NCD986187094_20030902_Reasor Chemical Company_FRBCERCLA RD_Design Criteria abd Data Evaluation June - September 2003-OCR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
Ms. Teresa Offner
Site Manager
Weston Solutions, Inc.
5430 Metric Place, Suite l00
Norcross, GA 30092
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
September 2, 2003
' Subject: Data Evaluation Summary Report (Revision 2) Approval
Reasor Chemical CompanySite·-Remedial Design ,. • .... ,_;
Work Assignment Number 147-RDRD-A424
Dear Ms. Offner:
I have reviewed the Data Evaluation Summary Report Revision 2 dated August 15, 2003,
which Weston Solutions, Inc. prepared for the Reasor Chemical Company Site Remedial Design.
I approve the document as the final version. Thank you for making the necessary corrections to
previous versions. If you have any questions, please feel free to contact me at [phone].
Sincerely,
~~~
Samantha Urquhart-Foster
Remedial Project Manager
North Site Management Branch
cc: David Mattison, NC DENR (with enclosed Revision 2 document)
Sara Ward, US FWS (with enclosed Revision 2 document)
Michel Gielazyn, NOAA (with enclosed Revision 2 document)
Kelly Stynes, CH2M Hill (with enclosed Revision 2 document)
'•,rc~•T1et J\ddress {l!RL) • http"t!www,epa.gov
l~.:.1.-y·:i<>11:l-lf .. ",•;,1ld1, •, ,,-,,,,, ,! ,•,1t11 VtH'IN<-'hlP oa H;i.Sf!d ln~:s on H,icydud Pap!:!r (M!nirnurn 30':'o PoslGOnsUlntlf)
4WD-NSMB
Ms. Kelly Stynes
CH2MHill
103 Java Ct
Cary, NC 27519
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
August 21, 2003 .. ..
SUBJECT: Response to CH2M·Hill's comments dated July 30, 2003·· •" · ·
SUP!:RF! IND SE_CI!Or,i
Reasor Chemical Company Site, Castle Hayne, New Hanover County, NC
Dear Ms. Stynes:
Thank you for your comments dated July 30, 2003 regarding the Data Evaluation Report,
Revision I, and the Design Criteria Report, Revision 0, for the Reasor Chemical Company Site
located in Castle Hayne, New Hanover County, North Carolina. The purpose of this letter is to
address each of your comments.
Data Evaluation Report
1. Surface Water. During the Remedial Investigation (RI) and Ecological Risk
Assessment (ERA), surface water samples from Ponds 3 and 4 were not analyzed for inorganic
constituents. When it was realized that inorganic information was needed from the ponds, Ponds
3 and 4 did not contain surface water and therefore, samples could not be obtained. EPA does
have surface water inorganic results for Ponds 1 and 2. Although EPA does not have inorganic
data on surface water in ponds 3 and 4, we do have inorganic data from the sediments of all
ponds. The surface water inorganic contaminants of concern are copper, lead, iron and zinc.
Tables on the following page include concentrations of copper, iron, lead and zinc found
in sediment and surface water in ponds 1-4 during the May 1999 and.December 2001 sampling
events. During the May 1999 RI sampling event, of the four ponds, Pond 4. sediments had the
highest concentrations of these contaminants, except for iron, which was second highest in Pond
4. Pond 3 had the second highest concentration of copper. In the December 200 I ERA sampling
event, Pond 3 sediments had the highest concentration of copper, with Pond 4 following close! y
behind. Although there is not a perfect correlation between the surface water data and the
sediment data, if pond 1 had a copper sediment concentration of 100 mg/kg and surface water
concentration of 61 µg/L, it is a reasonable estimate to believe that water coming into contact
with sediments containing copper concentrations of 770 -920 mg/kg (Pond 4, Pond 3) would
most likely result in concentrations greater than the clean-up level of 7 µg/L. The "liquid tar"
from Pond 3 had concentrations exceeding cleancup levels.and it would be difficultto separate.
that from the surface water during removal. ·Therefore, in my professional judgment; I do not
believe that obtaining a sample of surface water from ponds 3 and 4 is necessary. I believe that it
is a safe assumption, based on the existing data, that if water is present in those ponds, it would
·1i1!Hrn0t Addross (URL)., htt1r//wwy,,.epa.go\i
~ :l>o~1IH••-yci;,ibl,: .. )'"r,t,:J wi:t Vegetnblu·Oil f:lr1.o;;id h1ks (m-Re.;ycitJd P..tper {Minimum Jl:J% f>os1co11surneq
...-; 1·~.-~·~"::"'\'t,,, ~-• '. • Page 2
most likely contain concentrations of at least one inorganic compound in exceedance of the
clean-up levels. Therefore, I will not require EPA's contractor to obtain samples from Ponds 3
and 4 prior to removal and disposal will continue as planned .
• '' t t' • " -
R I May 1999 Sediment Data for Select Inorganics in Ponds (m• 1k g)
~' ~ ~Poiidf,~ i:R·7i':2'f, . on !· • WE<irui}3~ ~p•''"dl':41 .. on .. ,
Cooner 5.2 208 245 655 I.·•··._.
Iron 28,400 4,970 2,720 9,670
Lead 8.5 42.8 4.5 58.9
Zinc 28.7 106 4.3 117 ..
ERA December 200LS.ediment Data for Select Tnorgaiiics in Ponds (mg/kg)· · '' -~••;:: "'t>< U< .:.,, .. -·; -' ~,;-. ~P,ond~im ~Rorui}2~ lffono'B~I ..... -1\.z;, r.~1i:fon'\:11ii'li: ~.,.. -·· --o.:-·-·
Cooner 100 110 920 770
Iron 14,000 7,700 3,700 9,200
Lead 68· 81 7.9 120
Zinc 480 210 30 260
ecember 2001 Surface Water Data·for Select Inorganics in·P onds (µg/L) · ·
~~~ ~1r=,ir.1m1 ,_on ·t 1-. 1iRon"'df2~ ifi<'tiean'tuoJi!B\'eij
Coooer· · 61 <6.1 . ' .... ·7
Iron 6900 4800 -· 1000
Lead 35 8.6 2.5
Zinc 61 41 50
2. Groundwater Monitoring Schedule. Section 2.12.2.1 of th_e Record of Decision (ROD)
for the Site states, "Groundwater monitoring will take place annually, at a minimum, at the
existing monitor wells and former production wells and the data will be evaluated. All
groundwater samples will be analyzed for metals." During the Remedial Design (RD), I
scheduled semi-annual sampling because of the installation of the new monitoring well, and to
obtain more data-regarding thallium because of uncertainties in previous data. Because of the
installation of the new monitoring well, elevated concentrations found in it, and the "at a
minimum" language in the ROD, I have instructed Weston Solutions, Inc. (WESTON) to
continue with the planned September 2003 groundwater sampling and analysis event for the
Remedial Design. The groundwater sampling will occur on an annual basis during the Remedial
Action.
3. Amendment of ROD's Groundwater Monitoring Requirements. The groundwater
data at this Site has been puzzling throughout the RI and RD. The cleanup levels for
groundwater were set in the ROD for aluminum (16,000 µg/L) and thallium (2 µg/L) .. During ...
the RI, the cleanup level for aluminum was exceeded in temporary well TMW-8, in 1999, which
is the location of the newly installed MW-7. The cleanup level for thallium was exceeded in four
temporary wells sampled in 1999, and in production well PW-3 in 1999.
•• • Page 3
' .. '\,-. ...... ~··· .....
During the March 2003 RD groundwater sampling event, the only well with exceedances
of the ROD clean-up goals was MW-7S. During this sampling event, arsenic was detected above
the Safe Drinking Water Act Maximum Contaminant Level (MCL) of 10 µg/Lin well MW-2,
filtered (41µg/L}. However, it was not detected in the unfiltered sample from this well. The
MCLs for beryllium and lead were also exceeded in MW-7S. Groundwater samples could not be
obtained from PW-3 because of an obstruction. Page 5-7 of the Baseline Human Health Risk
Assessment for this Site stated that the carcinogenic risks in groundwater were largely due to
arsenic in on-site groundwater. · The concentration found during the March 2003 event in well
MW-2 (41 µg/L} was much higher than what was found during the RI (maximum detection of 3
µg/L}. Because of exceedances of MCL values for other constituents and knowing that a
decision.will.have to.be.made as.to,whether a groundwater remediation system is required,.l do ... _ .... ·
not agree with amending the ROD monitoring requirements at this time. This decision may be
re-evaluated'as.more data is received:
Design Criteria Report .
I. Revised Removal Volu·mes.· The revised volumes have been incorporated into the
preliminary construction cost estimate of the Remedial Design.
2. Construction of Access Roads. EPA would greatly appreciate improvement of the
access roads. If the access road improvements are made prior to finalization of the Remedial
Design, and they are sufficient to accommodate truck traffic during the Remedial Action, this
information will be incorporated into the design. If the improvements occur afterwards, but
before the remedial action, obviously this task, or a,portion thereof, of the scope of work will no
longer be required of the remediation contractor. Mr. Dannelly has EPA's response to the
proposed Interim Site Security Plan. ·
This concludes my response to your comments. Thank you for taking the time to review
documents related to this project and providing valuable comments. I look forward to meeting
with you again ori August 26, 2003 at 3 PM. If you have any questions, I can be reached at
[phone] or via e-mail at [e-mail].
cc: Teresa Offner, WESTON
David Mattison, NC DENR
Sara Ward, USFWS
Michel Gielazyn, NOAA-· ,
~~
Samantha Urquhart-Foster
Remedial Project Manager
North Site Management Branch
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET .
ATLANTA, GEORGIA 30303-8960
Ms. Teresa Offner
Site Manager
Weston Solutions, Inc.,.
