on days of exposure. The ADD
is calculated as follows:
·--.___ ADD
(concentration)(volume inspired)(absorption) (hours)
(in air) (per hour) (from air) (per day)
(body weight]'-
For an adult female,
(c mg/m'II0.875 m' /hl(l )120 hi
ADD=----------158 kg)
=(3.02 x 10-•11,)mg/kg·day
for any concentration (c mg/m 3 ) of chemical in air.
For xylene. the average concentration at the closest residence during excavation of the
west lagoon is estimated to be 3.91 x 10-1 mg/m 3 as vapor and 6.81 x 10-• associated
with airborne dust, for a total of 3.92 x 10-• mg/m'. The subchronic ADI of xylene is
0.0103 mg/kg·day. The ADD/ADI ratio for this exposure is
ADD (3.02 x 10-1)13.92 x 10-c).mg'lcg·day
ADI 10.0103) mg/kg·day
= 11.48.
A.2 Ingestion of Contaminated Dust-Subchronic (Preschool Child)
We have used the value of 1 g/day to represent the amount of dust a child with pica would
ingest. Not all the soil a child living in the area of the site would ingest would consist or dust
deposited from the excavation site. In the absence or knowledge or what proportion that
might be, we have selected l(f,,~ as a reasonable estimate.
A.2.1 F.srimarion of LADD and Upptr-Bound Canctr Risk. The LADD from soil
ingestion for each chemical treated as a possible carcinogen is calculated based on the
concentration in the soil and the estimated human intake:
(concentration) (soil) (fraction oO (gastrointestinalM.contact/1
LADD=
(in soil) (ingcsted/day)(soil contaminated) (absorption) (lifetime)
(days/lifetimc)(body weight)
le mg/kg)( I x IO-' kg)(0. l )(I )(60 days/life)
(365 days/yr x 70yr/1ife)(l7kg)
= (1.38 < IO-1)(c) mg/kg·day
for any coocentratioo (c mg/kg soil) of chemical in soil.
Since upper-bound risk= LADD x UCR. the upper-bound· lifetime risk at any
• •
concentration of tctrachloroethylene. for example. is
upper-bound risk= [11.38 x w-0)(c)mg/kg·day)[(0.051)(mg/\g·day)-1)
= (7.05 X 10-IO)(C(
The a ... eragc concentration or tetrachlorocthylenc in the west lagoon is 160 mg/kg.
Therefore. the upper-bound lifetime risk to preschool childmi from s011 ingestion during
excavation of the west lagoon is
upper-bound risk=(7.05 X w-10)(160)
=l.13xl0-'.
A.2.2 Esrimation of ADD1Znd ADD/ADI Ratio. As noted above, the ADD is
similar to the LADD except that it applies only to the period of exposure and is not
averaged over a lifetime. For dust ingestion. the ADD is calculated as
(concentrationl(amount of soil) (fraction! (gastrointestinal)
(in soil) (ingested/day) (contaminated) (absorption)
LADD=-----~----'-----------'---(body weight)
For the preschool child modeled, --
(c mg;\g)I I x IO-' kg/day)(OI )I I)
ADD=----------(17kg)
= 5.88 x IO-'(c) mg/\g·day
for any concentration (c mg/kg) of chemical in soil.
For xylene. the average soil concentration in the west lagoon is estimated as
9379 mg;kg. and the subchronic ADI is 0.0103 mg/\g·day. The ADD/ADI ratio for this
exposure is
ADD (5.88 x I0-')(9379)mg/\g·day
--= ADI (0.0l03)mg/\g·day
= 5.36.
A.3 lnhabtion of Chemical Vapor and Particubles-Acult
The foregoing calculations considered the average exposure over the period of excavation.
However. because or the nonuniform distribution of chemicals in the soil to be excavated.
exposure will not be uniform from day to day during the exposure period. On days when
the most contaminated ponions of soil arc being excavated. the exposure would be higher
than the average calculated above. To determine whether those acute exposures arc likely
to present a risk of acute health effects. the maximum daily doses (MDDs) have been
calculated aod compared to acute ADls. The MDD is calculated similarly to the ADD
except that the air concentration (c) used in the equation is the concentration resulting
from the highest measured soil concentration rather than the median soil concentration.
• .. . • •
For both carcinogens and noncarcinogcns !he MDD.1acu1c ADI ratio is calculated as
(con~ntration)(volume inspircd)(absorpt_ion)(hours exposed)
MDD (in air) (per hour) (from air) (per day!
(body weight)
For an adult remale.
Ir mgim' )(0.875 m' /h)( I )(20 hiday) MDD=-="-s--------~ 158 kg)
= (3.02 x 10-1 )(r) m&'J<g·day
for any conccntration /cmg.imJ) of a chemical in air. where c is the highest I-day
concen1ration predicted on days when the most contaminated areas of soil are excavated.
For xylene. the highest I-day concentration at the closest residence during the
excavation period is predicted to bc4.91 mg/mJ as vapor and 0.867 mglm 3 associated with
airborne dust. and the acute ADI is 32 mg/kg·day. The MDD/acute ADI ratio for this
exposure is
MDD (3.02 x 10-1)(5.78)m&'J<g·day --ADI (32) m&'J<g·day
= 0.05.
A.4 Ingestion of Contaminated Dust-Acute
Calculations similar to those for acute inhalation may be conducted for acute ingestion of
dust:
jconcentration)(amount of soil) (fraction) 1gastrointestinal1
MDD (in soil) (ingested/day) (contaminated! (absorption!
(body weight)
For the preschool child modeled.
Ir mg:lcgi( I x 10-' kg/day)(0. I Iii I MDD=----'------'------'----
17 kg
= (5.88 x 10-•)lc) m&'J<g·day
for any concentration (c mg/kg soil) of chemical in soil.
For xylene, the highest measured soil concentration in the area to be excavated is
147.000 m&'J<g. and the acute ADI is 32 m&'J<g·day. The MDDiacutc ADI ratio for this
exposure is
MDD (5.88 x 10-•)(147,000) mg/kg·day --= ADI (32) m&'J<g·day
.. , ..
August 7, 1990
Chirlin & Associates, Inc.
18 Anamosa Court
Rockville, MD 20855
RE: Closure Design Review
Chemtronics Superfund Site
ENSCI Job Number: AD90-003
Dear Gary:
As per .our discussions, a review was made of the closure prepared
by Sirrine Environmental Consultants (SEC) for the referenced
facility. The comments included herein are based solely on
information contained within the SEC drawings, design report, and
project drawings that were submitted for my review. No site
visit or additional design or laboratory testing were performed
during this review.
THE SEC design documents related to the closure cap profiles are
focused exclusively on surface sedimentation control factors. No
infiltration or stability calculations are included in the SEC
work and, therefore, the cap designs are incomplete. Significant
deficiencies are apparent in reviewing the current documents.
SLOPE STABILITY----Final cap contours shown on SEC drawings C-8
through C-10 indicate interior controls of all caps that greatly
exceed the 3 to 5 degree design objective. Maximum slopes
obtained by scaling contours are as follows: DA6-14 •, DA7 /8-1·1 •,
DA9-20°, DAl~ll-23°, DA23-12°, and Acid Pit-11°, As currently
specified, disposal areas DA6, DA9, DA23, and the acid pit have
covers that include geotextile to smooth HOPE interfaces. Such
interfaces, particularly under .the low normal loads associated
with caps, can have interface ,':friction angles less than 10
degrees. Therefore, portions of the caps will be marginally
stable under static loading and may fail under the dynamic load
associated with construction.
The remaining caps, DAl0/11 and DA7/8, are acknowledged to be
steep and incorporate a 60-mil textured HOPE membrane. While
this may increase the interface interaction coefficient, direct
shear tests must be performed on the membrane and select fill to
confirm it. The on-site soils are micaceous and may not produce
a stable slope under soaked conditions.
1108 Old Thomasville Rd.• High Point. NC 27260 ~ 919-883-7505 • Fax [phone]
AN ENVIRONMENTAL SERVICE COMPANY
ENGINEERING• ASSESSMENT• SITE REMEDIATION
• • •• •
Chirlin & Associates, Inc.
August 7, 1990
Page 2
•
If actual laboratory testing and design calculations are not
provided for the cap profiles, then the entire slopes must be
maintained at the minimal 3 to 5 degrees recommended by EPA
Minimum Technology Guidance (EPA/530-SW-89-047).
COMPOSITE BARRIER----The SEC concept incorporates a composite low
permeability barrier consisting of a HOPE membrane overlying 12-
inches or compacted "select''fill". In those caps not using the
textured HOPE, the composite action of the HOPE and the soil is
destroyed by the introduction of a 12-ounce non-woven geotextile
between the two components. While providing a "cushion", the
geotextile has a significant transmissivity and will allow
leakage through penetrations in the HOPE to readily flow to the
full face of the select soil barrier .. The geotextile cushion
should be eliminated in all caps by requiring the "select soil"
have a maximum particle size of 3/4-inch and have a final smooth
surface prepared by a steel drum roller. This is actually a
relaxation of the specs for all caps except that for the acid pit
(currently requiring 2-inch maximum). Actual EPA research data
is available to SEC to confirm the survivability of HOPE under
such installations.
The effectiveness of the composite barrier cannot be evaluated
since no data exists on the permeability of the "select soil".
Such laboratory data must be obtained and the infiltration
characteristics of the caps modeled before this closure plan is
approved.
DRAINAGE LAYER----A drainage layer is provided atop the low
permeable barrier. Such layers are intended to prevent the
buildup of a hydrostatic had against the HOPE membrane. The SEC
drawings do not indicate .how these drainage layers are th_emselves
drained: Cap section drawings shown. on drawing C-12 show the
geocomposite drawing terminating in an anchor trench at the
perimeter of the cap. No drainage details or sizing of drainage
pipes are provided. Such information must be provided before
this closure plan is approved.
BIOBARRIER----The gas vent detail for the gas collection system
to be placed over the acid pit shows HOPE geomembrane being
extrusion welded to PVC pipe. This cannot be done and the detail
must be revised to show a mechanical connection of the boot to
the pipe. Additionally, no protection is provided for the PVC
gas vent pipe. The detail shown on drawing C-12 does not result
in a stable, protected vent pipe. What keeps the bentonite
pellets out of the No. 57 gravel once they hydrate? Poor detail!
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August 7, 1990
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DIFFERENTIAL SETTLEMENTS----The SEC report downplays the
potential for differential settlements based on the observation
that no waste has been placed at the facility since 1979 and that
no significant settlements have been observed in recent years.
With drums of liquids existing within the waste, the potential
for significant localized differential settlements remains very
high. A detailed annual survey of the cap to establish elevation
topo's for each cap must be'part of the .permit document.
In summary the SEC proposal is currently an incomplete design
that must be finished before approval for closure could legally
be granted. There is no doubt in my mind that the current
proposed closure plan will lead to failure and the expense of
recapping this facility.
ENSCI appreciates this opportunity to work with Chirlin &
Associates and welcomes your comments on our findings.
Sincerely yours, !Ee,e~
Gr~ N. Richardson, Ph.D, P.E.
Director
ENSCI-Environmental Design Group
112 North Person street • Raleigh. North Carolina 27601 • 919 832-7491
✓138 East Chestnut street • Asheville. North Carolina 28801 • 704 251-0518
August 10, 1990
Lee Crosby
Chief, Superfund Section
Solid & Hazardous Waste Management
P.O. Box 27687"
Raleigh, NC 27611-7687
Re: 95% design, Chemtronics Superfund Site, Swannanoa
Dear Lee Crosby:
I am writing for the Clean Water Fund of N.C. and on behalf of
Citizens' Watch for a Clean Environment, the citizen's group
concerned with the Chemtronics NPL site in Swannanoa, N.C.
As you may know, Citizens' Watch has received a technical
assistance grant from Region IV EPA, and has hired a technical
consultant, a part of whose job tasks is a critique of the 95%
design documents on the Chemtronics site remediation plan.
I am enclosing that consultant's comments, which will be included
in Citizens' Watch comments, to be forwarded to Region IV EPA by
August 14. Chirlin & Assoc .. , the consulting firm, found some
serious deficiencies in the design as well as data on which the
design is based. More technical comments on the "capping" design
are expected from the consultant.
Today I spoke by phone with Bill Meyer, who suggested I forward
this document to you, so that these comments could be reviewed
before your comments on the 95% design are forwarded to Region
IV.
Would you be so kind as to send me a copy of the state's comments
on the 95% design? I appreciate your concern relating to this
site. Obviously, everyone's preference is to see design errors
corrected before construction begins.
Sincerely,
~~
• • Chirlin & Associates, Inc. 18 Anamosa Court • Rockville, MD 20855
Consulting
Engineering and Hydrogeology
[phone]
August 13, 1990. Mr; Robert B. Watson, President
Citizens' Watch for a Clean Environment
PO Box 956
Swannanoa, NC 28778
RE.: Preflnal Design Analysis, Chemtronlcs Site Remediation, Swannanoa, North Carolina, June 1990 C3 vols>, Preflnal Design Specifications, Chemtronlcs Site Remediation, Swannanoa, North Carolina, June 1990 (2 vols), and Preliminary Operation and Maintenance Plan, Chemtronlcs Site Remediation, Swannanoa, North Carolina, June, 1990 Cl vol>
Dear Mr. Watson:
Thank you for the opportunity to review the referenced documents. The attached comments were prepared by Dr. James Kaweckl, adjunct toxicologist at the Institute of Health Policy Analysis, Georgetown University Medical Center, Washington, DC (toxicology and risk assessment)J
Dr. Gregory Richardson, PE, Executive VP, ENSCI, High Point NC, an Instructor In the EPA course "Design and Construction of RCRA/CERCLA Final Covers· (cap deslgn/constructlon)J and Dr, Gary Chlrlln, PE, Pr~sldent, Chlrlln & Assoclat•s; Inc., consulting hydrologist (contaminant plume characterization,
ground-water extraction, and water quality monitoring).
These comments describe a number of serious conceptual and lmplemental shortcomings In the PRP's planned site remedy. Based on our training and experience, Including at numerous other Superfund sites, at the Chemtronlcs. ~lte
Cl> chemical sampling Is too sparse, Infrequent, and
unrepresentative to prope~ly assess ~lgratlon of contaminants in surface and ground-watersJ
C2) the proposed long-term monitoring Is Inadequate to characterize performance of the remedy or detect future Increases in risk, even by the most likely pathwaysJ and (3) the remedy Itself has potentially serious design ·def I c I enc I es.
We hope that EPA will require the PRPs to take corrective measures. Some suggestions are made In our comments. Furthermore, If substantial changes are made In the remedial plans, then we would be happy to conduct a timely review of the revised plans.
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Chlrlln & Associates, Inc.
Rockville, Maryland
•
August 13, 1990
COMMENTS ON PREFINAL DESIGN ANALYSIS,
DESIGN SPECIFICATIONS, AND PRELIMINARY O~M PLAN
CHEMTRONICS SITE REMEDIATION, SWANNAN □A; NC
JUNE, 1990
GENERAL
I. A survey of all exlstlng.;wells for ground-water elevation In
a non-drought, non-summer period ls needed, <I'd be surprised If
EPA has another CERCLA site In Final Design with only one
complete round of watir leve'l readings. Even RCRA facilities
measure quarterly!) This will permit verification of ground-water
flow direction under more normal conditions. It will also reveal
whether any known wastes are now below the water table. (The
findings of the RI are Inconclusive In this respect). Wastes
below the water table would not be contained by a cap.
2. I find It remarkable -and regrettable -that only a single
round of surface water quality sampling has been performed during
the entire course of the field Investigations at this CERCLA
site. Particularly in light of the unusual drought conditions
during the RI, and also for quality assurance purposes, one
should resample the surface water stations at the Chemtron!cs
Uk-This data would offer an applicable (non-drought) baseline
against which Improvements could be measured as source controls
are Implemented. Such a survey could be Implemented as a part of
a surface water monitoring program which would parallel the
ground-water sampling program of the PreFlna1 Design Analysis
CPFDA).
3. Bis (2-ethylhexyl) phthalate was detected In several wells In
both valleys, yet Is dismissed as a well Installation or · ·
laboratory contaminant. If the former, then time (since 1985) and
proper well purging procedures should eliminate the problem. If
the latter, then laboratory quality control must be examined,
because bis (2-ethylhexyl) phthalate Is not.a common laboratory
contaminant. Wells affected by bis (2-ethylhexyl) phthalate
should be resampled. If bis <2-ethylhexyl> phthalate persists In
the analyses, then measures should be taken to contain or extract
It.
4. I applaud the additional effort made by the PRP's contractor
which ultimately led to an Increase In coverage of several of the
disposal area caps. I do so In spite of the fact that n_g_
Information or data was provided In the reviewed documents
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Rockvllle, Maryland
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August 13, 1990
allowing one to Judge the appropriateness or adegu3cy of these
revisions. This Information should be made available for our rev I ew.
5; Nowhere in six years of documents (Work Plan/RI/FS/ROD/
Conceptual Deslgn/PFDA/PreFlnal Speclflcatlons/PO&H) has anyone
dared to sketch the extent of ground-water contamination by any
chemical. One might fairly ask after all these studies, "Where
are the contaminant plumes?" There Is no answer principally
because of the scanty distribution of monitoring wells at the
Chemtronlcs site. Several oi,,'.the following comments address this
matter. EPA may also wish to compare the Chemtronlcs monitoring
network to that of another Superfund Site with a similar
Industrial history: the Aerbjet General Corporation site near
Sacramento, CA.
FRONT <PICRATE> VALLEY
A. Monitoring to Assess Contaminant Dlstrlbutlon
6. Although DA-10/11 ls known to have received BZ and CS wastes,
and although CS wastes were found In test pit soil, nevertheless
well SW-2 was not sampled for CS and BZ contaminants! Given that
SW-2 ls the principal well being used to demonstrate lack of
migration from DA-10/11, this Is a serious oversight. Well SW-2
should be sampled for cs and BZ.
7. Area DA-10/11 was Included In the FS principally because It
ls felt to pose a threat of future releases to the ground water
(e.g., FS Table 3.1). Nevertheless, the proposed monitoring
program of the conceptual and preflnal design documents does not
specify any observations which could reveal onset of leakage from
DA-10/il. In addition to a program of surface water monitoring
related to this site (see related comments below), wells SW-2 and
BW-2 should be Included In the list of monitoring wells In ·
section 2.4.3 of the Preliminary Operation and Maintenance Plan
CPO&H>. Furthermore, one new monitoring well cluster should be
Installed ENE of DA-10/11 because this Is the direction of
ground-water flow In the bedrock <RI Table 3.2-3). I also suggest
tbat a second cluster be Installed further downgradlent. behind
Building 104 southwest of the drainage channel. Both new clusters
should be part of the PO&H ground-water sampling program. Since
these are detection -rather than quantification -measures,
composite samples or analyses could be performed to reduce costs.
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August 1.3, 1990
8. BZ was present In several wells CSW-4, BW-4, MS5L10)
downgradlent of DA-23. BZ concentration has been Increasing at
.all wells where repeated observations were made Cat SW-4, BZ
concentration was 0.49 mg/1 In 6/86, 1.2 mg/1 In 10/87, and 3.4
mg/1 In 1/89). Nevertheless, the. stream sample CRW-7) near to DA-
23 was not analyzed for BZ or CS. In fact, only one surface water
sample In Unnamed Valley was analyzed for BZ and cs cRw-10, which
Is 400 feet upstream of well M85Ll1>.
Thus BZ Is In the groundwater which drains to Unnamed Branch.
The Impression that BZ (or CS) ls not migrating offslte ln
surface waters rests on anaijsls of a single sample taken at RW-
10 on June 12th, 1986. I suggest that Unnamed Branch be resampled
for BZ and cs at several points. Including at a minimum stations
RW-7 and RW-10, .
B. Monitoring for Remediation Performance Evaluation
I recommend review of the attached excerpt from the EPA
Ground Water Issue paper Performance Evaluations of Pump-and-
Treat Remediations by Joseph F. Keely, Superfund Technology
Support Centers for Ground Water, October 1989. It describes the
types and functions of ground-water monitoring during a remedial
period. I Introduce terminology from that paper In some of the
following comments.
9. There are Insufficient monitoring wells to observe the effect
of the proposed ground-water extraction system near DA 23. The
proposed wells Include only 3 clusters which will be useful for
definition of the zone of capture, namely S/BW-4, MB5L4/IO, and
S/BW-5. In order to assess whether the system Is Indeed creating
the desired capture zone, several <say. 4> additional plezometer
clusters will be required. and unlike the existing set they
should not be collnear. In Keely's terms these plezometers are
gradlent control polnts, and at least some should be located just
outside the plume. They are necessary to meet the third ·
("evaluate contaminant plume containment") and fourth ("determine
the need for extraction well network modifications") data quality
objectives described In PO&M Section 2.4.2. Without additional
plezometers In the area around the pumping wells, It ls futile to
attempt the "hydraulic performance assessment" of PO&M section
2.5.1.
10. The proposed ground-water sampling locations during
remediation are SW4 and BW4 only. In Keely's terms, they are
flnternall plume monltorlng points. The Conceptual Design
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Rockville, Maryland
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August 13, 1990
Analysis also Included H85L4 and H85LIO as [lnter~all plume
monitoring points; these were deleted In the Preflnal Design
.Analysis CPFDA) without explanation. Based on the RI data, SW4
and BW4 are Indeed highly contaminated wells. However, SW4 and
BW4 water quality should not be the sole determinant of whether
PA-23 has ceased to contaminate the ground water. For Instance,
In 1986 plcrlc acid was detected In. M85LIO and was not found In
SW4 or BW4: M85LIO clearly taps Into a different source area
within DA-23, and therefore It, too, should be routinely
monitored, The same can be said of M85L4 based on the singular
presence of Trans-1,2-dlchloi;-._bethene.
11. During remediation, effluent from STW-1 and BTW-1 will
provide an unparalleled opportunity to measure most of the
contamination leaching from DA-23 Into the ground waterl
therefore pumping well effluents should at a minimum be monitored
using the same schedule and parameters as SW4 and BW4, and clean
effluent should be one criterion for halting pumping. Be aware
that samples for volatile organics taken with a standard
submersible pump tend to be underestimated; however, positive
readings will still have considerable Information value. It Is
unclear from PO&H section 2.4.3 which parameters would be
measured In extraction well effluent, and at what detection
limits. The PO&H (pg. 29) refers to •selected operational
parameters• after the first year. This terminology Is vague
enough to suggest to a skeptic that the analysis may be of no use
In assessing progress of the remediation. The PO&H should clearly
state the water quality monitoring requirements for pumping well
effluent. I would strongly urge that effluent from the two
pumping wells be analyzed annually for the ·contaminants of
Concern· of PO&M Table 2.4.1. It should also be recognized that clean effluent will not
demonstrate complete recovery of ground-water contaminants,
because of both the dilution effect of captured streamflow from
Unnamed Branch and the effects of any f ug It Ive NAPL or un·ca~ped
wastes <which causes concentrations to rise upon cessation of
pumping !Mackay and Cherry 1989, ES&T 23(6):6301).
12. The planned ·evaluation of contaminant distribution· CPO&H
section 2.5.2) requires:
a) "Isopleth maps for each contaminant of concern". However,
It Is patently Impossible to develop meaningful Isopleth maps
using a slngl~ monitoring location CS/BW-4). Furthermore,
without a natural water quality monitoring point <Keely,
1989) just downgradlent of the existing plume, one cannot
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August 13, 1990
Intelligently draw the critical "zero" contour on such a map.
Finally, under the proposed plan after the first year only
Indicator parameters will be analyzed: this suggests that
most contaminants of concern will not be measured and
therefore will not be mapped (see next comment);
b) "concentration versus time curves for each contaminant at
each monitoring point·. However, after the first year only
Indicator parameters will be analyzed Cpg. 29) and therefore
the concentration of most contaminants of concern may not be
determined -or graphed -even though they were detected
during the. first year. ,·/
These PO&H monitoring plans are vague (what Is an Indicator
parameter anyway? TOX?J and may be nearly useless. I urge that
additional monitoring ~ells &e established <see related comment>
and that all monitoring wells be analyzed annually for the
"Contaminants of Concern· of PO&M Table 2,4,1. If a contaminant
does not occur for several years, then It may be deleted.
However, detected contaminants should be Individually quantified.
The final samples before closure of the remedial system should
once again Include the entire TCL/TAL scans and Leyel 5 analysis.
13. Because the water quality of base.flow In Unnamed Branch
directly reflects ground-water quality, and because Unnamed
Branch collects most ground-water flow from beneath Disposal
Areas 10111 and 23, the routine monitoring program should Include
chemical analyses of surface water samples from upstream and
downstream of these Disposal Areas. Care should be taken to
sample during periods of baseflow. Such surface water samples
Integrate ground-water flow from an entire sub-basin and thus can
detect contamination regardless of the circuitous route
contaminants may follow through the ground. Samples from
monitoring wells characterize only a single "streamtube" and are
.easily bypassed by contamination, especially If the wells are
close to the source as Is the case at this site.
For Instance, It would be Informative to sample Unnamed
Branch baseflow just upstream and just downstream of the
discharge zone of DA-23. The stream Is presently a drain for
contamination emanating from DA-23; and will continue to receive
DA~23 wastes If the source control Is Inadequate. To demonstrate
that the cap and extraction system are effe6t!ve source controls,
one should require that stream samples show no Incremental
contamination from DA-23. (Also see J. Kaweckl comments on the
limited value of proposed bloassay monitoring).
14. During preparation of the Workplan (COM 1985) a small stream
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August 13, 1990
Issued from the DA 10/11 valley. In the drought of -1986 there was
an "Inadequate source of water to sample" In this channel CJ. F.
Schultheis letter to Jon Bornholm dated 10/21/86). A recent
(7/22/90) site visit Indicated that at least In the mid-summer,
flow ls still negligible. However, the PO&M sets out a thirty-
year monitoring plan. There will be periods like 1985 once again,
with baseflow In the Intermittent streams. The chemical quality
of this stream segment could reveal any leakage of contaminants
from DA 10111. When present, the baseflow of this DA 10111 stream
should be analyzed as part of routine monitoring for the complete
set of contaminants ~f conce~h <PO&H Table 2.4,1>, This
measurement will be an Important contribution to the presently
sketchy assessment of leakage from DA 10/11. In addition, I
suggest that wells SW2 and MW2 be pumped for some time to gather
In any nearby contamination. ana then resampled.
At DA-10/11 the deepest soil samples submitted for analysis
were 20-22 feet below land surface, and one of these [DA 10/11-21
contained 1,2-dlchloroethane. Contamination may be deeper. The
water table In DA 10/11 was as little as 32 feet below land
surface during the 1986 drought and maj presently be higher. If
waste sits In the saturated zone, a cap will not control leachate
formation and migration. I also note that boring DA!0/11-5 was
high In total cyanide yet lies outside of the new cap boundary.
15. Modifications In cap coverage (the PFDA made several) occur
because .the locatlon,and extent of Chemtronlcs disposal areas are
not fully known. This uncertainty ls the principal argument for
regular, comprehensive chemical monitoring of Unnamed Branch,
which collects ground waters from all portions of Front Valley.
Data reported In the RI Indicate that several reaches of the
stream are receiving chemical contaminants, Including In
Intervals where no disposal area has been Identified, e.g.:
ROX at RW-3 upstream of all known disposal areas; note that
the ROD Incorrectly labels RDK as Chloroform at RW-3:
an Increase In TCE between RW-12 and RW-10 downstream of all
known dlsposal areasJ and
unexplained and uncontrolled contamination at wells SW5, BW5
and spring #I across Unnamed Branch from DA-23, well SW6
upgradlent from DA-23, and well M85LII near building 140.
It ls clear from this and other evidence that there are sources
of ground-water contamination In Front Valley In addition to the
two Disposal Areas Identified In the Work Plan and RI.
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16. In light of the uncertainty of the location of dumping
grounds, It would be appropriate to Install and routinely samole
a line of monitoring wells across the moyth of Front Valley.
Several (say, 4 to 6) additional wells would be advisable,
situated more or less northeast and south of well M85LII. These
we.lls would serve to demonstrate lack of offslte migration of
ground-water contamination now and during the course of
remediation and post-remediation monitoring.
17. The bloassay monltorlnqi~lan In both valleys ts not a
substitute for surface water and ground-water chemical monitoring
programs. As proposed, the bloassay program runs Independently as
an Interesting, resea~ch-llKe data acquisition program. We do not
advocate deleting the bloassays, but favor Incorporating
potential findings Into the decision-making process. At present,
a "kill" does nothing more than simply extend the bloassay
monitoring Itself. Also see comments by J. Kaweckl.
C. Ground-water Extraction. System Design
18. It would be practical to use the natural Front Valley drain -
the Unnamed Branch -as a component of the ground-water
extraction system. One could continuously treat the flow of
Unnamed Branch In order to remove dissolved and suspended
contamination. This would alleviate th~ bleed of contaminants to
Beetree Creek. CA single round of surface water samples In 1986
Is Inadequate to evaluate long-term contaminant loading to the
creek. See earlier comment). Even near DA-23, the extraction
wells may not capture all contamination leaching to the creek.
For example, the concentration of 1,2-dlchloroethane was higher
In the adjacent stream sample CRW-7> than In either proposed
extraction well.
A stream diversion/Intake for treatment would best be located
as far downstream as possible, on or near to the property ·11ne;
This would capture and treat contaminants such as ROX and Plcrlc
Acid, 1,2 Dlchloroethane, Trlchloroethene, and Chloroform, all of
which were detected In downstream water samples RW-12 and/or RW-
10. The average flow of Unnamed Branch I~ about 107 gpm CR! pg.
3-24), which Is a workable flow rate for continuous treatment.
Stormflows could be buffered In a holding pond.
19. The proposed extraction wells STW-1 and DTW-1 will capture
ground water flow In a zone substantially narrower than (perhaps
one half as wide as) that predicted In the conceptual and
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Chlrlln & Associates, Inc.
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preflnal design documents. This Is true because the analysis
Incorrectly assumes that drawdowns from tests of the two pumping
wells may be added together. In fact, there can be considerable
Interference between the two wells, and both wells pumping
together may create a zone of capture which differs little from
that of either one alone. The only way to determine the true zone
of capture Is to begin pumping both wells and to monitor drawdown
In several new plezometers distributed throughout the desired
capture zone (see comment I). A two~well test shoyld be done
prior to finalizing the number and location of extraction wells
needed to capture ground-water flow from beneath DA-23.
20. Based on a detailed review of analogous calculations for the
Back Valley (see comments In Appendix A), It ls likely that the
pump test analyses and capture zone calculations for the Front
Valley were performed incorrectly. All related calculations
should be examined and appropriate changes made In extraction
system design.
D. Water Treatment
21. There Is apparently widespread chromium contamination In
Front Valley. Contamination outside of the DA-23 area will not be
addressed, even though the cleanup criterion In the ROD requires
remediation to a level of 0.05 mg/1. For Instance, well IW-1
contained 0.44 mg/1 of chromium In 1986, and Unnamed Creek
conveyed 0.10 mg/1 at station RW-12. How will chromium
contam\nat!on be contained throughout the valley?
. 22. What were the liquids which entered the ground water when the
original blolagoon at DA-23 failed In 1979? What compounds did
they contain? What volume of liquid.escaped? Where ls It n~w? CA
PRP consultant, Environ, Inc., asked similar questions In a March
31, 198 letter to EPA, attached to the ROD). This unresolved
matter should be addressed prior t~·ftnallzlng number and.
location of extraction wells, and treatment processes.
