NCD981927502_19941219_Geigy Chemical Corporation_SERB C_Correspondence 1992 - 1994-OCR

State of North Carolin& a
Department of Environ,.t,
Health and Natural Resources
Division of E'1vironmentai Managen:ent
James 8. Hunt, Jr., Governor
Jonathan 8. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
December 19, 1994
HNB
RECEIVED \
Mr. Garland E. Hilliard, Project Coordinator
Olin Corporation, Ciba-Geigy Corporation
Kaiser Aluminum & Chemical Corporation
I 186 Lower River Road, NW
Charleston, Tennessee 37310
Dear Mr. Hilliard:
JAN 3 11995
suPERFUNO SECTION
Subject: Permit No. -.,-00009949
Ocigy Chemical Coq,oration Site
Former Pesticide Blending Facility
Groundwater Remediation Facilities
Town of Aberdeen, North Carolina
Moore County
In accordance with your application received August 31, 1994, we are forwarding herewith Permit
No. WQ0009949 dated ~mbcr 19, 1994, ,to Olin Corporation, Ciba-Geigy Corporation, and Kaiser
Aluminum & Chemical Corporation for the construction a11d operation of the subject groundwater
remediation facility. Please note, this permit requires additional monitoring wells and maps to be provided.
This permit shall be effective from the date of issuance until!lllovember 30, 19Q9, and shall be
subject to the conditions and limitations as specified therein. Please pay particular attention to the
monitoring requirements in this permit. Failure to establish an adequate system for collecting and
maintaining the required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter I SOB of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings, P.O. Drawer
27447, Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
One set of approved plans and specifications is being forwarded to you. If you need additional
information concerning this matter, please contact Mr. John Seymour at [phone].
cc: Moore County Health Department
RUST Environment & Infrastructure
Fayetteville Regional Office, Water Quality Section
___ Fayetteville Regional Office, Groundwater Section
Jack Floyd, Groundwater Section, Central Office
Training and Certification Unit
Facilities Assessment Unit
Sincerely,
A~:~~f.2~ '1'"
flECEI\1ED
DEC 2? \995
ENV M/>.N;\GEMEN1 \
FAY[Tf[\!il!. E flEG. OFFICl:1 _
P.O. Box 29535, Raleigh, North Carolina 27626-0535
An Equal Opportunrty Affirmative Action Employer
Telephone [phone] FAX [phone]
50% recycledr'TO% post-consumer paper
• NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
GROUNDWATER REMEDIATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Olin Corporation, Ciha-Geigy Corporation, Kaiser
Aluminum & Chemical Corporation
Moore County
FOR THE
construction and operation of a 30,000 GPD groundwater remediation facility consisting of five (5)
recovery wells (4 with jet pumps and one with electric submersible), a 500 gallon equalization tank with
dual transfer pumps, dual bag filters in parallel. two parallel sets of three 165 pound carbon adsorption
canisters in series (each set designed to handle 10 gpm flow), a lift pump station to the infiltration
galleries, three infiltration galleries at 200 feet long by 2 feet wide by 15 feet deep each (set so one gallery
can be taken off line for maintenance at any one time), and all associated piping, valves, controls, meters,
and appurtenances to serve the Geigy Chemical Corporation Site, former pesticide blending & formulation
facility, near Aberdeen North Carolina with no discharge of wastes to the surface waters, pursuant to the
application received August 31, 1994, and in conformity with the project plan, specifications, and other
supporting data subsequently filed and approved by the Department of Environment, Health and Natural
Resources and considered a part of this permit
This permit shall be effective from the date of issuance until November 30, 1999, and shall be
subject to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
I. Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted
facility has been installed in accordance with this permit, the approved plans and
specifications, and other supporting materials. Mail the Certification to the Water Quality
Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC 27626-0535.
2. The Fayetteville Regional Office, telephone number 910/ 486-1541 shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an in-place
inspection can be made. Such notification to the regional supervisor shall be made during
the norm'111 office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
1
. .
3.
4.
5.
6.
7.
This permit sh.ecome voidable if the soils fail to ade-tely assimilate the wastes and
may be rescinded unless the facilities are installed, maintained, and operated in a manner
which will protect the assigned water quality standards of the surface waters and ground
waters.
In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those
actions that may be required by this Division, such as the construction of additional or
replacement treatment or disposal facilities.
The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this facility.
Any residuals generated from these treatment facilities must be disposed in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Environmental Management
Diversion or bypassing of the untreated groundwater from the treatment facilities is
prohibited.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times.
2. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of
the wastewater treatment facilities. The operator must hold a certificate of the type and
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A. Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class II, III, and IV facility at least daily, excluding weekends and
holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A, .0202. Once
the facility is classified, the Permittee must submit a letter to the Certification Commission
which designates the operator in responsible charge within thirty days after the wastewater
treatment facilities are 50% complete. ·
3. The facilities shall be effectively maintained and operated as a non-discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring deemed necessary by the Division of Environmental Management to insure
surface and ground water protection will be established and an acceptable sampling
reporting schedule shall be followed.
2. Noncompliance Notification:
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone
number 910/ 486-1541 as soon as possible, but in no case more than 24 hours or on the
next. working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any occurrence at the wastewater treatment facility which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such as
the dumping of the contents of a basin or tank, the known passage of a slug of
hazardous substance through the facility, or any other unusual circumstances;
2
b. Any proce.it failure, due to known or unknown~sons, that renders the facility
incapable of adequate wastewater treatment, such as mechanical or electrical failures of
pumps, aerators, compressors, etc.;
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to
such station or facility; or
d. Any time that self-monitoring information indicates that the facility is not in compliance
with its permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REQUIREMENTS
I. Prior to beginning waste disposal operations, three additional monitor wells (MW-16S,
MW-17S, and MW-18S) shall be installed to monitor groundwater quality in the vicinity of
the infiltration gallery. The well(s) shall be constructed such that the water level in the well
is never above or below the screened (open) portion of the well at any time during the year.
The general location and name for each well is marked on Attachment A.
2. Monitor wells MW-1S, MW-1D, MW-2S, MW-3S, MW-6S, MW-6D, MW-10S, MW-
11D, MW-12S, MW-13S, MW-16D, MW-17D, and MW-18D, and the new wells MW-
16S, MW-17S, and MW-18S shall be sampled every January, April July and October
using the following methods and parameters:
EPA SW-846 Method 5030/8240
EPA SW-846 Method 3520/8080
pH
Water Levels
The measurement of water levels must be made prior to sampling for the remaining
parameters. The depth to water in each well shall be measured from the surveyed point on
the top of the casing.
The measuring points (top of well casing) of all monitoring wells shall be surveyed to
provide the relative elevation of the measuring point for each monitoring well.
3. The effluent from the treatment system shall be sampled once every two (2) weeks for the
first three (3) months and monthly thereafter for the parameters specified below:
EPA SW-846 Method 5030/8240
EPA SW-846 Method 3520/8080
pH
Water Levels
4. The results of the sampling and analysis shall be sent quarterly to the Groundwater Section,
Permits and Compliance Unit, P.O. Box 29535 Raleigh, N.C. 27626-0535 on Form GW-
59 [Compliance Monitoring Report Form] for all groundwater quality data every February,
May, August, and November. Effluent data may also be reported quarterly along with the
groundwater quality data. --•
5. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall
be provided.
3
6.
7.
8.
The three new.s that are constructed for purposes o.undwater monitoring shall be
constructed in accordance with 15A NCAC 2C .0108 (Standards of Construction for Wells
Other than Water Supply) and any other state and local laws and regulations pertaining to
well construction.
The Fayetteville Regional Office, telephone number 910/ 486-1541 shall be notified at least
forty-eight (48) hours prior to the construction of any monitoring well so that an inspection
can be made of the monitoring well location. Such notification to the regional groundwater
supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on
Monday through Friday, excluding state holidays.
Within sixty (60) days of completion of all monitoring wells, the permittee shall submit two
original copies of a scaled topographic map (scale no greater than I": 100') signed and
sealed by a professional engineer or a state licensed land surveyor that indicates all of the
following information:
a. the location and identity of each monitoring well,
b. the location of the waste disposal system,
c. the location of all property boundaries,
d. the latitude and longitude of the established horizontal control monument,
e. the relative elevation of the top of the well casing (which shall be known as the
"measuring point"), and
f. the depth of water below the measuring point at the time the measuring point is
established.
The survey shall be conducted using approved practices outlined in North Carolina General
Statutes Chapter 89C and the North Carolina Administrative Code Title 21, Chapter 56.
The surveyor shall establish a horizontal control monument on the property of the waste
disposal system and determine the latitude and longitude of this horizontal control
monument to a horizontal positional accuracy of+/-above shall be surveyed relative to this
horizontal control monument. The positional accuracy of features listed in a. through e.
above shall have a ratio of precision not to exceed an error of closure of I foot per I 0,000
feet of perimeter of the survey. Any features located by the radial method will be located
from a minimum of two points. Horizontal control monument shall be installed in such a
manner and made of such materials that the monument will not be destroyed due to
activities that may take place on the property. The map shall also be surveyed using the
North American Datum of 1983 coordinate system and shall indicate the datum on the map.
All bearings or azimuths shall be based on either the true or NAD 83 grid meridian. If a
Global Positioning System (GPS) is used to determine the latitude and longitude of the
horizontal control monument, a OPS receiver that has the capability to perform differential
GPS shall be used and all data collected by the GPS receiver will be differentially
corrected.
The maps and any supporting documentation shall be sent to the Groundwater Section,
N.C. Division of Environmental Management P.O. Box 29535 Raleigh, N.C. 27626-
0535.
9. Upon completion of all well construction activities, a certification must be received from a
professional engineer certifying that the monitoring wells are located and constructed in
accordance with the Well Construction Standards (15A NCAC 2C) and this permit. This
certification should be submitted with copies of the Well Completion Form (GW-1) for
each well. Mail this certification and the associated GW-1 forms to the Permits and
_..,,,.-.~--. ~-~~:Compliance Unit;"Ground~r Section, P.O. Box 29535, Raleigh, NC, 27626-0535. -
4
10. For the initial s.ling of the well as specified elsewhe.the permit. the permittee shall
submit a copy of the GW-1 Form (Well Completion Form) with the Compliance
Monitoring Form (GW-59) for that well. Compliance Monitoring Forms that do not include
copies of the GW-1 form will be returned to the permittee without being processed. Failure
to submit these forms as required by this permit may result in the initiation of enforcement
activities pursuant to NC General Statutes 143-215.6.
11. All components of the groundwater recovery, treatment, and disposal system shall be
properly weather-proofed to prevent freezing and failure of the system.
12. The groundwater recovery, treatment and disposal system shall be inspected weekly. If it
is determined that the system is malfunctioning, all repairs should be made as soon as
possible and reported to the Fayetteville Regional Office within 48 hours.
13. The groundwater treatment system shall consistently achieve an effluent quality that is
compliant with 15A NCAC 2L (Groundwater Standards) prior to discharge to the
infiltration gallery. If the treatment system fails to consistently achieve this standard,
additional treatment units or changes in operational methods, may be required.
14. Isoconcentration (lines connecting points of equal concentration) maps in both the vertical
and horizontal directions shall be developed using the April groundwater monitoring data.
A water level contour map must also be developed on a annual basis using the April data.
These maps shall be submitted along with all other monitoring data for that period.
V. INSPECTIONS
1. Adequate inspection, maintenance and cleaning shall be provided by the Permittee to insure
proper operation of the subject facilities.
2. The Permittee or his designee shall inspect the groundwater recovery and treatment
facilities to prevent malfunctions and deterioration, operator errors and discharges which
may cause or lead to the release of wastes to the environment, a threat to human health, or a
nuisance. The Permittee shall maintain an inspection log or summary including at least the
date and time of inspection, observations made, and any maintenance, repairs, or corrective
actions taken by the Permittee. This log of inspections shall be maintained by the Permittee
for a period of three years from the date of the inspection and shall be made available to the
Division of Environmental Management or other permitting authority, upon request.
3. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related to the disposal site or facility at any reasonable time for the
purpose of determining compliance with this permit, may inspect or copy any records that
must be maintained under the terms and conditions of this permit, and may obtain samples
of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
1. Issuance of this permit does not constitute approval for reimbursement from the Leaking
Petroleum Underground Storage Tank Cleanup Funds (15A NCAC 2P).
2. This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans and specifications, and other supporting
data.
3. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data. --· ·
5
4. This permit is. transferable. In the event there is a.ire for the facilities to change
ownership, or there is a name change of the Permittee, a formal permit request must be
submitted to the Division of Environmental Management accompanied by an application
fee, documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of this request will be considered on its merits and may or may
not be approved.
5. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
6. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6(a) to 143-215.6(c).
7. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by !SA NCAC 2H .0205
(c)(4).
8. The issuance of this permit does not preclude the Perrnittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
9. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request. the Commission will review the adequacy of the
facilities described therein, and if warranted, will extend the permit for such period of time
and under such conditions and limitations as it may deem appropriate.
Permit issued this the 19th day of December, 1994
NORTH CAROLINA ENVIRONMENT AL MANAGEMENT COMMISSION
A. Preston ijo •ard. Jr., P.E., irector
Division of En · onmental Management
By Authority of the Environmental Management Commission
Permit Number WQ0009949
6
-
Permit No. WQ0009949
December 19, 1994 •
ENGINEER'S CERTIFICATION
•
I, ----,--------' as a duly registered Professional Engineer in the State of North
Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the
project, _____________________________ for the
Project Name Location
Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and
intent of this permit, the approved plans and specifications, and other supporting materials.
Signature ___________________ Registration No. _____ _
Date _______ _
7
SCALE 1:24 000
:=f:½=CE========OE=SESE=E=E=ESE=ESESESE==SaC'=C'==EC'==31 MILE
1000 2000 JOO() 4000 5000 6000 7000 FE[T
5 0 I J(ILOMETER ==a:===::E=================="===
CONTOUR INTERVAL 10 FEET
NATIONAL GEOOCTIC VERTICAL DATUM OF 1929
MAP COMPLIES WITH NATIONAL MAP ACCURACY STANDARDS
.ALE• BY U.S. GEOLOGICAL SURVEY. RESTON. VIRGINIA 22092
'.SCRl6,NG TOPOGRAPHIC MAPS AND SYMBOLS IS AVAILABLE ON REQUEST
ASHLEY HEIQHTS 2.IJ M. rEFORD 1• Ml.
QUADRANGLE LOCATION
ROAD CLASSIFICATION
Heavy-duty light-duty ...... ----
Medium-duty .. Unimproved dirt ........ .
Qu.S. Route Q State Route
SOUTHERN PINES, N. C.
NW/4 SOUTHERN PINES 15' OUADRAHOL!
35079-B4-TF-024
1967
PHOTOAEVISEO 1984
OMA 5154 Ill NW-SERIES Y842
This map was reproduced by electronic color scanning of an earlier printing (1960
'
State of North cAna
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, SecretaryDecember 16,
William L. Meyer, Director
Mr. Luis Flores
Remedial Project Manager
North Superfund Remedial Branch
345 Courtland Street, NE
Atlanta, Georgia 30365
RE: Comments on Draft Downgradient Groundwater Investigation Work
Plan
Geigy Chemical Corporation Site
NCD 981 927 502
Aberdeen, Moore County, NC
Dear Mr. Flores:
The Draft Downgradient Groundwater Investigation Work Plan for
the Geigy Chemical corporation Site, located in Aberdeen, North
Carolina has been received and reviewed· by the North Carolina
Superfund Section. The following comments are offered by the North
Carolina Superfund Section.
1. The purge volume equation shown on page 3-15 should be
corrected as follows:
V = (nr 2h) x 7.481
-2. Water sent to the land surface containing acetone should
meet the NCAC 2L Standard of < O. 7 mg/kg promulgated
October 19, 1993. See the Spent Decontamination Fluids
Section on page 3-25.
3. Spent drilling fluids and soil cuttings generated from
saturated portions of the second uppermost aquifer are
discussed on pages 3-25 & 3-26. This investigation
derived waste must be containerized and as a minimum
solidified and disposed in a Solid Waste Landfill. The
Landfill's management can provide details for
solidification of drilling fluid and saturated soil
cuttings with ash or other materials.
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
RD
\
Mr. Flores
12-16-94
Page 2
• •
purged groundwater will be treated on-site using
activated carbon canisters and released to the land
surface on the facility property. Treated purge water
may not be discharged to the ground surface as proposed.
The State recommends the following two alternatives for
disposal of the purge water and other fluids resulting
from drilling operations at the site.
After treatment and testing of the fluids for TCE and
Target Compound List Pesticides, the results should be
provided to the Fayetteville Regional office, Non-
Discharge Permit Applications Branch of the DEM Water
Quality Section.
A. If the permit for the on-site infiltration gallery
is complete, the fluids and purge water may be
discharged to the permitted infiltration gallery.
The volume to be discharged and the analytical
results must first be provided to the DEM as noted
above for approval. The discharge rate must be
within the permit limits.
B. The fluids and purge water may be discharged to the
Moore County Water and Sewer Authority (MOWASA) as
a one time, small volume discharge. The discharge
must be authorized by MOWASA and then presented to
the DEM Water Quality Section for approval.
6. The addendum to the Health and Safety Plan, Appendix A,
should include in addition to the personnel protection
equipment listed, employees taking acidified water
samples should wear appropriate gloves, goggles, and
splash shields. Tyvek suits should be worn while bailing
wells, and occasional air monitoring with a PID or FID is
recommended.
If you have any questions or comments, please do not hesitate
to contact us at, [phone].
Sincerely, (,'\
\j/0 ·~-~~\cL,l~V\
Randy McElveen \
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
; • •
December 13, 1994
MEMORANDUM
To:
From:
RE:
File
Randy McElveen
Environmental Engineer
NC Superfund Section
The EPA and PRP Meeting on Model Calibration
Geigy Chemical NFL Site
NCD 981 927 502
Aberdeen, Moore County, NC
On 8 December 1994, a representative of the NC Super fund
Section participated in a meeting with the EPA and the PRP
representatives. The Superfund Section participated through a
conference call to the EPA Region IV office located in Atlanta,
Georgia. The meeting was called to present the proposed
calibration input data for the Groundwater Flow Model MODFLOW.
MODFLOW was proposed by the PRPs as the model to be used on the
uppermost aquifer at the Geigy Chemical Corporation NPL Site
located in Aberdeen, Moore County, NC.
The Draft Groundwater Flow Model calibration Results, dated 3
December 1994, was provided for review by the EPA and the State
prior to this meeting. The EPA contractor, CDM Federal, provided
two significant comments on the groundwater model calibration data.
1. Are the clay thickness zones shown on Figure 5 supported
by sufficient data to provide the associated recharge
rates? This question remained unresolved during the
meeting.
2. The simulated water level contours for the uppermost
aquifer shown in Figures 6 & 7 of the subject document
were not consistent with the observed water level
contours or with the monitoring well water levels. This
comment was also debated and remained unresolved during
the meeting.
The State provided two related comments on the model
calibration data.
1. How were the recharge rates on Figure 5 determined for
the different zones and how sensitive are these recharge
rates to changes in the system? Are the clay zones and
• •
Memorandum to File
12-13-94
Page 2
recharge rates realistic when compared to the field data from the
site?
Vedat Batu with RUST E&I, the PRP contractor, responded that
the zones evolved during the calibration process. Vedat explained
that the various input data is adjusted until the simulation is
consistent with the observed data from the site. Vedat suggested
that the process has become very complicated due to the complex
flow system at the site and the limited data. He also seemed to
suggest that the recharge zones were sensitive to changes in the
system.
2. The hydraulic conductivity rate in cm/ sec, shown on
Figure 4 for monitoring well ow-2s, is inconsistent with
the rate listed in Table 1 for the same well.
Vedat said that 10-• as listed in Table 1 was correct.
The 10-6 as noted on Figure 4 was a typographical error.
RUST E&I will make this correction and provide the
results to the EPA and the state.
The State also asked if the correct data was used during
the calibration process and Vedat said that it was.
The constant head evaluation at the "pinch out" line shown on
Figure 6 as the southern boundary of the uppermost aquifer, has
created some complications in deciding the simulated water level
contours for the Site. It appears that additional calibration
efforts should be performed before the preliminary model is ready.
cc: Jack Butler, NC Superfund
• •
December 3, 1994
Mr. Luis Flores
Remedial Project Manager
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
USEPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, GA 30365
RD
.CEDV~D
DEC O 5 1994
RE: Draft Groundwater Flow Model Calibration Results and Draft Conference Call Agenda
Geigy Chemical Corporation Site c_ _ [\ A..
Aberdeen, North Carolina · t~...w/. N1i ✓, z..qJ ,99,
VIA FEDERAL EXPRESS
Dear Mr. Flores:
On behalf of Olin Corporation, Ciba0Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), attached are seven copies of the referenced documents. The
documents are being submitted for your review prior to our conference call on December 8.
Copies of the referenced documents have been sent directly to Mr. Winston Smith of the
USEPA, Mr. Tim Eggert and Mr. Mark Taylor of CDM, and Mr. Randy McElveen of the
NCDEHNR.
The conference call on December 8 is scheduled to begin at 2:45 pm. To access the conference
call, dial the following phone number: [phone]. The pass code for the call is "Geigy". -=
We are looking forward to the conference call with you and discussing these materials further.
Please feel free to contact me at [phone] if you have any questions or require additional
information.
Sincerely,
Garland Hilliard
Project Coordinator
• •
DRAFT AGENDA
GROUNDWATER MODELING CALIBRATION RESULTS
GEIGY CHEMICAL CORPORATION SITE
CONFERENCE CALL
DECEMBER 8, 1994
2:45 PM
1.0 INTRODUCTIONS
2.0 DISCUSSION OF GROUNDWATER MODELING CALIBRATION RESULTS (AS
NECESSARY)
2. I Model domain and boundary conditions
2. 2 Model input parameters
2.2.1 Hydraulic conductivity
2.2.2 Leakage rate
2.2.3 Aquifer bottom elevation
2. 3 Model evaluation under static (non-pumping) conditions
2. 3. I Observed and simulated hydraulic heads at monitoring well locations
2. 3. 2 Observed and simulated groundwater contours
2.3.3 Observed and simulated groundwater flow direction
2.3.4 Observed and simulated hydraulic gradients
2.4 Model evaluation under PW-IS pumping conditions
2.4.1 Observed and simulated hydraulic heads at observation well locations
2.4.2 Observed and simulated groundwater contours
2.4.2 Observed and simulated drawdowns
2.5 Conclusions
3.0 REVIEW SCHEDULE FOR REMAINDER OF MODELING
4.0 ACTION ITE?,fS/ SUMMARY
Mr. Luis Flores
December 3, 1994
Page Two
/ Attachments
•
c: W. Smith (USEPA)
T. Eggert (CDM)
M. Taylor (CDM)
~R. McElveen (NCDEHNR)
J. Serfass (Olin)
H. Moats (Ciba)
G. Crouse (Ciba)
J. Vinzant (Kaiser)
V. Batu (RUST)
J. Cloonan (RUST)
M. Sheehan (RUST)
S. Sargent (RUST)
RUST E&I Project File 7.4.5
•
MEMORANDUM
To:
From:
RE:
•
December 1, 1994
File
Randy McElveen
Environmental Engineer
NC Superfund Section
Remedial Overview Field Sampling
Geigy Chemical NPL Site
NCD 981 927 502
•
Aberdeen Pesticide Dump, Route 211
NCD 980 843 346
Aberdeen, Moore County, NC
On 30 November 1994, a representative of the NC Superfund
Section provided remedial overview of a field sampling event in the
new area of the proposed infiltration gallery at the Geigy Chemical
Corporation NPL Site located in Aberdeen, Moore County, NC. The
work in this area was performed by F&R Drilling out of Raleigh, NC.
The soil types and stratigraphy logged by the RUST E&I geologist,
Leanne Wagg er, were observed and discussed. A one foot thick
plastic clayey silt layer noted at 2.0 and 8.0 feet below ground
surface was of concern since infiltration may be perched on this
confining unit. Photographs were taken of borings and adjacent
monitoring wells and piezometers.
A concrete monument was also installed in the area of MW-4D.
This monument will be surveyed at a latter date and used to
establish the exact location of the infiltration gallery. I
departed from the site around 4:00 Pm.
The surface casing for the last deep monitoring well was also
being installed at the Route 211 area of the Aberdeen Pesticide
Dumps Site. I briefly walked through the site noting the various
work areas and new wells. I discussed the work and the proposed
disposal procedures for the drilling mud from the wash-bore
operations with the EPA Oversight contractor Philip Nicholson.
Appropriate disposal practices are being practiced. Departed from
site around 3:30 Pm.
cc: Jack Butler, NC Superfund Section
• •
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
November 30, 1994
Mr. Luis Flores
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: History for November 17th Meeting
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Mr. Flores:
~D
Dtc -.• 0
011994
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Coq,oration (the Companies), attached is one copy of the referenced document. Copies of this
document have been sent directly to Mr. Winston Smith of the USEPA, Mr. Tim Eggert and
Mr. Mark Taylor of CDM, and Mr. Randy McElveen of the NCDEHNR.
Plea:;e feel free to contact me at [phone] if you have any questions or require additional
infmmation.
Regards,
Garland Hilliard
Project Coordinator
•
/ Attachment
c: W. Smith (USEPA)
T. Eggert (CDM)
M. Taylor (CDM)
R. McElveen (NCDEHNR) .
J. Serfass (Olin)
H. Moats (Ciba)
G. Crouse (Ciba)
J. Vinzant (Kaiser)
V. Batu (RUST)
J. Cloonan (RUST)
M. Sheehan (RUST)
S. Sargent (RUST)
RUST Project File 7.4.5
•
• I idlff ENVIRONMENT & I INFRASTRUCTURE HISTORY
PLACE:
DATE OF MEETING:
PRESENT FOR:
Meeting History No. 6
Geigy Chemical Corporation Site
Remedial Design
RUST E&I Project No. 86619.500
EPA Region IV Office
Atlanta, Georgia
November 17, 1994
Olin Corporation
Mr. Garland Hilliard
Mr. Jack Serfass
Ciba-Geigy Corporation
Mr. Harold Moats
Mr. George Crouse
United States Environmental Protection Agency
Mr. Luis Flores
Mr. Winston Smith
Camp Dresser & McKee Federal
Mr. Tim Eggert
Mr. Mark Taylor
North Carolina Department of Environment. Health and Natural
Resources
Mr. Randy McElveen
RUST Environment & Infrastructure
Mr. Vedat Batu
Mr. Jim Cloonan
Mr. Orlando Rodriguez
Ms. Stacy Sargent
Mr. Michael Sheehan
CORRECTIONS AND OMISSIONS
This history is the writer's interpretation of the events, discussions, and transactions which took
place during the meeting. If there are any additions and/or corrections to this history, please
inform the writer within 14 days.
• PURPOSE OF MEETING
The purpose of the meeting was to discuss EPA' s requests in their letter dated October 13, 1994,
to answer any questions on the work descriptions submitted on November 10, 1994, and to
discuss the preliminary results of the additional groundwater modeling. The meeting agenda is
attached.
ITEMS OF DISCUSSION
The meeting lasted from approximately 1:15 PM to 3:30 PM with a 10 minute break. Major
resolutions and issues discussed were:
I. Flores opened meeting by stating that the objective was to allow the Companies to ask
EPA/CDM questions on their letter dated October 13, 1994. Introductions were made
by all.