5430 Metric Place, Suite 100
Norcross, GA 30092
• August l, 2003
Subject: Comments on the Data Evaluation Summary Report (Revision l) and the Design
Criteria Report (Revision 0)
Reasor Chemical Company Site -Remedial Design
Work Assignment Number 147-RDRD-A424
Dear Ms. Offner:
I have reviewed the Data Evaluation Summary Report Revision l and the Design Criteria
Report Revision 0, dated July 2003, which Weston Solutions, Inc. prepared for the Reasor
Chemical Company Site Remedial Design. In addition, the North Carolina Department of
Environment and Natural Resources (NC DENR), U.S. Fish and Wildlife Services (US FWS),
and the property owners' contractor, CH2M Hill, also reviewed these reports and subrnitted
comments to me. Their comments are enclosed.
Most of my few comments were .also reflected by NC DENR and USFWS. Therefore, I
will not repeat them. On the attached page, I will provide my comments not mentioned by others
and provide discussion/direction regarding some of the comments submitted from NC DENR,
USFWS, and CH2M Hill. I will not list/discuss each of their comments, but only ones that I
either have a differing opinion or that need further evaluation. If you have any questions, please
feel free to contact me at [phone].
cc: David Mattison, NC DENR
Sara Ward, US FWS
Kelly Stynes, CH2M Hill
Attachment
Enclosures (5)
Sincerely,
g~~
Samantha Urquhart-Foster
Remedial Project Manager
North Site Management Branch
1ntl=lme1 Address (URL) .. httµ://www.eµa.yov
fiflc.yr.lerJ/Roc.;y.:!ab!{l # l'rmlt,J wiU, Vt gelable Oil BaseJ Inks un RecycJed Paper (Minimum Jo~-~ Poslconsumur)
• •
Data Evaluation Summary Report. Revision 1
1. Now that the analytical data from the revised thallium analysis has been received, please
include it in the report. Since you mentioned yesterday that you still. have not received a
copy of the results, I am enclosing a copy, · · 0 •
2. NC DENR's comment #6 regarding well MW-2 turbidity was also one of my comments,
which we discussed yesterday. You said that on the original paper (not copies that we
received) the value for turbidity looks like 176 instead of 476. The value of 176 is also
more in line with·the other readings at-the well. Although there is a large numerical
difference between 176 and 476, both are above the recommend 10 NTU.
3. CH2M Hill's comment #2 discusses groundwater monitoring frequency. Section 2.12.2.1
of the Record of Decision·(ROD) for .the Site states, '-'Groundwater monitoring will take ,
place annually, at a minimum, at the existing monitor wells and former production wells
and the data will be evaluated. All groundwater samples will be 'analyzed for nietals."
During the Remedial Design, I scheduled semi-annual sampling because of the
installation of the new monitoring well, and to get more data regarding thallium because
of uncertainties in previous data. Because of the installation of the new monitoring well,
and elevated concentrations found in it, I would like to continue with the planned
September 2003 sampling and analysis event for the Remedial Design. However, for the
Remedial Action, sampling should occur on an annual basis. Please correct any
statements in the report which may indicate that sampling will be semi-annually instead
of annually during the Remedial Action.
4. CH2M Hill's comment #3 makes several valid points that I will take into further
consideration. However, at this time, please do not make any changes related to this
comment.
Design Criteria Report, Revision 0
1. In a meeting with the property owners on May 27, 2003, they offered the use of part of
their property as a borrow area, to obtain fill for backfilling excavated areas during the
remedial action. I will verify this with them. If this is a viable option, it could result in
cost savings.
2. Section 3.5 -Please revise the second sentence of this section. Semi-annual sampling is
scheduled for the Remedial Design, while annual sampling is intended for the Remedi_al
Action.
3. Whether or not the man-made ponds are considered wetlands appears to be an important
issue. Hopefully this will be resolved upon the U.S. Army Corps of Engineers visit to the
Site on August 27th. Because of U.S. Fish and Wildlife Services concern, I will also
invite them to meet me at the Site on that date to evaluate options for addressing this
issue. I will also discuss with the property owners the prospect of utilizing another area
of their property for habitat restoration, if needed.
• North Carolina
Department of Environment and Natural
Resources
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Ms. Samantha Urquhart-Foster
Superfund Branch
Waste Management Division
US EPA Region IV
·-th 61 Forsyth Street, 11 Floor
Atlanta, Georgia 30303
July 28, 2003
.. ·, ''
RE: Data Evaluation Summary Report (Revision I)
Reasor Chemical Company NPL Site
Castle Hayne, New Hanover County, North Carolina
Dear Ms. Urquhart-Foster:
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received the Data Evaluation Summary Report (Revision I) for the Reasor
Chemical Company National Priorities List (NPL) Site. The Superfund Section has reviewed this
document and offers the attached comments.
Thank you for the opportunity to comment on this document. If you have any questions, please
feel free to contact me at [phone], extension 349.
Attachment
Sincerely,
Di'i.,lflc( 13 /Y/c,._LL<'.Jv,~J c( J·
David B. Mattison, CHMM
Environmental Engineer
Supcrfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: 9'19-733-4996 \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL Oi'i'ORTUNITY \ AFFIRMATIVE ACl'ION EMPLOYER -50% RECYCLED/ 1()% POST CONSUMER PAPER
Ms. Samantha Urquhart-Foster
July 28, 2003
Page I
•
REASOR CHEMICAL COMPANY
•
DATA EVALUATION SUMMARY REPORT (REVISION 1)
Section 3.1 Operating History
1. Please correct the third sentence of the third paragraph qfSection 3.1 to state, "Raw
product from the extractor was transferred to the refinery and still, where it was distilled
and stored temporarily in ·the south tank•cradle and work-cradle•areas: '°' ... ,. · ·
Table 4-1 TCLP Analytical Summary Data Table
2. Please correct the spelling of the word "quantitation" as given in the definition of"BQL"
at the bottom of Table 4-1.
Section 4.5 Monitor Well Installation
3. Please define the acronym "CLP" in the eighth sentence of the third paragraph of Section
4.5.
4. Please define the acronym "FSAP" in the second sentence of the fifth paragraph of
Section 4.5.
Section 4.6.2 Groundwater Sampling Analytical Results
5. Please correct the second sentence of Section 4.6.2 to state, "From 0.01 to 10 microns in
. size, they will pass through the 0.45 micron filter recommended for filtering metals in
groundwater."
Table 4-4 Groundwater Samples, Total Metals Analytical Results Summary Table
6. Please verify that the turbidity for the groundwater sample collected from monitoring well
MW"2 is 176 nephelometric turbidity units (NTUs) as the field data sheet indicates that
the turbidity is 476 NTUs.
APPENDIX B LABORATORY ANALYTICAL REPORTS
7. The laboratory report documenting the Toxicity Characteristic Leachate Procedure
(TCLP) semi volatile.analytical results.for the sediment sample RC-SD-COMP I was
inadvertently omitted from Appendix B. Please correct this oversight.
•
Ms. Samantha Urquhart-Foster
July 28, 2003
Page 2
•
APPENDIXD
General
WETLANDS DELINEATION REPORT
8. Figu·re I -Site Location Map and Figure 2 -Site Map were inadvertently omitted from
the Wetlands Delineation Report submitted as Appendix D. Please correct this oversight.
Table of Contents
9. e_Jease correct the Table of Contents of the Wetlands Delineation Report submitted as
Appendix D to indicate that Section 4.2.2 -Wetland Hydrology is located on page 4-3.
Section 2.3 Site Soils
10. Please define the acronym "NRCS" in the first sentence of Section 2.3.
Section 3 Methods
11. Please define the acronym "COE" in the first sentence of Section 3.
North Carolina
Department of Environment and Natural •~·-· •· ·
Resources
Michael F, Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Ms. Samantha Urquhart-Foster
Superfund Branch
Waste Management Di.Yision
US EP K Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
July 28, 2003
RE: Design Criteria Report (Revision 0)
Reasor Chemical Company NPL Site
Castle Hayne, New Hanover County, North Carolina
Dear Ms. Urquhart-Foster:
•
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received the Design Criteria Report (Revision 0) for the Reasor Chemical
Company National Priorities List (NPL) Site. The Supcrfund Section has reviewed this document
and offers the attached comments.
Thank you for the opportunity to comment on this document. If you have any questions, please
feel free to contact me at [phone], extension 349.
Attachment
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL Ol'l'ORTUNITY \ AFFIRMATIVE ACTION E~IPLOYF,R -50% RECYCLED/ !0%'POST CONSUMER PAPER
Ms. Samantha Urquhart-Foster
July 28, 2003
Page I
•
REASOR CHEMICAL COMPANY
DESIGN CRITERIA REPORT (REVISION 0)
Section 1.l · Site/Facility Description
•
I. Please revise the last sentence of the first paragraph of Section I. I to define the acronym
"RD" .. , .
2. !'.lease revise the first sentence of the last paragraph of Section I) to define the acronym--
URI,,_
Section 2.1 Project Objectives
3. Please correct the last sentence of the first paragraph of Section 2.1 to state, "Meeting the
goals described previously will require addressing the following preliminary design
assumptions and parameters:".
4. Please revise the seventh bullet item of the first paragraph of Section 2.1 to define the
acronym "ARARs".
5. Please correct the eighth bullet item of the first paragraph of Section 2.1 to state,
"Technical factors of importance to the design and construction including use of currently
accepted environmental control measures, constructability of the design, and use of
currently acceptable construction practices and techniques".
Section 3.1 Waste Characterization
6. Please revise the second sentence of the second paragraph of Section 3.1 to define the
units "mg/1".
7. Please revise the eighth sentence of the second paragraph of Section 3.1 to define the
acronym "RCRA".
Section 3.6 Compliance with ARA Rs, Pertinent Codes, and Standards
· 8. Please revise the third item in the first paragraph of Section 3.6 to define the acronym
"OSHA".