BACK <GREGG> VALLEY
A. Monitoring to Assess Contaminant Distribution
24. The downstream extent of the contaminant plume emanating from
the Acid Pit and DA-9 Is not known. There are no wells In the
approximately 800 ft by 500 ft area which may contain the front
of the plu-me. It remains credible that the plume has reached
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Beetree Creek. The single downgradlent monitoring well CBW-11> Is
approximately 1000 feet from the Acid Pits and was sampled only
once. The analytical results for the sample from BW-11 are of
virtually no diagnostic value because:
a) BW-11 Is cased (not open> to the upper 75 feet of
saturated thickness and therefore does not characterize the
shallower depth lntervaf ~~here most contamination Is found
throughout the sltel
..
b) well BW-11 ls In virtually Impermeable rock, and therefore
Is hydraulically Isolated from local ground-water flow. A
sample from BW-11 (If a valid one can be obtained) does not
characterize the quality of the migrating ground waters In
the area, not even over the well's deep uncased Interval. In
both packer tests reported In the RI (Appendix Mand Table
3.2-5) It was concluded that BW-11 has "essentially no
permeability In that no water was taken by the bedrock under
various pressures during packer tests· <RI pg 3-42>: and
c) the sampled water from BW-11 was probably not aquifer
water. Because of the nonconductlve materials tapped by BW-
11, the RI could not properly purge three borehole volumes
from the well prior to sampling on 6/2/86. In fact "static
water level and therefore purge volume could not be
determined due to very low permeability of aquifer In this
area· CRI Appendix H). Therefore the well was pumped dry and
the (partially recovered?) water column was sampled the next
day. This water was likely a mix of drilling water which had
been In the well since Its construction/development and a
small amount of packer test water, both well-aged.
In short, BW-11 ls definitely not a useful well to characterize
local aquifer water quality. As a sentry to detect contamlnant
migration from the Acid P!ts/DA-9, BW-11 ·has virtually no value,
And no other existing well fulfllls this role either.
Based on a pore water velocity of 148 ft/yr (Conceptual
Design Analysis Table 4.9 and RESSQ modeling) and assuming·
contamination began at the Burning Ground In 1952, mobile
contaminants will have migrated over 5600 feet from the Acid
Pits. Even assuming that contamination began In 1975 when
Chemtronlcs Inc. reportedly started to dispose of liquid acidic
wastes, mobile contaminants will have moved over 2200 feet
downgradlent.
The proposed extraction wells have a predicted downgradlent
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range <"stagnation point· distance) of 20 feet according to the
PFDA and 64 ft according to my calculations. In either case It Is
likely that the proposed extraction system will not recover most
of an existing body of contaminated ground water downgradlent of
the Acid Plti and DA-9, I would advise addlng monitoring wells to
define the extent of the Acid Plts/DA-9 plume, and as necessary
adding or shifting extraction wells to contain and recover the
entire plume.
25. DA-6 was included In the FS principally because it ls felt to
pose a threat of fut~re releases to the ground water (e.g., FS
Table 3.1). Nevertheless, the proposed monitoring program of the
PFDA does not specify any observations which could reveal onset
of leakage from DA 6. In addition to a program of surface water
monitoring related to this site <see related comments), wells SW-
12 and SW-13 should be added to the list of monitoring wells In
section 2,4,3 of the PO&M. Bedrock Is shallow here; bedrock wells
should be added adjacent to sw-12 and SW-13. Furthermore, one new
monitoring well should be Installed midway between these two
wells to fill a large gap In the monitoring network, Since these
are detection -rather than quantification -measures, composite
samples or analyses could be performed to reduce costs. li
necessary, add extraction wells to recover contamination found to
be emanating from PA-6.
26. An analogous comment applies to DA-7/8. There, however, the
list of potential leachate contaminants ls much longer <ROD,
Table No. 4) and there ls only one existing downgradlent
monitoring well, X-4s. Well X-4s Is 14 feet deep, of unknown
screen Interval <RI Appendix F-1), and was not reported as purged
during sampling (RI Appendix H) .. It ls Immediately adjacent to
Gregg Branch and appears to be upstream of much of the grbund-
water flow beneath DA-7/8. Therefore, the water sample from X-4s
ls not adequate to conclude that DA-7/8 does not leak. I would
Install and sample a long-screen ~onltorlng well or a well
cluster 50 to 75 feet southeast of the center of the southeast
side of DA-7/8. If the well<s> proved to be contaminated, then
ground-water extraction would be appropriate.
27. BZ (19 mg/1) was present In ground water recovered from the
eastern portion of the Acid Pits during the DTW-2 pump test <PFDA
Table 3.2). Ground water In this area dralns to the mlddle llmb
of Gregg Branch (northeast of DTW-2>. The nearest downstream
surface water sample (RW-21) was not analyzed for BZ (or CS). In
fact, onl£ one surface water sample In Gregg Valley was analyzed
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for BZ and CS (RW-24, which Is adjacent to well SW-9 on the south
limb of Gregg Branch).
Thus BZ Is In the groundwater which drains to the middle limb
of Gregg Branch. The Impression that BZ (or.CS) ls not migrating
offslte In surface waters rests on analysis of a single sample
taken at RW-30 In Beetree Creek beyond the confluence with Gregg
Branch. I suggest that Gregg ,Branch be resampled for BZ and cs at
several points, Including at''a minimum stations RW-21, BA-3 <see
PO&M Fig. 1.1.1). and RW-28.
B. Monitoring for Remediation Performance Evaluation
28. The remedial monitoring program will not provided sufficient
Information to assess the progress of the remediation,
In the terminology of Keely (1989),
a> the proposed monitoring plan for Back Valley completely
lacks natural water quality monitoring points, whose purpose
Is to "Indicate out-of-control conditions when a portion of
the plume escapes the remedial action·. Even the
"downgradlent• monitoring wells HWI and MW2 are within the
zone of capture and therefore not actually downgradlent of
the extraction system. (Stagnation point offset x. Is
estimated to equal 64 feet for a single pumping well and will
be even larger due to Interference between wells. See
Attachment A). Thus HW-1 and MW-2 will not satisfy _their
stated purpose "to evaluate water quality downgradlent of the
system• (PO&M pg. 90). Shift the MW-I and MW-2 clusters
further downgradlent. Furthermore, there should be at least
one <I would recommend two) additional monitoring well
cluster(s) located between MW-I and MW-2. (Examine PFDA
blueprint drawing G-9169-C-l3 for perspective).
b) the proposed monitoring plan has an Inadequate
distribution (number and location) of gradient control
monitoring points. These are used to determine the capture
zone established by the extraction system. (See next
comment).
29. The "flow net· approach of the PFDA, when based on adequate
field data, Is the best method of designing, assessing, and
optimizing an extraction system. A reasonable network of
plezometer clusters (say, 6 to 10 more) should be Installed In
the vicinity of the extraction wells In order to measure the
shape of the plezornetrlc surface during extraction operations. If
the shape Indicates that all flow converges to pumping wells,
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then the system Is satisfactory (and In fact certain pumps may be
seen to be unnecessary>. If not, then additional extraction wells
will be required.
30. Well BW-3 Is proposed for water level monitoring during
remediation of Back Valley CPFDA pg. 150). However, BW-3 Is not
In the Back Valley. It Is ~n'.the Front Valley.
•·.
31. I made earlier Front Valley comments concerning the PO&M
plans to monitor only "lndl~ator parameters" at monitoring wells
and ·selected operational parameters" at extraction wells, and
concerning the "evaluation of contaminant distribution and
extraction· (Sect. 2.5.2). These comments also apply to the Back
Valley. I urge that all extraction and monitoring wells b.JL
sampled annually for the Contaminants of Concern In PO&H Table
2,4,1. If a contaminant does not occur for several years, then It
may be deleted, but detected contaminants should be Individually
quantified. The final samples before clos~re of the remedial
system should once again Include the entire TCL/TAL scans and
Level 5 analysis.
32. Because the water quality of baseflow In Gregg Branch
directly reflects ground-water quality, and because It collects
most ground-water flow from beneath Disposal Areas 6, 7/8, 9, and
the Acid Pits, the routine monitoring program should Include
chemical analyses of surface water samples from upstream-and
downstream of these Disposal Areas. care should be taken to
sample during periods of baseflow. Such surface water samples
Integrate ground-water flow from an entire sub-basin and thus can
detect contamination regardless of the circuitous route
contaminants may follow through the ground. Samples from
monitoring wells characterize only a single "streamtube" and·may
be bypassed by contamination, especially If the wells are close
to the source as Is the case at this site.
For Instance, the RI found that volatile organics are
leaching from DA-7/8 and/or DA-9 Into Gregg Branch (sample RW-24
and RI pg. 3-149). The proposed extraction system will not
Intercept any ground-water flow traveling from DA-7/8. It ·ts also
very unlikely to Intercept flow between DA-9 and Gregg Branch
upstream of RW-24. In other words, the source of Gregg Branch
contamination upstream of RW-24 probably will not be contained by
the proposed remedy. Therefore I would suggest that as part of
routine monitoring during remediation, sample Gregg Branch
baseflow just upstream and just downstream of the discharge zone
of these·'two disposal areas, To demonstrate that the cap and
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extraction system are effective source controls, one should
require that stream samples show no Incremental contamination
from DA-7/8 and DA-9. (Also see J. Kaweckl comments on the
limited value of the proposed bloassay monitoring).
33. Proposed bloassay sampling point BA-2 CPO&M Fig. I.I.I) ls
located upstream of any surf.ace water discharge from DA-10/11. It
should be shifted downstreak''~o Include this basin! I suggest
placing BA-2 across from the BW-6/IW-t well cluster.
C. Ground-water Extraction System Design
34. The principal function of the DTW-2 pump test was to provide
a technical basis for designing the horizontal spacing and
vertical open Intervals (screen and/or open hole) of the proposed
extraction wells. Unfortunately, the PFDA makes several serious
technical errors In the analyses of the test at DTW-2, and In the
application of both methods of capture zone analysis ("flow-net
and "theoretical"). Errors range from choice and application of
pump test methods to neglect of well Interference to the use of
Incorrect values In formulas. Because of the dry and lengthy
nature of supporting explanations, they are relegated to
Attachment A.
The PFDA errors lead to an overestimate of the transmlsslyltv
from the DTW-2 pump test and an unfounded estimate of the width
of the capture zone. Given the PFDA's Incomplete understanding of
ground-water hydraulics, EPA should take particular care In
establishing a p!ezometrlc monitoring network for the extraction
area, It must be adequate to determine -using field data -the
horizontal and vertical extent of the capture zone, The PFDA-
proposed network needs revisions (see related comments),
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ATTACHMENT A. HYDRAULIC ANALYSIS OF THE
BACK VALLEY EXTRACTION SYSTEM
Al. Although the PFDA did not recognize lt, the pump test at DTW-
2 was strongly Influenced by water table <or vertical leakage>
effects. This Is clear from several pieces of evidence.
First, the water level I~ pumping well DTW-2 fell .below the
top of screen at approximately 70 minutes Into the te~t. In
fact, by 1300 minutes the entire upper screen was dewatered.
Thus, the test began with a partially penetrating pumping
well, but soon converted to water table conditions.
Second, water levels within observation wells X-3 and SW-II
were below top of screen throughout the test. Well X-3 has a
short saturated screened Interval (1.99 feet on 8/26/86) and
showed a 0.12 foot drawdown during the pump test. This
demonstrates that effects of the test reached the water
table. Well SW-!! has a longer saturated screened Interval
(32 feet), and probably acted as a short-circuit between the
mld~level saprollte and the water. table, thus reducing
drawdown.
Third, the strong vertical gradient In drawdown at the well
cluster SW-11/IW-2/BW-9 Is typical of dewaterlng (see
attached Fig. Al.
Fourth, 'the three clustered wr·' ls (BW-9, IW-2 and SW-I I)
yield estimates of transmlsalv•ty from the Theis "type curve
solution" (Revised Table 2.~) which Increase monotonically
from 7 ft2 /d (deep wel 1) to 34 ft2/d <middle well> to 55 .ft 2 /d
(shallow well). This trend Is just as would be expected when
the Theis model Is Inappropriately applied to a setting with
water table/vertical ~eakage effects. Normally, three
adjacent wells would le exoected to yield the same
transmlsslvlty estimate (!~deed, have essentially Identical
drawdown data) under the Theis assumption of full
penetration. That they do not Indicates that the Theis model
should not be applied to the data.
The high storage coefficient associated with the water table
acts to reduce drawdown ,:ompared to tests In a confined setting.
The PFDA assumes confined conditions. A lesser drawdown Implies a
greater transmlsslvlty Ctll else being equal). Therefore, tl.Y.
Ignoring -water table/ver1: !cal leakage effects, the PFDA analysis
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overestimates transm!sslvlty lo the y!cln!ty of the Acid Pits.
This error affects estimates based on •:very one of the
observation wells. during oumolng and during recovery, and for
all the PfQA methods of Interpretation. In particular,
transmlss!vlty estimates based on analwts of all wells other
than BW-9 are unfounded and should not be used,
. '
In passing, It follows i~~t the "apparent recharge effect"
discussed In the PFDA (Vol. 1,· p. 13) Is actually a water table
effect (or equivalently, a vertical leakage effect), and not due
to partial penetration. Interpretations based on partial
penetration (e.g., pg. 16) should be revised.
A2. The PFDA rightly cautions that early time pump test data Is
affected by pumping wellbore storage (pg. 11). The PFDA then
Ignores Its own warning and erroneously Interprets early time
data using the Theis Type Curve Solution (pg. 13-14; Revised
Table 2,2). During this early time period the pumping rate "felt"
by the aquifer ls Increasing from Oto the actual pumping rate of
1.4 gpm. An appropriate method to analyze such data ls given by
Papadopulos (1967) [Orawdown distribution around a large-diameter
well, IN Proc. Nat. Symp. on Ground-Water Hydrology, AWRA, San
Francisco, CA, Nov. 6-8, pp. 157-1681.
For well BW-9, the Papadopulos (1967) type curve yields a
transmlsslvlty estimate of 10 ft 2 /d with a storage coefficient of
10-•. The type curve matches the log-log data perfectly for time
up to approximately 220 minutes. (The PFDA Indicates
dissatisfaction with Its match; see pg. 13). Beyond 220 minutes,
the drawdown Is less than the Papadopulos type curve would
predict, as would be expected when water table/vertical leakage
effects begin.
A3. It Is Important to analyze the early data from monitoring
well BW-9 In the DTW-2 test because of the confounding Influence
of the water table <or vertical leakage) on later data. In Its
semi-log.analyses, the PFDA mistakenly uses later data without
recognizing that ~ate~·table/vertlcal leakage effects are ·
present, and therefore overestimates the transmlsslvlty of BW-9
<Revised Table 2,2).
From the Papadopulos (1967) analysis, the break In semi-log
slope In the B-9 well data at 220 minutes Is now seen to be due
to a factor other than wellbore storage, and most likely reflects
a water table effect. Data for time greater than 220 minutes
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therefore should not be used for the Jacob (semi-log) analysis.
The reported estimate of 22 ft2 /d Is therefore Incorrect. An
estimate of II ft 2 /d based on the first slope (80-220 minutes) Is
appropriate, and Is consistent with that developed from the
Papadopulos (1967) type curve match. The later slope break at 813
minutes Is emphatically not due to wellbore storage, as.
erroneously stated and calcuLated In the PFDA (Vol. I, pg 16 and
Vol. 3, Appendix G3: Caslng'~torage Effects).
A4. Because of the copnectlvlty and vertical flow between the
bedrock and the saprollte throughout the DTW-2 test, none of the
monltorlng data Is appropriate to estimate a separate "Saprollte
transm\sslv\ty·. Representations of this quantity ln the PFDA
(e.g., Revised Table 2.2) are unfounded. The value of 68 ft 2 /d In
Table 2.2 Is an artifact of an analysis which neglects water
table effects and Ignores the vertical flow from the saprollte to
the bedrock during the test. And from a practical point of view,
vertical hydraulic conductivity of the saprollte, and not
saprollte transmlsslvlty, Is of principal concern In a design
which seeks to drain contaminants downward to deeply-screened
extraction wells. Vertical hydraulic conductivity was not
estimated by .the PFDA.
Furthermore, drawdown data from the shallow and mid-level
wells SW-11 and IW-2 Imply that vertical flow persists at least
1300 minutes Into the pump test (Figure A). Therefore, It Is
Incorrect to Interpret drawdown data from these two wells as
measurements from a fully-or partially-penetrated confined
aquifer. Neither the Theis (type curve) or Jacob (seml-log)
methods should have been applied. I suspect that these wells
measure head within an aqultard of sorts -an Interval of.
moderately lower conductivity overlying a conductive bedrock-
saprollte contact.
In summary, all of the DTW-2 pump test analyses In the PFDA
are faulty, and the net result ls an overestimate of
transmlsslvlty from the avatlable data. This Is one of the errors
made by the PFDA when calculating the capture zone for an
extraction well. The next comment addresses this matter.
A5. The PFDA misuses the Bear (1979) formulas for stagnation
point and capture zone width. The analyst may not have understood
the deflnltlon of q 0 , the uniform discharge per unit area. The
value of g b was not (and rarely ls) measured directly, but
should hav~ been calculated by using Darcy's Law. The relevant
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therefore should not be used for the Jacob (semi-log) analysis.
The reported estimate of 22 ft 2 /d Is therefore lncnrrect. An
estimate of II ft 2 /d based on the first slope (80-220 minutes) Is
appropriate, and Is consistent with that developed from the
Papadopulos (1967) type curve match. The later slope break at 813
minutes Is emphatically not due to wellbore storage, as
erroneously stated and calcuLated In the PFDA (Vol. I, pg 16 and
Vol. 3, Appendix G3: Casing' Storage Effects).
A4. Because of the copnectlvlty and vertical-flow between the
bedrock and the saprollte throughout the DTW-2 test, none of the
monitoring data Is appropriate to estimate a separate "Saprol\te
transrnlsslv\ty". Representations of this quantity In the PFDA
(e.g., Revised Table 2.2) are unfounded. The value of 68 ft 2 /d In
Table 2.2 Is an artifact of an analysis which neglects water
table effects and Ignores the vertical flow from the saprollte to
the bedrock during the test. And from a practical point of view,
vertical hydraulic conductivity of the saprollte, and not
saprollte transmlsslvlty, Is of principal concern In a design
which seeks to drain contaminants do,onward to deeply-screened
extraction wells. Vertical hydraulic conductivity was not
estimated by the PFDA.
Furthermore, drawdown dgta f1·om ~e shallow and mid-level
wells SW-II and IW-2 Imply .hat ver-,al flow persists at least
1300 minutes Into the pump .test CF! ·e A). Therefore, It Is
Incorrect to Interpret drawdown ~at from these two wells as
measurements from a fully-or pactl0.l7-penetrated confined
aquifer. Neither the Theis (type curve) or Jacob (semi-log)
methods should have been applied. I s•1•~~ct that these wells
measure head within an aqultard of s~r~s -an Interval of.
moderately .lower conductivity overlying a conductive bedrock-
saprollte contact.
In_ summary, ~11 of the DTW-~ pump test analyses In the PFDA
are faulty, and the net result i3 an ovirestlmate of
transmlsslvlty from.the available data. This Is one of the errors
made by the PFDA when calculati,,g the capture zone for an
extraction well. The next·cc·· ~nt addresses this matter.
A5. The PFDA misuses the Bea~ (1979) formulas for stagnation
point and capture zone width. ~h~ analyst may not have understood
the definition of q 0 , the unlfora discharge per unit area. The
value of g b was not (and 1·arely ls) measured directly, but
should hi~; been calculated by using Darcy's Law. The relevant
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relation ls q0 b=TI, where T ls transmlsslvlty (available from the
pump test) and I .Is the hydraulic gradient (available from a
plezometrlc surface map of the area downgradlent of the Acid
Pits, and not one off to the side as used In Figure 2.3). Using
T=IO ft 2 /d and I=0.067 ft/ft CI determined "I" by plotting
hydraulic head data from nearby wells sampled on 8/26/86 and Acid
Pit borings sampled on 10/21/86 and then drawing head contours),
the "theoretical" stagnat106 ~olnt offset x =64 ft, and caotvre
zone width ZY,=100 feet. These "theoretical" values are 3.2 times
larger than those miscalculated In the PFDA. <Warning to
reviewers: do not set design well spacing based on my
calculations. As Technical Advisor to CWCE I will not and.cannot
assume liability for third party uses of my analyses>.
Furthermore, It Is Important to recognize that well spacing
should be reduced to accommodate Interference between wells and
heterogeneity In hydraulic conductivity. Host Importantly, a
network of new plezometers Is required to observe the performance
of the system. See related comments.
A6. The PFDA's "flow net• method, which offers a second estimate
of capture zone width, yields n smaller width (80 feet) than the
theoretical estimate (originally 125 ft, corrected to 400 ft).
Hore than anything else, this d!ncrepancy reflects the nearly•
total absence of monitoring wella necessary to apply a flow net
approach. One could have obtained almost any value for the
capture zone width using flow net analysis on the available data.
The "estimated capture zone" line on Figure 2.3 and associated
capture zone width (80 feet) are quite arbitrary and
·undefenslble. In essence, there Is only one well cluster which
contributes a single drawdown value to Figure 2.31 The shape of
the "end of test• contours clearly cannot be defined by one
point. This shape In turn determines the shape of the estimated
captured zone, which Is simply a line begun at the stagnation
point and then drawn perpendicular to the ·end of test" contours.
<Figure 2.3 Is also In erro1· In not passing Its capture zone
lines through the stagnation point).
A7. For design purposes the PFDA used a capture zone width of 80
feet for the Acid Pit area. Accepting this value lmpl les that, at
the most, lnterwell spacing should be 80 feet. Indeed, as
projected on a line across the valley, the extraction wells are
about 80 feet from each other. However, Interference between the
extraction wells will reduce the width of each capture zone. Ih!L
result wlfl be a requirement for closer spacing of extraction
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wells. During design, Interference effects should be assessed ~Y
an exoerJenced analyst using an appropriate multi-well model.
During operation, the extent of the capture zone should be
determined by an adequate plezometrlc monitoring network.
Ignoring Interference will create passageways between the wells
along which contaminants can proceed down-valley. In fact, the
extraction wells will accelerate this migration.
AB. A single pump test was used to design the spacing between
extraction wells. If one were to perform I-day pump tests In
several wells throughout the Acid Plts/DA-9 area, natural·
geologic heterogeneity would probably lead to over an order of
magnitude variation In estimated transmlsslvltles. This was the
case In the low volume pump tests of the RI (Table 3.2-6), which
found the hydraulic conductivity at BW-9 CO.I ft/d) to be one
tenth that at BW-8 CI.O ft/d). These wells are on the two
downgradlent corners of the Acid Pits. Transmlsslvlty Is an
Inverse factor In the calculation of the capture zone, so an
Increase by a factor of 10 causes a decrease In the predicted
capture zone, In the present case from 400 ft (based on BW-9) to
40 ft. Thus on the basis of heterogeneity alone. It Is
appropriate for the PFDA to use a design lnterwel) spacing of
less than 100 ft Cit uses ao ft).
18
RA.cl, a.i f"'"' a°',J.,Q,..., o .(J F "'1' <),__ YY'lo-n ,-b r , r.s we.V-o f" , n ~ '\J o,(s 4:
Bi "-1' T a.£rt lJ 9 DnD-2 ( Aid P, ·+ o.reo-) .
1<2-'I
c:l.,,_,,,J,,-, "l W ....tl n ..,_m l:xz.r (,;+) .
a.~ 1300 ,.;,~ ,mo-+ast"
I 11 ;. / 00 1
-
100"
S,u. ... u5: Pnt.Cd ~s,s: hi 2· s.,
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•
&EPA
October 1969 Envl-ntal Protoctlon Rosoarch and and Erf\orgoncy
-A-ge_n_,., ________ o_e_vo_i_op_m_e_n_t--R-es_p_o. __________ _
Ground Water Issue
Performance Evaluations of
Pump-and-Treat Remediations
Joseph F. Keely
Superlund Technology Support Centers for Ground Water
Robert S. Kerr Environmental
Research Laboratory
Ada, OK
Monitoring for Remedlollon Performonco
Evaluallons
Ground.waler data are conoctod durtng romoolallons lo evaluate
progress towards goals spocllled In a ROD. Tho key controls
on tho qualllyof lhoso data are tho monitoring crllorla that are
soloctod and tho locations -~t'.whlch those crllerta are lo bo
applied. Ideally, the crttdrla and the locations would bo
soloctod on the basis ol a delaTiod stte characterization, from
which transport pathways pr1or to romodlaUon could bo ldentlfled,
and from which the probable pathways during remediation
could bo prodlctod.
The monitoring crtterla and locations should also bo chosen In
such a way as to provide Information on what Is happening
both downgradlont of tho plumo boundary and Inside tho
plume. Monttorlng wllhln tho plume makes n possible to
dotormlno which parts of tho plume nro being o((octlvoly
remodlated and how quickly. This facilitates man_agement of
the remedlallon welllleld for groatosl elllclency; for example,
by reducing tho llowrates of oxlracllon wells that pump from
rolatlvoly cloan zonos and Increasing tho nowratos ol oxlractlon
wells that pump from zones that are highly contaminated. By
contrast, tho oxcluslvo uso of monitoring polnls downgradlont
of the plumo boundary doos not allow ono to gain any
understanding about the bohavlor of tho plumo durlng
romodlallon, except lo Indicate out-of-control conditions when -
contaminants Mil detected.
Thero are many kinds of monllortng crtterla and locations In
uso today. Toe .former are divided Into throe ca log cries:
chornlcal, hydrodynamic, and admlnlslratt,o control. Chomlcal
crllorla oro basod on &londards rolloctlng tho bonoflclaf usos
,of ground wator (e.g., MCL's or othorhoallh-basod standards
for polonllal drlnklng wale~. Hydrodynamic monhorlng crttorla
are such things as:
(1) provenllon ol lnflllratlon through tho
unsaturated zono,
(2) malntonanco of an Inward hydrauflc gradlont
at the boundary of a plume of ground-
wator conlamlnatlon, and
(3) providing minimum llows In a stream.
Admlnlstratlvo controls may bo codlllod governmonlal rulos
and rogulallons, but also lncludo:
(1) ollocllvo lmplomentallon of drllllng bans
and othor access-llmlllng admlnlslrallvo
ardors,
(2) proof of malntonanco of silo socurlly, and
(3) reporting roqulromonls, such as lroquoncy
and character ol oporallonal and post-
operatlonal monllorlng.
Combinations cl chomlcal, hydrodynamic, and admlnlslratlvo
control crllerla aro gone rally nocossaryl or speclllc monltorlng
points, dopondlng on locatlon rotative to tho source of
contamination.
Natural Water Quamy Mon/faring Points
Natural water quallly (or "background") sampling locations
are tho most widely used monitoring points, and aro usually
po_sltlonod a short distance downgradlonl of tho plumo. Tho
exact location Is chosen so that:
(1) It Is nollhor In the plumo nor In adjacent
areas Iha! may bo alloctod by :t:r,
romedlatlon,
(2) II Is In an uncontamlnaled porto,. of the
aqullor through which lho plumo would
mlgrato II lho romodlatlon lallod, ond
(3) Its location minimizes the posslblllty ol
dotocllng olhor potonllal sources cl
contamination (o.g., rolevanl to lho largo!
slle only),
Data gathorod at a natural walor quallly monllorlng point
lndlcato out-ol-control conditions whon a portion cl tho r,,lume
escapos the romodlal action. The criteria typically spoclllod
for this kind of monitoring po_lnt aro known natural wator
quallly concentrations, usually ostabllshod with watorquallly
dala froni_:,v_ells located upgradlenl of the source.
-Publlc-Suppfyl,n/forlng Points
Public wator supply walls localod downgradlonl ol o plumo oro
anolhorklnd cl monitoring point. Too locations ol thoso points
aro not nogotlablo; !hoy havo beon drlllod In locations that are
sultablo for wator supply purposos, and wore novor lnlondod
to sorvo as plume monltorlng-wolls. Too purposo of sampllng
thoso wolls Is lo assuro tho quallly of walor dollvorod to
consumors, as rolatod to sp_oclllc contaminants associated
wllh tho target site. Tho crllorla typically speclllod for this kind
of monhorlng point aro MCL's or other heallh-basod standards.
Gradient Control Mon/faring Points
A third kind of oll-plumo monnortng point lroquonlly ostabllshod
Is ono lordotormlnallons ol hydraullcgradlonls. This kind may
bo comprlsod of a clustor cl small diameter wolls that have
vory short scroonod lnlorvals, and Is usually localed just
outsldo tho portmelor of tho plurm. Water !oval moasuroments
aro oblalnad from wolls that have comparablo screonod
lnlorvals and aro thon usod lo proparo dolallod contour maps
!rem which tho dlroctlons and magnltudos cl local horizontal
hydraullc gradlonls can bo dotormlnod. It Is oqually Important
lo ovaluale vortlcal gradlonls, by compartson of wator !oval
moasuromonts from shallow and doopor scroonod lntorvals,
bocauso a rormdlallon wolnlold may conlrol only lho uppormcsl
portions of a contaminant plume II remodlatlon walls aro too
shallow or havo lnsulllclont flow ratos.
[Infernal] Plume Mon/faring Points
Loss ollon ullllzod Is tho kind cl monitoring point roprosontod
by monllorlng walls locatod wllhln Iha porlmotor of tho plume.
Most ol lhoso aro lnstallod during tho silo lnvosllgatlon phaso,
prior lo tho romodlatlon, but cl hors may bo addod subsoquont
to lmplomontallon ol lho romodlallon; !hey aro usodto monitor
tho progress of Iha remodlallon wllhln !ho plumo. Those can
bo subdlvldod Into on-silo plumo monltorlng points localod
within tho proporty boundary of tho faclllly that contains tho
sourco of tho contaminant plumo, and oll-sno plumo monnorlng
points locatod boyond tho faclllly boundary, but within tho
boundary of tho contamlnallon plume.
Interdependencies of Mon/faring Point Cr/for/a
_ Each kind o/ monltorlng point has a speclllc and dlstlncl role lo
,P.lay In ovatuatlng tho progross of a rormdlatlon. Too Information
galhorod Is not llmhod to chomlcal ldontltles and concantratlons,
but lncludos olhor obsorvablo or moasurablo !toms that rolato
•-: to spoclllc remodlal actlvlllos and lholr attributes. In choosing
'; spoclllc locallons cl monllorlng points, and crttorla approprlalo
lo lhoso locallons, n Is ossonllal lo rocognlze tho lntordopondoncy
of tho crltorta for dllforont locations.
In addition to tho lorogolng, ono must docldo tho following:
Should ovaluatlons cl monitoring data lncorporato allowances
for statlstlcal varlallons In tho roported valuos7 II so, than
what cut-oil (o.g., tho avorogo valuo plus two standard dovlallons)
should bo usod7 Should ovaluatlons consldor oach monllortng
point lndopondonlly oruso an average? Finally, what mothod
should bo usod lo Indicate that the maximum clean-up has
bean achlevod7 Tho zoro-slopa method, for example, holds
that one must domonstrale that contamlnanl lovols have
stabTilzod at their lowost valuos prlor lo cossallon of romodlallon
•· and that !hay will romaln at that !oval subsoquonlly, as
shown by a nat (zoro-slopo) plot of conlarrdnant conconlrallons
vorsus !Imo.
.. 4t
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
MEMORANDUM
DATE: JUN z. I~
REGION IV
J•s COURTLAND STREET
ATLANTA, GEORGIA 303d5 ·!KtCtl\lE[J
JUN 2 9 1990
SUPERFUND SECTION
SUBJECT: Review and Comment on the 95 Percent Prefinal
Remedial Design for the Chemtronics Superfund Site
A-al, IL &6/MJ c__...
FROM: Jhn K. Bornholm
Remedial Project Manager
TO: Addressees
Attached is a copy of the above referenced document. The Chemtronics site is
located in Swannanoa, North Carolina and the Record of Decision for the site
was signed on April 5, 1988.
Please review and comment on this document. In aider for the Potentially
Responsible Parties to meet their next deadline, submission of the Final
Design (100 percent design) by the end of August, it is imperative that you
submit your comments to me by Friday, July 20, 1990. If you are unable to
get your comments to me by this date, please call me and let me know when you
will be able to submit your comments.
If you have any questions, please contact me at 347-7791.