2. Hilliard stated that Companies agreed to implement EPA' s requests and were here to
present their approach. Input was requested from EPA/CDM so that the final product
would be satisfactory to all. The Companies wou.ld like there to be an exchange of
information and for design to proceed. The Companies have started the additional
groundwater modeling and would like to obtain feedback from EPA/CDM during this
meeting on the modeling objectives, design, and initial calibration results.
3. Cloonan reiterated the redefined objectives for Remedial Design:
• prevent contaminant migration from uppermost to second uppermost aquifers
• minimal dispersion of the TCE plume
• expeditious remediation of groundwater.
The Companies do not intend the proposed groundwater remediation system to
necessarily be the final solution. EPA guidance recommends a phased approach and the
· ROD allows for modification of the operating groundwater remediation system. System
performance will be based on actual performance and modified as necessary.
4. Sargent described the objectives for the additional groundwater modeling efforts in the
uppermost aquifer:
• confirm and enhance understanding of groundwater flow
• evaluate additional extraction scenarios
• evaluate release zones for infiltration galleries.
The conceptual model of the hydrogeology beneath the former facility was presented
using Earth Visions software, which portrayed the thinning of the uppermost aquifer to
the south. Taylor asked whether there was any direct evidence of clay thickness to the
south. Sargent replied yes, from borings P-7, P-8 and MW-llD. Taylor asked if the
uppermost aquifer was present to the south. Sargent replied no but that the uppermost
clay is present in varying thicknesses. Sargent stated that the· characterization to the
south is sufficient for extraction design. Taylor stated that the clay appeared to be thick
to the south. Sargent replied that the clay thickness is a projection of the model and not
necessarily accurate in areas with limited data.
5. Sargent stated that the modeling would only address the uppermost aquifer, since there
is no direct hydraulic connection between the uppermost and second uppermost aquifers.
Taylor stated he had no objection.
2
• •
6. Sargent stated that the uppermost aquifer was to be modeled as one unit. Smith asked
if this was based only on visual observations. Sargent replied no, that there was also
data from the aquifer test, slug tests, and the piezocone borings.
7. Taylor said that modeling the aquifer as one unit was fine but that using one layer
assumed two~dimensional flow, which would not address the vertical flow component.
Batu stated that the underlying clay has more than two orders of magnitude less hydraulic
conductivity than the overlying aquifer, which means that the flow in the aquifer is
dominantly two dimensional (2-D) and the flow in the confining layer is vertical. Batu
added that there are published papers supporting this approach. Taylor said that this .was
acceptable except near the pinch out points. Batu replied that there the saturated
thickness gradually decreases towards the pinch out lines because the vertical flow
component through the clay confining layer varies from location to location.
8. Batu described the basis for the modeling approach, including use of a 2-D. calibration
and a no flow boundary to the northwest. Taylor asked if tins was based on data. Batu
replied no, that this was based on extrapolation of the saturated thickness data. Taylor
requested that the northwestern no flow boundary be realigned to more closely lie
perpendicular to the flow lines. The Companies agreed. During the break, this
boundary was further discussed by Taylor, Batu and Sargent using the preliminary
calibration figure. Taylor requested that the northwest boundary be simulated as a
prescribed head boundary and this was agreed to.
9. Smith asked if there was a flux condition to the south. Batu replied no. Taylor stated
that the flow lines should end in the south since there is no horizontal flow in this portion
of the Site and therefore the maps shouldn't show the potentiometric surface there.
Sargent stated that south was made a no flow boundary in . response to a previous
. comment by EPA/CDM. It was agreed that the model would evaluate both a no flow
condition and a constant head boundary set to zero feet for the south, to determine which •
has the better calibration.
IO. Batu de~cribed the preliminary input parameters·. Taylor asked how leakage was
simulated. Batu replied as negative recharge. Taylor asked if this was uniform, Batu
replied that zones of varying leakage rate would be used. Taylor proposed that the clay
layer be added to the model, making it a 3-D model. Batu asked what kind of boundary
conditions would be assigned to the bottom of the clay layer. Taylor replied that the
bottom elevations of the clay unit should be set to atmospheric pressure and the vertical
hydraulic conductivities should be varied during the calibration process. Batu replied that
using a 2-D model and negative recharge rates; the rnodel will be calibrated with the
observed heads. The resulting leakage rates will then be evaluated using the thickness ·
and lithologic data of the clay layer, with refinement as necessary. Batu also noted that
if the approach proposed by Taylor was used, the same approach would be necessary for
the calibrated vertical hydraulic conductivities, which would complicate the modeling.
Batu then summarized the modeling approach by stating the groundwater flow model will
be 2-D and the leakage rates from the bottom of the aquifer will be simulated as negative
recharge rates in the aquifer. After model calibration, the leakage rates at different
locations through the clay layer will be evaluated by the thickness and lithologic data of
3
• •
the clay layer, with refinement as necessary. Batu added that the calibrated model will
be evaluated against the aquifer test data. This approach was acceptable to EPA/CDM.
11. Sargent noted that conference calls were planned after key modeling steps, such as
calibration and simulation of extraction alternatives, to present results to EPA/CDM.
Flores and Taylor said this was acceptable.
12. Batu described the use of MODFLOW for modeling the aquifer and MODPATII for
evaluating capture zones. Batu asked for comments on the models but there were none.
Aquifer test data will be used to calibrate the model. The current average difference in
observed vs. calculated heads is 2. 7 feet but this will be improved. The Companies will
also evaluate hydraulic gradients to assess the goodness of calibration.
13. Taylor asked about the distance of the observation wells from the pumping well during
the aquifer test. Sargent said 15 to 50 feet. Taylor said the grid spacing was 25 feet.
Sargent stated the current grid was preliminary and would be refined in the test area.
14. Taylor stated that the re-evaluation of extraction scenarios should address the objective
of preventing migration from the uppermost to the second uppermost aquifer. Cloonan
replied that this objective would be evaluated using the additional modeling but that
models have limitations. The installed system would be evaluated in the field to assess
effectiveness. Taylor replied that a system that will not meet the objectives should not
be installed. Cloonan stated that mass removal was an objective of the system and the
concentrations in the uppermost aquifer are the result of soil concentrations prior to the
two removal actions. Infiltration will help accelerate· restoration of the uppermost
aquifer. EPA guidance prescribes a phased approach for groundwater restoration and the
ROD allows modifications of the system based on actual response. Flores stated that the
initial design should address the remediation objectives. Cloonan stated that the revised
PDR will address how the extraction scenarios address the remediation objectives.
15. Flores said there were no comments on the work description for the additional infiltration
pilot test. Cloonan stated that the borings may be conducted sometime between
November 28th to 30th if a hollow-stem rig could be found since RUST would have
personnel in the area. Otherwise, the borings and the test would be conducted the week
of December 5th contingent on subcontractor availability. Flores said this was
acceptable.
16. Cloonan asked whether the PDR could be revised using replacement pages and new
appendices. Flores requested a complete document. The Companies agreed to this.
17. The information to be submitted with the additional modeling was reviewed. Taylor said
that the list looked good but should include hydrostratigraphic (as opposed to
stratigraphic) cross-sections. The Companies agreed to this.
18. Tentative dates for the conference calls were discussed, Hilliard will confirm dates with
Flores next week. McE!veen asked to be included in the calls.
19. Taylor stated that EPA approval of the PDR will likely be 30 days after receipt. The RD
schedule will be revised accordingly. Conference calls will be excluded from the
schedule at the request of Flores.
20. McElveen described the status of the TCE investigation. The State has started a
preliminary assessment of the Crestline Site, McElveen issued a letter to the PA/SI office
requesting that this effort be accelerated. NCDOT has installed monitoring wells at Lee
4
•
paving, analytical testing is in progress. McElveen is not concerned, based on projected
infiltration rates, about potential mounding or dispersion of TCE by the proposed
infiltration gallery. The State wants to remediate the source of TCE as quickly as
'possible.
21. Hilliard summarized action items as:
• modeling efforts would re-assign the northwestern boundary as prescribed head,
evaluate no flow and zero head conditions at the south boundary, and assign
leakage based on clay thickness
• submit the Preliminary Design Report in its entirety
• revise the RD schedule
• call from Hilliard to Flores to schedule conference calls and the infiltration pilot
test.
22. Hilliard closed by stating that the Companies want to facilitate the exchange of
information throughout the remedial process so that the Site can effectively move towards
remediation.
RUST Environment & Infrastructure
Jialoonan
/ Attachment
November 29, 1994
5
•
AGENDA
REVISED PRELIMINARY DESIGN MEETING
GEIGY CHEMICAL CORPORATION SITE
USEPA OFFICES -ATLANTA, GEORGIA
NOVEMBER 17, 1994
1:00 PM
1.0 INTRODUCTIONS
2.0 DISCUSSION OF REQUESTED TASKS
2. I Remedial Design Objectives
2.2 Groundwater Modeling
2. 3 Evaluation of Extraction Design
2.4 Infiltration Pilot Test
2.5 Submittal Content/Format
3.0 SCHEDULE
4.0 OTIIER ISSUES
4.1 TCE
5.0 ACTION ITEMS/ SUMMARY
\
NOV 23 '94 02:04PMiST ENV-INFRASTRUC.
, ..... ENVIRONMENT& I
IW>I tN:FRASfRUCTURE FACSIMILE TRANSMISSION
PROJECT NUMBER 86619.500 DATE 11-23-94
SUBJECT: · Geigy Chemical Corporation Site
Sampling Notification
FROM: Jim Cloonan [phone] Fax: [phone]
TOTAL PAGES SENT INCLUDING TI-JI$ PAGE: _j__
ADDRESSEES
TIME 1400
USEPA
Luis Flores
[phone]
NCDEHNR
Randy McElveen
Comments
Hard copy to follow to EPA by FedEx.
[phone]
P.1
NOV 23 '94 02:04PM'T ENV-INFRASTRUC.
November 23, 1994
Mr. Luis Flores
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, GA 30365
RB: Notification of Additional Field Work
Geigy Chemical Corporation Site
Aberdeen, North Carolina
VTA FACSWTLE
Dear Mr. Flores:
P.2
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies) and in accordance with Section IX, Paragraph 23 of the
Consent Decree, attached is a schedule for sample collection activities. As discussed in our
meeting on November 17th, the Companies will sample monitoring wells PW-lS and
MW-18D for the hardness cations Ca, Fe, Mg, and Mn. This sampling will better define the
potential effects of groundwater constituents on the proposed treatment system. MW-18D
will also be sampled for toxaphene, as the laboratory (Quanterra) recently advised us that
the toxaphene data for this well i5 suspect. Sampling will be conducted in accordance with
the~ approved Sampling and Analysis Plan (RUST E&I, November 1993). Results of the
analyses will be presented in the Preliminary Design Report, if possible. This sampling
effort will be conducted while personnel are mobilized to complete the infiltration gallery
pilot test. Initiation of field activities is scheduled for November 30, 1994. A more detailed
schedule is attached as Table 1.
Also attached, as Table 2, are proposed dates for submitt,tl of interim groundwater modeling
results and follow-up conference calls. A copy of this correspondence has also been sent
to Randy McElveen in response to his request to be informed of the pending conference
calls. Please let me know at your earliest convenience if these dates are not acceptable.
Please feel free to contact me at [phone] if you have any questions or require
additional information.
NOV 23 ,'94 02:05PM'T ENV-INFRASTRUC.
Page Two
Mr. Luis Flores
November 23, 1994
Sincerely,
Garland Hilliard
Project Coordinator
/ Attachment
c: R. McElveen. (NCDEHNR)
P.3 •
NOV 23 '94 02: 05PM,ST ENV-INFRASTRUC. • P.4
Date
11/30
12/5
12/6
12/6 -12/8
12/9
TABLE 1
SCHEDULE FOR ADDITIONAL FIELD ACTIVITIES
GEIGY CllEMICAL CORPORATION SITE
Activity
~Conduct soil borings at location of proposed infiltration gallery
~ Construct infiltration test trench .
Sample wells P\V-1S and MW-18D
,;;.... pConduct infiltration pilot test .
Clean up, depart site
NOV 23 '94 02:05PWST ENV-INFRASTRUC. • P.5
Date
12/5
12/9
12/27
1/3
1/16
TABLE 2
SCHEDULE FOR 111E REVISED PRELIMINARY DESIGN REPORT
GEIGY CHEMICAL CORPORATION SIIB
Activity
Submit groundwater modeling calibration results to EPA/CDM
¥Conference call to discuss calibration results
Submit groundwater modeling simulation results for extraction
alternatives to EPA/CDM
\\· Conference call to discuss simulation results
Submit revised PDR to EPA (Federal holiday)
,·
MEMORANDUM
To:
From:
RE:
•
November 17, 1994
File
Randy McElveen
Environmental Engineer
NC Superfund Section
•
Atlanta Meeting with EPA and the PRP's
Geigy Chemical NPL Site
NCD 981 927 502
Aberdeen, Moore County, NC
On 17 November 1994, a representative of the NC Superfund
participated in a meeting with the EPA and the Potentially
Responsible Parties (PRPs) for the Geigy Chemical Corporation NPL
Site located in Aberdeen, Moore County, NC. The meeting at the EPA
Region IV office in Atlanta, Georgia was held in order to discuss
the additional groundwater flow modeling (3 dimensional) EPA has
requested for the shallow aquifer and pilot testing of the new
infiltration gallery location for the revised Preliminary Design
Report. The investigation of the Trichloroethene (TCE) plume
located up-gradient of the Geigy Chemical Site (Crestline
Contaminated wells site) was also discussed.
The PRP's contractor Rust E&I gave a presentation summary of their
proposed 3 dimensional (3D) Modflow Model and their proposed in-put
data and boundary conditions. The purpose for the presentation was
to seek in-put from EPA and the State at this time in order to
resolve any concerns before the modeling and revised design report
are completed and re-submitted.
The EPA's primary concern discussed during the meeting was the
3D contouring of the uppermost confining unit, being used as in-put
in the model. to establish the seepage rate of the perched
groundwater to the second uppermost aquifer. The EPA's oversight
contractor CDM Federal, Mark Taylor, recommended that the upper and
lower surfaces of the upper confining unit be contoured in order to
provide a better model of the confining unit and therefore the
potential seepage conditions between aquifers. The minimum that
Mr. Taylor would accept is an assurance that real data was being
used in estimating the confining unit thickness and associated
Memo to File
11-18-94
Page 2
•
seepage rate between aquifers.
•
The States primary concern was that the infiltration gallery
not create mounding of the groundwater to the extent that the up-
gradient TCE plume will be redirected into another regional flow
direction, especially to the north, threatening the contamination
of Town Wells #2 and #3. The 2D model output data seems to
indicate that all up-gradient groundwater diverted around the Geigy
Site by the proposed infiltration gallery will be effectively
returned to its normal flow path by the proposed down-gradient
extraction well.
The RUST E&I contractors also stated that piezometers will be
placed around the proposed infiltration gallery in order to verify
the modeling results. The state will request regular monitoring of
these proposed piezometers and all field measurements must be faxed
to the State as soon as possible. It will also be recommended that
the groundwater from the private wells down-gradient to the north
and west of the site be tested before the start of remedial action
and retested on a regular bases during the first year of the
remedial action. These private wells are located between the Geigy
Site and Town wells #2 and #3.
A list of those in attendance at the meeting are included as
an attachment to this memorandum. Conference calls have been
scheduled for 8 December 1994 and 6 January 1995 to refine and
assure that all issues are properly addressed. The State has
requested to participate in these calls.
cc: Jack Butler, NC Superfund Section
• •
GfilGYCHEMICALSUPERFUNDSITE
Remedial Design Meeting ·
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14:37 EPA REGION JU IJ'.1STE MGT PROGReMS • 001
'
.
~~
~wam bu JG1 lr9}' @!i
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGiON IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
FACSIMILE TRANSMITTAL COVER SHEET
'kfl'h,½ TO: ~c~•
·NCDB-l+t--.)~
COMPANY/ORGANIZATION;
Cf I q
PHONE NUMBER: FAX NUMBER: 733-4 e, II
NUMBER OF PAGES SENT (Including this cover sheet): 3
Pl9ase contact the person sending this tax ft tr ts recelvect poorly or tnaomplete,
FROM: LUIS E. FLORES
NORTH SUPERFUN.D REMEDIAL BRANCH
WASTE MANAGEMENT DIVISION
Phone Number: (404) 347•7791 Vmx-4118
Fax Number: [phone]
COMMENTS: ~ ·. ~£}~~to. ~ J<j)
(V,1-0,_ 0.f 6P~ N(IV"· I b '/qctv (I ;JT(Jn ,\ --k:, l,-)12.f>s
/\.I! ..CJ
J .J ,._")-I-a-" I ( _.11'\). P;, ...... ~ I\] I"\,(__.) -1-k ., ~" . " --' , .. I\ • ' ,( I ~" .. L,, _. ': .f\l rrJ)__CJ-/v ( f> 5 \.) P l l
K
' V l ~ \.,
11 '15/94 14: 38 • EPA REGION IU IJC1STE MGT PROGRAMS •
UNITED STATl'.':S ENVIRONM!cNTAL PROTECTION AGENCY
RE:GION JV
4WD-NSRB
Mr. Garland E, Hilliard
Project Coordinator
Olin Corporation
P.O. Box 248
343 COI.JliiTl-AND 61'RE:ET. N.i!.
ATLANTA, GEORGIA 30365
Noverobe~ 16, 1994
002
1186 Lower River Road NW
Charleston, Tennessee 37310
YIA FACSIMILE
ORIGIHI\L VJA MAIL
SUBJ1 Performance standard11 verification Plan (PSVP)
Geigy Chemical Corporation Site
Aberdeen, North C~rolino,
Dear Mr, Hilliard,
The purpose of this letter is to transmit a summary of the
State's concerns which they wou'ld like addreseed in t)1e PSVP
during the Intermediate Design .submittal. EPA agrees in part
with some of these concerns and is willing to discuss them with
the PRPs and the State before the draft PSVP is prepared.
The !allowing are the State'11 concerns,
1. If local hot spots are observed as indicated by stained
soil.a, st;i;ong odors or pes;ticJ.des debris such as ba9s,
confirmation smnpllng must be _perfocned.
The State informed EPA that they have performed a thorough
evaluation of all. site analytical data and Vadose Zone
Interactive Processes (VIP) modeJ.ing and concluded that tho
Site ctata provided in the .Remedial Investigation/
Feasibility Study indicates that the current level of
pesticides contamination at the Site.are border-line for
protection of groundwater.: The State states that due to the
borderline natu;i;e of average J.evels at the Site, if
undetected local hot spots exist at the Site they may
represent a significant t)ireat to the groundwater.
2, At anytime du;i;ing or after the remedial. action, Stato
repre11entativee may perform confirmation swnpJ.ing after
excavation and back-filling • If soil contamination is found
which exceeds the levels listed in Tables A.2 and A,4 of the
FeaaibiJ.ity Study, the State will recauira that additional
excavation and disposal treatment would be required to
whatever depth is necessary to achieve the soil contaminant
levels listed in Tables A, 2 and A. 4 ,for protection of
groundwater.
11/16/94 14:38 • EPA REGION ll.J WASTE MGT PROGRl'l'1S • 003
2
3, Procedures for assuring th~t good professional judgement
will be ueed by the remedi.al act.ion' contractor· to iJllplement
proper verification sampling under the conditions noted
above are basic to the effective clean up of the Geigy.Site
and should be identified in the PSVP during the Intermediate
Design 6Ubm1ttDl,
'l'hese concerns will be addreesed at a future meeting to be
scheduled later, since the purp9se of the November 17, 1994,
meeting is to clar.ify issues re+ated to finalize the Preliminary
Design Report, Please contact me at [phone] x-4118 if you
have any questions,
CCI Curt Fehn, EPA, 4WD-NSRB
Wineton Smith, EPA, GWTSU
Randy MCElveen, NCDEHNR
Manager
• .Y •
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
November IO, 1994
Mr. Luis Flores
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: :Descriptions of Additional Modeling and Pilot Testing
Geigy Chemical Corporation Site
Aberdeen, North Carolina
VIA FACSIMILE AND FEDERAL EXPRESS
Dear Mr. Flores:
RECEl\!E.D
NOV 1 41994
sUPERFUND SECTION
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), attached are seven copies of the referenced documents. The
documents are submitted for your review prior to our meeting on November 17th. Also attached
is the resume of the lead modeler, Mr. Vedat Batu, for the additional groundwater flow
modeling effort. At your request, copies of the referenced document and Mr. Batu's resume
have been sent directly to Mr. Tim Eggert, Mr. Mark Taylor, and Mr. Billy O'Donnell of
CDM, and Mr. Randy McElveen of the NCDEHNR.
We are looking forward to meeting with you and discussing these materials further. Please feel
free to contact me at [phone] if you have any questions or require additional information.
Sincerely,
Garland Hilliard
Project Coordinator
/ Attachments
RD
•
c: T. Eggert (CDM)
M. Taylor (CDM)
B. O'Donnell (CDM)
· R. McE!veen (NCDEHNR)
J. Serfass (Olin)
H. Moats (Ciba)
G. Crouse (Ciba)
J. Vinzant (Kaiser)
H. Grubbs (WCS&R)
J. Cloonan (RUST)
M. Sheehan (RUST)
S. Sargent (RUST)
RUST E&I Project File 7.4.5
•
• •
Vedat Batu
Senior Consultant
Education
University Associate Professor Degree (gained with an approved thesis and passing additional
examinations), 1979, Hydraulic Engineering, Interuniversities Institution, Ankara, Turkey
Ph.D., 1974, Hydraulic Engineering, Istanbul Technic·al University, Istanbul, Turkey
B.S. and M.S. (combined), I 969, Civil Engineering and Hydraulic Engineering, respectively,
Istanbul Technical University, Istanbul, Turkey
Professional Registration.
Registered Professional Engineer -Pennsylvania
Certified Ground Water Professional by the Association of Ground Water Scientists and Engineers
Experience
Dr. Batu has extensive experience in all aspects of hazardous waste management, with emphasis
on the groundwater and surface water flow systems. Areas of expertise include assessment of the
hydrogeologic, hydrologic, and geochemical systems, with particular emphasis on groundwater
hydrology, contaminant hydrogeology, and interaction between groundwater and surface water
systems. Dr. Batu has extensive experience in preparing environmental impact assessment for
existing and projected waste disposal facilities. He provides technical support to multidisciplinary
projects including hazardous waste investigations and feasibilty studies, permitting studies, and
mining projects. Dr. Batu has a strong background in numerical and analytical models for flow and
contaminant transport in groundwater (in porous and fractured media) and surface water systems.
He has participated at numerous RCRNCERCLA site projects including data analysis, in-house
model development, and development of modeling studies ranging from simplified analytical
models up to complex three-dimensional numerical groundwater flow and contaminant transport
models. He is familiar with the use of publicly available numerous computer codes for ground and
surface water systems. Interdisciplinary team experience includes working with geologists,
hydrogeologists, chemists, toxicologists, wetlands specialists, meteorologists, regulatory
specialists, and engineers on water resource planning, design and construction, operation and
maintenance projects. Dr. Batu has also teaching, research, and consulting experience in
hydraulics and fluid mechanics, open channel hydraulics, water hammer, experimental hydraulic
modeling techniques, and mathematical model and computer code development for flow and
contaminant transport in ground and surface water flow systems. Dr. Batu is widely published in
different journals and symposia proceedings throughout the world and his publications are
referenced by many authors in different journals and books.
Senior consultant, RUST Environment & Infrastructure, Naperville, Illinois.
Responsible for technical support and project management in the areas of hydrogeology,.
hydrology, groundwater flow and solute transport modeling, surface water hydraulics,
groundwater impact assessment, remedial investigations and feasibility studies, permit
applications, landfill design, and civil engineering projects. Specific project experience includes:
Kankakee Recycling and Disposal Facility, Waste Management of Illinois, Inc.,
Chebanse, Illinois. Groundwater impact assessment development to meet the requirements of
Illinois Environmental Protection Agency regulations. Involved comprehensive three-dimensional
groundwater flow and contaminant transport modeling and monitoring wells system design.
• •
CID Environmental Complex, Waste Management of Illinois, Inc. and Chemical
Waste Management Inc., Calumet City, Illinois. A justification and evaluation of the
monitoring well spacing was performed based on the regulations of Illinois Environmental
Protection Agency.
Tazewell Recycling and Disposal Facility, Waste Management of Illinois, Inc.,
East Peoria, Illinois. Groundwater impact assessment development to fulfill the requirements
and standards of Illinois Environmental Protection Agency. Involved extensive data analysis,
conceptualization, and complex multilayer three-dimensional groundwater flow and contaminant
transport modeling and monitoring wells system design.
South Side Facility, Waste Management of Illinois, Inc., Cook County, Il_linois.
Involved groundwater impact assessment for a projected recycling and disposal facility to meet the
requirements of Illinois Environmental Protection Agency. Involved extensive data analysis and
three-dimensional groundwater flow and contaminant transport modeling and monitoring wells
system design.
Laraway Recycling and Disposal Facility, Waste Management of Illinois, Will
County, Illinois. Groundwater impact assessment development to fulfill the requirements and
standards of Illinois Environmental Protection Agency. Involved comprehensive three-dimensional
groundwater flow and contaminant transport modeling through a system formed by a composite
liner and an aquifer.
Chain of Rocks Sanitary Landfill, Waste Management of Illinois, Inc., Madison
County, Illinois. Groundwater impact assessment development to fulfill the requirements and
standards of Illinois Environmental Protection Agency. Involved comprehensive three-dimensional
groundwater and contaminant transport modeling through a system formed by a composite liner
and an aquifer bounded by the Mississippi River and Chain of Rocks Canal.
Senior project manager, Golder Associates Inc. Responsible for project management and
technical support involving groundwater flow and solute transport modeling, hydrogeology,
hydrology, field tests (pumping, slug, and packer tests), and surface water hydraulics for remedial
investigations/feasibility studies and civil engineering projects. Specific project experience
includes:
Remedial investigation/feasibility studies of the Industri-Plex Site, Woburn,
Massachusetts. Involved site characterization, hydrogeologic data analysis (pumping and slug
tests) extraction and injection wells design with groundwater modeling.
Bell Aerospace Textron DNAPLs contamination site, Wheatfield, New York.
Involved site characterization and extraction/injection wells design for a multiple aquifers system
with groundwater flow and solute transport modeling using the telescopic mesh refinement (TMR)
approach.
Sandy Hill Landfill Expansion, Bowie, Maryland. Involved site characterization,
hydrogeologic data analysis (pumping and slug tests), and evaluation of various engineering
design aspects with different levels of groundwater modeling.
Development of the one-and two-dimensional solute transport modeling package called "A 1M -
Analytical Solute Transport Models, Theory and User's Manuals". The programs are being used in
various Golder offices.
• • Senior hydroloi:ist, senior staff consultant and senior technical associate,
International Technoloi:y {IT} Corporation, Pittsburgh, Pennsylvania. Provided
high-level technical supervision in various hazardous waste projects, especially in areas of water
resources management, including hydraulics, fluid mechanics, groundwater hydrology,
contaminant transport analysis (organic/inorganic), mathematical model development for
groundwater flow and solute and radionuclide transport analysis, and computer modeling of
processes associated with these disciplines. Involved in numerous environmental science and
engineering projects including hydrogeologic data analysis, in-house model development,
development of modeling studies ranging from simplified analytical models up to complex three-
dimensional numerical groundwater flow and solute transport models in aquifers, feasibility
studies, proposal and statement of qualifications (SQQ) report writing, as well senior level
consultation to all IT offices. Representative consulting projects include:
Recovery, monitoring, and hydraulic control of the Aetna-Dover Fuel Spill, Aetna
Casualty and Surety Company, Passippany, New Jersey .
