NCD981927502_20031001_Geigy Chemical Corporation_FRBCERCLA FYR_Five-Year Review Report-OCR

Region 4
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FIVE YEAR REVIEW FACT SHEET
GEIGY CHEMICAL CORP. SITE
•
Aberdeen, Moore County, North Carolina
October 2003
Where is the Geigy Chemical Site located?
The Geigy Chemical Corporation Site is located just cast of the corporate limits of Aberdeen,
North Carolina in southeastern Moore County. The one acre Site is bounded on the no11h by
State Highway 211 and on the east by Domino Drive. The Aberdeen & Rockfish Railroad cuts
through the Site where the former pesticide blending/mixing/bagging buildings stood. The
property forms an elongated triangle with the highway and railroad forming the apex ..
Site Background
The Site operated as a pesticide blending and formula,ion facility by various operatoi·s from
approximately I 947 to 1967, and by retail distributors of agricultural chemicals from 1967 until
1989. The pesticides DDT, toxaphene, and BHC were received in bulk at the Site, blended with
clay and other ine11 matc1ials, repackaged, and sold. Pesticides were not manufactured at the Site
but were formulated by dry mixing into a product suitable for local consumer use. EPA
conducted an initial site investigation in March 1987. The Site was proposed for listing on the
National Priorities List (NPL) in June 1988, and was officially placed on the NPL as of October
4, 1989. The Rccoid of Decision was issued in 1992 selecting u pump~and-trcatment system to
remove pesticide contaminants from groundwater, and the contaminated soil was excavated and
structures and their foundations were tom down and taken to an approved landfill. The previous
owners took action to removed approximately 3,300 tons of contaminated soil and debris, and
EPA removed approximately 6,935 tons of soil and debris. The contaminants of concern are;
aldrin, BHC isomers, dieldrin, endrin, toxaphene, DDD, DDE, DDT and chlordane isomers. The
· Site was covered with clean soil ,ind revegetated with native grass, plants and trees. The soil
clean up actions were completed as of February 1997. The groundwater treatment system began
operating in January 1997 and has currently treated approximately 30 million gallons of extracted
groundwater from both the surficial and Upper Black Creek aquifers. Monitoring and sampling
of groundwater has continued in order to characterize the migration pattern of the water in the
Upper and Lower Black Creek aquifers.
What is the purpose of a Five-year Review?
The purpose of the review is to determine whether the remedy selected at a site is or remains
protective of human health and the environment, identify issues/problems and recommend
corrective action, if necessary.
Why and when should a Five-year Review be conducted?
As required by the Superfund law, when a remedial action is selected that results in hazardous
substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited
use and unrestricted exposure, the lead agency shall review such action no less often than every
five years after the initiation of the selected remedial action. [40 CFR §300.430(f)(4)(ii)]
• •
Since a groundwater treatment system was installed to treat contaminates in· groundwater, a five
year review is required because contaminants are still being detected in the groundwater at the
Site. The next five-year review should occur by September 2008. These five-year reviews will
continue until the levels of contaminants drop to concentrations that allow unlimited use.
Who conducts the review at a.fund-financed or enforce/llent lead site?
EPA has the responsibility of either conducting the review or hiring a contractor or other
agencies (i.e., U.S. Army Corps of Engineers) to perfotm studies, condµct investigations, and/or
develop draft Five-Year Review reports.
The U.S. Anny Corps of Engineers out of Wilmington, NC conducted the review for this Site
between January 2003 through September 2003. The final report was completed, approved and
signed in September 2003. The Corps was used to provide an unbiased assessment of the Site.
In general, how was the assess/Ile/It of the protectiveness of the rellledy
conducted?
► All relevant data, monitoring/sampling results of groundwater, Operation & Maintenance
reports, Record of Decision, monthly discharge monitoring results, and other documents were
reviewed.