Addressees:
Charlotte Jesneck, NCDEHNR (2 copies)
Lee Crosby, NCDEHNR (w/o attachment)
John Dickinson, RCRA (1 Copy)
Bernie Hayes, G-WTU (2 copies)
Michael Carter, ESD (1 copy)
Jane Penny, Dynamac (l copy)
Bob Watson, Citizens' Watch (2 copies)
Winston Smith, APTMD (2 copies)
U.S.E.P.A.
Region IV
• NIMMO & CO.
Consultants
P.O. Box 536
Swannanoa, NC 28778
[phone]
•
Apr l I 1 2 , 1 990
JFS-047-90
345 Courtland Street, N.E.
Atlanta, Georgia 30365
ATTENTION: Jon K. Bornholm, Superfund Project Manager
REFERENCE: EPA Memo_randum from: John Dickinson, Chief
NC/SC Unit, Waste Engineering Section; To:
SUBJECT:
Dear Jon:
Jon Bornholm NC/SC Unit, North Management
Section; Subject: Review of Chemtronlcs
Site Remedial Design Concept
PRP response to referenced memorandum on
the submitted Chemtronics Site 30% Design
for Remediation
The referenced memorandum was received by the PRP
Coordinator via FAX on March 28, 1990. To date, this
information has not been officially transmitted to the
PRP' s. For this reason, l t was felt that the response to
these comments should be treated separately from those
received in EPA's letter dated March 23, 1990.
The responses to
numbered ln the
presented.
the referenced memorandum comments are
same sequence as the comments were
Response to John Dickinson's memorandum to Jon Bornholm
dated March 28, 1990:
Item 1:
Item 2:
on page 22 of the amended ROD, dated 26
April, 1989, the following statement ls
made: "The mu l t l -1 ayer cap ( Area DA-23)
will meet as a minimum, the requirements
specif led under 40 CFR Subsection 264,
Subparts K-N." No other reference to
portions of 40 CFR Subsection 264 ls made
ln the initial or amended ROD. The
Imposition of 40 CFR 264.110 through 115
could be considered an inappropriate change
ln scope and possibly an unauthorized
amendment to the ROD.
Since area DA-23 ls to be remedlated under
CERCLA as defined on page 23, from line 2
thru line 13 of the amended ROD, dated
26 Apri I 1989, this comment and condition
is inappropriate.
• •
Item 3: Same response as Item 2 preceding.
Item 4: Same response as Item 2 preceding.
Item 5 a) The PRP's and Project Engineer are aware
of the situation described and w i l l proceed
accordingly.
Item 5 bl Same response as Item 2 preceding. Once
again, It could be construed as a change in
scope or an unauthorized amendment to the
amended ROD.
Item 6: The statement: "It not only Involves the
stabilization of soils ... " Indicates that
the reviewer was unaware of the amended
ROD. The response for Item 2 preceding
would apply here.
Item 7: Same response as Item 2 preceding. In
addition, it should be pointed out that
long-term monitoring maintenance will be
covered in detail In the 95% Design
submission of O&M manuals. All of the
items covered In this general comment will
be covered at that time In accordance with
CERCLA regulations.
It ls hoped that the preceding responses to the RCRA Section
comments adequately define the PRP's position regarding
RCRA's evaluation of the 30% Design submission.
If you have any questions or comments, please contact me at
[phone].
Slncerely,,~;A-., ·
/ ) C ~, _,",/;f / /-----:-;:--:-r/~1f f. , (/ . 1.dl L#
~;_;~hn F. Schultheis
PRP Coordinator
cc: Steering Committee
C. Bromby
J. Wrathal l
T. Young
J. Impens
J-10101
~~1l(llll~~~~i~~~~
0
MAJOR WORK TASKS
I. Submit Proposed RD/RA Schedule
/Mav 5-l989l
II. Work Plan for RD/RA
Ill. WP Review and Approval
JV. uther Contract Uocumenl~
<Concurrent with Task Ill\
V. Treatability Testing•
Data Gatherino-Survev
VI. Develop Design Basis
VII. 30% Design
VIII. 30% Comment Period
IX. 95% Design
X. 95% Comment Period
XI. Finalize Design Packet
XII. Bid Process
XIII. Contractor Mobilization
XIV. Permitting
(Mav varv based on needs\
xv. Start Remedial Action
XVI. Final OM Manual -(Development)
Monthly Progress Reports
CHEMTRONICS RD/RA
Jan 1, 1990
60 120 180 240 300 360 420 480
'/////// , .JI ......
"///A
77 ..
' ' '
Key: Studies or Activities EPA Comment Period
tZZZA
DATE: · 4/9/90
PROJECT NO.: G-9169
PREPARED BY: JPI
Jan. 1, 1991
540 600 660 720 780-
•
' '
ii1Ii~11l~!~i;~~~ DATE: 4/11/90
CHEMTRONICS SITE REMEDIATION PROJECT NO.: G-9169
PREPARED BY: JPI
1990
FEBRUARY MARCH ,\PRII, MAY JUNE JULY AUGUST SEPTEMBER OCl'OBER NOVEMBER DECEMBER
30% DESIGN REVIEW PHASE
' Submission of 30% Design I 2/27/90
Regulalory Review I I I
PRP Response L...I..
Consensus -95% DESIGN PHASE
Permilting & lnsti1u1ional Re11'ments I
Soil Borrow Survey
I I I I
Acid Pit Arca-Gas Survev
I I I I I
lnfil. Gallery Soil Survey I I I I
Detailed Design I I I I I -Pre-final Design Analysis ~ 1..1.
Preliminary SS Plan I I I L..J..
Preliminary QA Project Plan I I I L..J..
Preliminary O&M Plan I I I I I I 1...1,,
Regulatory Review
I I ■
FINAL DESIGN PHASE
Final Design -Final SS Plan ~
Final QA Project Plan ~
OTHER ACTIVITIES
Bioassay
Perrnilting
I I I
Final O&M Plan
. 6/15/91
HJDDJNG PHASE I I I I I I .
CONSTRUCTION PHASE
Comractor Mobilization
I
Remedial Construction
I ~ 6/1/91
•
April 12, 1990
Mr. Jon K. Bornholm
Superfund Project Manager
U.S.E.P.A.
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
NIMMO & CO.
Consultants
P.O. Box 536
Swannanoa, NC 28778
[phone]
RE: U.S.E.P.A. Letter 4WD-SFB Dated March 23, 1990
Received by PRP Coordinator on March 30, 1990
Response to Comments on the 30% Design for the
Chemtronics Superfund Site -JFS-046-90
Dear Jon:
•
Attached are the PRP and Engineering Contractor's responses to the comments
presented in the referenced letter. Basically those responses that pertain to a change
or an addition to the text of the submitted document will be treated as an addendum
to the initial submission. Comments requiring only clarification or additional explanation
are presented in as concise and clear manner as possible.
The PRP Coordinator and the Project Engineer, Sirrine Environmental Consultants, are
available to meet with you and your associates if any additional information or
explanation is necessary.
In addition I have included two (2) schedules, the first being an update of the schedule
presented in the Work Plan which shows the major milestones and the second being
a more detailed schedule of the 95% Design Phase, Final Design through the beginning
of construction. Once all contracts are issued for the Construction Phase, a detailed
schedule of activities for that phase will be prepared and issued.
The PRP's are well aware of your statement in the closing paragraph of the referenced
letter that the 95% Design is due by May 28, 1990; however, it must be pointed out that
in our submission of the 30% Conceptual Design, the PRP's and the Engineering
Contractor were amenable to this date if certain conditions could be met. The major
• •
point being that EPA comments be received and responded to and consensus reached
by all parties by March 30, 1990. This, unfortunately, has not happened. The
Engineering Contractor started working on the DRAFT information provided by FAX and
then compared it to the official version received on March 30 to ensure all bases had
been covered properly with PRP review on April 9. The PRP's and Engineering
Contractor are assuming consensus will be reached no later than the close of business
on April 20, 1990. Thus, the 95% Design will be ready to submit on June 20, 1990.
As can be seen from the included detailed schedule titled, Chemtronics Site
Remediation, there are several sections of field work that need to be performed in order
to properly complete the 95% Design.
As stated in the transmittal letter for the 30% Design, it is felt that the next interval of
design is the most critical for the overall effectiveness of the selected remediations and
these require the appropriate time to accomplish the engineering tasks in the
professional manner expected by EPA, the PRP's, and the public whom this
remediation is designed to protect. It should be pointed out that in the original Work
Plan schedule, at the completion of the 30% Design review phase, the PRP's had
scheduled ninety (90) days to prepare the 95% Design for submission. We have
reduced that to sixty (60) days which we feel is the minimum acceptable period to
produce a quality design.
As previously presented, the PRP's and the Engineering Contractor set the close of
business of April 20 as the latest when consensus can be reached. In order to
maintain the proposed schedule based on that date, the PRP's must take the position
that if no response to the information contained in this communication is received by
the close of business on April 20, 1990, the included responses and schedules will be
assumed acceptable to EPA and the Engineering Contractor will be directed to proceed
forward on that basis.
If you have any questions or comments, please contact me at [phone].
Sincerely,
@;~~l 1 {4J~~
John F. Schultheis
PRP Coordinator
Attachments
cc: Steering Comm.
Decision Makers
• •
RESPONSE TO EPA REGION IV
AND STATE OF NORTH CAROLINA
COMMENTS ON:
CONCEPT DESIGN REVIEW
CHEMTRONICS SITE REMEDIATION
APRIL 11, 1990
SIRRINE ENVIRONMENTAL CONSULTANTS, INC.
GREENVILLE, SOUTH CAROLINA
• •
Page 1
Comments from USEPA CERCL.A
Item No. Response
1. The Remedial Investigation, Feasibility Study, and Record of Decision (and Amendments) are viewed as part of the integral process not as a part of the 30% Design Submittal.
The 30% Design Submittal is hereby modified as follows: Section 1.3, third
paragraph, Line 6, delete" ... remediated according to the Record of Decision through groundwater migration .... " and add " .... remediated according to the initial Record of Decision (ROD), dated 5 April 1988 and the Amended ROD, dated 26 April 1988, through groundwater migration .... "
2. Detailed schematic diagrams of the test wells are included in Appendix A.2 of the 30% Design Submittal.
The 30% Design Submittal is hereby modified as follows: Section 2.2.1, at end of paragraph add • Schematic diagrams of the test wells showing construction
details are contained in Appendix A.2."
3. A large scale map will be included in the Prefinal Design Submittal.
4. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Section 2.2.1, ninth paragraph, line 5, after "Some silt zones were present.' add ''The lower saprolite, at the target depth for DTW-2, at this site consisted of partially
weathered rock. Silt zones were also present, which necessitated the installation
of a well screen rather than using an open hole construction throughout.•
5. Noted and Incorporated.
The 30% Design Submittal is hereby modified as follows: Section 2.2.2, second
paragraph, at the end of the paragraph add "The tests were discontinued after
24 hours since further pumping would provide little additional meaningful data.
The data plots were asymptomic at the end of the tests."
6. The recovery data was used as a check on the drawdown calculations and are theoretically equal to the drawdowns measured (Driscoll, 1987). Minor pump fluctuations do not appear in recovery data often yielding a smoother fit. For a reference check Bruin, Jack and Hudson, HE, 1955, Selected Methods for Pumping Test Analysis by the Illinois State Water Survey (Report of Investigations 25). Residual drawdown plots are commonly used and are well
documented in the literature. Some residual drawdown plots will be included
in the 95 percent design package.
• •
Page 2
7. The capture zone widths reported In the 30% Design document were developed
by contouring actual measured water levels collected during the aquifer tests.
The theoretical capture zones created by the test well in the Acid Pit Area have
been calculated using the equation (Bear, 1979):
Where: Y1 = one half of the capture zone width, L
Q = well pumping rate, L3/T
q0 = Specific discharge rate, LIT
b = aquifer thickness, L
8. Further documentation for casing storage effects and the barometric efficiency
will be included, in an appendix of the Prefinal Design document.
9. The results were calculated using the following values for the parameters:
Bedrock Aquifer: Q = 270 ft3/d
q0 = 0.048 ft/d
b = 45 ft.
The results indicate that the theoretical capture zone is 125 ft. wide.
Saprolite Aquifer: Q = 270 ft3/d
q0 = 0.08 ft/d
b = 45 ft.
The results indicate that the theoretical capture zone is 75 ft. wide.
10. The fluctuations resulting from changes in atmospheric pressure during the test
were minimal. The water-level fluctuations caused by the earth tide effects were
the significant changes.
• •
Page 3
The 30% Design Submittal is hereby modified as follows: Section 2.3.3, seventh
line down after " ... atmospheric pressure." add "This is apparent from the
analysis of the static water level data collected prior to the tests. These water
levels show a cyclical fluctation of approximately 720 minute duration."
11. Agreed and incorporated.
The 30% Design Submittal is hereby modified as follows: Section 2.3.3, at the
end of the paragraph add ''The solution by the semi-log method was somewhat
ambiguous. In addition, many values were not in the range reported In the RI
or by calculated type curve methods. Since type curve solutions were in better
agreement with the RI and less ambiguous, it is believed that these values are
closer to the true aquifer coefficients."
12. See Response No. 11.
13. The theoretical capture zone generated by the combined pumping of both wells
was calculated using the equation described above. The values used in the
calculations were as follows:
Q = 1254 ft3/d
q0 = 0.12 ft/d
b = 114ft
The resulting theoretical capture zone is approximately 92 ft. wide.
14. Agreed and incorporated.
The 30% Design Submittal is hereby modified as follows: Section 2.4,
conclusion 1, to the end of the conclusion add: 'Within the transition zone the
rock has not completely weathered to soil, though some silt seams are present.
Therefore, both fractured and diffuse flow may occur in this zone depending
upon location, depth and lithology."
15. Spent activated carbon will be taken off-site to a RCRA permitted facility for
incineration. Procedures for handling spent carbon will be specified In the
Construction Operation and Maintenance Plan of the Prefinal Design Submittal.
• •
Page 4
16. The only site-specific indicator compounds above groundwater remediation levels
in the Back Valley are volatile organics. The volatile organics will be removed
through air stripping prior to biological treatment. As stated in Section 4.5.3, the
settled biological solids would not be hazardous and will be collected by a
septic tank service (or equivalent sewage handling service) for disposal.
Specific requirements will be provided in the Construction Operation and
Maintenance Plan of the Prefinal Design Submittal.
17. Groundwater concentrations for design of the Front Valley treatment system were
flow proportioned from the analyses of SlW-1 and DlW-1. Groundwater
concentrations for design of the Back Valley system are a linear average of the
most recent sampling of wells SW-8, SW-9, BW-8 and DlW-2. Estimated
groundwater influent concentrations are presented in Table 4.3.
18. Federal and State groundwater levels were presented for reference, as required
by the evaluation of potential ARARs described in the RD/RA Work Plan. All
potential cleanup levels ARARs are presented in Table 4.3. Groundwater
cleanup must conform to the remediation levels specified in the Amendment to
the Enforcement Record of Decision (April 26, 1989). Groundwater remediation
levels are specified in Table 3 of the amended ROD, which is attached here as
part of the addendum to the 30% Design Submittal.
ROX was below detection levels in the Front and Back Valleys during the most
recent sampling events.
19. The most recent data was used for each well because it would be the most
representative of groundwater concentrations at the time of remediation.
Sampling and analytical procedures for the referenced data comformed to EPA
Region IV SOP.
20. The most recent data was used for each valley because it would be the most
representative of groundwater conditions at the time of remediation. The
absence of chromium . concentrations above cleanup levels under current
conditions was verified through the sampling of the aquifer test wells.
21. Though the assumption that the drawdowns may be added is theoretically valid,
it is recognized that some deviations from this may occur locally due to
inhomogeneities in the hydrogeologic system. Performing an additional short
term aquifer test may not show whether this assumption is valid or yield
additional meaningful data. It may be more effective, therefore, to observe the
performance of the system after startup, over a longer period of time. An
additional extraction well can be added at a later date, if needed. The water
treatment system design will need to take this possibility into account.
• •
Page 5
22. The opinion of North Carolina's Groundwater Section towards an infiltration
gallery would be given in their review comments on the Concept Design Review
submittal. North Carolina allows the discharge of treated groundwater to
infiltration galleries. To allow the most flexibility regarding the discharge of
treated groundwater, the option of discharge to a surface water is being
evaluated concurrently.
23. Frost line is generally between 8 and 16 inches depending upon the reference
used. All piping will be placed adequately below frost line as identified in the
Prefinal Design phase.
The 30% design submittal is hereby modified as follows: Figure 4.2, change the
dimension "0.5 feet" to '> 0.5 feet''.
24. North Carolina groundwater standards were provided as reference in the
evaluation of potential ARARs, as directed in the RD/RA Work Pian.
Groundwater cleanup must conform to the remediation levels specified in Table
No. 3 of the amended ROD (attached}. The North Carolina Class GA standards
for volatile organics are less than the EPA Method 8010/8020 detection limits
specified in the RD/RA Work Plan. As stated in Section 4.2.3 of the submittal,
discharge to the infiltration gallery for these compounds will be below the
Method 8010/8020 detection levels. These discharge levels will be below the
remediation levels specified in the amended ROD.
25. Noted.
The 30% Design Submittal is hereby modified as follows: Section 4.3, delete
the first sentence and add 'As part of the remediation at the Chemtronics site,
groundwater interception and extraction system downgradient of the disposal
areas of concern in both the Front Valley and Gregg (Back Valley) are to be
installed."
26. The objective of the extraction system design is to capture the contaminant
plume while producing the least volume of water that requires treatment, thus
reducing the long term costs. Therefore, the proposed discharge rates are
based upon the minimum required to capture plume. However, It will also be
necessary to maintain water levels at particular depths, and the final flow rates,
upon installation, will be adjusted to provide the desired drawdown.
27. The four RCRA monitoring wells (BW-4, SW-4, M85L4 and MB5L10) along with
two additional wells (SW-5 and BW-5) will be used to monitor the groundwater
extraction system performance.
• •
Page 6
The 30% Design Submittal is hereby modified as follows: Section 4.3.1, last
paragraph delete the last sentence and add "The four RCRA monitoring wells
(BW-4, SW-4, M85L4 and M85L 10) along with two additional wells (SW-5 and
BW-5) will be used to monitor the groundwater extraction system performance.
These wells should be suffucient to evaluate whether the anticipated capture
zone has developed and whether remediation is occurring."
28. See Response No 21.
29. Several of the proposed monitoring well clusters are located downgradient of
the system. However the complete network will be further evaluated In the
Prefinal Design phase.
30. 1 & 2) Spent bag and cartridge filters are specified to remove any inorganic
(Fe, Mn, Ca, Mg) particulate matter that might foul or obstruct downstream
processes. The collected inorganic residuals will be non-hazardous and will be
sent to a sanitary landfill. 3) See Response No. 15. Specific requirements will
be provided in the Construction Operation and Maintenance Plan of the Prefinal
Design Submittal.
31. See Response No. 30.
32. The sentence incorrectly implied insufficient area.
The 30% Design Submittal is hereby modified as follows: Section 5.1.2, delete
the first four sentences of the first paragraph and add "Disposal Area 7/8
(DA 7/8) and the area to be covered, as proposed in the RI/FS, are shown in
Drawing D-4 (dashed line boundary). DA 7/8 is a trench/landfill lying in a partly
wooded area. Visual inspections and interviews with former employees Indicate
that the area to be capped is incorrectly shown as defined in the RI. Drawing
C-4 shows the revised boundary to be capped (solid line boundary)."
33. Air sampling from the gas vents will be performed prior to completion of the
Prefinal Design Submittal.
34. Agreed. Specific requirements will be presented in the Prefinal Design Submittal.
35. Disposal Area 23, Aquifer tests 1 and 2: The recharge/recovery pattern evident
in the drawdowns data from well BW-4, is the result of the earth tide, a cyclical
pattern lasting about 720 minutes. The earth tide effect was strongly displayed
• •
Page 7
. in the static water levels for this well measured prior to the test. Therefore, the
· pattern displayed during the pumping period is the static regional trend
superimposed on the drawdown curve.
36. Relevant calculations will be provided on the data plots within 10 days of this
submittal.
Comments from NCDEHNR CERCLA
Hem No. Response
37. The only wastes potentially generated during operation of the air strippers would
be the spent solution following acid rinsing of the columns to remove scale
formation. The spent acid solution would be non-hazardous following
neutralization, as discussed in Section 4.4.2, and could be sent to the sewer or
collected by a septic tank service. The volume of neutralized acid is anticipated
to be less than 100 gallons per application. Specific requirements will be
provided in the Construction Operation and Maintenance Pian of the Prefinal
Design Submittal.
Regarding spent carbon, see Response No. 15.
38. A biotic barrier is proposed only for root control. The biotic barrier is a
geotextile material impregnated with Trifluralin, an EPA registered biodegradable
herbicide.
The 30% Design Submittal is hereby modified as follows: Section 5.2.5, delete
the entire paragraph and add "Plant roots may disrupt the integrity of the
drainage layer by their intrusion. Root intrusion into the drainage layer may be
counteracted by utilizing a biotic barrier around the perimeter of each capped
disposal area. The barrier consists of an EPA registered biodegradable
herbicide impregnated to a geotextile fabric."
39. The effectiveness of groundwater remediation and the long-term quality of site
groundwater would be assessed using the monitoring well system described In
Section 6.2.
The irregular disposal of drums and unprotected exposure for over 20 years
suggest that few drums are intact. The contents of intact drums are likely to
contain rubbish, sludges and similar residuals that would not be expected to
exert a strong impact on groundwater upon deterioration of the drum. Any
• •
Page 8
remaining liquids should be limited to BZ and CS hydrolysis products and the
caustic methanol solution used to neutralize off-spec materials. No hydrolysis
products have been found in wells downgradient of drum disposal areas. ·
All drums were buried above the water table and infiltration Is the predominant
mechanism for chemical migration. After capping, infiltration to the buried drums
will, for all practical purposes, be eliminated. This reduces the potential for
continued groundwater contamination in two ways. The reduction In soil
moisture will reduce the rate of drum deterioration. Also, If a drum should leak,
escaping liquids should be attenuated by the underlying soils. Contaminants
will then not reach the water table without infiltration to flush them out.
Sirrine has conservatively estimated that groundwater remediation wlll take
approximately 30 years. Should a drum leak and its contents somehow enter
the groundwater, it most likely will be within the next 30 years. Any released
contaminants would be captured by the groundwater extraction system.
Editorial Comments
Item No. Response
40. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Page 6, second line
down, change ''The test to be performed ..... " to "The test performed ..... '.
41. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Page 35, last
paragraph, change " ...... DlW-1 simultaneously a rates similar .... ' to • DlW-1
simultaneously at rates similar .... ".
42. Agreed and incorporated.
The 30% Design Submittal is hereby modified as indicated on the revised table
(attached).
43. Chemical concentrations prior to air stripping were not measured since a more
representative estimate of groundwater concentrations was obtained through the
direct sampling of the aquifer test wells (Table 4.1 ).
• •
Page 9
44. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Page 49, third
paragraph, first sentence: 'General chemistry parameters observed in the RD/RA
sampling (Table 4.3) are similar to values from the treatability test groundwater
{Table 4.1) except for DTW-2."
45. Yes. The referenced well is DTW-2, located in the Back Valley.
The 30% Design Submittal is hereby modified as follows: Page 49, third
paragraph, third sentence: "The most likely explanation for this discrepancy is
that purging of DTW-6 prior to sampling only influenced the upper aquifer while
the greater ex1raction rate during the aquifer test influenced the entire screened
interval."
46. The NRCD Administrative Codes were given for reference purposes only.
Regulations governing the construction and operation of the remedial system
will be provided in the Prefinal Design Submittal.
4 7. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Section 4.3.1, Page
61, first paragraph, change the first sentence to " ... groundwater contamination
downgradient of DA 23 must be ..... ".
48. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Section 4.3.1, Page
61, first paragraph fourth line down, change " .... explosives (ROX and Picric Acid)
metals, to " ... explosives (RDX and Picric Acid), metals, ...... ".
49. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Section 5.1.3, Page
97, first paragraph, fourth line down remove "based,".
50. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Section 5.2.2.2, Page
106, second paragraph, first line, change "The associated lower shall component
be ... " to read "The associated lower component shall be ... .'.
51. Noted and incorporated.
The 30% Design Submittal is hereby modified as follows: Page 116, first line,
change "chemtronics" to "Chemtronics".
Date
1103
1/05
1/10
1/12
Average
% Removal
• •
TABLE 3.2
TREATABILITY TESTING RESULTS
CHEMTRONICS REMEDIAL DESIGN
CARBON ABSORPTION TESTING
BLENDED FRONT VALLEY GROUNDWATER
CARBON DOSAGE (mg/I) ,
Parameter 0 55 28 110
TOC (mg/I) <1 3 2 <1
COD (mg/I) 10 8 5 3
Benzophenone (ug/I) 19 <10 <10 <10
Benzilic Acid (ug/I) <50 <50 <50 <50
1 -Concentrations following air stripping.
Carbon: Powdered activated carbon; F-300/regenerated.
pH: 6.5
BIOLOGICAL TREATABILITY TESTING
BACK VALLEY GROUNDWATER (DTW-2)
210
4
2
<10
<50
COD (mgil) BOD (mgil)
HRT
(days) Influent Effluent Influent Effluent
3.5 540 18 >45. 5•
3.5 470 13 348 2
1.5 545 21 367 4
1.5 490 30 297 5
502 21 337 4
96 99
• Not included in averages or removal efficiencies.
TSS vss
(mgll) (mgil)
2060 1610
2130 1660
2130 1590
1680 1290
2000 1540
• •
GROUNDWATER REMEDIATION LEVELS
FROM
AMENDMENT TO THE ENFORCEMENT
RECORD OF DECISION
APRIL 26, 1989
(
• •
TABLE NO. 3 Gi<Ql.l!\'Th/An:R RE'-IEDIATION LEVELS AND CITED REFERENCES
Rerre:Jiaticn level
Q;r;g,m:l m/1
l, 2-Dic:hloroethane 0.005
Tridllcroethylene 0.005
Methyle:ie Chl.oride 0.06
Trans-l,2-Dic:hloroethylene 0.01
Benzene 0.005
Chl.O?'Ofom 0.l
Ethyl.benze."le 0.68
Tetac:hloroethylene 0.007
Br=fom 0.l
Carbon Tet...'"ac:hloride 0.005
Tolue.-ie 2.0
Pic:=ic Acid 14.0
:RD)( 0.035
'!NI' 0.044
Total cyanides 0.200
Lead 0.05
Cu·:%1-.i u::i 0.05
Nickel 0.5
~,.. l
Zinc 5
Be.-izilic 1-.cid 0.02:.
Ee'..z~e."lCne 0.1:2
MCL -!'--=Y.im.m C:::ntami.nant Level.
MCL(~Y.) -'Ille MCL fer 'Ictal Trihalaret.'lanes (s.::i cf all c:::n=.'l-
t= ti ens) is 0 .1 l!C../1. T!F.?-1' s include c:hlcrcf OI':11,
bra;x:,fcr:n, bn:m::dicilo~..hane, an::. c:hlcro:l.ili=o-
IDethane.
Sg.L""C'-2
MCL
MCL
:RSD
B-ICI.G
MCL
MCL(T.IEM)
B-ICI.G
l'!SD
MCL(T.IEM)
MCL
~
FP;.,V
'l.lSAiw;:c
E'L"J
RfD
MCL
MCL
R.."D
MCL
~
F:;.,V
f:;,LV
P.o.G -Pl:,::pcse:i M3.xim.mi O:intami.nant Lelfel Goal so rn 46936-41022
(Nove!Dber 13, 1985).
P?LV -Preliminary l'ollutant Limit Value (see~ A).
RfD -Refe..""e.'")::::e 0:se 52 rn 29992-29997 (AJ.igust 12, 1987).
:RSD -Risk Specific D:se, 51 FR 21646-21693.
USAIW;;C -US /. .r::y i.; at.= Q..Ja1 i. ty er i teria . n-.e g i ve.'J values have
bee.'l ai:prcved by t..'-1e Ar.r:,• SU..'"geon Ge..,;e....-aJ..
-Clean \.;at.er Act, \;"at.er Q..Jality criteria for Htlrran Healt.'1
-1-.:: j us--...e:j for Dr i.nk.ug \.;at= o:tl. y, [ Gold B::ck] •
Fr= 'ILV -Ca.lo..llate:l. fran a 'Ihres.'lola Liniit Value, bas.a::i. on a' 70 kg:
J_:E-rson "'ho c:1:-:inY.s_ 2 liters of "-at.er per day. A safety
fa c;--.or of 1 o o has al so bee.'l 2.IT)li.e:l..
-20-
•
•
•
• •
Attachment II'
Engineering Calculations
I -Cost Documentation
II -Quantity Calc·ulations
References for Cost ~stimates
-Means Building Construction Cost Data -1986
-Means Site Work Cost Data -1985
•
•
•
• •
1. Cost Documentation
(See Attachment III, Section 2 for Quantity Calculation)
A.
B.
Liner and Concrete Pad Removal/Disposal (Per GSX Estimate)
(Includes safety equipment-. canister, .suits,
1. Crew/equipment
$3078/day x 3 days
2. Add 50% if al.r packs required due to
loss of efficiency
3. Add $25.65/day/worker for air packs
$25.65 X 4 workers X 3 days X 1.5 =
4. Hauling liner and concrete pads to
Pinewood (100 mil thickness)
5.35 tons X 4 c. y. /ton = 20 c.y.
2 loads X $3.90/load/mile X 300 miles
5. Disposal costs at Pinewood
20 c.y. X $190.00 c.y. =
Subtotal
Removal of Leachate Detection System
1.
2.
3.
4" sand layer removal (Means crew B lOR)
121' x 45' x .33' = 1,800 c.f. 67 c.y.
$568/day x 1 day=
Add 507. due to use of air packs=
Air packs 525.65/day x 3 x 1 day=
4. Hauling/disposal at Pinewood (per GSX
estimate)
4 loads x $3.90/load/mile ~ 300 =
67 c.y. x $190.00/c.y. =
5. Removing underdrain trench (Means crew B
(3 X 121') + (2 X 45') X 2' X 3' = 2,178
2,718 c.f. = 100.7 c.y.
27
$610/day x 1 day
6. Add 50% due to air packs=
7. Hauling/disposal at Pinewood (per GSX
estimate)
5 loads x $3.90/load/mile x 300 =
100 C. y. X $ 190. 00/ C. y. =
gloves, OVA, etc.)
-1 lC)
C. f.
$
$
$
$
$
$
$
$
$
$
$
$
$
9,234
4,617
462
2,339
3,800
20,452
568
284
77
4,679
12,730
610
308
$ 5,848
$ 19,000
•
•
•
• •
8. Fill manhole, overflow box and pipes with
grout
(Means 2.3 23-020)
225 c.f. X $15.50 =
Subtotal
C. Placing Fill Material
1.
2.
3.
4.
5.
Cost of fill from on site borrow pit
(Means 12.1-614 $1231)
3,986 c.y. x $4.16/c.y. =
Chemical analysis of borrow pit soils=
Compaction of fill (Means 12.l 724-3150)
3,986 c.y. x $2.38/c.y. =
Add 50% if air packs used due to loss of
efficiency while compacting
Air Packs
$25.65/day/worker x 3 workers· x 10 days=
Subtotal
D. Liner Installation (Per Manufacturer)
1.
2.
Material cos ts (30 mil PVC liner)
$0.38/s.f. x 16,290/s.f.
Installation costs
$0.21/s.f. x 16,290/s.f.
Subtotal
E. 12" Layer of Sandy Material
l. Buy and haul to site and spread
(Means 2.3 05-050)
(16,290 s.f. x l') ~ 27 = 603 c.y.
603 c.y. x $12.52 Subtotal
F. 6" Topsoil/Lime/Fertilizer/Seed
l.
2:
Topsoil (Means 2.3 05-080)
(16,290 s.f. x 0.5') ~ 27 = 302 c.y.
