NCD981927502_19960814_Geigy Chemical Corporation_FRBCERLA RI FS_Remedial Investigation 1991 - 1996-OCR

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•
State of North cctlnna· ·· · · · Department of Ehvironment, Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
Mr. Sammy Fields
Environmental Health Supervisor
Moore County Health Department
Post Office Box 279
Carthage, North Carolina 28327
RE: Site Visits
Geigy Chemical, NCD98 l927502
::AVA
DEHNR
August 14, 1996
Aberdeen Pesticide Dumps, NCD980843346
Dear Mr. Fields:
David Lilley of the NC Superfund Section spoke with Ms. Barbra Brady of your office today to notify you that the NC Superfund Section will conduct site inspections of the subject sites located in Moore County, North Carolina. The inspections will be conducted from August 26 through December 20, 1996 by Randy McElveen of the NC Superfund Section .
The purpose of the inspections is to collect confirmatory surface soil samples in excavation areas. You may want to have your representative meet the inspection team at the sites. If so, please contact Randy McElveen at (919) 733-280 I, ext. 341 and he will coordinate a meeting.
If the inspection team indicates the need for future study of the sites, we will contact your office to advise. If you have any questions, please don't hesitate to call David Lilley or me at (9 I 9) 733-280 I.
cc: Phil Prete
Doug Holyfield
Pat Williamson
•Scott-Ros~
David Lilley
Donna Keith
P.O. Box 27687,
Raleigh, North Carolina 27611-7687
Voice 919-733-4996
Sincerely,
~JJ~l
G over Nicholson, HeaJ '--
ederal Remediation Branch
NC Superfund Section
~uc-.e~ tel
FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/10% post-consumer paper
• NPL/DOD •
Trip Notification & Authorization
Today's Date: ;g-/ 2 · '1 0
TO BE COMPLETED BY PROJECT TEAM LEADER (INK ONLY)
Date of Trip: f-2.&
If trip changed or cancelled note below:
Trip Date Changed To: Cancelled:
.qr I '12.7 5"o2 -G-"'--•H_____ -----/, Q
NCD#: 4 'i\ 0 8' 4 3 3 4 (p M,.,.J,.,~ite Name: 6--e I !r'-/ d."2.v1,c\ ,/4..( //t ~-'Y71 ~~1,1
(If none, State ID) f / ? ~1,rcl&....,_ .D<Jw ).S
City: Ab~;y--c~ -€5:+>. V\ County:_cc..M&&'c=·'-'-_,_f _____ _
Name of Hotel (Overnight Trip): -------------------
Hotel Telephone Number: ( ) ---
j. ( (/,~,f
Authorized by: ___ -~W"---'"---;-.P_""""_-,bf-----
lndustriaJH ~
Project Team Leader: ~vu.ll M cE: L-.,;~e,,v\
I
Assistants: Bh.:e e tJ ·; cJJ .S&.v\ ' b11..1..r ·e.. L-_,<'.:n
Project Team Leader: If this is a sampling trip, submit a copy of this form to the QA/QC Chemist
To Be Completed by Industrial Hygienist:
County Health Department Contact: __ /J1 __ 1_S_a.ni,.,, __ 7_,/~~;C;;_:~e_lci~---------
Title: . -----------------------
Notes: Health Department Official Contacted: fri~-t3a.r-br-0c l5coJ7
Back Up Letter Required: Yes --.k.._ No __
Submit Ibis form to the Industrial Hygienist with a copy of the Site Location Map (8½ x 11 paper only)
• •
June 20, 1996
MEMORANDUM
TO:
FROM:
RE:
File
Randy McElveen
Environmental Engineer
NC Superfund
Conference Call with EPA and Potentially Responsible Pai1ies Representatives
Proposed Additional Downgradient Remedial Investigation Work for RAWP
Geigy Chemical Corp. NPL Site
NCD 981 927 502
Aberdeen, Moore County, N011h Carolina
On 28 May 1996, a representative of the NC Superfund Section participated in a Conference
call with the EPA and the potentially responsible parties' representatives for the Geigy Chemical Site.
During the call various issues relative to the downgradient groundwater investigation were discuss
and a proposal for additional downgradient investigation work for the Remedial Action Work Plan
strategy was completed. Primary issues of concern to the agencies were surface water sampling
locations in Trough Branch and Aberdeen Creek. The results of this meeting will be included in the
final Sampling and Analysis Plan which is available in the NC Superfund files.
cc: Grover Nicholson, NC Superfund Section
RI
. 1 , JUN 10 '96 04:53PM RUST E&I •
.. ...-ENVIRONMENT& l~I INFRASTRUCTURE
P.1 •
FACSIMILE TRANSMISSION
PROJECT NUMBER 86619.500 DATE 6/10/2!2 TIME 4:53PM
SUBJECT: Monthly Progress Report No. 36 (May, 1996)
Geigy Chemical Corporation Site
FROM: Michael Sheehan [phone]
TOT AL PAGES SENT INCLUDING THIS PAGE: .5.
ADDRESSEES
USEPA Region IY
Bernie Hayes
NCDEHNR Randy McEiveen
Olin Coq,oration
Garland Hilliard
Comments
Fax: [phone]
FACSIMILE#
[phone]
[phone]
[phone]
Attached is the Geigy Chemical Corporation Site Monthly Progress Report for your files.
Copies will be issued to you via Federal Express.
Regards,
,J.41
JUN 10 '96 04:53PM RUST E&I • •
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
June 10, 1996
Mr. Bernie Hayes
Remedial Project Manager
USBPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, GA 30365 VIA FACSIMILE AND FEDERAL EXPRESS
RE: Geigy Chemical Corporation Site
Monthly Progress Report No. 36, May 1996
Dear Mr. Hayes:
P.2
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), attached are five copies of the referenced document in accordance
with Section XI, Paragraph 29 of the Consent Decree.
Please feel free to contact me at [phone] if you have any questions or require additional
information.
Regards,
Garland Hilliard
Project Coordinator
/Attachment
c: VIA U.S. MAIL
J. Serfass (Olin)
H. Moats (Ciba)
G. Crouse (Ciba)
B, Vinzant (Kaiser)
1. Cloonan (Rust)
M. Sheehan (Rust)
S. Sargent (Rust)
, JUN 10 '96 04=54PM RUS.&I •
GEIGY CHEMICAL CORPORATION SUPERFUND SITE
Aberdeen, North Carolina
Remedial Design
Monthly Progress Report No. 36
MAY1996
P.3
This report summarizes Remedial Design and Downgradient Groundwater activities for the
Geigy Chemical Corporation Site during the given period. This report is submitted in accordance
with Section XI, Paragraph 29 of the Consent Decree.
1. ACTIONS TAKEN TOWARDS COMPLIANCE WITH THE CONSENT DECREE
The Companies met with EPA and NCDEHNR on May 14, 1996 to discuss preparation of the
Downgradient Area Remedial Action Work Plan. The Companies verbally notified the Agencies
at that time that surface water and stream sediment sampling activities would be conducted
during the week of June 3, 1996.
The Companies held a conference call with the Agencies on May 28, 1996 to discuss the revised
surface water and stream sediment sampling and analysis plan. A final version of the plan was
submitted to the Agencies on June 3, 1996.
The Companies selected OHM as the contractor for the remedial action and issued a Notice of
Intent to award the contract. OHM initiated preparation of the contractor submittals required by
the Statement of Work (air monitoring plan, health & safety plan, erosion and sedimentation .
control plan, construction quality assurance plan, etc.).
2. RESULTS OF SAMPLING, TESTS AND OTHER DAT A
The Companies received the results of in-situ soil samples collected for TCLP testing on May
23, 1996. Preliminary results indicate that 19 of the 21 excavation areas passed TCLP limits for
pesticides. Collectively, these areas represent approximately 95 percent of the volume of soils to
be removed from the Site during the remedial action.
The preliminary results further indicate that only the composite soil sample collected from
excavation areas 1 0a and 13 failed TCLP limits for ganima BHC. Field observations suggest that
this result may be due to the presence of pesticides in a limited portion of the surface soils in area
1
P.4
10a. Per the In-Situ .Soils TCLP Characterization Work Plan, which was submitted to the
Agencies on April 8, 1996, the Companies are conducting additional TCLP analyses of grab
samples collected from areas 1 Oa and 13 (i.e., samples held in archive at the laboratory). The
additional analyses will be used to further define the volume of soils requiring incineration.
Preliminary results of these additional analyses are expected on June 18, 1996.
3. WORK PLANS. REPORTS AND OTIIBR DELIVERABLES
None.
4. ACTIONS SCHEDULED FOR THE NEXT SIX WEEKS
The following activities are anticipated:
• conduct surface water and stream sediment sampling during the week of June 3, 1996;
• install monitoring wells MW-31L and MW-32L during the week of June 10th, pending
receipt access agreements;
• sample EPA piezometer PZ-5 and newly installed wells MW-311 and MW-321 during the
week of June 10th;
• submit the Draft Downgtadient Area Remedial Action Work Plan to the Agencies on July 15,
1996.
5. PERCENTAGE OF COMPLETION
The Remedial Design is 100 percent complete.
6. DELAYS ENCOUNTERED OR ANTICIPATED
None.
7. MODIFICATIONS TO THE WORK PLANS OR SCHEDULES
None.
8. COMMUNITY RELATIONS SUPPORT
a) Activities Conducted During This Reporting Period
2
9.
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The Companies initiated contact with property owners in the downgradient area to obtain
access agreements for the surface water/stream sediment sampling locations and locations
for proposed wells MW-31L and MW•32L.
b) Anticipated Activities During Next Reporting Period
None.
OTIIBR SIGNIFlCANT ACTIVITIES
OHM'S draft work plans (air monitoring plan, health & safety plan, erosion and sedimentation
control plan, construction quality assurance plan, etc.) are currently scheduled to be submitted to
the Companies on June 14th.