► Since the clean up action of soil and debris was completed in 1997, based on a final
inspection of the Site by EPA and the State of North Carolina Department of Environment
and Natural Resources in I 998, the soil contaminant level goals established in the Record of
Decision and Remedial Design have been met and no further soil remediation is required.
► Conducted a performance evaluation of the groundwater and treatment systems to detennine
if the groundwater remedy is functioning as intended, if the exposure assumptions, toxicity
data, clean up levels and remedial action objectives are still valid, and if other information
has come to light that could question the protectiveness of the remedy.
► Prepared a written Five-Year Review document
What did the assess/llent reveal about the rellledies?
Based upon data from the past five years of operation, review of monitoring information, and
general site conditions, the remedy implemented remains protective of human health and the
environment because the on-going groundwater treatment clean up actions continue to remove
contaminants of concern from the impacted areas. There have been no changes to the physical
conditions of the Site or the adjacent land use that would affect the remedy. The review of
documents, Applicable or Relevant & Approptiate Requirements (ARARs), risk assumptions,
groundwater and monitoring well data, and the results of the Site inspection indicate, overall, that
the groundwater remedy has functioned to this point as intended. No significant issues were
noted during the five-year review of the remedial action components. _
What were the recommendations of the Five-Year Review?
I. Fencing and signing of the Site as proposed in the documents of record have not been
I
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• •
installed. Since the soil has already been cleaned up, this recommendation is no longer
applicable. EPA should issue an ESD to eliminate this requirement.
2. The Site Groundwater Remediation Permit will expire in June 2004. Wording needs to be
changed to renect that the treatment facility consists of seven recovery wells rather than five
since the permit only covered five wells.
3. There is evidence that a plume of trichloroethene (TCE) from another source is starting to
encroach into the Site treatment.area. This situation will continue to be monitored in order to
recognize any impact from the TCE plume.
How should the community be informed and involved?
Activities should include notifying the public that the Five-Year Review will be conducted,
contact citizens for their input, notify the public that the Review has been completed, and
place a copy of the Review in the Site Information Repository.
A display ad was placed in the local newspaper to notify the public that the Five-Year Review
was being conducted. A number of citizens were interviewed by telephone during the review
period. No one expressed any major concerns regarding the remedial action and its operations
over the years at the Site. A copy of the completed questionnaires were placed in the back of the
review document. A copy of the Five-Year Review was placed in the Information Repository
located in the Aberdeen Town Hail, i 15 N. Poplar Street, Aberdeen, NC making it available to
the public. This fact sheet was prepared summaiizing information in the 2003 Five-Year Review
and mailed to people on the Site mailing list. A display ad was placed in the local newspaper to
notify the public that a copy of the Fivc-Y car Review had been completed and is avai I able for
reading in the r~pository.
Have questions?
If you have technical questions about the Five-Year Review document, please contact Jon
Bornholm, EPA Remedial Project Manager at 1-800-435-9233, ext. 28820 or 404-542-8820. If
you want copies of Site fact sheets or general Site information, please contact Diane Barrett,
Community Involvement Coordinators at 1-800-435-9233, ext. 28489 or 404-562-8489.
Want to read documents about the Site?
Copies of all documents developed during the investigation and remediation of this Site have
been placed in the Site Information Repository located in the:
Aberdeen Town Hall
115 N. Poplar Street
Aberdeen, NC 28315
[phone]
and the:
EPA Record Center, 11th Floor
61 Forsyth Street, SW
Atlanta, GA 30303
[phone]
•
Site Mailing List
If ymi want to change/conect/dclete your name from the Geigy Chemical Corp. Site mailing list, please complete the
fonn below and return to Diane Barrett, Community Involvement Coordinator, USEPA, Waste Management
Division, 61 Forsyth Strec.t, SW, 10th Floor, Atlanta, GA 30303.
Name
Address
City, State, Zip Code
Region 4 .
