NCD981021157_19920528_New Hanover County Airport Burn Pit_FRBCERCLA RI_Remedial Investigation 1991 - 1992-OCR

MEMORANDUM
DATE: MAY 2 8 1992
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
RECEIVED
JUN 5 1992
SUPERFUND SECTION
SUBJECT: Approval of January 1992 Remedial Investigation Report
f the New Hanover County Airport Burn Pit Site k 80'wJ <...-------
FROM: K. Bornholm
Remedial Project Manager
TO: Site File
This memorandum approves as final the January 1992 version of the Remedial
Investigation (RI) report for the New Hanover County Airport Burn Pit Site
located in Wilmington, North Carolina. The report was prepared by Fred Sloan
in the Hazardous Waste Section, Environmental Compliance Branch,
Environmental Services Division, Region IV, EPAa The revised RI addressed
the significant comments generated by the review of the draft RI, dated
August 1991. The revised RI was transmitted for review in January 1992 and
as no pertinent comments were received, the Agency has accepted as final the
January 1992 New Hanover County Airport Burn Pit Site RI report.
cc:. Elmer Akin, EPA
Bill Bakey, ESD
Dennis Burks, NHCDEM
Raymond Church, NHCDEM
Lee Crosby, NCDEHNR
Bernie Hayes, G-WTSU
Jamee Lee, DOI
Ramiro Llado, ORC
William Meyer, NCDEHNR
Letitia O'Connor, HQ
Lee Page, APTMD
John Walch, NCDEHNR ✓
Printed on Recycled Paper
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. Jon K. Bornholm
Remedial Project Manager
10 March 1992
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: [N.ewHanov~r_Cot1n!yJ\irport-Burn•Pit ~PL Site
Comments on Revised Remedial Investigation Report and
Third Round Sampling Data
Dear Mr. Bornholm:
William L. Meyer
Director
As per our telephone conversation of 6 March 1992, we have reviewed the New
Hanover County Airport Burn Pit Revised Remedial Investigation Report and the data from
the third round of sampling at the site and are providing the comments:
Comments 1 through 3 refer to the EPA "Response to Comments" letter 6 November
1991, attached.
(1) Response 1: The Agency was to provide groundwater level measurements to
define groundwater flow patterns. This information was not included with the
third round sampling data.
(2) Response 5: The figures showing soil sampling locations have not been
changed or noted to indicate where actual samples were obtained.
(3) Response 6: Visual inspection may not detect all possible contaminants.
Were leaking drums sampled? If drums were not leaking, please revise
figures.
( 4) Appendices D and F are missing from the Revised Remedial Investigation
Reports sent to the NC DEHNR.
An Equal Opportunity AJftrmalfve Actton Employer
\
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Mr. Jon Bornholm
10 March 1992
Page 2
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(5) Comments on the Draft Remedial Investigation plan by the NC Division of
Environmental Management were not addressed. A copy of the comments
are attached.
(6) Please provide the actual dates and times of sample analysis for the third
round samples.
(7) The map provided with third round sampling data does not indicate where
SFC-001 Scagars well is located. Please locate.
Please contact me at [phone] if you have any questions regarding these
comments.
JWW/acr
Enclosures
~"LJ.rJli
John W. Walch
Environmental Engineer
Superfund Section
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James _G. Marlin, Governor
William W. Cobey, Jr., Secretary
· Mr. Jon K. Bornholm
Remedial Project Manager
6 February 1992
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Comments on the New Hanover County Airport Burn Pit NPL Site
Revised Remedial Investigation Report
Dear Mr. Bornholm:
William L. Meyer
Director
Your letter of 6 November 1991, responding to the North Carolina Superfund
Section's 4 September 1991 comments, indicates an additional round of groundwater
sampling, collection of water level data, installation and sampling of another temporary well
and sampling of the nearest private wells will be conducted as part of the Remedial
Investigation. This information was not provided in the 16 January 1992 Revised Remedial
Investigation Report. We would appreciate receiving a copy of this information. If you
have any questions, please contact me at [phone].
CJ/aci-
Sincerely, ut~u,iv Vr-U(
Charlotte Jesneck
Superfund Sectio
An Equal Opportunity .A.'~m,ative Acrion Employer
,.,._STAT["'
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•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. Jon K Bornholm
Remedial Project Manager
27 December 1991
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: New Hanover County Airport Burn Pit NPL Site
Additional Comments on the Draft Remedial Investigation Report
Dear Mr. Bornholm:
William L. Meyer
Director
Attached are additional comments from the Division of Environmental Management
on the Draft Remedial Investigation Report. Please contact me at [phone] if you
have any questions.
CJ/acr
Attachment
Sincerely,
~w!v!li~
Charlotte Jesneck
Superfund Section
An Equal Opportunity Affirmative Action Employer
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State of North Carolina O("C t/t,~
Department of Environment, Health, and Natural ~urc~Ji /, 14..t)
Division of Environmental Management ,c'q.f'b :99/
512 North Salisbury Street O Raleigh, North Carolina 27604 ;s'~QO,t
James G. Martin, Governor
William W Cobey, Jr., Secretary
December 10, 1991 George T Everett, Ph.D.
M E M O R A N D U M
TO:
FROM:
SUBJECT:
Lee Crosby, Chief
Superfund Section
George T. Everett, Director -,jJo-,,...~
Division of Environmental Management
New Hanover County Burn Pit Site
Review of Remedial Investigation Report
Wilmington, North Carolina
New Hanover County
Project #91-52
Director
The Division of Environmental Management has reviewed the subject
report as requested. The comments from our Water Quality, Air
Quality and Groundwater Sections are provided below:
Water Quality Section:
In reference to the subject document, it is inferred in
Section 3.2.2 "Site-Specific Surface Water Features," there
exists the possibility of a storm water discharge from the New
Hanover County burn-pit site. Although an application for a
National Pollutant Discharge Elimination System (NPDES) Stormwater
Permit is not required, we would like to emphasize that you still
have to comply with all NP.DES stormwater regulations. A point of
contact for stormwater regulations is Coleen Sullins at 733-5083.
Air Quality Section:
No air quality issues are discussed in the subject report.
No permits are required at this time since no remedial action is
proposed. However, if and when remediation alternatives are
decided upon, permits for air quality may be required depending
upon technology and changes in the rules/regulations.
Asheville
704/251-6208
Fayetteville
919/48&154I
Mooresville
704/663-1699
Regional Offices
Raleigh
919/733-2314
Washington
919/94&648I
Pollution Prevention Pays
Wilmington
919/395-3900
P.O. Box 29535, Raleigh, 1North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
Winston•Salem
919/761-2351
• •
A "toxic review" will be required if permits are required for
remedial activities.
Groundwater Section:
According to 15A NCAC 2L, the potentially responsible parties
(PRPs) must define the extent, horizontal and vertical, of the
groundwater quality violations. The subject report does not
accomplish this. The "upgradient" monitoring wells show volatile
organic compounds, semi-volatile compounds, and chromium above 2L
standards. Also, the downgradient monitoring wells show chromium
and ((butoxyethoxy) ethoxy) ethanol above 2L standards. We
therefore, recommend expanding the assessment to define the entire
horizontal extent of these violations.
Moreover, the basal confining bed of the unconfined aquifer
is discontinuous in this area, so we also recommend that an
appropriate level of assessment be performed on the semi-confined
aquifer.
The section realizes that the soil excavation has already
occurred at the subject site, but it appears that the test methods
used were not the ones that the Groundwater Section requires. Our
standards require that soils containing petroleum fuels be tested
by using the total petroleum hydrocarbon (TPH) test methods, and
soils would have to be remediated -removed, in this case, to less
than TPH concentrations of 10 parts per million (ppm) for the
remaining soil. We recommend that soil samples be collected
based on a grid laid out across the subject site and analyzed for
the appropriate TPH test methods.
The Section recommends that a unit concentration type be
added to the right of "non-carcinogenic PAH's" in table 2-2.
No explanation concerning the disposal of the excavated
contaminated materials was offered in the report. We understand
that the material was disposed of properly.
Isoconcentration maps would be helpful in illustrating the
results of the groundwater and soil analyses.
Some of the acronyms used in the report are left undefined.
We recommend adding these definitions in future reports.
Specifically, we reference "TCL", "TAL", and "CLP".
Should you need any additional information, please contact
Preston Howard, Wilmington Regional Office at [phone].
003.RGE
Attachments
cc: Perry Nelson
Steve Tedder
·Lee Daniel
Preston Howard
Nargis Toma
File
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
NOV 6 1991
4WD-NCRS
Ms. Charlotte Jesneck
North Carolina Department of Environment,
Health an.d Natural Resources
401 Oberlin Road
Raleigh, NC 27605
RE: Response to Comments on the Draft Remedial Investigation Report for the
New Hanover county Airport Burn Pit superfund site
Dear Ms. Jesneck:
The Agency received your comments on the above referenced document on
September 10, 1991. Fred Sloan with ESD in Athens and myself reviewed all
comments received on the draft RI report on Monday, October 21. Below
details how we addressed the State's comments with respect to revising the RI
report. If a specific comment is not incorporated, an explanation is
provided as to·why this particulate comment was not incorporated. Enclosed
are copies of all the comments received on the draft RI and superfund's
response to these comments.
Response to comment 1, the Agency will collect a third round of groundwater
samples during the ·week of November 18. As part of this effort the
following activities will be done: l) sample all existing on-site
monitoring wells, 2) measure and record groundwater levels in each well, 3)
install and sample a temporary well northwest of the burn pit ·at the
boundary of the site, and 4) sample the nearest private, potable wells
either downgradient or lateral to the regional groundwater flow direction.
All groundwater samples will have full analytical scans ran on them. Full
analytical scans include volatile organics, semi-volatile organics, and
metals. The temporary well will penetrate the same water bearing zone as
the other monitoring wells on site, the upper sandy aquifer. And finally,
the Agency has asked the county of New Hanover to conduct a well
inventory. The nearest wells as well as the Airport well located
immediately downgradient of the site will be sampled as part of the
November 18 effort.
Response to comment 2, noncarcinogenic hazard indices and carcinogenic human
health risks will be determined in the Risk Assessment.
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Response to comment 3, the sample collected from the septic tank is defined
as sediment and the need for remediation will be determined by the Risk
Assessment.
Response to comment 4, these corrections will be made.
Response to comment 5, the sampling locations reflected in the figures
represent where flags were placed so that the surveyor could see them. The
soil samples represented by these flags were usually collected from within
and at the bottom of the excavations. since the surveyor would not have
seen the flags there, the flags were placed at ground level. The figures
will either be altered to reflect this fact or a footnote will be added to
explain this.
Response to comment 6, upon visual inspection of the soil after the drums
were removed, no visual evidence of any leaked material was seen and
therefore, no soil samples were collected. This inspection was conducted
by an Agency's representative from the Environmental services Division
(ESD).
Thanks for your comments on the draft RI. If you have any questions or
additional comments, please contact me at [phone].
sincerely yours,
jn K f:»h'J r__--
Jon K. Bornholm
Remedial Project Manager
Enclosures
cc: Lee Crosby, NCDEHNR (w/o encls)
William Meyer, NCDEHNR (w/o en_cls)
• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
NOV 6 1991
4WD-NCRS
Ms. Mary Leslie
CDM-FPC
701 Scarboro Road
Suite 3005
Oak Ridge, TN 37830
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
RE: Response to Comments on the Draft Remedial Investigation Report for the
New Hanover County Airport Burn Pit Superfund Site
Dear Ms. Leslie:
The Agency received your comments on the above referenced document on
saptembe~ 11, 1991. Fred Sloan with ESD in A~hens and myself reviewed all
com.'nents recei7ed on the draft RI report on Monday, October 21. Beiow
details how we addressed your comments with respect to revising the RI
t:eport. If a specific comment is not incorporated, an explanation is
provide:d as ":.·~ why this particulate comment was not incorporated. Enclsoed
at:e cop.L,;:s of c:l.11 the comments received on the draft RI and Superfund's
response to t!-:t=se: comments.