3
March 14, 1996
Mrs. Shula Schloegl
200 Blue Street
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Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
Aberdeen, North Carolina 28315
RE: Water Treatment System Laboratory Test Results
Dear Mrs. Schloegl:
RECEIVED
MAR 181996
SUPERFUND SECTION
Please find enclosed the laboratory results that were obtained from the sampling event performed
on January 16, 1996. The results show that the water treatment system is performing as designed
and is removing the compounds previously detected in your well water. A diagram showing
sample locations is attached. I understand that RUST Environment & Infrastructure (RUST
E&I), on behalf of Olin Corporation, Ciba-Geigy Corporation and Kaiser Aluminum & Chemical
Corporation has arranged to collect another set of samples April 15, 1996 to confirm and verify
that the system continues to operate properly. As we agreed, the companies will maintain the
system and periodically test the water to insure that the system performs as designed.
Thank you, and your son Richard, for your continued help in this matter. Should you have any
questions or concerns, please do not hesitate to contact me at 423-336-4479, or Laura Tew of
Olin Corporation at 1-800-225-0256 ( extension 551-0509).
Regards,
e:J~ 4~ I ,M
Garland Hilliard
Project Coordinator
/ Attachments
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bee: Bernie Hayes -EPA
L Randy McElveen -NCDEM
Steven Biggs -Town of Aberdeen
Sam Fields -Moore County Health Department
Harold Moats -Ciba
George Crouse -Ciba
Bill Vinzant -Kaiser
•
-SL SAVANNAH tfaoRATORIES
& ENVIRONMENTAL SERVICES. INC.
•
2846 Industrial Plaza Drive (32301) • P.O. Box.13056 • Tallahassee, FL 32317-3056 • [phone] • Fax [phone]
Ms. Kristen Harms
RUST Env. & Infrastructure, Inc.
15 Brendan Way
Greenville SC 29616
CC: Ms. Diana Baldi
REPORT OF RESULTS
LOG NO: T6-10133
Received: 17 JAN 96
Reported: 29 JAN 96
Project: 88633.100/Schloegl Well
Sampled By: Client
Page 1
WG NO SAMPLE DESCRIPTION, LIQUID SAMPLES DATE SAMPLED
------------------------------------------------------------------------------------
10133·1 SCHL·AA3 01-16-96
10133-2 SCHL·B8 01-16-96
10133-3 SCHL·C8 01-16-96
------------------------------------------------------------------------------------
PARAMETER 10133-1 10133-2 10133 -3 -------------------------------------------------------------------------------
Organochlorine Pesticides (508)
Aldrin, ug/1
alpha-BHC, ug/1
beta-BHC, ug/1
delta-BHC, ug/1
gamma-BHC, ug/1
alpha-Chlordane, ug/1
gamma-Chlordane, ug/1
4,4' -DOD, ug/1
4,4'-DDE, ug/1
4,4' -DDT, ug/1
Dieldrin, ug/1
Endosulfan I, ug/1
Endosulfan II, ug/1
Endosulfan Sulfate, ug/1
Endrin, ug/1
Endrin Aldehyde, ug/1
Endrin ketone, ug/1
Heptachlor, ug/1
Heptachlor Epoxide, ug/1
Methoxychlor, ug/1
Toxaphene, ug/1
Surrogate Tetrachloro-m-xylene
Surrogate -Decachlorobiphenyl
Surrogate -Dibutyl Chlorendate
Date Extracted
Date Analyzed
Batch ID
<0.10
4.9
1.1
2.6
3.9
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<20
104 %-
125 %-
117 %-
01.17.96
01.24.96
0117B
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<1.0
62 %*F99
74 %-
89 %
01.17.96
01.23.96
0117B
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<1.0
65 %'*F99
7 8 %-
92 %-
0l_.17.96
01.24 .96
0117B --------------------------------------- ----------------------------------------
Laboratories in Savannah, GA • Tallahassee, FL • Tampa, FL • Deerfield Beach, FL • Mobile, AL • New Orleans, LA
•
SL SAVANNAH L'30RATORIES
& ENVIRONMENTAL SERVICES. INC.
•
2846 Industrial Plaza Drive (32301) • P.O. Box 13056 • Tallahassee, FL 32317-3056 • [phone] • Fax [phone]
LOG NO: T6-10133
Received: 17 JAN 96
Reported: 29 JAN 96
Ms. Kristen Harms
RUST Env. & Infrastructure, Inc.
15 Brendan Way
Greenville SC 29616
CC: Ms. Diana Baldi
REPORT OF RESULTS
Project: 88633.100/Schloegl Well
Sampled By: Client
Page 2
LOG NO SAMPLE DESCRIPTION, LIQUID SAMPLES DATE SAMPLED
10133-4 SCHL-DB 01-16-96
PARAMETER
Microbiological
Total Coliform MF, col/l00ml
Date Analyzed
Time Analyzed
10133-4
ABSENT
01.17.96
1515
Laboratories in Savannah, GA • Tallahassee, FL • Tampa, FL • Deerfield Beach, FL • Mobile, AL • New Orleans, LA
Treated Water
Flowmeter
Ultraviolet Purifier
X -Valve
~ -Sampling Port
Water Treatment System
Schloegl Well
Aberdeen, North Carolina
SCHL-CB
Filler
Carbon Tanks
SCHL-B8 -Sample Identification for January 16, 1996 Sampling Event
Sample not taken from
this port for 01-16-96
event.
•
Raw Water
Filter
PSMAC-88633:WATER TREATMENT
. ' • •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION ◄
3

◄

5

COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
February 22, 1996
4WD-NSRB
Mr. Garland Hilliard, Project Coordinator Olin Chemical Corporation
P.O. Box 248
Charleston, Tennessee 37310
RE.CF !\Ir:-;.'
FEB 2 7 1996
RE: Geigy Chemical NPL Site, Aberdeen, North Carolina Draft Final Design Report . Draft Data Summary Report, Downgradient Groundwater Investigation
Dear Mr. Hilliard:
EPA has completed its review of the Draft Final Design Report for the Geigy Chemical NPL Site. That. report is hereby approved. Attached are a number of minor comments that should be addressed in the preparation of the Final version:of the Design . . . . . . . ·,1 , ' Report. If there are any questions regarding:ah acceptable manner in which to address these comments, 'please'cohtact me for guidance so that no further drafts or revi~ions ir\. the Final Design Report will be necessary.
In addition, EPA has reviewed the Draft Data Summary Report for the Downgradient Groundwater Investigation, dated November, 1995. EPA concurs in the findings of that investigation as presented in that report,:and·hereby approves the .Data Summary Report as submitted. Since approval of the Data Summary Report does not trigger an additional submittal ori the part of the Site Responsible Parties, EPA will be contacting you in the near future regarding response actions that may be necessary as a result of these findings. At this time, EPA is of the position that the terms of the Consent Decree for the remedial action at this Site regarding additional response actions may have to be invoked. The widespread groundwater contamination defined by the downgradient investigation will no·t be addressed by the remedial actions described in the Remedial Design Report as approved above, making it likely that additional response actions will be necessary.
Please submit final copies of the Remedial Design Report and the Data Summary Report to EPA and to NCDEHNR to the addresses specified in the Consent Decree. As has been the practice
•
recently, please send
McElveen at NCDEHNR.
Administrative Record
repository located in
•
-2-
two copies each to EPA and to Randy EPA will add these reports to the for the Site, and to the public information the Town Hall in Aberdeen, NC.
Thank you for your continued cooperation. If you have any questions, please contact me at [phone], extension 2067.
Sincerely, .h/
~~~
R~. Hayes ·
Remedial Project Manager
North Superfund Remedial Branch
cc: Randy McElveen, NCDEHNR
I
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Attachment
Draft Final Design Report
Geigy Chemical NPL Site
Aberdeen, NC
Final EPA comments
•
The following comments require minor revisions to the document:
1. At the bottom of page 2-1, it is stated that urnitial
results of the investigation indicate that the direction of
groundwater flow in the Upper Black Creek aquifer is to the
southwest, towards McFarland's Branch tributary .... •,
The results of the investigation actually indicate that
groundwater flow is to the southwest, west, and northwest
from the area of the Site. Contaminant migration appears to
be limited, however, to a southwesterly direction. This
statement should be revised to indicate that contaminant
migration, rather than groundwater flow, is to the
southwest.
2. Volume and area calculations as shown on Drawing 86619-C-01
are incorrect. Please recalculate and correct these
volumes. The calculations in Excavation Area 15 and, as a
result, the total volume, appear to be incorrect.
3. Proposed monitoring well MW-30D as shown on drawing number
86619-C-02 should be screened across the entire Upper Black
Creek aquifer.
4. In Section 2.2.3.1 of the PSVP, reference is made to Table
2-7 as displaying the indicator wells for determining
extraction termination. This reference should be to Table
2-6 throughout this section. Also, monitoring well MW-30D
should be added to Table 2-6 and should be used in this
determination.
5. Please add a discussion in.the appropriate l~cation in
Section 2.2 of the PSVP clarifying the different manner in
which the indicator wells presented in Table 2-2 and the PSV
wells listed in Table 2-6 will be used as part of
performance standards verification. The description
included now leaves this determination open to
interpretation. EPA's understanding is that the wells in
Table 2-2 will be used.during the operation of the
extraction system until such time as they indicate that
performance standards may be achieved. At that time, the
PSV monitoring described using the wells listed in Table 2-6
will be performed. Section.2.2 of the PSVP should contain
language which clarifies this understanding.
•• •
January 23, 1996
Mr. Rutherford B. Hayes
Remedial Project Manager
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
USEPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
REC!="1' 'ED
JAN 2 4 1996
SUPERh.Ji,u SECTION
Atlanta, GA 30365 VIA FEO.ERAL_EXFRESS
RE: Meeting History
Draft Data Summary Report Review
Downgradient Groundwater Investigation
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Mr. Hayes:
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), attached are three copies of the referenced document. To facilitate
distribution, a copy of the referenced document has been sent directly to Mr. Randy McElveen
of the NCDEHNR.
Please feel free to contact me at [phone] if you have any questions or require additional
infomiation.
Regards,
Garland Hi Ilia rd
Project Coordinator
/Enclosure
•
c: VIA EEDERALEXERESS
<R:-McEl\ieen .(NCDEHNR) "
YTA_lLS_MAIL
H. Moats (Ciba)
G. Crouse (Ciba)
B. Vinzant (Kaiser)
J. Cloonan (Rust)
M. Sheehan (Rust)
S. Sargent (Rust)
•
• •
I ..... ENVIRONMENT & I . l~U~ I INFRASTRUCTURE . ___ ___.H..Ll,.,STORJ'.