9. Please revise the sixth item in the first paragraph of Section 3.6 to define the acronym
"NPDES''.
t,l-
•
Ms. Samantha Urquhart-Foster
July 28, 2003
Page 2
Section 3.10 Project Schedule
•
I 0. Please correct Section 3. IO to state, "A preliminary construction schedule will be
submitted under separate cover with the preliminary plans and specifications outlined."
• •
United States Department of the Interior··· · ~ · ·
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box. 33726
Raleigh, North Carolina 27636-S726
August I, 2003
Ms. Samantha Urquhart-Foster, Remedial Project Manager
North Superfund Remedial Branch
Waste Management Divsion, .. ,. "
U.S. Envjronmental Protection Agency
Atlanta Feiferal Center
6 I Forsyth Street
Atlanta, Georgia 30303-8960
Dear Ms. Urquhart-Foster:
Thank you for your July 17, 2003 correspondence requesting U.S. Fish and Wildlife Service
(Service) review of the Design Criteria Report (Revision 0) and the Data Evaluation Report
(Revision I) for the Reasor Chemical Company Site in Castle Hayne, New Hanover County, NC.
These comments are intended as technical assistance for the USEPA's assessments and planning
conducted pursuant to the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended (42 U.S.C. 9601 et seq.); they do not represent any position that the
U.S. Department of the Interior may adopt concerning possible injury to natural resources under
their trusteeship.
Several preliminary design assumpti0ns and parameters are identified in the Design Criteria
Report (OCR) to support remedial design for the selected remedy at the Reasor Chemical site
(removal of soil from contaminated areas onsite and removal of sediment I water from four
ponds with subsequent backfilling, regrading, and revegetation). · Given the habitat value present
onsitc, we appreciate that Section 3.5 of the DCR (Long-Term Performance Monitoring and
Opero/ions and .Mair.tenance Requir~mCnts) identifies_revcgeta:io:1 of cxcavUtcd areas ·.-vith
native plants as a rernedial goal. Previously the Record of Decision (ROD)for the site (dated
September 2002) indicated that cover of regraded areas would incorporate both native vegetation
and crushed stone. We would be pleased to provide assistance in selection of appropriate plant
species and sources of plant material for site restoration activities. Consistent with the goal of
rcvegctation with native plant species, it is important to detail performance criteria for this
objective (e.g .. percent cover of desirable vegetation to be achieved in a given time period) in
future remedial design plans.
Section 3.6 of the DCR (Co111p/ia11ce 1Fi1'1 AI/Al/s, l'erlinent Codes. and Standards) presents the
assumption that remediation of onsitc ponds is uni ikcly to adversely impact jurisdictional
wetlands (to be verified by the U.S. Anny Corps 01· Engineers). According to Appendix D
• • f
(Wetland Delineation Report) of the Data Evaluation Summary Report, portions of all four onsite
ponds proposed for remediation satisfy wetland criteria. While these ponds are of man-made
origin, they I) provide essential habitat to a variety of aquatic-dependent species currently using
the site, 2) support functions and values of wetland or open water habitats, and.3) are
hydrologically linked to downgradient wetland areas (including onsite drainage ditches and
Prince George Creek). The Service believes that wetland and open water habitat values which
are degraded or lost as part of the remedial action for site clean-up shoul_d ultimately be restored.
Compensation for lost use of wetland and open water habitat functions and values of site ponds
and wetlands should be addressed through wetland mitigation and habitat restoration in future
remedial design plans. We would be pleased to further discuss evaluation and restoration of . .
wetland and aquatic habitats, including on-and off-site options, with you,-the responsible parties,
and site contractors in support of additional,remedial design planning,•«·'
The Service appreciates the opportunity to comment on the Design Criteria Report and the Data
Analysis Reporrfor the Reasor Chemical Company Site. If you have any questions or comments'·
regarding our recommendations, please contact me at 919/856-4520, (Ext. 30). If you would like
to discuss restoration of native plant communities onsite and/ or sources of plant material for
planning purposes, please contact Mr. Dale Suiter (Ext. 18), our staff botanist, for additional
information.
Sincerely,.
Sara Ward
Ecologist
cc: Mr. Greg Hogue, REO, DOI/OEPC, Atlanta, GA
Dr. Bill Starke!, FWS, AES/HC, Atlanta, GA
Dr. Diane Beeman, FWS, AES/HC, Atlanta, GA
Ms. Michele Burgess, Acting ChieC USEPA/ETAG, Atlanta, GA
NCDSWM-Superfund Section, Raleigh, NC
Dr. Tom Dillon, NOAA, Atlanta, GA
2
CH2MHILL
July 30, 2003
•
Samantha Urquhart-Foster
USEPA
Region IV
61 Forsyth Street
Atlanta, Georgia 303?3
CH2M HILL
4824 Parkway Plaza Blvd
Suite 200
Charlotte, NC
28217-196B
Tel [phone]
Fax [phone]
Proud Sponsor of
National Engineers Week 2000
Re: Data Evaluation Report, Revision 1, Design Criteria Report, Revision 0
Reasor Chemical Company Site
Castle Hayne, North Carolina
Dear Ms. Urquart-Foster:
On July 21, 2003, CH2M HILL received a copy of the Data Evaluation Report,
Revision 1 and the Design Criteria Report, Revision 0. Ms. Hilda Dill and Ms. Jane
Sullivan have requested that CH2M HILL review these documents and provide
comments to EPA. The following letter provides CH2M HILL' s comments to these
documents.
Data Evaluation Report
1. Surface Water. The report provides the results of the surface water sampling .
conducted in March 2003. During field activities, EPA collected one discrete
sample for VOC TCLP analysis from Pond 2 and one composite sample from all
four ponds for TCLP metals and TCLP extractable organics analysis. All TCLP
results were below the quantitation limits and therefore, the report stated that
the surface water could be disposed of as non-hazardous waste.
Surface water samples from Ponds 3 and 4 were not evaluated for metals during
the Remedial Investigation and therefore, it is unknown if the surface water
concentrations in these ponds exceed the Clean-up Levels specified in the Record
of Decision (ROD). CH2M HILL recommends that the surface water from Ponds
3 and 4 be tested prior to removal to determine if there are exceedances of the
Clean-up Levels. If there are no exceedances, CH2M HILL recommends that
EPA investigate the feasibility of discharging the surface water from these ponds
onsitc. WESTON has estimated the surface water volume for Ponds 3 and 4 to
Dl:SIG/JCRI I EHIAOAT AEIJAI.LE ff ER.DOC
Ms. Urquart-Foster
Page2
July 30, 2003
• •
total 141,930 gallons. Using WESTON's estimated unit costs for surface water
transportation and disposal, onsite disposal of the water from Ponds 3 and 4
could reduce the total project costs by almost $30,000.
2. Groundwater Monitoring Schedule. Both the Design Criteria Report and the
Data Evaluation Report state plans to conduct groundwater monitoring on a
semi-annual basis. The Data Evaluation Report states intentions to collect
samples in September 2003. According to the ROD, groundwater is to be
monitored on an annual basis. For the reasons stated in the next section, if EPA
decides.to continue with groundwater monitoring for a five-year period, there is
certainly no justification to increase the monitoring frequency from the annual
. . sampiing specified in the ROD. . . . .
3. Amendment of ROD's Groundwater Monitoring Requirements. The data from
the most recent groundwater monitoring event is presented in the report. Of the
ten permanent monitoring wells and two production wells that were sampled,
only monitoring well MW-75 had an exceedance of a ROD-specified Clean-up
Level. The groundwater concentration in MW-75 exceeded the ROD-specified
Clean-up Level for aluminum. MW-75 was installed in March 2003 and this data
represents the first time that the well was sampled. The report stated the ·
fo)lowing in regards to the metals concentrations detected at MW-75:
"The elevated metals concentrations in groundwater sampled from MW-75
may be attributed to turbidity and low yield for this well. Another
contributing factor may be low pH. The pH for purge water from monitor
well MW-75 during development was 3.42. Following purge for sampling,
the pH was 2.31. If these field measurements accurately reflect the naturally
occurring pH for groundwater in this area and are not a artifact of recent well
installation and development acidity may be the primary reason dissolved.
metals were detected at elevated concentrations in groundwater sampled
from this area."
Aside from aluminum, thallium is the only other groundwater Chemical of
Concern listed in the ROD. The thallium results were not available at the time
the report was written, however EPA stated in its cover letter that all of the
thallium results were all below the maximum detection limit of 1 r1g/L.
CH2M HILL reviewed the groundwater monitoring well data collected during
the Remedial Investigation and in March 2003. With the exception of the
aluminum exceedance in MW-75 discussed above, there have been no
exceelfances of the ROD-specified Clean-up Levels in any other monitoring well.
The two groundwater COCs (Aluminum and Thallium) are naturally occurring
and were not detected in the onsite soils at significant concentrations.
OESIGNCRI I ERIAOAT AEVALLET1 ER DOC
·•, ' ... . ' \.•
Ms. Urquart-Foster
Page3
July 30, 2003
• •
Based on the i"ackof exceedances and the Jack of evidence that the groundwater
COCs are site-related, CH2M HILL recommends that the future groundwater
monitoring at the site be reduced. CH2M HILL recommends that monitoring
well MW-7S be redeveloped and resampled in March 2004 according to the
annual sampling frequency specified in the ROD. As no other well has ever
demonstrated concentrations of the COCs above the Clean-up Levels, there is no
justification for additional sampling at these wells. During the March 2004
sampling event, CH2M HILL recommends that particular attention be paid to
reduce the turbidity in this sample. If the turbidity can not be reduced to below
10 NTUs, a filtered sample should be collected as recommended by WESTON
(i:e_ collected through a device that enables the filtered and unfiltered samples to
be collected at the same time). The analysis of the March 2004 sample should be
limited to the ROD specified COCs -Aluminum and Thallium. If no
exceedances are detected in this sample, CH2M HILL recommends that the ROD
be amended and the groundwater monitoring program be stopped.