. Waste Isolation Pilot Plant (WIPP), U.S. Department of Energy, Carlsbad, New
Mexico. Involved data analysis and stochastic solute transport modeling.
Hardeman County Landfill, Velsicol Chemical Corporation, Memphis, Tennessee.
Involved assessment of contaminant migration in unsaturated and saturated media.
Hydrologic Assessment of Union Carbide Taft Plant, Hahnville, Louisiana.
Involved assessment of contaminant migration using the VHS model.
J.T. Baker Facility, Philipsburg, New Jersey. Groundwater flow and contaminant
transport modeling investigations to design an extraction wells system.
Ironton Iron Production Wells and Gold Damp Disposal Area, Allied
Chemical/Ironton Coke Site, Ironton, Ohio. Numerous geohydrologic and hydraulic
analyses and computer modeling applications.
Closure and Postclosure Plans. IT Corporation Vine Hill and Baker
Impoundments, Contra Costa County, California. Involved numerous hydrogeologic and
hydraulic analyses including extensive three-dimensional design-oriented groundwater modeling,
contaminant migration assessment for the design of postclosure facilities. Incorporated
development and use of computer models.
Remedial Investigation. and Feasibility Study for the former Firestone Facility,
Salinas, California, Firestone Tire & Rubber Company, Akron, Ohio. Involved site
characterization and extraction wells design using extensive ground water flow and solute transport
modeling.
Site Characterization of the Engelhard Specialty Chemicals, Delancy Street
Facility, Newark, New Jersey.
Odessa Chromium II Site, Texas Water Commission, Odessa, .Texas. Extraction
wells design under some specified .constraints with groundwater flow and solute transport
modeling. · ·
Development and use of Computer Models in Fractured Media for the IT
Corporation Panoche Facility, Solano County, California.
• • · Great Lakes Chemical Corporation, EI Dorado, Arkansas. Involved hydrogeologic
data analysis and extraction wells design for a complex aquifers system with extensive
groundwater flow modeling.
Hydrogeologic Study of Feed Materials Production Center (FMPC), a
Nuclear/Mixed Waste Site, Discharge to the Great Miami Riv.er, Cincinnati, Ohio ..
Involved in extensive two-and three-dimensional groundwater flow and radionuclide transport
modeling study with SWIFT III (Sandia National Laboratory's three-dimensional groundwater
flow, brine, and radionuclide transport code). Incorporated development and use of solute
transport models for surface and subsurface flow systems. Involved and extensive code
verification study for SWIFT ill against other numerical codes (MODFLOW, Princeton Transport
Code, and GEOFLOW, IT's proprietary code) and analytical groundwater flow and solute
transport codes.
In House Code Developments: Revision 4.1 of the GEOFLOW (IT's finite element groundwater
flow and solute transport computer program, user manual, third printing, 1986). Performed
extensive verification of the GEOFLOW code, with the use of analytical solutions available in
literature and developed by Dr. Batu. Development and use of one-and two-dimensional solute
transport programs based on Dr. Batu's original works published in journals. These programs are
being used in various IT offices.
Senior groundwater hydrologist. NUS Corporation. Pittsburgh. Pennsylvania.
Responsible for groundwater modeling studies. Also provided high-level technical support to
multidisciplinary mostly Superfund projects involving groundwater components, including
hazardous waste investigations, permitting studies, and mining projects. Specific project
experience includes:
Data analysis and contaminant migration assessment for the Vega Alta Well Field,
Vega Alta, Puerto Rico, U.S. Environmental Protection Agency.
Remedial Investigation and Feasibility Study for the New Bedford Landfill, New
Bedford, Massachusetts, U.S. Environmental Protection Agency.
Remedial Investigation and Feasibility Study for the Port Washington Landfill,
Town of North Hempstead, New York, U.S. Environmental Protection Agency.
Groveland Wells Site, Groveland, Massachusetts, U.S. Environmental Protection
Agency.
Remedial investigation and. feasibility study for the Tybouts Corner Landfill, New
Castle County, Delaware, U.S. Environmental Protection Agency.
Remedial investigation and feasibility study for the Gloucester Environmental Management
Services, Inc. (GEMS) Landfill, Gloucester Township, New Jersey.
Swope Oil Site, Pennsauken, New Jersey, U.S. Environmental Protection
Agency.
Nyanza Chemical Site, Middlesex County, Massachusetts, U.S. Environmental
Protection Agency.
Drake Chemical Site, Clinton· County, Pennsylvania, U.S. Environmental
Protection Agency.
• • D'lmperio Landfill Site, Atlantic County, New Jersey, U.S. Environmental
Protection Agency.
Visiting Associate Professor, Soil Science Department. University of Florida.
Gainesville, Florida. Research on mathematical modeling to simulate the transport of multiple
solute species in soils.
Visiting Research Scholar, Department of Civil Engineering. Auburn University.
Auburn. Alabama. .Research on finite element simulation of hydrodynamic dispersion
(contaminant migration) in non homogeneous and anisotropic aquifers and teaching graduate and
undergraduate courses in the subjects of surface and ground water hydraulics, ground water flow
and contaminant migration modeling.
Visiting Research Associate Professor, School of Engineering, University of Mississippi, Oxford,
Mississippi. Research on finite element computational surface and ground water hydraulics and
teaching.
Associate Professor, Department of Civil Engineering. Karadeniz Technical
University. Trabzon, Turkey. Teaching and research in hydraulic engineering area, Chairman
of the Civil Engineering Department, and Director of Hydraulics Laboratory.
Visiting Scientist. Deoartment of Civil Engineering. University College of
Swansea. Swansea, Wales, United Kingdom. Research on finite element computational
hydraulics.
Assistant Professor, Department of Civil Engineering. Karadeniz Technical
University. Trabzon, Turkey. Teaching and research in hydraulic engineering area.
Visiting Assistant Professor. University of Wisconsin, Madison. Wisconsin.
Research on ground water hydraulics.
Assistant Professor. Department of Civil Engineering. Karadeniz Technical
University. Trabzon. Turkey. Teaching and research in hydraulic engineering area.
Ph.D. student, Faculty of Civil Engineering, Istanbul Technical University, Istanbul, Turkey.
Instructor, Department of Civil Engineering, Karadeniz Technical University, Trabzon, Turkey.
Teaching in hydraulic engineering area.
Presentation, Publications, Awards
Author of oyer thirty authored and co-authored publications on the subject of ground and surface
water. Has published a number of papers in internationally recognized journals such as Ground
Water; Journal of Hydraulic Engineering and Journal of Irrigation and Drainage Engineering of
American Society of Civil Engineers; Journal of Hydrology: Soil Science Society of America
Journal; and Water Resources Research and symposia proceedings. Has developed numerous
mathematical models and introduced new concepts on the subject of ground water flow and
contaminant transport. Publications are referenced by many authors in different journals and
symposia proceedings.
Publications
Batu, V., "A Mathematical Modeling Method for Prediction of Surface Water Contamination As a
Result of Ground Water Contamination," Submitted to Journal of Hydrology. 1993. ·
• • Batu, V., "A Generalized Two-Dimensional Analytical Solute Transport Model in Bounded Media
for Flux-Type Finite Multiple Sources," Water Resources Research (in press), 1993.
Batu, V., and R.C.F. King, "The Application of Mathematical Modeling Tools for Remedial
Investigations and Feasibility Studies," Proceedings of the Mediterranean Conference on
Environmental Geotechnology. Cesme, Turkey, May 25-27, 1992.
Batu, V., "Recent Developments in Two-Dimensional Analytical Solute Transport Models,"
Invited Paper, Proceedings of the Solving Ground Water Problems With Models Conference,
International Ground Water Modeling Center and Association of Ground Water Scientists and
Engineers, pp. 3-17, Dallas, Texas, February 11-13, 1992.
Srivastava, V.K., V. Batu, S. Niaki, and E. Zoratto, "Long-Term Groundwater Cleanup
Strategy," Proceedings of HAZMACON 90, Hazardous Materials Management Conference and
Exhibition, Anaheim, California, pp. 189-200, April 17-19, 1990.
Batu, V., and M.T. van Genuchten, "First-and Third-Type Boundary Conditions in Two-
Dimensional Solute Transport Modeling," Water Resources Research, Vol. 26, No. 2,, pp. 339-
350, February, 1990.
Batu, V., "A Generalized Two-Dimensional Analytical Solution for Hydrodynamic Dispersion in
Bounded Media With the First-Type Boundary Condition at the. Source," Water Resources
Research, Vol. 25, No. 6, pp. 1125-1132, 1989.
Batu, V., "Contaminant Plume Analysis Using the Hydrodynamic Dispersion Stream Function
(HDSF)Concept," Ground Water, Vol. 26, No. I, pp. 71-77, 1988.
Batu, V., "Introduction of the Stream Function Concept to the Analysis of Hydrodynamic
Dispersion in Porous Media," Water Resources Research, Vol. 23, No. 7, pp. 1175-1184, July,
1987.
Broscious, J.A., V. Batu, and M.C. Plautz, "Recovery of Petroleum Product from a Highly
Permeable Aquifer Under the Effects of Municipal Water Supply Wells," Proceedings of the Sixth
National Symposium and Exposition on Aquifer Restoration and Ground Water Monitoring. The
Ohio State University, Columbus, Ohio, pp. 493-509, May 19-22, 1986.
Batu, V., and S. Haji-Djafari, "The Use of Mathematical Modeling for the Environmental Impact
Assessment of Hazardous Waste Sites," Proceedings of the Third International Symposium on
Environmental Management for Developing Countries, August 6-12, Istanbul, Turkey.
Batu, V., "Comments On 'Non uniform Leaching From Non uniform Steady Infiltration' by J.R.
Philip," Soil Science Society of America Journal, Vol. 49, pp. 1594-1595, 1985.
Batu, V., J. Ho, and J.G. Yeasted, "Solute Transport in Soils Based on the Theory of Linearized
Unsaturated Flow Net Analysis," 20th Annual Meeting, Northeastern Section of the Geological
Society of America, Lancaster, Pennsylvania, March 13-16, 1985.
Batu, V., J. Ho, and J.G. Yeasted, "Analysis of Unsaturated Flow Beneath a Landfill," Computer
Applications in Water Resources, edited by H.C. Torno, American Society of Civil Engineers,
Buffalo, New York, pp. 162-172, 1985.
Batu, V., "A Finite Element Dual Mesh Method to Calculate Nodal Darcy Velocities in
Nonhomogeneous and Anisotropic Aquifers," Water Resources Research, Vol. 20, No. I I, pp.
1705-1717, 1984.
• • Batu, V. R.S. Mansell, and S.A. Bloom, "Finite Element Simulation of Lineanzed Water and
Solute Transport in Unsaturated Soil," Soil Physics Division, 76th Annual Meeting of the
American Society of Agronomy, November 25~30, Las Vegas, Nevada, 1984.
Batu, V ., "Flow Net for Two-Dimensional Linearized Infiltration and Evaporation from
Nonuniform and Nonperiodic Strip Sources," Journal of Hydrology. Vol. 64, No. 1/4, pp. 225-
238, 1983.
Batu, V., "Time-Dependent, Linearized Two-Dimensional Infiltration and Evaporation from
Nonuniform and Periodic Strip Sources," Water Resources Research, Vol. 19, No. 6, pp. 1523-
1529, 1983. .
Batu, V.,. "Time-Dependent Linearized Two-Dimensional Infiltration and Evaporation from
Nonuniform and Equally Spaced Strip Sources," Proceedings of the National Conference on
Advances in Infiltration, .
American Society of Agricultural Engineers, Chicago, Illinois, pp. 55-68, 1983.
Batu, V., "Two-Dimensional Dispersion from Strip Sources," Journal of Hydraulic Engineering,
American Society of Civil Engineers, Vol. 109, No. 6, pp. 827-841.
Batu, V., "Time-Dependent, Linearized Two-Dimensional Infiltration and Evaporation from
Nonuniform and Nonperiodic Strip Sources," Water Resources Research, Vol. 18, No. 6, pp.
I 825-1833, I 982.
Batu, V., "Unsteady, Two-Dimensional Linearized Infiltration and Evaporation from Nonuniform
and Nonperiodic Strip Sources," Hydraulic Problems of Ground Water Drainage, International
Association for Hydraulic Research, Belgrade, Yugoslavia.
Batu, V ., "Linearized Modeling Techniques for Unsaturated Porous Media and Applications to
Nonuniform and Nonperiodic Strip Sources," NATO Advanced Study Institute on Mechanics of
Fluids in Porous Media -New Approaches in Research, University of Delaware, Newark,
Delaware, July 18-27, 1982.
Batu, V., "Flow Net for Unsaturated Infiltration from Periodic Strip Sources," Water Resources
Research, Vol. 16, No. 2, pp. 284-288, 1980.
Batu, V., "Flow Net for Unsaturated Infiltration from Strip Sources," Journal of the Irrigation and
Drainage Division, American Society of Civil Engineers, Vol. 105, IR3, pp. 233-245, 1979.
Batu, V., "Doymarnis Zeminlerdeki Akim Aglarinin, Kaynaklarin Tek Serit ve Periodik Serit
. Olmasi Hallerinde lncelenmesi (Flow Net for Unsaturated Infiltration from Single and Periodic
Strip Sources)," Associate Professorship Thesis, Interunivrsities Institution, 98 pp., Ankara,
Turkey, 1979.
Batu, V ., "Steady Infiltration from Single and Periodic Strip Sources," Soil Science Society of
America Journal, Vol. 42, pp. 554-559, 1978.
Batu, V., W.R. Gardner; "Steady-State Solute Convection in Two Dimensions with Non-Uniform
Infiltration," Soil Science Society of America Journal, Vol. 42, pp. 18-22, 1978.
Batu, V., "Steady Infiltration from a Ditch: Theory and Experiment," Soil Science Society of
America Journal, Vol. 4C pp. 677-682, 1977 (Adapted from the Ph.D. dissertation presented to
Istanbul Technical University in March 1974 and supported as research project No. MAG-299 by
the Scientific and Technical Council of Turkey).
• •
Batu, V ., "Doymamis Ortamdald Bir Kanaldan Enfiltrasyon (Infiltration from a Ditch in
Unsaturated Porous Media))," Ph.D. Dissertation, Faculty of Civil Engineering, Istanbul Technical
University, Istanbul Turkey, 212 pp. (in Turkish with an English summary).
Batu, V., and K. Cecen, "On the Method of the Determination of Unsaturated Flow Characteristics
by Means of Electrical Resistivity," Proc. 15th Cong., International Association of Hydraulic
Research, No. 3, pp. 135-144, Istanbul, Turkey.
Batu, V. and K. Cecen, "Acik Bir Kanaldan Enfiltrasyon (Infiltration from an Open Channel," 4th
Congress ofTUBITAK, Ankara, Turkey (in Turkish).
Professional Memberships
American Geophysical Union
American Society of Civil Engineers
National Water Well Association
Employment History
I 992 -Present
1990-1992
1985 -1990
1984-1985
1984
1983 -1984
1982 -1983
1979 -1982
1979
1977 -1979
1976-1977
1974 -1976
1970-1974
1969 -1970
balU. ved/052193
RUST Environment & Infrastructure, Inc.
Golder Associates, Inc.
International Technology Corporation
NUS Corporation
University of Florida
Auburn University
University of Mississippi
Karadeniz Technical University
University College of Swansea
Karadeniz Technical University
University of Wisconsin-Madison
Karadeniz Technical University
Istanbul Technical University
Karadeniz Technical University
• •
GROUNDWATER FLOW MODEL DESCRIPTION
FOR THE
REVISED PRELIMINARY DESIGN
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
NOVEMBER 10, 1994.
RUST PROJECT NO. 86619.500
• •
1.0 PURPOSE
The purpose of this submittal is to describe the proposed groundwater flow model for the
uppermost aquifer at the Geigy Chemical Corporation Site (Site). This submittal is in
partial response to EPA's October 13th correspondence. The objective of the modeling
study is to characterize flow and to. evaluate different extraction alternatives for the
uppermost aquifer, including vertical extraction wells and horizontal extraction wells.
The evaluation will involve an effort to optimize the configuration of the final extraction
system. Additionally, infiltration gallery simulations in the uppermost aquifer will be
included in the modeling effort.
In order to achieve these goals, a groundwater flow model will be developed. Based on
the conceptual model of the hydrogeologic system (Section 2.0), and the remedial action
alternatives to be evaluated, the three-dimensional USGS model MOD FLOW (McDonald
and Harbaugh, 1988) will be used for the groundwater flow simulations. The model will
be constructed in two and three dimensions to evaluate vertical and horizontal extraction
wells, respectively. The model will be constructed, calibrated, and subsequently utilized
to evaluate extraction well capture zones for the uppermost aquifer.
2.0 CONCEPTUAL MODEL AND CODE SELECTION
Site topography and well and boring locations are shown on Figure 1 (attached). The
stratigraphy and hydrogeology beneath the Site are depicted on cross-section diagram
B-B' (see Figure 2, attached). Based on Site-specific qualitative and quantitative
information including saturated thickness, pumping test, lithologic, and water level data,
the Site conceptual model presented in Figure 3 (attached) was prepared. This
conceptual model was developed based on the stated purpose of the modeling effort
(Section 1.0), and to illustrate the hydrogeologic units present beneath the Site (i.e.,
uppermost, second uppermost, and third uppermost aquifers and associated confining
units), the interconnection of these units, and general hydrogeologic aspects of the system
(e.g., saturated thickness, lateral continuity, hydraulic conductivity, etc.). In accordance
with agency comments, the modeling study will be conducted for the uppermost aquifer,
which is ·underlain by the uppermost confining unit. This part of the hydrogeologic
system acts as a separate unit from the underlying second uppermost aquifer. With the
exception of limited recharge from the uppermost to the second uppermost aquifer where
the uppermost confining unit is not sufficiently thick to prevent leakage, the uppermost
aquifer has no hydraulic communication with the underlying second uppermost aquifer.
The saturated thickness of the uppermost aquifer thins south of the former facility", and
the aquifer is no longer present in the vicinity of well MW-11D. As shown in Figure
3, the leakage rate of water from the uppermost aquifer increases as the thickness of the
uppermost confining unit decreases. Although the uppermost aquifer is losing water
through the confining layer, the predominant groundwater flow direction in the aquifer
Groundwater Flow Modeling 2 November 10, 1994
• •
is horizontal. Lithologic characterization of the uppermost aquifer (based on the
installation of over 30 borings) indicates that the grain size distribution is consistent
throughout the aquifer. Thus, for the modeling effort it will be assumed that the aquifer
consists of one lithologic formation (e.g., silty and clayey sands). Because the uppermost
aquifer is relatively thin (saturated thickness of Oto 20 feet), composed of one formation
(silty and clayey sands), and has no vertical gradients, groundwater flow will initially be
simulated using one layer. Additional layers will be added to the model during the
evaluation of extraction alternatives (see Section 4.0).
Based on the conceptual model of the hydrogeologic system, and the extraction
alternatives to be evaluated, the three-dimensional USGS model MODFLOW (McDonald
and Harbaugh, 1988) will be used for the groundwater flow simulations. MODFLOW
is a well-accepted and well-verified finite-difference code and has been widely used in
the groundwater industry for more than a decade. MODFLOW can simulate both
two-and three-dimensional groundwater flow. Boundaiy conditions for the model will
include prescribed head in areas of groundwater recharge, and no flow in areas where
equipotential contours are perpendicular to the model boundary, and in areas where the
uppermost aquifer pinches out.
3.0 CALIBRATION
Model calibration will be conducted following construction of the model. Initial input
parameters for horizontal hydraulic conductivity and precipitation recharge will be 3
feet/day and 15 inches/year, respectively. Model calibration will be achieved by
adjusting the horizontal hydraulic conductivity, precipitation recharge rate, and leakage
rate through the uppermost confining unit. The observed and modeled hydraulic heads
at monitoring well locations within the uppermost aquifer will be tabulated and
compared, and the observed and modeled groundwater head contours will be presented
on the same figure. The observed and modeled response to pumping well PW-IS at a
constant rate will also be evaluated by comparing groundwater head contours on the same
figure, and by tabulating and comparing observed and modeled hydraulic heads at
observation well locations within the uppermost aquifer. The observed and modeled
capture zones for well PW-IS will be compared using the USGS model MODPATII
(Pollock, 1989), which directly imports results of MODFLOW and conducts particle
tracking based on simulated hydraulic head values.
4.0 EVALUATION OF EXTRACTION SYSTEM DESIGN ALTERNATIVES
Using the calibrated model, different extraction configurations for the uppermost aquifer
will be evaluated. The first alternative to be evaluated will be fully-penetrating vertical
extraction wells and infiltration galleries. The simulations for this case will be conducted
using the two-dimensional calibrated model. The next alternative to be evaluated will
Groundwater Flow Modeling 3 November 10, 1994
• •
be horizontal extraction wells and infiltration galleries. Because of the flow
configurations, this alternative will be evaluated using a three-dimensional model which
will be created by adding additional layers to the existing two-dimensional calibrated
model. The additional layers will-be added to simulate the vertical gradients produced
by the horizontal well. Extraction well capture zones and infiltration gallery release
zones will be created using MODPATII. Sensitivity analyses will be conducted by
varying measured hydrogeologic parameters (i.e., hydraulic conductivity, precipitation
recharge rate, and leakage rate) .to evaluate the impacts on the capture zones.
5.0 REPORTING OF RESULTS
The revised report will include:
• model domain and boundary conditions, including the location, rationale, and
testing of boundary conditions;
• model stratigraphy cross-sections and elevation contour maps of the bottom of the
uppermost aquifer;
• tabulation and statistical comparison of observed heads and simulated hydraulic
heads for the calibrated model at monitoring well locations in the uppermost
aquifer;
• observed groundwater contours and simulated groundwater contours for the
calibrated model on the same figure;
• tabulation and statistical comparison of observed heads and simulated hydraulic
heads for the calibrated model under pumping conditions utilizing well PW-1 S;
• observed groundwater contours and simulated groundwater contours for the
calibrated model under pumping conditions utilizing well PW-1 S on the same
figure;
• observed and modeled capture zone for well PW-lS on the same figure;
• a description and justification for model input parameters (i.e., hydraulic
conductivity, precipitation recharge, and leakage rate) presented in tables and
figures; and
• results of ·extraction alternative simulations (including simulated groundwater
contours and capture and release zones) presented in figures in relation to the
groundwater plume.
Results of the model will be presented in the revised PDR.
Groundwater Flow Modeling 4 November 10, 1994
• •
REFERENCES
McDonald, M.G., and A.W. Harbaugh, 1988. A Modular Three-Dimensional
Finite-Difference Ground-Water Flow Model, Techniques of Water-Resources
Investigations of the United States Geological Survey, Book 6, Chapter Al.
Pollock, D.W., 1989. Documentation of Computer Programs to Compute and Display
Pathlines Using the Results from the U.S. · Geological Survey Modular
Three-Dimensional Finite-Difference Ground-water Flow Model, USGS Open
File Report 89-381.
Groundwater Flow Modeling 5 November 10, 1994
05/27/94
0
LEGEND
♦GS-02-2
~W-15D
♦PZ-1
.q>OW-1D
♦PW-10
U.S. GEOLOGICAL SURVEY WELL
MONITORING WELL
PIEZOMETER
OBSERVATION WELL
AQUIFER TEST WELL
WOODS
ED ALLRED APPROXIMATE LOCATION OF ALLRED WEU
A P-6 DIRECT PUSH TECHNOLOGY BORING
.q>WP-1S WELL POINT PIEZOMETER
~ RAILROAD
0 100 200 400 600 ------
SCALE IN FEET
4
P-7
NOTES:
1. TOPO MAPPING BY WOOLPERT CONSULTANTS BASED ON
AERIAL PHOTOGRAPHY FLOWN MARCH 26. 1989 WITH
GROUND CONTROL TIED TO THE STATE PLANE COORDINATE SYSTEM.
2. PLANIMETRIC FEATURES WERE FIELD IDENTIFIED
ON MAY 18, 1989 BY WOOLPERT CONSULTANTS.
5, THIS DRAWING HAS BEEN MODIFIED BY MURPHY YELU ASSOCIATES.
REGISTERED LANO SURVEYORS. AS FURNISHED, THE FILE WAS NOT
ORIENTED OR REGISTERED TO STATE PLANE, BY USE or COORDINATES
FlJRNISHED TO us BY RUST, WE nno LOCATED VISIBL.£ ITEMS AND
ROTATED/TRAHSLATED THIS nu TO 8£ CLOSELY ALIGNED .WITH SYATE
PLANE.
P-2 ~ MW-170
1111 IMfllll lENVIRONMENT & l~U>I l!NlFRASfRUCTURE
4
P-3
FIGURE 1
SITE TOPOGRAPHIC MAP
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
N:\86619\6619JP12.DWG
I ,,
05/23/94
B
SOUTHWEST
P-13/WP-1D
480
470
,,..... 460
...J
~ 450
t;: 440 ......,
z 430
0
1-420 <( > ~ 410
l.&J
400
390
380 ·
370
360
350
0 80 160
SCALE IN FEET
P-9/WP-1S
(PROJECTED) P-1 o
240
(PROJECTED)
LEGEND
429•4, 2 STATIC WATER L£VEL
SCREENED INTERVAL · · ·
· 419.4 WITH EL£VATIONS
TD=55.5' WELL/DIRECT PUSH EXPLORATION
TOTAi. DEPTH
CJ UNSATURATED ZONE
UNSATURATED ZONE
CLAY UNIT
SILT UNIT
FACtl.JTY PROPERTY
MW-2S
B'
NORTHEAST
• 211
NOTES:
I. VERTICAL EXAGGERA TiON = lX.
2. WATER L£VEL DATA llASED ON PIEZOCONE DATA
AND MONITORING WELi. DATA FROM 1/24/94.
3; LITHOLOGY FOR PROJECTED WELLS CORRECTED FOR
DISTANCE ONTO CRO$S-SECTION B -B'.
MW-9S·
FIGURE 2
480
470
----...J
V)
~
440 t:: ......,
430 z
0
420 1-< >
410 ~
400
390
380
370
360
350
l.&J
I'll _..ENVIRONMENT & ■--U>I INFRASTRUCTURE
HYDROGEOLOGIC CROSS-SECTION B-8'
GEIGY CHEMICAi. CORPORATION SITE
ABERDEEN, NORTH CAROUNA
N:\86619\ 6619JP03.DWG
2 w I-en >-
Ground Surface
---•---------~~ __ Up~rmost ___ _
<:J Aquifer
g
0 w
<:J
0 a: C >-::i:
a: w a. a. =>
2 w I-en >-en
0
<:J 0 ..J
0 w <:J 0 a:
C >-::i:
a: w
:i!:: 0 ..J
Uppermost
Confining
Unit
Second
Uppermost
Aquifer
Second
Uppermost
Confining
Unit
Third
Uppermost
Aquifer
PRECIPITATION RECHARGE
-40 FT
t
10-13 FT t
-60 FT
frWlllft!ENVIRONMENT&
11«.U>I INFRASTRUCTURE
FIGURE3
SITE CONCEPTUAL MODEL
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
PROJECT NO. 88619,500
• •
ADDITIONAL INFILTRATION PILOT TESTING
FOR TIIE
REVISED PRELIMINARY DESIGN REPORT
GEIGY CHEMICAL CORPORATION SITE .