Meeting History No. 1
Geigy Chemical Corporation Site
Downgradient Groundwater Investigation -Draft Data Summary Report Review
RUST E&I Project No. 33288.510
PLACE:
DATE OF MEETING:
PRESENT FOR:
Jani1ary 23, 1996
Atlanta Hilton and Towers
Atlanta, Georgia
December 5, 1995
Qlin_Corporatinn
Mr. Garland Hilliard
CibacGeig.y_Carparatian
Mr. Harold Moats
Mr. George Crouse
Kaiser_Aluminum..&_ChemicaLCarporatian
Mr. Bill Vinzant
llnited.States_EruLironmentaLErntectiD!LAgency
Mr. Bernie Hayes
Mr. Luis Flores
Ms. Julie Keller
NortlLCarolinaJ)epartmenLaLEn.vjranment,...Health_and_Natural
Resaurces_(yja_conference_call)
Mr. Randy McElveen
RUSLEmLironmenL&-1nfrastructure
Mr. Jim Cloonan
Mr. Michael Sheehan
Ms. Stacy Sargent
• •
CORRECTIONS_AND_DMISSIONS
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.
EIIRPQSE DE MEETING
The purpose of the meeting was to review the Draft Data Summary Report for the Downgradient
Groundwater Investigation submitted to EPA on November 27, including a review of investigation
activities and findings, and discuss anticipated future activities for the downgradient area. The
meeting agenda is attached.
ITEMS OE DISCT!SSION
The meeting lasted from approximately I: 15 PM to 4:30 PM with a 10 minute bre._i.k. Major
resolutions and issues discussed were:
I. Hayes opened meeting by stating that EPA would be using a team approach for the Geigy
Site, and that he was still responsible for. the Geigy Site. He said that EPA was reviewing
the possibility of transitioning responsibility back to Luis Flores.
2. Hilliard stated that the objective of the meeting was to review the results of the
Downgradient Groundwater Investigation, address any comments or questions from EPA
regarding the investigation, and obtain an understanding of the Agencies' perspective on
the results of the investigation and anticipated future activities for the downgradient area.
Hilliard stated that community relations efforts were continuing. Discussions were on-
going with the Town Manager (Steve Biggs) for Aberdeen, and the work conducted to date
had been well-received by Town personnel and the community. The Geigy Site info-line
was still active, and a limited number of calls (2) had been received from the public during
the course of the downgradient investigation.
3. Moats reported that the community liaison group for Aberdeen had not received any
questions to date regarding the Geigy Site. Hayes stated that a special representative for
the Geigy Site should not be needed.
4. Hilliard stated that a meeting with Steve Biggs and the Companies will be held to review
the results of the downgradient investigation prior to release of the report to the repository.
Hilliard said the meeting was tentatively scheduled for early January pending EPA's
review of the report. Hayes concurred that the meeting should be held and stated that he
would like to attend if his travel budget allowed. Hilliard stated that he would coordinate
the meeting date and time directly with Hayes following today's meeting.
5. Sheehan provided a review of the field activities for the downgradient investigation,
including a description of Phase One, Phase Two, Phase Three A, and Phase Three B.
Sheehan reported that results from Phase One of the investigation were reviewed with EPA
January 23, 1996 2
• •
on June 5th. Based on the results of Phase One, the investigation was expanded to include
the Lower Black Creek aquifer. Modifications to the scope of work for Phases Two,
Three A, and Three B were submitted by the Companies to EPA and approved prior to
conducting each phase of work. Sheehan stated that the downgradient extent of TCL
pesticides in both the Upper and Lower Black Creek aquifers has been defined. Lithologic
data from the investigation indicated that a lateral discontinuity in the Lower Black Creek
confining unit was present in a portion of the study area hydraulically downgradient from
the Geigy Site. Within this area, the Upper and Lower Black Creek aquifers are in
hydraulic communication. Lithologic data also indicate that the Cape Fear confining unit
is a laterally continuous aquitard that exists throughout the downgradient investigation area
and defines the base of the Lower Black Creek aquifer.
6. Sargent reviewed groundwater flow directions. Downgradient groundwater flow in the
Upper Black Creek aquifer is predominantly to the west-southwest towards McFarland's
Branch. Downgradient groundwater flow in the Lower Black Creek aquifer is ,
predominantly to the west-northwest towards Aberdeen and Ray's Mill Creeks. Sargent '
stated that based on water-level data from piezometer nests and stream water-level
elevation data, the streams in the downgradient area, including McFarland's Branch,
Trough Branch, Ray's Mill Creek, and Aberdeen Creek, served as natural hydraulic
discharge boundaries for groundwater flow in both the Upper and Lower Black Creek
aquifers. Gaining conditions were demonstrated for each piezometer and stream staff
gauge location, with the exception of SG-7, which is well removed from the area of
pesticides (over 1500 feet north of the extent of pesticides). Vertical hydraulic gradient
data indicate that a downward component of flow from the Upper to Lower Black Creek
aquifers exists in the immediate vicinity of the lateral discontinuity of the Lower Black
Creek confining unit. Groundwater from the Upper Black Creek aquifer enters the Lower
Black Creek aquifer at this location.
7. Hayes stated that the Companies and Rust had done a good job characterizing the
hydrogeology of the downgradient area. McElveen added that the state agreed that an
excellent job had been done, and the state was satisfied with the characterization. Hilliard
stated that results of the investigation substantiated the original conceptual model for area.
8. Keller asked whether McFarland's Branch had been sampled. Sargent replied that
McFarland's Branch was not sampled as part of this investigation. Based on sampling
conducted for the APDS Rt;medial Investigation, no pesticides were present in Aberdeen
Creek. Hayes stated that he believed McFarland's Branch had been sampled in the past,
he would check on this.
9. Keller asked if the Cape Fear fonnation was used for drinking water purposes. Sargent
replied that it does not serve as the sole source for any wells in the area. City Well No.
2 is screened in both the Lower Black Creek aquifer and the Cape Fear. The Cape Fear
consists of interbedded sand and clay units, with a clay unit defining the top of the
fonnation.
January 23, 1996 3
• •
10. Sargent noted that the water level in WP-18LB appeared to be anomalous. This
piezometer had poor recoveries during development and is believed to be damaged.
Because it is located .on the west side of Ray's Mill Creek, that other piezometers in the
vicinity indicate gaining conditions along the stream, and due to schedule constraints, the
piezometer was not replaced.
11. Hayes asked how deep Pages Lake was maintained. Keller replied that the lake was
shallow, and was drained periodically for maintenance.
12. Sargent noted that slug tests conducted in the downgradient area indicated no significant
variability in hydraulic conductivity exists between the Geigy Site and the downgradient
area. The hydraulic conductivity appears to be approximately 5 feet/day in both the Upper
and Lower Black Creek aquifers.
13. Hayes stated that the source of contamination in City Well No. I has potentially been
identified, and that the high pesticide levels may be due to previous pumping of the well.
Hilliard reported that City Well No. 2 was sampled in late October, the data had just been
validated and all pesticides were below detection limits except for beta-BHC (detected at
a concentration of approximately 0.02 ug/1). Hilliard stated that the Companies would
inform Steve Biggs of the results soon. Hayes asked about the status of City Well Nos.
I and 4. Hilliard replied that they had been abandoned by filling with concrete. Hayes
asked where the Companies obtained water quality data for Town of Aberdeen municipal .
wells. Moats replied that the data had been obtained from Rickie Monroe. McElveen said
he would check with Art Barnhardt of the NCDEHNR regarding data on all of the city
wells.
14. Sargent stated that private wells in the downgradient area had been identified during the
investigation and all potential receptors have a safe source of drinking water. Hilliard
stated that one private well owned by the Whisenand's was abandoned, and a second well
(Davis) had detects of pesticides right at the current MCLs or Site performance standards.
The Davis well was being used for outside, non-drinking purposes only.
I 5. Hilliard stated that the Companies wanted to work closely with EPA in the near future,
with the FDR being submitted soon (within approximately one to two weeks), and the
Companies possibly concluding field work for the remedial action in 1996. Hilliard noted
that the soil removal at the Geigy Site would be the first in the area, and the Companies
wanted to ensure public satisfaction with the work.
I 6. Hilliard asked when the Downgradient Groundwater report would be placed in the
repository, and how the information in the report would be disseminated to the public.
Hayes replied that the downgradient investigation can serve as a Remedial Investigation.
EPA could define a remedy now or a separate Operable Unit could be designated which
would require an FS and ROD. Hayes stated the extent of contamination in the
downgradient area was serious. Hayes said he would like to see the remedial design for
the current ROD implemented, and a revised Fact Sheet developed for distribution to the
public and discussion during a public meeting. He anticipates that the public meeting
would include a discussion of the downgradient investigation, although this would not be
January 23, 1996 4
• •
an official comment period. He would like to have the Downgradient report finalized and
in the repository by the time the meeting is held. Hayes stated that EPA had an initiative
to stop plume chasing and find innovative solutions to groundwater problems. He felt the
same investigation process at the Geigy Site would be repeated at other sites in the
Aberdeen area if innovative solutions were not developed, which would not be cost
effective. The Town of Aberdeen is concerned about maintaining their water supply, and
it would not be cost effective to have multiple extraction wells, treatment systems, and
discharge the water without using it for consumption. Well head treatment has been
implemented at other Superfund sites.
17. Hilliard stated he understood city well head treatment was being considered by EPA as a
potential "global" remedy for the Aberdeen area, and asked how many wells might be
included in this remedy. Hayes replied that the Town's water supply needs must be
addressed, including loss of water resources associated with closure of City Well Nos. I
and 4. Hayes said the details of well head protection would probably depend on how the
PRPs decided to share in the remedy. Keller said the solution must provide for expansion
of the Aberdeen water supply system. Hilliard stated that with past agricultural practices,
all pesticides detected in the downgradient area may not be attributable to the Geigy Site.