Change □
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303-8960
Geigy Chemical Site
Co1Tection □ Deletion □
1-..i •
Waste Management Division
Diane Barrett, Community Involvement Cp · ·
Jon Bornholm, Site Remedial Project M
HASCER $0.37
OCT 21 2003
US POSTAGE
FIRST CLASS
MAILED FROM 30303
011A0413CC1152
Official Business
Penalty for Private Use $300
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S/F .GEIG 13-~ r·---~ c;_;:__,i'.lc_ '· 71 n ! I
RANDY MCELVEEN, PROJECT MANAGER llnl' ' [JJJ I 1
SUPER FUND SECTION, WASTE MGMT. DIV. i ! ! OCT 2 8 200 · j · '
NC DEPT OF ENVIRONMENT & NATURAi. RESOURCES u I . ' J '
1601 MAIL SERVICE CENTER I --.-...C,
RALEIGH NC 27699· 1601 ' ! __ S,UP~l3fUNn_ SECT1or,1 ----·---------1
• Five• Year Review
Geigy Chemicc! Corp. (Aberdeen Plant), Aberdeen, NC
Five-Year Review Report
First Five-Year Review Report
For
Geigy Chemical Corp. (Aberdeen Plant)
Aberdeen
Moore County, North Carolina
September 2003
Prepared By:
US Army Corps of Engineers
Wilmington District
Wilmington, North Carolina
Prepared For:
Region 4
U.S. Environmental Protection Agency
Atlanta, Georgia
Sfp 3 0
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/ I ;
• Five~Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Five-Year Review Report
Table of Contents
List of Acronyms .......................................................................................................................... iii
Executive Summary ..................................................................................................................... iv
Five-Year Review Summary Form ............................................................................................... i
I. Introduction .............................................................................................................................. 1
II. Site Chronololgy ...................................................................................................................... 2
Ill. Background ............................................................................................................................ 2
A. Physical Characteristics .................................................................................................... 2
B. Land and Resource Use ..................................................................................................... 3
C. History of Contamination .................................................................................................. 4
D. Initial Response ................................................................................................................. 6
IV. Remedial Actions ................................................................................................................... 6
A. Remedy Selection ............................................................................................................. 6
B. Remedy Implementation ................................................................................................... 9
C. System Operations / O&M ................................................................................................ 9
V. Progress Since the Last Five-Year Review ......................................................................... 15
VI. Five-Year Review Process ................................................................................................... 15
VII. Five-Year Review Findings ............................................................................................... 15
A. Interviews ........................................................................................................................ 15
B. Site Inspection ................................................................................................................. 16
C. ARAR Review ................................................................................................................. 16
D. Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics ....... 17
E. Data Review .................................................................................................................... 17
VIII. Assessment ........................................................................................................................ 28
Question A: Is the remedy functioning as intended by the decision documents? ............... 28
Question B: Are the assumptions used at the time of the remedy selection still valid? ...... 28
Question C: Has any information come to light that could call into question the
protectiveness of the remedy? ............................................................................................... 34
· IX. Issues ..................................................................................................................................... 35
X. Recommendations and Follow-up Actions ......................................................................... 35
1
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
XI. Protectiveness Statements ................................................................................................... 36
XII. Next Review ........................................................................................................ , ............... 36
List of Figures
Figure 1. General Location ............................................................................................................................. 3
Figure 2. Specific Site Location ...................................................................................................................... 5