B~lcw are the t:.gency' s responses:
F,:ir co:.mnents .1--:lr the Agency will attempt to generate the requested
inforraatio::.-i..
i:'"'or comma,nt 5, soil samples BP-01 and BP-02 were collected from the drainage
ditch. Neitl:er sampled indicated the presence of contamination. An
additional surface soil sample from the ditch will be collected as part of
th8 Novembet: 18, 1991 sampling effort. Please refer to the Agency's lette_r
dated October 29, 1991. As you know, there are only two locations where
surface water could migrate off the Site as the raised road bed that
su~rounds the site acts as a berm. -The two locations where a culvert runs
underneath the road were sampled. These sampling points were designated
NHOOl-SC and llH003-SL in the draft RI report. Neither of these samples
showed the presence of contaminants.
For comment 6, with the help of the County of New Hanover, the Agency will
attempt to sample several downgradient private, potable wells. as part of
the November 18 sampling effort .
. For comment 7, the groundwater encountered in the two sandy aquifer zones at
the Site discharge to Smith Creek and the Northeast Cape Fear River.
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~or '~ommen~· 8, as: ioJ ~~_,;.;-th~ Site -is flat, therefore, please refer to
USGS Castle Hayne, N.c;'quad topographic map for the topography of the
and surrounding area.
the
Site
It is presently anticipated that the majority of the samples, if not all of
them, collected during the November 18 sampling effort will be analyzed
"in-house" and therefore, the QA'ed data should be available prior to
Christmas.
If you have any questions, please contact me at [phone].
Sincerely yours,
Jon K. Bornholm
Remedial Project Manager
Enclosures
cc: Raymond Church, NHCDEM
R .:;1.;JON IV
.. 345 couR· LAND STREET. N.E.
ATLANT.A GEORGiA 3036?
4WD-NCRS
Mr. Raymond L. church, Jr.
Director of the Department of Environmental Management
county of -NeW .-eanOver · ·
3002 U.s.·:'eighw;._y, 421 North
Wilmington, _North Carolina 28401-9008
RE: Response to Comments on the Draft Remedial Investigation Report for the
New Hanover County Airport Burn Pit superfund site
Dear Mr. church:
The Agency received your set of comments on the above referenced document on
October 2, 1991. I spent Monday, October 22, 1991 in Athens with Fred Sloan
to review and respond to all comments received on -the draft R; report.
Below are the -A~0nCy ,' S. responses to the c·?unty, s c_~mments: ·
Response to comment 1 on section 3.2.4, the pit may have contributed to the
mounding effect in tpe groundwater. ·If this was the case, then this could
imply that the contaminants in the pit leaked out along with the water
which would have created this mounding effect. If this was the case,
higher levels of contamination would be expected to be seen in the
groundwater.
Response to comment 2 on section 3.2.4, the classification of the aquifer is
a.major component when determing wh~ther or'not remediation of an agui~er
is necessary. The upper sandy aquifer,· the aquifer above the blue-gray
clay layer, the lower sandy aquifer,' the aquifer immediately below the
blue-gray clay layer, and the castle Bayne limestone aquifer beneath the
lower sandy aquife·r ·are all classified ·as 'either IIA or IIB. Clas·s IIA
aquifers are defined ~s a~if8rs'cUrr0ntly being used as a source o~
drinking water and .. Class IIB aquifers·are aquifers.that have the potential
to be used as a source of drinking _water. For both types of aquifers, the
Agency is tasked with protecting these aquifers to drinking water
standards. Therefore, MCLs will ably to the upper sandy aquifer as this
aquifer is classified as a potential source of drinking water.
Response to comment 1 on Section 5.0, it is typically just as expensive to
analyses for a set number of contaminants as it would be to run full
scans. Therefore, the third round of samples will be analyzed for volatile
organics, semi-volatile organics, and metals. The majority of these
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s~ples will be ran "in-house" which should help control the cost some. In
addition, as can b9 seen in some of the other comments on the draft RI,
there is some concern with respect to the quantation limits established for
the first rounds of analyses. The lab will be instructed to keep the
quantitation limit below either the treatment level or MCLs.
Response to comment 2 on Section 5.0, suggestions are noted.
Response to comment 1 on Appendix c, your comment is correct, the date on
this memo should be 1991 and 1990.
Response to Item # 1 on page 2' comment has been noted.
Response to Item # 2 on page " ccrnment has been noted. .. '
Response to Item# 3 on page 2, there is no implication in the RI report that
generally accepted field prccedures w1~re not required for field work
performed at this site. Proper field decontamination procedures were used
throughout the study, as described in the us-EPA, Region IV, Environmental
Services oivisi.on, Environmental Compliance Branch standard Operating
Procedur,as· and Qt:ality Assu!:."ance Manual, (ECBSOPQAM), February 1, 1991.
The samples and field equipment used in the screening study were
contaminated witll isopropanol and acetone (a precursor of isopropanol)
because field p1:::\:·5onnel we1:-e 111:1!'.amiliar with some screening equipment which
was boi:rowed s9ecifically for this study. It must De emphasized that this
contamination had no impact u~on the screening study or the subsequent
investigation. 'l'he isopropancl used during this investigation was
purchased from Fi3her scienti::'ic an::. c::ansported L'.nopened to the field.
The isopropancl ',\:,3.s pestic.id.e grade.
Respons,3 to Item # '-1 on page 2,. the ani1lyt.ical rr,ethcci;;.; used to determine
naphthalene conc::ntration a::i;: the st:::.ndard methoe'.s '.1:::ed nationwide by
US-EPA to yield data of the highest c:_uality. Tl.1.e C2.ta presented for
naphthalene is considered ti:; i:e adequ,ite for any decision making purposes.
The data is gual:.tied because the ccncentratior:s de-:..,2;cted are so low.
Response to Item# 5 on page 2, the lat~rat~ry that analyzed the soil samples
collected during the confirmation sampling was net reimbursed for expenses
for four of these samples. Monies paid to the laboratory were reduced for
the remaining samples for each violation of contract protocols.
Response to Item# 6 on page 3, lead ani chromium are co~only found in grout
and bentonite blanks at low ccncentra,:.ions. These elements are naturally
present in the environment, and their occurrence at low levels in these
materia).s does not materially affect the study. Blanks are taken because
these materials are often present. The presence of xylene at low levels in
the grout blank also do not affect the quality of the data. Xylene was
present in the blanks at concentrations well below that found in the
groundwater samples. No xylene was detected in any other quality assurance
sample.
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MEMORANDUM
DATE: NOV 6 1991
SUBJECT:
FROM:
Response to Comments Received on the Draft R~medial Investigation
Report for the New Hanover County Air,POrt Burn Pit.Superfund Site
JoJ/~'v;;;,r;;;;;;
Remedial Project Manager
TO: Jennifer Herndon, Hydrogeologist
Ground-Water Technology Support Unit .. }
I received yours comments on the above referenced document on September 24, . ~ . . ._ . . . . -1991. Fred Sloan with ESD in Athens and myself reviewed 'all comments _,
received on the draft RI report on Monday October '21. 'As· ·you will ·rec~i"i";·'r
met with you on Wednesday, October 23 to review some of your comments in._.-
greater detail. Below details which of your comments will be incorporated
into the revised RI report. If a specific comment· is nOt incorporated, .an
explanation is provided as to why this partiCulate ··comment was not .. '
incorporated. Attached are copies of all the comments received on .the \ir'~ft: ·
RI and Superfund1 s response to these comments.
Response to ycur first comment, both the upper and lowe~. sandy aquifers will
be classified in the revised RI report· as class IIB and .IIA, respective·1y.
Response to comment 1, we have asked the County of New Hanover to help us
conduct a well inventory. We will sample the nearest wells identified -as
well as the Airport well located immediately downgradient of the Site.· __
This sampling effort is to occur the week of NoVember ·1a ~
Response to comment 2, during our November
on-site monitoring wells will be sampled.
ran on all samples collected.
18 sampling effort, all existing
and full· analytical scans will_ }>e
. ' .
Response to comment 3, if the level of groundwater contamination in the upper
sandy aquifer warrants remedi"ation, as determined in the Risk Assessment,
then a minimum of two deep wells, completed in the lower sandy aquife"r,
will be ,installed as part of the remedial design.
Response to comment 4, preliminary remediation goals for this site were
establishe~ by Becky Fox, in the Health Assessment Unit. Final cleanup
goals will be established in the Risk Assessment, which is still.under
development.
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Response to comment _5, sample points designated BP-17 through BP-20 provide
the 'information requested in this col11Itlent. These samples we.re col le ;ted
either prior. to or during the rem<;>val activities in December of 1990.
Response to comment 6, as part of the November 18 sampling effort, ·a
temporary well will be installed northwest of the burn pit at the boundary
of the site. This well will penetrate the same water bearing zone as the
other monitoring wells on site, the upper sandy aquifer. The groundwater
sampled collected from this well will be sent for full scan analysis.
Re~ponse to comment 7, the findings of the endangered species survey wil~ be
included in the revised RI.
Thar.!cs fer your comments on the draft RI, if you have any questions or
additional comments, please contact me at X-7791.
Attachments
cc: Fred Sloan, ESD
DATE: NOV 6 1991
SUBJECT: Response.to conunents Received on the Draft Remedial Investigation
Report 'fcir the New B~nover,coun'ty'Airpcirt 0Burri Pit'superfund site
Jon1.~~-:··· .. .
FROM: . . ' . .
·: Remedi~},;P~~-~~-~~. Man~~-e': .. _ ••:."•J.
··: ... ~. ,.
TO: Julie W: Ke'iieic"; Toxicologist
Health Assessment Unit
.:, ..
I received your c_c~munentS ol\ the.'.above refer;nced docUIIlerit on -, , ., ' . • . ., . .., ' •. ·-·•·-1·"'·:·•· .,. . ..
September 5, 1991:· Fred Sloan with ESD ·in'Athens ;and myself reviewed all
conunents received on the draft .. RI report cin'M~n~at'/ octob;,r·_21 •. Below
details how we addressed your conunents with resi,ect to revising the RI
report. If a specific ·Comment is not inCoI:'Pc;;·.rat8d/:_ran explanation is •· ,· . • .. ,,_-.,r,-~••~••w; .• • ,•. I • • • , !." •' ·•J.~·.'.;'i'~''•,:c::~-l'';l'·: ·~•: (_ •• _:.,;~, ... , .• .. -, .. :;•:• ';,•,77"•~•.: ''. provided as to why this "particulate conunent "Was.:not ·incorporated. ,'!Attached
are copies of all_ the c?minen~s reCeived· on-~~f'.~~~f~~ ~-1··.-~n~.:-.;~_dperf~~~-~-~· ' 'i-
response to these comments · ·· •.::_;::· ~-·:-: ' · . . . . . ·:· .
-. . .:::·~·/:-::{:,;:·~~-, ·_: .
Response to your first conunent, Fred Sloan is aware of this and will
highlight this. point .. to ... the·· lab when the lab "analyzes the-third round of . '.: ..
groundwater samples •. These samples will ti·e c'oii.;,cted the week of November
18 and will probably ·b;,,-ana.lyzed •in-house•'. -~,, · .......... ,.
Response ~o comm~?t
scans ran on them
and metals.