Vinzant stated that he was encouraged by EPA' s approach that focused on ensuring a safe ·
drinking water supply. Moats stated that the Companies want to support the goals of EPA
and the Town of Aberdeen (i.e., safe drinking water supply), and that he felt a response
should be fonnulated in a rapid time frame (i.e., next few months). Hayes agreed.
McElveen stated that the state was open to the idea of the global remedy, and feels that it
would be an innovative and appropriate solution. He has had some preliminary discussions
with Jack Butler, and he provided his initial concurrence with the idea. Hayes said EPA
would need to hold further discussions soon with both the'state and the Town of Aberdeen,
and that administrative hurdles within EPA still needed to be cleared regarding
implementation of the global remedy.
18. Keller said the global remedy would require an amended ROD at a minimum. Keller said
Chuck Mikalian (ORC) believes that a new Consent Decree would be required and that the
proposed plan for the global remedy would need to be very detailed in order to gain
approval from EPA upper management.
19. Hilliard asked if, hypothetically, the global remedy would eliminate the need for pump-
and-treat systems. Hayes replied that source control measures would not be abandoned,
and that the ROD for OU! and OU4 at APDS would stand. Hayes stated that zones of
technical impracticability might be established, within which potential groundwater users
would be identified and ensured a safe drinking water supply. ARARs would be waived
with the zone(s) of technical impracticability. The basis for technical impracticability
would include the potential presence of unknown sources in the area·.
20. Hayes said the remedy would have to ensure a safe water supply through treatment of all
public and private wells in a defined area. Whether the public water was treated at the
well head or at a central location needs to be resolved. Hayes stated that the solution
January 23, 1996 5
• •
would need to address potential contamination in area creeks, to address Fish and Wildlife
concerns. He added that restoration of the aquifers in the downgradient area would need
to be addressed even though City Well Nos. I and 4 were no longer being used. He stated
that the Department of the Interior can waive natural resource damages within the Consent
Decree to aid in implementation of the global remedy. He requested that McElveen begin
compiling available surface water quality data for the area.
21. Hilliard requested approval to submit the FDR on December 15th. Hayes agreed.
22. McElveen stated he may request that additional investigation work be conducted in the area
of additional surface soil contamination north of Highway 21 I. Hayes stated that EPA
does not want remedial design to be delayed if additional investigation work is conducted
north of Highway 211. McElveen will send a list of additional data requests to Hayes.
Hilliard closed by stating that the Companies would review his request upon receipt.
RUST Environment & Infrastructure
January 23, 1996
/ Attachment
January 23, 1996 6
• •
MEETING AGENDA
GEIGY CHEMICAL CORPORATION SITE
DOWNGRADIENT GROUNDWATER INVESTIGATION
DRAFf DATA SUMMARY REPORT REVIEW
DECEMBER 5, 1995
ATLANTA HILTON AND TOWERS
FULTON ROOM
ATLANTA, GEORGIA
1:00 p.m. -4:00 p.m.
AGENDA ITEM TIME
1 INTRODUCTIONS AND MEETING OBJECTIVES 1:00
2 PROJECT STATUS AND COMMUNITY RELATIONS UPDATE 1:05
3 INVESTIGATION ACTIVITIES 1:15
3.1 Step One
3.1.1 DPT explorations
3.1.2 Subsurface soil samples
3. I. 3 Stream staff gauges
3.2 Step Two
3.2.1 DPT explorations
3.2.2 Monitoring wells/piezometers
3.2.3 Groundwater quality samples
3. 3 Step Three
3.3.1 Monitoring wells/piezometers
3. 3. 2 Groundwater quality samples
3. 3. 3 In-situ hydraulic conductivity tests
3.3.4 Water-level measurements
4 JNVESTIGA TION FINDINGS I :30
4. I Upper Black Creek Aquifer
4. I. 1 Groundwater flow directions
4. I. 2 Discharge boundaries
4. I. 3 Discontinuity in Lower Black Creek confining unit
4. I .4 Distribution of TCL pesticides
4. 2 Lower Black Creek Aquifer
4. 2. I Groundwater flow directions
4. 2. 2 Discharge boundaries
4. 2. 3 Distribution of TCL pesticides
4.3 Summary
5 GENERAL DISCUSSION/ PROJECT SCHEDULE 2:45
6 CLOSURE/ACTION ITEMS 4:00
Rev. 0 12/4/95
DEC 05 '95 06:03RM RUST ENV-INFRRSTRUC. • •
MEETING AGENDA
GEIGY CHEMICAL CORPORATION SITE
DOWNGRADIENT GROUNDWATER INVESTIGATION
DRAFT DATA SUMMARY REPORT REVIEW
DECEMBER 5, 1995
ATLANTA HILTON AND TOWERS
FULTON ROOM
ATLANTA, GEORGIA
1:00 p.m .• 4:00 p.m.
AQENDAITEM
P.2
:r!M.B
1 INTRODUCTIONS AND MEETING OBJECTNES 1 :00
2 PROJECT STATUS AND COMMUNITY RELATIONS UPDATE 1:05
3 INVESTIGATION ACTIVITlES 1:15
3.1 Step One
3. 1.1 DPT explorations
3. 1.2 Subsurface soil samples
3. 1. 3 Stream staff gauges
3.2 StepTwo
3. 2.1 DPT explorations
3. 2. 2 Monitoring well5'piezometers
3. 2.3 Groundwater quality samples
3. 3 Step Three
3. 3.1 Monitoring wells/piezometers
3.3.2 Groundwater quality samples
3. 3. 3 In-situ hydraulic conductivity tests
3.3.4 Water-level measurements
4 INVESTIGATION FINDINGS 1:30
4, 1 Upper Black Creek Aquifer
4.1. 1 Groundwater flow directions
4.1.2 Discharge bouncta.1es
4, I. 3 Discontinuity in Lower Black Creek confining unit
4. 1. 4 Distribution of TCL pesticides
4. 2 Lower Black Creek Aquifer
4, 2.1 Groundwater flow directions
4. 2. 2 Di~charge boundaries
4. 2. 3 Distribution of TCL pesticides
4.3 Summary
5 GENERAL DISCUSSION/ PROJECT SCHEDULE 2:45
6 CLOSURE/ACTION ITEMS 4:00
Rev, 0 1215,95
DEC 05 '95 06:03AM RUST ENV-INFRASTRUC. •
.__..ENVIRONMENT &
..Ult■ INFRASTRUCTURE
P.1 •
FACSIMILE TRANSMISSION
PROJECT NUMBER 33288.510 DATE 12/5/95
SUBJECT: December 5th Meeting Agenda
Geigy Chemical Corporation Site
FROM: Michael Sheehan [phone]
TOT AL PAGES SENT INCLUDING THIS PAGE: 2
ADDRESSEES
NCDEHNR
Randy McElveen
Comments
TCME 6:02AM
F"": [phone]
FACSIMILE#
[phone]
Attached is the agenda for our December Sth meeting to discuss the Draft Data Summary
Report for the Downgradient Oroundwatc;r Investigation. The mcc,ting will be held in the
Fulton Room of the Atlanta Hilton and Towers. We will call you at your office number al
1:00 p.m.
• •
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
November 27, 1995
Mr. Rutherford B. Hayes
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N .E.
RECEIVED
NOV 2 8 1995
SUPERFUND SECTION
Atlanta, GA 30365 VIA HAND DELIVERY
RE: Draft Data Summary Report
Downgradient Groundwater Investigation
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Mr. Hayes:
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), please find enclosed two (2) copies of the Draft Data Summary
Report for the Downgradient Groundwater Investigation. Per your telepho~e conversation with
Mr. Michael Sheehan on November 20th, one copy of the report have been sent directly to Mr.
Randy McElveen of NCDEHNR to facilitate distribution. ·
We look forward to meeting with you in Atlanta on December 5th to review the findings of the
downgradient investigation. A preliminary version of the meeting agenda will be sent to you for
your review this week. If you require additional copies of the report, or have'any questions about
the investigation findings, please feel free to contact me at [phone]. :
Regards,
Garland Hilliard
Project Coordinator
/Enclosure
c: R. McElveen (NCDEHNR)
H. Moats (Ciba)
G. Crouse (Ciba)
H. Grubbs, Esq. (WCS&R)
B. Vinzant (Kaiser)
M. Sheehan (Rust)
MEMORANDUM
TO:
FROM:
RE:
Octobe_r 25, 1995
File
Randy McElveen
Environmental Engineer
NC Superfund Section
Remedial Overview
•
Downgradient Investigation Field Work
Geigy Chemical Site
NCD 981 927 502
Aberdeen, Moore County, North Carolina
On 19 October 1995, a representative of the NC Superfund
Section provided remedial overview of the Downgradient
Investigation field work being performed in the area of the Geigy
Chemical site located in Aberdeen, Moore County, , NC. The work
underway at this time included Rotosonic Drilling and installation
of a downgradient groundwater monitoring well to the south of the
subject Site.
cc: Jack Butler, NC Superfund Section
September 28, 1995
•
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
Mr. Rutherford B. Hayes
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
· Atlanta, GA 30365
RE: Geigy Chemical Corporation Site
Step Three B Field Activities
VIA FEDERAL EXPRESS
Dear Mr. Hayes:
• RECEIVED
OCT O 21995
, SUPERFUND SECTION
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical
Corporation (the Companies), this letter constitutes 14 days notice to EPA for completion of
Step Three B field activities, including a proposed expansion in the scope-of-work, for the
Downgradient Groundwater Investigation for the Geigy Chemical Corporation Superfund Site
("Site") located in Aberdeen, North Carolina. This notice is being provided to EPA in
accordance with Section IX, Paragraph 23 of the Consent Decree. This letter also presents
minor revisions to the Step Three B scope-of-work so as to permit the objectives of the downgradient groundwater investigation to be fulfilled.
Field work for Step Two and Three A of the downgradient investigation was conducted in
accordance with the approved June 1995 Downgradient Groundwater Investigation Work Plan
Addendum. Field work was completed in September 1995 according to schedule, with the
exception of sampling EPA piezometer PZ-4. Sampling of PZ-4 was delayed approximately
one month due to difficulty establishing property access. Sampling of PZ-4 was conducted
September 19, 1995. '
The downgradient investigation scope-of-work for Step Three B has been revised and slightly
expanded to include additional assessment of portions of the Upper and Lower Black Creek
aquifers. Field work will be separated into two separate sections but performed as one field
effort. The field work will consist of the installation of ten pairs of nested piezometers and
associated stream gauges along the streams and creeks that border the study area, and the
installation of three piezometer/monitoring wells (see attached figure).