Design Criteria Report
·1. Revised Removal Volumes. EPA revised its estimate of the sediment volume to
be removed based on recent field measurements of the pond boundaries. This
resulted in a reduction of the estimated sediment removal volume from 1,252
cubic yards to 1,076 cubic yards. In addition, EPA revised its estimate of the
surface water volume to be removed based on recent field measurements of the
pond boundaries and surface water depth. This resulted in a reduction of the
estimated surface water removal volume of 526,592 gallons to 343,860 gallons.
The reduction in the sediment and surface water removal volumes will result in a
cost reduction for disposal and transportation of the affected media.
2. Construction of Access Roads. The report states that access roads will have to
be improved to accommodate truck traffic and that additional roads will have to
be installed to provide access to pond areas. Ms. Dill and Ms. Sullivan have
indicated that they intend to improve the roads between the property boundary
and the boundary of the Superfund Site. It is anticipated that these
improvements will be made when they implement the site security measures. It
is my understanding that EPA's comments on their proposal are being sent to
Bill Dannelly, the attorney for Ms. Dill and Ms. Sullivan. Mr. Dannelly reports
that he has not received those documents as of July 29.
!Vis. Jane Sullivan ,rnd Ms. Hilda Dill appreciate the opportunity to comment on the
above referenced reports. If you have any questions regarding the above
comments, please feel free to ml! Kelly Styncs at 919-363-4120 to discuss.
OE SIGt~Cfm ERi ADA T A[VALLE r TE R. DOC
Ms. Urquart-Foster
Page4
July 30, 2003
Sincerely,
\d~:~
KellyS~~'
•
Project Manager• , " , , · " ..
CH2M HILL
c: Hilda Dill
Jane Sullivan
Bill Dannelly/ Hunton & Williams
DESIGNCRITERIAOA f AEVALLE 1 TER.DOC
•
: ::~~ . · :\;1~·~~~i~1;i;t''.:~;_:;rir~·:·· • • ··--5'' .
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region 4
MEMORANDUM
Date: 07/22/2003
Science and Ecosystem Support Division
980 College Station Road
Athens,.Georgia 30605-2720
•
Subject: Results of METALS Sample Analysis ·
03-0361 •-Reasor Chemical
Castle Hayne, NC
From: Goddard, Denise ,;a-·-·
To: Urquhart-Foster, Samantha
CC: Ralph McKeen
RACS/W
Thru: QA Office
Attached are the revised Thallium results based on ICP/MS analysis of the water samples for this project. If
you have any questions, please contact me.
ATTACHMENT
, · '~~1t~·· ... /kf;.~:·
< ,,
~~~~!~~;·~·rt-t\mft '•·~:ff..:.;t,~~'{ ,_ . .u;~·
',, t,
Case Number: 31526
Project Number: 03-0361
• •
July
INORGANIC DATA QUALIFIERS REPORT
•
Site: Reasor Chemical, Castle Hayne, NC
Sarn:E::!:le No. Element Flag .Reason
5412 Tl no data qualifiers were applied
5413 Tl no data qualifiers were applied
5414 Tl no data qualifiers were applied
5415 Tl no data qualifiers were applied
5416 Tl no data qualifiers were applied
5417 Tl no data qualifiers were applied
5418 Tl no data qualifiers were applied
5419 Tl no data qualifiers were applied
5420 Tl no data qualifier_s were applied
5421 Tl u Baseline instability in cal blanks
5422 Tl no data qualifiers were applied
5423 Tl no data qualifiers were applied
5424 Tl no data qualifiers were applied
5425 Tl no data qualifiers were applied
542 6 Tl u Baseline instability in cal blanks
5427 Tl u Baseline instability in cal blanks
5428 Tl no data qualifiers were applied
5429 Tl no data qualifiers were applied
5430 Tl no data qualifiers were applied
5431 Tl no data qualifiers were applied
5432 Tl u Baseline instability in cal blanks
5433 Tl no data qualifiers were applied
Page 1 of 1
8, 2003
,., M\oT ALS SAMPLE ANAL_YSIS EPA-REGION IV SESD, ATHENS, GA
Sample 5412 FY _2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: RCIBL01 / ·
., Media: GROUNDWATER
; RESULTS UNITS 'ANALYTE
12 U UG/L Aluminum
2.3 U UGIL •Antimony
3.7 U UG/L Arsenic
0.51 UG/L · Barium
0.20 U UG/L Beryllium
0.40 U UGIL Cadmium
7.9 U UG/L Calcium
0.60 U UG/L Chromium
0.50 U UG/L Cobalt
1.5 U UG/L Copper
8.7 U UG/L Iron
1.1 U UG/L Lead
58 UG/L Magnesium
0.20 U UG/L Manganese
0.10 U UG/L Total Mercury
1.0 U UG/L Nickel
240 UG/L Potassium
2.6 U UG/L Selenium
0.70 U UG/L Silver
140 UG/L Sodium
1.0 U UG/L Thallium
0.40 U UG/L Vanadium
2.8 UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Casile Hayne, NC
Case No: 31526
MD No: 1TA9 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requestor: "
Project Leader: SURQUHAR
Beginning: 03/19/2003 08:00
Ending:
•
•
U•Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K·ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. 1 A-Analyte analyzed in replicate. Reported value is "average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problen:is. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS EPA -REGION IV SESD, ATHENS, GA
Sample 5413 FY. 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW1 /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
100 UJ UG/L Aluminum
2.3 U UG/L Antimony
9.1 R UG/L Arsenic
88 UG/L Barium
0.57 U UG/L Beryllium
0.40 U UG/L Cadmium
15000 UG/L Calcium
0.60 U UG/L Chromium
6.2 UG/L Cobalt
1.5 U UG/L Copper
8100 UG/L Iron
1.1 U UG/L Lead
3600 J UG/L MagnesiUm
45 UG/L Manganese
0.10 U UG/L Total Mercury
8.9 UG/L Nickel
1800 U UG/L Potassium
5.6 U UG/L Selenium
0.83 R UG/L Silver
9600 UG/L ·-·sodium
1.0 U UG/L Thallium
0.41 U UG/L Vanadium
7.7 U UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TB0 lnorg Contractor:' LIBRTY
Production Date: 07/22/2003 14:31
Produc~d by: Goddard, Denise
Aequestor: · ..
Project Leader: SUROUHAR
Beginning: 03/25/2003 16:45
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of arialyte is acceptable; reported value is an estimate. I UJ-Anafyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. j NJ-PresumptiVe evidence arialyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable: reported value may be biased low. Actual value expected to be greater than rePorted value.
NA-Not Analyzed. I NAJ-Not Arlalyzed due to lnt8rferences. I A-Analyte analyzed in replicate. Reported value is "average" of replicates. ·
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusabl;'
Page 1 of 1
ME,T ALS SAMPLE ANALYSIS EPA-REGION IV SESD, ATHENS, GA
Sample 5414 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
: Id/Station: GWMW2 /
• Media:GROUNDWATER
RESULTS
21 UJ
2.3 U
3.7 U
23
0.20 U
0.40 U
5500
0.60 U
0.50 U
1.5 U
2300
1.1 U
1400 J
44
0.10 U
1.0 U
1200 U
4.8 UJ
0.70 U
7100
1.0 U
0.40 U
4.8 U
NA
UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UGIL
UGIL
UGIL
UGIL
UG/L
UGIL
UG/L
UGIL
UGIL
UG/L
UG/L
UGIL
UG/L
UGIL
UG/L
UG/L
UG/L
UGIL
UGIL
ANALYTE
Aluminum
. Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
, Lead
, Magnesium
Manganese
.Total Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Jhallium
Vanadium
Zinc
Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TB1 lnorg Contractor:LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requesibr:
Project Leader: SUROUHAR
Beginning: 03/25/2003 14:15
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; anatyte reported as tentative identification. Reported value is an estimate.
K-ldentilication of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-1dentification of analyte is acceptable: reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is ~average" of replicates.
R-Presence or absence of ana1yte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
ME)"ALS SAMPLE ANALYSIS EPA-REGION IV SESD, ATHENS, GA
Sample 5415 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
ld/Slalion: GWMW2F /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
440 J UGIL Aluminum
2.3 U UG/L Antimony
41 UG/L Arsenic
25 UG/L Barium
0.20 U UG/L Beryllium
0.40 U UG/L Cadmium
5800 UG/L Calcium
6.8 UG/L Chromium
0.50 U UG/L Cobalt
1.9 R UGIL Copper
39000 UG/L Iron
1.1 U UGIL Lead
1400 J UG/L Magnesium
53 UG/L . Manganese
0.10 U UG/L Total Mercury
1.0 U UG/L Nickel
1200 U UGIL Potassium
5.9 J UGIL Selenium
0.70 U UG/L Silver
7100 UGIL Sodium
1.0 U UG/L Thallium
1.5 U UG/L Vanadium
7.3 U UGIL Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TB2 lnorg Contractor: LIBRTY
Production Date: 07/22/200314:31
Produced by: Goddard, Denise
RequestOr:
Project Leader: SURQUHAR
Beginning: 03/25/2003 14:15
Ending:
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; repdrted value is·an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present: analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Anatyzed. ! NAI-Not Analyzed due to lnterterences. I A-Analyte analyzed in replicate. Reported value is ·average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control prob1ems.-Oata are rejected and considered unusable. • J • ~ge1~1
METALS SAMPLE ANALYSIS ~ ' '
EPA-REGION IV SESD, ATHENS, GA
. Sample 5416 FY_ 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW3 /
Media: GROUNDWATER
RESULTS UNITS
160 UJ
2.3 U
3.7 U
32
0.20 U
0.40 U
6100
1.6 R
0.50 U
1.8 R
25000
1.1 U
1700 J
45
0.10 U
1.0 U
1400 U
2.7 UJ
0.84
12000
1.0 U
5.0 U
34 U
NA
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UGIL
UG/L
UG/L
ANALYTE
Aluminum
Antimony
.' Arsenic
Harium ·
Beryllium
·cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Total Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
Cyanide Analysis Not Requested·
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TB3 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requester: ·
Project Leader: SURQUHAR
Beginning: 03/25/2003 17:15
Ending:
' ' •
•
U-Analyte not detected at or above reporting limit. j J-ldentification of analyte is acceptable: reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. l NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K•ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the re.ported value.