2, all
which
groundwater samples '·.will ·have fuil analytical
includes volatile·.:~~i~f~-~, ·send-volatile -~I'cjani_cs,
., ··;. -~-_. .. ' ~. .
Response to
Response to cominenf · 4 ,'_~th.iS
section of the report.·
Attachments
cc: Elmer Akih, Health Assessment Officer
to the_appropriate
Printed on Recycled Paper
• UNITED STATES ENVIRONMENTAL PROTECTION AGEN~c
REGION IV '-l"J:.111.11:-
345 COURTLAND STREET NE Der .,1 <:D
ATLANTA. GEORGIA 30365 'v ,,
SUp[RFu, sg;
OCT 1 8 1991
4WD-NCRS
Mr. Raymond L. Church
New Hanover County
Department of Environmental Management
3002 U.S. Highway 421 North
Wilmington, North Carolina 28401-4340
'ND S[CTtotv
RE: Well Survey In and Around the New Hanover County Airport
Burn Pit Superfund Site
Dear Mr. Church:
I received your comments on the draft New Hanover County
Airport Burn Pit Superfund site Remedial Investigation (RI)
report on October 2, 1991. Currently, I am anticipating that
the draft RI report will be revised by mid-November.
As can be seen in the set of comments I sent you on the draft
RI, a number of reviewers strongly advised the analysis of a
third set of groundwater samples from the monitoring wells at
the Site. For your information, these samples will be analyzed
for the full range of contaminants on the Target Compound List
(TCL) and Target Analyte List (TAL). The TCL includes volatile
organic compounds, extractable organic compounds, PCBs, and
pesticides. The TAL includes the metals and cyanide (i.e.,
inorganics). I am anticipating this sampling effort to occur
in late November 1991.
Another data deficiency identified in the review of the draft
RI report was the lack of a well inventory in and around the
Site. It is to this end that I request your assistance. The
only well survey information I was able to find in the New
Hanover site file is the one included in the Hazardous Ranking
Score (HRS) package, dated June 1986. In this report, the
following information is provided:
Identified water-supply well(s) drawing from
aquifer(s) of concern with a )~mile radius and
populations served by each:
· Printed on Recycled Paper
• •
-2-
Population Served by Ground Water Wells Within a
3-Mile Radius
Active Communitv
Well Systems
1. Brookfield S/D
2. Carol C MHP
3. Double D MHP
4. Glynnwood MHP
5. Oakley MHP
6. Town and Country MHP #1
7. Walnut Hills S/D
8. New Hanover County
Water System
TOTAL
Population Served
350
125
60
300
80
120
595
250
1,880
In addition, there are approximately 4,409 people
using private wells within the 3-mile radius of
the site.
I am requesting the support of New Hanover County Department of
'Environmental Management to help locate all potable wells
within a ½-mile radius of the Site. It is important that these
potable water supply wells (private/commercial/municipal) be
identified as soon as possible as it is the Agency's intention
to sample the nearest one(s) that are excessable along with
sampling of the on-site monitoring wells.
It is important to identify and sample the nearest potable
well(s) as this information will be used in the development of
the risk assessment. As you may be aware of, the findings of
the risk assessment drive the need for remediation at a
Superfund site. If no potable wells are sampled and depending
on the distance from the Site to the nearest potable well, it
may be necessary to use the analytical data from on-site
monitoring wells to assess the current risk posed by
groundwater contamination to human health at that particular
potable well. This would provide the worse case scenario which
is the most conservative and protective approach the Agency can
take. Therefore, it would be very beneficial to use actual
·analytical data for a sample collected from the nearest potable
well(s) to show that the quality of the aquifer supplying water
to the potable well has not been adversely impacted.
The risk assessment calculates the risk posed by a Site under
present conditions as well as in the future. In both
situations, a "worse case scenario" is used to calculate the
actual or potential risk. In determining future risks posed by
contaminated groundwater beneath a Site, the Agency typically
• • -3-
assumes that a private potable well is installed on the Site.
I have heard that the County or City is interested in having
the property where the Site is located as well as the
surrounding property be developed into an industrial park. If
you can provide sufficient information to the Agency
corroborating this understanding, then this worse case scenario
can be revised or modified in the risk assessment accordingly.
As implied above, any information the County can supply the
Agency with respect to the well survey needs to be submitted by
November 18. For your convenience, my facsimile number is
[phone]. I would like to thank you in advance for your
assistance in this effort.
If you any questions, please give me a call at [phone].
Sincerely yours,
t:~~~
Remedial Project Manager
cc: Dennis Burks, NHCDEM
Charlotte Jesneck, NCDEHNR
Fred Sloan, ESD
• • • UNITED STATES ENVl'r<Ol'<i~-ENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
MEMORANDUM
DATE:
SUBJECT:
FROM:
TO:
SEP 1 a \991
comments on Draft Remedial Investigation Report for the
New Hanover county Airport Burn Pit Superfund site
J~~~-
Remedial Project Manager
Fred Sloan
Hazardous waste section
Environmental compliance Branch
Environmental services Division
As requested, two copies of the above referenced document were received on
August 13, 1991. Numerous copies were subsequently made and distributed to
the State of North Carolina Department of Environment, Health & Natural
Resources (Charlotte Jesneck), New Hanover county Department of Environmental
Management (Dennis Burks), U.S. Department of the Interior (James Lee), U.S.
Department of Commerce/National oceanic and Atmospheric Administration (John
Lindsay), Agency for Toxic substances and Disease Registry (Chuck
Pietrosewicz), Camp, D~esser & McKee (Mary Leslie), Region IV Health
Assessment officer (Elmer Akin), Ground-Water Technology support unit (Bernie
Bayes), Laboratory Evaluation & Quality Assurance Section (Wade Knight), and
Air, Pesticides, and Toxics Management Division (Lee Page) for review and
comment. Comments were requested by September 9.
Attached are the comments I have received to date. I will transmit any
additional comments I receive to you immediately. Below are my comments.
All comments embodied in the text of this memo and those attached need some
type of response, either acknowledging that the requested change has been
· incorporated into the_report or a statement explaining why the requested
change was not warranted and the supporting rationale. If there is any thing
I can do to help revise the draft report based on these comments, please do
not hesitate to ask for support.
1. General comment: somewhere in this report the fact that RI derived
waste was generated and stored on-site needs to be made. This report
should also state what disposal options are available for this RI
derived waste and what information is needed in order to make a
selection on disposal.
Printed on Recycled Paper
. ,. • •
-2-
2. General collDllent: The findings/conclusions of the endangered species
survey need to be incorporated into this report.
3. Index page listing Appendices:
listing of all the figures and
included here. For example,
under both Appendix A and Appendix B, a
tables and their titles needs to be
APPENDIX A:
Figure 2-1
Figure 2-2
etc.
APPENDIX B:
Table 2-1
Table 2-2
etc.
FIGURES
Site Location Map
site Map
TABLES
Preliminary Remediation Goals for Groundwater
Preliminary Remediation Goals for Soil
This allow easy reference to information presented in the report.
4. Page 1, section 1.0 Introduction, first paragraph: The source of the
aerial photographs referred to in this paragraph need to be referenced
(i.e., New Hanover county Airport Burn Pit superfund site Site
Analysis Environmental Photographic Interpretation Center (EPIC)
report (TS-PIC-90109), dated August 1990.
5. Page 1, section 1.0 Introduction, first paragraph, last sentence: Bas
the burning of confiscated drugs in the pit been
confirmed/documented? or_ has this occurrence only been reported? I
have not seen any documentation substantiating this claim.
6. Page 2, Section 1.2 Site status: Additional information needs to be
incorporated into this section or in section 2.1 that states when the
site was finalized on the NPL, the HRS score, and its ranking. Below
is information that needs to be incorporated. The Site was proposed
on the NPL in June 1988 and was finalized on the NPL in March 1989.
The site ranked 518 out of 1218. The HRS total score was 39.39 with
the following Route Scores of 67.69 for groundwater and 7.83 for
surface water and 0.00 for air.
7. Page 2, section 1.2 Site status, second paragraph, first sentence: As
we are referring to past tense, this sentence should be changed to
read, "EPA gave approval to the PRP's ••• •.
8. Page 3, Section 2.1.1 Location:
lies east and west of the Site,
what is to the north and south.
Since this paragraph identifies what
this section also needs to identify
9. Page 3, Section 2.1.2 History, first paragraph: I would suggest
splitting this paragraph into two paragraphs making the split after
the fourth sentence.
0 •
-3-
10. Page 3, Section 2.1.2 History: Add an additional paragraph following
the first paragraph as the report is now presented. In this
paragraph, restate the HRS score, the dates the Site was proposed and
finalized on the NPL, summarize the investigation and data collected
during the preliminary investigation and site assessment. This
paragraph should highlight the contaminants found, in what
environmental media, and act what concentrations. A figure should
also be included identifying sampling points.
11. Page 3, section 2.1.2 History, second paragraph, last three
sentences: Reading these three sentences together makes it sound like
since the PRPs did not do what the Agency wanted, we placed the site
on the NPL as a consequence. This paragraph needs to be rewritten,
may be with the concept expressed in comment number 10. in mind.
12. Page 4, section 2.1.2 History, paragraph at top of page, third
sentence: Change this sentence to read, "PRG'a are subject to change
and may be modified during the RI/FS process.• As currently written,
this sentence implies that the PRGs trivial and insignificant.
13. Page 4, section 2.1.2 History, paragraph at top of page, last
sentence: Change this sentence to read '"The PRGs and their
derivations are included as Appendix c.•
14. Page 4, section 2.1.3 Physical Features, first paragraph, fourth
sentence: I suggest using another verb such as "obtained" instead of
"removed" as this term has been associated with the removal" action.
15. Page 4, section 2.1.3 Physical Features, fourth paragraph, fourth
sentence: The valve controlling flow to the burn pit is not
incorporated into any of the figures. If this valve is the same as
the junction box, the the last sentence needs to be altered as this
junction box controlled flow to all four firefighter training areas
including the burn pit.
16. Page 4, section 2.1.3 Physical Features, last paragraph, first
sentence: This is the first time that confirmation sampling is
mentioned and therefore it is a little confusing. The removal and
accompanying verification (i.e., confirmation) sampling should be
first cited in section 2.1.2 site History.
17. Page 5, section 2.2 Removal/RI soil Sampling, second paragraph, first
sentence: Typo -Change • ... as follows: Following the
excavation/removal ••• • to read ..... as follows: following the
excavation/removal ......
18. Page 5, section 2.2 Removal/RI soil Sampling, second paragraph, first
sentence: Change the end of this sentence to read • ••. 18 composite
soil samples were collected from all excavated areas to confirm/verify
that the removal action removed the contaminated soil and reached
clean soil.".
0 •
-4-
19. Page 5, section 2.2 Removal/RI soil sampling, second paragraph, second
sentence: This sentence as presently written is a little confusing.
Is it necessary to state that these samples were collected as surface
soil samples? or can it be state that they were collected from the
soils found at the bottom of the excavations?
20. Page 5, section 2.2 Removal/RI soil Sampling: why not incorporate
Section 4.2.1 into this section?
21. Page 5, section 2.3 Enforcement Profile: It needs to be stated in this
section that the PRPs performed the removal action under a signed
Administrative order on consent, signed in June 1990. And that the
removal was overseen by the Agency.
22. Page a, section 3.2.3 Regional Groundwater Features, first paragraph:
This is the first time the Pee Dee Formation is mentioned. If it is a
geological formation, why is it not discussed in either section 3.1.1
Regional Geology or Section 3.1.2 Site-specific Geology?