Mr. Hayes
Page2
September 28, 1995
• •
I The portion of the field effort involving the installation of the ten pairs of nested piezometers
was included in the approved Addendum to the Downgradient Groundwater Investigation
Work Plan dated June 13, 1995. An adjustment to the proposed piewmeter locations has been
implemented based upon the preliminary results of Steps Two and Three A Piezometer nests
WP-13LT/WP-13l.B and WP-14LT/WP-14l.B, originally located approximately 1200 feet west
of PZ-5 along Aberdeen Creek, will be moved to McFarland's Branch in replacement of
piewmeter nests WP-llLT /WP-lll.B and WP-12LT /WP-12l.B. These piezometer nests will
be screened in the Lower Black Creek aquifer to confirm that McFarland's Branch
hydraulically bounds this portion of the Lower Black Creek aquifer. Piezometer nests
WP-llLT/WP-llLB and WP-12LT/WP-12l.B will be moved to the immediate vicinity of
existing stream staff gauge SG-1. These piewmeter nests will be screened in the Upper Black
Creek aquifer to confirm that McFarland's Branch hydraulically bounds the Upper Black
Creek aquifer hydraulically downgradient of MW-26D.
Piewmeter WP-7D will be installed in the Upper Black Creek aquifer based upon preliminary
sampling results from monitoring well MW-23D. The construction materials and installation
methods for WP-7D will be modified to be consistent with monitoring well installation
procedures presented in the approved Downgradient Groundwater Investigation Work Plan
and Work Plan Addendum. The modified construction of WP-7D will allow for the collection
of groundwater samples if necessary. Sampling will occur if the groundwater level in WP-7D
is below an elevation of 390 feet MSL, indicating the potential for flow downgradient of the
facility property in the Upper Black Creek aquifer toward this location. A groundwater level
elevation above 390 feet MSL in WP-7D would indicate the piezometer is sidegradient of
groundwater flow from the facility property and water-level data only would be collected at
this location. Preliminary water-level data collected during Step Three A indkate that WP-7D
will be located sidegradient of flow from the facility property.
As an expansion to the Step Three B scope-of-work, two monitoring wells (MW-29D and
MW-29L) will be installed southeast of the headwaters of McFarland's Branch. Sampling of
both wells will be contingent on groundwater flow directions determined from water-level data
collected from these wells. Monitoring well MW-29D will be installed at lthe base of the
Upper Black Creek aquifer to verify groundwater discharge conditions to McF;arland's Branch
south of the creek. Sampling of MW-29D will occur if the groundwater level in the well is
below an elevation of 380 feet MSL indicating the potential for groundwater flow in the Upper
Black Creek aquifer toward this location from areas to the north and east of McFarland!;
Branch. If the water-level elevation in the well is above 380 feet MSL, groundwater quality
sampling will not be conducted. Monitoring well MW-29L will be installed in the Lower Black
Creek aquifer and will provide stratigraphic and water-level data to further define the gradient
and direction of groundwater flow in this portion of the study area. If the water:level elevation
in MW-29L is above 380 feet MSL, and the Lower Black Creek confining unit is present,
groundwater quality sampling from MW-29L will not be conducted. If the water-level
Mr. Hayes
Page3
September 28, 1995
• •
elevation is below 380 feet MSL, or the Lower Black Creek confining unit is absent, a
groundwater quality sample will be collected from the well. Monitoring well installation
methods will be consistent with procedures presented in the approved Downgradient
Groundwater Investigation Work Plan and Work Plan Addendum.
Groundwater samples will be analyzed for TCL pesticides, TCE, and field indicator
parameters in accordance with Section 3.5.4 of the approved Downgradient Groundwater
Investigation Work Plan. · '
All work will be accomplished within the time-frame of the existing, approved schedule such
that the Data Summary Report will be provided to EPA in accordance with the submittal date
shown on the revised schedule in the Work Plan Addendum. ·
The schedule presumes the work to be accomplished is that which is described in this
addendum without further changes and that work will begin following the 14-day notification
period (i.e., on October 12th). Major modifications may significantly impact the schedule.
Any changes or modifications which are deemed appropriate based on the data collected
and/or interim reports of field activities, and their effect on the estimated schedule, will be
reviewed by the EPA at the earliest opportunity. Such changes or modifications, including
schedule revisions, will be implemented after written approval by EPA.
Schedule dates are contingent on the procurement of property access agreements, where
required, weather, and contractor availability. To facilitate distribution, a: copy of this letter
has been sent directly to Mr. Randy McElveen of NCDEHNR.
Please feel free to contact me at (615) 3364479 if you have any questions or require additional
information.
Regards,
Garland Hilliard
Project Coordinator
/ Attachments
c: VIA FEDERAL EXPRESS
R. McElveen (NCOEHNR)
H. Moats (Ciba)
G. Crouse (Ciba)
J. Vinzant (Kaiser)
N
t
-Er
Legend
c::J
=
Pond
Swamp
Building
Paved Roads
Unpaved Roads
/'V Stream (Air Photo)
/'v" Stream (USGS Quadrangle)
[__-=:J Wooded Area
./7---/ Railroads
/"-/ Topographic Contour
•
+ Tawn of Aberdeen Municipal Well
,4-Town of Aberdeen Municipal Well
(Abandoned)
• ffi
~
"'
~ •
A
A
'41
USGS Well Cluster
Monitoring Well
Lower Bleck Creek Aquifer
Monitoring Well
Upper Black Creek Aquifer
\Nell Point Piezometer
Upper Black Creek Aquifer
Stream Staff Gauge
Piezometer Nest
Upper Black Creek Aquifer
Direct Push Exploration
Lower Black Creek Aquifer
Direct Push Exploration
Upper Black Creek Aquifer
Proposed Step Three B Installation Locations
Proposed Piezometer Nest •
•
■
A
~
Upper Black Creek Aquifer
Proposed Piezometer Nest
Lower Black Creek Aquifer
Proposed Piezometer/Monitoring Well Cluster
Upper and Lower Black Creek Aquifers
Proposed Piezometer/Monitoring 1/\/ell
Upper Black Creek Aquifer
Proposed Stream Staff Gauge
US EPA Monitoring Well/Piezometer
..... ENVIRONMENT &
l~U>I INFRASTRUCTURE
BOO 0 BOO
SCALE IN FEET
Contour Interval = 10 FT
DRAFT
PROPOSED STEP THREE B
SAMPLE LOCATIONS
1600
UPPER AND LOWER BLACK CREEK AQUIFER
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
• •
' '
• • RECEIVED
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OCT 27 1995
VIA FAX [phone]
Harold W. Moats
Ciba-Geigy Corporation
410 Swing Road
P.O. Box 18300
Greensboro, NC 27419-8300
Dear Harold:
REGION 4 SUPERFUND SECTION
HS COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
September 14, 1995
EPA has reviewed the Draft Phase IVa Addendum to the Remedial Investigation
Report for Operable Unit 5 at Aberdeen Pesticide Dumps Site. EPA disapproves the
submission, the enclosed comments detail the deficiencies. Also, enclosed are comments
from Randy McElveen, NC-DEHNR.
The Report should be revised and resubmitted to the EPA within thirty (30) days. If
you would like to meet or hold a conference call to discuss the comments, a submission of
responses to EPA comments and request for meeting should be received no later than seven
(7) days prior to the date of the proposed meeting. However, a request to meet to discuss
the comments will not extend the thirty (30) day resubmission deadline as required by
Section VIIl of the ~dministrative Order by Consent.
Enclosure
cc: Randy McElveen, NC-DEHNR
Bob Rose, CDM Federal
Sincerely,
4J-J~
JuQe W. Kelle:
Project Coordinator
J .Keller/JK:4WD-NSRB:2029/07 /14/95/C:\ WP51 \RIIV
• •
DRAFf PHASE IVa ADDENDUM TO THE RI REPORT
ABERDEEN PESTICIDE DUMPS SITE OU#S
McIVER DUMP AND ROUTE 211 AREAS
General Comments
I) With respect to meeting the objective of further assessing the local geologic,
hydrogeologic, geotechnical properties, and ground water quality of the Areas, this
report fulfills that objective well. However, with respect to meeting the objective of
further characterizing the extent of contamination, this report, like the draft RI report
is incomplete. This report neither presents an analysis of background concentrations
(which are needed to define the extent of site-related contamination) nor does it even
partially define the extent of contamination.
2) It appears that the PRPs are anticipating eliminating metals as contaminants of
concern (COCs) without proper justification. The sample results collected during this
RI indicate that certain metals are at concentrations above MCLs and hence will likely
be included in the list of COCs. The PRPs should be aware that to eliminate these
metals as COCs, further sampling and analysis will be required. Attributing the high
metals concentrations to suspended soil particles without proper sampling results to
support this claim will not be acceptable "to EPA. Neither will filtered sample results.
The PRPs will need to minimize the turbidity of the samples as best as possible
through acceptable sampling techniques, and use the analytical results from these
samples to justify elimination of metals from further consideration.
Specific Comments
1) page ES-2
2) page 1-1
3) page 1-2
EXECUTIVE SUMMARY
The PRPs state that they have "sufficiently delineated" the extent of
contamination in the Surficial Aquifer at the Route 211 Area. This
report, however, does not present the extent of contamination. Please
c_larify. In addition, see General Comment #1 with respect to defining
background conditions before extent can be delineated.
The first paragraph should reference the June, 1995 field sampling
plan, rather than a June 1994, plan.
Section 1.1 PROJECT OBJECTIVES/TECHNICAL APPROACH
If the objectives of the Phase IV a RI were to "further characterize the
nature and extent of pesticides in groundwater" at the site, why were
the groundwater samples also analyzed for VOCs and metals? In
1
4) page 2-2
5) page 2-4
6) page 2-6
7) page 2-7
8) Table 2-2
9) page 3-1
• •
addition, why isn't the extent of contamination even partially defined in
this report? Please clarify.