L·ldentification·ot analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAl•Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is •average· of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS EPA -REGION IV SESD, ATHENS, GA
. Sample 5417 FY . 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW4D I
Media: GROUNDWATER
RESULTS UNITS ANALYTE
210 UJ UG/L Aluminum
2.3 U UG/L Antimony
3.7 U UG/L Arsenic
26 UG/L Barium
0.20 U UG/L Beryllium
0.40 U UG/L Cadmium
120000 UG/L Calcium
0.60 U UG/L Chromium
0.50 U UG/L Cobalt
1.5 U UG/L Copper
20000 UG/L Iron
1.1 u UG/L Lead
9600 J UG/L Magnesium
140 UG/L Manganese
0.10 U UG/L Total Mercury
1.5 R UG/L Nickel
3700 UG/L Potassium
2.6 U UG/L Selenium
0.70 U UG/L Silver
20000 UG/L Sodium
1.0 U UG/L Thallium
0.43 U UG/L Vanadium
4.0 U UG/L Zinc
NA UG/L 9yanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TB4 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produc~d by, Goddard, Denise
Requester:
Project Leader: SUROUHAR
Beginning: 03/25/2003 15:50
Ending:,
i
'
•
•
U-Analyte iiot detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-tdentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. 1 NAI-Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is "average" of replicates.
A-Presence or absence of analyYe can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
M~TALS SAMPLE ANALYSIS EPA -REGION IV SESD, ATHENS, GA
Sample 5418 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
ld/Station:GWMW4DF /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
21 UJ UG/L . Aluminum
2.3 U UG/L Antimony
3.7 U UG/L Arsenic
25 UG/L Barium
0.20 U UG/L Beryllium
0.40 U UG/L .cadmium
120000 UG/L Calcium
0.60 U UG/L Chromium
0.50 U UG/L Cobalt
1.5 U UG/L Copper
20000 UG/L Iron
1.1 U UG/L Lead
9400 J UG/L Magnesium
140 UG/L Manganese
0.10 U UG/L Total Mercury
1.0 U UG/L Nickel
4100 UG/L ·Potassium
5.2 J UG/L Selenium
0.70 U UG/L Silver
20000 UG/L Sodium
1.0 U UG/L Thallium•
0.40 U UG/L Vanadium
6.6 U UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TB5 lnorg Contractor: LIBRTY
Production Date: 07/22/200314:31
Produc~d by: Goddard, Denise
Requester:
Project Leader: SUROUHAR
Beginning: 03/25/2003 15:50
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. l UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. l NJ-Presumptive evidence analyte is present; ana1yte reported as tentative identification. Reported value is an estimate.
K·ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than t~e reported value.
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is ·average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS EPA-REGION IV SESD, ATHENS, GA
' . Sample 5419 FY 2003 Project: 03-0361
' Metals Scan
Facility: Reasor Chemical
Program: SF
ld/Station:GWMW4S I
Media: GROUNDWAT_ER
RESULTS UNITS ANALYTE
37 UJ UG/L Aluminum
2.3 U UG/L Antimony
3.7 U UG/L · Arsenic
24 UG/L Barium
0.20 U UG/L Beryllium
0.40 U UG/L Cadmium
120000 UG/L Calcium
0.60 U UG/L Chromium
0.50 U UG/L . Cobalt
1.5 U UG/L Copper
15000 UG/L Iron
1.1 u UG/L Lead
9000 J UG/L Magnesium
150 UG/L Manganese
0.10 U UG/L Total Mercury
1.0 U UG/L Nickel
4000 UG/L Potassium
4.9 UJ UG/L Selenium
0.70 U UG/L Silver
14000 UG/L Sodium
1.0 U UG/L Thallium
0.40 U UG/L Vanadium
4.4 U UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
"MD No: 1TB6 lnorg Contractor: LIBRTY
Production Date:· 07/22/2003 14:31
Produced by,: God_dard, Denise
Requester:
Project Leader: SUROUHAR
Beginning: 03/25/2003 15:15
Ending:·
•
•
U-Anatyte not detected at or above reporting limit. I J-ldentlficatlon of analyte is acceptable; reported value is' an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptivc evidence analyie is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. ! NAl-Not Analyzed du~ to Interferences. I A-Analyte analyzed in replicate. Reported value is "average" of replicates. 1 A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusabl~. , .. Page 1 of 1
METALS SAMPLE ANA!-YSIS EPA -REGION IV SESD, ATHENS, GA
Sample 5420 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW5 /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
150 UJ UGIL Aluminum
2.3 U UG/L Antimony
3.7 U UGIL Arsenic
19 UGIL Barium
0.20 U UGIL Beryllium
0.40 U UGIL Cadmium
2700 UG/L Calcium
0.81 R UGIL Chromium
0.50 U UGIL Cobalt
1.5 U UG/L Copper
44000 UG/L Iron
1.1 U UGIL Lead
1600 J UG/L Magnesium
19 UG/L Manganese
0.10 U UG/L Total Mercury
1.0 U UG/L Nickel
950 U UG/L Potassium
6.4 J UG/L Selenium
0.70 U UG/L Silver
7600 UGIL Sodium
1.0 U UG/L Thallium
2.8 U UG/L Vanadium
5.1 U UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TB7 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requestor: I
Project Leader: SURQUHAR
Beginning: 03/24/2003 13:33
Ending:
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence anatyte is present: analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K•ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
l·ldentificatlon of analyte is acceptable: reported value may be biased low. Actual vatue expected to be greater than reported value.
NA·Not Analyzed. ! NAl·Not Analyzed due to Interferences. j A·Analyte analyzed in replicate. Reported value is "average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS EPA -REGION IV SESD, ATHENS, GA
Sample 5421 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW6D /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
130 UJ UGIL Aluminum
2.3 U UG/L Antimony
3.7 U UG/L Arsenic
310 UGIL Barium
0.20 U UG/L Beryllium
0.40 U UGIL Cadmium
110000 UGIL Calcium
0.60 U UGIL Chromium
0.50 U UG/L Cobalt
1.5 U UGIL Copper
7000 UG/L Iron
1.1 U UG/L Lead
2800 J UGIL Magnesium
100 UG/L Manganese
0.10 U UG/L Total Mercury
5.7 UG/L Nickel
2500 U UG/L Potassium
5.1 U UG/L Selenium
0.70 U UG/L Silver
10000 UGIL Sodium
0.36 UJ UG/L Thallium
0.40 U UG/L Vanadium
2.5 U UG/L Zinc
NA UGIL Gvanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526·
MD No: 1TB8 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requesior: ·'
Project Leader: SURQUHAR
Beginning: 03/25/2003 12:20
Ending:·
•
•
U-Analyte not detected at or above reporting limit. 1 J-ldentification of analyte is acceptable; reported value is:an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present: analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentlfication of analyte is accep~able; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is ~average• of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and consider~d unusable. Page 1 of 1
I ,
METALS SAMPLE ANALYSIS EPA -REGION IV SESD, ATHENS, GA
Sample 5422 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW6S /
Media: GROUNDWATER
RESULTS UNITS ·ANALYTE
2100 J UG/L Aluminum
2.3 U UGIL Antimony
3.7 U UG/L Arsenic
37 UGIL Barium
0.20 U UGIL Beryllium
0.40 U UG/L Cadmium
4100 UG/L Calcium
3.9 UGIL Chromium
0.50 U UG/L Cobalt
1.5 U UGIL Copper
7900 UGIL Iron
1.2 R UG/L Lead
930 J UGIL Magnesium
54 UG/L Manganese
0.10 U UG/L Total Mercury
1.5 R UG/L Nickel
1300 U UG/L ~otassium
4.3 UJ UG/L Selenium
0.70 U UG/L Silver
7300 UGIL Sodium
1.0 U UGIL Thallium
4.6 U UG/L Vanadium
3.8 U UGIL Zinc
NA UGIL Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TB9 lnorg Contractor: UBRTY
Production Date: 07/22/200314:31
Produced by: God_dard, Denise
Requestor:
Project Leader: SUROUHAR
Beginning: 03/25/2003 13:00
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of ana1yte is acceptable: reported value is an estimate. I UJ-Analyte not detected at or above reportif1g limit. Rel)Orting limit is an_ estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value. · (
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is ·average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and consi~ered unusable. Page 1 of 1
i
METALS SAMPLE ANALYSIS EPA -REGION _IV SESD, ATHENS, GA
Sample 5423 FY : 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW6SF /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
120 UJ UG/L Aluminum
2.3 U UG/L Antimony
3.7 U UG/L Arsenic
29 UG/L Barium
0.20 U UG/L Beryllium
0.40 U UG/L Cadmium
4100 UG/L Calcium
0.60 U UG/L Chromium
Castle Hayne. NC
Case No: 31526
MD No: 1TCO lnorg Contractor: LIBRTY
Production Date: 07/22/200314:31
Produce_d by: Goddard:Denise
Requestor:
Project Leader: SUROUHAR
Beginning: 03/25/2003 13:00
Ending:·
j
, ¥-.
r.· -; ....