23. Page 10, section 3.2.3 Regional Groundwater Features, first full
paragraph at top of page, last sentence: This sentence makes a
statement that needs to be referenced.
24. Page 10, section 3.2.4 site-specific Groundwater Features, first
paragraph, second sentence: I believe this is the first time the
acronym NGVD-29 is used and therefore, it needs to be spelled out.
25. Page 11, section 4.1.1 Temporary Piezometers, second sentence: If the
hollow steel rods were stainless steel, then this fact should be stated.
26. Page 11, Section 4.1.1 Temporary Piezometers, last sentence:
Figure 4-1 does not provide the results of the water level survey as
stated in this sentence. This information is presented on Figure 3.3.
27. Page 11, Section 4.1.2 Temporary Monitoring wells: fourth sentence:
Change this sentence to read •temporary well located approximately
70 feet southwest from the burn pit ••• •.
28. Page ll, Section 4.1.2 Temporary.Monitoring wells: fifth sentence:
change this sentence to read • ... presumed downgradient· direction,
approximately 40 feet south of the burn pit. contained no ••• ".
29. Page 11, section 4.1.2 Temporary Monitoring wells: Add another
sentence reading something like "Temporary monitoring well BP-22 was
located approximately 275 feet due north of the burn pit.•.
30. Page 12, Section 4.1.2 Temporary Monitoring Wells, paragraph at top of
page, second sentence: Refer to comment number 25.
. , ',
31.
• •
-5-
Page 12, Section 4.1.2 Temporary Monitoring wells, paragraph at top of
page, third sentence: change this sentence to read • ... the samples were
collected and analyzed for volatile organic compounds, semi-volatile
o=,r.,,g.,a,.n.,i,.,c._c=o.,,m.,p::,o,.,u,,n..,d"'s...._, _,,a.,ne,d,.__.i,.,n..,o"'r"-g=a.,,n~i"'c'--'a"n-"a"'l"y'""'t.,,e=s prior to placement ... " .
32. Page 12, Section 4.1.3 Permanent Monitoring wells: some discussion
needs to be incorporated into this section with respect to the
development of the wells.
33. Page 12, section 4.1.3 Permanent Monitoring wells, second paragraph,
third sentence: I am not comfortable stating "throughout the site
area". I feel it is better to state that this dense blue-gray clay
was encountered at approximately the same depth in the two other test
borings and the two borings for the two deep permanent monitoring
wells and then state, based on these five encounters, it is assumed
that this dense blue-gray clay layer is continuous across the entire
site.
34. Page 12, Section 4.1.3 Permanent Monitoring Wells, fourth paragraph,
seventh sentence: The thickness of the bentonite pellet seal should
be included in this sentence.
35. Pages 12 and 13, the carry over sentence: Since t~e deep well was not
installed in accordance to the E~BSOPQAM, Appendix E; dated
February 1, 1991, a detailed explanation as to why bentonite pellet
seals were not placed on top of the sand packs needs to be included.
This will help prevent future disputes with either our own contractors
or PRPs and their contractors on the construction of monitoring wells.
36. Page 13, section 4.1.3 Permanent Monitoring Wells, first full sentence
of page: The previous sentence, the carry over sentence between
pages 12 and 13, discussed only the two deep wells. As currently
written, this first full sentence carries on this thought and
therefore, implies that only the two deep wells had concrete caps and
pads.
37. Page 13, section 4.1.3 Permanent Monitoring Wells,·second paragraph,
first sentence: The date(s) the first round of samples was(were)
collected needs to be included in e_~ther this sentence or paragraph.
· 38. Page 13, Section 4.1.3 Permanent Monitoring wells, second paragraph:
The type of analyses ran on both set of samples needs to be stated.
39. Page 13, Section 4.1.3 Permanent Monitoring Wells, second paragraph,
seventh sentence: I suggest changing this sentence to read as
follows, •other contaminants of concern~ detected but at levels
below their PRGs ••• •.
40. Page 13, Section 4.2
laboratory problems
section.
Soil sampling: It is unclear why information on
with groundwater samples are included in this
• •
-6-
41. Page_l6, Section 5.0 Conclusions and Recommendations: This section
needs to attempt to define the extent of contamination as well as
assign an estimated volume of soil and/or groundwater impacted.
Figures depicting the text should also be included.
42. Figures 2-2, 3-1, 3-3, 3-4, 3-5, 4-1, 4-3, 4-4, 4-6, and 4-7: The names
of the roads should be included on.these figures.
43. Table 2-1, Note #1: The PRG for total concentration of carcinogenic
PABs is not to exceed 0.0002 mg/1. To the best of my knowledge, there
is no analytical method that determines the concentrations of
carcinogenic PABs only. The only why to derive the total.
concentration of carcinogenic PABs is to add the concentrations of the
individual compounds. Are the detection levels/limits such that this
concentration goal can be realized?
44. For all Tables: A clear definition of what all the information included
in the column headings needs to be incorporated; For example, on
Table 4-4, what does NB-00lGW mean? To make it clear, the four digit_
number in the column heading should be labeled as the time the sample
was collected. The other approach is to eliminate this extraneous
information if it is not needed.
Attachments
•
,era,,
' ~ 1;.
Q -;.
..,; 0
~ ~
~,~
l:G:ed States Department o~e Interior
OFFICE OF TIIE SECRETARY
Office of Environmental Affairs
Richard B. Russell Federal Building
75 Spring Street. S.W.
Atlanta, Georgia 30303
August 19, 1991
Mr. Jon K. Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, NE
Atlanta, GA 30365
Dear Jon:
---■
!:PA -REGION IV
P.. TLANT ! .. G !i.
I received your letter and three copies of the draft RI for the New
Hanover County Airport Burn Pit site, NC. I have forwarded copies
to U.S. Geological Survey and U.S. Fish and Wildlife Service for
review and possible comment back to you. Thank you for keeping us
informed.
cc: USGS, Raleigh
FWS, Raleigh
FWS, Atlanta
Sincerely,
James H. Lee
Regional Environmental Officer
Q
·-_,,
-· p:..~:.:... -. -:':~
~3-?: -~-r.=-·· -~---
MEMORANri~~-
DATE:
SUBJECT:
FROM:
TO:
THROUGH:
September 5, 1991
Review of the Draft Remedial Investigation Report, New
Hanover County Burn-Pit Site, New Hanover County, North
Carolina
Julie W. Keller~l6...,t,,{.v..,
Toxicologist 0
Jon K. Bornholm
Remeidal Pro~ect M/ger
Elmer Akin~
Health Asse~ent Officer
Per your request, I have reviewed the Draft Remeidal Investigation
Report for New Hanover County Burn-Pit Site, New Hanover County,
North Carolina. We concur with the recommendation that additional
sampling is necessary before conducting the baseline risk
assessment. The following comments and concerns should be
considered before additional sampling is conducted.
The sample quantitation limit for lead in groundwater (40 ug/L) is
unacceptably high for all samples. The contract laboratory program
contract required quantitation limit is 5 ug/L and the treatment
technique action level is 15 ug/1. The sample quantitation limit
is more than twice the treatment technique action level for all
onsi te groundwater samples. Lead is a potential 1 y critical
contaminant due to the nature of activities conducted at this site.
The samples from the second round of groundwater sampling were only
analyzed for volatile organic compounds. Metals were detected in
the_ first. sampling round, with chromium (58-82 ug/L) above levels
established-for the PRG's (50 ug/L). Semi-volatile compounds (2-,,._.~ , '••'~-• methylnaphtlialene and naphthalene) were also detected in the first
sampling}"'fi:p'.und. Therefore metals and semi-volatiles should not be
el imin~~'.¥om further investigations.
:t;~~;' ,.. .,._ .
Table 2-2-; tlie PRG for benzene should be 0.40 mg/kg not 0.41 mg/kg
(Table 3, PRG Memo from Rebecca Fox to Fred Sloan, 1/23/90).
It is unclear why information on laboratory problems with
groundwater samples are included in Section 4.2, Soil Sampling.
If I can be of further assistance or if you have any questions
please contact me at xl586.
M2nToch Environmental Tochnology, Inc.
™T Region IV, 545 Kesemn D~. Suite A, Athens, Georgia 30605 4-04-546-761 I . FAX [phone]
Date
From
Subject
To
September 17, 1991
ATSDR Senior Regional Representative
New Hanover County Airport Burn Pit;
New Hanover County, North carolina
Jon Bornhol:m, Remedial Project Manager
U.S. EPA WMD NSRB
• Public Health Ser,,ice
Agency for Toxic Substances
anci Disease Registry
Memorandum
,
As requested, the Draft Remedial Investigation Report, dated August
1991, for the above site has been reviewed. We have no substantive
comments to offer on this docurrent. All of the recornmen:lations made
in ATSDR's May 1990 Prelintinary Health AssesSll'e11t for this site have
been addressed either during the renoval action or the con::luct of the
investigation.
If we can assist further, please feel free to contact either Bob Safay
or myself.
Ctw~l-
Clluck Pietrosewicz, R.H.S.P.
cc: file; Bob Safay; OAA,IORO
-•
COM FEDERAL PROGRAMS
September 6, 1991
Mr. Jon Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Project: EPA contract No. 68-W9-0056
Document Control No.: 7740-005-EP-BDDY
CORPORATION
Subject: Comments on Draft Remedial Investigation Report
New Hanover County Airport Burn Pit Site
Wilmington, North Carolina
Work Assignment No.: 05-4L5Q
Dear Jon:
. As described in Task 6.0, Remedial Investigation Report Review of
the approved Work Plan for the Risk Assessment and Feasibility
Study (Document Control No. 7740-005-WP-BCCS), FPC has compiled
comments on the Draft Remedial Investigation (RI) Report prepared
by EPA. FPC reviewed the draft RI report specifically to ensure
that sufficient information is provided to allow for preparation of
the risk assessment (RA) .and feasibility study (FS) report. The
report was not reviewed for compliance with guidance document
requirements or for editorial comments.
The following is a list of specific information not found in the
draft RI report that is required for the RA and FS:
1) groundwater contour map for the site
2) concentration contour maps for the contaminants of
concern, down to the PRGs
3) delineation of the limits of the groundwater plume
(horizontal and vertical)
4) additional chemical data for groundwater, i.e., VOAs,
semivolatiles and metals (include in proposed third round
of sampling) analyzed to CLP designated detection limits
or limits at or below the PRGs set for the site
101 North Rutgers Avenue, Suite 202 Oak Ridge, TN 37830 615 482-1065
i ' ' • Mr. Jon Bornholm
Page 2
• COM FEDERAL PROGRAMS CORPORATION
5) Additional surface soil samples in drainage ditches and
at site perimeter to verify offsite contaminant movement
(see attached figure for suggested locations). Although
there appears to be no perimeter or offsite surface soil
contamination, the existing data base for the site does
not include specific samples/chemical analyses to verify
this hypothesis. In order to prepare a defensible risk
assessment, we must have data to show the extent of
contaminant at the site and in particular at the site
perimeter. Collection of the samples indicated on the
attached figure would provide the necessary information.
Samples should be analyzed for the TCL. In addition,
collection of a surface sediment sample in the drainage
ditch beyond the site perimeter would provide data to
conclusively state that there is no contaminant migration
offsite via the surface water /runoff pathway. These data
are needed for both the human health and ecological risk'
assessments.
6) Data on human receptor population; verification of
closest downgradient private well; if specific
information is not available we can assume the worst case
scenario.
7) Definition of groundwater discharge points (receptors in
terms of general groundwater usage downgradient and
surface water interaction)
8) A topographic map of the site. Topographic information
on the site is necessary to prepare reasonably accurate
cost estimates for remedial alternatives.