Section 2.2 HYDROGEOLOGIC CHARACTERIZATION,
ROUTE 211 AREA
. The approved Field Sampling Plan for the Phase IV Remedial
Investigation for Route 211 indicates that a Step Drawdown Test will
be conducted to determine the well efficiency and specific capacity of
the aquifer. Please provide the results as well as a discussion of the
Step Drawdown Test in this Section and in Appendix D.
Ground Water Flow Patterns
In the first sentence it is unclear what is meant by deflection of water-
level contours. Water-level contours can be deflected for several
reasons; some water -level contour deflections may be a result of non-
homogeneous aquifer conditions, while some deflections may be the
result of conditions unrelated to the degree of aquifer homogeneity.
Section 2.3.1.1 Groundwater Sampling
The PRPs state that the groundwater sample designated MC-HP-01 was
collected adjacent to Patterson Branch. According to Figure 2-1,
however, the sample location is over 100 foet southwest of Patterson
Branch. Please explain how a sample located this far from a stream
could be characterized as being collected adjacent to the stream.
Section 2.3.2.1.1 Surficial Aquifer
Why was the original well at MW-11 abandoned and a replacement
well which is unlikely ever to have water in it installed in its place?
Based on the screen elevation of the replacement well a~d the hydraulic
gradient depicted in Figure 3-4, this well should be dry. Please
explain.
According to Table 2-2, the d50 for the sample form RT-TW-02D-ST is
0.06 mm, yet the sample contains 12 % fines. The d50 for the sample is
a coarse silt grain size, implying that more than 12 % of the sample is
fines, if fines are both the silt and clay size fraction of the sample.
Section 3.1 GEOLOGY
The third paragraph should better define which hard, brittle silty clay
was not encountered at the RT-TW-14D location. In the last paragraph
on this page, the text should be more explicit in identifying the
locations of the Shelby tube and HQ wireline core samples.
2
10) page 4-1
11) page 4-2
12) page 4-3
13) page 5-3
• •
Section 4.0 NATURE AND EXTENT OF CONTAMINATION -
GROUNDWATER
See General Comment #I with respect to defining the extent of
contamination. Contrary to what the text states, this section does not
summarize the extent of contamination.
Section 4.2.1.1 Surficial Aquifer
Why is the fact that TCL pesticides were not detected in the RT-DP-13
wellpoint mentioned here in the text. According to Figure 2-2, this
wellpoint was installed during Phase Ila and hence was not sampled
during Phase !Va. No other non-Phase !Va results are discussed in this
section. Please explain.
Section 4.2.3 TAL Metals
See General Comment #2 with respect to disqualifying the metals
concentrations. ·
Section 5. 3. 2 Route 211 Area
The report should note that because of the absence of the surficial
aquifer in the area more or less south of monitoring well RT-MW-10,
additional investigation of the underlying upper Black Creek aquifer in
that area is needed to define the extent of groundwater contamination.
The Phase !Vb sampling proposal includes an additional upper Black
Creek aquifer monitoring well in that area. Of the eight pesticides
detected in the sample collected from RT-TW-14D, only one pesticide
(toxaphene) was previously not detected in any groundwater samples
collected from the Route 211 Area. In addition, toxaphene was
detected once at the Mclver Dump Area. Please explain the first
statement made in the last paragraph, particular in light of the above
observation and the fact that the sample data log indicates that the
sample collected from RT-TW-14D had a low turbidity. In fact, the
turbidity in this sample was lower than the turbidity of all the other
Phase !Va samples. Are all the other wells going to be redeveloped
and resampled too because of the high turbidity?
14) page E-9 Section 5.3 A1;mendix E -Quality Control Summary Report
Flagging the data only with an "i" does not indicate how much the
surrogate recovery was "out-of-criteria." Are the i-flagged data
considered "J" estimated (per functional guidelines criteria)? Could
some of the i-flagged data be considered "R" rejected (per functional
guidelines criteria)? Either "J" or "R" should be used in conjunction
with the "i" flag.
15) page E-11 · Section 6.1.1 Appendix E -Quality Control Summary Report
It would be useful to calculate for all positive results, including those
flagged "J" or "L."
3
• • State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management .WA
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
September 5, 1995
Ms. Julie Keller
North Superfund Remedial Branch
US EPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
DEHNR
RE: Comments on the Draft Phase IVa Addendum to the Remedial Investigation Report OU5, Groundwater
Mciver Dump and Route 211 Areas NCD 980 843 346
Aberdeen, Moore County, North Carolina
Dear Ms. Keller:
The Draft Phase IVa Addendum to the Remedial Investigation Report for Operable Unit (OU)5, Groundwater, dated August 1995 for the Mciver Dump and Route 211 Areas of the Aberdeen Pesticide Dumps Site has been received and reviewed by the North Carolina Superfund Section. The following comments are offered by the North Carolina Superfund Section.
1. The extent of pesticide contamination discovered to the south of monitoring well RT-MW-10 was investigated through installation of monitoring well RT-MW-11 as discussed on page 4-2 and located on Figure 2-2. The conclusions of the Phase !Va investigation are discussed on page 5-3 of the report. The absence of groundwater in the area of . RT-MW-11 and the .absence of pesticide contamination in the area of RT-HP-OlA is not sufficient data to conclude that "pesticides are not present in the Surficial Aquifer east of location RT"."MW-10 and Bull Run. "
Additional monitoring wells (deep and shallow) located east of RT-MW-11 and south of RT-MW-10 should be installed to verify the extent of the contamination plume in the Surficial Aquifer. A similar sc~nario may also be required in the shallow aquifer to the west of RT-MW-11. Since the upper confining unit is present in this area a deep aquifer monitoring well should be installed just south of RT-MW-10 to verify that leakage to the upper Black Creek aquifer has not occurred.
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
Ms. Keller
9-5-95
Page 2
• •
If you have any questions or comments, please do not hesitate to
contact me, at {919) 733-2801, extension 341.
Sincerely, ~ ~~~~\~~ten
Environmental Engineer
NC Superfund Section
cc: Jack Butler, N.C. Superfund Section
State of North Carina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes. Secretary
William L. Meyer. Director June 23, 1995
TO: Arthur Mouberry, Chief
Groundwater Section
DEHNR.
Division of Environmental Management (DEM)
FROM:
RE:
Randy McElveen
Environmental Engineer
NC Superfund Section
Downgradient Groundwater Investigation
Data Summary Report
Geigy Chemical Corp. NPL Site
NCD 981 927 502
Aberdeen, Moore County, North Carolina
EPA is in the process of completing a Downgradient Groundwater
Investigation Data Summary Report for the Geigy Chemical
Corporation Superfund site, a National Priority List site.
Attached is one copy of the Downgradient · Groundwater
Investigation Data Summary Report for the subject site. This
report was prepared by RUST E&I for the us EPA, Region IV. It is
requested that these documents be forwarded to the appropriate
sections of DEM and comments be submitted to the NC Superfund
Section. The NC Superfund Section will be reviewing this document
and submitting comments to EPA Region IV by January 15, 1996. If
your reviewers are unable to comment by this date, please inform me
as to when they will be able to review the information in the
document relative to their Section. It is our desire to include
the views and permitting requirements of the Air Quality,
Groundwater, and Water Quality Sections of DEM. The attached
Revised Response to comments dated December 6, 1996 is provided for
Art Barnhart at the Fayetteville Regional office since some of his
comments are addressed in it.
If you or your staff have any questions, please do not
hesitate to call us at [phone].
Attachment
cc/ Jack Butler, NC Superfund Section
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
• •
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
June 14, 1995
Mr. Rutherford B. Hayes
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
rr
RECEIVED
JUN 16 1995
. SUPERFUND SECTION
Atlanta, GA 30365 VIA FEDERAL EXPRESS
RE: Figure 12, Draft Addendum
Downgradient Groundwater Investigation Work Plan
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Mr. Hayes:
On behalf of Olin Corporation, Ciba-Geigy Corporation, and Kaiser Aluminum & Chemical·
Corporation (the Companies), please find enclosed two (2) copies of Figure 12 of the Draft
Addendum for the Downgradient Groundwater Investigation Work Plan. Copies have also been
sent directly to Mr. Randy McElveen of NCDEHNR (I copy) and Mr. Tim Eggert of CDM Federal
Programs (2 copies).
We apologize for any inconvenience this may have caused. If you require additional copies of the
figure, please feel free to contact me at [phone].
Regards,
Garland Hillard
Project Coordinator
/Enclosure
c: T. Eggert (COM)
R. McElveen (NCDEHNR)
H. Moats (Ciba)
G. Crouse (Ciba)
H. Grubbs, Esq. (WCS&R)
B. Vinzant (Kaiser)
M. Sheehan (Rust)
February 24, 1995
Mrs. Shula Schloegl
200 Blue Street
• •
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
Aberdeen, North Carolina 28315
RE: Water Treatment System Laboratory Test Results
Dear Mrs. Schlocgl:
RECEIVED
FEB 2 81995
SUPERFUNO SECTION
Please find enclosed the laboratory results that were obtained from the sampling event performed
on .lanurary I 8, 1995. The results show that the water treatment system is performing as
designed and is removing the compounds previously detected in your well water. A diagram
showing sample locations is attached. I understand that RUST Environment & I nfrastructurc
(RUST E&I), on behalf of Olin Corporation, Ciba-Geigy Corporation and Kaiser Aluminum &
Chemical Corporation has arranged to collect another set of samples April 19, 1995 to confirm
and verify that the system continues to operate properly. As we agreed, the companies will
maintain the system and periodically test the water to insure that the system performs as
designed.
Thank you, and your son Richard, for your continued help in this matter. Should you have any
questions or concerns, please do not hesitate to contact Stewart Johnson in Greensboro at
1-800-334-9481, extension 7713 or910-632-7713.
Regards,
C:x,,.,~( ;-/. c..L{t<,.J//l--1ri-<;,
Garland Hilliard
Project Coordinator
/ Attachments
~ R::c::.