ABERDEEN, NORTH CAROLINA
NOVEMBER 10, 1994
RUST E&I PROJECT NO. 86619.500
• •
1.0 INTRODUCTION
In response to comments from EPA/CDM dated October 13th, the Companies have prepared this
document which describes the methods and materials for an infiltration pilot test at the Geigy
Chemical Corporation Site. The infiltration pilot test will be conducted under the following
conditions:
• located at the actual location of the proposed infiltration gallery
• run for not less than 24 hours
• the side walls will be scarified.
2.0 PROPOSED PILOT TEST
The location of the proposed infiltration gallery is presented in Figure !(attached). The pilot
test will be conducted within the area of the proposed infiltration gallery. The previous pilot
test established an allowable infiltration rate of 12 gpd/ft2. The additional test will attempt to
operate at this rate or higher.
Prior to construction of the gallery, soil borings would be conducted within the infiltration area
to a depth of 20 feet to assess the presence of any shallow clay lenses. Soil boring logs
(attached) from P-7 and P-8 (Figure I) in the vicinity of the proposed infiltration gallery provide
lithology for the area. These borings indicate there are no confining units in this area above the
water table.
A water truck would collect water from the fire hydrant across the street for the infiltration pilot
test. This hydrant was used previously for decon water during the pre-design field investigation.
The pilot-scale trench cross-section (Figure 2) will be designed similarly to the anticipated
full-scale trench to simulate as closely as possible the true characteristics of the soil. This would
also allow for the incorporation of the pilot-scale trench into the full-scale system should the
design prove favorable. The anticipated loading rate (1-2 gpm) would be equal to or higher
than both the median and average infiltration values from the compact constant head
permeameter (CCHP) testing conducted during the pre-design efforts.
Monitoring wells and piezometers downgradient of the pilot test (MW-11D, OW-ID, OW-2D,
PW-1D, and WP-lS) will be monitored prior to, during, and following the pilot test to note any
influence on the uppermost and/ or second uppermost water table.
3.0 LOCATION AND CONSTRUCTION OF THE TRENCH
The selection of the infiltration gallery location was described in detail in the draft PDR. The
pilot test will be located along the easternmost lateral of· the proposed infiltration gallery as
shown in Figure 1. The exact location of the pilot gallery along the lateral will be determined
Infiltration Pilot Testing 2 November 10, 1994
• •
in the field. ,
The side walls of the pilot trench will be scarified using the toothed bucket of a backhoe. This
method will simulate construction of the full-scale trench and actual operating performance.
Care will be taken during scarification so that the side walls do not collapse.
The pilot test infiltration gallery would be constructed by excavating a trench two feet wide,
approximately six feet deep, and approximately 20 feet long. The nominal depth of the gallery
will be six feet.
A geotextile would be placed against all sides of the trench to maintain separation between the
trench walls (sand) and the stone to be placed later. The t,rench would then be backfilled with
stone to within one foot of the surface. A perforated pipe would be placed on top of the stone
for the full length of the trench. A six-inch layer of similar stone would be placed on top of the
pipe followed by a'layer of geotextile (to maintain separation between the stone and native soil).
Native soil would be used to provide the remaining six-inch layer. In addition, sections of I-
inch PVC piping will be placed vertically between the trench bottom and the surface at points
along the trench to allow monitoring of any standing water that develops within the trench during
the test.
\
4.0 SCHEDULE AND REPORT
Rust E&I could be ready to conduct the pilot borings and the pilot test as early as the week of
December 5th, contingent on subcontractor availability and approval by EPA/CDM. Results of
the pilot test will be presented in the revised PDR.
Infiltration Pilot Testing 3 November 10, 1994
DE
P-8
'D VID UPCHURC
BOOK 668, PA~ 231
,/607
' "a ' I:).
7 ' -'
\ \
' \
' '
\
' ' ' ' '------
\
\
WOOOS
: I
\
\
\
APPROXIMATE LOCATION or PROPOSED INFILTRATION GALLERIES
------------
50' PROPERTY LINE BUITTR o
II) --. - - ---".-,I(..
- -... --,---_ __J
o;__ _ _:so 100 200 300
SCALE IN FEET
RI .. ENVIRONMENT &
IUl>I INFRASTRUCTURE
FIGURE 1
PROPOSED INFILTRATION
GALLERY LOCATION
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN NORTH CAROLINA
N:\86619\6619KJO6.DIJG
•
6 ft.
2 ft.
I'll llt=9 ENVIRONMENT & lfl.U]) I INFRASTRUCTURE
•
; _L _____________ -
:;
F1GURE2
PILOT SCALE INFILTRATION GALLERY
Geigy Chemical Corporation Site
Aberdeen, North Carolina
h66\IJ41JO.UU
IIEl'TH
FEET
1
2
3
4
5 • 7
B
' 18
11
12
· 13
14
15
16
17
18
19
28
21
?2
23
24
25
26
27
28
29
Je
• •
IN-SITU TEDN:LOGY SOIL BEHAVIOR TABLE FOR SOUTHEASTERN UNITED STATES SOILS
JOB IA£ • • • • • • • • • 1£16Y OEIUCll
AllERiml IC
IISTE I I
FILE IRE......... PC-87
SJIL Brn'IYIOR · II: Lf N N' rm: IK6/CIC2l IK6/CIC2) WllES
I
SILTY TO Cl.AVEY F.S. 29.3 ... 9 6
SIL TY FIi£ SWD 57.2 • 14 11
SILTY TO Cl.AVEY F.S. 42.1 .4 14 1e
SILTY TO Cl.AVEY F.S. 117.4 2.23 3'l 32
11.AVEY FIIE ~ 136,2 4,35 54 45
SILTY FIi£ SWD 268.9 5.24 67 7S
FIi£~ 216.6 1,84 43 51
SILTY FIi£ ~ 218 3.49 54 58
DEHSE OR CEIEHTED ~ 287 1,112 47 62
IIENS£ OR CEIEHTED SIWDS 319.8 1.22 53 69
DEHSE OR CEIEHTED SIWDS Je5.8 ,8 58 1,4
DENSE OR CEIEHTED SWDS 212.3 .56 35 45
DEHSE OR CEIEHTED SIWDS 184.9 .51 Je 3'l
FIi£ SWD 163.4 .51 32 35
SILTY FIi£ liAND 75.8 .25 18 16
FIIE SWD 158. 7 • 91 Je 34
DEHSE OR CEENml SOOS 228.8 .62 36 47
DENSE OR CEIEHTED SWDS 293 .97 33 44
FIIE~ 188.9 ,98 'ST 42
DENSE OR CEIEHTED liAND5 188.5 .• 63 31 48
FIIE liAND 165.6 ,49 33 35
FIIE liAND 168.8 .42 33 35
DEHSE OR CEIEHTED SOOS 221,2 .62 36 47
FIIE liAND 173.5 ,95 34 3'l
fllE liAND 162 ,31 32 34
FIIE liAND 134,9 .27 26 28
DEHSE OR CEIEHTED liAND5 193.2 .56 32 41
SILTY FIPE ~ 68.8 ,lrl 15 12
SILTY FIi£ liAND · 57.7 ,1)6 14 12
DENSE OR CEIEHTED SWD5 218. 7 ,52 35 44
VEl!TICll RELATll'E FRICTI~ Y!UES l.liDRAIIED
EFFECTIVE IE6ITY IHU l(JDlUJS 9£AR
STRESS llO IDEGREES> (K6/CIC2) STREl6TH
(K6/CIC2) (K6/CIC2) • ff ... ....
-~ se,:-6t,: HS 1,4
.897 7ti,-ll8:( 148 125
.146 6e%-7ti-44-46 92
.195 88%-'lei: 148 258
.244 )'le% )48 299
.293 )'le% 148 S'll
.346 )<Jet )48 476
.395 )'le% )48 479
.454 )'le% 148 631
.512 )'let 148 783
· .549 )'Jet 148 672
.586 )'le% 46-48 467
.622 ~-98'.( 44-46 411!,
.655 ~-98'.I 44-46 359
.686 se,:-1,e,: 48-42 166
• 719 88%-98'.I 44-46 331
·• 756 )<Jet 44-46 485
, 793 88%-'lei: 44-46 446
• 826 ~-98'.( 44-46 . 415
.862 eeJ-98'.I ,44-46 414
.896 78".(-i!eS -42""" 364
• '129 m..-~ 'STI
.965 )<Jet 44-46 486 .999 78'.l-ll8:( ~ 381
1.832 m..-42""" 356
1.865 6e%-78'.( 42""" 296
1,182 88'.(-98'.( 42""" 425
1,132 (~ 36-38 133
1,163 (~ 36-38 12{,
1.2 ~-98'.( 42""" 463
!E6ITIVITY ClM>. OCll
ilEPTrl
=a1
'
,e
.1
.2
:3
•• < ·" ,1,
.7
.&
:9
!8
~1
~
~
:4
~
j,
:7
:B
-~
~
• •
IN-SITU TECHNOLOGY SOIL.BEHAVIOR TABLE
FOR SOUTHEASTERN UNITED STATES SOILS
JOB . ""' • • • • • • • • • IUGY DEIUCA'..
ABERDEEN IC
RUSTE&I
FILE ""'" ....... P--8
SOIL BEHAVIOR oc LF N N'
TYPE IK6/CK2l tKG/CM2l V~lES
t
S!L TY TO Cl.AYEY F. 5 •. 24 • lb & < " SIL TY TO C..AYEY F. S. 35.4 .15 11 b
SILTY TO Cl.AfEY F.S. 37.2 .19 l< B
SIL TV F INt 5/flD 5c:. 3 .25 13 11
SIL TY F !NE Sl'l'-.'.D bl. 9 .24 15 13
SlLTY FINE SAND 58. 7 .23 14 13
SILTY FINE 5A'lD 55.9 .3 13 12
SILTY FINE SAND 58.& .3 14 13
FINE SAAD 82.6 .23 JI, 17
FINE SAND 93 .12 18 19
FINE~ 130.9 .ec 2(, 2!,
FI Ne: SAi.Ji 146 .14 29 30
FINE SAND 143.8 • 01 28 29
DENSE OR II1£NTED S1VIDS lb5.b .el 27 33
DENSE OR CE!e<TED ~ 171. 7 .83 28 34
D€N!f OR Ci"'1flED SAIIDS 11,3.8 .ec cl 33
FINESANII 154.9 .83 30 31
FINE SAND 132.5 .03 21, 27
FINE SAND 98.2 .1!6 19 20
FIIESAND 93.8 .39 18 20
FINE SAND 183.4 .63 20 23
FINE SAND 128.8 .16 25 26
FINE SAND 112.3 .19 22 23
FINE SAND J19. 7 .49 23 21,
FINE SAND 123.9 .21 24 26
FINE SAND 125.5 .26 25 26
FINE SAND 129.9 .83 25 21,
FINE SAND 120.5 .27 24 25
FINE SAND 151,, I .36 31 33
Fl!£ SAND 125.4 • 81 25 25
VERTICAL RWlTIVE FRICT!OO YD..NGS OORAIIOJ
EFFECTIVE DENSITY ~u: 11'.lDU.US SHEAR
STRESS (%) IDE6REESI (K6/Cll21 STRENGTH
IKG/CIQI IKG/C!QI
• H HI ffH
.04& 5el:-f,0): 46-4B 52
.097 1,0):-70% <\b-4& 77
• 14!, 1,0):-70~ 44-4b Bl
.195 1,0):-70% 44-4!, 115
,2,.,, 60%-70% 44-4l, 136
.293 68%-70% ,.,,--4!, 129
.341 60):-70): 42-44 122
.39 60%-78% 42-4/t 12'J
• 44-1 70%~ 42-44 181
• 498 70%~ 42-44 204
.551 70%-801-44-46 287
.605 80%-90): 44--4!, 321
.659 70%-801-44-46 316
• 717 80%-98% 44--4!, 364
• 771, 80%-90% 44-4o m
.835 80%-98% 42-44 368
.888 78%-80% 42-44 340
• 942 70%-88% ~ .... 291
.996 50i-60% ,40--12 216
1.049 50%-60% ·4H2· 206
1.183 50i-68l' 48-42 227
I. 157 68)(-78'( 4Hc 283
1,211 :;ei-1,e,; 40--12 247
J,21,4 68l'-70% 4Hc 263
1. 318 60%-78'( 40--12 272
1.372 68)(-78'( 40-42 271,
J. 421, 60%-78'( 40--12 285
1.479 58%-f>in 4&-42 21,5
J.533 60%-701: ~, 343
I. 587 58%-f,0): 38-40 275
SENSITIVITY coo. OCR
-
•
[IUil ENVIRONMENT & I INFRASTRUCTURE
•
FACSIMILE
PROJECT NUMBER 86619,500 })ATE 11-8-94 TIMB 1830
SUBJECT: Geigy Chemical Corporation Site
Descriptions of Additonal Modeling and Pilot Testing
FROM: Jim Cloonan [phone] Fax: [phone]
· TOTAL PAGES SENT INCLUDING nns PAGE: 26
ADDRESSERS
USBPA
Lui~ Flores
NCDEHNR
· Randy McBlveen
COM
Tim Eggert
Mark Taylor
Billy O'Donnell
Comments
[phone]
[phone]
(404) 9S1-8910
[phone]
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), attached please find the referenced document, Hard copies are
being forwarded to you, NCDEHNR, and CDM via Federal Express for priority delivery
·tomorrow,
Sincerely,
7:"d
•
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
November 10, 1994
Mr. Luis Flores
Remedial Project Manager
USBPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, GA 30365
RB: Descriptions of Adc!itional Modeling and Pilot Testing
Geigy Chemical Corporation Site
Aberdeen, North Carolina
VIA Ei'ACSIMILE AND FEDERAL EXPRESS
Dear Mr. Flores:
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), attached are seven copies of the referenced documents. The
documents are submitted for your review prior to our meeting on November 17th. Also attached
is the resume of the lead modeler, Mr, V edat Batu, for the additional groundwater flow
modeling effort. At your request, copies of the referenced document and Mr. Batu's resume
have been sent directly to Mr, Tim Eggert, Mr. Mark Taylor, and Mr. Billy O'Donnell of
COM, and Mr .. Randy McElveen of the NCDEBNR. .
We 8IO looking foiward to meeting with you and discussing these materials further. Please feel
free to contact me at [phone] if you have any questions or require additional infonnation.
Sincerely,
Garland Hilliard
Project Coordinator
/ Attachments
2'd
c: T. Eggert (COM)
M. Taylor (CDM)
B. O'Donnell (CDM)
R. McBlveen (NCDBHNR)
J. Serfass (Olin)
H. Moats (Ciba)
G. Crouse (Ciba)
J. Vinzant (Kaiser)
H. Gtubbs (WCS&R)
J. Cloonan (RUST)
M. Sheehan (RUST)
S. Sargent (RUST)
RUST B&I Project File 7.4.S
•
E'd 377I/\N33~~ 'I~3 1sn~ Wd6v:v0 V6, 0, ~ON
•
Vedat Batu
Senior Consultant
Education
Univen:ity Associate Professor DeU" (gained with an approved thesis and pW!sing additional
examinations), 19.79, Hydraulic Engineering, Interuniversities Institution, Ankara, Turkey
Ph.D., 1974, Hydraulic Engineering, Istanbul Technical University, Istanbul, Turkey
B·.s. and M.S, (combined), 1969, Civil Engineering and Hydrautic Engineering, respectively,
Istanbul Technical University, Istanbul, Turkey _
Professional Registration
Registered Professioillll Engineer• Pennsylvania · ·
Certified Ground Water Professional by the Association of Ground Water Scienti5!5 and Engineers
Experien_ce
Dr. Batu has extensive experience In all aspects of hazardous waste management, with emphasis
on the groundwater and surface water flow systems. A!cas of expertise include assessment of the
hydrogeologic, hydrologic, and geochemical systems, with partioular emphasis on groundwater
hydrology, contaminant hydrogeology, and Interaction between groundwater and surface water
systems. Dr. Batu has extensive experience in preparing environmental impact 11ss11ssment for
existing and projected Waste disposal facilities. He provides technical support to multidisciplinary
projects incluclii,g h=dous waste investigations and feaslbilty studies, permitting studies, and_
mining projects. Dr. Batu has a strong background in numerical and analyticw models for flow and
contaminant transport in groundwater (in porous and fractured media) and surface water systems .
. He has participated at numerous RCRA/CERCLA site projects including data analysis, in-house
model development, and development of modeling studies ranging from simplified analytical
models up to complex th!ee-dimensional numerical groundwater flow and contaminant transport
models. He is familiar with the use of publicly available numerous computer codos for ground and
surface water systems. Interdisciplinary team experience includes working with geologists,
hydrogeologists, chemists, toxicologists, wetlands specialists, meteorologists. regulatory
specialists, and engineers on water resource planning, design and construction, operation and
maintenance prolectS. Dr. Batu has also teaching, research, and consulting experience in
hydraulics l)nd ffuid mechanics, open channel hydraulics, water hammer, experimental hyclraullc
modeling techniques, and mathematieal model and computer code development for flow und
contaminant transport in ground and surface water flow systems. Dr. Batu is widely publisbecj in
different journals and sym.J?osia proceedings throughout the world and his publications -are
referenced by many authors m different journals and books.
Senior Mnsultant. RUST Environment & Infrastructure, NAperville. Illinoi••
Responsible for technical support and project management in the areas of hydrogeology, ·
hydrology, groundwater flow and solute transport modeling, surface water hydraulics.
groundwater impact assessment, remedial investigations and feasibility studies, permit
applications, landfill design, and civil engineering projects. Specific project experience includes: ·
Kankakee Recycling and Pisposal Facility, Waste Management of Illinois, Inc.,
Chebanse, Illinois, Groundwater impact assessment development to meet the requirements of
Illinois Envirolll1l()ntal Protection Agency regulations. Involved comprehensive three-dimensional
groundwater flow and contaminant transport modeling and monitoring wells system design.
377IAN33~~ ·1~3 1sn~ Wd0S:v0 P6, 01 AON
•
CID Environmental Complex, Waste Management of Illinois, Inc, and Chemical
Waste Management Inc., Calumet City, Illlnoi&, A justification and evalu11tion of the
monitoring well spacing was perfonned based on the regulations of Illinois Environmental
Protection Agency.
Tazewell Recycling and Disposal Facility, Waste Management or Illinois, Inc,,
East Peoria, Illinois. Groundwater impact assessment development to fulfill the requirements
and standardli of Illinois Environmental Protection Agency. Involved extensive data analysis,
conceptualization, and complex multilayer three-dimensional groundwater flow and contaminant
transport modeling and monitoring well8 system design.
South Side Facility, Waste Management of Illinois, Inc,, Cook County, Illinois.
Involved groundwater impact assessment for e. i;rrojected recycling and disposal facility to meet the
requirements of Illinois. Environmental Protection Agency. Involved extensive data analysis and
three-dimensional groundwater flow and contaminant transport modeling and monitoring wells
system design.
Laraway Recycling and' Disposal Facility, Waste Management of Illinois, Will
County, Illinois. Groundwater impact assessment development to fulfill the requirements and
stan~s of Illinois Environmental Protection Agency. Involved comprehensive !~-dimensional
groundwater flow and corirarninant transport mocleling through a system fonned by a composite
liner and an aquifer.
Chain of Rocks 'sanitary Landfill, Waste Management of Illinois, Inc., Madison
County, Illinois. Groundwater impact assessment development to fulfill thfl requirements and
standards of Illinois Environmental Protection Agency, Involved comprehensive three-dimensional
groundwater and contaminant trans~on modeling through a system formed by a composite liner
and an aquifer bounded by the MissJ.SSippi River nnd Chain of Rocks Can!!l.
Senior mana er Golder ciates Inc. Responsible for project management and
technical support involving groundwater ow and solute transport modeling, hydrogeology,
hydrology, field tests (pumping, slug, and packer tests), and surface water hydraulics for remedial
investigations/feasibility studies and civil engin~g projects. Specific project experience
includes: · · ·
Remedial investigation/feasibility studies of the lndustri-Plex Site, Woburn,
Massachusetts. lnvolved site characterization, hydrogeologic data analysis (pumping and slug
tests) extraction and injecti~n wells design with groundwlller modeling. ·
Bell Aerospace Textron DNAPLs contamination Gite, Wheatfield, New York.
Involved site characterization and extraction/injection wells design for a multiple aquifers system
with groundwater flow and solute transport modeling using the telescopic mesh refinement ('fMR)
approach.
Sandy Hill Landfill Expansion, Bowie, Maryland. Involved site characterization,
hydrogeologic data analysis (pumping and slug tests), and evaluation of various engineering
design aspects with different levels of groundwater modeling, ·
Development of the one-and two-dimensional solute transport modeling package called "ATM -
Analytical Solute Transport Models, Theory and Uset's Manuals". The programs are being used in
various Golder offices. ·
S"d
• •
Senior hydrologi~t. senior staff con~ultant and senior technical associate.
Internatjonal Technology (IT) Corporation, Pjttsburgh, Penn~ylvanja. Provided
high-level technical Sui>ervision in various hazardous waste projects, especially in areas of water
resources management, including hydraulics, fluid mechanics, groundwater hydrology,
. contaminant transport analysis (organic/inorganic), mathematical model development for
groundwater flow and solute and radionuclide transport analysis, and computer modeling of
processes associated with these disciplines. Involved in numerous environmental science and
engineering projects including hydrogeologic data analysia, in-hou~e model development,
development of modeling studies ranging from simplified analytical models up to complex three-
dimensional . numerical groundwater flow and solute transport models in aquifers, feasibility
studies, proposal and statement of qualifications (SOQ) report writing, as well senior level
consultaµon to all IT offices. Representative consulting projecis include:
Recovery, monitoring, and hydraulic control of the Aetna■Dover Fuel Spill, Aetna
Casualty and Surety Company, Passlppany, New Jersey.
Waste Isolation Pilot Plant (WIPP), U.S. Department of Energy, Carlsbad, New
Mexico. Involved data analysis and stochastic solute transport modeling.
Hardeman County Landfill, Velsicol Chemical Corporation, Memphis, Tennessee.
Involved assessment of contaminant migration in unsaturated and saturated media.
-Hydrologlc Assessment of Union Carbide · Taft Plant, Halmville, Louisiana.
Involved assessment of contaminan_t migration using the VHS model.
J,T, Baker Facility; Philipsbµrg, New Jersey, . Groundwater flow and contaminant
transport modeling investigations to design an extraction wells system. . ·
Ironton Iron Production. Wells and Gold Damp Disposal Area, Allied
Chemical/Ironton Coke Site, Ironton, Ohjo. Numerous geohydrologic llild hydraulic
analyses and computer modeling applications.
Closure and Postclosure Plans. IT Corporation Vine Hill and Baker
Impoundments, Contra Costa County, California, Involved numerous hydrogeologic and
hydtaulic analyses including extensive three-dimensional design-oriented groundwater modeling,
contaminant migration assessment for the design of postclosure · facilities. Incorporated
development and use of computer models. _
Remedial Investigation and Feasibility Study for the former Firl'.'ltone Facility,
Salinas, Calffotnia, Firestone Tire &_Rubber Company, Akron, Ohio, Involved site
characterization and extraction wells design using extensive ground water flow and solute transport
modeling._· -. · ·
Site Characterization of the Engelhard Specialty Chemicals, Delancy Street Facility, Newark, N,;,w Jersey, . _
Odessa Chromium II Site, Texas -Water Commission, Odessa, .Texas. Extraction
wells design under som.e specified constraints with groundwater• flow and solute· transport
modeling.
Development and use of Computer Models in Fractured Media for the IT
Corporation Panoche Facility, Solano. County, California.
· 9"d
•
Great Lakes Chemical Corporation, El Dorado, Arkansas. Involved hydrogeologic
data analysis and extraction wells design for a complex aquifers system with extensive
groundwater flow modeling. . .
Hydrogeologic Study of Feed Materials Production Center (FMPC), a
Nuclear/Mixed Waste Site, Discharge to the Great Miami River, Cincinnati, Ohio.
Involved in extensive two-and three-dimensional groundwater flow and radionuclide transport
modeling study with SWIFT ill (Sandia National Laboratory's ~nsional groundwater
flow,, brine, and radionuclide transport code). Incorporated development and use of solute
transport models for surface and subsurface flow systems. Involved and extensive code
verification study for SW!Ff III against other numerical codes (MODFLOW, Princeton Transport.
Code, and GEOFLOW, IT's proprietary code) and analytical groundwater flow and solute
transport codes.
In House Code Developments: Revision 4.1 of the _GEOFLOW (IT's ~te element groundwater
flow and solute transport computer program, user manual, third pnnting, 1986). Performed
extensive verification of the GBOFLOW code, wjth the use. of analytical solutions available in
literature and developed by Dr, B11tu. Development and use of one-and two-dimensional. solute
transport programs based on Dr. Batu's original works published in journals. These programs are
being ·used in various IT offices.
Senior groundwater hydrolo,:ist, NUS Corporation, Pittsburgh, PennRylvania.
Reapo1111iblc for groundwater modeling studies. Also provided high-level technical support to
multidisciplinary mostly Superfund projects involving groundwater components, including
hazardous waste investigations, pennitting studies, and mining projects_. Specific project
experience includes: ·
Data analysis and contaminant migration assessment for the Vega Alta Well Field,
Vega Alta, Puerto Rico, U.S. Enviroo!llental Protection Agency.
Remedial Investigation and FeasibUJty Study for the New Bedford Landfill, New
Bedford, Massachusetts, U.S. Environmental Protection Agency.
Remedial Investigation and Feasibility Study for the Port Washington· Landfill,
Town of North Hempstead, New York, U;S. Environmental Protection Agency.
Groveland Wells Site, Groveland, Massachusetts, U.S. Environmental Protection
Agency. ·
llemedial investigation and feasibility study for the Tybouts Corner Landfill, New
Castle County, Delaware, U.S. Environmjlntal Protection Agency.
Remedial investigation and feasibility study for the Gloucester Environmental Management
Services, Inc. (GEMS) Landfill, Gloucester Township, New Jersey.
Swope Oil Site, Pennsauken, New Jersey, U.S. Environmental Protection
Agency.
Nyanza Cbemlc11l Site, Middlesex County, Massachusetts, U.S. Environmental
Protection Agenty.
Drake Chemical Site, Clinton County, Pennsylvania, U.S. Environment.;ll
Protection Agency.
377It-N33~9 'I~3 1sn~ WdlS:P0 P6, 0l ~ON
•
D.'Imperlo Landfill Site, Atlantic County, New Jersey, U.S. Environmental
Protection Agency,
Visiting Associate Professor. Soll Science Department. · University of Florida.
Galne~viHe, Flodda. Research on mathematical modeling to simulate the transport of multiple
solute species in soils.
Visiting Research Scholar, Deportment of Civil Engjneering, Auburn University,
Auburn. Alabama. ,Research on fmite element simulation of hydrodynamic dispersion
(contaminant migration) in non homogeneous and .anisotropic aquifers and teaching graduate and
undergmduate courses in the subjects of surface and ground .water hydraulics, ground water flow
and contaminant migration modeling. · . ·
Visiting Research Associate Professor, School of Engin~ring, University of Missi~sippi, Oxford,
Mississippi. Research on finite element computational surface and ground water hydraulics and
teaching.