We appreciate the opportunity to review the draft RI report for
sufficiency for the RA and FS. Please do not hesitate to call if
you have questions or need further clarification of our data needs.
Sincerely,
CDM FEDERAL PROGRAMS CORPORATION
Manager
ML:pm
cc: Gary Clemons, FPC Region IV ARCS Program Manager
Document Control
NEW HANOVER BURN PIT
WILMINGTON, NORTH CAROLINA
APRIL 1991
, , , , , , , , , , , ,
I/
' ' . ' ' , ' ' '
Figure I
' , ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' '' ~FORESIED------------
"._
Legend
BERM/ROAD
SAMPLE LOCATION
PROPOSED SURFACE SOIL
PROPOSED SURFACE SEDIMENT
SCAL[ APPROXIMA 1[ , r • r r-us·
•
•
' • • /,,. STATE: o-f' , ..... , ""~ -" ) '\.'1': :~(;:,;'t"r ,~
!'."' j' ,h1·•". ~, .... • 1 r;:;· . ;,:,; .\S ·;,, ; i 81 •. i'l
.
. , ....... -,.. ".:'..:::;;,/
•
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
4 September 1991
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
·Atlanta, GA 30365
RE: New Hanover County Airport Burn Pit NPL Site
Comments on the Draft Remedial Investigation
Dear Mr. Bornholm:
William L. Meyer
Director
We have reviewed the New Hanover County Airport Burn Pit Draft Remedial
Investigation and are providing the following comments. The North Carolina Division of
Environmental Management may be providing additional comments. We will forward these
to you as soon as we receive them.
(1) The Remedial Investigation Report recommends another round of
. groundwater sampling be conducted to establish baseline conditions. We
concur. We would also feel another set of groundwater elevation readings
should be taken to confirm groundwater flow directions at the site. The
figures included in the Draft Remedial Investigation Report indicate that
locally at the site, groundwater may be flowing out in all directions from the
center of the site. Groundwater flow patterns will need to be clearly defined.
Also, the closest monitoring well north of the burn pit is located at a distance
of approximately 225 feet. Additional monitoring wells may be necessary
closer to the north end of the burn pit to evaluate the extent of groundwater
contamination.
• •
Mr. Jon K. Bornholm
4 September 1991
Page 2
(2) The areas labelled as Burn Pit sw, Small Burn Pit, Burn Pit Horn, and the
· buried pipe have residual concentrations of a few parts per million of
individual organic compounds. The contaminants include 2-methylnapthalene,
ethyl benzene, xylenes, and napthalene. These contaminants should be
evaluated to ensure that they do not pose an increased carcinogenic health
risk of greater than 1 x 10-<>, have noncarcinogenic hazard indices of greater
than one, or are present in a TCLP leachate in concentrations greater than
. the North Carolina groundwater standards (15A NCAC Subchapter 2L).
(3) Mercury and arsenic are present in slightly elevated concentrations in the
septic tank sample. Information needs to be provided on whether this sample
is soil or sludge. If these concentrations exceed the health-based limits
outlined in the previous comment or are present in the TCLP leachate in
concentrations exceeding the North Carolina groundwater standards, these
areas will require remediation.
(4) The laboratory data sheets for samples BP22, BP23, BP24, and BP25 report
the results for cyanide in mg/kg. Since these are water samples the units
should be mg/1 or ug/L
(5) Sample BP12 was collected adjacent to and not within the tank car burn area.
A soil sample should be collected from within this area to determine if the
area requires remediation. Sample BP17 is located adjacent to but not within
an unnamed excavated area. A soil sample should be collected within this
excavated area to confirm that the area has been sufficiently remediated.
(6) Figure 4-5 indicates that leaking drums are present at the site. Soil samples
· should be collected immediately aujacent to any leaking drums. Remedial
action should cover treatment/removal of this waste and any soils which have
become contaminated as a results of the drums.
Please contact me at [phone] if you have any questions regarding these
comments.
CVJ/acr
Sincerely,
CWJ?c:1/2'
Charlotte V. Jesneck
Superfund Section
' -TED STATES ENVIRONMENTAL P-ECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
MEMORANDUM
DATE:
SUBJECT:
FROM:
TO:
SEP 1 D 1991
comments on Draft Remedial Investigation Report for the
New Hanover county Airport Burn Pit superfund Site
/fb:Jl, · ~ Joft!K. B~nholm
Remedial Project Manager
Fred Sloan
Hazardous Waste section
Environmental compliance Branch
Environmental services Division
As requested, two copies of the above referenced document were received on
August 13, 1991. Numerous copies were subsequently made and distributed to
the state of North Carolina Department of Environment, Health & Natural
Resources (Charlotte Jesneck), New Hanover County Department of Environmental
Management (Dennis Burks), u.s. Department of the Interior (James Lee), U.S.
Department of Commerce/National oceanic and Atmospheric Administration (John
Lindsay), Agency for Toxic Substances and Disease Registry (Chuck
Pietrosewicz), camp, o~esser & McKee (Mary Leslie), Region IV Health
Assessment officer (Elmer Akin), Ground-Water Technology support unit (Bernie
Hayes), Laboratory Evaluation & Quality Assurance Section (Wade Knight), and
Air, Pesticides, and Toxics Management Division (Lee Page) for review and
comment. comments were requested by September 9.
Attached are the comments I have received to date.
additional comments I receive to you immediately.
All comments embodied in the text of this memo and
I will transmit any
Below are my comments.
those attached need some
type of response, either acknowledging that the requested change has been
incorporated into the report or a statement explaining why the requested
change was not warranted and the supporting rationale. If there is any thing
I can do to help revise the draft report based on these comments, please do
not hesitate to ask for support.
1. General comment: somewhere in this report the fact that RI derived
waste was generated and stored on-site needs to be made. This report
should also state what disposal options are available for this RI
derived waste and what information is needed in order to make a
selection on disposal.
' Printed on Recycl~d Paper
• • -2-
2. General col!Dllent: The findings/conclusions of the endangered species
survey need to be incorporated into this report.
3. Index page listing Appendices:
listing of all the figures and
included here. For example,
Under both Appendix A and Appendix B, a
tables and their titles needs to be
APPENDIX A:
Figure 2-1
Figure 2-2
etc.
APPENDIX B:
Table 2-1
Table 2-2
etc.
FIGURES
site Location Map
site Map
TABLES
Preliminary Remediation Goals for Groundwater
Preliminary Remediation Goals for soil
This allow easy reference to information presented in the report.
4. Page 1, Section 1.0 Introduction, first paragraph: The source of the
aerial photographs referred to in this paragraph need to be referenced
(i.e., New Hanover county Airport Burn Pit superfund site Site
Analysis Environmental Photographic Interpretation Center (EPIC)
report (TS-PIC-90109), dated August 1990.
5. Page 1, Section 1.0 Introduction, first paragraph, last sentence: Bas
:he burning of confiscated drugs in the pit been
confirmed/documented? or has this occurrence only been reported? I
have not seen any documentation substantiating this claim.
6. Page 2, Section 1.2 Site status: Additional information needs to be
incorporated into this section or in section 2.1 that states when the
site was finalized on the NPL, the HRS score, and its ranking. Below
is information that needs to be incorporated. The site was proposed
on the NPL in June 1988 and was finalized on the NPL in March 1989.
The Site ranked 518 out of 1218. The ·HRS total score was 39.39 with
the following Route scores of 67.69 for groundwater and 7.83 for
surface water and 0.00 for air.
7. Page 2, Section 1.2 Site Status, second paragraph, first sentence: As
we are referring to past tense, this sentence should be changed to
read, "EPA gave approval to the PRP's ..• •.
8. Page 3, section 2.1.l Location:
lies east and west of the site,
what is to the north and south.
since this paragraph identifies what
this section also needs to identify
9. Page 3, Section 2.1.2 History, first paragraph: I would suggest
splitting this paragraph into two paragraphs making.the split after
the fourth sentence.
• • -3-
10. Paga 3, Section 2.1.2 History: Add an additional paragraph following
the first paragraph as the report is now presented. In this
paragraph, restate the HRS score, the dates the Site was proposed and
finalized on the NPL, summarize the investigation and data collected
during the preliminary investigation and site assessment. This
paragraph should highlight the contaminants found, in what
environmental media, and act what concentrations. A figure should
also be included identifying sampling points.
11. Page 3, Section 2.1.2 History, second paragraph, last three
sentences: Reading these three sentences together makes it sound like
since the PRPs did not do what the Agency wanted, we placed the Site
on the NPL as a consequence. This paragraph needs to be rewritten,
may be with the concept expressed in comment number 10. in mind.
12. Page 4, Section 2.1.2 History, paragraph at top of page, third
sentence: change this sentence to read, "PRG's are subject to change
and may be modified during the RI/FS proces&." As currently written,
this sentence implies that the PRGs trivial and insignificant.
13. Paga 4, section 2.1.2 History, paragraph at top of page, last
sentence: change this sentence to read '"The PRGs and their
derivations are included as Appendix C."
14. Page 4, Section 2.1.3 Physical Features, first paragraph, fourth
sentence: I suggest using another verb such as •obtained• instead of
"removed" as this term has been associated with the removal action.
15. Paga 4, section 2.1.3 Physical Features, fourth paragraph, fourth
sentence: The valve controlling flow to the burn pit is not
incorporated into any of the' figures. If this valve is the same as
the junction box, the the last sentence needs to be altered as this
junction box controlled flow to all four firefighter training areas
including the.burn pit.
16. Paga 4, section 2.1.3 Physical Features, last paragraph, first
sentence: This is the first time that confirmation sampling is
mentioned and therefore it is a little confusing. The removal and
accompanying verification (i.e., confirmation) sampling should be
first cited in section 2.1.2 site History.
17. Paga S, section 2.2 Removal/RI soil Sampling, second paragraph, first
sentence: Typo -Change • ... as follows: Following the
excavation/removal ..• • to read '" ... as follows: following_ the
excavation/removal ......
18. Paga 5, Section 2.2 Removal/RI soil sampling, second paragraph, first
sentence: change the end of this sentence to read • ••• 18 composite
soil samples were collected from all excavated areas to confirm/verifv
that the removal action removed the contaminated soil and reached
clean soil.".
• • -4-
19. Page 5, section 2.2 Removal/RI soil Sampling, second paragraph, second
sentence: This sentence as presently written is a little confusing.
Is it necessary to state that these samples were collected as surface
soil samples? or can it be state that they were collected from the
soils found at the bottom of the excavations?
20. Page 5, Section 2.2 Removal/RI Soil Sampling: Why not incorporate
Section 4.2.l into this section?
21. Page 5, section 2.3 Enforcement Profile: It needs to be stated in this
section that the PRPs performed the removal action under a signed
Administrative Order on Consent, signed in June 1990. And that the
removal was overseen by the Agency.
22. Page 8, Section 3.2.3 Regional Groundwater Features, first paragraph:
This is the first time the Pee Dee Formation is mentioned. If it is a
geological formation, why is it not discussed in either section 3.l.l
Regional Geology or section 3.l.2 site-specific Geology?
23. Page 10, section 3.2.~ Regional Groundwater Features, first full
paragraph at top of page, last sentence: This sentence makes a
statement that needs to be referenced.
24. Page 10, section 3.2.4 site-Specific Groundwater Features, first
paragraph, second sentence: I .believe this is the first time the
acronym NGVD-29 is used and therefore, it needs to be spelled out.
25. Page ll, Section 4.1.l Temporary Piezometers, second sentence: If the
hollow steel rods were stainless steel, then this fact should be stated.
26. Page 11, section 4.1.l Temporary Piezometers, last sentence:
Figure 4-l does not provide the results of the water level survey as
stated in this sentence. This information is presented on Figure 3.3.