•
bee: Luis Flores -EPA
Randy McElveen -NCDEM
Steven Biggs -Town of Aberdeen
Sam Fields -Moore County Health Department
Harold Moats -Ciba
Stewart Johnson -Ciba
Bill Vinzant -Kaiser
•
SL SAVANNAH LA.RATORIES
& ENVIRONMENTAL SERVICES. INC. •
28t,6 lndusi,ia! Plaza Drive (32301) • P.O. Box 1c056 • ,·2'!2:1ass•2e FL 323·, 7•3056 • (904) 878-399~ • Fa>: (90.:) 878-950j
LOG NO: T5·10156
Ms. Stacy Sarge11t
Rust Environment. & Infrastructure
P.O. Box 24000
Greenville, SC 29615
Received: 19 ,JAN 95
Project: 88633.100/Area Groundwater Survey
Sampled By: Client
REPORT OF RESULTS Page 1
LOG NO
10156·1
10156-2
10156-2
SAMPLE DESCRIPTION, LIQUID SA!1PLES
SCHL-A4
SCHL·B4
SCHL-C4
DATE/
TIME SAMPLED
01·18-95/1200
01-18-95/1220
01-18-95/1230
TRUOG
TRUOG
TRUOG
-- - - --- - -------------------. -- ------ - --. ----------------------- ----- - -. - -
O:_·ganochlo1:ine Pesticides (508)
_:._ldrin, ug/l
.:..lpha-BHC, ug/1
3eta-BHC, ug/1
Delta·BHC, ug/1
Gamma-BHC, ug/1
alpha-Chlordane, ug/1
gamma-Chlordane, ug/1
4,4' ·DDD, ug/1
4, 4' ·DDE, ug/1
4, 4' ·DDT, ug/1
Dieldrin, ug/1
Endosulfan I, ug/1
Endosulfan II, ug/1
Endosulfan Sulfate, ug/1
Endrin, ug/1
Endrin Aldehyde, ug/1
Heptachlor, ug/1
Heptachlor Epoxide, ug/1
Methoxychlor, ug/1
10156-J.
<0.050
3.8
1.0
1.8
4.3
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
10156-2
<0 .0050
<0. 0050
<0 .0050
<0.0050
<0.0050
<0.0050
<0.0050
<O. 0050·
<0.0050·
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
----------
}0156-3
<O .0050
<O .0050
<0 .0050
<0 .0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
<0.0050
----------
·Q'1()(1L' , L . lj
Laboratories in Savannah, GA • Tallahassee. Fl. • Tampa. FL .. Deerfield Beach. FL • Mobile. AL • New Orleans. LA
SL SAVANNAH LA-ATOR/ES
·. & ENVIRONMENTAL SERVICES. INC. •
2846 lndusiri?.I Plaza Drive (32301) •PO.Ge> ,3056 • fallanassee. FL 32317-3056 • [phone] • i'2•. (901.) 878-9501.
LOG HO: TS-1015~
Received: 19 J.::.N SS
Ms. Stacy Sarge11t
Rust Environment & Inf1:astruct:ure
P.O. Box 24000
Greenville, SC 29615
LOG NO SAMPLE DESCRIPTION
10156-4 SCHL-D4
PARJ\METEP.
Microbiological
Total Coliform MF, col/100:nl
Dat.e .4nalyzed
Time Analyzed
A= Absent
Project: 88633.100/Area Grou11dwat:.er Surve~·
Sampled By: Client:.
REPORT OF RESULTS
DATE/
QC RE:PORT FOR LIQUID SAMPLES TIME SAMPLED
10156-4
A
01.19.95
1645
01-18-95/1_235
Page 3
TRUOE
Laboratories in Savannah. GA • Tallahassee. FL• Tampa. FL ., Deerfield Beach. FL • MolJifc. /4L • New Orleans. LA
Treated \'later
Flow meter
Ultraviolet Purifier
Z -Valve * • Sampling Port
Water Treatment System
Schloegl Well
Aberdeen, North Carolina
SCHL-C4
Filter
SCHL-B4
Carbon Tanks
•
•
SCHL-A4
• Filter
PSMAC-88633:WATER TREAT/.\Ef.lT
.:; • w • •
Olin cHEMICALs
P.O. BOX 248. LOWER RIVER ROAD, CHARLESTON, TN 37310
PHONE: [phone]
March 13, 1992
Giezelle Bennett
Remedial Project Manager
Waste Management Division
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: Final Remedial Investigation (RI), Risk Assessment
{RA) and Feasibility study (FS) for the Geigy Chemical
Corporation Site, Aberdeen, North Carolina
VIA: Federal Express from Olin Corporation (RI), Clement
International {RA) and SEC-Donahue (FS)
Dear Ms. Bennett:
On behalf of the PRPs, enclosed are final copies of the RI (Book 1),
RA and FS report (four bound and one unbound copies of each). These
documents incorporate EPA comments (January 31, 1992) as discussed
and agreed upon (February 14, 19 and March 5, 1992). Note that each
document is being sent from a separate location as indicated above.
Please transfer the USGS Topographic Maps, Southern Pines Quadrangle
and Pinebluff Quadrangle {Fig 2-1) from the previous RI (Book 1)
(January 14, 1992) to this final RI (Book 1) document.
Book 2 of the RI required no revisions and labels are being provided
to update the title page information of the document you have from
our January 1992 submittal.
Please call me at 615/336-4381 if you have any questions.
LMM/cat/099
Enclosures
Sincerely,
>( ~ '7n. )11.Lluv
Lorraine M. Miller
for
OLIN CORPORATION
CIBA-GEIGY Corporation
Kaiser Aluminum & Chemical Corporation
• •
cc:
L. M. Rapp o. L. Paulson
R. K. Harold
L. J. Pearsall
J. J. Cloonan
T. M. Wilson
•
bee: s. L. Goldfarb
R. H. Grubbs
R. E. Lannan
A. o. Rheingold
D. L. Cummings
I ' • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
NOV O 6 1991,
4WD-NSRB
CERTIFIED MAIL
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
RETURN RECEIPT REQUESTED
Ms. Lorraine Miller
Olin Chemicals
P.O. Box 248
Lower River Road
Charleston, TN 37310
RE: Geigy Chemical NPL Site
Aberdeen, NC
Dear Ms. Miller:
fffCt:fVED
Nov· B 199,
SUPiRffllfD S£c11llft)
Attached are the Agency's comments on the draft Remedial
Investigation Report. According to the site schedule, a letter
report that provides responses to all comments is due in the
Region no later than November 20, 1991.
Of particular. note is the fact that EPA does not agree with the
conclusion that the contamination in the ·second aquifer is
corning from off-site upgradient sources. Both the pesticides
and the trichloroethene detected in the second aquifer are due
to contamination from the above referenced site. As such, all
of the language in the report to this effect must be deleted.
If you have any questions, please give me a call at
404/347-7791.
erly~ ~
Giez lie s. Bennett
emedial Project Manager
PrinteC on Rec,".:/ed PDper
• •
RI COMMENTS
1. The figures and the tables should be incorporated into the
RI report in the appropriate part of the text. The
appendix should remain as a separate volume. This would
help in the overall review and understanding of the
document.
2. It appears that a document search was conducted on the
text to capitalize "site" throughout the document. This
resulted in capitalizing the word "site" when unnecessary
and in creating errors, such as "composite".
3. The report needs an executive summary that briefly
summarizes all aspects of the report.
4. Page 1-2, Section 1.1.1 -The absence of surface water
samples should be explained in this section.
5. Page 1-5, Section 1.2 -The Site Backgr~und Section should
be in more detail. Describe what each company did on the
site; how the property was used, buildings used, etc.;
shipping practices; disposal practices; reasons for
contamination. In addition, was there any past
enforcement action at this site; DEM or OHR· inspections;
violation citings? NUS and the HRS are mentioned, yet the
dates of proposal and finalization on the NPL are not
mentioned. Was the NUS investigation the only sampling
that has ever been conducted ·at this site? What were the
conclusions and recommendations of the NUS study?
6. Page 1-6, Section 1.2.3 -The removal actions should not
be included in the site background. They were conducted
in conjuction with and in support of the Remedial
Investigation. This discussion and the discussion of the
soil sampling phases is confusing. The removal actions
and the phases of soil sampling should be discussed in
sequential order in Chapter 4. The rationale or the soil
levels that prompted the first removal should be given,
followed by the report of the analyses of what was left on
site, and then the results of the first phase of the soil
investigation. If a removal was conducted after the first
phase, then that discussion should come next. If the 1991
removal was the last action for the soil at the site, then
the details of that removal and the results of the
post-excavation samples should be presented last. The RI
document should be able to stand alone and should not have
to be supported by other documents. It is difficult from
the text to determine what are the current site
conditions, and what information the risk assessment was
based on, etc.
• •
-2-
7. Page 1-7, Section 1.2.3.1 -An explanation of why the
removal was conducted in two phases is needed.
8. Page 1-7, Section 1.2.3.2 The Administrative Order
limits need to be discussed here and need to be included
in Table 1-3. From the maps, there appears to be overlap
between the 1991 removal and the earlier removals. This
would seem impossible if the areas were backfilled with
crushed stone. Please explain.
9. Page 1-7, Section 1.2.4, Line 4
"document" to "support".
Change the word
10. Page 2-1, Section 2.2 -This section needs a discussion
about demography and land use immediately surrounding the
site, within a one or two mile radius.
11. Page 2-1, Section 2.2, para 2, Line 10 -Change "roll" to
"role".
12. Page 2-6, Section 2.5 -Why use 1980 census data here
use the 1990 census data in the earlier discussion?
data should be consistent.
and
The
13. Page 2-7, last line
11 stands".
Change the word "strands" to
14. Page 2-7,
consists
dwellings.
Section 2.7.2 -The area around the site also
of a significant number of residential
This needs to be included in the discussion.
15. Figure 3.5 -The low elevation of the water table measured
in monitoring well MW-6S indicates a depression in the
water table surface. This depression could indicate that
ground water is flowing from the "upper most aquifer" to
the "second upper most aquifer." However, in November
1990, pesticides were detected in monitoring well MW-6S
and not in monitoring well MW-6D, which monitors the
"second uppermost aquifer." The depression indicates that
contaminants should have leaked from the upper aquifer to
lower aquifer, but analytical data indicate that leakage
of contaminants has not occurred.