302 c.y. X $14.52 =
Fine grade/see/lime/fertilizer
(Means 2.8 45-031)
(16,290 s.f. ~ 9) x $1.55/s.y. =
Subtotal
G. Exc3v3ce Dr3inage Swales (Nor:h and West Sides)
$ 3,489
$ 47,593
$ 16,563
$ 2,565
$ 9,488
$ 4,744
$ 770
$ 34,130
$ 6,187
S 3,343
$ 9,530
$ 7,551
$ 4,384
$ 2,804
$ 7,188
•
•
•
1.
2.
3.
•
Excavation (Means 2.3 10-010)
267 c.y. x $6.10/c.y. =
Grassing (Means 2.8 07-001)
267 S.y. X $1.54 =
Jute.mesh (Means 2.8 07-001)
267 S.y. X $0~90 =
•
4. Remove and replace 200 L.F. of fence on
west side (Means 2.1 45-075)
200' X $7.54 =
Subtotal
H. Soils Density Test and Proctors
1. Four proctor tests at borrow pit
(Means 1.1 60-490)
2.
3.
4 each x $115.50 =
Density tests/moisture tests
(Means 1.1 60-472, 475)
4 each x ($24.62 + $7.69)
Field technician
(r!eans 1. 1 60-555)
8 days x $154/day
I. Decontamination
Lump sum
J. Engineers Certification
Eight trips to site
8 x 150 miles x $0.23 =
8 x 8 hours x $51/hour
Per diem 8 x $20.50 =
Certification document
Subtotal
Subtotal
$ 1,631
$ 411
$ 241
$ 2,508
' $ 3,791
$ 462
$ 128
S 1 , 231
$ 1,821
$ 1,026
$ 250
$ 2,383
$ 160
S 2,052
$ 5,756
•
•
•
• •
2, QUANTITY CALCULATIONS
Biological Lagoon
A. Volume
Area at top of berm= 161.5' x 85' = 13,728 s.f.
Area at bottom of basin= 121.5' x 45' = 5,468 s.f.
Volume= 13,728 + 5,468 x 10 v.f. = 95,975 c.f. = 3,554 c.y.
(level) 2
Add 4% slope to cap
85' X 4% = 1.7' -2-
Vo l ume = 1. 7' x 85' x 161. 5' = 11,668 s. f. =
{4%)
Total Volume
B. Surface Area (With 5' overlap on all sides)
(161.5' + 10') X (85' + 10') = 16,293 S.f. =
C. Swale Volumes and Area
West side
400' x 3' avg. depth x 4' wide= 4,800 c.f. =
North side
200' X 3 ' X 4 ' = 2,400 C • f. =
Total
Area to grass
( 400' + 200') x 4' wide = 2,400 s. f. = 267 s .y .
432 C .y.
3,986 c.y.
1,810 s.y .
178 c.y.
89 C .y.
267 C .y.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
MAYO I '1980
4WD-NSRB
Mr. John F. Schultheis
Nimmo & co . ~~
P.O. Box 536
Swannanoa, NC 28778
345 COURTLAND STREET, N.E.
ATLANTA, GEORGIA 30365
Re: Agency's Acceptance of Responses to Comments on the
30 Percent Remedial Design for the Chemtronics
Superfund Site
Dear Mr. Schultheis:
ttf:.Gl:IVED
MAYO 4 199')
Sllf'HlRJIIJD SEtrtoru
The Agency sent comments on the above referenced document to the Potentially
Responsible Parties (PRPs) on March 23, 1990 and April 23, 1990. As mutually
agreed to during the development of the Remedial Design/Remedial Action Work
Plan, the PRPs were not required to revise the 30% Design document based on
these comments. However, the substance of these comments would be
incorporated into the next submittal, the 95% Design.
The PRPs' responses to the Agency's comments were routed to those individuals
who submitted review comments oq the 30% Design for acceptance .. We discussed
by telephone EPA RCRA program's comments. You were to call Mr. John
Dickinson for any clarification you felt you needed with respect to their
comments.
This letter confirms the Agency's verbal agreement stated during our
telephone conversation on Friday, April 27, 1990, that the PRPs have
satisfactorily addressed the Agency's comments on the 30% Design and that the
PRPs shall proceed with the next deliverable, the 95% Design. In accordance
to the schedule enclosed in your April 12, 1990 correspondence, the 95%
Design should be submitted to the Agency for review on June 27, 1990. If
there is any disagreement with date, please contact me.
Sincerely yours,
t!.~o~
Remedial Project Manger
cc: Charlotte Varlashkin, NCDEHNR
Bob Watson, Citizens' Watch
Printed on Recycled Paper
•
{]3\ ~~j;J,:1)1·
oger t-0 Yt\M
t:illt:IB {li1J{'.B1!!3
I
I
I
I
' I
April 1990
INTRODUCTION
• •
UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
FACT SHEET
ON THE CONCEPTUAL REMEDIAL DESIGN FOR
CHEMTRONICS SITE
SWANNANOA
BUNCOMBE COUNTY, NORTH CAROLINA
For More Info Contact:
Jon Bornholrn
North Superfund
Remedial Branch
[phone]
The information presented in this fact sheet is based on the work conducted
by the Potentially Responsible Parties (PRPs) pursuant to the Unilateral
ACllninistrative Order (UAO) iE:C'..led ~:l EPA, Regio~ IV. The UAO! dated March
22, 1989, was issued to Chemtronics, Inc., Hoechst-Celanese Corporation, and
Northrop Corporation, and required these PRPs to develop and implement a
Remedial Design/Remedial Action (RD/RA) work plan for the Chemtronics
Superfund site.
The RD/RA work plan, developed for the PRPs by their consultant, Sirrine
Environmental Consultants, was approved by the Agency on September 1, 1989.
The Agency's oversight contractor to assist the Agency in the review of
remedial design activities is the Dynamac Corporation under the Technical
Enforcement Support Program of the Agency.
The Remedial Action for the Chemtronics site was declared in the Record of
Decision dated April 5, 1988 which was modified by an Amendment to the Record
of Decision dated April 26, 1989. The selected remedial alternative is
provided below. All documents and information associated with the
development of the Record of Decision and the Amendment are contained in the
Administrative Record located in the Warren Wilson College Library located in
Swannanoa, North Carolina and in EPA, Region IV office in Atlanta, Georgia.
The Record of Decision was based on the Remedial Investigation and
Feasibility Study (RI/FS) conducted by the PRPs between August 1985 and
February 1988. In addition to these Administrative Records, several
information repositories have also been established in the Asheville area
where all pertinent information pertaining to the site can be reviewed by the
public. They are located at:
• •
* Buncombe County Emergency Services
* Chemtronics Site Information Bureau
* University of North Carolina@ Asheville
(The addresses, contacts and telephone numbers are provided later.)
SITE DESCRIPTION
The Chemtronics site occupies approximately 1,027 acres of rural land in
Buncombe County near the town of Swannanoa. The property was first developed
as an industrial site in 1952 and since has had several owners/operators. The
site is currently owned by Chemtronics, Inc. but is presently being leased to
Jet Research Center; Inc., another subsidiary of the Halliburton Company.
The primary products manufactured on-site were explosives, incapacitating
agents, and chemical intermediates. The waste streams associated with
manufacturing included various chlorinated and non-chlorinated solvents and
acidic solutions.
There are six discrete disposal areas (DA) on-site. These are DA-6, DA-7/8,
DA-9, DA-10/11, DA-23, and the Acid Pit Area (Figure 1). The Acid Pit Area
embodies sixteen individual disposal areas. The site can also be subdivided
geographically into the Front Valley which is drained by an unnamed stream and
the Back Valley which is drained by Gregg Creek. All surface runoff from the
site eventually discharges into Bee Tree Creek which also is the prominent
discharge location fo~ the groundwater flowing underneath the site.
· ; l\.flf>ro,omal<' f),sr,osal Area Aounda,oes 000 0
~ ""'
FIGURE 1 LOCATION OF DISPOSAL AREAS
Source: Chemtronics Feasibility Study
i
• • -3-
THE SELECTED REMEDIAL ALTERNATIVE
MIGRATION CONTROL (Remediatinq Contaminated Groundwater)
Installation of a groundwater interception and extraction system
downgradient of the disposal areas in both the Front Valley and\the Back
Valley. The level and degree of treatment of the extracted groundwater
will depend on 1) the ultimate discharge point of this water and 2) the
level of contaminants in the extracted groundwater. The three ~ater
discharge alternatives for the treated water are 1) the local s~wer system,
2) a surface stream and 3) on-site irrigation. The range of tr~atment for
the extracted groundwater includes air stripping, filtration through
activated carbon filter and metal removal. The point of discharge and the
degree of treatment will be determined in the Remedial Design stage. The
water discharged will meet all ARAR' s. I
A monitoring program, employing bioassays, will be established t'or surface
water/sediment. Monitoring locations will be located on the Unn1amed
Stream, Gregg Branch and Bee Tree Creek. The purpose of this mohitoring
program is 1) to insure no adverse impact on these streams during
implementation of the remedial action and 2) to establish a data!base to
use to measure the success of the remedial action implemented. The
initiation of this monitoring program will be concurrent with th0 remedial
design activities.
Review the existing groundwater monitoring system and install additional
wells, if necessary, to insure proper monitoring of groundwater 1 downgradient of each disposal area. This includes disposal area~ #6, #7/8,
#9, #10/11, #23, and the acid pit area.
In addition to the monitoring of the groundwater downgradient of 1,each
disposal area identified above, action levels for the contaminant's present
' in the disposal areas will be set so that after remediation levels for
groundwater have been obtained and verified through monitoring, i 1f this
level is reached in any subsequent sampling episode, a remedial a~tion to
' permanently eliminate that source of contamination will be initia~ed.
SOURCE CONTROL (Remediating Contaminated Soils)
Cap Disposal Area #6, Disposal Area #7/8, Disposal Area #9, DispoSal Area
#10/11, Disposal Area #23, and the Acid Pit Area with a Multi-Lay~r cap
which includes a synthetic liner. Security fencing, vegetative cOvers and,
where deemed necessary, a gas collection/ventilation system will be
installed. The multi-layer cap will meet as a minimum, the standJrds
' specified under 40 CFR Subsection 264, Subparts K-N. I
Sample On-Site Pond on Unnamed Stream
During the Remedial Design stage, sample the water and sediment in the
pond. If the analysis indicates contaminants in either the water: column
or sediment, then the pond will be drained, with the water being ~reated
through the treatment system developed for addressing the extracted
groundwater and the sediments will be transported to another disposal area
and capped along with that disposal area. 1
• •
RECENT MILESTONES
A Technical Assistance Grant (TAG) of $50,000 was awarded to the Citizens'
Watch For. A Clean Environment, Inc. in December 1989. Subsequently, copies
of draft documents submitted on behalf of the PRPs have been transmitted to
the Citizens' Watch For A Clean Environment association for review and
comment. Responses from the PRPe to comments and questions raised as a
result of the Agency's review have also been shared with the TAG recipient.
The revision of the Community Relations Plan (CRP) was completed in February
1990. Copies of the revised CRP were disseminated to various entities
including the information repositories.
As required by the UAO, the PRPs were to develop, for the Agency's approval,
a RD/RA work plan. The objectives of the Agency approved RD/RA work plan
are:
* definition of the site design basis;
• preparation of a conceptual design of the selected remedy (30% design),
including selection of the capping materials, the groundwater treatment
system, and discharge of treated groundwater;
• preparation of a final draft design, including specifications of the
caps, groundwater treatment system, and the treated groundwater
discharge system;
• preparation'of a Quality Assurance/Quality Control (QA/QC) plan for
construction during Remedial Action;
• preparation of Worker Health and Safety considerations for Remedial
Action (the actual Safety, Health and Emergency Response Plan to be
prepared by contractor conducting the Remedial Action);
* preparation of Preliminary Operation and Maintenance Plans for
construction and groundwater treatment;
* development of a design packet for contractor bids;
* determination of the present worth costs of the selected remedy; and
* formation of a Remedial Action schedule.
The Chemtronics RD/RA work plan identified several additional data
requirements necessary to complete the RD in order to initiate the RA. These
additional data requirements included 1) characterization of groundwater, 2)
treatability testing, 3) survey and soil information, and 4) sampling on-site
pond. The RD/RA work plan also provides direction to the development of the
remedial design and the implementation of the approved design in the remedial
action stage of the Superfund process.
• • .----·
J -5-
The effort to further the characterize the groundwater and hydrogeology of
the site was addressed in a separate document entitled "Groundwater
Characterization Scope of Work" which was approved by the Agency in September
1989. The primary emphasis of this further characterization was to generate
additional information necessary to design appropriate groundwater extraction
systems in both valleys. The major components of this initiative were the
installation of three extraction wells, the running on pump tests using the
newly installed extraction wells and existing monitor wells, and the
collection of groundwater samples of analytical analyses.
The treatability study centered on devising the most appropriate means of
treating the extracted groundwater. The groundwater samples collected during
the groundwater pump tests were used to establish design parameters for the
identified treatment technologies.
In order to ensure the proper design of the caps, more detailed topographical
survey maps delineating the disposal areas were necessary. These maps will
allow the determination of fill requirements and the amount of materials
necessary for capping. Compaction and other appropriate testing procedures
will be conducted on soils from potential on-site borrow pits to determine
their feasibility for use during remediation. The soil tests are to include
1) classification of soils, 2) standard proctor, 3) moisture content, 4)
relative density by sand-cone method, 5) relative density by nuclear methods,
and 6) permeability. If testing of on-site soils indicate that these soils
are usable for construction of the caps, then this would eliminate the need
to haul soils to the site.
Permeability and percolation values of soils in the areas where treated
groundwater may be discharged to on-site soils needs to be established. Thie
work will be done in accordance to the specification in North Carolina State
codes.
The final set of field data to be collected as part of the RD is the analysis
of samples collected from the on-site pond on the unnamed stream in the Front
Valley. This analytical data will allow the final determination for the
remediation of the on-site pond.
Also called for in the ROD is the development and implementation of a
Bioassay Monitoring Program (BMP). The objective of the BMP is to l) insure
no adverse impact on surface water and 2) establish a data base for use in
determining the success of the implemented remedial action. The draft BMP
was submitted to the Agency on November 17, 1989 for review. The last set of
comments on this document were sent to the PRPs on December 12, 1989. on
February 15, 1990, the revised BMP was submitted to EPA for review. Comments
on this revised document will be sent to the PRPs in the near future.
Overall, the approach detailed in this document to monitor the surface waters
on and off the site are acceptable.
• •
FINDINGS OF RECENT REMEDIAL DESIGN FIELD INITIATIVES
The 30 percent (30%) remedial design (Remedial Design Concept Design Review
document) was submitted to the Agency for review on February 27, 1990.
Copies of this draft document were routed to various Programs within EPA, _the
State and the Citizens' Watch group for review and comments. Compiled
comments from this review process were sent to the PRPs on March 23 and 28,
1990. In summary, the Agency concurs with the approach that the PRPs are
taking with respect to the Remedial Design. Although a revised 30% design is
not required, the PRPs do need to respond to the comments on the 30% design.
Requested changes will be made in the next submittal which is the 95%
remedial design document.
Below are discussed individual sections of the 30% remedial design document.
Based on the groundwater pump tests conducted on site as part of the
groundwater characterization effort, the groundwater extraction systems and
future groundwater monitoring strategies were defined in the 30% design
package. The Agency had several comments with respect to the proposed
groundwater extraction and monitoring strategy for the Front Valley but the
design proposed for the Back Valley appears to be acceptable.
The proposed groundwater treatment systems were also described. The PRPs'
have decided to treat the groundwater extracted in both valleys separately.
Figure 2 shows the proposed treatment scheme for groundwater extracted in the
Front Valley while Figure 3 shows the proposed treatment scheme for extracted
groundwater in the Back Valley. The inclusion of the fixed film bio-reactor
in treating groundwater from the Back Valley is due to the high chemical
oxygen demand (COD)/biological oxygen demand (BOD) content of the
groundwater. In essence, there is sufficient organics, the source of carbon,
to support the growth of bacteria. These treatment scenarios are based on
the data generated during the treatability study.
The options for discharging treated groundwater were also evaluated as part
of the 30% design. The PRPs discussed groundwater discharge options with
State and municipal personnel. The State indicated that, while not
impossible, obtaining a National Pollution Discharge Elimination System
(NPDES) permit for surface water discharge would be difficult. Pursuing this
route would prolong the Chemtronics RD due to the increased technical
requirements, the need for stream characterization, internal and governmental
reviews, and public comment periods. Based on these preliminary discussions
with the State, the State gave a strong preference for discharge to the
publicly owned treatment works (POTW). Discussions between the PRPs and the
Buncombe County Metropolitan Sewer District (MSD) indicated a strong
reluctance on the part of the Buncombe County MSD to accept treated
groundwater from the Chemtronics site. The primary objections were the
current hydraulic limitations of the treatment plant, potential impacts of
"clean" groundwater, and the new user allocation process. POTW's generally
dislike to receive clean water because there is minimal organic content to
sustain the microbial populations in the treatment plant.
Utnctioll w,n,
•
Equaliz.ation
Bag
Fill tr
.,
-7-
Air
Slrippint
Acid Rime
(ror ,calt rtmov1I)
Carboo
Adsorption
Monitoring Infiltration
Gall«y
FIGURE 2 PROPOSED GROUNDWATER TREATMENT SYSTEM FOR FRONT VALLEY
Ecp■tiatioa
FIGURE 3
... ..... ,
Air
Strippi"W
N•trwnt
Additioll
N.OH
Nf'lltraliutioa
Ya.rd Fila
Bio-rnrtor Mdi111ntatioa
~f---\
Sol ...
ToDispaul
lafihntim G,...,
PROPOSED GROUNDWATER TREATMENT SYSTEM FOR BACK VALLEY
The Buncombe County MSD is currently out of compliance and corrective
construction is underway. Because of permit violations, the MSD is under a
Consent Order from the North Carolina Department of Health, Environment and
Natural Resources that allocates additional wastewater flows under specified
conditions. The MSD has stated that an allocation request from Chemtronica
would be reviewed unfavorably. Therefore, treated groundwater will be
discharge on-site through unite referred to in the North Carolina Department
of Health, Environment and Natural Resources NRCD Administrative Code 15 NCAC
2H.0200 as Remediated Groundwater Treatment Systems. The actual discharge
option selected was infiltration galleries. Figure 4 shows a cross section
of a trench in an infiltration gallery. Figure 5 shows the anticipated
locations of the infiltration galleries on-site.
The water column and sediment in the pond on the unnamed stream in the Front
Valley were sampled in January 1990. These samples were analyzed for
volatile contaminants. Based on the analytical results, the Agency concurs
with the approach proposed by the PRPa for abating the pond. The
concentrations of the two contaminants found in the water column,
~6.0'
5.01
BACKFLL
__ UNOtSTIJRBEO
NATURAL SOIL
TREATED GROUNOW!ITER
---DISTRIBUTION
AGGREGATE OR ---SYNTt£TlC DRAl'IAIE MEDIA
--SYNTHETIC DRANAGE FABRIC
MEAN r.£Sli OPOING= 0.4nm
I
TYPICAL TRENCH SECTION
N.T.S.
FIGURE 4 CROSS-SECTION OF INFILTRATION
GALLERY TRENCH
Source: Remedial Design Concept Design review
1,2-dichloroethane and
trichloroethylene, are well
below the Ambient Water
Quality Criteria (AWGC).
AWGC represent conservative
levels that are protective
of aquatic life and
propagation. The PRPa have
proposed to breach and empty
this impoundment. The
resulting impression will
then be graded to prevent
the formation of standing
water in this location, thus
eliminating the pond.
The preliminary design of
the multilayer cape to be
placed over each of the
disposal areas were also
proposed in the 30% design
document. Six cape will be
constructed and each cap
must be considered
independently due to
differences in the slope of
the land, forest cover,
drainage requirements,
access, buried utilities,
and disposal area contents,
etc. Figure 6 shows a cross
• • -9-
LEGENO
Olapoeal Ar .. 8o,undatln
<00 0 ,oo
SCAl..[INFCET
FIGURES LOCATION OF POTENTIALLY SUITABLE RECHARGE AREAS
section for the
area. Figure 7
7/8 and 10/11.
NEXT STEPS
Source: Remedial Design Concept Design review
cap proposed for disposal areas 6, 9, 23, and the acid pit
shows a cross section for the cap proposed for disposal areas
The designs of the caps appear to be acceptable.
Prior to submitting the 95% remedial design package, additional data needs to
be generated. The PRPs need to determine if on-site soil can be used to
construct the caps and if on-site soils are capable of being used as
infiltration galleries. The 95% design is scheduled to be delivered to EPA
the week of June 25, 1990.
Copies of this design package will be shared with the previously identified
entities for review and comments. The final design is to be completed in
August 1990. Presently, it is anticipated that actual construction
activities will begin in November 1990.
Figure 8 provides an updated schedule of activities/milestones for the
remainder of the year.
• • -lQC. ·-·'
i
' "' S~m
FIGURE 6 CROSS-SECTION FOR PROPOSED MULTILAYER CAP FOR
DISPOSAL AREAS 6, 9, 23, AND THE ACID PIT AREA
Source: Remedial Design Concept Design review
Com~I• Drainage Net
J, (
r· Erosion Control Blank•!
/
FIGURE 7 CROSS-SECTION FOR PROPOSED MULTILAYER
CAP FOR DISPOSAL AREAS 7/8 AND 10/11
Source: Remedial Design Concept Design review
• • -11-
FOR MORE INFORMATION
Copies of the draft FS and other pertinent documents are available for review
at the information repositories listed below:
Buncombe County Emergency
Services
Asheville, NC 28807
[phone]
Contact: Mr. Jerry VeHaun
University of North Carolina
at Asheville
One University
Asheville, NC
[phone]
Heights
29904-3299
Contact: Dr. Gary Miller
Chemtronics Site Information
Bureau
P.O. Box 18177
70 Woodfin Place
Asheville, NC 28814
[phone]
Contact: Mr. Chad Russell
Warren Wilson College
701 Warren Wilson College Road
Swannanoa, NC 28778
[phone]
For questions or further information, contact either of the following:
Jon Bornholm
Remedial Project Manager
North Superfund Remedial Branch
U.S. Environmental
Protection Agency
345 Courtland St., NE
Atlanta, GA 30365
[phone]
Beverly Mosely
Community Relations Coordinator
Office of Public Affairs
U.S. Environmental
Protection Agency
345 Courtland St., NE
Atlanta, GA 30365
[phone]
IBN!1iilllDSI RR IN E IJATE 4/9/90
CHEMTRONICS RD/RA PROJECT NO. G-9169 fJ]Piflllill . •·;! ENVIRONMENTAL PREPARED IJY Jl'I
l!t!filllllilcoN SULT ANTS Jan I, 1990 Jun. I, 1991
0 60 120 180 240 300 360 420 480 540 600 660 720 780-
MAJOR WORK TASKS ,. Submit Prnposed RD/RA Schedule
{l\'"V 5. IUIZIJI
II. Work Plan for RDIRA ....,
Ill. WP Review and Approval
IV. Other Contracl Uocumenl,; 1....1 {Concurrent with Task llll
V. Trealability Teshng-
Data Gatherino-S11rvev
VI. Devtlop Design Basis I
VII. 30% Uesigo I
VIII. 30% Comment Puiod I Irr. '-r.,
IX. 95% Design
X. 9S% Commenl Per-iod ...,,
XI. Finalize Design Packet ...
XII. Bid Process -XIII. Contractor Mobilization ' 1 ......
XIV. Permiuing •' I I
<Mav varv based on needs)
xv. Start Remedial Action
XVI. Final OM Manual: (Development) ~, ' ' '
Monthly Progress Reports
Key: Studies or Activities EPA Comment Period
-rz:zz2I
FIGURE 8 SCHEDULE OF ACTIVITIES/MILESTONES FOR THE CHEMTRONICS SITE FOR THE YEAR OF 1990
Source: April 12, 1990 Correspondence from John Schultheis
f i
•
•
UNITED STATES •
ENVIRONMENTAL ?ROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
OFFICIAL BUSINESS
PENAL TY FOR PRIVATE USE. 5300
Stan Atwood
North Carol· Human Res ina Department of p ources .o. Box 2091
Raleigh, NC 27602
_j
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
MEMORANDUM
SUBJECT: Review of Chemtronics Site Remedial Design Concept
FROM:
TO:
submitted by the Chemtronics Facility
EPA I. D. Number NCD 095 459 392
John Dickinson, Chief
NC/SC Unit, Waste Engineering Section
Jon Bornholm
NC/SC Unit, North Management Section
The purpose of this memorandum is to forward to you our comments
on the Chemtronics Site Remedial Design (RD) Document. We
apologize for the lateness of our comments and for any incon-
venience to you. This review focused on the remediation of the
biolagoon as part of the Disposal Area (DA) 23 and its adequacy
regarding the July, 1989, approved Closure Plan for the same
area, DA 23 (an inactive surface impoundment).
My staff has determined that the RD proposal as described is not
entirely complete regarding the Closure Plan requirements and
has attached a number of comments for your review. Please note
these comments and if you have any questions contact Dennis
Manganiello of my staff at extension 3433.
• •
COMMENTS ON CHEMTRONICS
SITE REMEDIAL DESIGN CONCEPT
EPA I. D. NUMBER NCD 09~i 459 392
1. Page 3 -Statement is made that the designs and specifi-
cations will comply with 40 CFR 265 . .310(a),
This regulation cited refers to closure and post-closure
care requirements which will be acceptable for the
multi-layer cover for DA 23. The additional applicable or
relevant and appropriate requirementn (ARARs) the RD must
comply with are the closure plan requirements of 40 CFR
264.110 through 115. Compliance with these regulations will
ensure that the completed closure activities will control,
minimize or eliminate threats to human health and the
environment, and post closure escape of hazardous waste,
hazardous constituents, leachate, contaminated rainfall or
waste decomposition products to the 9round or surface waters
or atmosphere.
2. Time allowed for closure: for ordinaiy RCRA closures,
closure activities commence with the acceptance and approval
from the State of the closure plan and are completed within
180 days. These requirements apply here, however since this
plan is being carried out under the Superfund Program, it is
anticipated that the time schedule for closure may require
modification.
If an unexpected event occurs during the RD phase or
Remedial Action (RA) Phase, which requires a modification to
the closure of DA 23, then Chemtronics, Inc. will amend the
closure plan as necessary no later than 30 days after the
unexpected event occurs.
3. Page 36 -Treatability Testing
The Chemtronics RD includes selected treatment processes
(filtration, carbon adsorption, bioloqical treatment) as
part of the overall groundwater remed:Lation design which
must treat and neutralize the hazardous waste and hazardous
constituents extracted from the groundwater in the vicinity
of DA 23. To adequately comply with the RCRA closure plan
and ARARs, specific requirements addreissing on site
treatment are required which include:
0
0
0
The calculation of the anticipated incremental
pollutant emissions, discharges, and residues.
The assessment of additional haz1:,rds posed to human
health and the environment.
The determination whether additional emissions or
discharges are justifiable and minimized.
•
•
• •
-2-
Transporting any residues to an appropriate off site
management facility in accordance with 40 CFR 264,114 .
For shipment of waste liquids a.nd sludges and
contaminated liners and soils, Chemtronics must
identify and characterize the waste as hazardous or
not, according to the RCRA waste characteristics and
lists contained in 40 CFR Part 261. Also Chemtronics
must comply with all applicable RCRA and authorized
State regulations for hazardous waste, generators and
transporters contained in 40 CFR Parts 262 and 263,
respectively.
For overall compliance, Chemtronics must document and report
the results of these efforts to both the EPA and NC DHR
reviewers as part of the CERCLA RD/RJ\ and RCRA closure plan
activities. Attention should be paid to whether the
facility receiving the waste is permi.tted to handle the
waste types destined for it, particularly regarding the land
disposal restrictions in effect at the time and the ban on
landfilling liquids.
4. Page 45 -General Comment on Groundwater Remediation Design:
Groundwater monitoring has been performed in this area since
1980. At that time, two groundwater monitoring wells were
installed downgradient of the impoundment, M85L4 (depth -12
feet) and M85Ll0 (depth -35 feet). In March of 1986, two
additional groundwa·ter monitoring wells were installed, BW4
(bedrock well -121.5 feet in depth) and SW4 (surficial well
-53. 2 feet in depth). Location of t}1ese monitoring wells
can be found in Attachment 1. Coritam.i.nation of the ground-
water in this area has been confirmed from the analyses
performed. It is anticipated that at the onset of closure
of the surface impoundment, the groundwater will be
extracted from this area and treated to acceptable standards
as established under the CERCLA progrc1m and accepted for use
under the Closure Plan. After treatmemt, the effluent will
be discharged into either the Metropolitan Sewerage District
or receiving waters via NPDES permit. Closure compliance
requires that groundwater monitoring be performed in this
area quarterly and samples be analyzed for the following
parameters: pH, Specific Conductance, Total Organic Carbon,
Nitrate Metals (Barium, Chromium, Iron, Magnesium,
Manganese, Sodium, Lead) and Volatile Organic Compounds.
5. Cap Design: Page 99 and Page 126 discussing the cap for DA
23:
• •
-3-
a) Page 99 -100 General Consider,:i.tions:
No hazardous waste or hazardou,, constituents are to be
placed in the biolagcon, This surface impoundment has
not received hazardous waste ot any kind since June
1984. Any material in the impoundment at this time is
solely accumulated rainwater. The RD proposes to
construct a final cover for DA 23 that complies with 40
CFR 265,310. This will entail the discharge of the
rainwater. Therefore, the Clos:ure Plan requires this
water be tested to ensure that it complies with
pretreatment standards for discharge into the sanitary
sewer and pumped directly to the Buncombe County
Metropolitan Sewerage District treatment facility.
Accumulated biological growth, natural organics matter
and miscellaneous debris will be disposed of in a
non-hazardous landfill. Prior approval for this
disposal will be obtained from the NC DEHNR.
b) Page 126 -Section 5.3.9.5. -Disposal Area 23:
This section describes the activities comprised in
construction of the cap for DA :?3. This section is
incomplete since it does not mention any details
regarding the removal of the bic,lagoon' s leachate
detection system. The followin9 information should be
added to section 5.3.9,5:
The leachate detection system is comprised of
perforated polyethylene pipe, washed gravel about the
pipe, polyethylene filter fabric outlining the trenches
and a layer of overlying washed sand, Attachment II
provides additional details regarding the removal of
this system. This system will be removed using normal
excavation techniques and transported to a RCRA
permitted waste facility via cov1~red liquid tight, dump
type truck. All work will be pei:formed by a contractor
familiar with hazardous waste requirements. The
existing groundwater diversion trench will be kept in
place to help prevent groundwate1: intrusion beneath the
impoundment. After removal of the liner and leachate
detection system and plugging of all piping to and from
the lagoon, the impoundment will be covered so as to
prevent the migration of hazardous constituents into
the groundwater or surface waters.
6. The capping of Disposal Area 23 is both a source control and
migration control measure. It not only involves the
stabilization of soils but also the subsequent redistri-
bution of these soils into the biolagoon basin. Because of
the indeterminate nature or results as:,ociated with these
activities, Chemtronics must evaluate and document the
• •
-4-
effect of these remediation methods to both the EPA and NC
DEHNR immediately following their implementation.
7. Section 6.0 Long Term Monitoring and Maintenance -Page 132
-133:
The following discussion should be added to this section to
comply with the post closure plan for an inactive surface
impoundrnent ( 40 CFR Part 264. 228), spe,cifically, DA 23:
Post-Closure care shall be provided fer the inactive surface
impoundrnent, once it is closed in accordance with approved
closure procedures, and shall continue for thirty years
unless otherwise directed after the completed closure date.
Post-Closure care will include the following:
1. A description of planned monitoring activities and
frequencies of performance in accordance with the
specifications in Sub-Part F during the post-closure
period.
2. A description of the planned maint,,mance activities and
frequencies of performance to insu:re the integrity of
the cap and final cover of the sur:Eace irnpoundrnent area.
3. The name, address and phone number of the person or
office to contact about the facility during the
post-closure care period.
Of course, the RCRA post-closure care permit will
incorporate these requirements when issued.