27. Page 11, section 4.1.2 Temporary Monitoring Wells: fourth sentence:
Change this sentence to read "temporary well located approximately
70 feet southwest from the burn pit ••. •.
28. Page 11, Section 4.1.2 Temporary Monitoring Wells: fifth sentence:
Change this sentence to read " .•. presumed downgradient direction,
approxjmately 40 feet south of the burn pit, contained no ... N.
29. Page ll, section 4.1.2 Temporary Monitoring Wells: Add another
sentence reading something like "Temporary monitoring well BP-22 was
located approximately 275 feet due north of the burn pit.•.
30. Page 12, Section 4.1.2 Temporary Monitoring wells, paragraph at top of
page, second sentence: Refer to comment number 25.
• • -5-
31. ·Page 12, section 4.1.2 Temporary Monitoring Wells, paragraph at top of
page, third sentence: Change this sentence to read " .•. the samples were
collected and analyzed for volatile organic compounds, semi-volatile
=o~r~g~a~n~i~·c,._=c=o~m~p~o~u~n~d=s~,--=a~n~d'---'i~·n~o=r~g=a~n~i~c'-'a~n~a=l~y~t~e=s prior to placement ... ".
32. Page 12, Section 4.1.3 Permanent Monitoring Wells: some discussion
needs to be incorporated into this section with respect to the
development of the wells.
33. Page 12, section 4.1.3 Permanent Monitoring Wells, second paragraph,
third sentence: I am not comfortable stating "throughout the site
area". I feel it is ·better to state that this dense blue-gray clay
was encountered at approximately the same depth in the two other test
borings and the two borings for the two deep permanent monitoring
wells and then state, based on these five encounters, it is assumed
that this dense blue-gray clay layer is continuous across the entire
site.
34. Page 12, section 4.1.3 Permanent Monitoring Wells, fourth paragraph,
seventh sentence: The thickness of the bentonite pellet seal should
be included in this sentence.
JS. Pages 12 and 13, the carry over sentence: since the deep well was not
installed in accordance to the ECBSOPQAM, Appendix E, dated
February 1, 1991, a detailed explanation as to why bentonite pellet
seals were not placed on top of the sand packs needs to be included.
This will help prevent future disputes with either our own contractors
or PRPs and their contractors on the construction of monitoring wells.
36. Page 13, section 4.1.3 Permanent Monitoring wells, first full sentence
of page: The previous sentence, the carry over sentence between
pages 12 and 13, discussed only the two deep wells. As currently
written, this first full sentence carries on this thought and
therefore, implies that only the two deep wells had concrete caps and
pads.
37. Page 13, Section 4.1.3 Permanent Monitoring Wells, second paragraph,
first sentence: The date(s) the first round of samples was(were)
collected needs to be included in either this sentence or paragraph.
38. Page 13, Section 4.1.3 Permanent Monitoring Wells, second paragraph:
The type of analyses ran on both set of samples needs to be stated.
39. Page 13, section 4.1.3 Permanent Monitoring wells, second paragraph,
seventh sentence: I suggest changing this sentence to read as
follows, "Other contaminants of concern~ detected but at levels
below their PRGs •.• •.
40. Page 13, Section 4.2
laboratory problems
section.
soil sampling: It is unclear why information on
with groundwater samples are included in this
• • -6-
41. Page 16, Section 5.0 Conclusions and Recommendations: This section
needs ta attempt to define the extent of contamination as well as
assign an estimated volume of soil and/or groundwater impacted.
Figures depicting the text should also be included.
42. Figures 2-2, 3-1, 3-3, 3-4, 3-5, 4-1, 4-3, 4-4, 4-6, and 4-7: The names
of the roads should be included on these figures.
43. Table 2-1, Note #1: The PRG for total·concentration of carcinogenic
PAHs is not to exceed 0.0002 mg/1. To the best of my knowledge, there
is no analytical method that determines the concentrations of
carcinogenic PAHs only. The only why to derive the total
concentration of carcinogenic PAHs is to add the concentrations of the
individual compounds. Are the detection levels/limits such that this
concentration goal can be realized?
44. For all Tables: A clear definition of what all the information included
in the column headings needs to be incorporated. For example, on
Table 4-4, what does NH-00lGW mean? To make it clear, the four digit
number in the column heading should be labeled as the time the sample
was collected. The other approach is to eliminate this extraneous
information if it is not needed.
Attachments
•
,.,a,,
,..
Q ;:. . .
~ 0 .
=' .-!
UiJed States Department o.e Interior
OFFICE OF THE SECRETARY
Office of Environmental Affairs
Richard B. Russell Federal Building
75 Spring Street, S.W.
Atlanta, Georgia 30303
August 19, 1991
Mr. Jon K. Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland street, NE
Atlanta, GA 30365
Dear Jon:
---.
I received your letter and three copies of the draft RI for the New
Hanover County Airport Burn Pit Site, NC. I have forwarded copies
to U.S. Geological Survey and U.S. Fish and Wildlife service for
review and possible comment back to you. Thank you for keeping us
informed.
cc: USGS, Raleigh
FWS, Raleigh
FWS, Atlanta
sincerely,
~✓-#~
es H. Lee
ional Environmental Officer
James G. Martin, Governor
William W. Cobey, Jr., Secretary
•
4 September 1991
Mr. Jon K. Bornholm
Remedial Project Manager
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: New Hanover County Airport Burn Pit NPL Site
Comments on the Draft Remedial Investigation
Dear Mr. Bornholm:
William L. Meyer
Director
We have reviewed the New Hanover County Airport Bum Pit Draft Remedial
Investigation and are providing the following comments. The North Carolina Division of
Environmental Management may be providing additional comments. We will forward these
to you as soon as we receive them.
(1) The Remedial Investigation Report recommends another round of
groundwater sampling be conducted to establish baseline conditions. We
concur. We would also feel another set of groundwater elevation readings
should be taken to confirm groundwater flow directions at the site. The
figures included in the Draft Remedial Investigation Report indicate that
locally at the site, groundwater may be flowing out in all directions from the
center of the site. Groundwater flow patterns will need to be clearly defined.
Also, the closest monitoring well north of the burn pit is located at a distance
of approximately 225 feet. Additional monitoring wells may be necessary
closer to the north end of the burn pit to evaluate the extent of groundwater
contamination.
• • Mr. Jon K. Bomholm
4 September 1991
Page 2
(2) The areas labelled as Burn Pit sw, Small Burn Pit, Burn Pit Horn, and the
buried pipe have residual concentrations of a few parts per million of
individual organic compounds. The contaminants include 2-methylnapthalene,
ethyl benzene, xylenes, and napthalene. These contaminants should be
evaluated to ensure that they do not pose an increased carcinogenic health
risk of greater than 1 x 10-6, have noncarcinogenic hazard indices of greater
than one, or are present in a TCLP leachate in concentrations greater than
the North Carolina groundwater standards (15A NCAC Subchapter 2L). ·
(3) Mercury and arsenic are present in slightly elevated concentrations in the
septic tank sample. Information needs to be provided on whether this sample
is soil or sludge. If these concentrations exceed the health-based limits
outlined in the previous comment or are present in the TCLP leachate in
concentrations exceeding the North Carolina groundwater standards, these
areas will require remediation.
(4) The laboratory data sheets for samples BP22, BP23, BP24, and BP25 report
the results for cyanide in mg/kg. Since these are water samples the units
should be mg/I or ug/1. ·
(5) Sample BP12 was collected adjacent to and not within the tank car burn area.
A soil sample should be collected from within this area to determine if the
area requires remediation. Sample BPl 7 is located adjacent to but not within
an unnamed excavated area. A soil sample should be collected within this
excavated area to confirm that the area has been sufficiently remediated.
(6) Figure 4-5 indicates that leaking drums are present at the site. Soil samples
should be collected immediately adjacent to any lealdng drums. Remedial
action should cover treatment/removal of this waste and any soils which have
become contaminated as a results of the drums.
Please contact me at [phone] if you have any questions regarding these
comments.
CVJ/acr
Sincerely,
C~wt:~,,
Charlotte V. Jesneck
Superfund Section
~'
-~--
MEMORANri\Ji
DATE: September 5, 1991
SUBJECT: Review of the Draft Remedial Investigation Report, New
Hanover County Burn-Pit Site, New Hanover County, North
Carolina
FROM:
TO:
THROUGH:
Ju 1 i e W • Ke 1 1 e r C:t,.) ~
Toxicologist 0
Jon K. Bornholm
Remeidal Pro~ec~ M/ger
Elmer Akin~
Health Asse~ent Officer
EPA -llEGION IV
ATLANTA, GA.
Per your request, I have reviewed the Draft Remeidal Investigation
Report for New Hanover County Burn-Pit Site, New Hanover County,
North Carolina. We concur with the recommendation that additional
sampling is necessary before conducting the baseline risk
assessment. The following comments and concerns should be
considered before additional sampling is conducted.
The sample quantitation limit for lead in groundwater (40 ug/L) is
unacceptably high for all samples. The contract laboratory program
contract required quantitation limit is 5 ug/L and the treatment
technique action level is 15 ug/1. The sample quantitation limit
is more than twice the treatment technique action level for all
onsite groundwater samples. Lead is a potentially critical
contaminant due to the nature of activities conducted at this site.
The samples from the second round of groundwater sampling were only
analyzed for volatile organic compounds. Metals were detected in
the first sampling round, with chromium (58-82 ug/L) above levels
establ.'s ··· for the PRG's (50 ug/L). Semi-volatile compounds (2-
methyl ·.· • :.1 ene. and naphthalene) 1o1ere al so detected in the first
sampli d. Therefore metals and semi-volatiles should not be
elimin' ·om further investigations. ·-~. .
·.,,. ... _ -·r-r-·· ·_·
Table 2-2'?·the PRG for benzene should be 0.40 mg/kg not 0.41 mg/kg
(Table 3, PRG Memo from Rebecca Fox to Fred Sloan, 1/23/90).
It is unclear why information on laboratory problems with
groundwater samples are included in Section 4.2, Soil Sampling.
If I can be of further assistance or if you have any questions
please contact me at xl586.
M1l1ll,di Enviroomenw lechnology, Inc.
l!S,\.Tlegion IV, 545 Resmdl l)rh,o, Suite~ Athens, Geo'KJ2 J-0605 404-546-7611 PAX 404-546-7831
-•
COM FEDERAL PROGRAMS
September 6, 1991
Mr. Jon Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Project: EPA Contract No. 68-W9-0056
Document Control No.: 7740-005-EP-BDDY
CORPORATION
Subject: comments on Draft Remedial Investigation Report
New Hanover County Airport Burn Pit Site
Wilmington, North Carolina
work Assignment No.: 05-4L5Q
Dear Jon:
. As described in Task 6.0, Remedial Investigation Report Review of
the approved Work Plan for the Risk Assessment and Feasibility
Study (Document Control No. 7740-005-WP-BCCS), FPC has compiled
comments on the Draft Remedial Investigation (RI) Report prepared
by EPA. FPC reviewed the draft RI report specifically to ensure
that sufficient information is provided to allow for preparation of
the risk assessment (RA) .and feasibility study (FS) report. The
report was not reviewed for compliance with guidance document
requirements or for editorial comments.