Language on page 3-6 states that there is a depression in
the surface of the clay layer beneath the "uppermost
aquifer" at wells MW-6S and MW-6D. This depression
correlates to the above mentioned depression in the water
table, and indicates that there is a greater potential for
leakage through the confining layer at this location.
• •
-3-
16. Page 3-12, Section 3.3.2 -A brief discussion is needed on
the results of the sampling. Describe if any compound was
found in an elevated level, etc.
17. Page 3-16, Section 3.6.1.2 Were the owners of the
off-site wells given the results of the analyses of their
water?
18. Page 3-17, Section 3.6.2.1 -All the values stated in the
text for MW-lS match the values stated in Figure 3-9 for
MW-1D, not MW-lS. Also, the specific conductivity value
stated for MW-6S matches the value for MW-3S, not MW-6S.
19. Page 3-18, Section 3.6.2.4, Para. 3 -The text states that
toxaphene was found in MW-2S at 610 ug/1 and in MW-4S at
4.5 ug/1. Figure 3-11 shows that toxaphene was found in
MW-2S at 10 ug/1 and in MW-4S at 5 ug/1.
20. Page 3-19 -In addition to the wells ·along the railroad
track at the site, trichloroethene was detected in private
wells upgradient of the site. The three monitoring wells
located between the private wells and the site that were
installed to . determine if the trichloroethene was coming
from off-site, are not contaminated with trichloroethene.
This evidence indicates that trichloroethene in the
private wells is likely from a different source than the
trichloroethene in the wells at the site. The
trichloroethene along the railroad track is likely
associated with spillage from rail cars. In addition,
trichloroethene was detected in PZ-1 above the MCL. This
is not mentioned anywhere in the report.
21. Figure 3.13 indicates that the PMP well is located north
of the site, yet Figure 1.5 indicates that the well is
located south of the site. Please reconcile these figures
to the correct location of the PMP well.
22_. Page 3-18, Section 3.6.3
Statement of Work"?
What is the "March 1990
23. Page 3-19, Section 3.6.3.2, Line 2
"confirm that" to "determine if".
Change the words
24. Page 4-1, Section 4.3.1 -The samples SS-2, 7, 8, 10, and
11 are not included on Figure 4-1.
• •
-4-
25. Page 4-2, Section 4.3.2 Since there were only two
samples that contained pesticide concentrations over 100
ppm, they should be included on Figure 4-3.
26. Page
map.
211.
4-3, Section 4.3.2 -Sample SS-83 is not shown on the
Sample SS-103 is not located along State Highway
2 7. Figures -The figures and the text should reflect exactly
what was found. It is difficult to follow the discussion,
when one number is given in the text and another number is
shown on the figure (for example, figures 3-11 and 3-13,
and the text on page 6-1).
28. Page 6-1, Para 5 -The lateral extent of contamination to
the south and east of the site has not been defined. As
· this was one of the main objectives of the RI, please
explain how the extent will be determined or estimated.
29. Page 6-2, Para 1 -The first sentence of this paragraph is
not correct, and the second sentence is misleading. This
paragraph should be reworded.
30. Page 6-2 Delete Section 6.1.1 from "There is no
definitive ••• " down to " •.• upgradient, off-site source."
31. Page 6-4 -Delete the first full paragraph.
32. Page 6-5, Section 6.2, Para 2 -Why is 100 ppm used as a
sort of cleanup goal here? This paragraph should be
reworded. Cleanup levels for soil will be well below 100
ppm total pesticide.
33.
34·.
Page 7-5, Section 7.2.3.1
correct and should be
information.
The last
reworded to
sentence is not
state accurate
Section 8
comments.
22, 23, and
This section should reflect the previou·s
Numbers 4, 6, 7, 12, 13, 15, 16, 17, 18, 21,
24 need to be either reworded or deleted.
-• •
-5-
North Carolina DEHNR Comments (On all three documents RI,RA,FS)
In general, it appears that the Water Quality Standards
applicable to the Groundwaters of North Carolina as presented
in the North Carolina Administrative Code (NCAC) Subchapter 2L
Section .0100, .0200, and .0300 have been ignored. Because of
this, several points in the NCAC 2L should be noted and the
appropriate actions taken. In Section .0103 Policy it is
stated that "The rules established . in this Subchapter are
intended to maintain and preserve the quality of the
groundwaters, prevent and abate pollution and contamination of
the waters of the state, protect public health, and permit
management of the groundwaters for their best usage by the
citizens of North Carolina. It is the policy of the commission
that the best usage of the groundwaters of the state is as a
source of drinking water. It is the intent of these Rules to
protect the overall high quality of , North Carolina's
groundwaters and to enhance and restore the quality of degraded
groundwaters to the level established by the standards."
Furthermore, it is stated in Section .0106 that "The goal of
actions taken to restore groundwater quality shall be
restoration to the level of the standards, or as close thereto
as is economically and technologically feasible." The
"standards" referred to are listed for 72 compounds in Section
.0202(g).
Three exceptions to these listed standards are given in Section
.0202(b). These exceptions are as follows:
1. Where the maximum allowable concentration of a substance
is less than the limit of detectability, the substance
shall not be permitted in detectable concentrations.
2. · Where two or more substances exist in combination, the
Director shall consider the effects of chemical
interactions and may establish maximum concentrations at
values less than those established in accordance with
Paragraphs (c) and (g) of this Rule. In the absence of
information to the contrary, the carcinogenic risks
associated with carcinogens present shall be considered
additive and the toxic effects associated with
non-carcinogenic present shall also be considered
additive.
3. Where naturally occurring substances
established standard, the standard will be
occurring concentration as determined by the
exceed the
the naturally
Director.
I • •
The Groundwater
and con side red
standards at the
-6-
Standards thus established should be
in establishing action levels and
Geigy Chemical Site.
reviewed
cleanup
It was also noted that metals such as lead, copper, and zinc
were generally considered to be non-site related in the
discussion in the subject documents. It should be noted that
several metal containing compounds such as lead arsenate, lead
arsenite, zinc arsenate, and zinc arsenite have been used as
insecticides in the past. In addition, copper arsenate, and
copper arsenite have been used as fungicides and copper
chromate has been specifically used as a seed fungicide
treatment.
• • United States Department of the Interior ---
■ ..
FISH AND WILDLIFE SERVICE
Raleigh Field Office .. ■
Post Office Box :33726
Raleigh, North Carolina 27636-:3726
Mr. Giezelle s. Bennett
Remedial Project Manager
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Bennett:
November 1, 1991
This is in response to your letter to Mr. James Lee, Regional Environmental
Officer for the Department of Interior, dated October 9, 1991, requesting a
review of the Draft Remedial Investigation Study, Geigy Chemical Corporation
Site, Aberdeen, Moore County, North Carolina.
The Fish and Wildlife Service (Service) was asked to provide technical
assistance to Section 2.7 that discusses Ecological Habitats and
Environmentally Sensitive and Rare/Endangered Species. The Service believes
that these sections are very general in nature, and we encourage expansion of
this section to more accurately describe the habitats present at the project
site and its immediate vicinity. Additionally, more detailed information is
needed on Federally-listed endangered and threatened species. To assist you
in this regard, we are enclosing a formal listing of Federally-listed
endangered and threatened species known to occur in Moore County, North
Carolina.
The Endangered Species Section identified the Federally-listed endangered red-
cockaded woodpecker (Picoides borealis} as a species that can be found--in
longleaf pine habitat. Additionally, the Service believes that two Federally-
listed endangered plant species, the Rough-leaved loosestrife (Lysimachia
asperulaefolia), Michaux's sumac {Rhus michauxii), and the proposed endangered
American chaffseed (Schwalbea americana) should be addressed in this
particular section since all three species are known to occur in Moore County
and may potentially be found in the habitat surrounding the site.
The legal responsibilities of the Environmental Protection Agency under
Section 7 of the Endangered Species of 1973, as amended, were detailed in
material sent to your agency previously. If you would like another copy of
this material, or if you have questions, please contact us at 919/856-4520.
We appreciate the opportunity to provide these preliminary comments, and we
look forward to working with you in the future.
Sincerely yours, ,
GL~t_G£
L.K. Mike Gantt
Supervisor
• •
REVISED OCTOBER 10, 1991
Moore County
Red-cockaded woodpecker (?icoiCes borealis) - E
Cape Fear shiner (Notroois mekist=cholas} - E
Rough-leaved loosest=~fe (Lvsimachia asoerulaefol~a) -·E
Michaux's sumac (Rhus michauxii) - E
American chaffseed (Schwalbea americana)-PE
There are species which, although not new listed or officially proposed for
listing as endangered or threatened, are under status review by the Ser·.rice.
These "Candidate" (Cl and C2) species are not legally procected under t!ie
Act, and are not subject to any of its provisions, including Sect.ion 7,
until they are formally proposed or listed as threatened or endangered. We
are providing the below list of candidate species which may occur within the
project area for the purpose of giving you advance notification. These
species may be listed in the future, at which time they will be protect.ed
under the Act. In the meantime, we would appreciate anything you might do
for them.
White-wicky (Kalmia cuneata) -C2
Nestronia (Nestronia umbellula) -C2
Sun-facing coneflower (Rudbeckia heliopsidis) -C2
Spring-flowering goldenrod (Solidacro ~) -C2
Bachman's sparrow {Aimonhila aestivalis) -C2
Pinewoods darter (Etheostoma mariae) -C2
Sandhills chub (Semotilus lumbee) -C2
Northern pine snake (Pituoohis melanoleucus melanoleucus) -C2
Sandhills clubtail dragonfly (Gomnhus parvidens carolinus) -C2
Georgia leadplant (Amorpha georgiana georgiana) -C2
Pine barrens boneset (Euoatorium resinosum) -C2
Bog spicebush (Lindera subcoriacea) -C2
Savanna cowbane (Oxypolis ternata) -C2
Conferva pondweed (Potamogeton confervoides) -C2*
Pickering's morning glory(Stylisma pickeringiivar.pickeringii) -C2
*Indicates no specimen in at least 20 years from this county.
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