4. Maintenance Activities
Once closure of the surface impoundrnent has been
completed, the following maintenance activities should
be conducted in conjunction with the CERCLA activities
that will be performed in this area.
Chemtronics should ensure that the closed surface
impoundrnent is properly maintained by inspecting it
regularly in the following areas:
1. Security devices ( fence and padlock,3)
2. Erosion damage
3. Vegetative cover
4. Run-on/run-off control system
• •
-5-
The surface impoundment's cap should be sloped to provide
positive site drainage away from the impoundment. Cap
elevations should be checked annually to ensure that the
positive drainage slope is maintained. Should minor
subsidence or spot irregularities be discovered, new topsoil
must be placed on the cap and the top soil must be regraded
and reseeded.
The cap will also be protected from ,3rosion by maintaining
an appropriate vegetative cover. Maintenance activities for
the vegetative cover will be perform,3d· on an as-needed basis
due to the seasonal nature of the veqetation.
The surface impoundment' s security s:rstem ( fence and
padlocks) should be inspected weekly. The fence should be
checked for corrosion and structural damage. The padlocks
should be checked for corrosion, ease of operation and
integrity. Repairs and replacements should be made as
necessary. Clearly visible signs declaring the area to be
off limits to unauthorized personnel should be posted on all
sides of the fence.
. :?Ar-J~.JE;,
D1?l'21t-Ul10N
f;:;,o..:
•
I
LAe,A.-Jc;o...Jec~ D-;=,,i..1rJF1EL:?
(Af'~. ~AT1or-l)
C)
•
/L-_-_,j-__ 11 ,1_1_-_-_~"'
' _j ----
,oc•
FIGURE 1.l.
LOCATION OF BIOLA{
ANO ABANDONED· DRAIN
CHEMTfl0NIC3
"
Envlronm
Dlwlolc -
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
MAR 2 3 1990
4WD-SFB
Mr. John F. Schultheis
Nimmo & Co.
P.O. Box 536
swannanoa, NC 28778
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
Re: Comments on the 30 Percent Remedial Deai9n
fc~ tha Che~~=o~ics S~perfu~d Site
Dear Mr. Schultheis:
-~ECEIVED
MAR ;JO 1990
SUPERFUND SECTION
Four copies of the above referenced document prepared by Sirrine
Environmental Consultants (SEC) for the Potentially Responsible Parties
(PRPs) were received by the Agency on February 27, 1990. As part of
Superfund's review process, copies of these dccuments were transmitted to
various programs within the Agency, to North Carolina Department of the
Environment, Health & Natural Resources (NCDEHNR) and the Citizens• Watch for
A Clean Environment for review and comments.
The necessity of this document was to fulfill a requirement in the Unilateral
Administrative Order (UAO), dated March 22, 1999, under Paragraph V entitled
Order, Subparagraph D. -Schedule for the Work, Task 5. -Submission of a 30
percent Conceptual Design. This subparagraph ,,lso specified the minimum
information to be included in the 30% design. The 30% Concept Remedial
Design document submitted by the PRPs fulfills the requir_ements of the
section of the UAO specified above.
Below is a compilation of the _comments I received from within the Agency and
from NCDEHNR on this document. Comments from E:PA • s RCRA program are to be
submitted March 27, 1990. Upon receipt, I wiii i:raruimit them ·i;.o you.
I have separated the technically oriented comme,nts from the editorial ones.
Although a revised 30% design is not required, all the technically oriented
comments need to be addressed. I would like a response, as soon as possible,
to the requested data in comment number 36.
The technically oriented comments follow:
-.
1.
• -2-
Page 2, Section 1.3: It would be helpful
Declaration from the Record of Decision
from the April 26, 1989 ROD Amendment:
quickly focus in on what the design and
to accomplish.
•
to include the April S, 1988
(ROD) and/or the Declaration
Thia would allow the reader to
resulting remedial action is
2. Page 6, Section 2.2.l: It would be help:Eul having schematics of the
test wells showing actual construction details included in this
section.
3. Page 6, Section 2.2.1, second paragraph: Monitor well 8W-12 is
mentioned but is not shown on any figu1:e included in this document. A
large scale map showing all monitor well locations needs to be
incorporated.
4. Page 11, last paragraph, third sentence: Thia sentence highlights that
the screen for DTW-1 was located at a particular depth due to
Silbsu..:face conditioi.16 but these subaurf~cs-cor.diti=ins are na\·er
specified. These "subsurface conditions" need to be expounded upon.
5. Page 12, Section 2.2.2: It was stated in the last paragraph, second
sentence on page 10 in the "Ground Water Characterization Scope of
Work" document, dated August 1989, that the duration of the pumping
teats would be dictated by the aquifer response. The rationale for
ending the pump teats after 24 hours was not clearly stated in this 30
percent design document.
6. Page 17, Section 2.3.1: The aquifer teat data from the recovery period
was analyzed using type curve techniques (i.e., the Theis Method).
The Theis Method as described in numerous references is typically used
only for evaluation of drawdown data. •rhe reference(s) followed in
performing the recovery data evaluation,a needs to be provided.
7. Page 18, Section 2.3.1: The stagnation p<>int equation used in the flow
net analysis is correct, however, great1!r detail needs to be provided
with respect to the determination of tht! width of the capture zone in
the flow net analysis. Was an equation used to determine this value
or was this width estimated from water-:Level data acquired during the
aquifer test? If actual field data was used, how does the estimated
width compare with a theoretical width determined using:
2 (g,,l (b)
The variables here are the same as those, defined on page 18 in the 30%
Concept Design submittal.
8. Page 19, Section 2.3.2: The determination. of the time for the effect of
casing storage to become insignificant and the barometric efficiency
needs to be documented in either the text or in appendix A.
• -3-•
9. Page 22, Section 2.3.2: Refer to comment number 7.
10. Page 26, Section 2.3.3, seventh line down: It is unclear as to the
exact source of these "fluctuations". Are these fluctuations due to
earth tides or changes in the atmospheric pressure or due to both of
these forces?
11. Page 26, Section 2.3.3, last sentence: ·rhis sentence states that the
values of transmissivity obtained from semilog time-drawdown analyses
were nearly two time those obtained fr,:,m type curve analyses. It is
unclear as to which transrnissivity value was used. What is the
rationale/advantage for using one anal:rses over the other?
12. Page 26, Section 2.3.3.1, fourth sentenc13: Why was ~ype curve analyses
used and semilog time-draW'down analyseH not to calculate the
transmissivity value?
13. Pa<;;e 32, Secti.on 2. 3. 3. 3 ~ Ra fez: to com:ri.:~;i·::. r-,·,.;.rnt.er 7.
14. Page 33, General Conclusion 1.: A more detailed description of the
transition zone is warranted.
15. Page 41, Section 3.2, top of page: Some discussion needs to be included
in this section or some other appropriate section that states what is
to be done with the spent activated cazbon.
16. Page 42, Section 3.3, second paragraph: Some discussion needs to be
included in this section that states what is to be done with the
settled biological solids.
17. Page 45, Section 4.1.1: This section was difficult to follow. It may
make it easier to split this section into two parts, one for the Front
Valley and one for the Back Valley.
18. Page 46, Table 4.1: Add an additional column to identify cleanup
levels, as specified in the ROD, for Methylene chloride, Benzophenone,
Benzilic acid, and RDX.
19. Page 48, Table 4.2: Why was data for SW-9 from the RI omitted from this
table? Why not include all existing data for all wells identified in
"this table as well as in st:.te other table::s?
20. Page 49, second paragraph, first sentence: Although the levels of
chromium were below detection from samples collected from the aquifer
test wells, chromium was detected in monitor wells during the RI.
21. Page 51, Section 4.1.3: The assumption that extraction wells STW-1 and
DTW-1 can capture the contaminated groundwater from DA-23 is baaed on
a flow net developed by adding drawdowns from separate aquifer tests
performed on the saprolite zone and the weathered/fractured bedrock
zone. Theoretically, this additive drawdown effect is correct so the
assumption has merit. However, due to the geological complexities
• -4-• within the aquifer system at the Chemtronics site, the Agency has
strong reservations. It may be necessary to perform an additional
aquifer test at this location utilizing both STW-1 and DTW-1 at the
drawdown rates projected here to evaluate this extraction system. At
a minimum, intensive monitoring of water levels should be performed
during the start-up phase of this extraction system. Analysis and
evaluation of this data may indicate t~'le need for additional
extraction wells and/or adjustments to the proposed pumping rates.
22. Page 54, second paragraph: As stated on the previous page, page 53, the
States preference is to discharge to the WWTP. What is the States
opinion on employing infiltration gallE!ries for the discharge of
treated 9roundwater?
23. Page 57, second paragraph, second sentence: With the piping only 1. 0
foot below the ground surface, is this below the frost line for this
part of the country?
24. Page 59, Section 4. 2. 3: This section die:cusses the discharge levels of
the treated groundwater to the infiltra.tion gallery. It is stated
that the quality of the discharged water will meet North Carolina
water quality standards for Class GA groundwater (NCAC Tl5:02L.0202).
Is this more stringent than a Federal standard? If so, this should be
stated in this section. If not, then the most stringent requirement
needs to be applied.
25. Page 60, Section 4.3, first sentence: Change the language in this
sentence to reflect the language in the Declaration of the April 5,
1988 ROD and the ROD Amendment dated April 26, 1989. The Declaration
states "Installation of a groundwater interception and extraction
system downgradient of the disposal are,,s in both the Front Valley and
Gregg Valley.".
26. Page 63, Table 4.4: What is the rationalo for establishing flow rates
at 80 percent the maximum flow rate?
27. Page 67, first paragraph: This paragraph summarizes Section 4.3.1 but
does not state the effectiveness of the existing groundwater
monitoring system. In light of the fact. that test wells will become
the extraction wells, is the existing mc,nitoring system adequate to
monitor the groundwater and insure that the plume is being captured.
28. Page 67, Section 4.3.1: Refer to comment number 21.
29. Page 78, Section 4.3.2: Monitor wells are necessary downgradient of the
extraction system in order to evaluate the effectiveness of the
process. Additional monitor wells need to be proposed.
30. Page 78, Section 4.4: What is to be done with the following:
1. Used bag filters?
2. Spent Cartridge filter?
3. Spent Activated Carbon?
• -5-•
31. Page as, section 4.5: What is to be done with the used bag filters?
32. Page 96, Section 5.1.2: It is stated in the second sentence that the
surface area for DA 7/8 is approximately 14,900 square feet. Further
on in this paragraph, it is stated that a cap of this size would not
be sufficient to cover the area of con,:ern. The fifth sentence states
that the proposed cap has a surface ar,3a of approximately 13,800
square feet. There is a contradiction here. If a cap of 14,900
square feet is insufficient to cover the area of concern, then the
proposed cap size of 13,800 square feet will also be insufficient to
cover the area of concern.
33. Page 115, first paragraph, last sentence:: Why wait to sample these
vents? If gas is being released, then a gas venting system will need
to be included in the design. Sarnplin9 the vents prior to abandonment
is too late. If it is determined that venting is required at this
late date in the design, this will lead to an unacceptable delay in
cor::.pl'S!ting th.: desi;rr~ t.nd tha1:afore:, tt.c ir:rplementation cf the
remedial action.
34. Page 133, Section 6.2, sixth and seventh sentences: The mechanism
discussed here needs to be developed within the frame work of the ROD.
35. Appendix A: Disposal Area 23, Aquifer Tests l & 2: The data plots for
monitor well BW-4 show a strange behavior pattern during the pumping
period and recovery period of both tests. For the pumping periods of
approximately 600 minutes in Test 1 and 700 minutes in Test 2, a
recharge-type of event occurred. This action lasted approximately 300
to 400 minutes and was followed by a period of additional drawdown
lasting to the end of the test. Also, for each test an episode of
additional drawdown occurs at approximately 250 minutes into the
recovery period. After approximately 300 minutes, normal recovery
occurs but this is followed by another c:ycle of drawdown and
recovery. What explanation is availablt:! for this action? This
monitor well is located downgradient of DA-23 where a two-well
extraction system is proposed (refer to comment number 21).
36. Appendix A: The aquifer test data plots are provided in this appendix.
Due to professional interpretation in the data evaluation methods, it
is difficult to duplicate the determination of transmissivity and
storage coefficient. All calculations need to be included on the data
plots. This needs to be done prior to the submittal of the 95% design
document. This will allow for a review of the method employed.
Below are comments/concerns raised by the State! of North Carolina.
37. The remedial design needs to address how any air stripping tower wastes
and spent carbon will be disposed of or treated.
• -6-•
38. Section 5.2.5 Biotic Barrier Layer indicates chemical barriers will be
used to reduce the threat of burrowing animals which could disturb the
cap. Please specify in the remedial design what type of chemicals
will be used as the "chemical barriers".
39. If the disposal areas at the site contain leaking containers, the
groundwater could continue to receive contamination for an unknown
number of years. When and how will it be determined that groundwater
remediation is complete? Many years from now containers could
deteriorate and contaminants could again be released to the soil and
the groundwater. Capping of the waste would likely not prevent any
dense liquid solvents present in the buried wastes, from migrating to
groundwater.
Below are the editorial comments.
40.· Page 6, second line down: Change "The tost to be performed •.• " to read
•· T!ie test performed ......
41. Page 35, last paragraph: Change " •• ,DTW••l simultaneously a rates
similar ... " to read " ... DTW-1 simultanE!OUsly at rates similar ... ".
42. Page 39, second paragraph, first sentence, and Page 40, Table 3. 2: To
insure that there is no misunderstanding as to what concentrations
exist after air stripping, the first column under the heading Carbon
Dosage should be footnoted to highlight the fact these concentrations
were found after air stripping.
43. Page 39, second paragraph, first sentence and Page 40, Table 3.2: It
may be advisable to include another graphic in this table identifying
the initial concentrations of chemicals in the groundwater prior to
air stripping and the concentrations in the efflu·ent.
44. Page 49, third paragraph: Some table, po.asibly Table 4.3, should be
referenced in this paragraph to help th,a reader visualize what is
being stated in this paragraph.
45. Page 49, third paragraph, fifth line down: Should "DWT-1" read "DWT-2"?
46. Page 54, Section 4.2.2, second line: It would be beneficial to have all
the NRCD Administrative Codes refer.enced in this document included in
the appendix.
47. Page 61, Section 4.3.1, first paragraph: Change the language in this
paragraph to read "downgradient of the disposal areas".
48. Page 61, Section 4.3.1, first paragraph, fourth line down: Missing
comma between "(ROX and Picric Acid)" and "metals".
49. Page 97, Section 5.1.3, first paragraph, fourth line down: Remove
"based,".
• -7-•
SO. Page 106, Section 5.2.2.2, second paragraph, first line: Change "The
associated lower shall component be ... " to read "The associated lower
component shall be ... ".
51. Page 116, first line: Change "chemtroni,:s'' to "Chemtronics".
The Agency concurs with the approach that the PRPs and SEC have taken to date
on the Remedial OeSign for the Chemtronics site. As stated previously, the
submittal of a revised 30\ Conceptual Design ls not necessary. In accordance
to the UAO, Paragraph V: Order; Subparagraph D. Schedule for the Work;
Task 7., the next submission is to be the fin,,l draft (95%) design. The
95% design is to be submitted to the Agency b:, May 28, 1990.
If you have any questions on the comments abo•,e, please call me at
[phone].
Sincerely yours,
,Jrrr<rbvr-J~·
lan K. Bornholm
Remedial Project Manager
cc: Charlotte Varlashkin, NCDEHNR
Lee Crosby, NCDEHNR
John Dickinson, RCRA
Bernie Hayes, G-WTU
Doug Lair, ESD
Jane Penny, Dynamac
Bob Watson, Citizens' Watch
Winston Smith, APTMD
• _-..,..~·::0.:,s: .. ::--.l . ...., ; :\.~
1~'(,~j\~j ~ ,J) --~< . . ,,,:-:::·;.,·,.i -·· 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
Mr. Jon K. Bornholm
Remedial Project Manager
20 March 1990
U.S. Environmental Protection Agency
Region JV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Comments on the Chemtronics 30% Concept Remedial Design
Dear Mr. Bornholm:
William L. Meyer
Director
The Chemtronics 30% Concept Remedial Design has been reviewed and the
following comments are offered.
J. The Remedial Design needs to address how any air stripping tower wastes
and spent carbon will be disposed or treai:ed.
2. Section 5.2.5 Biotic Barrier Layer indicate~; chemical barriers will be used
to reduce the threat of burrowing animals which could disturb the cap.
Please specify in the Remedial Design what type of chemicals will be used
as the "chemical barriers."
3. If the disposal areas at the site contain leaking containers, the groundwater
could continue to receive contamination for an unknown number of years.
When and how will it be determined that groundwater remediation is
complete? Many years from now containers could deteriorate and
contaminants could again be released to the soil and the groundwater.
Capping of the waste would likely not prevent any dense liquid solvents,
present in the buried wastes, from migrating to groundwater.
•
Mr. Jon K. Bornholm
20 March 1990
Page 2
•
If you have any questions concerning these comments, please contact me at (919)
733-2801.
CV /acr
Sincerely,
Charlotte Varlashkin
Superfund Section
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCJ-, IV
REGION IV ttt..,;1:. ED
MEMORANDUM
DATE: FEB Z 8 1990
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 303_65 MARO 6 1990
SUPERFUND SECTION
SUBJECT: _Review and Coinment on the 30 p,3rcent Concept \Remedial
Design for the Chemtronics Sup,:rfund Site
Jo/t~o~lm FROM:
Remedial Project Manager
TO: Addressees
Attached is a copy of the above referenced document. The
Chemtronics site is located in Swannanoa, North Carolina and the
Record of Decision for the site was signe:d on April 5, 1988.
Please review and comment on this document. In order for the
Potentially Responsible Parties to meet their next deadline,
submission of the 95 percent design by May 28, 1990, it is
imperative that you submit your comments to me by March 21, 1990.
If you are unable to get your comments to me by this date, please
call me and let me know when you will be able to submit your
comments.
If you have any questions, please contact me at 347-7791.
Addressees:
Charlotte Varlashkin, NCDEHNR (3 copies)
LLee Crosby, NCDEHNR (w/o attachment)
John Dickinson~RCRA (1 Copy)
Bernie Hayes, G-WTU (3 copies)
Doug Lair, ESD (1 copy)
North Carolina File (w/o attachment)
Jane Penny, Dynamac (1 copy)
Bob Watson, Citizens' Watch (3 copies)
Winston Smith, APTMD (2 copi'es)
• .!.,I,&; .
uui!,,,,C/f.HV!t'"ir,
UNITED STATES ENVIRONMENTAL PROTECTION AGENGY r--
REGION 1v Ee '' r, 1:::~,u
345 COURTLAND STPEE~/jl:e;'RF/J
ATLANTA. GE:ORGIA 30365<. Nr, SECTION
MEMORANDUM
DATE: FE 8 1 6 19go
SUBJECT: Review and Comment on the Revised Draft Bioassay
Monitoring Plan for the ;Remedial Design/Remedial Action
at the Chemtronics Superfund Site
A ~ ~ FROM: Joi{./K. Bornholm
Remedial Project Manager
TO: Addressees
Attach is a copy of the above referenced document along with the
PRPs response to comments sent to them en December 14, 1989 and
December 20, 1989. Please review this document. If you are unable
to get your comments to me by March 9, 1990, please call me and let
me know when you will be able to submit your comments.
If you have any questions, please contact me at [phone].
Addressees:
Charlotte Varlashkin, NCDEHNR
Lee Crosby, NCDEHNR (w/o attachment)
Bernie Hayes, G-WTU
Doug Lair, ESD
North Carolina File
Bob Watson, Citizens' Watch (3 copies)
l • • UNITED ST.ATC:S ENVIRONMENTAL PROTECTION AGENCY
REGION IV
JAN % 3 1990
4WD-SFB
Mr. John F. Schultheis
Nimmo & Co.
P.O. Box 536
Swannanoa, NC 28778
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365 -~lE.tCrt:]Vtt l
JAN ~ !J 1990
SUPERFUND SECTION
RE: Response to Rationale and Causes for ExteLding Remedial Design/Remedial
Action Schedule
Dear Mr. Schultheis:
This correspondence is in response to your December 1989 Monthly Progress
Report dated January 10, 1990. This Monthly Progress Report summarized and
highlighted the accomplishments the Potential Responsible Parties (PRPs) and
their contractor made during the month of December. And more importantly,
along with this report was submitted a revised :Remedial Design/Remedial
Action (RD/RA) schedule. Accompanying the revised schedule were the PRPs'
reported causes and rationale for the delays in the schedule.
The revised schedule has been reviewed as well as the accompanying
rationale/causes for extending the schedule. The Agency concurs with
extending the schedule a period of three weeks due to the lost field work
time resulting from inclement weather. This is the amount of lost time
specified in the December Monthly Report that was attributable to inclement
weather. With respect to the need for a treatahility study on the
groundwater in the back valley due to the unexpe,cted high level of COD, it is
the Agency's opinion that the time needed to conduct this treatability study
should be absorbed into the existing time table and that no additional time
needs to be added to the schedule to accommodate· the completion of this
treatability study.
The Agency does not feel that the other causes/rationale are justifiable for
the purpose of extending the schedule. As stated above, the Agency concur's
with extending the RD/RA schedule by three (3) weeks and not the six (6)
weeks as stated in your December Monthly Progress Report.
The Agency appreciates the effort the PRPs' and ·:heir contractor are putting
forth to bring the work back in schedule. And due to the short period of
time between today and the new,. proposed submitt::!.l date for the 20 precent
design, February 27, 1990, the Agency will concur w::.th this submittal date.
• -2-•
But, please be advised that the Agency will only accept a three (3) week
delay in the submittal of the 95 percent design according to the original
schedule dated October 2, 1989. This would make the submittal date for the
95 percent design due the week of May 28, 1990,
Also, in reviewing the revised schedule as well as the original schedule,
dated October 2, 1989, it became apparent that the level of detail in these
schedules is inadequate for tracking of the ChHmtronics RD/RA project by the
Agency. Presently, the format of the schedule only allows the tracking of
major goals of the RD/RA process and not the subtasks that are site
specific. These site specific subtasks may affect equally, as the major
tasks, the timeliness of the completion of either the RD or the RA.
For example, two site specific subtasks that ne!ed to be incorporated into the
schedule are the Ground Water Characterization Scope of Work and the Bioassay
Monitoring Plan. Another subtask that should be shown in the schedule is any
treatability testing conducted or proposed.
Another modification of the schedule that would make it a more useful tool is
the addition of dates for completed tasks or subtasks. This would insure
that both the Agency and the PRPs are in agreement on the completion of a
particular task or subtask.
Finally, there is a gap in the revised schedule between days 150 and 180.
This gives the appearance that no work was done during this time frame.
Either revise the schedule to reflect the work performed during this time or
provide a written explanation as to why no work was accomplished during .this
gap.
If you have any questions on the above, please i:all me at [phone].
Sincerely yours,
t:K~ Be::lm
Remedial Project Manager
cc: Reuben Bussey, ORC
Jane Penny, Dynamac
Gordon Peterson, Sirrine
Charlotte Varlashkin, NCDEHNR
DEC 18 '89 08:41
MEMORANDUM
TO:
IBROUGH:
FROM:
SUBJECT:
DEHl"R LI BRARY' 458 P02 •
DIVISION OF ENVIRONME!\'TAL MANAGEMENT
Thursday, December 14, 1989
Lee Crosby, Chief, Supedund S,:ction
Ken EaglesorilfJ,/
Steve Tedder \'
I /
LaITy Ausleyl."'-.:)
Cherntronics Site Qraft.Bioassay :Pfai17
My staff has re.viewed the referenced dmft plan ~nd has the following comments.
l. 111ere seems to be an unnc:cessaiy arnount of stream footage that will not be properly
covered by the existing su-eam sa1T1pling plall. Several of the Liibmaries to the mosi likely
impacted streams would appar~ntly cause dilution effect,. and thus tend to underestimate actual
toxicam concemracions. I have attached a CO?Y of Sin-ine Inc. ·s map with suggested changes in
$ampling sites which would solve some of this problem. Since we arc not fru,1iliar with the ·
existing modes of entry of roxicants to the streams, i.e. any groundwater flow concerns, this
scheme may need adjustmellt acrnrdingly. The intent of the ,tudy should be to protect aquatic.:
populations in even the smallest of tributaries. Thus it is felt <1ppropriate, unless there is some
unforeseen reason not to , that sampling downsLieam of the two rribt.taries on Bee Tree Creek be
dropped. Sampling upstream of the two areas on Bee Tn:e Cr.eek should be cominned as a
possible area control source. Should this sample how•~ver prove not to meet required survival
and reproduction levels. its use as a control rnu,t be excluded and a laboratory water source used
for compa1ison with the "impacted" sites. We would re,;ommend that a laborat(Jry
dilution/contr(Jl water source be used which is indicative of m(Jst North Carolina su·eams. For
NPDES monitoring requirements we require that that water have a CaCO3 hardness betw~,:n 30-
50 mg/1 and a pH betw~~n 6.5 and 8.0 standard units.
2. There is no obvious discussion of su-eam flow consideration in the prnposed sampling
,ch<!me. \Vere the sampling to take place during high flow events, the results of toxicity analyses
could underestimme the e.ffecr of to.xicant concentrations during low flow. Wastewater
dischargers (NPDES) are pennitted for whole efflue.m ro:<icity using 7Ql0 stream flow values
and regulated accordingly. The study conducted by Sirrine should obviously include imniediate
testing to observe any current effects instream but should also add testing dming a dry, low
stream flow period to show what the worst case effects will be.
3. The first paragraph of the sampling procedme stat::s that a ,inglc gmb sample will be used
for the testing. The iast para~>Taph indicates chat sJmples will be collected for test renewals on the
third and fifth test days abo. Which statement is correct shouid be addressed.
ff renewals are planned on the third and fifth days only, thi, would be i:ontmry 10 the EPA
method cited and should be referenced as not following this protocol.
Should a single sample be used, some analysis of its stability over the seven day holding time
should be inrnrporated into the study plan.
"bEc 18 '89 08:41 DEHl·IR LI BP.ARY 468 P03 • •
4. The testing section references Horning and Webe:r (1985) as the rest protocol to be
followed. I feel that it is appropriate to change this to: U.•,ited States Environmental
Protection Agency. 1989. Shorr Term Mcthod1for Estimating the Chronic Toxicity of
EJ]luents and Receiving Waters to Freshwater Organisms.Second Edition EPA/60014-
89I001, 249 pp. which is the subsequent edition of this procedure and one ,inder which
NPDES monitoring currently operates.
I hope that these comments prove useful to your efforts. One noteworthy fa~t overall is
that Sirrine Environmental Consultants is not currently a certified biological laboratory in
the State of North Carolina, though in this application (not doing NPDES required work)
this certification is not specifically rtquired. lf I can provide you ,vith any fLmher
info1mation, please contact me at 733-2136.
Figure 1
Bioassay Sampling Locations
Z:::=::7 Z=· =-
LEGEND
Former Oisoosal
Area
Process Building
Sampling Locations
•
0 rn . n
~ OJ
,
OJ ,D
0 OJ ,,_
I\)
•··~
•
~
r
tr/ ;u
D ~
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
frr(rt C lfJV f D
Nov :Jo 198/j
:t,1'.EMORA..lllDUM
SUPERFUIVD SECTION
DATE: NOV 2 8 1S89
SUBJECT: Review and (Comment' on the Chemt:rnnics Superfund Site
Draft Bioassay Monitoring Plan :Eor the Remedial
Design/Re~Action
JJ,_ ~~ornholm FROM:
Remedial Project Manager
TO: Addressees
Attach is a copy of the above referenced document. The Chemtronics
site is located in Swannanoa, North Carolina and the Record of
Decision for the site was signed on April 5, 1988.
Please review this document. If you are unable to get your
comments to me by December 15, 1989, ·· please call me and let me know
when you will be able to submit your comme·nts.
If you have any questions, please contact me at X-7791.
Addressees:
Charlotte Varlashkin, NCDEHNR (3 copies)
Lee Crosby, NCDEHNR
Bernie Hayes, G-WTU, (3 copies)
Doug Lair, ESD (1 copy)
North Carolina File
• •
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
Mr. Jon K. Bornholm
Remedial Project Manager
22 September 1989
U.S. Environmental Protection Agency
Region IV
345 Courtland street, NE
Atlanta, GA 30365
RE: Additional Comments on the Chemtronics Site
Draft Remedial Design/Remedial Actior, Work Plan
Dear Mr. Bornholm:
William L. Meyer
Director
Enclosed are comments from the NC Division of Environmental
Management on the Chemtronics Site Draft Remedial Design/Remedial
Action Work Plan. If you have any questions concerning these
comments, please contact me at [phone].
CV/acr
Enclosure
Charlotte, Varlashkin, Hydrogeologist
Superfund Se,ction
Division of Environrnental Mt:mag~rnent
512 North Salisbury Street• Raleigh, North Carolina 27611
Ja111es C. Martin, Covernor
Willia111 \Y/. Cobey, Jr., Secretary
M E M O R A N D U M
TO:
FROM:
Bill Meyer
Paul Wilms
September 12, 1989
SUBJECT: Draft Remedial Design/Remedial Action Work Plan
Chemtronics Superfund Site
Buncombe County
R. l'aul \Y/ilms
Director
The Division has completed its review of the subject documents
and offers the following comments and recommendations.
The Air Quality Section (AQS) notes that the agency with
jurisdiction for air pollution control i.n Buncombe County is WNC
Regional Air Pollution Control. A copy of the subject draft document
has been forwarded to Mr. Ronald Boone of WNC so that he may present
any comments or recommendations directly to the Superfund Project
Manager. The AQS has no additional comments concerning this.project.
The Water Quality Section .would like to recommend that
Responsible' Party make application for a Wastewater Pretreatment
permit from the Metropolitan Sewerage District of Buncombe County, and
that the properly pretreated contaminated groundwater be discharged to
public sewers. It is further recommended that no discharge of
pretreated contaminated groundwater to sur:Eace waters of the State be
initiated.
The Groundwater Section suggests
that groundwater remediation standards
NCAC 2L standards [Classifications
Applicable to the Groundwater of North
that the applicant be advised
should be in accordance with 15
and Water Quality Standards
Carolina].
If you have any questions concerning these matters, please
advise.
cc: Perry Nelson
Steve Tedder
Lee Daniel
Roy Davis
RPW/MC/tej
Central .Files
Groundwater Section Files
P.O. llox 27687, lt1lci1;h, Nonh C1ruli11;i 27611-7687 "kkrlionc 919-733-7015
•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4WD-SFB
Mr. John F. Schultheis
Nimmo & Co.
P.O. Box 536
Swannanoa, NC 28778
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA, GEORGIA 30365
IRIECEIV!ED
SEP tl l~tl~
SUPERfUND BRANCH
Re: Approval of the Revised Kemedial De,;igu/Rt:iuedial Action Wor.}:
Plan for the Chemtronics Superfund !;ite
Dear Mr. Schultheis:
Five copies of the above refer.enced document prepared by Sirrine
Environmental Consultants (SEC) for the Potentially Responsible
Parties (PRPs) were received by the Agency on August 11, 1989 as
well as the PRPs response to EPA's comments on the draft Remedial
Design/Remedial Act. ion Wo.r.k Plan, recei v,~d August 10, 1989. The
Agency has ,:eviewed· both the t:esponses to our. comments and the
revised Remedial Design/Remedial Action Work Plan and find them
accept.able. This is the Agency's notification to the PRPs to
proceed with Remedial Design activities.
If you have any quest.ions, I can be contacted at [phone].