' : Ji 0.50 U UG/L Cobalt .J~ 1.5 U UG/L Copper . ..;,::;: 7200 UG/L Iron
1.1 U UG/L Lead
870 J UG/L Magnesium
54 UG/L Manganese
0.10 U UG/L Jotal Mercury
1.0 U UG/L Nickel
1200 U UG/L Potassium
3.6 UJ UG/L Selenium
0.70 U UG/L Silver
7200 UG/L Sodium
1.0 U UG/L Thallium
0.45 U UG/L Vanadium
4.4 U UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
•
U-Analyte not detected at or above reporting limit. I J-ldentification of anatyte is acceptable: reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present: analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is a~ceptable; reponed value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable; reponed value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. l NAI-Not Analyzed due to Interferences. ! A-Analyte analyzed in replicate. Reported value is •average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable.
Page 1 of 1
};(
. "
METALS SAMPLE ANALYSIS EPA -REGION IV SESD, ATHENS, GA
Sample 5424 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW7D /
Media:GROUNDWATER
RESULTS
830 J
2.3 U
3.7 U
62
0.20 U
0.40 U
160000
11
0.50 U
1.5 U
36000
1.1 U
7900 J
410
0.10 U
14
3100
5.2 U
0.70 U
13000
1.0 U
4.1 U
9.2 U
NA
UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
.ANALYTE
.Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Total Mercury
Nickel
Potassium
Selenium
· Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TC1 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requestor:
Project Leader: SUROUHAR
Beginning: 03/24/2003 17:25
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-tdentification at analyte is acceptable; reported value is an estimate. I UJ-Anatyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. ! NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K·ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L·ldentification of analyte is acceptable: reported value may be biased low. Actual vatue expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is ·average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS EPA-REGION IV SESD, ATHENS, GA
Sample 5425 FY; 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW7DF I
Media: GROUNDWATER
RESULTS UNITS ANALYTE
B4 UJ UG/L Aluminum
2.3 U UG/L Antimony
3.7 U UG/L Arsenic
55 UG/L 83.rium
0.20 U UG/L Beryllium
0.40 U UG/L Cadmium
150000 UG/L Calcium
0.60 U UG/L Chromium
0.50 U UG/L Cobalt
1.5 U UG/L Copper
35000 UG/L Iron
1.1 u UG/L Lead
7300 J UG/L Magnesium
390 UG/L Manganese
0.10 U UG/L Total Mercury
5.8 R UG/L Nickel
2900 UG/L Potassium
6.3 J UG/L Selenium
0.70 U UG/L Silver
12000 UG/L Sodium
1.0 U UGIL Thallium
0.40 U UGIL Vanadium
7.2 U UGIL Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle H_ayne, NC
Case No: 31526
MD No: 1TC2 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requester: '· I -
Project Leader: SURQUHAR
Beginning: 03/24/2003 17:25
Ending:
• -,
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present: analyte reported as tentative identification. I NJ-Presumptive evidence 8.nalyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. l NAI-Not Aiialyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is ·average• of replicates.
R-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS EPA-REGION IV SESD, ATHENS, GA
Sample 5426 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GWMW7S I
Media: GROUNDWATER
RESULTS UNITS ANALYTE
220000 J UG/L Aluminum
4.3 R UG/L Antimony
6.5 R UGIL ·Arsenic
47 UG/L Barium
8.3 UG/L Beryllium
0.40 U UGIL Cadmium
56000 UG/L Calcium
40 UG/L Chromium
230 UG/L Cobalt
91 UG/L Copper
160000 UG/L Iron
26 UG/L Lead
16000 J UGIL Magnesium
1300 UGIL Manganese
0.10 U UG/L Total Mercury
200 UG/L Nickel
3100 UGIL Potassium
6.9 J UG/L Selenium
0.70 U UG/L Silver
28000 UG/L Sodium
0.29 UJ UG/L Thallium
42 U UG/L Vanadium
440 UG/L Zinc
NA UG/L Cyanide
CyElnide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TC3 lnorg Contractor: LIBRTY
I
Production Date: 07/22/2003 14:31
Produce9 by: Goddard, Denise
Requester:
Project Leadef' SUROUHAR
Beginning: 03/24/2003 16:20
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. j UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. ! NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of ana1yte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value. ·
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is "average" of replicates.
Fl-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS EPA -REGION IV SESD, ATHENS, GA
Sample 5427 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor ChemiCal
Program: SF
Id/Station: GWMW7SF /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
240000 J UG/L Aluminum
3.8 R UG/L Antimony
3.7 U UG/L Arsenic
27 UGIL Barium
8.6 UG/L Beryllium
0.44 R UG/L Cadmium
42000 UGIL Calcium
26 UGIL chromium
250 UG/L Cobalt
170 UG/L Copper
170000 UG/L Iron
22 UG/L Lead
15000 J UG/L Magnesium
1300 UG/L Manganese
0.10 U UG/L Total Mercury
210 UG/L Nickel
2200 U UG/L Potassium
8.8 J UG/L S.elenium
0.70 U UGIL Silver
29000 UG/L Sodium
0.23 UJ UG/L Thallium
62 UG/L Vanadium
510 UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526.
MD No: 1TC4 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requester:
Project Leader: SURQUHAR
Beginning: 03/24/2003 16:20
Ending:
U-Analyte not detected at or above reporting limit. J-ldentification of analyte is acceptable; reported value is 'an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
•
•
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimB.te.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentitication of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. ! A-Analyte analyzed in replicate. Reported value is "average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable .
. • . 1 Page 1 of 1
METALS SAMPLE ANALYSIS EPA-REGION IV SESD, ATHENS, GA
Sample 5428 FY _2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: MBLWATER I
Media:WATER
RESULTS UNITS ANALYTE
33 U UGIL .Aluminum
1.8 U UGIL 'Antimony
3.6 U UG/L Arsenic
24 UGIL Barium
0.20 U UG/L Beryllium
0.30 U UG/L Cadmium
84000 UG/L Calcium
0.70 U UG/L Chromium
0.90 U UGIL Cobalt
120 UGIL Copper
15 U UGIL Iron
1.3 U UG/L Lead
2500 UG/L Magnesium
17 UG/L Manganese
0.10 U UG/L Total Mercury
1.3 R UG/L Nickel
1100 U UGIL Potassium
2.1 U UG/L Selenium
0.80 U UG/L Silver
8200 UG/L Sodium
1.0 U UG/L Thallium
0.89 UG/L Vanadium
160 UGIL Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requ9sted
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TD2 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requester:
Project Leader: SURQUHAR
Beginning: 03/26/2003 08:20
Ending:
•
•
U-Anatyte not detected at or aboye reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Ana1yte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present: analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is·an estimate.
K-ldentiflcation of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to Interferences. I A-Analyte analyzed in replicate. Reported value is •average• of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS EPA -REGION IV SESD, ATHENS, GA
Sample 5429 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: RB01 /
Media: GROUNOWATE\R
RESULTS UNITS ANALYTE
30 U UG/L Aluminum
1.8 U UGIL Antimony
3.6 U UGIL Arsenic
1.0 U UGIL Barium
0.20 U UGIL Beryllium
0.30 U UG/L Cadmium
26 U UGIL Calcium
0.70 U UG/L Chromium
0.90 U UGIL Cobalt
2.1 U UGIL Copper
15 U UGIL Iron
1.3 U UG/L Lead
7.4 U UG/L Magnesium
0.22 U UG/L Manganese
0.10 U UG/L Total Mercury
1.2 U UG/L Nickel
31 U UGIL Potassium
2.1 U UGIL Selenium
0.80 U UG/L Silver
560 U UG/L Sodium
1.0 U UG/L Thallium
0.70 U UG/L Vanadium
3.6 U UG/L Zinc
NA UG/L Cyanide
,.
Cyanide Analysis Not Requested
Thallium reported by ICPMS,
Castle Hayne, NC
Case No: 31526
MD No: 1TD3 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requester:
Project Leader: SUROUHAR
Beginning: 03/2612003 08:00
Ending:
I '
•
•
U-Analyte not detected at or a~ove reporting limit. \ J-ldentification of ana1yte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. ! NAI-Not Analyzed due to Interferences. \ A·Analyte analyzed in replicate. Reported value is "average" of replicates.
A-Presence or absence of ana(yte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable.
Page 1 of 1
METALS SAMPLE ANALYSIS EPA -REGION IV SESO, ATHENS, GA
Sample 5430 FY. 2003 Project: 03-0361
Metals Scan
Facility: ReaSor Chemical
Program: SF
Id/Station: GWPW1 /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
4600 J UG/L :Aluminum
3.9 R UG/L 'Antimony
15 U UG/L Arsenic
54 UG/L Barium
1.4 R UG/L Beryllium
0.40 U UG/L CadmiuiTI
36000 UG/L Calcium
4.7 UG/L Chromium
0.50 U UG/L Cobalt
18 UG/L Copper
120000 UG/L Iron
11 UG/L Lead
2800 J UG/L Magnesium
99 UG/L Manganese
0.10 U UGiL Jotal Mercury
7.4 UG/L _Nickel
340 U UG/L Potassium
4.8 UJ UGIL Selenium
0.70 U UG/L Silver
10000 UG/L Sodium
1.0 U UG/L Thallium
5.1 U UG/L Vanadium
78 U UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No' 31526.
MD No: 1TC5 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requestor:
Project Leader: SURQUHAR
Beginning: 03/24/2003 13:25
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present: analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K·ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-tdentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. 1 NA1-Not Analyzed due to Interferences. I A·Analyte analyzed in replicate. Reported value is "average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANALYSIS .. EPA -REGION IV SESD, ATHENS, GA
Sample 5431 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemic_al
Program: SF
Id/Station: GWPW 1 F /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
190 UJ UG/L Aluminum
2.3 U UG/L Antimony
3.7 U UG/L Arsenic
37 UGIL Barium
0.20 U UGIL Beryllium
0.40 U UGIL Cadmium
38000 UG/L Calcium
0.96 R UGIL Chromium
1.3 R UG/L Cobalt
1.5 U UGIL Copper
1600 UG/L Iron
1.1 U UG/L Lead
3100 J UGIL Magnesium
92 UGIL Manganese
0.10 U UG/L Total Mercury·
4.2 UG/L Nickel
670 U UG/L F?otassium
2.7 UJ UGIL Selenium
0.70 U UG/L Silver
11000 UGIL Sodium
1.0 U UG/L -Thallium
0.44 U UG/L Vanadium
20 U UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TC6 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requester:
Project Leader: SURQUHAR
Beginning: 03/24/2003 13:25
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. j UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported v8.tue is an estimate.