The following is a list of specific information not found in the
draft RI report that is required for the RA and FS:
1) groundwater contour map for the site
2) concentration contour maps for the contaminants of
concern, down to the PRGs
3) delineation of the limits of the groundwater plume
(horiz·ontal and vertical)
4) additional chemical data for groundwater, i.e. , VOAs,
semi volatiles and metals ( include in proposed third round
of sampling) analyzed to CLP designated detection limits
or limits at or below the PRGs set for the site
:Cl No.th Rergm Avenue, Suire Z01. Oa, Ridge, TN 37830 615 -182-1065
• Mr. Jon Bornholm
Page 2
coAEDERAL PROGRAMS CORPORATION
5) Additional surface soil samples in drainage ditches and
at site perimeter to verify offsite contaminant movement
(see attached figure for suggested locations). Although
there appears to be no perimeter or offsite surface soil
contamination, the existing data base for the site does
not include specific samples/chemical analyses to verify
this hypothesis. In order to prepare a defensible risk
assessment, we must have data to show the extent of
contaminant at the site and in particular at the site
perimeter. Collection of the samples indicated on the
attached figure would provide the necessary information.
Samples should be analyzed for the TCL. In addition,
collection of a surface sediment sample in the drainage
ditch beyond the site perimeter would provide data to
conclusively state that there is no contaminant migration
offsite via the surface water/runoff pathway. These data
are needed for both the human health and ecological risk
assessments.
6) Data on human receptor population; verification of
closest downgradient private well; if specific
information is not available we can assume the worst case
scenario.
·,
7) Definition of groundwater discharge points (receptors in
terms of general groundwater usage downgradient and
surface water interaction)
8) A topographic map of the site. Topographic information
on the site is necessary to prepare reasonably accurate
cost estimates for remedial alternatives.
We appreciate the opportunity to review the draft RI report for
sufficiency for the RA and FS. Please do not hesitate to call if
you have questions or need further clarification of our data needs.
sincerely,
COM FEDERAL PROGRAMS CORPORATION
Mary Leslie
·Project Manager
ML:pm
cc: Gary Clemons, FPC Region IV ARCS Program Manager
Document Control
NEW HANOVER BURN PIT
WILMINGTON, NORTH CAROLINA
APRIL 1991
,
' , ,
' ' , ' ' , ' , ,,
, , ' , ,
' ' , '
Figure I
, I , ,
, I , , , ,
, I
, I , , , ·, , , , , "----FORESIED---------
'
Legend
SAMPLE LOCATION
PROPOSED SURFACE SOIL
PROPOSED SURFACE SEDIMENT
SCAL[ APPf!OXIMAI[
b .,.. : T
r-u,·
LJ
[_
[
•
•
Date
From
Subject
To
September 17, 1991
ATSCR Senior Regional Representative
New Hanover County Airport Burn Pit;
New Hanover County, North carolina
Jon Bornholln, Renroial Project Manager
U.S. EPA WMD NSRB
• Memorand'um
As requested, the Draft Renroial Investigation Report, dated August
1991, for the above site has been reviewed. We have no substantive
=ts to offer on this document. All of the recamrrerdations nade
in ATSCR's May 1990 Preliminary Health Assessment for this site have
been addressed either during the rem:,va1. action or the =rrluct of the
investigation.
If we can assist further, please feel free to =ntact either Bob Safay
or myself.
ClwQ,l,
Chuck Pietrosewicz, R.H.S.P,
cc: file; Bob Safay; QAA/ORO
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
DATE: SEP ? ~ 1991
SUBJECT:
TO:
FROM:
THROUGH:
Preliminary Comments for the New Hanover County
Airport Burn Pit NPL Site, Wilmington, NC
Jon Bornholom, Remedial Project Manager
NC Section, North Remedial Branch
Waste Management Division
//,~ Jennifer Herndon, Hydrogeologist '-/C•
Ground-Water Technology-Support Unit
Jon Isbell, Acting Chief
Ground-Water Technology Support Unit
The following comments are provided after reviewing the
Remedial Investigation Report for the New Hanover County Burn
Pit in Wilmington, North Carolina.
The ground-water classification of the surficial aquifer at the
site has been conducted. As outlined by the Guidelines for
Ground-Water ciassification under the EPA Ground-Water
Protection Strategy, Final Draft, December 1986 the surficial
aquifer is classified as Class IIA, A Current Source of
Drinking Water Supply. This classification is based on well
data from Progress Report on Ground Water in North Carolina,
M.J. Mundoreff, North Carolina Department of Conservation and
Development, Division of Mineral Resources, Bulletin 47, which
indicates that a public well field exists at the New Hanover
County Airport. Class IIA ground-waters are subject to
stringent clean-up standards based upon protection of human
health (MCLs or proposed MCLs).
General Comments
(l) A well inventory survey in the vicinity of the site should
be conducted. Private wells (if any exist) in the residential
area located 0.22 miles from the site should be sampled.
Public water supply wells near the site should also be sampled.
(2) Levels of benzene and aluminum above MCLs were found in the
following wells during the first sa.-ilpling event ( Table 4-4) •
Printed on Recycled Paper
Well
MWSOOl
MWDOOl
MWD002
MWS002
MWS003
MWS004
•
Benzene (mg/L)
.007
.11
.11
•
Aluminum (mg/L)
52
56
36
46
58
16
During the second round sampling event the amount of benzene
detected decreased in wells MWDOOl and MWD002 {Table 4-5).
Inorganics were not tested for during this round of sampling,
but should be tested for in future sampling events to establish
the level of inorganic contamination.
(3) Water quality samples should be taken from ~he Sand
Aquifer near the site area to confirm that the confining unit
is continuous and prevents communication between the surficial
and Sand aquifers. Wells should be installed near the burn pit
with the top of the screen penetrating at approximately 33 feet
below land surface. If contaminants are present additional
wells should be installed downgradient in the southeast
direction.
(4) Because of the high content of aluminum in soils at the
site (ranging from 400 to 4,900 mg/kg), soil clean-up goals for
aluminum should be. established.
(5) Soil samples should be collected near the berm break if
these soils have not already been excavated. Also, soil
samples should be collected in the area o:f "30 feet west and 50
feet north" of the burn pit. This area showed evidence of
prolonged periods of standing water, the source of which was
drainage and/or overflow from the pit.
(6) The regional ground-water flow direction in the area is
toward the southwest (section 3.2.4). However, locally at the
burn pit site the direction of flow is in a radial direction
based on water level measurements collected April 9, 1991.
There is concern that contaminants could migrate to the
residential area 0.22 miles to the northwest. Shallow wells
northwest of the burn pit should be sampled, if any exist, or
new shallow wells should be installed in this area and sampled
in order to delineate the extent of the contaminant plume.
-2-
• •
(7) The work plan for the New Hanover County site stated that
an endangered species survey would be conducted of the forested
area adjacent to the site. Results of the survey and
literature review should be provided.
Hopefully these comments will be helpful in completing the
remedial investigations at New Hanover County, Wilmington, NC.
If you have any questions, please contact me at x3866.
-3-
RA HIOSD L, CHliRCH JR. R.S,
Director of Environmaual Management
TROY G. FLASAGAS
Resourte Recovery Manager
STEPHEN T. EDESS
Landfill Manager
J. TIMOTHY COLE
Recycling Manaca-
September 30, 1991
NEW HAN()9EK COUNTY
DEPARTMENT OF ENVIRONMENT AL MAi'IAGEMENT
3002 U.S. HWY. 421 NORTH
WILMINGTON, NORTH CAROLINA 28401-9008
TELEPHONE [phone]
Mr. Jon K. Bornholm
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Review and Comment on Draft Remedial Investigation Report.
for the New Hanover County Airport Burn Pit superfund Site
Dear Mr. Bornholm:
Please find attached comments from the PRP's review of the Remedial
Investigation Report for the New Hanover County Airport Burn Pit
Superfund Site.
If you have any questions, please call.
~ely~
Raymond L. Church, Jr., Director
Department of Environmental Management
attachments
cc: Dennis Burks
Tom Pollard
Lonnie Williams, Jr.
Rick Duarte
• •
Section 3.2.4 Site-Specific Groundwater Features
1.) The report notes a mound effect on the groundwater table at
the site with speculation that this is due to soil removal
activities. Could the previous pit at the site have contributed to
this condition?
2.) If the blue clay layer at the 28-33 feet level at the site
discovered by EPA was determined to be an aquatard which prevents
seepage to the lower groundwater levels, should you not consider
looking at the depth of the drinking water wells in the vicinity.
If these wells fall below the blue clay layer, then a recalculation
of the public health related parameters (i.e. benzene and ethyl
benzene) should be considered before any additional sampling,
analysis or review of data takes place.
Section 5.0 Conclusions and Recommendations
1.) If EPA determines a third round of sampling is necessary,
sampling and analysis should be limited to the contaminants of
concerned as addressed (i'.e. chromium, benzene, and ethyl benzene).
This would serve to keep the cost down while providing the data
necessary to determine if future actions are necessary.
2.) Reduction in parameter concentrations for benzene and ethyl
benzene from the first to second sampling could be attributed to
natural occurring remediation cqnditions present at the site.
Consideration to this alternative if third round results come back.
lower, would justify a no action alternative. Initial chromium
results over the PRG could be due to sediment interference in the
sample.
Appendix C Prelimary Remediation Goals (PRPG)
1.) The memo from Rebecca Fox, Toxicologist, dated January 23,
1991 is a typo. We received a copy of the PRG in March 1991. The
submittal had an EPA date stamp of January 25, 1991.
• •
Enclosure One (Review Comments)
Report New Hanover County Burn-Pit
"Draft Remedial Investigation
Site', New Hanover County, North
Carolina" ·
REFERENCE
Cover Letter
Pg. 3
Pg. 12
Pg. 13
'E>g. 13
ITEM #
1
2
3
4
5
COMMENT
Paragraph one, second sentence -
Suggest the word "on" be added
immediately after the word "based".
Paragraph 2.1.2 -The site history
states that local industries used this
site for firefighter training purposes,
yet these local industries are not
named as potentially responsible
parties who may be liable for future
site cleanup) See Pg. 2, Paragraph
1.2). Shouldn't these industries be
named? Has the USEPA done everything in
its power to protect the other PRPs by
attempting to include these additional
entities as PRPs?
Paragraph 4.1.2, last sentence -
Generally accepted field sampling
protoc_ols include procedures for
eliminating isopropanol and acetone
contamination. Strongly disagree with
the implication that these procedures
were not required at this site since
these two compounds are not suspected
of being contaminants. What steps were
taken to insure trace contaminants were
not present in the solvents used during
field decontamination?
Paragraph 4.1.3 -Please explain why
naphthalene was detected in the SVOC
determination, ·but not in the voe
determination. Comparison of the
naphthalene data by two different
methods often provides useful
information on relative efficiencies of
the methods.
Paragraph 4.3 -What steps are being
taken to obtain damages from the two
laboratories who failed to maintain
physical control of the soil samples.
The PRP's interest will be protected
only if an aggressive approach is taken
to correct this violation of standard
chain-of-custody procedures. At a
Pg. 15 6
Pg.· 14 7
Pg. 14 8
Pg. 16 9
l\.ppendix A 10
Appendix B 11
• minimum the laboratories should be held
liable for all resampling costs plus a
penalty for their portion of damage to
data completeness.
Paragraph 4.5, last sentence -Strongly
disagree with the caviler attitude
expressed concerning possible
contamination of the samples with
chromium, lead, and xylenes. All data
for these analytes must be flagged and
are of questionable value to the
project. suggest a detailed discussion·
of the contamination and its most
severe effect on the data be added.
Paragraph 4.2.1 -Please provide a
discussion as to the RDS's of the
duplicates and explain possible causes
for the major discrepancies noted.
Paragraph 4.2.2 -Since these samples
were taken to reconfirm earlier
results, strongly recommend a statement
be added which clearly addresses the
results as they relate to this
objective. In addition, a comparison
table of the two data sets would be
appropriate and most beneficial.