Sincerely yours,
t:.!::o~
Super.fund Project Manager.
cc: Lee Cr.osby, NCDHR
Bill Hamner., NCDHR
Don Link, NCDNRCD
Gordon Peter.son, SEC
Jennie Rominger., Clean Wat.er. Fund of North Car.olina
Char.latte Var.lashkin, NCDHR
Bob Watson, President of Citizen's Watch
•
• "' --s SEif 21 1989 ~I ~ '-" ... , i 7~ _,~$
State of North Carolina • ~"•IANA~
Department of Natural Resources and Community D@velopment --
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
J11ncs C. Martin, Governor
\\1/illia111 \Y/. Cobey, Jr., Secretary
M E M O R A N D U M
TO:
FROM:
Bill Meyer
Paul Wilms
September 12, 1989
SUBJECT: Draft Remedial Design/Remedial Action Work Plan Chemtronics Superfund Site
Buncombe County
R. Paul \\1/ilms
Director
The Division has completed its review of the subject documents and offers the following comments and recommendations.
The Air Quality Section (AQS) no·tes that the agency with jurisdiction for air pollution control in Buncombe County is WNC Regional Air Pollution Control. A copy of the subject draft document has been forwarded to Mr. Ronald Boone of,WNC so that he may present any comments or recommendations directly to the Superfund Project Manager. The AQS has no additional comments concerning this project.
The Water Quality Section would like to recommend that Responsible Party make application for a Wastewater Pretreatment permit from the Metropolitan Sewerage District of Buncombe County, and that the properly pretreated contaminated crroundwater be discharged to public sewers. It is further recommended that no discharge of pretreated contaminated groundwater to surface waters of the State be initiated.
The Groundwater Section suggests
that groundwater remediation standards
NCAC 2L standards [Classifications
Applicable to the Groundwater of North
that the applicant be advised
should be in accordance with 15
and Water Quality Standards
Carolina).
If you have any questions concerning these matters, please advise.
cc: Perry Nelson
Steve Tedder
Lee Daniel
Roy Davis
RPW/MC/tej
Central Files
Groundwater Section Files
1'.0 Box 27687, Raleigh, North C-1mlina 27611-7687 "Ji:lcrhonc 919-733-70!5
A11 Fqual (")pp(irtt1nity i\flinnativc Acti(lll Ernr,lciycr
•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
AUG O I 1G63
4WD-SFB
345 COURTLAND STREET. N.E
ATLANTA. GEORG!A 30365
.'-J,Uti I 1989 Mr, John F. Schultheis
Nimmo & Co.
P.O. Box 536
Swannanoa, NC 28778
SUPERFUND BRANCH
Re: Additional Comments on the Draft Groundwater Characterization Scope of
Work Section of the Remedial Design/Remedial Action Work Plan for the
Chemtronics Superfund Site
Dear Mr, Schultheis:
Enclosed are two additional sets of comments on the above referenced document
prepared by Sirrine Environmental Consultants (SEG) for the Potentially
Responsible Parties (PRPs). All of the following comments pertaining to the
draft Groundwater Characterization Scope of Work need to be addressed in the
revised Groundwater Characterization Scope of Work, This can be accomplished
by either incorporating the requested change into the text of the revised
work plan or by a written explanation as to why t:,e PRPs do not feel the
comment is appropriate or warranted. As stated b,,fore, the revised Ground
Water Characterization Scope of Work should be submitted to the Agency for
approval as soon as possible,
The Agency is willing to meet and discuss with the
the identified deficiencie~ or requested changes,
I can be contacted at [phone],
Sincerely yours,
Jon K, Bornholm
Superfund Project Manager
Enclosures
cc: Charles Case, Chemtronics
PRPs and Sirrine any of
If you have any questions,
John Creighton, Buncombe County Environmental. Affairs Board
Lee Crosby, NCDHR
Bill Hamner, NCDHR
David Hunter, Hoechst-Celanese
Don Link, NCDNRCD
I
• •
Gordon Peterson, Sirrine
Jennie Rominger, Clean Water Fund of North Carolina
Gary Rowan, Hoechst-Celanese
Gary Serio, Northrop
Charlotte Varlashkin, NCDHR
Bob Watson, President of Citizen's Watch
Tony Young, Northrop
• •
North Carolina Department of Human Resources
Division of Health Servic,is
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.
July 20, 1989
Mr. James H. Scarbrough, P.E., Chief
RCRA Branch
Waste Management Division
US EPA, Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Attention: Mr. John E. Dickinson
Reference: Jet Research Center
Draft Ground Water Characterization ·scopH
of Work Section
NCD095459392
Dear Mr. Scarbrough:
State Health Director
CPA -REGION IV
A T!..~!':T.,, GA.
Enclosed is a copy of the draft comments on Jet Rese,arch Center's (Chemtronics)
"Ground Water Characterization Scope of Work Section" in the Remedial Design/
Remedial Action Work Plan for the Chemtronics Superfund site.
If you have any questions concerning the comments concerning Jet Research Center,
please contact Robert McDaniel at [phone].
~~ye. &c; ~
Yerome H. Rhodes, Head
Hazardous Waste Branch
JHR/RCM/mb/0141-101
Enclosure
cc: William F. Hamner
James A. Carter
Sharon A. Myers
D. Keith Masters
Robert C. McDaniel
•
Comments on the Ground Water Characterization Scope of Work Section of the Draft
Remedial Design/Remedial Action Work Plan for Chemtronics
Section 2.0 -Test Well Construction
1. Chemtronics should describe which method (including the assumptions inherent
in the method) is anticipated to be used to analyze the data collected during
the pumping test.
2. Chemtronics should include a topographic map indicating the location of the
pumping well in relation to the observation wells.
3. Discuss the reasons for a seven ( 7) foot lonq well foot placed in the deep
wells.
4. Chemtronics must provide well schematics and well completion reports
(DHS-3342) for each pumping well and observati-:m well (Attachment 1).
5. If the well screen is placed directly above a grout plug, the possibility of
grout contamination affecting the ground water samples collected for analysis
is greatly increased and the integrity of the well could be questioned. The
well screen should be placed at the bottom of the bore hole.
6. The bentonite seal must be allowed to fully hydrate prior to the placement of
grout in the annular space.
7. Provide a discussion why black steel casing in proposed for the shallow well
to be installed at DA-23. Inorganic constitue,nts may be introduced into the
water samples collected in the wells construct.ad of black steel.
Section 3.0 -Aquifer Test Program
1. Describe which method is anticipated to be used to analyze the pumping test
data.
2. Will a control well be used to measure the eff,acts of varying barometric
pressures, rainfall, or any other influences which may affect the ground
water elevations?
Section 3.3 -Ground Water Sampling and Analysis
1. Ground water collected during the pumping test will probably not be
representative of the aquifer. There will be a loss of volatile organic
compounds in the process of pumping, transpor<:ing and collecting the ground
water.
2. Chemtronics must describe, in detail, the sampling and analysis plan,
including the following:
Description of sampling/analysis procedures.
-Equipment used to collect samples.
-Equipment cleaning procedures.
-Ground water sampling procedures.
-Description of the sample collection procedui:e.
-Sample identification and shipment.
-Chain of custody.
-Analytical methods.
3.
•
'l'he concentration of volatile organics, in
sample, will be of concern if an air stripper
ground water. It would be necessary to
contaminated ground water to the air stripper.
General Comments:
a representative ground water
is to be employed to treat the
determine the flow rate of
1. The information collected during the ground water characterization at the
biolagoon (in DA-23) should be compatible with RCRA standards so that it can
be used to develop the aquifer characterizaL,on at the RCRA unit for the
post-closure permit application.
2. The closure of the biolagoon, the RCRA unit in DA-23, must not be compromised
by ongoing activities in the biolagoon area.
7/19/89
RCM/mb/0141-99-100
•
ATTACHMENT I
•
TYPICAL MONITORING WELL SCHEMATIC
COPY OF WELL COMPLETION REPORT (DHS 3342)
SUBMITTED TO THE HAZARDOUS WASTE BRANCH UPON
COMPLETION OF MONITORING WELL
VENTED CAP
(PVC. STAINLESS STEEL OR
I 1/4" x I l/4" X 2" ANGLE
MINIMU.M 2-INCH (O.D.)
SCHEDULE 40 PVC.
·::::·
STAINLESS STEEL OR TEFLOf'r'"---
THREADED COUPLING
MUST BE.USED.
AVOID USE OF SOLVENTS.
FILTER PACK SHOULD EXTEND
NO MORE THAN TWO FEET
ABOVE THE SCREEN
WELL SCREEN
(SLOTTED SCHEDULE 40 PV .
STAINLESS STEEL OR TEFLON)
END CAP
(PVC, STAINLESS
STEEL OR TEFLON)
STEEL ·:ASING WITH CAP AND LOCK
-VENT HOLES
...... :::::::::::·
'-------· CONCRETE COLLAR EXTENDING
AT LEAST 3.0 FEET BELOW
GROUND SURFACE
-GROUT BACKFILL
1.0 FOOT SEAL OF
BENTONITE PELLETS
THE BENTONITE PELLETS SHOULD BE
ALLOWED TO HYDRATE PRIOR TO
---PLACING GROUT IN
THE ANNULAR SPACE.
S,>.ND
BACKFILL (NC #2 5)
SCR ES ,.J
I f'JTER\/Al
• N. C. Oeparrment of Human Resc,urces
Division of Health Services! •
WELL COMPLETION RECORD
.fLETE ALL lNFORMA TION REQUESTED BELOW FOR EACH WELL INSTALLED, AND RETURN FORM TO THE N.C.
/ARTMENT OF HUMAN RESOURCES, SOLID AND HAZARDOUS WASTE MANAGEMENT BRANCH. ,· /o. BOX 2091, RALEIGH, N.C. 27602
I
NAME OF SITE:
ADDRESS:
DRILLING CONTRACTOR:
Casing Type,
Casing Depth:
Screen Type:
Screen Depth:
from
from
dia. __ in.
to ft. -dia. __ in.
dia. __ in.
to ft. -dia. __ in.
Static Water Level: _______ feet from top of casing
PERMIT NO.:
OWNER (print):
REGISTRATION NO.:
Grout Depth: from to ft. -dia. __ in.
Bentonite Seal: from to ft. -dia. __ in.
Sand/Gravel PK: from to ft. -dia. __ in.
Total Well Depth: from to ft. -dia. __ in.
Date·Measured __ / __ / __
Yield (gpm): ____ Method of Testing: ---------------Casing is ____ feet above land surface
DRILLING LOG LOCATION SKETCH
DEPTH (show distance to numbered roads, or other map reference points)
FROM TO FORMATION DESCRIPTION
REMARKS: --------------------------------------
f)ATE: _______ _ SIGNATURE: ---------------------------
Purpose:
Preparation:
Distribution:
Disposition:
•
Permits issued for operation of a sanitary landfill require the installation of groundwater qualiry
monitoring wells. Upon completion of insrallation, a re,:ord of each well must be completed.
The owner/operator of the sanitary landfill is responsibi.e for completing the well record. The
owner/operator must sign the record.
Original to: Solid & Hazardous Waste Management Bi:anch
Division of Health Services
P. 0. Box 2091
Raleigh, NC 27602-2091
This form may be destroyed in accordance with Standard 7, Inspection Records, of the RecOTds
Disposition Schedule published by the North Carolina Division of Archives and History.
Order additional forms from: Solid & Hazardous Waste Manag,,ment Branch
Division of Health Services
P. 0. Box 2091
Raleigh, NC 27602-2091
. ,_ .:..
• u ENVIRONMENTAL PROTECTJ.AGE
REGION IV, ATHENS, GEol ~
MEMORANDUM
DATE: JUL 2 7 1989
SUBJECT: Comments on the Draft Ground Water Characterization Scope of Work,
Chemtronics Superfund Site, Swannanoa, NC, ESD Project Number 89E-346.
FROM:
TO:
THRU:
Donald R. Hunter, Hydrogeologist ,{k~t/ l?;.}u;::t:::::,,
Hazardous Waste Section
Environmental Compliance Branch
Environmental Services Division
Jon K. Bornholm,
Superfund Branch
Waste Management
M. D. Lair, Chief
Superfund Project ManaE;er
Division
Hazardous Waste Section
Environmental Compliance Branch
Environmental Services Division
The subject document has been reviewed as requested and the follo~ing comments
are offered. These comments are referenced to th,, appropriate page and section
numbers of the document.
Comment
Number
1
2
Comment
p. 2/Sec. 2. 0 Test Well Construction -Decontamination or
cleaning of well construction materials is not addressed in
this document, either directly or by reference to procedures
found in other documents. Even though the primary purpose of
these wells is for the extraction of water for pump test
purposes, they will also be us,,d for ground-water sampling.
Any wells installed that will be used for sampling, must be
constructed of screen and riser that has been cleaned according
to ESD standards, as specified in the SOP.
Accordingly, drill rigs used fo;~ installation of these wells
should be properly cleaned prior to arrival on site and between
each hole. A copy of these rig cleaning procedures is
attached.
p. 3/Sec. 2.0 Test Well Construction -There is no statement
indicating that the combination saprolite/bedrock well will
be developed, as is planned for the saprolite well. Before
the saprolite interval can be used for either chemical sampling
or formation characteristic testing, the sand pack and
disturbed formation material adjacent to this interval should
be developed to remove fines from the sand pack and restore
saprolite characteristics. The auger flights could have
smeared the walls of the borehole and reduced the hydraulic
• - 2 -
3
4
conductivity. Development procedures should be specified.
Development of the screened portion of the deep well will not
be straightforward, and will re0_uire special methodology, such
as packers to isolate it from the open borehole below.
p. 7 /Sec. 3. 0 Aquifer Test Po:ogram -No apparent serious
deficiencies were detected in a cursory review of this section.
p. 7/Sec. 3.3 Ground Water Sampling and Analysis -ESD
recognizes that the construction materials for the pump test
wells are not as we would normally specify for monitoring well
construction. Analyses of samples collected from these wells,
however, should be closely compared to existing and
concurrently gathered data for r,earby monitoring wells to help
ensure that no false negative data for treatment study
sensitive parameters result from well construction or sampling
procedures.
Please contact me if you have any questions regarding these comments. I can be
reached at ITS 250-3351.
Attachment
cc: Finger/Patton
Lair/Bokey
Knight
• REGION IV ESD
DRILL RIG AND EQUIPMENT DECONTAMINATION PROCEDURES
Normally, any portion of the drill rig, backhoe, etc. that is over the borehole (Kelly bar, mast, backhoe buckets, drilling platform, hoist or chain pulldowns and/or cathead, etc.) must be steam ,:leaned and wire brushed before being brought on site to remove all rust, soil and other material which may have come from other sites. The drill rig should then be inspected to insure that all oil, grease, hydraulic fluid, etc. ha:; been removed, all seals and gaskets are intact and no fluids are leaking. Steam cleaning of the drill rig is then required prior to drilling each bocehole. In addition, all downhole drilling, sampling, and associated equipment that will come into contact with the downhole equipment and sample medium shall be decontaminated by the following procedure, as specified in the Region IV ESBSOP/OAM, April 1, 1986.
1. Clean with tap water and laboratory grade detergent, using a brush, if necessary, to remove parti.culate matter and surface films. Steam cleaning may be necessary to remove matter that is difficult to remove s•ith the brush.
2. Rinse thoroughly with tap water.
3. Rinse thoroughly with deionized water.
4. Rinse twice with solvent (pesticide grade isopropanol).
5. Rinse thoroughly with organic-free water and allow to air dry as long as possible. If organic-free water is not available, allow the equipment to air dry as long as possible. Do not rinse with deionized or distilled water.
~OTE: Organic-free water can be processed on site by p\lrchasing or leasing a mobile deionization-organic
filtration system.
NOTE: Tap water may be applied with a pump sprayer. All other decontamination liquids (D. I. ••ater, organic-free
water, and solvents), however, must be applied using non-interfering containers. These c,mtainers will be made of glass, Teflon, or stainless steel. No plastic containers or pump sprayers will be allowed.
6. Wrap with aluminum foil, if appropriate, to prevent contamination if equipment is going to be stored or transported. Clean plastic can be u,;ed to wrap augers, drill stems, casings, etc. if they have been air dried.
7. As previously stated, all downhole augering, drilling and sampling equipment shall be sandblasted before Step #l if there is a buildup of rust, hard or c:aked matter and/or painted equipment. All sandblasting shall be performed prior to arrival on site.
• -

2

-
NOTE: ~ell caslng and screen, as well as tremle tubing, shall be cleaned according to these procedur,as. Prior to cleanlng, however, lt may be necessary to sand ocf prlntlng lnks, if present, on these materlals. If any of these materials are of PVC construction, the solvent rinse st,,p should be omitted.
If any sampling equlpment, such as split-spoons, are used to collect samples that contain oil, grease, or 01:her hard-to-remove materials, it may be necessary to rinse the equipment several times with pestklde grade acetone or hexane to remove the materials before proceeding wlth the prevlously described decontamination procedures. Any sampling equipment that cannot be cleaned using these procedures should be discarded.
Decontamlnation of all equipment should occur at a decontamination pit, excavated either by backhoe or other means. The pit and surrounding area should be lined with heavy-dut:y plastic film and should be designed to promote run-off of decont:amination waste into .the pit. An above ground pit comprised of plastic shpPtlng bermed with soil, timbers, or other material may be adequate for small jobs. All cleaning of drill rod, auger flights, well screen and casing, etc., will be conducted above the plastic film using saw horses or other appropriate means.
Solvent.rinsates should not be placed in the..J2.ll. All solvent rinsates should be collected in separate containers for proper disposal.
At the completion of drilling activities, the pit should be filled, but only after it has been sampled to determine if the contained water and sediment need to be disposed off site.
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
4WD-SFB
Mr. John F. Schultheis
Nimmo & Co.
P.O. Box 536
Swannanoa, NC 28778
345 COURTLAND STREET. r-LE. oe1cE''1EO
ATLANTA. GEORGIA 303613 \f\~ I
J\Jl O 1 \989
SUPERH}ND BRANCH
Re:CCo=ents on the'.Draft Groundwater CharacterizatJ.on Scope of Work Section
of the Remedial Design/Remedial Action Work Plan for the Chemtronics
Superfund Site
Dear Mr. Schultheis:
Five copies of the above referenced document prepared by Sirrine
Environmental Consultants (SEC) for the Potentially Responsible Parties
(PRPs) were received by the Agency on July 7, 1988. As part of Superfund's
review process, copies of these documents were tranBmitted to various
programs within the Agency, to the North Carolina Departments of Human
Resources (NCDHR) and Natural Resources & Community Development (NCDNRCD),
EPA's TES VIII contractor as well as to several entities in the private
sector in the Swannanoa Community for review and comments.
The development of this document was necessitated b:; the need of additional
hydrogeologic data to complete the Remedial Design •:RD) and implement the
Remedial Action (RA) at the Chemtronics site. As wlth the review comments on
the draft RD/RA Work Plan, all of the following comments pertaining to draft
Groundwater Characterization Scope of Work need to ·oe addressed in the
revised Groundwater Characterization Scope of Work. This can be accomplished
by either incorporating the requested change into the text of the revised
work plan or by a written explanation as to why the PRPs do not feel the
comment is appropriate or warranted. The revised Ground Water
Characterization Scope of Work should be submitted to the Agency for approval
as soon as possible.
The comments are organized into two\ategories: general and specific. The
specific comments are listed as they appear in the text of the draft Ground
Water Characterization Scope of Work. Again, all comments and requested
changes stated below need to be addressed.
General Comments
1. An explanation of the location of the proposed wells in terms of
lithology needs to be included. This information will help to
determine whether pumping and air lifting is the best method for well
development.
• •
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2, Some language should be included stating that well construction permits
will be obtained from North Carolina Department of Natural resources &
Community Development prior to the installation of the proposed wells.
3, The design of the proposed pump tests does not incorporate the impact of
the local geology on groundwater hydraulics, The geologic formations
present at the site are characterized as aquifers with
three-dimensional anisotropic parameters that are not accounted for in
the design of the pump tests. Therefore, the proposed GCSOW may not
characterize the aquifer anisotropy present at the site.
4, As reported in the remedial investigation (RI) report prepared by Metcalf
& Eddy (M&E), the site is underlain predominan,tly by biotite gneiss
(bedrock) and saprolite derived from the biotite 8neiss, These
materials have a foliation trending N25° E to N45 E with a dip of
25° to 65° to the northwest. Anisotropic aqul.fer conditions exist
due to the foliation and the jointing preserved in the saprolite and
bedrock, The jointing exists predominantly suhparallel to parallel to
the trend of the foliation with dips intersecting the foliation dip,
Jointing is also developed roughly perpendicular to the foliation and
trends N25° to 65° W with dips of 20° to 70° NE, ·
Aquifer pump tests should be designed and conducted in order to
quantify the distortion of the cone of depres,;ion caused by the
heterogenous and anisotropic aquifer conditions. The foliation and
joint of the site geology should be accounted for in the pump test
design. Observation wells need to be oriented in relation to the
foliation, i.e., located both parallel and pe:cpendicular to foliation
in order to determine the variation of the aquifer transmissivity and
to quantify the anisotropy, Anisotropic effe,cts were noted in the pump
tests conducted during the RI from which M&E determined that the
surficial and bedrock aquifers were interconnected,
Consideration should be given to the natural :nydraulic gradient in
designing the pump tests, Based upon the potentiometric map in the RI,
the hydraulic gradient of the surficial aquif9r is quite steep
(approximately 0,0875 at Site #1, 0,0625 at Site #2), The effect 0£
the steep natural gradient upon the pump test is a narrow zone of
capture; the zone of capture (see Keely and Tsang, 1983; Keely, 1984)
is that portion of the aquifer which actually yields water to the
well, The.steeper the hydrau~c gradient, the more the cone of
depression becomes distended irtto an elliptical cross-sectional shape.
Optimally, two wells should be located upgradient and two wells
downgradient, but given the steep hydraulic gradient, more observations
wells may need to be located upgradient and downgradient, as well as
perpendicular, to the groundwater flow in order to accurately
characterize the aquifer anisotropy. Therefore, a minimum of eight
observation wells should be used to characterize the aquifer
0 0 anisotropy; four located parallel (N20 to 45 E) to the foliation
and four located perpendicular (N25° to 60° W) to the foliation,
• •
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The 40-to SO-foot distances between the pumping wells and the first
observation well may be too great for the aquifer conditions, ,
Observation well spacing from the pumping well should be defined and
located on a suitably scaled sit.e map,
5. Evaluation of the previously installed monitoring wells for use as
observation well locations was not possible due to the lack of a
suitably scaled well location map, Also lacking from the GCSOW was
well installation and completion information, fc,r the existing
observation wells, such as well diameters, scre,ening intervals,
lithologies and split-spoon blow counts, slug/recovery test
information, water level in each well, and relation to potentiometric
surface.
6. Ideally, to characterize the aquifer anisotropy during the deep pump
tests, two sets of observation wells, one set screened in the shallow
to intermediate depth saprolite and one set screened in the same zone
as the deep pumping wells, should be employed, Each set.of observation
wells should be located parallel and perpendicular to the foliation, as
previously described above. This strategy is not discussed by SEC,
7. All test wells should be constructed in accordance with Region IV
Engineering Support Branch Standard Operating Procedures Quality
Assurance Manual (ESD SOPQAM). All casing and :;creen should be
thoroughly steam-cleaned prior to well construccion; all paint and dye
should be removed from the casing and screen. In addition, all
drilling equipment to be used either over or in the borehole should be
free of paint or foreign material, i.e., grease and mud.
8, Stainless steel casing would be the preferred material of well
construction based upon the contaminants of concern and the ESD
SOPQAM, Justification is required for SEC' s proposed use of carbon
steel casing as part of the pumping well construction.
9, SEC has specified that prior to installation of the casing and screen,
the samples taken by split spoon sampling device.swill need to be
sieved to determine the screen slot and gravel pack size, This needs
to be explained with consideration given to:
Amount of time to turn-around grain-size analyses;
Method/contingency for keei1'\ng hole open while awaiting
screen and gravel pack determination and procurement,
10, In drilling the two deep test wells, SEC specified that hollow stem
augers will be used to drill through the saprol.lte until reaching
depth of auger refusal. The GCSOW states that ·bedrock will be drilled
using roller-cone bit and mud rotary techniques. Specify if other
options for drilling the bedrock have been considered (i.e., air
rotary, dual-cased or triple-cased reverse air)., Drilling with
bentonite mud should be considered as a last re,;ort, given the
possible permeability damage to fractures and mi.crofractures by the
development of wall cake.
• •
-4-
11. If drilling mud is to be used, a sample should be collected for
analysis, per Region IV ESD S0PQAM.
12. Following installation of the casing/screen string, the bentonite seal
must be allowed to hydrate a minimum of eight hours or as per the
manufacturers' specifications, whichever is greater (ESD S0PQAM).
13. Following installation of the casing, SEC has proposed that 4-inch
diameter, flush-threaded PVC temporary casing; be used essentially as a
protective sleeve inside the casing string tc, protect the screen and
prevent wobbing of drilling tools while coring bedrock:
Since this well will be used for obtal.ning
groundwater samples, specify if another
material has been considered rather than PVC.
PVC will be gouged and scraped by the drill
bit and drill string, contributing PVC
shavings. These shavings will need to be
eliminated due to their potential
contribution of contaminants, in particular
phthalates ( the RI report mentions ph,:halate
contamination to groundwater samples, which
were unexplainable).
PVC is relatively light; therefore, the drill
string may cause "whipping" of the end and/or
middle of the temporary casing.
If PVC casing is used, shattering of the PVC
may occur to the point o~ losing a portion of
the temporary casing downhole.
Specific Comments
14. Page 2, Section 2.0: Figures need to be provi.ded to show t!,e proposed
locations of the test wells. The Agency requests that these figures
include test well locations as well as the locations of the existing
monitoring wells to be utilized as piezomete:rs during pumping tests.
15. Page 2, Section 2.0: The prop1ed design of the deep test wells will
lead to a reduction in well efficieney due to the effects of partial
penetration. The partial penetration condition resulting from the
segment of easing located between the open bedrock interval and the
screened interval within the saprolite will create vertical flow
gradients in the vicinity of the well. Thill will cause additional
drawdown in the pumped well due to well los,;es. Therefore, the
efficiency of the well will decrease. In order to eliminate this
potential concern, the Agency strongly advi:;es that the wells be
designed as follows:
16.
17.
18.
19.
20.
21.
• •
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Set a minimum 25-foot length of screen from
the top of the competent bedrock up through
the weathered zone and into the saprolite.
The screen slot size should be selected
based on the finest aquifer material within
the screened interval as determined through
a sieve analysis.
Use an open hole for the competent bedrock
as proposed in the Scope of Work.
Page 3, third paragraph: The HQ coring techniques needs to be either
referenced or explained in greater detailed. Specify if coring will
provide a scribed and oriented core as this will allow the core
fractures to be count and oriented.
Page 3, third paragraph: What method will be used to remove cuttings
from the borehole and how will the cuttings be transmitted to the
surface, i.e., inside the temporary casing or in the annular space.
Page 4, first paragraph: The development of the shallow well is
discussed but not the two deep wells. Has the development of the two
deep wells been omitted?
Page 4, second paragraph: Explain what criteria will be utilized in
choosing ''selected'' split spoon samples for grain size analysis as the
saprolite may have variations in the clay content due to the effects
of weathering,
Page 4, second paragraph: The text states that the final screen slot
size and sand pack selections fqr all three ,,ells will be determined
on these analyses. Specify if screen size and gravel pack for all
three wells will be based on the aforementioned ''selected'' split-spoon
samples (Comment 24), Specify if the "selected" split-spoon samples
will come from only the first well drilled, or will all holes be left
open for samples to be taken through hollow stem ·auger drilling.
Include any grainsize analysis from the RI which would ai.l"w
interpretation of uniformity of grain-size with depth and in Site Ill
and Site #2.
Page 5, first paragraph: The ti,est states estimates values of
transmissivity (T), storage coefficient (S), and specific capacity
were estimated. These values were estimated from hydraulic
conductivity data obtained during the RI. Specify and/or reference
the method(s) used to determine hydraulic conductivity data obtained
during the RI. Specify if ".previously estimated" refers to M&E or
SEC, and if the hydraulic conductivity data was measured or
estimated. If hydraulic conductivity was estimated on the basis of
grainsize, uniformity coefficient, and density (split spoon blow
count), then the 050 Grain Size would be known for potential use in
gravel pack and screen sizing.
• •
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22. Page 5, second paragraph: SEC anticipates that the flow rate for the
deep wells will be 3 to 6 gallons per minute (gpm) and 1 to 2 gallons
per minute (gpm) for the shallow well. Because of the significantly
lower estimated transmissivity at Site U2 (as compared to Site #1, 52
gallons per day (gpd)/ft compared to 130 gallons per day (gpd)/ft,
respectively), more time may be required to dewater the formations.
The variation in transmissivity may also need to be factored into test
well spacing. Also needing to be factored into amount of time and
rate of pumping for well testing is the presence of fractures in the
bedrock. According to the RI, permeability of the fractures in·
portions of the bedrock aquifer varies by ove1: four orders of
magnitude across the site (p. 3-31). Pumping rates used during the RI
were generally less than 1.0 gpm. Are the proposed higher pumping
rates feasible? And if so, will they allow noticeable drawdown at
distances without drying well?
23. Page 5: The values for the storage coefficient range from values
indicative of unconfined aquifers (0.2) to values indicative of
confined aquifers (0.0001). Describe the type of aquifer that is
present at the Chemtronics site and either provide the derivation or
reference of these values.
24. Page 5, Section 3.1: Specific capacity is an estimate of the
productivity of a well. It is defined as the ci.ischarge divided by the
drawdown. The drawdown as measured in a production well is a
combination of the drawdown in the formation adjacent to the well and
the drawdown due to well losses created by turbulent flow through the
well screen and pump intake. Therefore, the specific capacity is
effected by the design of the well and can vary from well to well
within an aquifer. No indication is given in the text as to how the
values of specific capacity presented in this section were
determined. If these numbers are theoretical in nature, then they can
be used to determine the efficiency of the production wells following
the step-drawdown tests. However, the specific capacity values
determined through the step-drawdown tests should be used to determine
the discharge rates for the pumping tests.
25. Page 5, Section 3.2: There are reservations as to whether an adequate
cone of depression in the saprolite can be gener,ited by pumping the
deep wells at rates of 3 to 6 gallons per minute.
26. Page 6, Section 3.2: No indica\ion is given in th<! text as to the time
period between the completion of the step-drawdo,m tests and the
beginning of the pumping tests. The aquifer should be permitted to
return to static conditions prior to beginning the collection of
pre-test trend data. The work plan needs to specify the length of the
time between the step drawdown test and the pump test or some other
language that will insure that static conditions have returned prior
to initiating the pump tests.
• •
-7-
27. Page 6, second paragraph: Please specify where in the water column of
the well will the submersible pump be located during the aquifer
tests.
28.
29.
30.
31.
32.
33.
Page 6, fifth paragraph: Pumping test should be a minimum of 24 hours
in duration. If steady-state conditions are not obtained during the
test, the pumping should continue until conditions become constant.
Page 7, first paragraph: The test states recovery measurements will be
made in outlying wells for a period of 12 hours. In wells equipped
with pressure transducers, water level measurements will be recorded
for the full recovery period of 24 hours or until no appreciable
change is being recorded. Outlying wells are of importance in that
the drawdown measurements will be used to determine the degree of
anisotropy. State what methods will be used to measure water levels
in the outlying wells and whether the frequency of measurements
differ. Recovery (and drawdown) measurements in outlying observation
wells should also be conducted until no appreciable change is noted;
recovery in transducer-equipped wells should be monitored until no
appreciable change is observed, since the full recovery period may be
longer than 24 hours.
Page 7 second paragraph: The test states that drawdown data may be
obtained in additional monitoring wells if the radius of influence is
greater than anticipated. The radius of influence will not be of
constant length about the pumping test well; the "radius" will be
shortest in the downgradient (hydraulic:) direction. The "radius" of
influence will be longer in the upgradient direction. The "radius" of
influence will also be effected by the aquifer's foliation and the
presence/development of fractures. The preferentiality of the
groundwater flow toward the pumping well must be accounted for by SEC
in order to provide data necessary to finalize extraction well
locations, well density, and quantify total design flow rates.
Therefore, additional observation wells (piezometers) made need to be
installed.