• e .Prnfe r ent of n ineerln r echnlcal
Ua:jiversity, Trabzon, Tur ey. Teaching 1111d research in hydraulic engineering area, Chairman
of the Civil Engineering Department,' and Director of Hydraulics Laboratory .
.Vlsitjn;: Scientist, · Department of Civil En1ineerlng, University Colleiie of
Swansea, Swansea. Wales, United Kingdom. Research on finite element computational
hydraulics.
Assistant Professor, Departmept of Civil . Eneineeclng, Karad1mb Teehnical
University. Trabzon. Turkey. Teaching and research in hydraulic engineering area.
Visiting Assistant Prnfe~sor. University of Wisconsin, Madison, Wisconsin.
Research on ground water hydraulics.
Assl8111nt Professor. Department· of CiyH Engineering, Karadeniz Technical
University, Tre.bzon, Turkey. Teaching and research in hydraulic engineering area.
Ph.D. student, Faculty of Civil Engin~ring, Istanbul Technical University, Istanbul, Turkey.
Instructor, Department of Civil Engineering; Karadeniz Technical University, Trabzon, Turkey.
Teaching in hydraulic engineering area ..
Presente.tion, Publications, Awards
Author of oyer thirty authored and co-authored publications on the .subject of ground and surface
water. Has published a number of papers in internationally recognized journals such as Ground
~; Journal of Hydraulic Engineenng and Journal of Irrigation and Drainage Engineering of
American Society of Civil Engineers; Journal of Hydrology; Soil Scjence Society of America
Journal; and Water Resources Research and symposia proceedings. Has developed numerous
mathematical models and introduced new concepts on the subject of ground water flow and
contaminant transport. Publications are referenced by many authors in different journals and
symposia proceedings. .
Publications
Batu, V., "A Mathematical Modeling Method for Prediction-of Surface Water Contamination A~ a
·Result of Ground Water Contamination," Submitted to Journal of Hydrology. 1993.
8'd
•
Batu, V., "A Generalized Two-Dimensional Analytical Solute Transpon Model In Bounded Media
for Flux-Type Finite Multiple Sources," Water Resources Research (in press), 1993.
Batu, V., and R.C.F. King, "The Application of Mathematical Modeling Tools for Remedial
Investigations and Feasibility Studies," Pmceerlings of the Mediterranean Conference on
Environmental Geotechnology. Cesme, Turkey, May 25-27, 1992.
·Batu, V,, "Recent Developments in Two-Dimensional Analytical Solute Transport Models,"·
Invi_ted Paper, ProceedingR of the Solving Ground Water ProbJems With Mnrlel~ <:onference,
Intema\ional Ground Water Modeling Center and Association of Ground Water Scientists and
Engineers, pp, 3-17, Dallas, Texas, February 11-13; 1992. ·
Srivastava, V.K., V, Batu, S. Nialci, and E. Zoratto, "Long-Tenn Groundwater Cleanup
Strategy," Prn~eeclinf!ll nf HA7.MA<:nN 90 Hazardous Material~ Man11pment Conference end
· Exhibition, Anaheim, California, pp. 189-200, April-17-19, 1990.
Batu, V,, an<1 M.T. van Genuchten, "First-and -Thircl•Type Boundary Conditions in Two-
Dimensional Solute Transpon Modeling," Water Resource~ Research. Vol. 26, No. 211 pp. 339-
350, February, 1990. · .
Batu, V., "A Generalized Two-Dimensional Analytical Solution for Hydrodynamic Dispersion "in
Bounded Media With the First-Type Boundary Condition at the Source," Water, Resources
Research, Vol. 25, No. 6, pp. 1125-1132, 1989.
Batu, V., "Contaminant Plume Analysis Using the Hydrodynamic Dispersion Stream Function
(HDSF) Concept," Ground Water, Vol. 26, No. I, pp. 71-77, 1988.
Batu, V., "Introduction of the Stream Function Concept to the Analysis of Hydrodynamic
Dis1"3rsion in Porous Media," Water Rcsource11 R"5eateh, Vol. 23, No, 7, pp. 1175-1184, July,
1987.
Broscious, J.A., V. Batu, and M.C. Plautz, "Recovery. of Petroleum Product from a Highly
Permeable Aquifer U · · ter Supply Wells," · Sixth
National · toration and-Oroun , The
Ohio State University, o um us, 10, pp. 93-509, May 19-22, 1986.
Batu, V., and S. Haji-Djafari, "The U~ of Mathematical Modeling for the Environmental Impact
Assessment of Hazardo~ Waste Sites," Proceedin1,1s of the Third Intematiopaj SympoRium on
Environmental Management for Devc,lQJ;lfpg Countries, August 6· 12, Istanbul, Turkey. ·
Batu, V., "Comments On 'Non uniform Leaching From Non uniform Steady Infiltration' by J.R.
Philip." Soi) Science Society of America Journal, Vol. 49, pp. 1594-1595, 198S. ·
Batu, _V., J. Ho, and J.G. Yeasted, "Solute Transport in Solis Based on the Theory of LineariZ.ed
· Unsaturated Flow Net Analysis," 20th Annual Mooting, Northeastern Section of the Geolo&ical
Sociel;JI of Ameri!:',!l, Lancaster, Pennsylvania, March 13-16, 1985.
Batu, V., J. Ho, and J.G. Yeasted, "Analysis of Unsaturated Flow Beneath a Landfill," Comiiuter
Applications in Water Resources, edited by H.C. Torno, American Society of Civil Engineers,
Buffalo, New York, pp. 162-172, 1985.
Batu, V,, "A Finite Element Dual Mesh Method to Calculate Nodal Darcy Velocities in
Nonhomogeneous and Anisotropic Aquifers," Water Re~nurees Research, Vol. 20, No.11, pp.
1705-1717, 1984.
6'd
•
Batu, V. 'R.S. Mansell, and S.A. Bloom, "Finite Element Simulation of Linearized Water and
Solute Transport in Unsaturated Soil," Soil Physics Division. 76th Annual Meeting of the
American Socjecy of Aaronomy. November 25-30, Las Vegas, Nevada, 1984. ·
Batu, V., "Flow Net for Two-Dimensional Linearized Infiltration and Evaporation from
Nonuniform and Nonperiodic Strip Sources," Journal of Hydrology, Vol. 64, No. 1/4, pp. 225-
238, 1983.
Batu, V., "Time-Dependent, Linearized Two-Dimensional Infiltration and Evaporation from
Nonuniform and Periodic Strip Sources," Water Resources Research, Vol. 19, No. 6, pp. 1523-1529, 1983. . . . .
Batu, V., ·"Time-Dependent Linearized Two-Dimensional Infiltration and Evaporation from
Nonuniform and.Equally Spaced Strip Sources," Proceedings of the National Conference on
Advances in Infiltration, ·
American Society of Agricultu~al Engineers, Chicago, Illinois, pp. 55-68, 1983.
B11tu, V., "Two-Dimensional Dispersion from Strip Sources," Journal of Hydraulic EngineedoL:-
American Society of Civil Engineers, Vol. 109, No. 6, pp. 827-841. .
Batu, V., "Time-Dependent, Linearized Two-Dimensional Infiltration and Evaporation from
Nonuniform and Nonperiodic Strip Sources," Water Resource~ Research, Vol. 18, No. 6, pp.
1825-1833, 1982.
Batu, V., "Unsteady, Two:Dimensional Linearized Infiltration and Evaporatipn from Nonuniform
and Nonperiodic Strip Sources," Hydrnn]jc Prohlems of Ground Water Drainage. International
Association for Hydraulic Research, .Belgrade, Yugoslavia.
Batu, V., ''Linearized Modeling Techniques for Unsaturated Porous Media and Applications to
Nonuniform and Nonperiodic Strip Sources," NAm Advanced Study Institute on Mechanjcs of
Fluids in Porous Media -New Approaches in Research, University of Delaware, Newark,
Delaware, July 18-27, 1982. ·
Batu, V., "Flow Net for Unsaturated Infiltration from Periodic Strip Sources," Water Resources
Research, Vol. 16, No. 2, pp. 284-288, 1980.
Batu, V., "Flow Net for Unsaturated Infiltration from Strip Sources," Journal of the lrri~ation and
Drajrn1ge Division, _American Society of Civil Engineers, Vol. 105, IR3, pp. 233-245, 179.
Batu, V ., "Doymamis Zeminlerdeki Akim Aglarinin, Ke.ynaklarin Tek Serit ve Periodik Serit
Olmasi Hallerinde Incelenmesi (Flow Net for Unsaturated Infiltration from Single and Periodic
Strip Sources)," As.~ociate Professorship Thesis, Interunivrsities Institution, 98 pp., Ankara,
Turkey, 1979. · .
Batu, V., "Steady Infiltration from Single and Periodic Strip Sources," Soil Scicpce Society of
America Journal, Vol. 42, pp. 554-559, 1978.
Batu, V., W.R. Gardner; "Steady-State Solute Convection in Two Dimensions with Non-Uniform
Infiltration," Sojj Science Society of America~oumal, Vol. 42, pp. 18-22, 1978.
Batu, V., "Steady Infiltration from a Ditoh: Theory and Experiment;" Spjj Science Societ,y of
America Journal, Vol. 41. pp, 677,682, 1977 (Adapted from the Ph.D. dissertation presented to
Istanbul Technical University in March 1974 and supported as research project No. MAG-299 by
the Scientific and Technical Council of Turkey).
0"\ "d 377IAN33~~ 'I~3 1sn~ WdES:v0 v6, 01 AON
•
Batu, V,, "Doymamis Ortamdaki Bir Kanaldan Bnfiltrasyon (Infiltration from a Ditch i,n
Unsaturated Porous Media))," Ph.D. Dissertation, Faculty of Civil Engineering, Istanbul Technical
University, Istanbul Turkey, 212 pp, (in Turkish with an English summary).
Batu, V ., and K. Cecen, "On the Method of the Detennination of Unsaturated Flow Characteristics
by Means of Electrical Resistivity," Proc. 15th Cong .. International Association of Hydraulic
Research, No. 3, pp. 135-144, Istanbul, Turkey.
Batu, V. and K. Cecen, "Acik Bir Kanaldan Enfiltrasyon (Infiltration from an Open Channel,"~
Congress ofTUBITAK. Ankara, Turkey (in Turkish).
Professional Memberships
American Geophysical Union
American Society of Civil Engineers
National Water Well Association
Employment History
1992 -Present
1990 -1992
1985 • 1990
1984 • 1985
1984
1983 -1984
1982 • 1983
1979 • 1982
1979
1977 -1979
1976 · 1977
1974 -1976
1970 • 1974
1969-1970
balll.ved/0S2193
H"d
8.UST Environment & Infrastructure, Inc.
Golder Associates, Inc.
International Technology Corporation
NUS Corporation
University of Florida
· Auburn University
University of Mississippi
Karadeniz; Technical University
University College of Swansea
Karadeniz Technical University
University of Wisconsin-Madison
Karadeniz Technical University
Istanbul Technical University
Karadeniz Technical University
377IAN33d~ 'It3 1snd WdvS:v0 v5, 0i ~ON
21'd
•
GROUNDWATER FLOW MODEL DESCRIPTION
FORTHE
;REVISED P.RBI..IMINARY DESIGN
GfflGYCHBMICALCORPORATIONSITB
ABERDEEN, NORTH CAROLINA
NOVEMBER 10, 1994
· RUST PROJECT NO. 866.19.500
377Ii\N33~5 'I~3 1sn~ WdvS:v0 P6, 01 AON
•
· 1:0 PURPOSE
The p1!Ipose of this submittal Is to describe the proposed groundwater flow model for.the
uppermost aquifer at the Geigy Chemical Corporation Site (Site). This submittal is in
partial response to EPA's October 13th correspondence, The objective of the modeling
study is to characterize flow and to . evaluate different extraction alternatives for the
uppennost a.quifer, including vertical extraction wells 1111d horizontal ~µ-action wells.
1b.e evaluation will involve an effort to optimize the configuration of the final extraction
system.. Additionally, inf'tltration gallery simulations in the· uppermost aquifer will be
included in the modeling effort.
In order to achieve these goals, a groundwater flow model will' be developed. Based on
the conceptual model of the hydrogeologic system (Section 2. 0), and the remedial action .
alternatives to be evaluated, the three-dimensional USGS model MODFLOW (McDonald
and Harbaugh, 1988) will be used for the groundwater flow simulations. The model will
be constructed in two and three dimensions to evaluate vertical and horizontal extraction
wells, respectively. The model will be constructed, calibrated, and subsequently utilized
to evaluate extraction well capture zones for the uppermost aquifer.
2.0 CONCEPTUAL MODEL AND CODE SELECTION
Site. topography and well and boring locations an: shown on Figure 1 (attached). The
stratigraphy and hydrogeology beneath the Site are depicted on cross-section diagram
B-B' (see. Figure 2, attached), Based on Site-specific qualitative nnd qlllllltltative
information including saturated thickness, pumping test, lithologic, and water level data,
the Site conc,eptual model presented in Figure 3 (attached) was prepared. This
conceptual model was developed based on the. stated puipose of the modeling effort
(Section 1.0), and to illustrate the hydrogeplogic units present beneath the Site (i.e.,
uppermost, second uppennost, and ,third uppermost aquifers and associated confining
· units), the interconnection of these units, and general hydrogeologic aspects of the system
(e.g., saturated thickness, lateral continuity, hydraulic conductivity, etc.). In accordance·
with agency comments, the modeling study will be conducted for the uppermost aquifer,
which is underlain by the uppermost confining unit. This part of the hydrogeologic
system acts as a separate unit from the underlying second uppermost aqui,f er. With the
exception of limited recharge from the uppermost to the second uppermost aquifer where
the uppermost confining unit is not sufficiently thick to prevent leakage, the uppermost
aquifer has no hydraulic communication with the undel'lylng second uppennost aquifer.
The satnrated thickness of the uppermost aquifer thins south of the former facility, and
the aquifer is no longer present in the vicinity of well MW-11D. As shown in Figure
3, theleakage ,:ate of water from tlie uppermost aquifer increases as the thickness of the
uppermost confining unit decreases. · Although the uppcnnost aquifer is losing water
through the confining layer, the predominant groundwater flow direction in the aquifer·
Groundwat.er Plow Modeling 2 Novcmbct 10, 1994
ET"d 377IUJ33~S 'I~3 1sn~ WdvS:v0 v6, 01 AON
•
is horizontal. Lithologic characterization· of the uppermost aquifer (based oo the
installation of over 30 borings) indicates tllat the grain size distribution is consistent
throughout the aquifer. Thus, for the moc!ellng effort it will be assumed that the aquifer
consists of one lithologic fonnation (e.g;, silty and clayey sands). Because the uppermost
aquifer is relatively thin (sa,turated thicknoss of 0 to 20 feet), composed of one (ormation
(silty and clayey sands), and has no vertical gradients, groundwater fl.ow will initially be
simulated using one layer. Additional layers will be added to the model during the
evaluation of extraction alternatives (see Section 4.0).
Based on the conceptual model of the hydrogeologic system, and the extraction
alternatives to be evaluated, the three-dimensional USGS model MODFLOW (McDonald
and Harbaugh, 1988) will be used for the groundwater flow simulations. MODFLOW
is a well-accepted and well-verified finite-difference code and has been widely used in
the groundwater industry for more than a decade. MODFLOW can simulate both
two-and three-dimensional groundwater flow. Boundary conditions for the model will
· include prescribed head in areas of groundwater recharge, and no flow· in areas where
equipotential contours are pexpendicular to the model boundary, and in areas where the
uppennost aquifer pinches out.
3,0 CALIBRATION
Model calibration will be conductw · following construction of the model., Initial input
parameters for horizontal hydraulic conductivity and precipitation recharge will be 3
feet/day and 1S inches/year, :respectively.· Model calibmtion will be achieved by
adjusting the horizontal hydraulic conductivity, precipitation recharge rate, and leakage
rate through the ·uppermost confining unit. The observed and modeled hydraulic heads
at monitoring well locations within the uppermost aquifer will be tabulated and
compared, and the observed and modeled groundwater head contours will be pre.rented
on the same figure. The observed and modeled response to pumping well PW-1S at a
constant rate will also be evaluated by comparing groundwater head contours on the same
figure, and by tabulating and comparing observed and modeled hydraulic heads at
observation well locations within the uppermost aquifer. The observed and modeled
capture zones for well PW-IS will be compared using the USGS model MODl>AtH
(Pollock, 1989), which directly imports results of MODFLOW and conducts particle
tracking based on simulated hydraulic head values.
4.0 EVALUATIOl'l OF EXTRACTION SYSTEM DESIGN ALTERNATIVES
Using the calibrated model, different extraction configurations for the uppermost aquifer
will be. evaluated. The first alternative to be evaluated will be fully-penetrating vertical
extraction wells and infiltration galleries. The simulations for this case will-be conducted
using the two-dimensional calibrated model. The next alternative to be evaluated will
Groundwater Flow Modeling 3 November 10, 1994
377IIW33~~ 'I~3 1sn~ WdSS:v0 v6, 01 AON
•
be horizontal extraction wells and infiltration galleries. Because of the flow
configurations, this alternative will be evaluated using a three-dimensional model which
will be created by adding additional layers to the existing two-dimensional calibrated
model. The additional layers will be added to simulate the vertical gradients produced
by the horizontal woll. Extraction well capture zones and infiltration gallery :celease
zones will be created using MODPATH, Sensitivity analyses will be conducted by
varying measured hydrogeologic parameters (i.e., hydraulic conductivity, precipitation
nicharge rate, and leakage rate) to evallljlte the impacts on the capture zones.
5.0 RBPORTINO OF RESULTS
The revised report will include:
• model domain and boundary conditions, including the location, rationale, and
testing of boundary conditions;
• model stratigraphy cross-sections and elevation contour maps of the bottom of the
uppennost aquifer;
• tabulation and statistical comparison of observed heads and simulated hydraulic
lteads for the calibrated model at monitoring well locations in the uppermost
aquifer;
• observed groundwater contours and simulated groundwater contours for the
calibrated model on the same figure;
• tabulation and statistical comparison of observed heads and simulated hydraulic
heads for the ~brated model und~ pumping conditions utilizing well PW-tS;
• observed groundwater contours and simulated groundwater contours for the
calibrated model under pumping conditions utilizing well PW-lS on the same
figure;
• observed and modeled capture zone for well PW-1S on the same figure;·
• a description and justification for model input parameters (i.e., . hydraulic
conductivity, precipitation recharge, and leakage rate) presented in tables and
figures; and
• results of extraction alternative simulations (including simulated groundwater
contours and capture and release zones) presented in figures in relation to the
groundwater plume. · ·
Results of the model will be presented in the revised PDR.
G10Undw11or Flow Modewis 4 November lO, 1994
Sl"d 377IIIN33~~ 'I~3 1sn~ WdSS:v0 P6, 0l AON
•
REFERBNCBS
McDonald, M,G., and A,W, Hll.rbaugh, 1988. A Modular Three-Dimensional
Finite-Difference Ground-Wa~ Flow Model, Techniques of Water-Resources
Investigations of the United States Geological.Survey, Book 6_, Chaptc:r Al. ·
Pollock, D.W., 1989. Documentation of Computer Programs tc Compute a.nd Display
Pathlines Using the Results from the U.S. Geological Suivey Modular
Three-Dimensional Finite-Difference Ground-water Flow Model, USGS Open
File Report 89-381.
Otoundwalor l'tow Modalins
91"d
NOV 10 '94 04:56PM RUST E&I, GREEIWILLE P.17 ! i
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•
ADDITIONAL INFILT'.RATION PILOT TESTING
FOR THE
REVISED PRELIMINARY DESIGN REPORT
GBIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
NOVEMBER 10, 1994
RUST B&I PROJECT NO. 86619.500
•
1,0 INrRODUC'TION
In response to comments from BPNCDM dated October 13th, ~e Companies have prepared this
document which describes the methods and materials for an infiltration pilot te.st at the Geigy
Chemical Corporation Site. The infiltration pilot test will be conducted under the following
conditions:
• located at the. actual location of the propo5ed initltratlon gallery
• run for not less than 24 hours ·
• the side walls will be scarified.
2.0 PROPOSED PILC)'~"I'EST
The location of the proposed infiltration gallery is presented in Figure 1(attached). The pilot
test will be conducted within the area of the proposed infiltration gallery. The previous pilot
test established an allowable inftltration rate of 12 gpd/ft2. The additional test will attempt to
operate at this rate or higher.
Prior to construction of the gallery, soil borings would be conducted within the infiltration area
to a depth of 20 feet to assess the presence of any shallow clay lenses. Soil boring logs
(attached) f\,Jm P• 7 and P·S (Figure l) in the vicinity of the proposed infiltration gallery provide
lithology for the area. These borings indicate there are no confining units in.this area above the
water table. · ·
A water truck would collect water from the fire hydrant across the street for the infiltration pilot
test. This hydrant was used previously for decon water during the pre-design field investigation. •
The pilot-scale trench cross-section (Figure 2) will be designed similarly to the anticipated
full-scale trench to simulate as closely as possible the true characteristics of the soil, This would
also allow for the incozporation of the pilot-scale trench into the full-scale system should the
design prove favorable. The anticipated loading rate (1·2 gpm) would be equal to or higher ·
than both th~ median and average infiltration values from the compact constant head
permeameter (CCHP) testing conducted during the pre-design efforts.
Monitoring wells and pi~ometers downgradjent of the pilot test (MW-11D, OW-1D, OW-2D,
PW-1D, and WP-lS) will be monitored prior to, during, apd following the pilot test to note any
influence on the uppermost and/or second uppermost water table,
3.0 LOCATION AND CONSTRUCTION OF THE TRENCH
The selection of the infiltration gallery location was described in detail in the draft PDR. The
pilot test will be located along the casternmo~t lateral of the proposed lnflltradon gallery as
shown in Figure 1. The exact location of the pilot gallery along the lateral will be determined . .
lmlltration Pool Testing 2
12'd 3771NsJ33~~ '1~3 1sn~ Wd6S:v0 V6, 01 ~ON
•
in the field.
The side walls of the pilot trench will be scarified using the toothed bucket of a backhoe. This
method will simulate construction of the full-scale trench and actual operating pelformance.
Care will be taken during scarification so that the side walls do not C(!llapse. ·
The pilot test infiltration gallery would be constructed by excavating a trench two feet wide,
approximately .six feet deep, and approximately 20 feet long. The nominal depth of the gallery
· will be six feet.
A gcol0xtilc would be placed against all sides of the trench to maintain separation between the
trench walls (sand) and the stone to be placed later. The trench would then be backfilled with
utQne to within one foot of the surface. A perforated pipe would be placed on top of the stone
for the full length of the trench. A six-inch layer of similar stone would be placed on top of the
pipe followed by a layer of geotextila (to maintain separation between the stone and native soil),
Native soil would be used to provide the remaining six-inch layer. In addition, sections of 1-
inch PVG piping will be placed vertically between the trench bottom and the surface at points
along the trench to allow monitoring .of any standing water that develops within the trench during
the'test.
4.0 SCHEDULE AND REPORT
Rust E&l could be ready to conduct the pilot borings and the pilot test as early as the week of ·
Oecember 5th, contingent on subcontractor availability and approval by EPA/CDM. Results of
the pilot test will be presented in the revised PDR.
lnfilttmao Pilot Testioo
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1111._.ENVIRONMBNT & Olmtl lNFRASI'RUCI'URE.
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; APPROXIMATE LOCATION 0:
OF PROPOSED INFILTRATION GALLERIES t!
FIGURE 1
PROPOSED INFILTRATION
GALLERY LOCATION
GEIGY CHEMICAL C□RP□RATI□N· SITE
A N□RTH CAR□
~
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•
6 ft.
,'
2 ft.
I'll ..-ENVIRONMENT & l~U::.I INFRASTRUCTURE
•
'. i
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FIGURE2 PILO'l'SCALEINFIL'l'RA.TIONGALLERY
Geigy Cbemlcal Corporation Site '
At,,,rd•,n, North Carolina
--2 ·--------------:377INsJ33cl:J 'I'83 1snc1 Wd00 :£0 \:>6, 0i /\ON-;mmm'
•
IN-SITU TEClftlOI 'D&Y &C:IIL BEHAYIOR TABLE
FDR BflUTHEAST£RN ~ITED STATES SOILS
DEPTH
J1IB Ml!£ • .. ... • . . IEIIIY Qf!UCII.
AIIER!m IC
RIST E & I
nL£ -.. •••••••• PC-i7
SOIL BSllVIOII · II: lF N h"'
Fm TYPE U<6/0l2l lHS/0121 VILlES
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SILTY TO CUl\'E\' F. S. 29.J ,16 9 6
l SILT! FIi£ 5llal 57.2 I 14 II
J SILTY m ll.ll\'E\' F.S. ~l .4 H 18
4 Slll't TO OJl'IEI' ~.S. 117,4 2.23 39 32
5 llJlYEV FIi£ Sl1Q i3'.2 4.35 54 45 . ' SILTY FIi£ SIWD 268.9 5.24 67 7:l
1 Fl!£ SAND 216.6 1,114 43 51 a SILTY t!IE SWD 218 3.49 54 58 • DENSE OR' CtJEHm) NS 2lJ7' 1,81! 47 6e
18 ll8E OR CEl£NTED lllWDS 319,8 1.22 5J 69
ll IJENSE OR ceEliral 5A'lDS 31lS.8 .a 5e M
12· IIENSE Da taallEII sttlDS 212.3 .56 3:s 45 . ll ll8E OR memD 9NlS 184, 9 ,51 38 :n
14 FIIEM 163,4 .51 32 35
15 SILTY I'll£ SN> '15.8 ,25 18 16
" FIIESIWD · 158.7 .91 38 34 17 DENSE QR 1E1EK1iD SlliDS E2t. 8 .62' 36 47 ta IIEN5E OR lE£NTEI ·SIWDS 283 ,97 33 44
' " . '11£M ,ea., .,a 37 42
28 DENSE OR telEJfm> 51WDS 188..5 .• '3 31 48
!I . nlE 5AND l!.S.6 .49 33 35
l2 fllE 5AND Ir.a. 8 .41! 33 35
2l DENSE 1111 CEIEN1ED 9N!S 221,2 ,62 36 47
!t f1IE lilND 17J.5 .95 34 39
l!5 ·.FJIE· 11111D 162 .a1 32 34
21, FINE &IINII IM.9 ,r, 2' 26
27 llEllSE DR CEIINTED !i11111S 193.2 .56 32 41
28 SILlY FIi£ 5AND ~8 .r, ' 15 12
29 611.lY Flt£ S1ND · S7,7 .16 I~ 12
38 msE DR CEl£NTEll ~ 218. 7 .52 35. 44
VERl'ICIL IEJITIUE FRICTI[)( 'r'llN,S ~RAIIE)
ErFECTIVE llE!SITY INi.£ lfJl>U.l6 ll£IIR
STRESS (Jl IDEllml (K6/CIC2l STREl6TH
U<6/0el (K6/0l2l • .. ""' ffff
.848 SH~ )48 M
,897 78'-Gti 148 12:i '
• 146 r,e,-~ 44-46 '2
.195 llti-'lel: ) 411 2:;a
.24-1 )91:r: 148 Z'l!