K-ldentification of analyte is acc~ptable: reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analy1e is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAI-Not Analyzed due to lnterterences. I A-Analy1e analyzed in replicate. Reported value is "average" of replicates.
A-Presence or absence of analyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable.
,., ,. Page 1 of 1
METALS SAMPLE ANALYSIS EPA-REGION IV SESD, ATHENS, GA
Sample 5432 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
Id/Station: GW PW2 /
Media: GROUNDWA TEA
RESULTS UNITS ANALYTE
1400 J UG/L Aluminum
2.3 U UG/L Antimony
4.0 R UG/L a Arsenic
81 UG/L Barium
0.20 U UGIL Beryllium
0.40 U UG/L Cadmium
40000 UG/L Calcium
3.8 UG/L Chromium
2.2 R UG/L Cobalt
1.5 U UG/L Copper
6300 UG/L Iron
1.1 U UG/L Lead
3900 J UG/L Magnesium
57 UG/L Manganese
0.10 U UG/L Total Mercury
2.2 R UG/L Nickel
1400 U UG/L Potassium
5.3 J UG/L Selenium
0.70 U UG/L Silver
11000 UG/L Sodium
0.26 UJ UG/L Thallium
4.8 U UG/L Vanadium
11 U UG/L Zinc
NA UG/L Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TC7 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requestor: 1 Project Leader: SUROUHAR
Beginning: 03/23/2003 18:20
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present: analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable; reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. ! NAI-Not Analyzed due to lnterlerences. I A-Analyte analyzed in replicate. Reported value is "average" of replicates.
R-Presence or absence of nnalyte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
METALS SAMPLE ANAL YSJS EPA-REGION JV SESD, ATHENS, GA
Sample 5433 FY 2003 Project: 03-0361
Metals Scan
Facility: Reasor Chemical
Program: SF
ld/Stalion:GWPW2D /
Media: GROUNDWATER
RESULTS UNITS ANALYTE
1400 J UG/L Aluminum
2.3 U UG/L Antimony
3.7 U UG/L Arsenic
80 UG/L Barium
0.20 U UG/L Beryllium
0.40 U UG/L Cadmium
40000 UGIL Calcium
1.9 UG/L Chromium
1.4 R UG/L Cobalt
1.5 U UG/L Copper
6400 UGIL Iron
1.1 U UG/L Lead
3900 J UG/L Magnesium
58 UGIL Manganese
0.10 U UG/L Total Mercury
1.1 R UGIL Nickel
1400 U UG/L Potassium
3.6 UJ UG/L Selenium
0.70 U UG/L Silver
9800 UG/L Sodium
1.0 U UGIL Thallium
4.1 U UGIL Vanadium
8.6 U UG/L Zinc
NA UGIL Cyanide
Cyanide Analysis Not Requested
Thallium reported by ICPMS
Castle Hayne, NC
Case No: 31526
MD No: 1TC8 lnorg Contractor: LIBRTY
Production Date: 07/22/2003 14:31
Produced by: Goddard, Denise
Requestor:
Project Leader: SUROUHAR
Beginning: 03/26/2003 18:20
Ending:
•
•
U-Analyte not detected at or above reporting limit. I J-ldentification of analyte is acceptable; reported value is an estimate. I UJ-Analyte not detected at or above reporting limit. Reporting limit is an estimate.
N-Presumptive evidence analyte is present; analyte reported as tentative identification. I NJ-Presumptive evidence analyte is present; analyte reported as tentative identification. Reported value is an estimate.
K-ldentification of analyte is acceptable; reported value may be biased high. Actual value expected to be less than the reported value.
L-ldentification of analyte is acceptable: reported value may be biased low. Actual value expected to be greater than reported value.
NA-Not Analyzed. I NAl•Not Analyzed due to lnterterences. j A-Analyte analyzed in replicate. Reported value is ~average" of replicates.
A-Presence or absence of anal~rte can not be determined from data due to severe quality control problems. Data are rejected and considered unusable. Page 1 of 1
• •
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33 726
Raleigh, North Carolina 276'6.3726
August I, 2003
Ms. Samantha Urquhart-Foster, Remedial Project Manager
North Superfund Remedial Branch .
Waste Management Divsion
U.S. Environmental Protection Agency
Allanta Federal Center
61 Forsyth Street
Atlanta, Georgia 30303-8960
Dear Ms. Urquhart-Foster:
Thank you for your July 17, 2003 correspondence requesting U.S. Fish and Wildlife Service
(Service) review of the Design Criteria Report (Revision 0) and the Data Evaluation Report
(Revision 1) for the Reasor Chemical Company Site in Castle Hayne, New Hanover County, NC.
These comments are intended as technical assistance for the USEPA's assessments and planning
conducted pursuant to the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended (42 U.S.C. 9601 et seq.); they do n_ot represent any position that the
U.S. Department of the Interior may adopt concerning possible injury to natural resources under
their trusteeship.
Several preliminary design assumptions and parameters-are identified in the Design Criteria
Report (DCR) to support remedial design for the selected remedy at the Reasor Chemical site
(removal of soil from contaminated areas onsite and removal of sediment I water from four
ponds with subsequent backfilling, regrading, and revegetation). Given the habitat value present
onsite, we appreciate that Section 3.5 of the DCR (Long-Term Performance Monitoring and
Operations and Maintenance Requirements) identifies revegetation of excavated areas with
native plants as a remedial goal. Previously the Record of Decision (ROD) for the site (dated
September 2002) indicated that cover of regraded areas would incorporate both native vegetation
and crushed stone. We would be pleased to provide assistance in selection of appropriate plant ·
species and sources of plant material for site restoration activities. Consistent with the goal of
revegetation with native plant species, it is important to detaii performance criteria for this
objective (e.g., percent cover of desirable vegetation to be achieved in a given time period) in
future remedial design plans ..
Section 3.6 of the OCR (Compliance with ARARs, Pertinent Codes, and Standards) presents the
assumption that remediation of onsite ponds is unlikely to adversely impact jurisdictional
wetlands (to be verified by the U.S. Army Corps of Engineers). According to Appendix D
• •
(Wetland Delineation Report) of the Data Evaluation Summary Report, portions of all four onsite
ponds proposed for remediation satisfy wetland criteria. While these ponds are of man-made
origin, they I) provide essential habitat to a variety of aquatic-dependent species currently using
the site, 2) support functions and values of wetland or open water habitats, and 3) are
hydrologically linked to downgradient wetland areas (including onsite drainage ditches and
Prince George Creek). The Service believes that wetland and open water habitat values which
are degraded or lost as part of the remedial action for site clean-up should ultimately be restored.
Compensation for lost use of wetland and open water habitat functions and values of site ponds
and wetlands should be addressed through wetland mitigation and habitat restoration in future
remedial design plans. We would be pleased to further discuss evaluation and restoration of
wetland and aquatic habitats, including on-and off-site options, with you, the responsible parties,
and site contractors in support of additional remedial design planning.
The Service appreciates the opportunity to comment on the Design Criteria Report and the Data
Analysis Report for the Reasor Chemical Company Site. If you have any questions or comments
regarding our recommendations, please contact me al 919/856-4520, (Ext. 30). If you would like
to discuss restoration of native plant communities onsite and/ or sources of plant material for
planning purposes, please contact Mr. Dale Suiter (Ext. 18), our staff botanist, for additional
information.
Sincerely,
Sara Ward
Ecologist
cc: Mr. Greg Hogue, REO, DOI/OEPC, Atlanta, GA
Dr. Bill Starke!, FWS, AES/HC, Atlanta, GA
Dr. Diane Beeman, FWS, AES/I-IC, Atlanta, GA
. Ms. Michele Burgess, Acting Chief, USEP A/ETAG, Atlanta, GA
NCDSWM-Superfund Section, Raleigh, NC
Dr. Tom Dillon, NOAA, Atlanta, GA
2
North Carolina • Department of Environment and Natural
Resources
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
• &l!?'A __ •;~~
m •'----NCDEMR
July 28, 2003
Ms. Samantha Urquhart-Foster
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I 1th Floor
Atlanta, Georgia 30303
RE: Design Criteria Report (Revision 0)
Reasor Chemical Company NPL Site
FILE COPY
Castle Hayne, New Hanover County, North Carolina
Dear Ms. Urquhart-Foster:
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received the Design Criteria Report (Revision 0) for the Reasor Chemical
Company National Priorities List (NPL) Site. The Superfund Section has reviewed this document
and offers the attached comments.
Thank you for the opportunity to comment on this document. If you have any questions, please
feel free to contact me at [phone], extension 349.
Attachment
Sincerely,
i) ct.vi. d 13 . li1 o.Xu:. Ser.-, / df
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: ,vww.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTIOcx EMPLOYER-SO% RECYCLED/ 10% POST CONSUMER PAPER
•
•
""7
~
(;'.'';:}
~?
~ »
•
Ms. Samantha Urquhart-Foster
July 28, 2003
Page I
REASOR CHEMICAL COMPANY
DESIGN CRITERIA REPORT (REVISION 0)
Section 1.1 Site/Facility Description
•
I. Please revise the last sentence of the first paragraph of Section 1.1 to define the acronym
"'RD".
2. Please revise the first sentence of the last paragraph of Section 1.1 to define the acronym
."RI".
Se"ction 2.1 Project Objectives
3. Please correct the last sentence of the first paragraph of Section 2.1 to state, "Meeting the
goals described previously will require addressing the following preliminary design
assumptions and parameters:". ·
4. Please revise the seventh bullet item of the first paragraph of Section 2.1 to define the
acronym "ARARs".