Paragraph 5.0 -Please provide more
·information on procedures followed to
insure the groundwater samples from the
monitoring wells would be
representative. Were procedures
outlined "Handbook of Suggested
Practices For the Design and
Installation of Ground-Water Monitoring
Wells" (EPA600/ 4-89 /034) followed? The
PRPs need to be provided with
sufficient information to document that
their interests are being protected.
-
Figures 4-2, 4-5, & 4-6 do not follow
the format of the other figures.
Additionally their legends do not agree
with the information as depicted,
please use only one format and correct
noted deficiencies.
Tables 2-1 and 2-2 do not have units
for the non-carcinogenic PAH's.
Appendix B 12
Appendix E 13
Appendix F 14 ·
General 15
• Table 4-x -The "N" flag is only
identified in one place, please provide
complete footnotes for each table.
Also the presentation for tentatively
identified compounds (TICs) or
unidentified compounds is extremely
confusing, please change format to make
it understandable. Several compounds
are listed more than once in the tables
and sometimes at different
concentrations.
Figures demonstrate a poor duplication
effort making them extremely hard to
read. Suggest replacement with
readable figures.
This appendix does not contain usable
raw data, but rather provides only
extracts of selected raw data. Please
provide a complete raw data package to
include all QC and QA information.
The analytical portions of this
submittal are extremely weak.
Recommend the inclusion of a more
detailed analytical data section to
include a full data quality
objectives/conclusions presentation.
•
CITY of WILMINGTON
North Carolina
Mr. Dennis Burks
P.O. BOX 1810
28402.
September 11, 1991
New Hanover County. Department
of Environmental Management
3002 Highway 421 North
Wilmington, N~ c. 28401 · ·
LEGAL DEPAATMEN1
[phone]
FAX [phone]
RE: Comments on draft Remedial Investigation Report
for the New Hanover County Airport Burn Pit
Dear Dennis:
I have reviewed the draft Remedial Investigation Report
for the New Hanover County Burn Pit site. I have divided
my comments into several general subject areas which follow:
corrections to Report;
l.· Page 3, Section 2.1.2--The second-paragraph of this
sectioli seems to indicate that there was an attempt to
negotiate.draft enforcement consent orders prior.to the
inclusion of the site on the NPL. This is incorrect.
The first notice that the City had· of its potential
involvement wlth this site was by letter that included
a draft consent order after the site had been placed on
the NPL.
2. Page 4, the last full paragraph of Section
2.1.2--Ind:fcates that Preliminary Remediation Goals
(PRG's) for the site were established in January, 1991.
I believe this to be correct although the memorandum
included as Appendix C is dated January, 1990.
3. Appendix C also states that it has been estimated that
100 to 500 gallons of jet fuel were burned in the pit
daily between 1968 and 1974. I do not know whether
this is intended to mean that between 106 to 500
gallons of jet fuel were burned each day the pit was
used for fire training exercises or that the pit was
• Mr. Burks Page 2 September 11, 1991
used during this period on a daily basis. I have not
found anything to indicate that the pit was used
regularly on a daily basis.
Absence of other Potentially Responsible Parties:
The information contained in the report confirms
information that I have received that several Potentially
Responsible Parties (PRP's) have not yet been identified.
-These responsible parties would include local industries
that used the site for fire training activities and persons
cleaning up oil spills in the area (which may include the
U.S. Coast Guard). These additional PRP's should be
identified.
Risk Assessment:
I certainly am interested in reducing the potential
costs to the PRP's as much as possible. It,' however, does
appear tha_t a Risk Assessment should be included as part of
the RI report. The report refers to the health assessment
performed prior to the placement of the site on the NPL. In
addition, PRG's were developed for the site, but there is no
Risk Assessment as part of the RI. The PRG's for
groundwater were developed bqsed on residential exposure
because of a residential area located a quarter of a mile
west of the site. The report indicates that there is no
surface water leaving the site and groundwater flow is to
the southwest away from,the residential areas. Based upon
this information, potential residential exposure is not an
appropriate basis for the PRG's for the site. Of course,
Appendix C itself contemplates that the PRG's might be
modified during the RIFS process. The data collected to
date clearly shows that the feasibility study should at
least be scaled down if not eliminated altogether.
Certainly, if the EPA takes another round of samples which
indicate a further reduction in benzene, such results would
argue for a no action decision beyond the work that-has
already been performed at the site.
Responsibility of the City for Military Use of the Site
To the extent that the remedial investigation study has
examined the remnants of the old military hospital located
on the site, including the septic tank serving these
buildings, the City of Wilmington should not have any
responsibility for any activities relating to the study or
potential cleanup of these buildings. Except for the
• •
Mr. Burks Page 3 September 11, 1991
smokehouse, any activities relating to such buildings
are well beyond the City's involvement at the site.
Thank you for your review of these comments. If you
have any questions, please let me know.
TCP/dbl
Thomas C, Pollard
City Attorney
• ,,.,~ "-'~~,
!'wi f! ; • "'"'"'· lli~Iil ~.~
•
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
4 September 1991
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: New Hanover County Airport Burn Pit NPL Site
Comments on the Draft Remedial Investigation
Dear Mr. Bornholm:
William L. Meyer
Director
We have reviewed the New Hanover County Airport Burn Pit Draft Remedial
Investigation and are providing the following comments. The North Carolina Division of
Environmental Management may be providing additional comments. We will forward these
to you as soon as we receive them.
(1) The Remedial Investigation Report recommends another round of
groundwater sampling be conducted to establish baseline conditions. We
concur. We would also feel another set of groundwater elevation readings
should be taken to confirm groundwater flow directions at the site. The
figures included in the Draft Remedial Investigation Report indicate that
locally at the site, groundwater may be flowing out in all directions from the
center of the site. Groundwater flow patterns will need to be clearly defined.
Also, the closest monitoring well north of the burn pit is located at a distance
of approximately 225 feet. Additional monitoring wells may be necessary
closer to the north encl of the burn pit to evaluate the extent of groundwater
contamination.
• •
Mr. Jon K Bornholm
4 September 1991
Page 2
(2) The areas labelled as Burn Pit sw, Small Burn Pit, Burn Pit Horn, and the
buried pipe have residual concentrations of a few parts per million of
individual organic compounds, The contaminants include 2-methylnapthalene,
ethyl benzene, xylenes, and napthalene. These contaminants should be
evaluated to ensure that they do not pose an increased carcinogenic health
risk of greater than 1 x 10·6, have noncarcinogenic hazard indices of greater
than one, or are present in a TCLP leachate in concentrations greater than
the North Carolina groundwater standards (15A NCAC Subchapter 2L).
(3) · Mercury and arsenic are present in slightly elevated concentrations in the
septic tank sample. Information needs to be provided on whether this sample
is soil or sludge. If these concentrations exceed the health-based limits
outlined in the previous comment or are present in the TCLP leachate in
concentrations exceeding the North Carolina groundwater standards, these
areas will require remediation.
(4) The laboratory data sheets for samples BP22, BP23, BP24, and BP25 report
the results for cyanide in mg/kg. Since these are water samples the units
should be mg/I or ug/1.
(5) Sample BP12 was collected adjacent to :rnd not within the tank car burn area.
A soil sample should be collected from within this area to determine if the
area requires remediation. Sample BPl 7 is located adjacent to but not within
an unnamed excavated area. A soil sample should be collected within this
excavated area to confirm that the area has been sufficiently remediated.
(6) Figure 4-5 indicates that leaking drums are present at the site. Soil samples
should be collected immediately adjacent to any leaking drums. Remedial
action should cover treatment/removal of this waste and any soils which have
become contaminate·d as a results of the drums.
Please contact me at [phone] if you have any questions regarding these
comments.
CVJ/acr
Sincerely,
lhwi.~
Charlotte V. Jesneck
Superfund Section
, ...............
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•
State of North Carolina
J
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 19 August 1991
MEMORANDUM
TO:
FROM:
Perry Nelson, Chief
Groundwater Section
Lee Crosby, Chief C (_/
Superfund Section f--
William L. Meyer
Director
RE: Request for Review and Comments on the New Hanover County Airport
Burn Pit NPL Draft Remedial Investigation Report
Attached are three copies of the New Hanover County Airport Burn Pit Draft
Remedial Investigation Report for your review. Please forward one copy to the Water
Quality Section and one copy to the Air Quality Section for comments. The US EPA has
requested that we submit comments by 9 September 1991. All comments should be sent
back to our office so that we may submit one package to the US EPA.
Please contact Charlotte Jesneck or me at 733-2801 if you require any additional
information or will be unable to meet the deadline. Thank you for your assistance.
LC/acr
Attachments
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
AUG 14 1991
4WD-NCRS
Ms. Charlotte Jesneck
North Carolina Department of Environment,
Health and Natural Resources
401 Oberlin Road
Raleigh, NC 27605
RE: Review and Comment on Draft Remedial Investigation Report
for the New Hanover County Airport Burn Pit Superfund Site
Dear Ms. Jesneck:
Enclosed are three (3) copies of the above referenced document as prepared by
the Environmental Services Division. The draft Remedial Investigation (RI)
report is based data collected during the Preliminary Investigation/Site
Assessment (PI/SA), the removal action conducted in November-December 1990,
and the recently completed RI field work. Field work for the RI was done
between April 8 and April 18, 1991.
Please review this draft report. In order to keep this site on schedule, I
would appreciate receiving your comments by no later than September 9, 1991.
If you are unable to get your comments to me by this date, please let me know
when you will be able to submit your comments.
If you have any questions, please call me at [phone].
sincerely yours,
Remedial Project Manager
enclosures
cc: Lee Crosby'·· NCDEHNR (W/O encl.)
William Meyer, NCDEHNR (w/o encl.)
Printed on Recycled Paper
• •
UNITED STATES ENVIRONMEMTAL PROTECTION AGEN~
REGION IV • 'ECt.ivEio
345 COURTLAND STREET NE JAN 2
ATLANTA. GEORGIA 30365 ,} 199/
SIJPERFUNo SEcr,oN
MEMORANDUM
DATE: Jf\N 1 5 1991
SUBJECT:
FROM:
Record of Communication for January 15, 1991 Telephone
Conversation On New Hanover Remedial Investigation
A-,~..J ~-
J or, K. Bornholm
Remedial Project Manager
TO: Fred Sloan
Hazardous Waste Section
Environmental Compliance Branch
Environmental Services Division
I would like to confirm the information shared during our telephone
conversation today, Tuesday, January 15, 1991.
You said that it would be beneficial to move the Remedial Investigation (RI)
field work back a month to allow sufficient time to review and interpret data
collected during the removal action conducted at the site in
November-December. You are currently anticipating receiving all analytical
data by January 25, 1991. I concurred with this proposal.
You are also waiting for Elmer Akin to provide ESD with Preliminary
Remediation Goals (PRGs). (I talked with Becky Fox shortly after talking
with you and she said the New Hanover PRGs should be completed today.) This
information along with the analytical data referred to above is needed to
finalize the sampling strategy in the RI work plan. The New Hanover RI field
work is now scheduled to occur the weeks of March 4 and March 11.
I requested the draft RI work plan be submitted as early as possible in order
to allow the State an opportunity to review this document prior to ESD
commencing with the field work. You replied that the draft RI work plan
should be available for review by February 8, 1991. This should provide the
State sufficient time to complete its review of the RI work plan as this
document should not exceed 30 pages in length.
Please contact me if any of the above is inaccurate.
cc: William Bakey, HWS
Lee Crosby, NCDEHNR
Curt Fehn, NCRS
Charlotte Jesneck, NCDEHNR
Bob Jourdan, NSRB
Printed on Recycled Paper