.293 1• 148 591
.34& ' ,~ I~ 476
.395 199,: )48 479
,454 )HJ 148 Ul .s12 199,: )48 783
· .549 )99,: 1,48 672
,586 )~ .\I,~ 467
.622 88'~ 44-46 486'
,6:1:l --'JM 4-\--16 35')
.686 ~~ 41-42 IU
.7U Bei-48ll 4-\-4& 331
~75!, I~ 44-46 48:i -• 'I'll ·•-m 44-4(, 446
.1121, ·"'" 44--41, 415
.862 .. .44-46 414
.ffl 79S-l8,I ~~ 364
.929 ffl-88l' ~ 371
,96:i 199,: 44-41, 486 ·"' 7~. 42-44 381
1,832 m• 4H4 J56
1.li&s 68l'-78J ' ~ e96
1,182 SM~ 42-44 425
I. la2 I~ 36-38 133
1; 163 ' (48S 31,-38 126
1,2 -~ 42-44 41,3
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DEPTH
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IN-SITU TECliNOLOGV SOI~ BEHAVIOR TAB~!
FOR SOUTHEASTERN UNITED STATES SOI~S
108 N\IE •••• "'" 6El6Y Del!Cll
AIIERD!lN IC
RUSTE&,I
FIL£~ ••• , ••••• P..B
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•
SlLTY TO Cl.AVEY F, S, ,~ • I~ e s
SILT'/ TO 0..AYEY F. S. 35.4 .15 11 6
SILTY 70 QJIID f. S. 37.2 • J 9 12 e
SILTY FIKi: ~ siJ ,25 13 11
SILT'f flNt ~ 61. 9 ,24 1~ 13
SILTY Flt£ SRlD 58. 7 .eJ H 13
SILTY fltli: SIIIID 55.9 .J 13 12 ·
SILTY FINE S1WO 58.8 .3 14 13
Flt£ SAAD 82,6 ,23 16 17
fJN; _&IN) 93 ,12 lB 19
FINE S/1111 !Jll., ,,82 a, a,
FINt SI» 146 ,14 2'l 38
FIN£ SAID 143.S .81 28 29
DENSE DR IIIENT£1l SANDS 165.6 ,el 27 33
IJ£NSE DR C8£NTm SIWIJ5 171.7 .eJ ~ 34
DENliE DR CEIE!ffED !AIDS 163.8 .e2 l7 33
FIIE stfjl) l~.9 .13 38 ~I
FIii, -lillND 132.S .e3' t'l, 27
FINE SIWD 98.2 .e6 19 ee
FIi£ SIWI)· · 93.8 • 3'I 18 2e
FIIESIWD 183,4 ,63 28 23
fJNE 5ll'G) 128.8 ,I& 25 eh
FINE M ue.3 ,It u !J
~!NE liAiOl!I 119,7 .49 2.3 26
fllEM 123.9 .21 24 21,
FINE~ 125.5 • e(, 25 e(,
FINE 6'Wll 121, 9 • e.i 25 2&
FINE liANU 128.5 .27 24 es
FINE 6/WD I~, I ,36 31 JJ
Fi!IE SllHrJ 125. 4 .81 25 ~
YERTICPL RELATIVE FRICT!tl't YIJ.WS l.NDIIRI !ED
EFF£CTIV£ 118.'SITY MlU: l«l!XA.US aE!lH
STRESS m 1Dt6R£f.S1 (1(6/CM21 S1RENSTH
!f(G/ Cl;2 l IK6/Cl'21
ff HI HM
.e~e se:H,0)( 4/dB :ii:
,e97 6tl:•79'( 4He n
.I~ 6~·70~ H·i6 Bl
, 195 6~·78J 44•~ 115
, 244 61ll•7eS 44---11, 136
• 1!'13 n1-1ei +;--4!, le'!
,3.\1 6~·70,; 42·44 )1'2
• l'l 68Me~ 41!44 12'l
,4'H 71ll~ 4Z·+I !Bl
.49B 7~-ffl 42-44 204 ..
.~I 71ll-B01, 44-&6 287
.685 88j-,~ 44--41, Jc!
.659 ffl-AQf. 4-1-\o 31,
.717 88S-91ll 4-1-41, 31,1
,?76 B0M~ 44~ ,317
,BJS se,-,es ~ 368
,886 m-eei. -Ii!--+; 348
.~42 7b-8e~ ~ 2'11
.996 !il!J-6~ ' ,49-42 214
1.M9 58,-68% ~-2e6
1.103 58J-6tl ff e27
I, ISl &111·1111 48-42 283
l,ZII ~-ie!, 'IHZ 247
l,1!64 ,.,._m -\Ht Zf,J
I. Ji8 ~8l-78l 4&-42 272
1,372 61ll-m 48-42 276
1.426 68l•'m 4Hl! 285
1,479 ~-68% 48-42 ,2£>5
l,:W 68%·7111' -l 3'J
1,587 5e%-i0J 38~ 275
SENSITIVITY [;OIi?,
'-
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9Z'd 377IN'133.~:) 'I'83 1sn~ Wd10:S0 t,6, 01 /\ON
OCR
-
-
NC SUPERFUND SECTION Fax:[phone]
** Receive Journal** Nov 3 '94 Nov 10 '94
Nov 10 '94 17:04
No. From: Mode Received Time Page Code Result Note
0003 9193781001 NORMAL 3,15:37 1'08" 2 0000 0 K
0004 8132899388 NORMAL 3,16:34 4'33" 10 0000 *R.5.2
0005 8132899388 NORMAL 3,16:45 0'53" 2 0000 * 0 K
0006 8132899388 NORMAL 3,16:54 1 '33" 3 0000 * 0 K
0007 8132899388 NORMAL 3,17:41 1 '22" 3 0000 * 0 K
0001 9194662000 NORMAL 4,10:40 0'29" 1 0000 * 0 K
0002 NORMAL 4,11:27 3'28" 7 0000 * 0 K
0003 9046566+3386 NORMAL 4,12:18 2'45" 7 0000 * 0 K
0004 9197331812 NORMAL 4, 13: 14 0'53" 2 0000 * 0 K
0005 9194662000 NORMAL 4,13:32 0'27" 1 0000 * 0 K
0006 NORMAL 4,17:44 3'50" 8 0000 * 0 K
0001 NORMAL 7, 8:30 3'02" 7 0000 * 0 K
0002 NORMAL 7,11:23 0'49" 1 0000 0 K
0003 NORMAL 7,11:25 1 '07" 1 0000 0 K
0004 NORMAL 7,11:29 1 '05" 2 0000 0 K
0005 4043471695 NORMAL 7,13:01 1'57" 4 0000 * 0 K
0006 NORMAL 7,16:36 1 '10" 3 0000 * 0 K
0007 NORMAL 7,16:48 2'54" 7 0000 * 0 K
0008 4043475205 NORMAL 7 ,16 :52 1 '38" 2 0000 *T.2.2
0001 4043471695 NORMAL 8,11:29 3'06" 3 0000 * 0 K
0002 3036692932 NORMAL 8,13:40 1'02" 2 0000 * 0 K
0001 NORMAL 9, 15: 12 1 '45" 3 0000 * 0 K
0002 9103965830 NORMAL 9,15:19 1 '41" 5 0000 * 0 K
0001 9198297356 FINE 10, 9:57 1 '25" 2 0000 * 0 K
0002 8032343000 NORMAL 10,16:45 12'23" 26 0000 * 0 K
•
11/08/94 12:36 -~• • EPA REG ION IV • MGT ffiOGR!l'IS 001
' ~ • •
~::;;.)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
'
345 ¢ourtl~nd Street, N.E.
Atlanta, Georgia 30365 . .
FACSIMILE TRANSMITTAL COVER SHEET
;p;;;& TO: ??'k~,d
lie D£ l-/fU!2J COMPANY/ORGANIZATION:
PHONE NUMBER: FAX NUMBcR: · tj/_2-13:d-t;:f JI
NUMBER OF PAGl:S 51:NT (lncludlng this cover sheet}: \.B '
Please contact the person sending this fax If It Is received poorly or Incomplete.
FROM: , LUIS E. FLORES
NORTH SUP,ERFU":10 REMEDIAL BRANCH
WAST!;! MANAGEMENT DIVISION
'
Phone Number: (4P4) 347-7791 Vmx-4118
Fax l'jumber: [phone]
COMMENTS: ~; 5'kjf~
('.,, _._..,, 11...£ I A ., ': /fl/ ht. d I /3 f-fv fl;ll,,1) rh µ, rrd:
'V / /
H(.Pv
'
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I
12:38 EPA REGION IV WAI MGT PROGRi'NS 002
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY l . ' ;
REGION IV
345 COURTLAND STREET, NJ::.
ATL.ANTA~ GEORGIA ·30:l6:;i ' .
13, 1994
4WD-NSRB
Mr. Garland E. Hilliard
P;i:ojoot Coordinator
Olin corporation
P.O Box 248 1186 tower River Road NW,
Cha:i:leaton, 'l'ennei,,.ee 373~0
SUBJ1 EPA'e determination regarding PRPs responses Preliminary Design R,port
Geigy Chemioal Corporation Bite Aberdeen, North!Carolina
Dear Mr, Hilliard1
EPA has determined that in order to address our concerns regarding the PRPs respon$es tq the Agency comments, and to expedite preparation of.tbe Geigy Chemical Corporation Site Remedial Design (RD), the[following tasks must be conducted, '
l) The PRPn nhall re4efin~ the RD ObjectiVO(S) for the Site to include not only qonta~nment of the groundwater contaminant plume, b~t the prevention of further downward migration of contwni11,ants ,from the uppermost aquifer to the second uppermost aquifer, minimal disturbance (i,e., diepersion) of the 'l'C:E plume, and expeditious remediation of SitG-related groundwater cpntwnination.
2) The PRPs shall deJ,elop ~n acceptable groundwater flow model £or the uppermo,st aquifer which provides a more realistic represent-at;ion of the aquifer eyetem and addresses the concerns presentS:d in l!:PA's comments. Due to the complexity of the aqu;ifer !lyatem, EPA recommends the use of a thrGG dimensional ~odel as opposed to the two dimensional model previously use~,
3) Using the newly de~eloped groundwater flow modoi, the PRPs shall reevaluat~ the previous groundwater modeling scenarios and evaluat'° new;ecenarios, including those identif.l'ed in l'lPA's cbmments to achieved the redefined RD objectives. The PRPs 15hall' then prepare and submit a revised report which presents\ the figures, analysis and results identified in EPA'e cp11U11ente along with the information presented in the prev1.ous Submittal, and any new information the PRPs believe is appropriate. The revised report shall be submitted to EPA by D9cember 16 1 1994.
11/08/94 12:39 • I EPA REG ION IV • MGT PROGRFl1S 003
4) In the event that!the-revised design still calls for infiltration galleri~s, the PRPS shall conduct additional infiltration testing\in t~e iu-ea(s) proposed, The infiltration tests s~all_l:1e run in the area(s) deoignated for infiltration for!a till\e period of not _less than 24 hrs, 1md shall include sci4rify1ng of the test area walls, as indic1>.ted in EPA's c· ents, The results of this testing 1>hall be included in the ~eport,
Please contact me at [phone] x-4118, if you have any questions,
Ma.nage;i:-
Rnclosure
I . • •
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
October 31, 1994
· Mr. Luis Flores
Remedial Project Manager
USEPA Region IV, North Superfund Remedial.Branch·
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: Draft Work Plan for Downgradient Investigation
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Mr. Flores:
NOV 2 1594
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), attached are seven copies of the referenced document in
accordance with Section VII, Paragraph 15 of the Consent Decree. Copies of the referenced
document have been sent directly to Mr. Tim Eggert and Mr. Billy O'Donnell of CDM and Mr.
Randy McElveen of the NCDEHNR.
As presented in the referenced document, the Companies have shown infonnation exchange
meetings following major milestones in the project. These meetings should provide a means for
better communications and information exchange thro1ighout the proposed work. The first such
meeting is tentatively set for November 18th. The purpose of this meeting is to describe our
approach towards investigating the downgradient groundwater and to address any initial agency
comments. Please let me know if this date is acceptable to you and your project team or if
another date would be preferable.
Please feel free to contact me at [phone] if you have any questions or require additional
information.
Regards,
Garland Hilliard
Project Coordinator
RP
/ Attachment
c: G. Luetscher (USEPA)
W. Smith (USEPA)
C. Fehn (USEPA)
T. Eggert (CDM)
M. Taylor (CDM)
B. O'Donnell (CDM)
, R. McElveen (NCDEHNR)
J. Serfass (Olin)
H. Moats (Ciba)
G. Crouse (Ciba)
J. Vinzant (Kaiser)
H. Grubbs (WCS&R)
J. Cloonan (RUST)
M. Sheehan (RUST)
S. Sargent (RUST)
RUST Project File 7.4.5
•
11: 16 EPA REGION JU iE MGT PROGRAMS 001 RD
~~
~)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 courtlantl Street, N.E.
Atlanta, Georgia 30365
FACSIMILE TRANSMITTAL COVER SHEET
~a:11 TO: h'Mhl!:!JJ.
AIC,JJE Jl/1,/0 COMPANY/ORGANIZATION:
PHONE NUMBER: FAXNUMBER: 9/f-7!J8-Y9//
NUMBER OF PAGES SENT (Including this cover Sh99t): 15
Please contact th11 person sending this faK If It Is received poorly or Incomplete.
PROM; LUIS E., FLORES ,
NORTH SUPEFIFUND REMEDIAL BRANCH
WASTE MANAG'EMENT DIVISION
Phone Number: [phone] Vmx-4118
FaK Number: [phone]
COMMENTS.;_ £ .. M, ~ ,,l/ a . . _, d ~, , ;,.
PR/(J ,., • · ".atti €"PA .:1 ~:#i] I /J.c.l,k ::) (,. If I// )
ch•,. -r I..· ·· ,J,1., F./J/3. '--
~ r : •J~ , --
-\ ~ ;£; <lit CW, ,/I -<4' µt '1J eA4.1). J wdl ~ ~ rA ~ ~ rA~'\.J~ We_ ~f f-i.u ~
-~
11/02;~ 11:15
11101/94 06:G4 FAll 6..,4166
EPA REG I ON I V WASTE MGT PROGRAMS
OLIN-ERG Chae.
Via facsimile
Qrl0Jaa1 Yia Mail
Mr. Luis Florea
Geigy Chem/ca/ Corporation
Aberdeen, North Caro/Ina
Committee Correspondence -
October 31, 1994
United Stetas Environmental Protection Agency
Region IV EPA .... nr-Gl0N IV
345 Courtland Street, NE
Atlanta, GA 30305
_.,,:,, ' .. ···,
Re: The Geigy Chemical Corporation Site, Aberdeen, North Cal"Qlinei
Dear Mr. Flores:
002
raJ 00Z/006
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum and
Chemical Corporation (the "Companies"), we were both surprised and disappointed
after rece~ your October 26, 1894, notice of disapproval regarding our prevll'msly
1:1ubmll.\c,i;l prc,llmln111ry design report.
A3 set forth in the attached comment&, tha Companies believe .that an adequattt model
and an approprii;ite preliminary design has been developed for remediation C>f the
Golgy fe1oilily prop$rly.
We understand there is a significant dlffe,rence or opinion between the Companies'
consultants and EPA's oversight contractors.-We have sought to discuss theee matters
with you, both on October 12 and October 26, but EPA has declined to discuss these
Issues on either occasion.
While we believe the level of effort and costs to complete the additional tasks
demanded by EPA are not commensurate with any ~enefits that may be gained, we are
willlng to undertake the additional tasks at the Site as outlined In your October 13, 1894
letter. ·
We accept your invitation to Cliscuss the~e lssu1:1s as soon a11 po::;llible, end we suggest
that we meet in Atlanta on November 7, 1984. While the Companli,i:; agr&e to oomplate
the tasl<S-ntifled In EPA's October 13,: 1994 letter, we do not feel that this work can
be completed by December 16, 1994. Ths Companies therefore, request ~n extension
of time from the Decembetr 16, 1994, oeadllne to accomplish these sddltlonal tasks. A~
11/02/liii,. 11:17
11/01/94 08:55 FAX 61.4166
Geigy Chemteal corporation
A1,ertleen1 North Carollnlll
C1>mmltte1t Com~sPondenoa
EPA REGION IV WASTE MGT PROGRi=t'IS
OLIN-ERG Chae.
Page2
mi;>re fully 1:tXplalned in the attached schedule, the Companies request a GO day
ext1;1nsion of the December 16, 1994 date. This is the minimum time necessaty to
accomplish the tasks set forth in your October 13, 1994, letter.
003
Ill 003100s
Lastly, It I& ni;>t clear if the State was copied on this letter but given the significance of
the TCE migration In groundwater under the Site from an upgradlant source (which Is
not the responsibility of the Companies), we believe it Is Important that the State
participate, fully In these discussions.
~
We 1001< forward to hearing from you at your earliest convenience.
GEH/cp
260
Sincerely,
OLIN CORPORATION
Gculam:I e. Hilliard
1 l/02t)/ 11 : 17 EPA REG ION l V -TE MGT PROGRFl'IS
11/01/94 08: 311 FAX 6 4166 . • OLIN-ERG cnas '
OCT 31 '94 11>1: 11Pl'I ENV•INFRASTl'IUC.:, -
USPONSB. TO EPA COMM;t:INTS DATBD OCTOBHR 13, 1994
QNTD .
DRAFI" l'KlWMINARY DIISWN BEl'QJlT
omoY CHJ!MICAL COJitPOllA110N SITB
ABBP't>BBN, NOR.TH CAaOt.lNA
OCTOBBR 31, 1994
RUST E&I PROJECT NO. 1\6619,400
004
Ill 004100s '-~
11/02/11 11:17 EPA REGION IV WASTE MGT PROGRA'IS
11101/94 oe:oo FAX 61 4160 ·.oLlN-lmG cnas l. OCT :oi ''3'1 10• l..:J"M . t:.Nv-.,-.-"""''"u1,,,
(" GOPftllal BPIJIQII~
005
@000/00&
tho opening pamamph of BPA's leuer not$ that one of the objectives of tbc Remedial Dastgn
(and lber gi.vtm t,Ula) Is •10 expedlEe prepamli,oD of dlo Gei&Y Chemtcal. Co,ponmon Site
~medial~-. The Compan!os agm, wllh this posldon. n is our t>ellef, however, fllat the
~ In )nVIQA\Qd ill ti. Pmllm1nary Deslp R=p<IIt (PI>ll) is iidel:jlWC to achieve nnncdiatiDn
fo.r tho Nd'aco soils a11d groundw11iw at the Gcslgy $ire. 'Xbci C~ t\lnhcr l>olklvc tliat the
additioDlll tasks 3Ifl not ncoe$SIII)' for the deaip of an offcclivo romedy and romcdlatioo of the
Sile. Neve.rtht:I."•"• tho ColllJlaniD& are piepaied. to perform these tuks bllt l:CCluiro additional
tiine bey~~bcT 16th to pi-epare a tbrea•cllmcnstonlll m.odol and addross Otbe.r SPA
requiremenu. The Companiu lherefore will need an at:ldltlonal 60 da)'& to adl1res1 these aim.
This cxten&lon inllQqlOmle5 a sc.heduled meelinJ f.O be held with BPA and CDM to diJeUsl la
detail tho Companies' sel.,,,,.,., groundwaw: model Add input parameters.
CommwNo, l
Summary: The PJ.U's ~ball ndeflnc tho RD obJmive(a) for the Sile.
RtlJ)QDSO
The c:olJlJ:llOIJt rodeflnm tho obJeclives as: .
1) ~ of tlODWDinaut mipalioo fiom the uppCimost aquifK lO ~ NOOud
uppoanost aqulf'm'
2) mkdmal dispersion of the TCB plume
3) i:xpedltloU5 romedlildon ot Sli.e-1\llated grvundwan:r to11W11lnad.on.
'11u1 Companio1 agree In prlnclplo with theso goneral ~s and offer the following pusltions
to addl-ms BPA's concom5; '
~ . 1) TM proposed ~Oli 17a~w in tbo UJ1pwu10$~ ~ tlddil,~ a. iub~
portJon oflliclllllli& ofpNt!Qi"" (6S peNlOllt.) di~«>~ lleOl>nd uppermost
aquifet. Well placemellt was limited to those QJea£ with a satumred t1iiclaiN~ of
at lca&t slx feet, as th!• WI!$ CQII~ 11 realilltlc minimum fo,: xecove,y of
groundwateir and for wc:ll mamtcmantlll bllMd on pump requirements and
C;On&tructioo exporlcncc at othl,r situ. Any nwdlfl.cations to·the exmictlon system
(e.2. , acldidooa1 exl!1lctiun wc.;lla ur c~ hi 1ha purupln,: ratos) would be based
on actual pcdonnanco In the field, as intllcrued by tho I.OD.
The, Compank1 iq willbJ& IO modify the exuac:tton 1ystem following 1Dltallation
ff BUfflclw hydraulh: and BJlalyticel momtoriog indicates that th8 remedial
obJICtives are not attained .. this approach Is consistent wltb BPA guldam:o,
wbicb ~ t11llt groundwater remedlal actions "abould genonlly bB implomemod.
In a phased approacn· c·consid\t'atiODi in <JrOU))llwater Rerriediatl.On tt Superftln(1
Sites BD<1 RCRAFacillliC$ -Ufdatc", OSWBR Dir, 9Z$3.l-06, May 27, l!iln),
anc, 1h11 llOIJ. Potantlal modifloatltms 10 tho ID&tallcd system ,ivan in the IWIJ
2
006 11/02~ 11:18
11/01/94 06:66 FM O 4106
EPA REG ION IV ~E MGT PROGRAMS
iOLlN-ERG Cl>.88 .. , ,_®OOU/006
PCT :a1 · '!!4 10: 12\'M 1· ENV-IHfll!A!!TRI.Jt:,
2)
~ include alt.emalillg the pumping rlf wellc and the illstaUar1o11 of additional
utldon woll&, Requirements for monltorlng thll ox~on ottectlvenw will
be proacm.ed ill the drift. Pm'formanl:B Standuda Yodftcwcn Plan, wbich will be
aubmin'ed witb thi:. Intermcdiile/l"reflnal Dc&ign.
11111 loQutoo or the 1111'11trarion plli:Iy is oonstrainod by North carouna
' ' aiphtdons. wblch require a. ,"closed loop" sysrem. IDttJaU.y, we rarget£d the
cutqm cwl of 11m fi!Gllll)' propcny u a pmtbm:d lDc;;adon for die lnflltradon
gallory, Iwwcv":I', p,w:c;mant ofthc> Wllwt.ion &alh>r)' bwc, in pwllimity to die
groondwator div.do oo~tmt with Jllpway :n1, i;ould teault 1n apn:ading tho
pt,atil:idea Ill tho uppcmi:1,;,st lli"liw to c:11m:nll;r ckw>. .11J1'11.11 md tbua lo IIQt a
viable option. 'Dlif ooiwhi1l1m 11 ~ on waiot levc:l maps, the distribution of
pesdcldes, and grolll)dwatar modeling. GivM this potential, aloJli wilh tile
requirement of a "closed loop" &)'St.em, land availability, wale{ hwsl data,
dbUibution of pesticides, and our undotstalldi!IJ 0f sub&urf11CO oondiliun& as a
result of Direct Fush Technology (DPI') bOrings P•7, P-8, and wells MW-110
and PW-ID, we ~~led the c;UJI'$11t location for thtJ inlUtmlum ial111ty.
Preliminary model nis11lta indlcatod infiltrati.oft in this portion of the second
uppcnncMt ~er WOllld malntain wmpleto hydJll.ulic wntwl of th11 pla1110, and
._ thus lllfl.ltlatlon at tbia location wu Viable. · This appn,acb Is consistent with
~ outlined ID tile appl'QVed ~odlal l>i:sign Wolfr. Plan.•
Tile TCB plumo ortgblating ftom an upgredl.ent source h cummtl)' 11ndcftnlld tNt
at a m1111mum 1S piesent 111 '11/'ells MW-4D, l)(W-tID, MW•l6D an11 MW•17D,
WI' boifnp P-3, P.,; 1'·7, ~F-13, and llleuplJlldieDt well$ Ml'OWderMellll
Prod11~ (locat=«I o»balt mile east of tbe SM) 111d tbe Allred resldo.!lce (loca.Uld
uppRlJl1rualely 200 tbet nontleaa or MW•ll5P). All'/ pon1ort of llul TCB plume
cldlected by 1he illflltnlion ro~ Will l'U5Uml:I 1h olliM!n; WIIDl:I downpadlmd.
of cxtracdon well PW-2l>, M $?!own on tllQ a.ttal:bod fww llnea. AJiy dlap=mh>n
of the TCB plomo will thcrefozo be looalfred ..,ithln tho ZOJ'1t'l of lnftltmtion In die
seM!'d uppcrmoit aquifer. 1'hete would bo 11D net vftect on 1hD dlatributlon of
TCB dowllAftdient of the GetS)I facility due to ,the inflltradon JalleQ'.
A poltlon of 1118 TCB phlme would be ooU,aed b)' exmwtlou wdt ~-21>, as
shown by die llltae:hcd flow lhx>s. The trea.11:d dlschqe to tho lnflltratlon aallery
. would pass through tbnle oarbon units and bllve TCR levels belo'IP the Nortb
Carolina ZL standards. The groundwater i:emedlatlon systom would in effoa bAve
a posi~ve result, as It reduces the [U3l!S of 1'CB at tho Sit.e without cnratlng any
sigoiflcut dowogradlent dlsperalon. · ._
no Companios 1el1erate that 'l'CB bU bem1 detennlllCld 1W w be Sito-J»JIWld IUld
sbOUIO noi oo u&ea ro c:on~ the discharge options provided tor by tho ROD.
Tho COmpani85 encwnigo BPA lllld the Slate to addJess Ille up1radient source of
TCB.
3
11/02~ 11 : 19 EPA REG I ON IV .LJ'.!STE MGT PROGR!TIS
11/01/94 06; 67 FAX 6 4166 . OLIN-ERG CllaB
~ <11 '94 1011.3PM El'lll-!Nri<~lt<Ul,,
007
Ill 001100&
Tbe Compallles acme 11!8.t "oxpeclitious mnediariol\ Of Site-related grolllldwm,r
CXlntamhla.tlon" la, OOBlnblo. .
commpnt No. 2 .
SIQIIDlu:y: nw Pal's shall dlMIIOp an aoceptable grouudwatar now moael tor mo uppeimo1t
aquifer.
JlcGqp,o
Couoems of BPA and CDM roprdlng the sn,u.ndwatot 'IISodcllng appear to be> iclated 1IO two
fundMmW!J j1&11cs:
• deflnldO!l of 1:ml remedial dedp objecdvea
• undorslimdlng ot the JIU,:po:lb of the model.
the Companies have a dlorou&h llnderstandlng ur the uppClllllDSt aquJfer bu8d on our field
invoatiptions at the Site over the last six years, the iesu1ts of which have beeu oonflrmed by the
p,undwlllm' modell111 Qffon. The Companies lntond to captur1:1 tho practicablD maa& of
pe6ticldes from thri uppcrmoat aquifer, liven the bycbanlle limlwlom of die aquifer and the
. mechani.ca:I llmltad.on1 of cxttaction equipm1111t. .