Page 7, third paragraph: The work plan should .;tate when and how many
discrete sets of "grab" samples will be colle,:ted and if samples will
be taken from each of the three pumping wells.
Page 7, third paragraph: Speci~y if the analys,as for chromium are for
total chromium, hexavalent chrbmium, or both. Samples for hexavalent
chromium need to be+gnalyzed within the 24-hour as 24 hours is the
holding time for Cr •
Page 8, Section 4.0: The summary report is to :lnclude projected capture
zones and design recommendations. The method,; used to determine the
projected capture zones and extraction well d,asign need be
doc.umented. The software used to model groundwater flow needs to be
specified, as well as any other type of data analysis software or
assumptions made in the modeling.
• -8-
The Agency is willing to meet and discuss with the
the identified deficiencies or requested changes.
I can be contacted at [phone].
Sincerely yours,
t~. ~0::---
Superfund Project Manager
Enclosure
cc: Charles Case, Chemtronics
•
PRPs and Sirrine any of
If you have any questions,
John Creighton, Buncombe County Environmental Affairs Board
Lee Crosby, NCDHR
Bill Hamner, NCDHR
David Hunter, Hoechst-Celanese
Don Link, NCDNRCD
Jennie Rominger, Clean Water Fund of North Carolina
Gary Rowan, Hoechst-Celanese
Gary Serio, Northrop
Charlotte Varlashkin, NCDHR
Bob Watson, President of Citizen's Watch
Tony Young, Northrop
\
Keely, J.F. 1984.
Remedial Actions.
• •
References
Optimizing Pumping Strategies fo:~ Contaminant Studies and
Ground Water Monitoring Review, 'l. 4, No. 3. pp 63-74.
Keely, J.F. and C.F. Tsang 1983. Velocity Plots and Capture Zones of Pumping
Centers for Ground Water Investigations. Ground Water, V. 21, No. 6, pp
701714.
\
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.
Mr. Jon K. Bornholm
Remedial Project Manager
26 July 1989
U.S. Environmental Protection Agency
Region IV
345 Courtland street, N.E.
Atlanta, GA 30365
State Health Director
RE: Chemtronics Draft Groundwater Characterization Scope
of Work for the Remedial Design/Remedial Action Work Plan
Dear Mr. Bornholm:
The Chemtronics site Groundwater Characterization Scope of
Work for the Remedial Design/Remedial Action Work Plan has been
reviewed.· Comments from the North Carolina Solid Waste
Management Section are attached. The State may have additional
comments at a later date.
If you have any questions, please contact me at (919)
733-2801.
CV/acr
Sincerely, ((✓,~~~-
Charlotte Varlashkin, Hydrogeologist
Superfund Branch
Superfund Branch
Chemtronics Site
26 July 1989
Comments on the Groundwater Characterization Scope of Work
Section of the Draft Remedial Design/Remedial Action Work Plan
for Chemtronics ·
Section 1.0 -Introduction
One test well is to be installed
the acid pit, DA7/8 and DA9. DA6
DA 7 / 8 and DA9 by Gregg Branch.
necessary in the area of DA6.
near DA23 and one near
is separated from areas
A test well may be
Section 3.3 -Groundwater Sampling and Analysis
Samples should be analyzed for all the contaminants
present at the site during the groundwater
characterization (i.e. extractable organics, PCBs, and
cyanide among other contaminants).
General Comments
Permits for pilot study activities are not discussed.
Permits may be necessary for off-site discharge of
extracted water. Pilot study activities should be
designed to allow substantive compliance with local,
state, and federal permit requirements.
., • •
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.
MEMORANDUM
TO:
FROM:
Lee Crosby, Head
Superfund Branch
July 20, 1989
Jerome H. Rhodes, Hea~
Hazardous Waste Branch
REFERENCE: Chemtronics
. Draft Ground Water Characterization Scope
of Work Section
Swannanoa, North Carolina
State Health Director
Enclosed is a copy of the draft comments on Chemtroni-cs' "Ground Water Characteri-
zation Scope of Work Section" in the Remedial Design/::l.emedial Action Work Plan for
the Chemtronics Superfund site. Please incorporate t;1ese comments with any comments
you may have regarding this work plan.
If you have any questions concerning the comments on the Chemtronics work plan,
please contact Rob McDaniel at extension 150.
JHR/RCM/mb/0141-108
cc: William F. Hamner
James A. Carter
Robert C. McDaniel
.. • • ID) ITIMPTI,l
Comments on the Ground Waler Characterization Scope of Work Section of the Draft
Remedial Des.ign/Remedia.l Action Work Plan for Chemlronics
Section 2.0 -Test Well Construction
l. Chemlronics should describe _which method ( including the assumptions inherent
in the method) is anticipated to be used to analyze the data collected during
the pumping test.
2. Chemtronics should incl.ude a topographic map indicating the location of the
pumping well in re.lat.ion to the observation wells.
3. Discuss the reasons for a seven ('/) foot lon9 well foot placed in the deep
wells.
4. Chemtronics must provjde
(DIIS-3342) for each pumping
well schematics and well completion
well and observation well. (Attachment 1).
reports
5. If the well screen is placed d.irectly above a grout plug, the possibility of
grout contamination affecting the ground water samples collected for analysis
.is greatly increased and the integrity of the wel.l. could be questioned. The
wel.l screen should be placed at the bot:tom of 1:he bore hole.
6. The bentonite seal must be allowed to fully hydrate prior to the placement of
grout in the annular space.
'/. Provide a discussion why black steel casing is: proposed for the shallow wel.t.
to be installed at DA-23. Inorganic constituents may be introduced into the
water samples collected in the welt.s constructed of black steel.
Section 3.0 -Aquifer Test Program
1. Describe which method is anticipated to be used to analyze the pumping test
data.
~~. \i.i.1.1. a control well be used to measure the effE~cts of varying barometr}c
pressures, rainfall, or any other j nf luences which may af feet the ground
water elevations?
Sect.ion 3.3 -Ground Water Sampling and Analysis
l. Ground water collected during the pumping test will probably not be
representative of the agujfer. There will be a loss of volatile organ.le
compounds h1 the process of pumping, transporting and co1.lect.i.ng the ground
water.
~. Chemtronics must describe, jn detail, the sampling and analysis plan,
including the following:
-Description of samp.l.J11g/analysis procedures.
-Equipment used to collect samples.
-Equipment cleaning procedures.
-Ground water sampling procedures.
-Descr.iption of the samp l.e co Uect.i on procedure.
-Sample identification and shipment.
-C::hcd n of custody.
-llnnt.yt:ical methods.
•
1. 'l'hc concentration of vo.l.E1til.e or.gan.i.c~~ jn a representative ground water. sample, will be of concern .if an air stripper is to be employed to treat the grour,d water. It would be necessary to determine the flow rate of contaminated ground water to the air stripper.
General Comments:
1 . '!'he information collected during the ground water b.iolagoon (in DA-23) should be compat.ible with RCRI\ be used to develop the aquifer characterization at post-closure permit: appljcation.
characterlzatJor1 al
standards so that ii:
the RCRI\ un.i I: for
t:he
CUii
the
7.. '!'he closure of the b.io\agoon, the RCRA unit in D1\-23, must not be compromised by ongo.ing activit.ies in the biol.agoon area.
7/19/89
RCM/mb/0141-99-100
• •
IITT/\CIIMEN'l' I
• •
TYPICAL MONITORING WELL SCHEMATIC
<f>I''/ OF WELi. COMPLETION REPORT (OHS 3342)
'.;lill/AITTED TO THE HAZARDOUS WASTE BRANCH UPON
r:OJAPI.ETION OF MONITOlllNG WELL
VENTED CAP
(PVC. STAINLESS STEEL OR TEFL~
I 1/,1' X I l/4' X 2'
MII-IIMlfM 2-INCH (0.0.)
SCHEDULE 40 PVC,
,;rA IN I. ESS STEEL OR TE F Lon-------.....__
THREADED COUPLING
MUST BE.USED.
AVOID USE OF SOLVENTS.
FILTER PACK SHOULD EXTEND
NO MORE THAM TWO FEET
ABOVE THE SCREEM
WELL SCllEEN
(SLOTTED SCHEDULE
STAI/HESS STEEL OR TEFLON)
END CAP
(PVC, STAI IH ESS --------------
STEEi. OR TEFLON)
STEEi. CASING WITH CAP AND 1.oc1:
VENT HOLES
CC~ETE COLI.All EXTE/;1)11-JG
AT I.EAST 3.0 FEET BELOW
GROUND SURFACE
GROUT BACKFILi.
1.0 FOOT SEAL OF
BENTONITE PELLETS
THE BENTOt-llTE PELLETS SHOULD BE
ALLOWED TO HYDRATE PRIOR 10
c---PLACING GROUT IN
THE ANNULAR SPACE.
~AND
BACKFILL (NC 112 S)
SCREE II
INTERVAL
.. •
N. C. Department of Human Resources.
Division of Health Services
WELL COMPLETION RECORD
COMPLETE ALL INFORMATION REQUESTED BELOW FOR EACH WELL INSTALLED, AND RETURN FORM TO THE N.C.
DEPARTMENT OF HUMAN RESOURCES, SOLID AND HAZARDOUS WASTE MANAGEMENT BRANCH,
P. 0. BOX 2091, RALEIGH, N.C. 27602
NAME OF SITE: PERMIT NO.:
..
ADDRESS: OWNER {print):
DRILLING CONTRACTOR: REOJSTRATION NO.:
Casing Type: dia. __ in. Grout Depth: from to ft. -dia. __ in.
Casing Depth: from to ft. -dia. __ in. Bentonite Seal: from to ft. -dia. __ in.
Screen Type: dia. __ in. Sand/Gravel PK: from to ft. -dia. __ in.
Screen Depth: from to ft. -dia. __ in. Total Well Dc:pth: from to ft. -dia. __ in.
Static Water Level: _______ feet from top of casing Date·Measured __ / __ / __
Yield (gpm): ____ Method of Testing: _______________ Casing is ____ feet above land surface
DRILLING LOG LOCATION SKETCH
DEPTH ( show distance to numbered roads, or other map reference poill.ts)
FROM TO FORMATION DESCRIPTION
REMARKS:--~-----------------------------------
DATE: _______ _ SIGNATURE: --------------------------
! 1HS B42 (6185)
:X-.lid &. Hauirdous Wutc Mana,emcnr Branch
Purpose:
Preparation:
Distribution:
Disposition:
• •
Permits issued for operation of a sanitary landfill require the installation of groundwater quality
monitoring wells. Upon completion of installation, a record of each well must be completed.
The owner/operator of the sanitary landfill is responsible for completing the well record. The
owner/ operator 1must sign the record. ·
Original to: Solid & Hazardous Waste Management Branch
Division of Health Services
P. 0. Box 2091
Raleigh, NC 27602-2091
This form may be destroyed in accordance with Standard 7, Inspection Records, of the Records
Disposition Schedule published by the North Carolina .Division of Archives and History.
Order additional forms from: Solid & Hazardous Waste Management Branch
Division of Health Services·
P. 0. Box 2091
Raleigh, NC 27602-2091
• •
UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREE·r
ATLANTA, GEORGIA 30365 RECIE\\I\ED
JUL 13 \9t,'=l
MEMORANDUM SUPERfUND BRANCH
DATE:
SUBJECT:
FROM:
.........
JUL ! 1 199S
Review and (.C_ommeryt~.Qn the •D_raft Ground Water
·characterization .Scope of Work Section of the Draft
Remedial Design/Remedial Action Work Plan for the
Chemtronics Superfund Site
J J. f{_~o ~
Superfund Project Manager
TO: Addressees
Attached for your review is a copy of the draft Ground Water Characterization Scope of Work document referenced in the draft Remedial Design/Remedial Action (RD/RA) Work Plan for the
Chemtronics Superfund Site located in Swannanoa, Buncombe County, North Carolina. I am requesting that you submit your comments to me by July 21, 1989 as this is the date the Potentially Responsible
Parties (PRPs) have requested a response. The schedule the PRPs are working under was provided to you as an 11ttachment to my June 8, 1989 memorandum requesting review of the draft Remedial Design/Remedial Action (RD/RA) Work Plan. If you are unable to meet this due date, please inform me of when I can expect to
receive your comments.
If additional copies of this draft Work Plan are necessary or if you ha~e qny auestions, I can be reached at [phone].
Addressees: Betsy Briggs, TES VIII
John Creighton, Buncombe County Environmental Affairs
Board
Lee Crosby, NCDHR ·,
John Dickinson, RCRA
Dick Green, SFB
Don Link, NCDNRCD
Glenn May, RCRA
Richard Muza, G-WTU
Jennie Rominger, Clean Water Fund of North Carolina
Charlotte Varlashkin, NCDHR
Bob Watson, President of Citizen's Watch
Candace Wingfield, OWPE (Mail Code OS-510)
• •
• • •
GROUND WATER CHARAC:TERIZII.TION
SCOPE OF WORK
CHEMTRONICS SITE
SWANNANOA, NORTH CAROLINA
JUNE, 1989
SEC JOB NO. G-9169
SIRRINE ENVIRONMENTAL CONSULTANTS
GREENVILLE, SOUTH CAROLINA
EPA -RE:GION IV
.\ T!.."-~!T A, G ft •.
• •
TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
2.0 TEST WELL CONSTRUCTION 2
3.0 AQUIFER TEST PROGRAM 5
3.1 PARAMETERS 5
3.2 TEST PROCEDURES 5
3.3 GROUND-WATER SAMPLING AND ANALYSIS 7
4.0 SUMMARY REPORT 8
• •
1.0 INTRODUCTION
In order to assist in the final remedial design, three aquifer tests will be conducted at the
Chemtronics Site in Swannanoa, North Carolina. One of !ht? tests will be performed in the
area downgradient of the Acid Pit, Disposal Area 7/8, and Disposal Area 9 (Site 1). Two
tests will be performed near Disposal Area 23 (Site 2). The tests are designed to evaluate
saprolite aquifer and the upper fractured portion, of the bedre>ck zone. The overall objective
of the aquifer tests is to provide the necessary information to properly design a ground-
water extraction system for both the front and back valley. The tests are designed to:
o Refine estimates of aquifer hydraulic properties;
o Evaluate the response to pumpage of the saprolite and bedrock zone;
o Provide the data necessary to finalize extraction well locations, well density, and
quantify the final total design flow rates;
o Provide the data necessary to finalize design of the ground-water treatment
systems.
The test to be performed at Site 1 is designed to evaluate the water-level responses
throughout the saprolite and bedrock aquifers to pumpagB of the lower saprolite and
bedrock. Two aquifer tests will be performed at Site 2 because the saprolite thickness is
greater at this location. A shallow test will be performed to evaluate the water-level
responses to pumpage of the upper saprolite. A deeper test will be performed to evaluate
responses throughout both the bedrock and saprolite aquifers.
1
• •
2.0 TEST WELL CONSTRUCTION
The test wells to be installed at each site will be located ano constructed so that they can
be converted to extraction wells at a later date. Each of the three wells will be 6-inch
diameter. The deep test well at each site will be open to both the upper portion of the
bedrock and the lower portion of the saprolite. The shallow well, located at site (DA-23),
will be screened in the upper part of the saprolite aquifer.
The pumping well at Site 1 will be located approximately 40-!:0 ft from BW9. This distance
should provide sufficient drawdown data on wells BW9, sw·I1, and IW2. Additional data
may also be obtained from wells X3 and M85L9.
Both the shallow and deep pumping wells at Site 2 will be constructed at a distance of 40-
50 ft from well BW4. This distance should provide sufficient drawdown data in wells BW4
and SW4, and possibly provide data in wells M85L4 and M8!iL 10. · These wells were also
located based upon drilling rig accessibility.
The pumping wells are located so that the aquifer is stressecl at nearby monitoring wells.
The effect of pumping on these wells will provide information on the hydrologic connection
between the saprolite zone and shallow bedrock, as well as the horizontal radius of
influence of the cone of depression and estimate of aquifer parameters.
Each deep test well will be constructed of two sections of carbon steel casing with a
stainless steel screen between them. The casing construction, from the bottom up, is as
follows:
o 7-ft long carbon steel casing;
o 25-ft long stainless steel screen;
o carbon steel casing to the land surface.
2
• •
The saprolite portion of, each deep well will be drilled to the selected screened interval
using hollow-stem augers. Split spoon soil samples will be collected at 5 ft intervals from
the top of the anticipated screened interval to auger refusal. The anticipated screen depths
for the deep wells are as follows:
0
0
Site 1 (AP-DA /8-DA9)
Site 2 (DA-23)
60 -75 ft;
100 -125 ft.
The wells will also be open to the upper 20 to 25 ft of bedrock.
Each deep well will be installed by first drilling a nominal 5 ft deep socket into bedrock
with a nominal 12-inch diameter roller cone bit and mud rotary techniques. A 5-ft thick
grout plug will be placed in the socket using a tremie pipe. The casing string will then be
lowered into the socket. The cement will then be allowed to set for a minimum of 12
hours. The screened portion of the well will be sand packe,j through a tremie pipe to a
depth at least 5-ft above the screen. A minimum 3-ft thick bentonite seal will be placed
above the sand pack, and the well annulus will be cementeid using a cement/bentonite
slurry through a tremie pipe. After the cement has been allowed to set for 24 hours, a 4-
inch diameter flush threaded PVC temporary casing will be installed inside the casing string
to protect the screen and prevent wobbling of the drilling tools. Approximately 20 ft of
bedrock will be cored using HQ coring techniques. The bottom portion of each well will
be completed as an open hole bedrock well.
A shallow well will be installed at Disposal Area 23. It is anticipated that the approximate
screened interval will be from a depth of 30 ft to a depth of 5!; ft. This well will also be a
6-inch diameter well, constructed of black steel casing and 25 ft of stainless-steel, wire-
wrapped screen. The well will first be drilled with hollow-stern augers to the anticipated
screened interval. Split-spoon soil-samples will be collected at 5 ft intervals to the total
depth of the boring. The borehole will then be reamed to a 12-inch diameter using mud
3
• •
or air rotary drilling techniques. The well will be sand pack13d using the tremie method to
a depth at least 5 ft above the screen. A minimum 3 ft thick bentonite seal will be installed
above the sand pack. The well annulus will be grouted with a cemenVbentonite slurry by
the tremie method. After the cement has been allowed to ~;et, the well will be developed
by pumping and air lifting until the water is clean and sand free.
Selected split-spoon soil samples will be analyzed in the laboratory for grain-size
distribution. The final screen slot size and sand pack selections for all three wells will be
based upon these analyses.
4
• •
3.0 AQUIFER TEST PROGRAM
3.1 Parameters
In order to estimate the responses to pumpage that should be obtained during the
aquifer test, values of transmissivity (T), storage coefficient (S), and specific capacity
were estimated. These values were previously estimatE?d from hydraulic conductivity
data obtained during the RI phase of work. The storage coefficient could not be
estimated, therefore a sensitivity analysis was performed for this parameter. The
estimated values were the following:
Site 1 (AP-DA 7/8 -DA9)
Transmissivity 130 gpd/ft
Storage coefficient 0.2 -0.0001
Specific Capacity 0.06!> gpm/ft
Site 2 (DA 23)
Transmissivity 52 gpd/ft
Storage coefficient 0.2 -0.0001
Specific capacity (shallow well) 0.035 gpm/ft
Specific capacity (deep well) 0.026 gpm/ft
3.2 Test Procedures
It is anticipated that the flow rate for the deep wells will be 3 to 6 gpm and for the
shallow well will be 1 to 2 gpm. However, the final flow rates will be determined by
first running pre-tests which will be step draw-down tests. Each pre-test will be run
5
• •
for a duration of 6 hours or less. The specific capacity .::,f the pumping well at the end of the anticipated aquifer test period will be calculated from the pretest data. The pretest will also be used to test equipment and flow s,,t controls.
The aquifer test will be pertormed using a suitable submersible pump for the rate of flow and total dynamic heads encountered. A throttling valve will be used to control the rate. Both totalizing and flow meters will be used to measure the total gallons pumped and the instantaneous flow rate.
The discharge from each test will be contained in tanks on the site. This will be done to avoid potentially recharging the aquifer during the test or discharging contaminated water.
After the pre-test has been pertormed, pre-test trend data will be collected. Measurements will be made of water levels, barometric pressure and rainfall, to determine antecedent trends, barometric efficiency and water-level responses. During the course of collecting the pre-test trend data, water levels will be measured in the test wells by a data-logging device using pressure transducers.
Each aquifer test will be scheduled for a target pumping period of 24 hours. Actual durations will be dictated by the aquifer response. Water levels in the pumping well and in the observation wells closest to the pumping well will be measured by pressure transducers and the data recorded on an electronic data logger. The data will be downloaded onto computer diskette at regular intervals ,juring the test to facilitate analysis. The water levels in outlying observation wells will be made throughout the test using electric drop lines. Barometric pressure will be measured throughout the test so that water levels may be corrected for this influencu, if necessary. Data plots will be maintained during the test as the measurements are taken, including barometric pressure, water levels, rainfall and discharge rate.
6
-
• •
Recovery measurements will be made in outlying wells for a period of twelve hours.
In wells equipped with pressure transducers, water-level measurements will be
recorded for the full recovery period of 24 hours or until no appreciable change is
being recorded.
The total discharge created during the course of prete,sts and constant-rate tests to
be conducted at both sites is approximately 21,600 gallons. Discharge created during
each test and the anticipated observation wells are shown in Table 1. Drawdown data
may be obtained in additional monitoring wells if the radius of influence is greater than
anticipated.
3.3 Ground Water Sampling and Analysis
Ground water extracted during the pumping test will be stored on-site in storage
tanks, as described in Section 3.2. This ground water will be used to conduct
treatability testing for the design of the ground water treatment system. In some
cases this source of site groundwater may be supplemented by direct collection from
the present monitoring well system. Pump test ground water will be collected prior
to storage and analyzed for the following compounds:
volatile organics (EPA Method 8010/8020);
• RDX;
benzophenone/benzilic acid;
chromium (filtered and unfiltered);
• lead (filtered and unfiltered).
7
Observation Wells
BW9, SW11, IW2,
X3, M85L9
Observation Wells
BW4, SW4, M85L4,
M85L10
Observation Wells
BW4, SW4, M85L4,
M85L10
• •
Table 1
Site 1 -Acid Pit. DA 7/8 and DA 9
Total Volume Discharged
after 6 hr. pretest (gal)
1800
Site 2 -DA 23
Shallow Aquifer Test
Total Volume Discharged
after 6 hr. pretest (gal)
720
Deep Aquifer Test
Total Volume Discharged
after 6 hr. pretest (gal)
1800
Total Volume Discharged
after 24 hr. test (gal)
7200
Total Volume Discharged
after 24 hr. test (gal)
2880
Total Volume Discharged
after 24 hr. test (gal)
7200
•
The following general parameters will be analyzed:
total organic carbon (TOC);
hardness;
calcium;
magnesium;
• iron;
manganese;
• alkalinity.
•
The given pump test wells adequately characterize PA-23 and the Acid Pits for
establishing a remedial design basis. The only other i,jentified disposal areas with
chemical levels above the proposed ground water levels are DA 7/8 and DA 9.
Monitoring wells SW-8 is the most representative of DA 7/8 while DA 9 is best
characterized by SW-9. These wells will also be samplEid for the given parameters.
Ground water sampling will conform to the requirements given in the EPA Region IV
Environmental Services Division document Standard Operating Procedures and Quality
Assurance Manual (April 1, 1986).
Aliquots of ground water for treatability testing will be withdrawn from the storage
tanks and blended to generate a sample representative of the actual treatment plant
influent. Loss of volatile organics is not a concern since 9round water will require air
stripped prior to further treatment. Ground water from SW-8 and SW-9 may also be
collected for inclusion in the treatability mixture if chemical concentrations from these
wells are not within the levels found in the pump test ground water.
9
• •
4.0 FINAL REPORT
Upon completion of all three constant-rate aquifer tes1s and accumulation of data, a
summary report will be prepared that includes:
Site location map;
Pumping and observation well locations:
• Pumping well construction diagrams and soil boring reports;
Figures showing screen intervals of pumping well and observation wells;
• Potentiometric surface map;
Data plots and solutions:
• Projected capture zones;
• Water quality data:
Conclusions and design recommendations.
10
•
North Carolina Department of Human Resources
Division of Health Servinis
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.
MEMORANDUM
TO:
FROM:
Lee Crosby, Head
Superfund Branch
July 20, 1989
Jerome H. Rhodes, Hea~
Hazardous Waste Branch
REFERENCE: Chemtronics
Draft Ground Water Characterization Scope
of Work Section
Swannanoa, North Carolina
State Health Director
Enclosed is a copy of the draft comments on Chemtroni.cs' "Ground Water Characteri-
-zation Scope of Work Section" in the Remedial Design/Remedial Action Work Plan for
the Chemtronics Superfund site. Please incorporate these comments with any comments
you may have regarding this work plan.
If you have any questions concerning the comments on the Chemtronics work plan,
please contact Rob McDaniel at extension 150.
JHR/RCM/mb/0141-108
cc: William F. Hamner
James A. Carter
Robert C. McDaniel
Comments on the Ground Water Characterization Scope of Work Section of the Draft
Remedial Design/Remedial Action Work Plarr for Chemtronics
Section 2.0 -Test Well Construction
l. Chemtronics should descdbe _wliich method (i11cluding the assumptions inherent
.in tire method) is ant.icipated to be used to analyze the data collected during
the pumping test.
7.. Chemtro11ics should incl.ude a topographic map ind.icat.i.ng the location of' the
pump.i.ng well in relation to the observati.on wells.
3. ll.iscuss the reasons for a seven ( '/) foot long well. foot placed .in Ure deep
wells.
4. Chemtronics must provide
(DIIS-3342) for each pumpi11g
well schema tics and well completion
well and obser:vation well (Al:tachment l).
reports
5. 1f the well screen is pl.aced directly above a grout plug, the possibility of
grout co11taminatio11 affecting tire ground water samples collected for analysis
is greatly increased and the .integdty of l:he well could be questioned. The
well screen should be placed at the botl:om of the bore hole.
6. '!'Ire bentoni te seal must be allowed l:o fully hydrate pr.ior to the placement of
grout .in the annular space.
·1. Provide a discussion why bl.ack steel. casing i,; proposed for the slral.low well
to be .installed at DA-23. l11orga11ic conut.itucnt:s may be .introduced .i.nl:o the
water samples collected in the wells constructed of black steel.
Section 3.0 -Aquifer Test Program
1. Descrjbe which method .is anticipated to be used to analyze the pumpjng test
data.
~~. W.i.11. a control well be used lo measure the effects of varying barometric
pressures, rainfal.l, or any other influences which may affect the groulld
wat:er elevatj_ons?
Section 3.3 -Ground Water Sampling and Analysis
J. Ground water collected during tire pumping test w.il.l probably not be
representative of the aqu.i[er. 'l'here will be a loss of volatile ol·ganlc
compounds in the process of pump.ing, transporting and collecting tire ground
water.
2. Chemtronics must descr.ibe, .in aetail, the sampling and analysis plan,
i11cludirrg the following:
-Descr.iplion of samp.L.ing/nnalysis procedures.
-Egu.i.pment used to collect samples.
-Eqt1l.pme11t cleaning procedllres.
-Ground water samp.l.ing procedures.
-IJescr.ipUon of the sample collection procedure.
-Sampl.e identification and shipment.
-Chain of custody.
-Arralytical methods.
1. 'l'lic concentration of v0Jc1Lil.e orgar1.ic?, :in sample, wiJ..l be of concern if an air stripper
ground wat:er. lt wou1d Le necessary to
conl:am.i.nated ground watot:'" to the cdr strjpper.
a repr.esentative ground \·lclter
is to be employed to treat the
determine the fl.ow rate of
Gener.al Comments:
] . 'l'he informal.ion col Lecl:ed dtJring the grotJnd water biol.agoon (i.n Dl\-23) shoul.d be compat.ible with RCRI\ be used to develop the aqtd/er chai-ac ter j za tj on at post-closure permit: appLicu\:ion.
characterizatjon at
standards so that it
the RCRI\ urd I: for
the
can
the
?, . '!'he clostJre o[ the b.i.ol.agoon, the RCRA unit in Dl\-23, must not be compromised by ongo.ing acLivit.ies in the biolagoon area.
7/19/89
RC:M/mb/0141-99-100
e:
/\'l"l'/\CIIMEN'l' J
0
TYPICAL MONITORING WELL SCHEMATIC
<J)PY or WELi. COMPLETIOl-l REPORT (DIIS JJ,12)
'.illlll,11TTED TO TIIE HAZARDOUS WASTE BIIAl·lCII I/POil
1:01"1PI.ETJOJ,J or MOJ,JTOIIIHG WELL
VEHTED
(PVC. STAIIHESS STEEi. 011
CAP
TEFLON)
' " ' ' ' ';a , ' "" " J~i~~0
,1 I l•l I M t/ M 2 · I l·l C II ( 0. D )
SCHEDULE 40 PVC,
'\jj
STAINLESS STEEL OR TEFLO~
THREADED COUPLING
MUST BE.USED.
AVOID USE OF SOLVEHTS.
FILTER PACK SHOULD EXTEND
t,O MORE THAN TWO FEET
ABOVE TII E SCREEH
WELL SCllEEl-l
(SLOTTED SCHEDULE
STAI IHESS STEEL OR TEFLO~I)
END CAP
(PVC. STAI IH ESS
STEEi. Oil TEFLON)
STEEi. CASIJ-JG Willi CAI' AND 1.oc1:
VEHT IIOLES
~ CO,·l Cll E TE COLL All EXT E l·l DI J,J<;
Al I.EAST 3.0 FEET BEi.OW
GROUMD SUIHACE
GROUT BACl'.FILI.
1.0 FOOT SEAi. OF
BENTONITE PELLETS
Tf!E BENTOJ,ITE PELLETS SIIOULD BE
ALLOWED TO II YDRATE PRIOR TO
>---PLACING GllOUT IN
TIIE ANNULAll SPACE.
SA I JD
BACl'.fll.L (NC 1/2 S)
SCREEII
INTERVAi.
N. C. Department of Human Resources
•-
1 WELLD~~i:;~;;;~:;;cl6
COMPLETE ALL !NFORMA TION REQUESTED BELOW FOR EACH WELL INSTALLED, AND RETURN FORM TO THE N.C,
DEPARTMENT OF HUMAN RESOURCES, SOLID AND HAZARDOUS WASTE MANAGEMENT BRANCH,
P, 0. BOX 2091, RALEIGH, N,C, 27602
NAME OF SITE: PERMIT NO,:
ADDRESS: OWNER (print):
DRILLING CONTRACTOR: REGISTRATION NO,:
Casing Type: dia, __ in, Grout Depth: from to ft, -dia, __ in.
Casing Depth: from to ft. -dia, __ in. Bentonite Seal: from to ft, -dia, __ in.
Screen Type: dia, __ in. Sand/Gravel l'K: from to ft_ -dia, __ in.
Screen Depth: from to ft, -dia, __ in. Total Well D,,pth: from to ft_ -dia, __ in.
Static Water Level: _______ feet from top of casing Date Measured __ / __ / __
Yield (gpm): ____ Method of Testing: ----------~-----Casing is ____ feet above land surface
DRILLING LOG LOCA T!ON SKETCH
DEPTH (show distance to numbered roads, or other map reference poirlrs)
FROM TO FORMATION DESCRIPTION
REMARKS: ---------------------------------------
DATE: _______ _ SIGNATURE: ---------------------------
: •HS H42 (6165)
.,;.lhd & Harordous Waste Mkf\aiCmcnt Branch
Purpose:
Preparation:
Distribution:
Disposition:
Permits issued for operation of a sanitary landfill require the installation of groundwater quality
monitoring wells. Upon completion of installation, a record of each well must be completed.
The owner I operator of the sanitary landfill is responsible for completing the well record. The
owner/operator must sign the record.