5. Please correct the eighth bullet item of the first paragraph of Section 2.1 to state,
"Technical factors of importance to the design and construction including use of currently
accepted environmental control measures, constructability of the design, and use of
currently acceptable construction practices and techniques".
Section 3.1 \Vaste Characterization
6. Please revise the second sentence of the second paragraph of Section 3.1 to define the
units "mg/I".
7. Please revise the eighth sentence of the second paragraph of Section 3.1 to define the
acronym "RCRA".
Section 3.6 Compliance with ARARs, Pertinent Codes, and Standards
8. Please revise the third item in the first paragraph of Section 3.6 to define the acronym
"OSHA".
9. Please revise the sixth item in the first paragraph of Section 3.6 to define the acronym
"NPDES".
-· •
Ms. Samantha Urquhan-Fostcr
July 28, 2003
Page 2
Section 3.10 Project Schedule
•
10. Please correct Section 3.10 to state, "A preliminary construction schedule will be
submitted under separate cover with the preliminary plans and specifications outlined."
North Carolina •
Department of Environment and Natural
Resources
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Ms. Samantha Urquhart-Foster
Superfund Branch
Waste Management Division
US EPA Region IV
6 I Forsyth Street, I I th Floor
Atlanta, Georgia 30303
•
July 28, 2003 FILE COPY
RE: Data Evaluation Summary Report (Revision I)
Reasor Chemical Company NPL Site
Castle Hayne, New Hanover County, North Carolina
Dear Ms. Urquhart-Foster:
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received the Data Evaluation Summary Report (Revision I) for the Reasor
Chemical Company National Priorities List (NPL) Site. The Superfund Section has reviewed this
document and offers the attached comments.
Thank you for the opportunity to comment on this document. If you have any questions, please
feel free to contact me at [phone], extension 349.
Attachment
Since.rely,
u Ci..<..1/.0 6. /ll o.;.U<. ~ If,.-' I d }
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: wvvw.em.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER C 50':. RECYCLED/ 10% POST CONSUMER PAPER
• •
•
Ms. Samantha Urquhart-Foster
July 28, 2003
Page I
REASOR CHEMICAL COl\1PANY
•
DATA EVALUATION SUMMARY REPORT (REVISION i)
Section 3.1 Operating History
I. Please correct the third sentence of the third paragraph of Section 3.1 to state, "Raw
product from the extractor was transferred to the refinery and still, where it was distilled
and stored temporarily in the south tank cradle and work cradle areas."
Table 4-1 TCLP Analytical Summary Data Table
2. Please correct the spelling of the word "quantitation" as given in the definition of"BQL"
at the bottom of Table 4-1. ·
Section 4.5 Monitor Well Installation
3. Please define the acronym "CLP" in the eighth sentence of the third paragraph of Section
4.5.
4. Please define the acronym "FSAP" in the second sentence of the fifth paragraph of
Section 4.5.
Section 4.6.2 Groundwater Sampling Analytical Results
5. Please correct the second sentence of Section 4.6.2 to state, "From 0.01 to IO microns in
size, they will pass through the 0.45 micron filter recommended for filtering metals in
groundwater."
Table 4-4 Groundwater Samples, Total Metals Analytical Results Summary Table
6. Please verify that the turbidity for the groundwater sample collected from monitoring well
MW-2 is 176 nephelometric turbidity units (NTUs) as the field data sheet indicates that
the turbidity is 476 NTUs.
APPENDIXB LABORATORY ANALYTICAL REPORTS
7. The laboratory report documenting the Toxicity Characteristic Leachate Procedure
(TCLP) semivolatile analytical results for the sediment sample RC-SD-COMP I was
inadvertently omitted from Appendix B. Please correct this oversight.
•
Ms. Samantha Urquhart-Foster
July 28, 2003
Page 2
•
APPENDIXD
General
WETLANDS DELINEATION REPORT
8. Figure I -Site Location Map and Figure 2 -Site Map were inadvertently omitted from
the Wetlands Delineation Report submitted as Appendix D. Please correct this oversight.
Table of Contents
9. Please correct the Table of Contents of the Wetlands Delineation Report submitted as
Appendix D to indicate that Section 4.2.2 -Wetland Hydrology is located on page 4-3. ·
Section 2.3 Site Soils
I 0. Please define the acronym "NRCS" in the first sentence of Section 2.3.
Section 3 Methods
11. Please define the acronym "COE" in the first sentence of Section 3.
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4WD-NSMB
Mr. David Mattison
Superfund Section
NCDENR
401 Oberlin Road, Suite 150
Raleigh, NC 27605
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
July 18, 2003
• l--~Wf{_R F lLN D .Sf CTI O ~! .. I
SUBJECT: Design Criteria Report, Revision 0, Data Evaluation Report, Revision 1, Thallium
Groundwater Results
Reasor Chemical Company Site, Castle Hayne, New Hanover County, N~
Dear Mr. Mattison:
Enclosed are copies of the Data Evaluation Report, Revision l, and the Design Criteria
Report, Revision 0, for the Reasor Chemical Company Site located in Castle Hayne, New
Hanover County,'North Carolina. If you have any comments regarding the Design Criteria
Report, please submit them to me by July 31, 2003.
Yesterday I received faxed results from the re-analysis of thallium in the groundwater
samples that were collected in March. All results were below the maximum detection limit of l
µg/L. Once I receive the entire data package, I will forward it to you. I appreciate your
assistance with this project. If you have any questions, I can be reached at [phone] or via
e-mail at [e-mail].
Enclosures (2)
Sincerely,
£~~
Samantha Urquhart-Foster
Remedial Project Manager
North Site Management Branch
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable• Printed with Vegetable 00 Based Inks on Recycled Paper (Minimum 30% Postconsumer)
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Ms. Teresa Offner
Site Manager
Weston Solutions, Inc.
5430 Metric Place, Suite 100
Norcross, GA 30092
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA. GEORGIA 30303-8960
June 20, 2003
Subject: Comments on the Data Evaluation Summary Report
Reasor Chemical Company Site
Work Assignment Number 147-RDRD-A424
( 1.
Dear Ms. Offner:
! ,, I have reviewed the Data Evaluation Summary Report, dated June 2003. which Weston
Solutions, Inc. prepared for the Reasor Chemical Company Site Remedial Design. Please
address my comments, which arc attached.
If you have any questions, please feel free to contact me at (404) 562-S760.
Sincerely,
Samantha Urquhart-Foster
Remedial Project Manager
North Siw Management Branch
cc: David Mattison, NC DENR
Attachment
lntemet Address (URL)• http://www.epa.gov
~iacyclfid/Recyclabl9 • Prinled with V~getable Oil Based Inks on Recyck!d Paper (Minimum 30% Postconsumer)
I.
j 2.
• • 0
RPM Comments on the Data Evaluation Summary Report (06/20/2003)
Reasor Chemical Company Site -Remedial Design
Figure 4-1 °
/ a. Please add RC-SD-0 I to the figure. 0 ...I b. Please add pond numbers 1-4 next lo the appropriate pond.
Section 4.6, page 4-8 states that there was an obstruction in PW-3. Table 4-3
indic1tcs that there was an obstruction i,1 PW-2. Please correct the error in the
appropriate place.
3. Sections 4.6.2 and 5.2-Arsenic was detected at 41 µ.g/L, which is above the
Maximum Contamin;nt Level (MCL), in the filtered sample from ·well MW-2, but
was below the detection limit of 3.7 /tg/L in the unfiltered sample from this same
well. The.concentration of Iron was also significantly greater in the filtered sample\.\
than in the unfiltered sample (39,000 µ.g/L vs 2,300 µ.g/L). The concentration of
aluminum was also significantly greater in the filtered sample than in the unfiltered
sample (440 J µ.g/L vs below detection limit of 21 J µ.g/L). In general, the other wells
that had both filtered and unfiltered samples showed similar concentrations or the
filtered result was less than unfiltered result. Please discuss this uncertainty/anomaly
for well MW-2 in section 5.2
j 4. Table 4-4, sample MW-2 -The Field Data Sheet found in Appendix C for well MW-
2 indicated the turbidity was 476 NTU at the sample time. Table 4-4 lists the
turbidity for this well as 20.7 NTU. According to the Field Data Sheet in Appendix
C, 20.7 NTU was the turbidity reading just before the well purged clry. Please correct
Table 4-4.
Js. The Field Data Sheet found in Aµpcll(lix C !"or well MW-7S states "low flow not
applicable'' in the comment section. Why was low now not applicable') Would this
contribute to the high turbidity/elevated conccntr:1ticms'J
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4WD-NSMB
Mr. David Mattison
Superrund Section
NC DENR
40 I Oberlin Road, Suite 150
Raleigh, NC 27605
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
June 3, 2003
SUBJECT: Data Evaluation Summary Report, Revision 0, June 2003
Reasor Chemical Company Site
Castle Hayne, North Carolina
Dear Mr. Mattison:
JUN -6 2003
Enclosed is ,i copy of the Data Evaluation Summary Report, prepared by Weston
Solutions, Inc. as part of the Remedial Design at the Reasor Chemical Company Site. Weston
Solutions, Inc. has informed me that this report will either be revised or an addendum created to
address outstanding data gaps. These data gaps include, at a minimum, the results of the re-
analyzed groundwater samples for thalliurh at lower detection limits and the wetland delineation
survey: These two items arc expected to be completed by the end of this month. I appreciatc any
comments your office may have on this document. If you have any questions, I can be reached ar
[phone].
Enclosure
Sincerely,
£~-~
Samantha Urquhart-Foster
Remedial Project Manager
North Site Management Branch
Internet Address {UAL) • http://www.epa.gov
Recycled/Recyclable • Prinled wilh Vegetable on Based Inks on Recycled Paper (Minimum 30% Postconsumer)