The ma11 and ra= of cliJcbalge of pesti.Cides In tho uppennoat aquifer can be ai:cura!Oly
calcula.a:d based on field investiptions which have cletenrdned tbo dlritd.bution and concentrallon
. ot pesti.cides, si;oundw'®r now Cli1ee1i0n, hycwuuc Qhllnlcterilf.tO&, and satllmcd lllickness of
the uppermost aquifer. lbo onure mass of pcsuc~ in Ille upponuon aqldfoJ' Is approxlroatel.y
C>.2 pounds, l>ascd on Uw llfflll extent of lhe aqulfw C1J1.wodlng ped'onnBJ1CO stanelar(fa1 an
av~e aqulto.r ~knw, of 7 t=t1 1111d II puro,~ty 01' Q.05. Dan:y's law provides tbe mta1
volume of flow through a. given aq~ifst ~. For~ uppeunOlt 11.iiu.lt\,r, the lalcml exa,ot of
· ;po~ abovo Pmfonnanoo Standards in the uppermost aquifor h approJciwatl'Pl;ir 800 &tit. The
,gmdiClnt along this line is appt01Uallltely 0.0S end I® hyd:imlJk; WIICluctiv1ty is approximately
!J feet/•>'· Prom D~r•s la.w, ~
Q "" (JC)(i)(A) m (X)(l)(l)(w)
"' (3)(0.05)(800)(6)
• 710 etday"" ~.7 plloll!l/minuts.
'Ibbi ls the total co~tamfnated flow across ,)le entm: uppomiost aquifer. This ls a very small
flow mte oonsidmtng tbl.'l 18llmll eiaent and prodllCtivity ot die aquifer.
Tbo aveiqe. concentn.tlon ot tQtAl pesticides In tbls now is 28 ug/1, a{vlng a 1Xltal mw d15cllarge
nite of pelllleidel of 0.0012 pounds/da.y. TIie UpP8ffllost aquifot extn.etion· sylllem will R!COYllr
approxima\ely 6, pen:ent of the mass of ~cides being currently r.lischarged to Ibo aocond
l!ppemlOit aqi,ffcr (0.0008 pPUDdS or o.oou total pounds). lbe PlllSS IJf postlcides µnoapturecl
by tho eim:acUon ,ymem wUI be approxJmatoiy o.0004 pounds per day, whlcli ts a mauveiy
4
11/02-11:19
11/01/94 08:57 FAX 6 4166
OCT S1 •o;,q 10•13PM T E:NY-lNF~C.
EPA REG I ON IV ~E MGT PROGRFtlS
OLIN-llRG Chas ..
008
li!I008/008 ',u
minor contribution of pesliefdes lhat will be subsequently captund b;y Iha IOOOlld uppermost
aq,ulter 8Xll8ction syst.em.
The ~ass of Jl!l:Stic.ldcs in the second uppi:nnost aquifer uppad)ent of, the pmpo9fld
~ wo.11 1s ~ly J IJOllDds, based on the im:a1 ol®.Ot of the aquifer exceeding
pe:d'onnance $llllldarclB, en av01118V pqullor tbiolaieas of 20 feet, and a porosity of 0.28. The
second upponnost aquiAv ~n system will recovot 100 percent of 1he: mus of pestlcldos
Cllmlltly flowJng through the aquifer, including capture of any paaticides migrarlng frolll the
llpP"ffllO&t aquifor. .
AqLlilin tv5tiul w111 cooducted t.o dotennine tho ac!Ual oapwre ZOl\8 Qf an ex~ well In the
uppemiosr aqwt.r. The wicltb or tlle aqwrer With a sawmoa tbi.cwss of at toast ab: feOt a!IO
Jlw5 ava.ltablc fbr pumping Willi IDStallaUOn l$ appl'OXlme.toly 4!fO (eot (I.e., bctWeeD MW-6S 81111
MW·lOS), TIUll available width 18 based on tield·me&Sllred aq,ulfer &atumu,d UJJ.c!moaa, Wllter
lcwol, and pealiddcs distdbutlon .data only) and not modoling. Plow l8tes of the wall& were
dotarmlnod fro111 tba punlpln; test and sanaatg1 thlclrnc:e& data 1llld not from 1hr; model.
ne groundwater now modaling waa used onl)' r.o csva11S11a capturo zon11t for multipJQ wons
actin9 in coneen, llUJII the aingle well clllta from the llr!lllfer test. Dis wa.s conduof.ed in
acoordanco wft:h the approved Remedial Des1J11 Work Plan, whieh &taiel that 'lhf puipo,e, of the
modeling is the fl81imatlon of captnre zones for each aqllifer. The modeled caprure zo11e ot tbe
pumping well matched the measured ca,plllre zone of the. pumping wall, indlc:atlnl tile modal met
lt.s ~ccti'lS4 csthnatiDg mallslk ca,ptule· ionas for ext.tact.ion wells.
As also s18ted In the approved Bemedial Deslg11 Work )'fan, tbe eval11atil)11 of hJtUUallon pllCJY
systema was to Include •conductlna a cursory prolimWl'y mod@l" to wun, vJablllty of tho
concept. 'Im, modeliDJ was conducted ill BOQOrdall0$ with !hi& purposo and was used to evaluate
the polCDtial ~om of dJC tnrutmton system with the exnactlon systems 1n tho uppermost
aquifer and second uppennost aquU'er. Re$11lts of the mod11li~ .indicated l.nfilb11tlon illto tbo
upponnost a.qulter was not a Viable option, and infiltration inw the 8f,COml uppemwst aquifer wu
a VUlblb option (&oe responso to COlllJOOlts Nos. 1 and 4). The decl&ion to proceed ·With the
lkllign of the lnflltrld.on system fll tbe second uppennost aquifer wu made bUeO upon flOIG
datA, ~ ~ f'aao.r& and allowance5, a.vailal>le land area, and the model resulU, aplD in
acu:.idM= w1t.h tb1> epprovGd Jit.omcdlal Dealp Wwk Plan.
Tho Companies beliovo tho p,undwatcr mode!h,g Condi.I~ to duo JDet 111 obJoc:li.VOI u aralOd
U1 tho appn>ved Remedial Dtllfgll WOik Plall. DopendlJII OD tho lovlll of dotaU .roqul.ml, 001118.
for the addi6onal pound"1ater lllPdllllng e:ffom gould eowllQCI those to iu.steJl the oxtra.l:lion
&)'stem in the uppermost aqulter. A mo.re ~ective 11pptc,aeh woulcl be 10 ll1£lall the
designed extmbtimi and lnflltnUion systems and flald verify fl$ eftectlveness, as provided for in
the llOD. In addltioo, as Staled in Comment No. 1, lhe insllllled exmction s;vstem will be
modified it l'lllllcdial objectives aro not llttalnlld. -
11/02. 11:20 EPA REGION IV WASTE MGT PROGRl'MS ll(Ol(94 0,:01 FAX 6 4166 , !OLlN-HRG cnas. OCT :31 '94 ua, 141"M T EMV•INFRRSTF<!IJC.:
009
~oozroou
t"'. ( ~-
('· In mmmaiy, a second mndelln,s Nfo1t shCMild 110i be neceasary for th, foQowui; toall01l8:
•
•
•
..
•
•
•
the modeling met it& objectives of estimating w~ eaptnre ZODB$ Ud pmvidhlg a.
pmlimlnary cursory usossment of lnflltration u Slllted In the approved :bmedfaJ De&Jgn. WOttPhm;
well pl.aeoment ID tho extraction system ts balled on aQUifer test, waw level, pesticlde diJiftbirtlon, and lllltllrated t1w;kne$& data gathend from fillcl investipliDnl, with ~ti.on by groundwaror flow modollna (the latter used to detOml.iJle w"'1 c:aptul'O
1.0nEIS only);
hlt'iltratkm plJcry phwawont Is based on CHP mults, data ftom existing \IQrlngs, deslp
safety taotou and allow~•, 11vlUlabJo land an,a, awl pJCliminary modoling;
tho install.i.iou and 0pllillllon of tllCI system will provide tho infonuatlon needod to dctcmtlno if dcslJ" wudlfl~th:,n, (o,J,, WtallallOn or additional extraction wells) are
nerosaeey►
based on ~l calculaliona (i.e., DOt mod~I caka•lat\OJI&), this ~ost aqullW· • · -...c:tion s:ystem will capture ~ pe«:Ont of the Olltb"e: mass ot pestlcldBs balDJ pNH11tl7 diachaiged by thlt aquifer, with tho mmalniDg 35 pctt.cnt being subsoqumJtly QJ.ptllrod
bf h sceo11d uppermoat •U"u extraaion ll)'s=,
plment or ftYbacllon wells 1n the uppenn<Ht aquifer ill ocmttol1od by tho shallow
llllurated thlclme&S aad low )'fdd of the 11quifw1 which have beltn nieasum4 in tho flold,
Mel not gt()Undwatcr ,,...,IDJ mult.11; lllld '
COl'll})loce ~\we of peaticldes will be amdned in flM second IIPJ)OMOSC 8qulfef-(lncllldmf
ea,plUl"c ot any peaticldla mlJmtlnt from the upplllmOst aquifer), whicli ocmtaiM 95
pctC6l)t ot the JtUU;s of pcalioldoa In tho sySIOm,
~ emnment No, 3
iiurnmary: TIit PRPs shall cvalulUe new· gmuuowaier omnctlon IICOlllldo1 to addre6s the ~sci remodiill design obJOCtlve&,
BOIPOOSl'i
Tho mcanJng oflhis la llllClear, 111d tho Compwdes would appJeelate cbuiflCatiOD by EPA/CDM, Ponding eladf1cation, this tcqui,;em~ is inti:Ipwwd to mean that the CompanlBS ShOUICI tovilll tho current gronndwator extra.ct!Oll a;ystcm ll5 IICCCnat)' bll5cd on thu now mOClellJli rosulU. PJoue see the response to Commi,nt No. 2 _ repzdlng tllfl adeq1W;y or tho oxb1ing oxtlaedon systbm dMlp. •New scenatltu" Is inta1pffllld t0 moan eval11Bt1on or an lntwoaptor lml~ NKJ hMimatal wells for the uppermost aqulf'el-,
Tho &ppiovcd Fe.uibllhy Sludy cleuly dascrtbed tho use 01' VMtleJIJ. exttactlo.G 'llleUa and dds extraction qproacb wu sub5111uently embnced by tbs ROD. 111& Pauibllity Study rejected die
\IH al an loterQoplm trench fof the uppennost aquifer. V&Jtir.al extnlctlon wells were alJQ
11/02. 11 : 21 EPA REG I ON I l.J WASTE MGT PROGRAMS 11101194 09:02. l'M O 04100 .OLIN-BRG Chas. QCT :i$1 ..,'='4 2..~• l.:.>t"" I ~Nv~.1.N1· Kr-Gil'IKU"-'• .
010
lt!IOOJ/000 I .u
c1cacribed in tho approved bmlldlal De&lgn Work Plan. The Compa.nies assert that the d111ip 1bQuld pl0QOCd la IICCOrdanet with Ille ROD a.o.d not IDvJte poat-ROD chanios (e.g., an l!SI>).
Cgtppg;pt No, 4
~: Tbo .intlltmtion pilot telit should be oomluctecl agatn.
leRPPDR
'l1u, purpose of thb pilot test WN to (lC)Qmm tho C()Dlllant-~ ptmntumetel' (Clfl') values COliductM prevlOU&l.y at tho Site. Tb pilot test was not part of tho :Relnlldlal J>oai,gn Wolk PIM and ,was QQ!lduebld vobmrarity by the Coznpanles to obtain conf"mn~iy desif;n data. BPA WI.Ii notified of the woik prlor to lmplemematioll In acconlimc:Q wlth tho Consent Doct(){:: and. offmd Do comments on thu pilot test u that dma. ·
~ pilot ICIII collfimusd tho CBP va!Ue&, thereby acllievinf its objecdvtt. The NCDBHNR, = ponnittlq .authority for the lnflll?ldon galleey, stated tbat they have no concerns about die pilot testing. 'Qi.NCDBHNR t,yplcally OU.ts mfiltmtl.on pennlu based on the soils ~ alone.
AJ; dlscuSsecl m re&pODBG ID Comment No •. I, the currently proposed location for the infilua.tfon pllBry ls bl&6d on the NCDBBNR requbement f~ a "closed loop" system, land availability, wa1er level data, · distdbUti011 of pesticides,. aroundwa18t modeling, and our undorstandfaS of 1111bsud\we c:ondldons as a rc:sult of bo:dngs P.7, P-8, ·a,ncj MW-UD. The absenoe of dte uppellll0$l aq1alf" Ill 1Jie lmmedlate vicinity of the iilflltratlon gallery, 140 feet nonb of the l:afil~ &ellN)-, ud zso t• nanhwost of the mflltmloD pllcJy (i.e., at borln1s P-7, P-B, and 'MW-1 lD, n,,apoctlvely) QOIIClU51vely delnonslllUW no c1'.y uDits are present in or l\"8f the p~ ~ of infUmi.tion lD lllfflclllllt tbii:knl!&s to pel\11 water and slgniflcantly pevont the vertical mlgmion of wai.r bito tho ~ UpPtmDOSt aquifer. 'l'hesc field datA, combined with de, CDP and pilot tcatibf ¢0nduc:teld at die Site, dcmousmm, tho proposed location of t1u!J infiltration gallery is favorab~ for lnftltro.tloo. Io adaitlun, the p.ceaeat location of the inflltml.Ol\ gallery will allow tl11~ of dle ffOOlld 11pporm0&t W{\dt'O.t" and ,hould c:.qx,dltc du, gn,ate.st cailsction of mass at lhe facility.
Tho C(lfflJ)lnlca have satisfictorily IWWored Ille NCDEHNR quostlons on tho IDflltmtloD plloly J)Cl:lllit application 1111.d anticipate ftWlivlng i:he permit by mid-November. Once a pom.lt 1-issued, th8J'o would appear to be little purpose Iii conducting a £eCond pilot roat. The NCJ:>EHNR iJ aware of the upgradient TC8 and col!CUTS with the placement of the lnfl11ratlon gallpzy, ~ '
l'ba pilot t41t tmnch was constructed using a IQOtbcd buclcet OD a ba.cklloe. This method dilllnlbs · tile tzelleh wall and tef)licates c:onstruCJ!i)q of the acwa:I lnfillmtJon plleiy. The ac:wal pllmry wIU Ol1ly 1.1se the bottom two feet oftbo 15-foot ttench sido wall and the tnmch bottom for flow di8ttlbudoa. It is tbfflfore unclear what addltiollal swifialtlnn is rcqum,d or bow lbat will enli.anw tho ~• of anomer tm. .Depondl.og on th# spec.Ifie requirements, rho oo&t of the
7
11/021: 11:22 EPA REGION IV ~E MGT PROGR~S 011 ll/0Jr~4 o,;oi l'il O 41GU . OLIN-BI\G CD88 • ---op, ~004/000 · OCT 31 •94 1lil• 1$PM T PIV-INl'l'IFltTltl.iC-· ,
iequest.ed pilot tut could approximara that for cm111tn1cti.on of Ibo pllcJiy itsolf. A SOO(ffld pilot teat is not Justifim Wilm th~ entire system i:an be evaluated for an equivalent coat.
In accordance with tbo aoD, the Wll!Jlllitin gallery q,li.on should remam a dellp option pendiq easparlson or clbcharp requbelnsats with those of. th& POTW. .Howevar, the Companies are wl.lling to discuss EI'A and CDM's concems repJdina addltlonal te,tlq of Ille lnflltrat1ongaller)'.
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11:23 EPA REG I ON I~ ITE MGT PROGRAMS 015
11:08 . , EPR REG ION I U .TE MGT PROGRRMS .
UNITED STATE:S ENVIRONMENTAL F'ROTECTION AGENCY
REGION IV
4WD-NSRB
Mr. Garland E. Hilliard
Project Coordinator
Olin Corporation
P.O •. Bo>c 248
::34~ COIJ~TL.AND STREc;T, N.E:,
ATLANTA, clE0RC31A 30;365
October 26, 1994
002
1186 Lower River Road NW
Charleston, Tennessee 37310 VIA FACSIMILE ORIGINAL VlA MAIL
SUBJI .Notice of Disapproval Concerning The Preliminary Design
Report submitted by the PRPs~ The Geigy Chemical
Corporation Site, Aberdeen, North Carolina (the Site)
Dear Mr, Hilliard:
The purpose of this lette'r is to clear up any lingering
uncertainty that the Potentially Responsible Parties (PaPs) at
the Site mi~ht have about the position of the U,S, Environmental
Protection Agency (EPA) concerning the Preliminary Design Report
(PDR) submitted by the PRP_s and the resulting exchange of
comments and responses.
Based on our records, the PRPs submitted (in accordance with
Section VI, Paragraph 10 of the Consent Decree) a draft PDR to
EPA on June 6, 1994, On July 18, 1994, EPA sent the PRPs a set
of general and specific comments concerning the PDR; North
Carolina's comments were sent two days later on July 20, 1_994,
On July 28, 1994, EPA received a fax from the PRPs consisting of
the PRPs' responses to EPA's July 18, 1994 1 general comments, and
on August 30, 1994, the PRPs submitted to EPA a set of responses
to the remainder of tPA's July 18, 1994, comments in accordance
with Section VI; Paragraph 10 of the Consent Decree. The PRPs·
included with these latest responses a selection of replacement
pages to the PDR based on an understanding reached during an
earlier meeting, The August 30 1 1994, transmittal from the PRPs
included a request that EPA approve the PDR based on the
responses ·and the replacement pages, EPA did not approve the
PDR; instead, after reviewing the August 30, 1994, responses from
the PRPs and associated replacement pages, on October 7, 1994,
EPA transmitted to the PRPs a further set of comments provided by
EPA' s · oversight contractor that EPA had adopted as its. comments.·
This was followed~up shortly with an October 13 1 1994, letter
summarizing EPA's concerns. Among other things, .E:PA's letter of
October 13, 1994, called for a revised PDR addressing EPA's
concerns to be submitted to EPA by December 16, 1994. In
response, the PRPs requested a meeting with EPA on October 26,
1994, without the presence of our respective contractors, but the
date was unsuitable to EPA and the meeting did not take place.
11: 08 EPA REGION IV.STE MGT PROGRAMS 003
2
In summary, the information contained in the initial PDR
submitted by the PRPs on June 6, 1994, lacked the detail
necessary for EPA to determine if the extraction and treatment
system proposed in the PDR would be sufficient to contain,
remove, and remediate contaminated groundwater at the Site. To
ensure that the project would not get side-tracked, the parties
agreed at or following a August 2, 1994, meeting that delineation
of the downgradient groundwater plume would be accomplished under
another plan of work. Nevertheless, the subsequent revision of
the PDR that the PRPs submitted under the existing workplan,
while more detailed than the first, essentially remained too
incomplete for EPA to determine if the conceptual model as
presented in the PDR would accomplish the objectives of the
Record of Decision (ROD). As a consequence, EPA has been unable
to approve the docwnents submitted by the PRPs.
Therefore, please consider the version of the PDR as
submitted to EPA by the PRPs on June 6, 1994, and subsequently
modified by the revised pages submitted on August 30, 1994, (the
existing submittal) to be deemed by this letter disapproved by
EPA in accordance with section XII of the Consent Decree, with
the PRPa hereby directed to modify the existing submittal in a
manner consistent with the scope and extent of the comments
trnnsmitted by EPA_to the PRPs on July 18, 1994, October 7 1 1994 1 and .October 13, 19.94. The letter from EPA to the PRPs dated
October 13, 1994, provided for a revised report by
December 16, 1994; in accordance with Section XII of the Consent
Dec:1.Cee, the date of December 16, 1994, .shall remain the date by
which the PRPs must correct the deficiencies as above-noted and
resubmit the PDR to EPA, EPA recognizes that a modification of
the schedule of subsequent deliverables is a logical consequence
of a December 16, 1994, deadline for the PDR, a·n:d ·i-s· oi:ien ·to a
discussion concerning necessary changes to the schedule that the
PRPa. -might reasonably propose. ·
Please contact me at [phone] x-4118 if you have any
questions concerning the substance of the modifications EPA has
directed the PRPs to undertake, or to set up a meeting to discuss
the impact on the work plan's schedule from.the December 16,
1994, deadline for submittal of a PDR acceptable to EPA.
cc, Gregory o. Luetscher, ORC
Curt Fehn, 4WD/NSRB
Winston Smith, GWTSU
_ s . Fores
Remedial Project Manager
1.
2.
3.
4.
Comment
RESPONSE TO NCDEHNR COMMENTS
DATED JULY 20, 1994 ON THE
DRAFT PRELIMINARY DESIGN REPORT
GEIGY CHEMICAL CORPORATION SITE
The second sentence of the second paragraph on page 2-7 indicates that well MW-
llD is screened in the upper 3 of the aquifer, ... Please indicate the units of this
interval.
Response
The uni!, of the interval are feet. The sentence should read, "Water levels in MW-
llD, screened in the upper 3 feet of the aquifer, are approximately 0.34 feet to 1.0
feet higher.than water levels in OW-lD, OW-2D, and WP-lD, screened in the
bottom 10 feet of the aquifer (see Appendix 2.6)."
Comment
The surface soil samples are not'located. on Figure 2-16 as noted on Page 2-12.
Response
The reference in the text to the location of the surface soil samples on Figure 2-16
in the PDR was incorrect. The locations of surface soil samples SSR-1 through SSR,
26. are shown on drawing 86619-PP-02 in the PDR.
Comment
The gray area of cross section B-B, shown on Figure 2-4, is the saturated zone not
the unsaturated zone as indicated in the legend. ·
Response
The legend shown on Figure 2-4 in the PDR will be re,vised to indicate the gray
shading on cross-section B-B' represents the saturated zone. ·
Comment
The Trichloroethene (TCE) plume as shown on Figure 2-15 should be treated
upgradient of the Geigy site, preferably at the source. Section 5.6 on page 5-8 states
"TCE in the second uppermost aquifer is not related to the Geigy Site .. " and
"Delineation or control of the upgradient TCE will therefore not be addressed as
part of the Geigy. Site Remedial Design." Section 5.6 also indicates that the
groundwater extraction system proposed for the Geigy site will accelerate TCE
migration toward the site resulting in increased concentrations of TCE over time.
August 30, 1994
1
•
A5 indicated in this report, addressing the migration of TCE in the second uppermost
aquifer is critical for the effectiveness of the carbon filter treatment remedy.
Therefore, it is recommended that a joint effort by EPA and the State be accelerated
at the Crestline Contaminated Wells site (NCD 986 172 492) located upgradient of
the Geigy site. The state plans to initiate a Preliminary Assessment (PA) at the
Crestline Contaminated Wells site in the near future.
The State supports recharging the treated groundwater to the second uppermost
aquifer developing a hydraulic barrier which would deflect groundwater flow
upgradient of the infiltration gallery around the capture zone of the extraction well. However, modeling must be performed to assure that mounding of the groundwater
in the area of the injection well does not redirect the regional recharge groundwater
flow direction so that other aquifers are contaminated. The non-discharge permit
requirements must also be satisfied for the injection well to the second uppermost aquifer. ·
Specifically non-discharge permit requirements will require that treated groundwater,
recharged to an infiltration gallery or to the aquifer, meet the NC Groundwater
Standards. Therefore, analytical testing for TCE must be performed for verification
purposes prior to recharging treated groundwater to the system .. It may become
necessary to include an air stripper as part of the remedy in order to achieve
acceptable TCE concentrations. In addition,. it must be demonstrated that all the
injected water is recaptured by the extraction well.
Response
The Companies support efforts by the EPA and the State to address the upgradient
source and downgradient migration of TCE in the second uppermost aquifer. The • Companies request that they be kept informed of agency efforts to characterize and control the upgradient source of TCE. TCE concentrations will be measured in the upgradient monitoring wells and evaluated for potential impacts on the treatment
system.
Infiltration of treated groundwater to the second uppermost aquifer as modeled will
create a hydraulic barrier which will deflect groundwater flow upgradient of the
infiltration gallery around the release zone of the infiltration gallery and the capture
zone of the extraction well (PW-20). Modeling of infiltration of treated water into the second uppermost aquifer has been conducted to assure that infiltration does not
alter regional groundwater flow directions so that other aquifers are contaminated.
Figure 1, attached, presents the simulated drawdown and recharge levels resulting
from pumping and infiltration rates of 13 gpm and 20 gpm, respectively, which are
the maximum design flow rates for the system. Mounding of the second uppermost
water table resulting from infiltration of 20 gpm and pumping of 13 gpm is estimated
to be approximately 4 feet.
August 30, 1994
2
• •
Measured and simulated (i.e.,. modeled) water level elevations in the second
uppermost aquifer under ambient conditions (no extraction or infiltration) are shown
in Figure 2 ( attached). As shown in this figure, simulated water levels are in·
excellent agreement with the measured water levels (within approximately 0.5 feet),
and the direction of groundwater flow in the second uppermost aquifer is from the
east-southeast to the west-northwest.
To evaluate the influence of infiltration on flow directions within the second
uppermost aquifer, the flowpaths of groundwater particles originating upgradient of
the infiltration gallery were simulated in the model under maximum design pumping
and infiltration flow rates (i.e., 13 gpm and 20 gpm, respectively). Figure 3, attached,
shows the simulated groundwater particle flowpaths, and the known area of the
second uppermost aquifer exceeding the site performance standard for TCE. The
known width of the TCE plume is approximately 700 feet, and .the actual width of
the TCE plume extends over, a larger area than is currently defined .. The lateral
deflection of groundwater particles as a result of infiltration occurs within a limited
portion of the aquifer (width of approximately 1700 feet). Particles that are deflected
resume ambient pathways of flow downgradient of extraction well PW-2D due to
drawdown occurring by pumping of the well, thus resulting in minimal disturbance
of groundwater flow directions and minimal dispersion of the TCE. Based on these
considerations, the disturbance of natural groundwater flow patterns will be minimal
and limited to the near vicinity of the infiitration gallery (within 1700 feet). Thus,
the potential for infiltration to contaminate other portions of the second uppermost
aquifer by inducing dispersion along the width of the TCE plume, which is currently
undefined, is not considered to be significant.
The uppermost aquifer and the third uppermost aquifer are present in the vicinity
of the facility property. Based on results of the pre-design field investigations, the
uppermost aquifer is not present at direct push technology (DPT) boring P-7, which
is in the immediate vicinity of the infiltration gallery. In addition, the uppermost
aquifer is not present at DPT boring P-8, approximately 140 feet north of the
infiltration gallery, or in the MW-11 D area, approximately 280 feet northwest of the
infiltration gallery. Because the system design basis for the infiltration gallery is two
feet of head, lateral migration of infiltrated water due to hydraulic loading in the
trench will be minimal. Based on these considerations, placing the infiltration gallery
in the vicinity of P-7 will not have an impact on the uppermost aquifer.
The second uppermost clay lies between the second uppermost aquifer and the third
uppermost aquifer. Based on results of the remedial investigation, pre-design field
investigations, and regional studies, the second uppermost clay is laterally continuous
and present throughout the region near the facility property. Based on stratigraphic
data collected within and surrounding the facility property, the thickness of the
second uppermost clay is approximately 10 to 13 feet. Thus, the presence and
August 30, 1994
3
• •
thickness of the clay will prevent the flow of groundwater from the second uppermost
aquifer to the third uppermost aquifer in response to vertical gradients induced by
infiltration, and infiltration will not have an impact on the third uppermost aquifer.
'
The non-discharge permit application for the proposed infiltration gallery will be
submitted to the North Carolina Department of Environment, Health, and Natural
Resources (NCDEHNR) in late August. The treated groundwater recharged to the
infiltration gallery will meet the NC groundwater (2L) standards. Analytical testing
for TCE will be performed for verification purposes prior to recharging treated
groundwater to the system. Based on projected influent concentrations of TCE,
activated carbon adsorption will efficiently remove TCE and pesticides to below
detection limits. Conservative estimates of carbon usage rates are low, and the use
of an air stripper to increase removal efficiencies is not anticipated, Recapture of
infiltrated water by the extraction well will be addressed in the permit submittal.