Original to: Solid & Hazardous Waste Management Branch
OiVision of Health Services
P. 0. Box 2091
Raleigh, NC 27602-2091
This form may be destroyed in accordance with Standard 7, Inspection Records, of the Records
Disposition Schedule published by the North Carolina Division of Archives and History.
Order additional forms from: Solid & Hazardous Waste Management Branch
Division of Health Services
P. 0. Box 2091
Raleigh, NC 27602-2091
• •
UNITED STATES ENVIRONMENTAL PR'.OTECTION A~S,\11:'I\R[E
REGION IV ll"'il!':.l,~y w D
JUL I 2 1929
4WD-SFB
Mr. John F. Schultheis
Nimmo & Co.
P.O. Box 536
Swannanoa, NC 28778
3•5 COURTLAND STREET
ATLANTA. GEORGIA 3036S JUL 1 1 ll-Jtl8
SUPERFUND BRANCH
Re: Comments on the Draft Remedial Design/Reme,dial Action Work Plan for
the Chemtronics Superfund Site
Dear Mr. Schultheis:
Five copies, four bound and one unbound, of the above referenced document
prepared by Sirrine Environmental Consultants (SEC) for the Potentially
Responsible Parties (PRPs) were received by the Agency on June 6, 1988. As
part of Superfund"s review process, copies of these documents were
transmitted to various programs within the Agency as well as to the North
Carolina Departments of Human Resources (NCDHR) and Natural Resources &
Community Development (NCDNRCD) for review and cornments.
This document was set up to direct the development: of the Remedial Design and
Remedial Actions for the Chemtronics site. All of the following comments
need to be addressed in the revised work plan. This can be accomplished by
either incorporating the requested change into the text of the revised work
plan or by a written explanation as to why the PRPs do not feel the comment
is appropriate or warranted. The revised work plan should be submitted to
the Agency for approval as soon as possible.
The comments listed below are as they appear in th,, text of the draft work
plan. No comments were received from the State. Again, all commt=nts au<l
requested changes stated below need to be incorporated into the revised work
plan.
1. Pages 1 and 2, Sections 1.1 and 1.2: Some discussion needs to be
included in these sections on establishing the monitoring program for
the surface waters on site as this activity is to coincide with the
development of the remedial design. This is required per the second
paragraph in the April 5, 1988 Record of Decision (ROD) in the
Description of the Selected Remedy on the pa;~e entitled Deelaration
for the Record of Decision. Additional language will be necessary in
other sections of the work plan to identify permanent sampling points
on the three surface streams associated with the Chemtronics site (the
Unnamed stream, Gregg Branch and Bee Tree Cre,ek) and describe what
activities will be conducted to accomplish the goals of the monitoring
2.
• •
-2-
program. It is important that the monitoring of these surface streams
be initiated along with the development of the remedial design as the
data generated will form the baseline to gauge improvements brought
about by the remedial action.
Page 4, Section 2.0 Additional Data Requirements:
Objectives (DQOs) need to be defined. Applicable
appropriate requirements need to be defined also.
The Data Quality
or relevant and
3. Page 4, Paragraph 3: Will two extraction wells, one in the intermediate
groundwater zone and one in the deeper zone, be sufficient to define
the aquifers' characteristics in both valleys?
4, Page 5, List of Contaminants to be Analyzed for: What is the rationale
for not analyzing these groundwater samples for the contaminants
listed in Table 13 --Groundwater Remediation Levels and Cited
References --of the April 5, 1988 Record of Decision.
5. Page 6, top of page: Although I know it is not necessary to state, I
feel it is necessary for the record. The extent of treatment of the
extracted groundwater will be based on the level of contaminants
coming from the wells and not on the concentrations following
comingling of the extracted waters. Combining extracted groundwater
from several wells will undoubtedly result in significant dilution of
the actual levels of contamination.
6. Page 6, third paragraph, second sentence: Will the metals removal jars
be able to prevent the escape of the volatile compounds? What effect
would the presence of volatile organics have on the removal of metals?
7. Page 6, third paragraph, fourth sentence: What is the possibility of a
change in the oxidation state of the metals during transport? What
variance will this cause in the conclusions reached?
8. Page 6, third paragraph, fourth sentence:
planned to be added to either the metal
water samples, will these wate.r samples
for transport?
Although no preservatives are
or flow-through carbon column 0 be cooled to 4 Centigrade
9. Page 6, third paragraph: The procedures plann,,d to be implemented to
conduct work discussed in this paragraph needs to be either included
or referenced.
10. Page 10, Section 3.1: A list of the specific _ARARs needs be included or
referenced.
11. Page 10, Section 3.1.l Capping: The cap for DA-23 which includes the
RCRA biolagoon, should be consistent with the RCRA closure plan that
Chemtronics submitted to North Carolina Depart:ment of Human
Resources. In addition, the cap for DA-23 should meet the
•
-3-
requirements outlined in a December 22, l.988 memorandum from Wayne
Garfinkel and the Closure/Post-Closure fasues Committee, subject,
Cover Design Requirements. A copy of th,.t memorandum is enclosed.
12. Page 12, Fourth paragraph: The existing portfolio of monitoring wells
and the need for additional wells should be evaluated as part of the
Groundwater Characterization Scope of Work document. The conceptual
design should then consider all wells use:! in the groundwater
characterization to determine whether mor,e wells are needed for the
remedial design,
13, Page 13, Section 3.1.2.2: The RCRA program recommends that the
groundwater samples collected from selecte:d wells be analyzed for
Appendix IX Wastes in furtherance of completing the Part B application
and post-closure Permit requirements, In conducting field work in
general, the work should ensure that CERCLA work will provide all
information needs of the Part B for the DA-23 biolagoon.
14. Page 18, Section 3.1.3: Both EPA's and the State's RCRA programs oppose
placing any hazardous waste sediments from the pond on the unnamed
creek into DA-23. The biolagoon cannot ac,oept hazardous wastes since
it is scheduled to undergo closure and has ceased receiving hazardous
wastes.
15. Page 20, first paragraph: Will all the treatment/discharge alternatives
be presented in detail within the conceptual design? Or only the
preferred alternative?
16. Page 22-23, Section 3.2.1: Please note the final paragraph of
Section 3. 2, 1 regarding the remediation of the onsite pond: ".The
impoundment must be removed whether or not remediation is required and
the required procedures will be clearly def:lned." This statement is
confusing, please clarify.
17. Page 30, third paragraph: A copy of the document Quality Control Manual
(Sirrine Environmental Consultants, as amended April 1989) needs to be
submitted since it is referenced or appendiced.
18. Page 37, first paragraph: The facility should be fully operational
during the pre-final inspection so that the performance of the
different subsystems (i.e., carbon adsorption backwash, bypass
systems, backup systems) can be evaluated and samples could be
collected, if appropriate.
19. Page 37, second paragraph, first sentence: Prior to which inspection?
•
-4-
The Agency is willing to meet and discuss with the PRPs and Sirrine any of
the identified deficiencies or requested changes, if you so desire. If you
have any questions, I can be contacted at [phone].
Sincerely yours,
j1K6Jwl~
Jon K. Bornholm
Superfund Project Manager
Enclosure
cc: Charles Case, Chemtronics
John Creighton, Buncombe County Environmental Affairs Board
Lee Crosby, NCDHR
David Hunter, Hoechst-Celanese
Don Link, NCDNRCD
Jennie Rominger, Clean Water Fund of North Carolina
Gary Rowan, Hoechst-Celanese
Gary Serio, Northrop
Charlotte Varlashkin, NCDHR
Bob Watson, President of Citizen's Watch
Tony Young, Northrop
.,
MEMORZ\NDUM • D?>.TE: DEC 2 2 1988
SUBJECT: Cover Design Requirements
Wayne Garfinkel, Chief, KY/TN Unit and
Closure/Post Closure Issues Carrnittee
TO: WES Staff
The EPA suggested standard cap design, described in our guidance
documents, is outlined in Attachments 1 and 2, Site-specific
conditions may permit the employment of a cover system •~ther
than that reccmnended by EPA. Alternate designs consistent with
existing regulatory requirements may also be considered,
provided that the functional requirements of each canpcment of
the cap are maintained; future maintenance can be minimized; and
releases of residual hazardous constituents controlled,
minimized or eliminated to the extent necessary to prot<ict human
health and the environment. Q.iidance documents indicate that
alternate designs may be acceptable if the Hydrogeological
Evaluation of Landfill Performance (HELP) Model or engineering
calculations indicate that the design is equivalent to or better
than the performance of the EPA suggested design, or if the
pathway of concern is convincingly demonstrated not tot€ soil
(i.e., percolation of water through the cover system is a remote
possibility). However, since the HELP Model indicates that a
reduction in the depth of the vegetative top cover increases
runoff and reduces percolation in the liner, sufficient
attention must be made to all ramifications of reducing the
cover thickness. Any alternative design must be carefully
evaluated to ensure that design requirements for each layer will
be satisfied. Specifically, maintenance of adequate soil
moisture to support vegetation during wet and dry period:; and to
prevent clay dessication, soil erosion control, prevention of
root penetration into the barrier layer, maintenance of
structural stability, and placement of the clay liner be:Low the
frostline must be evaluated.
The HELP Model was recently improved to thoroughly addre~:s the
variables involved in cover design and to provide sensitivity
analysis. Sensitivity analysis permits an accurate evalu•ation
of the effects that changes to variables have on a particular
cover system. The HELP Model provides much information that
should be considered in the design of open, partially-closed and
fully-closed landfill sites. various cc:rnbinations of
vegetation, cover soils, waste cells, synthetic covers and
liners are evaluated to determine the estimated runoff,
drainage, leachate production and soil water content to b~
expected fran the operation of a variety of landfill desiqns.
Although the Final Technical Resource Ibcument is not expected
to he available until the first half ?f next year, it is
recanmended that this HELP Model be employed by the Waste
Engineering Section to evaluate detailed landfill and cover
design plans. Copies of the user Guide for the updated HELP
Model are available within the section.
-,.-
Please note that the~ Model is designed to maximi!.
percolation through the vegetated top cover, and that separate
canputer runs incorporating modified input values (e,9., shallow
evaporative zone depths, lower values for hydraulic
conductivity} may be necessary to obtain conservative values for
the design of runoff control structures. The version of the
. model was canpleted in January 1988 in cooperation with the
u.s.c.o.E. Waterways Experiment Station at ITS 542-3709 or
[phone].
Contact Larry Fitchhorn if you need assistance or any :further
information.
D:x:uments that may be of interest to individuals involved in
evaluating cover design plans are listed below, A subjective
evaluation of each document is provided in parentheses, Copies
of these documents are available within the Waste Engineering
Section.
1. Hydrological Evaluation of Landfill Performance (HELP}
Model, user Guide, CPA/530-SW-84-009, June 1984 (good}.
2. Covers for Uncontrolled Hazardous Waste Sites,
EPA/504/2-85/002, September 1985 (good; oriented to
Superfund sites}.
3. Minimum Technology Guidance on Final Covers for
Landfills and Surface Impoundments, Preliminary Draft,
TRC-A87-240, August 1987 (excellent}.
4. Engineering Guidance for the Design, Construction and
Maintenance of Cover Systems for Hazardous Waste, EPA
number and date illegible on copy received (gooj)
5. Settlement and Cover Subsidence of Hazardous Waste
Landfills, Project Sum-nary, EPA/600/52-85/035, May 1985
(Informative}.
6. Landfill and Surface lm(??undment Performance
Evaluation, SW-869, April 1983 (good}.
7. Evaluati stems for Solid and Hazardous Waste,
SW-867, p r 982 minimal value.
8. Desi n and Construction of Solid waste Landfills,
EPA-600 2-79-165, August 1979 m1n:unal value.
Attachments
EPA sTL CAP DESIGN RB;)UIREMENTS ie
EPA guidance for the design of the final cover which will comply
with requirements specified in Section 264.310(a) calls for, at
a minimum, a vegetated top layer, a middle drainage layer, and a
low-permeability composite bottom layer. The following
standards have been established in our guidance documents to
meet the RCRA technical cover design requirements.
VEGETATED TOP LAYER
1. A minimum thickness of 24" is usually required to retain
soil moisture, minimize root penetration into the barrier
layer, avoid the construction problems prevalent in
attempting to evenly spread a thin layer (i.e., 6" here, 2"
there, etc.) and provide greater tolerance to the .,dverse
impact of erosion.
2. I.Dams are preferred soils; silt-rich soils are a se·cond
choice. Clay-rich soils require special management methods
while sandy soils retain water poorly unless rich in organic
matter.
3. The layer should be vegetated with persistent species
adaptable to local conditions. Short root systems •,mich
will not penetrate beyond the vegetative and drainaqe layers
are preferred. (Pensacola Bahia grass should not be used.
This particular grass has a very extensive deep roo,:
system.)
4. The ground surface slope, after settling and subsidence,
should be between 3 and 5%. The side slopes of the landfill
should not exceed 1 vertical to 4 horizontal unless
otherwise documented to be stable. The ground surfa.ce slope
should remain as close to the natural topography as
possible.
5. The surface drainage system must be capable of conducting
runoff across the cap with no problems. The drainage
ditches should be adequate to accanoclate the runoff fran a
24-hour, 25-year storm.
MIDDLE DRAINAGE LAYER
1. A minimum thickness of 12" is generally required to reduce
the head of water on the soil barrier layer and prevunt
water backup into the vegetative layer. The saturate,d
hydraul}c conductivity should be equal to or greater than
1 x 10 an/sec.
2. Poorly graded sands and gravely sand with little or no fines
( c;o Class if ic:ation) are rp~cn,nended for thP 4rai nage l;iyer
(see attached chart for the Unified Soil Classification
Sys tern (uses)) •
3. The bottcrn slope A•Jld be at least 2% after all,..Ae has
been made for set'Mng and subsidence. -..-
4. The upper portion of the drainage layer should be designed
to prevent clogging. This normally necessitates overlaying
the drainage layer with a synthetic fabric filter or graded
granular material.
5. Discharge frcrn the drainage layer should flow freely so
that fluid -does not back up into the vegetative layer
during a major sustained storm event. The edge of the
drainage layer should drain into surface runoff ditches.
Toe drains and graded riprap filters are effective in
intercepting the draining water.
LCM-PERMEABILITY CXMPOSITE BOl'lOI IAYER
Upper Component Flexible Membrane Component (FMC)
1. Should consist of at least a 20 mil .thick synthetic
membrane, Use of (2) 10 mil liners in lieu of one 20 mil
liner is not an acceptable alternative.
2. The final upper slope, in contact with the overlying
drainage layer, must be at least 2% after allowance for
settling.
3. The liner must be located below the average frost
penetration depth. FMC can be kept below frost line by
increasing vegetated top layer depth.
4. Bedding material may be required to protect the synthetic
liner. The material on each side of the FMC must be at
least 6" thick, must not be coarser than uses sand (SP),
and must be free of rocks, debris, roots and sudden changes
in grade. The drainage layer and lower soil (clay)
ccrnponent may serve as bedding materials if they canply
with the above specifications (this is generally the
case). Placement of the synthetic membrane directly on the
clay is preferred, due to reduced leakage resulting fran a
hole in the synthetic membrane.
Lower Component (Canpacted Soil)
1. The lower soil ccrnponent (clay) consists of a minimum
thickness of 24" of soil recanpacted to a satuE,ted
hydraulic conductivity of not more than l x 10 cm/sec.
The minimum depth of 24" was selected to retain structural
stability in the face of stress caused by settlement,
subsidence and the weight of the overburd~9 and to ensure
that the hydraulic conductivity of 1 x 10 cm/sec. will
be maintained in the future.
2.
3.
4.
5.
6.
7.
-

3

-
Soil should be e,.ced in lifts not exceeding 6" !ore
canpaction, with lift interfaces scarified or otherwise
minimized to achieve a blending of the lifts.
Typical clay soils recamiended for the lower canponent are
uses types: CH -Inorganic clays of high plasticity, fat
clays; CL -Inorganic clays of low to medium plasticity,
gravely clays, sandy clays, silty clays, lean clays; SC -
clayey sands, sand-clay mixtures.
Soil canpaction of at least 95% of the Standard Proctor
maximum density is recamiended.
The upper surface of the canpacted soil (in contact with
the lower surface of the FMC) should have a minimum slope
of 2% after allowance for settling.
EPA has indicated that it is not confident in the ability
of 24-inch-thick soil !~ners to achieve an effective field
permeability of 1 x 10 an/sec. This .is partially due to
the questionable integrity of the outermost lifts. The
lowest lift tends to be blended with the underlying
material while the uppermost lift is subjected to
deleterious effects of weathering (dessi~ion). It is
inevitable that all lifts will have some flaws or zones of
higher permeability even if there is a high level of
Construction QJality Assurance (CQA). Consequently, there
should be several inner lifts and effective scarification
bet..een these lifts. This will minimize the potential for
flows in one lift to be hydraulically connected to those in
adjacent lifts. Reports have indicated that a minimum of
four 6-inch inner lifts are necessary in order to obtain an
ov~7all field permeability of less than or equal to 1 x
10 an/sec. When a 6-inch outer lift is added to each
side of the cap, the resulting minimum compacted clay
thickness is 36 inches. With the placement of a synthetic
membrane immediately over the canpacted clay, the need for
an additional outer lift.on the top of the clay is
eliminated.·
It is realized that in site-specific cases it may be
possible to demonstrate.that a synthetic liner is not
necessary to prevent unacceptable quantities of liquids
from percolating into the buried wastes. Thus, a decision
may be made to· use a single, canpacted soil layer in plaoe
of the reccmnended composite bottom layer. H<::,,iever, even
if an extremely low-permeability liner is not deemed
necessary, EPA recamiends that a synthetic liner always be
placed directly over the cc:n,pacted soil layer. The
synthetic liner can serve as a barrier protecting the soil
layer from root intrusion. Canpletely covering the soil
layer with a synthetic liner also aids in the retention of
the proper soil moisture in the bottom layer, thereby
preventing desiccation and the possible formation of flow
pathways into and/or through the soil canponent.
8. DJe to the signiAnt variability observed betweAhe
results of field~ laboratory hydraulic conduct~y
tests, and the questionable effectiveness of field
canpaction methods and of reccrnpacted clay liners for
long-term protection against liquid migration, field
hydraulic conductivity tests should be conducted at
adjacent testfills and/or during landfill liner
installation when synthetic liners are not utilized in the
final cover design.
GRANULAR FILTER lAYER
1. Granular filters are designed to prevent migration of fine
soil particles into a coarser-9rained material (e.g.,
drainage layer) and to allow water to freely enter a
drainage medium without clogging it with fine particles of
soil.
2. Granular filters should be ccrnposed of SP, SM, ML and/or MH
(See attached chart) soils, depending on.the classification
of the soil to be protected.
J. The criterion for selecting filter grain size is
D 15 (filter) < 5
D 85 (base)
Where o1 and D refer to grain sizes for which 15%
and 85% By weig~~ of the soils are finer, respectively.
4. Geotextiles may be used in place of or in conjunction with
granular filters.
BIOTIC LAYER OR 8108..l\RRIER(OPTIONAL)
1. Biobarriers are used to resist intrusion of plant roots and
burrowing animals.
2. They typically are ccrnposed of sand, gravel, cobblestones
or mixtures of these ccrnponents (6" to 8" thick).
3. If objects in an animal's path are too large or tightly
packed (e.g., cobblestones) or the material is cohesionless
(e.g., a sand layer), the animal's progress is effectively
stopped.
4. The material ccrnpr1s1ng the biobarriers contains large void
spaces, which lack water and nutrients, thus reducing the
intrusto~ of plant roots.
5. The design and resulting effectiveness of a biobarrier is
quite site-specific.
ATTACHMENT 2
•. EPA STANIV\RD CAP DESIGN! •
GRADE BE'IWEEN 3% AND 5% AITER SETTLEMENT AND SUBSIDENCE
24" VEGCT1TED
TOP COVER
(LOAMS OR SILT-RICH
SOILS ARE RECCMIIENDED)
6" TOP SOIL
18" EARTH FILL
- - - - - - - - - --FILTER MAY BE RE)OUIRED-- - - - - - - - - - - -
12" DRAINAGE LAYER2. K~1Xl0-2CM/SEC
GRADE AT LEAST 2% AFTER SETTLEMENT
FLEXIBLE MEMBRANE ca,{P()NENT (SYNTHETIC LINER) (AT LEAST 20 MIL THICK)
24" I.O'I-PERMEABILITY
CLAY LAYER
K~lxlO-?CM/SEC
AITER COMPACTION
FOUNDATION (BUFFER) LAYER
24" COMPACTED BACKFILL
WASTE
1. Other designs may be proposed and, if so, must be evaluated on a
case-by-case, site-specific basis to ensure that the RCRA
requirement of minimizing to the greatest extent possible the
formation of leachate is met.
2. Can be replaced by a geonet or biobarrier when appropriate.
- 5 -
MISCE.EDUS DESIGN CONSIDERATIONS •
The cap may also need to be vented or otherwise ~odified to
account for site-specific conditions (e.g., high groundwater,
gas migration).
Provisions must be established to control erosion and minimize
sediment runoff during both construction and the period of
vegetative establishment.
Quality assurance and control measures should be included in
the design specifications. The contractor should establish and
follow a construction quality assurance (CQA) plan.
• Major Divisions
Hia:hly ora:anic soils'
• •
Classification of Soils for Engineering Purposes
ASTM Designation D--2487
Croup Symbols
GW
GP
GM
GC
SW
SP
SM
SC
ML
CL
OL
MH
CH
OH
Pt
Typical
Names
Well-,raded gravels and
gravel-sand mixtures.
little or no fines
Poorly rrad~ rravels and
gravel-sand mixtures,
little or no fines
Silty gravels, gravel-sand-
silt mixtures
Clayey gravels, rravel-
sand-clay mixtures
Well-rraded sands and
gravelly sands,
little or no fines
Poorly graded sands and
rravelly sands. little or
no fines
Silty sands, sand-silt
mixtures
Clayey sands. sand-clay
mixtures
lnori3nic ailu, very fine
aands, rock flour. silty or
clayey fine sands
Inorganic clays of low to
medium plasticity, gravelly
clays. sandy clays, silty
clays, lean clays
Organic ant.a and organic 1ilty clay1 of low pluti•
city
Inorganic silts, micaceous
or diatomaceous fine aands
or silts, elastic ailta
Inorganic claya of hi1b
plasticity, fat clays
Organic clays of medium
to high plasticity
Classification Criteria
C. -D,o/D11
(Dao)•
Greater than 4
Between 1 and 3
Not meetina: both criteria for GW
Atterbere Hmita plot ~low "A" line or
r.lastic:ity index
ess than 4
Atterbttg limits plot above "A" line and
plasticity index
rreater than 7
Atterbera: limits plot-
ting in hatched area
are borderline
classifications re-
Quirin1 use of dual
symbols
C. -Du/Du
{Du)' c. Dia X D,a
Greater than 6
Between 1 and J
Not meetine both criteria for SW
Atterberg limits plot below •·A" line or
plasticity index leas
than 4
Atterbera: limits plot
above "A" line and
plasticity indu
Krtater than 7
Pioslicify chorf J
F11r ctanification I)(,,-,,,-
Atterberg limiu plot-ting in hatched area
are borderline ~
aifications requirin1
use of dual symbols
V 60
50 I-9ro,n~a u,iJs ond fine _frochon
of coar-sl!-9roinrt3 sDIIS. @ _,~A·1lir,~
_ A,trrHr9 limi,. p/off1ft9 in
hatchc>d On!O orr border/in, /"" cJoa1f,tof1Dns rrquirin9
,o
7 4 0 0
USI of dual •ymblJIS.
/ Equation 0, I@ A-hne:
PJ•D.1J(LL·20) / I
' ----1 ,
10 20
.
JO
/ • ' 40 so 60
Liquid limit
~
70 80 90 100
Peat. muck and other hi1hly
ora:anic soils Visual-manual identification
Landfill Cover Design Standard:
Four Layers to Minimize Infiltration
Surface Layer:
-Vegetative or
Non-vegetative
Surface Component
-Soll Component
Granular or Synthetic
Drainage Layer
Barrier Layer
Foundation Layer
Wastes
•
•
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
Jznncs G. Mcrtin, Governor
David T. Flaherty, Secretary
Ronald H. Levine, M.D., M.P.H.
Mr. Perry Nelson, Chief
Groundwater Section
30 June 1989
Department of Natural Resources
and Community Development
512 North Salisbury Street
Raleigh, NC 27604
RE: Review and Comments on the
State Health Director
Draft Remedial Design/Remedial Action Work Plan
for the Chemtronics Superfund Site
Dear Mr. Nelson:
Three copies of the draft Remedial Design/Remedial Action
Work. Plan for the Chemtronics site in Swannanoa, North
Carolina, are attached for your review, Copies ·have been
included for Ogden Gerald, Chief, Air Quality Section, and
Steve Tedder, Chief, Water Quality Section, for their comments.
Please return comments, if any, to this Branch so that we may
submit one package to the U.S. Environmental Protection Agency.
A list of documents contained in our
Chemtronics site is also attached. If you have
please contact Charlotte Varlashkin or me at
appreciate your working with us on this site.
LC/acr
Attachments
Sincerely,
~ C¼ot::.~ Lee Crosby, Head
Superfund Branch
files for the
any questions,
733-2801. We
• I,
UNITED STATES ENVIRONMENTAL PROTECTION•AGENCY
!)EC O 9 1988
4WD-SFB
Mr. William Meyers
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30315
North Carolina Department of Human
Resources
p;o. Box 2091
·, R_;leigh, NC
' ' r
27601
,Re: Remedial Design/Remedial Action Negotiation Meeting
for the Chemtronics Site ,:-;::;. , ~
De,aI."' ·Mr.· Meyers:
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I am writing this letter to each Potentially Responsible Party (PRP) and the
State of North Carolina to confirm the Agency's desire conv~yed to you earlier
thl~ week by Reuben Bussey over the phone. Mr. Bussey called to inform you
that _the Agency would like to meet with all the PRPs togeth~r. The two
·~bjectives of this meeting are to provide the Agency an opp9rtuni~y to review
several possible enforcement scenarios with ·you as well as provide the PRPs a
chance to discuss settlement issues amongst themselves. Aslconveyed to you in
•.the past';· th·e ·Ager1cy· 'desires a full settlement for the cost of the Remedial
Design/Remedial Action at the Chemtronics Superfund site.
I would like to hold the meeting at EPA
1988 at 10:00 am. We want to encourage
to reach agreement.
~
I.
in Atlanta on Wednesday, December 14,
the parties to continue their efforts
i
If you have any questions, please contact ·me at
Sincerely yours,
(404)347-779'1.
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,(P' K ~-~-
Jan K. Bornholm
Superfund Project Manager
cc: Phillip Brooks, DOJ
Reuben Bus~ey; ORC
Mike Northridge, OCEM
.r .·
''
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
OCT 3 11988
4WD--SFB
Mr. John F. Schult11eis
Chemtronics, Inc.
180 Old Bee Tree Road
Swannanoa, NC 28778
J.15 COURTLAND STREET
ATLANTA, GEORGIA 30365
Re: Conclusion of(ReJUedial Design/Remedial Action Moratoriwu Pericd and
P-eview of Analytical Data a.,d Fixation Remediation for DA-,23
Dear Mr. Schultheis:
in:::::; . I,._.,_.
I am writing this letter to each Potentially Responsible Party for several
reasons, but most importantly, to ccnfirm that the Remedial Des.ign/Remedial
Action (RD/RA) moratorium pericd for the Chemtronics Superf,md site ended
October 24, 1988. The 120 day JOCJratoriwu pericd was initiated py a June 16,
1988 letter from the Agency. A seccnd letter followed, dated July 13, 1988,
that specified June 23, 1988 as the beginning date for the RD/RA JOCJratoriwu
pericd. ·Presently, it is not the Agency's intention to extend the moratorium
as it is the Agency's understanding that a settlement between a.).l the pa.rties
is not close at hand. An extension of the moratorium pericd an additional 30
days will only be granted by the Regional Administrator if an agreement and the
signing of the Consent Decree is irruninent. Since t.~is is not the situation,
the Agency will now evaluate available enforcement options and: pursue U1at
option which best meets the Agency's interests.
We want to encourage the parties to ccntinue their efforts to reach agree.~ent.
The Agency will continue to be available for such discussions even though the
IOCJratorium has elapsed.
I would also like to inform you that the Agency is revieMing the data submitted
by Cnemtronics, Inc. and Northrop Corporation supporting the recently
discovered transcription mistake wit.~ respect to the data associated wit11
IOCJnitor well S\'1-4. This surficial well is located downgradient of Disposal
Area 23 (DA-23). The Certificate of Analysis prcduced during the Remedial·
Investigation reported a quantity of 470 milligrams per liter (mg/L) or parts
per million, when in reality ilie actual result was 470 rnicrograrris per liter.
( ug/L) or parts per billion for Benzylic Acid and Benzophenone. ' According to,;,.
the laooratory that· ran the analyses, IT Corporation, the error was due to thet
failure of the lab to convert the w1it to mg/L when transcribing the raw
analytical data to ,1etcalf s, Eddy's worksheets. The second round of sampling
for this well showed a level of 1,200 ug/L for Benzylic Acid and Benzopherione.
The first sample (RI sample) c;as collected in June 1986 and t:1e second sample
~✓<:lS G)llected in O::::tobe:-1987. I
• • -2-
As part of this review, the Agency is planning to resample this well for
verification. The necessary arrangements will be made as so~n as possible.
This additional data will help the Agency make a determination on whether or
not to proceed with requiring the fixation/stabilization/solidification process ' called for in the Record of Decision or to substitute soil venting as the
source mitigation remedial action for DA-23.
If you have any questions, please contact Jon Bornholm at
Sincerely yours,
Patrick M. Tobin, Director
Waste Management Division
cc: Phillip Brooks, DOJ
Reuben Bussey, ORC
William Meyers, NCDHR
Mike. Northridge, OCEM
I
[phone].
.I
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•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30315
• · ,, : JUL 1 3 1988
4WD-SFB
Ms. Lee Crosby
NCDHR
P.O. Box 2091
Raleigh, NC 27602
Re: Confirmation of July 26, 1988 Meeting on the draft Consent
Decree for the Remedial Design/Remedial Action (RD/RA) at the
Chemtronics Superfund Site I:
,.
Dear Ms. Crosby:
This letter confirms that the first meeting with all involved parties to
discuss the Chemtronics draft Consent Decree (CD) for the RDiRA is to be held
in Region IV's office in Atlanta. The meeting is to begin at 10:00 a.m. in
Waste Management Division Conference Room on the second floor. The Agency
encourages all parties to participate and negotiate in good faith.
The Agency is prepared to discuss the general language of the CD as well as
begin discussing language to be incorporated into the CD that satisfies the
requirements specified in the Chemtronics Record of Decision:(ROD) document. ' The Notice/Moratorium letters were mailed to the Potentially 1Responsible
Parties (PRPs) on June 17, 1988. To allow for variance in the postal system, I
would like to designate June 23, 1988 as the beginning date of the RD/RA
moratorium period. If any party received their letter after ·June 23, 1988 and
would like to identify a different date for the initiation of'. the moratorium
period, please voice your preference at the.July 26, 1988 meeting.
The Agency feels the RI/FS was a superb success and I want to' ·affirm our
intention to continue to nurture a positive working relationship with the PRPs
as well as with the other governmental entities. We anticipa'te that the RD/RA
process will be as successful.
The following individuals have been notified of this upcoming'meeting:
Nancy Bethune,.RCRA
Reuben Bussey, ORC
Charles Case, Chemtronics
Lee Crosby, NCDHR
John Dickinson, RCRA
Robert Homiak, DOJ
I, 1',
Greg Reese, RCRA : ~-
James Rogers, Hoechst Celanese
Gary Rowen, Hoechst·cetanese
Pam Sbar, OECM , '
John Schultheis, Chemtronics
Gary Serio, Northrop
Anthony Young, Northrop;
-2-
If you have any questions, please feel free to contact me
Sincerely yours,
)rt K lxti•-<. v-
Jon K. Bornholm
Superfund Project Manager
J
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[phone].