5. Comment
6.
7.
The Erosion Control Plan is briefly addressed on page 3-3 and includes the contents
required for submittal. Fifty feet of construction access roadways with 6 inches of
crushed stone should be included in the erosion control plan submitted to the
· Regional Land Quality Section. A construction wash rack may also be required in
the graveled access roadway. These may be included under the crushed stone paving
design specification 0223.
Response
Acknowledged. In the scope of work defined for the Remedial Action contractor,
fifty feet of construction access road with 6 inches of crushed stone will be included.
These additional requirements and the paving design specification will be provided
in the 1/PDR.
Comment
Note (2) for Table 3-2 should read contract required quantitation limit.
Response
The misspelled word "contact" referenced in Table 3-2 will be changed to "contract".
Comment
The performance standards verification plan as noted in Section 8.5 indicates that the
excavation standards apply to a soil depth of 1 foot. The Record of Decision (ROD)
signed by EPA on August 27, 1992 states on page 8-7 that "Confirmation sampling
would be conducted to ensure that remediation levels are attained. Excavated areas
would then be covered with clean fill and vegetated with a perennial grass."
Confirmation sampling must be performed in all excavated areas regardless of depth
and excavation \performance standards listed in Table 1-1 apply to all soils at any
August 30, 1994
4
•
depth at the. site. The State contends that additional excavation would be required
below 1 foot or to whatever depth is required whenever the performance standards
are exceeded during confirmation sampling.
It is critical to understand that even though the performance standards are based on
potential health risk via dermal contact, the performance standards were checked
through computer modeling to verify that they are protective of groundwater. The
performance standards established for dermal contact are border-line for protection ·
of groundwater.
Vadose zone (VIP) modeling results corresponding to these established soil clean-up
standards and documented in Appendix C of the Feasibility Study, dated March 1992,
indicate leachate concentrations of 0.03 ug/1 for gamma-BHC and 1.6 ug/1 for
toxaphene. The NC Groundwater Standard for gamma-BHC is 0.02 ug/1 and 1 ug/1
for toxaphene.
The Performance Standards for soils listed in Table 1-1 include 13 pesticides which
range from .113 mg/kg to 7.6 mg/kg and average 2.35 mg/kg.• These performance
standards are slightly high as compared to other pesticide sites in North Carolina.
1 mg/kg is generally accepted as the background concentration for pesticides in NC
and has been used as the performance standard at other pesticide sites.
These performance standards establish the concentration of each contaminant which
is allowed to remain in the soil after the Site is cleaned-up. For the Performance
Standards to be protective of groundwater, the leachate model results noted above
must be less than the NC Groundwater Standards. As noted above the modeled
leachate concentrations for the Site are border-line to the NC Groundwater
Standards.
Therefore, it is critical that all soils at the site which exceed the performance
standards be excavated and removed from the site as determined by verification
sampling in the excavation areas as documented in the ROD. This procedure must
be included in the Performance Standards Verification Plan.
The ROD states soil will be excavated to a depth of one foot and the State of North
Carolina concurred with this.· This depth was chosen because the Site Performance
Standards are based on protectiory of human health through incidental contact. This
exposure pathway, and resulting rem_ediation levels, only apply to a dep!h of one foot.
Lateral confirmation sampling will be conducted at the Site to ensure that these
excavation Performance Standards have been attained.
August 30, 1994
5
V •
The VIP modeling conducted during the Feasibility Study and approved by EPA's
Groundwater Division and Environmental Services Division showed that even using
conservative assumptions there would be minimal impact to Site groundwater. The
maximum predicted gamma-BHC-concentration in groundwater is 0.02 ug/1, which
is below the North Carolina 2L groundwater standard (0.2 ug/1) · and the ROD
groundwater Performance Standard (0.05 ug/1). The maximum predicted toxaphene
concentration in groundwater is 1.3 ug/1, which is equivalent to the referenced North
Carolina groundwater standard of 1 ug/1. However, this toxaphene concentration
is below the Federal MCL (3 ug/1) and the North Carolina Drinking Water Standard
(3 ug/1). ·
Soils at depths greater than one foot are not governed by health-based remediation
levels. Remediation requirements for soils at depths greater than one foot are based
on the potential to impact groundwater.
The comment notes that the leachate concentration_s generated by the modeling are
"border-line" with comparison to State standards for groundwater. The pesticide
groundwater concentrations, not the leachate concentrations, should be compared to
~ the State standards. Present concentrations of pesticides in soils are approximately
S 1 \•Jft 90 percent below pre-removal concentrations. The modeling assumed that no Site 1 "I · soils were to be excavated. The PDR provides for the excavation of approximately
1,900 cubic yards of soil. 'The resulting reduction in the mass of pesticides at the Site
will decrease the predicted groundwater concentrations and provide another measure
of conservatism to the modeling. Site conditions will therefore be even more
protective of groundwater than currently indicated.
The Performance Standards for soils listed in Table 1-1 of the PDR were developed
by EPA during the risk assessment and are based on site-specific conditions,
toxicological data, and regulatory guidance.
As described in the ROD (see Declaration for the Record of Decision, and page 10-
5), the Performance Standards for soils establish a concentration at which surficial
soils will be excavated to a depth of one foot. Lateral confirmation sampling will be
conducted at the Site to ensure that these excavation Performance Standards have
been attained.
The Companies understand and appreciate· North Carolina's concerns regarding
potential impacts to the State's groundwater.· However, the Companies have
documented conservative estimates of pesticide transportthat show any impacts will
be insignificant.
August 30, 1994
6
• •
NO FLOW BOUNDARY
LEGEND
D
•
KNOWN AREA OF SECOND UPPERMOST
AQUIFER EXCEEDING SITE
PERFORMANCE STANDARDS FOR
PESTICIDES
CONSTANT HEAD NODE
-0.5-SIMULATED DRAWDOWNIRECHARGE CONTOUR
(FT.)
PW-2D
INFILTRATION
GALLERY
. OF INTEREST
0 ·o
NO FLOW BOUND
0 567
~;;]
SCALE IN FEET
... IW9I ENVIRONMENT & l~U>I INFRASTRUCTURE
FIGURE1
DRAWDOWN DISTRIBUTION
· SECOND UPPERMOST AQUIFER-
PUMPING AND RELEASE CONDITIONS
(13 GPM AND 20 GPM, RESPECTIVELY)
Geigy Chemical Corporation Site
Aberdeen, North Carolina
LEGEND
-----391
• •
WATER LEVEL CONTOUR BASED ON FEB. 22, 1994
DATA (FT. MSL)
-----390 SIMULATED WATER LEVEL CONTOUR (FT. MSL)
c.,
ID ....
•
c., c., c.,
ID ID ID 0 .... II,)
0
c.,
ID
,I>,
c.,
ID en
567
SCALE IN FEET
c.,
ID
0,
c.,
ID
~
RIKT ENVIRONlv1ENT &
INFRASTRUCTURE
FIGURE 2
SIMULATED STEADY-STATE
HYDRAULIC HEADS-NON-PUMPING
CONDITIONS SECOND UPPERMOST
AQUIFER
Geigy ChemicaJ Corporation Site
Aberdeell, North Carolina
r~---,-------,.--------~---------------:-------""'.------------"'·-==---~~---------·----:-"".""."'.'.""""..:.... _____________ ..:..:; ---• •
LEGEND
I
?
KNOWN AREA OF SECOND
UPPERMOST AQUIFER EXCEEDING
NORTH CAROLINA GROUNDWATER
STANDARD FOR TCE
LATERAL EXTENT OF TCE·UNDEFINED
KNOWN AREA OF SECOND
UPPERMOST AQUIFER EXCEEDING
SITE PERFORMANCE STANDARDS
FOR PESTICIDES SCl,LE IN FEET
~~~--·
ROUNOWATER
FLOW .
INFILTRATION
GALLERY
I'll...._. ENVIRONMENT &
l~U:> I INFRASTRUCTURE
FIGURE 3
SIMULATED GROUNDWATER PATHLINES
UNDER STEADY STATE CAPTURE (13
GPM) AND RELEASE (20 GPM)
CONDITIONS, SECOND UPPERMOST
AQUIFER
Geigy Chemical Corporation Site
Aberdeen, North Carolina
• • GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, N.C.
November 30, 1992
Gregory D. Luetscher
Assistant Regional Counsel, Region IV
Waste Management Division U. S. Environmental Protection Agency
345 Courtland Street
Atlanta, GA 30365
I RE: Geigy Chemical Corporation Site
Aberdeen, Moore Co., NC
"Special Notice Letter" dated October 8, 1992,
received October 13, 1992.
Otar Mr. Luetscher:
WfGl:IVtU
DEC 1 7 1992
SUPERRIND SECTION
This letter is to formally notify the USEPA and the State of North
chrolina of the willingness of Olin Corporation, CIBA-GEIGY
cbrporation and Kaiser Aluminum & Chemical Corporation (the
Cpmpanies) to conduct the Remedial Design/Remedial Action (RD/RA) at
the Geigy Site consistent with the Record of Decision (ROD), subject
tb parties being able to negotiate an acceptable Consent
I Decree/Statement of Work (CD/SOW).
Ak you know, the Companies have satisfactorily completed the
Remedial Investigation/Feasibility Study (RI/FS) at the site along
with several interim removal actions. The Companies wish to
continue this effort through the final remediation, contingent, of
course, on an acceptable settlement agreement. This offer does not
constitute an admission of liability for conditions at the Geigy
Chemical Corporation Site or acceptance of EPA's characterization of
conditions at the site.
TJe Com~anies are willing and prepared to negotiate in good faith
the terms and conditions of an acceptable CD/SOW. A paragraph by
paragraph response to the terms of the draft CD/SOW will be provided
t9 the USEPA on or.,.before December 14, 1992 (60-days from receipt of
"Special Notice"). Suggested language provided for both documents
is preliminary and the companies reserve their right to add, delete, 01 modify any provision of these documents as negotiations progress.
The Companies have had experience at Superfund sites throughout the
co'untry and in this instance will supervise RD/RA work with actual
de1sign and construction performed by consul tan ts and contractors.
SE1C-Donohue, Inc. of Greenville, South Carolina has been selected as
ou\: RD consultant (licensed professional engineer).
, • • The Companies' annual reports for 1991 are enclosed which provide a more detailed analyses of the Companies financial condition and ability to finance the $4.7 million remedy as described in the ROD. The Companies are prepared to reimburse EPA for appropriate oversight costs for the RD/RA providing that EPA will provide sufficient documentation of expenses. Throughout the RI/FS, USEPA has provided such documentation and we expect that such arrangements can continue.
~he Companies' primary contact through the negotiation period will be Ms. Lorraine M. Miller, P.O. Box 248, 1186 Lower River Rd., NW, Fharleston, TN 37310. Additional other representatives (the Companies and/or PRPs) will participate in various aspects of the negotiations.
I The Companies believe that the majority of the appropriate cleanup work at the site has been completed (through the interim removal actions) and we look forward to the completion of the remaining 'ilork, and to placing the site in the "remediation completed" column. I Should you have any questions regarding this letter, please don't hesitate to contact Lorraine Miller at 615/336-4381.
Sincerely yours,
OLIN CORPORATION
.-_, .4 .' <'/~ -----/' /,,/ / ,,,,i'. -,11 BY: L ·, U/ -/ it.A £-k
NAME: C. W. Newton
TITLE: Vice President -
Environmental Health and
Toxicology
::~~~ra4f
NAME: Doug J~effei
TITLE: Director of Environmental Protection
& CHEMICAL CORPORATION
N Jo eph A. Bonn
TITLE: Vice President
• Enclosure
I cc: Giezelle S. Bennett
I Joseph R. Franzmathes
Jack Butler -NCDEHNR
I /cat/442
.•.
•
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E. o
ATLANTA. GEORGIA 30365
!CT 1 -1 1992
4W-NSRB
I Mr. William Meyer, Director
Solid Waste Management Section
North Carolina Department Environmental
f Natural Resources
P.O. Box 2091
Raleigh, North Carolina 27603
I
..........
Health and
RE: Notification of Negotiations
Action
for Remedial Design/ Remedial
Geigy Chemical Corporation Superfund Site
Aberdeen, North Carolina
Dear Mr. Meyer: I The United States Environmental Protection Agency (EPA) has
documented the release of hazardous substances, pollutants or
contaminants · at the Geigy Superfund Site. Release ( s) were
indicated by the results of the Remedial Investigation completed in
March 1992. On August 27, 1992, a Record of Decision (ROD) for the
site was signed at EPA Region IV in Atlanta. The ROD documents
EPA's selection of a remedy for cleaning up environmental
bontamination of soil and groundwater at the site.
-I -
Section 121(f)(l)(f) of the Comprehensive Environmental Response,
'compensation and Liability Act of 1980 (CERCLA), as amended by the 1Superfund Amendments and Reauthorization Act of 1986 (SARA),
!requires EPA to notify the State of anticipated negotiations with
'the potentially responsible parties to voluntarily conduct the
Remedial Design/Remedial Action. This letter represents that
notification.
In addition, we wish to afford you an opportunity to participate in
the forthcoming negotiations and, subject to certain restriction,
be a party to any settlement.. However, please note that Congress
has mandated certain limited time frames under Section 122(e) of
SARA for negotiations with potentially responsible parties.
Therefore, it important that your Agency contact EPA as soon as
possible should you wish to participate in the negotiations.
Please contact Giezelle Bennett, the Remedial Project Manager for
Printed on Recycled Paper
• •
the site, at 404/347-7791, or Mr. Gregory Luetscher, Assistant
Regional Counsel, at 404/347-2641 extension 2275. This will
provide EPA with the maximum benefit of your expertise and unique
I • perspective.
I Thank you for your cooperation and support. Srt:y,
R6bert Jour n, Chief
Nprth Superfund Remedial Branch
:i::teJ:::a:::::: Division
Superfund Section
• •
·Rf.Gt\"EO
· J \.frl O 1 199'2.
EVALUATION OF TWO ADDITIONAL
SOIL REMEDIAL ALTERNATIVES
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION IV
ATLANTA, GEORGIA
MAY 1992
su~ERfO~D SE.C1ION
r. /' • •
INTRODUCTION
I The Feasibility Study for the Geigy Site evaluated three soil remediation alternatives: 1) No Action; 2) Off-Site Disposal; and 3) Capping. The purpose of this document is to evaluate two additional soil remediation alternatives; on-site thermal desorption and on-site incineration. These alternatives will be evaluated using the nine evaluation criteria: protection of human health and the environment; compliance with ARARs; long-term effectiveness and permanence; reduction of toxicity, mobility and volume; short-term effectiveness; implementability; cost; state acceptance; and community acceptance.
I State and community acceptance will be addressed after the public comment period ends.
I ADDITIONAL SOIL REMEDIATION ALTERNATIVES
I Alternative 4: On-Site Thermal Desorption
I in this alternative, soils exceeding the remediation levels would be excavated and treated utilizing low temperature thermal ~echnology. Treatment wou-ld consist of volatilizing the organic contaminants at a temperature generally less than 1000 degrees F with the off-gases being captured and treated to prevent the !release of contaminants. Treatment of the soils would continue until remediation levels are attained and the soil can pass the ' rCLP test for toxaphene and gamma-BHC (lindane). Demolition and disposal of the building foundation would be required to gain 1access to underlying soils.
JOff-gas treatment varies depending on the vendor, but usually 1consists of: 1) thermal oxidation in a secondary thermal oxidation chamber similar to incinerators; 2) condensing and concentrating the organics into a significantly smaller mass for further treatment (incineration); or 3) passing the off-gases through activated carbon to adsorb in the contaminants and then regenerating the carbon. Treated soils would be returned back into the excavated areas.
Protection of Human Health and Environment
The ultimate fate of the organic contaminants is thermal destruction. The place where the destruction takes place varies depending on the system. Final destruction can occur at a RCRA facility, on-site, or at a carbon regeneration facility. Because the organic contaminants are separated from the soil, there should be very little, if any, organic ash residue remaining after final destruction. Treated soils must pass RCRA hazardous characteristic
2
• • testing for lindane and toxaphene and meet the State requirements for disposal of solid wastes. Thus, implementation of this alternative would provide sufficient protection to human health and the environment.
I Compliance with ARARs
I Low temperature thermal desorption/separation technology is not considered to be the same as incineration, thus incinerator regulations (Subpart O, 40 CFR 264) are not applicable. However, the regulations may be deemed relevant and appropriate. All exhaust emissions must meet Clean Air Act requirements. The treated soil must pass the TCLP test and meet State requirements prior to on-site non-RCRA disposal.
I . Long-term Effectiveness and Permanence
I This alternative provides long-term effectiveness and permanence by thermally destroying the organic contaminants. Site risks would be permanently reduced.
I Reduction of Toxicity, Mobility, or Volume
I Thermal desorption of the organic contaminants will reduce the toxicity and volume of the contaminated soil. Because the soil must pass the TCLP test for toxaphene and lindane, mobility of the contaminants will be reduced as well. Implementation of this alternative meets the intent of the NCP to use treatment alternatives to reduce the long-term management of hazardous
\astes.
Short-term Effectiveness
during the implementation of this alternative, truck traffic, ~xhaust, noise, and fugitive dust will increase during the e'xcavation and treatment of the contaminated material. Additionally, organic vapors may be released as soil is excavated. ~11 of these effects will have a negative short-term impact on surrounding human health and the environment. This impact can be m1inimized by utilizing dust and vapor prevention controls. Noise tinpacts on surrounding neighbors can be reduced by limiting the operating hours of the thermal desorption unit.
O~-site workers will be exposed to contaminated material, fugitive dust, and volatile organic vapors. This exposure can be minimized by utilizing the proper level of protection. If dusty conditions Pfevail, proper control measures will be implemented. Vapor control measures, such as foam, may be required if air monitoring
3
I • • indicates that volatile organic vapors are being released.
I Since the estimated volume of soil to be treated is considered low '( less than 10,000 cubic yards), the treatment unit utilized would probably be small; on the magnitude of a pilot-scale operation. Assuming a process rate of 2.5 tons per hour, the estimated time required to complete the soil remediation is approximately two ~onths. Operation of the unit less than 24 hours per day would increase the remediation time.
I Implementability
I This alternative should not be difficult to implement, however, the number of vendors with systems capable of treating organochlorinated pesticide contaminants may be limited. Most of ihe vendors treat only volatile organics and hydrocarbon related wastes. Another limiting factor is the number of vendors with small units who would be willing to mobilize to the site for less than 10,000 cubic yards.
I The site has been the subject of two removals; therefore, space on ~he site is sufficient to support excavation, stockpiling, decontamination, etc. that would be involved in a removal. Space requirements for a thermal unit range from 50' x 50' for a pilot-s'cale unit to 100' x 200' for some full-scale models. Obviously, lith a one-acre site, the size of the unit will have to be small.
Cost -1-
The cost
i 1ncludes
s:100, ooo
of this alternative
an estimate of $200
mobilization costs.
is estimated to be $1,200,000. This
per ton for thermal processing, with
Aiternative 5: On-Site Incineration
Ihcineration is a thermal treatment technology which utilizes eievated temperatures to destroy or detoxify hazardous waste. Under this alternative, contaminated soil and debris would be incinerated on-site. Residual ash from the incinerator would be redeposited on-site and covered with clean fill. The ash would have to pass the TCLP for toxaphene and lindane before depositing to ensure that the ash is non-hazardous.
IAcineration is considered the Best Demonstrated Available Technology (BDAT) for halogenated organic compounds, which includes most of the pesticides found at the Site. The contaminated soil w~ll be excavated, homogenized and sized, incinerated, tested, and disposed back on-site. Any process wastewater or scrubber blowdown
4
• • sludge will be treated by reinjection into the incinerator.
The incinerator and air pollution control unit will be operated so
that:
An operating temperature in the kiln of 1,800 degrees Fis
maintained at all times to ensure· that any volatile and semi-
volatile organic constituents in the waste stream are driven
out of the ash and that the fixed carbon remaining in the ash
is minimized;
An operating temperature in the afterburner of 2,000 degrees
F is maintained at all times to oxidize and destroy all
remaining organic substances prior to exiting the afterburner
and entering the pollution control system;
The incinerator must achieve a destruction and removal
efficiency (DRE) of 99.99% for all designated principal
organic hazardous constituents (POHC); and
The air pollution control system will achieve performance
standards of 1) hydrogen chloride of less than 4 lb/hr and 2)
particulate matter of less than 0.08 grains per day ft3 in the
exhaust gas corrected oxygen content.
Protection of Human Health and the Environment
This alternative thermally destroys the organic contaminants in the
soil. The 1:esul ting ash will be verified as non-hazardous via RCRA
testing, and then it will be backfilled into the excavated area of
the site. The incineration operation must have a destruction and
removal efficiency of 99.99%. Therefore, implementation of this
alternative would provide sufficient protection to human health and
the environment .
. Compliance with ARARs
I
1The on-site incinerator must comply with all RCRA regulations for
1
thermal destruction of hazardous wastes. The remaining ash must
,pass RCRA characteristic testing and State requirements prior to
rn-site disposal.
,Long-term Effectiveness and Permanence
I
1This alternative provides long-term effectiveness and permanence by
thermally destroying all organic contaminants.
5
• • Reduction of Toxicity, Mobility, and Volume I . Thermal destruction of the organic contaminants will reduce the toxicity and volume of the treated material. Because it must pass RCRA characteristic testing prior to on-site disposal, further contamination from the ash is unlikely. Implementation of this alternative meets the intent of the NCP to use treatment alternatives to reduce the long-term management of hazardous wastes.
I Short-term Effectiveness
I During the implementation of this alternative, truck traffic, noise, exhaust, and fugitive dust will increase during the excavation and treatment of the contaminated material. All of these effects will have a negative short-term impact on the surrounding human health and the environment. This impact can be ~inimized by utilizing dust and vapor prevention controls.
I On-site workers will be exposed to contaminated material, fugitive dust, and volatile organic vapors. This exposure can be minimized by utilizing the proper level of protection. If dusty conditions prevail, proper control measures will be implemented. Vapor control measures, such as foam, may be required if air monitoring indicates that volatile organic vapors are being released.
I The incineration process must meet or exceed the 99.99 percent DRE as required under Subpart o, CFR 264. Air emissions can not exceed 4 pounds per hour of hydrogen chloride and 0.08 grains of particulate matter per dry cubic foot of exhaust corrected to 7 percent oxygen content.
I The estimated time required to complete the soil remediation is approximately 2 months. This estimate assumes that one unit can process 5 tons of contaminated material per hour and operates 12 hours a day.
I . Implementability
I Implementation of this alternative is dependant upon the availability of a mobile incineration unit, and dependant upon a vendor willing to mobilize to the site for less than the customary 10,000 cubic yards.
I Size of incineration units vary, but may require an area up to 300' x 150'. If a smaller unit is not available and space becomes a ~oncern, adjacent property may be needed to accommodate the unit. 1his may or may not be considered "off-site" since groundwater contamination contributable to the site exists south of the ' . property boundary. If the unit is located "off-site", permitting
6
• • requirements may be a hindrance to completing this alternative in a'. timely manner.
I Cost -1-
The cost of this alternative is estimated to be approximately $3.1
million dollars. This assumes an incineration cost of $600 per
ion, with mobilization costs of $300,000.
7
• •
ON-SITE THERMAL DESORPTION OF CONTAMINATED SOILS ' CALCULATED SOIL VOLUME -2200 CUBIC YARDS ' ASSUMED SOIL DENSITY -1.3 TONS/CUBIC YARD
I
Capital rosts -Excavation and Thermal Desorption
Unit Total
ITEM Quantity
I Work Plan 1
Waste Sarilpling 1
Waste Anklysis -TCLP 3 '
Unite Costa ( s ) Costs ( s)
LS 20,000 20,000
LS 3,500 3,500
EACH 1,500 4,500
Equipment Decon 1 ' Mobilization/Demob 1
Excavatibn 2200 '
LS 2,000 2,000
LS 100,000 100,000
CY so 110,000
Thermal Desorption 2860
I TON 200 572,000
TOTAL EXCAVATION AND TREATMENT CAPITAL COSTS 812,000
FACTORED COSTS
Health and Safety 3% of capital costs 24,360 I Bonds, Insurance 2% of capital costs 16,240 Contingency 20% of capital costs 162,400
Engrl. / Constr. Mgmt. 15% of capital costs 121,800
TOTAL FACTORED COSTS 324,800
I FOUNDATION DEBRIS DISPOSAL AT MUNICIPAL LANDFILL 84,980
TOTAL PRESENT WORTH COSTS s1.221.1ao
•
DETAILED COST ESTIMATE
ALTERNATIVE 5
Capital Costs -Excavation and Incineration
I ITEM Quantity Units
I Work Plan 1 LS
Waste Sainpling 1 LS I Waste Anfilysis -TCLP 4 EACH
Equipmen~ Decon 1 LS
Mobilization/Demob 1 LS
Excavatibn 2200 CY ' Incineration ' 2860 TON
Clean FiH
I
1100 CY
TOTAL EXCAVATION AND TREATMENT CAPITAL COSTS
FACTORED COSTS
Health and Safety 3% of capital costs I capital Bonde, Insurance 2% of costs ' Contingency 20% of capital costs
Engrl. /constr. Mgmt. 15% of capital costs
I TOTAL FACTORED COSTS
I FOUNDATION DEBRIS DISPOSAL AT MUNICIPAL LANDFILL
TOTAL PRESENT WORTH COSTS
•
Unit Total
Coste ( S l · Coats ( S l
20,000 20,000
3,500 3,500
1,500 6,000
2,000 2,000
300,000 300,000
so 110,000
600 1,716,000
15 16,500
2,174,000
65,220
43,480
434,800
326,100
869,600
84,980
$3,128,580
• e
RECORD OF COMMUNICATION
DATE:
I FROM:
I TO:
March 16, 1992
Giezelle Bennett, EPA Region IV
Dan Schleck
Chemical Waste Management
Oak Brook, IL
SUBJECT: Thermal Desorption
I told Mr. Schleck that we had a site that we were interested in
using thermal desorption to handle pesticide contamination.
Estimated quantity of soil approximately 1000 cubic yards. He
stated that while they require a lot more soil to mobilize their
full scale unit, 1000 cubic yards sounded ideal for their pilot
sdale unit. They could process the soil for approximately $200/ton
w:Uth $100,000 mobilization costs. The cost per ton included
d:Usposing of the concentrated waste material.
Ij a follow-up conversation with Mr. Schlec.k on April 23, 1992, I
asked about the spacial requirements for the pilot scale thermal
de1sorption unit. He stated that the unit would require I • approximately 50'x 50'.
DATE:
I FROM:
TO:
• •
RECORD OF COMMUNICATION
April 23, 1992
Bill Brinker, Terradyne
Sanford, NC
919-774-3478
Giezelle S. Bennett, EPA Region IV
MF· Brinker called to discuss thermal desorption at the Geigy Site.
He thought that the soil volume (approximately 2200 cubic feet) was
ehough to justify mobilization. Their company is located less than
ore hour away, which means their mobilization costs could be kept
a:t a minimum. His company was really interested in the bigger
Aberdeen Site, but he thought they could also handle the Geigy
Site. Their unit would need an area of approximately 100'x 100'.
I\faxed him a copy of the Geigy propose; plan and gave him the PRPs
contact's telephone number.