Figure 3. Flow Model of the Pump and Treat Sytem ............................................................................... 11
Figure 4. Monitoring Well and Sampling Locations ................................................................................. 12
Figure 5. Site Area Monitoring and Extraction Well Locations .............................................................. 13
Figure 6. Extraction System and Treatment Facility Diagram ................................................................ 14
List of Tables
Table 1. Chronology of Events ...................................................................................................................... 2
Table 2. Soil Clean-up Standards ................................................................................................................... 7
Table 3. Groundwater Clean-up Standards .................................................................................................. 7
Table 4. Downgradient Groundwater Clean-up Standards ........................................................................ 8
Table 5. Surficial Aquifer BHC Isomer Concentrations in Groundwater Monitoring Wells 1990 -
2002 .......................................................................................................................................................... 19
Table 6. Upper Black Creek Aquifer Sampling Results 1998 to 2002, Exceedences of Performance
Standards for BHC Isomers ................................................................................................................. 20
Table 7. Lower Black Creek .Aquifer Sampling Results 1998 to 2002, Exceedences of Performance
Standards for BHC Isomers ......................... : ............... : ....................................................................... 20
Table 8. BHC-isomer Sampling Results for Surface Water Monitoring 1996 -2002 ......................... 22
Table 9. Trichloroethene (TCE) Concentrations in Groundwater Monitoring Wells 1991 to 2002.27
Table 10. Remedial Alternative Summary ...... : ............................................................................................ 30
Table 11. Recommendations and Follow-up Actions ............................................................................... 36
11
List of Acronyms
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Pla11t), Aberdee11, NC
AOC Administrative Order on Consent
ARARs Applicable or Relevant and Appropriate Requirements
BHC Benzene Hexachloride
CENWO-HX-G Corps of Engineers Hazardous, Toxic and Radioactive Waste Center of
CERCLA
CERCLIS
Expertise
Comprehensive Environmental Response, Compensation, and Liability Act
Comprehensive Environmental Response, Compensation, and Liability
Information System
CESA W-TS-PE Wilmington District, Corps of Engineers Environmental Resources
CFR
CRQL
DOE
DDT
EPA
FS
HRS
!AG
Kg
L
Mg
NCGWQS
NCP
NPL
ppb
ppm
PRP
RA
RD
RI
ROD
RPM
SARA
TCE
TCL
µg
USACE
WasteLAN
Section
Code of Federal Regulations
Contract Required Quantitation Limit
Dichlorodiphenyldichloroethylene
Dichlorodiphenyltrichloroethane
United States Environmental Protection Agency
Feasibility Study
Hazard Ranking System
Interagency Agreement
Kilogram
Liter
Milligram
North Carolina Groundwater Quality Standards
National Oil and Hazardous Substances Pollution Contingency Plan
National Priorities List
Parts Per Billion
Parts Per Million
Potentially Responsible Party
Remedial Action
Remedial Design
Remedial Investigation
Record of Decision
Remedial Project Manager
Superfund Amendments and Reauthorization Act of 1986
Trichloroethene
Target Compound List
Microgram
United States Army Corps of Engineers
The Regional database related to CERCLIS
111
• Five• Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Executive Summary
This report documents the first five-year policy review of the National Priorities List
(NPL) site NCD981023260. The site, referred to as Geigy Chemical Corp. (Aberdeen Plant), is
a former pesticide formulation and retail sales site located in Aberdeen, Moore County, North
Carolina. The site is approximately one acre in size. Contaminants of concern originally
associated with groundwater at the site are pesticides including aldrin, BHC isomers, dieldrin,
endrin, toxaphene, and the solvent trichloroethene (ICE). Subsequent investigations showed
that trichloroethene contamination was not a result of site activities and was therefore removed
from the Site Target Contaminants List (TCL). There was also soil contamination involving the
same pesticides listed for groundwater and the additional compounds, DDD, DOE, DDT, and
chlordane isomers. These contaminants are the result of use of the site for pesticide formulation
and blending and agricultural chemical sales from 1947 to 1989.
In March 1988, an EPA Site Investigation.in support of the Hazard Ranking System
(HRS) was conducted on the site. Isomers of BHC were found in groundwater samples from
three municipal and two private wells. Based on the results of the site investigation, the site was
proposed to the National Priorities List (NPL) in June 1988 and listing was finalized October 4,
1989.
There were three removal actions associated with the site for soil remediation. The first
two, conducted in 1989 and 1991, removed soils visibly contaminated and other debris from the
site. Approximately 3,300 tons of soil and debris were removed for disposal in these two
actions. Following the preparation and finalization of a Remedial Investigation/Feasibility
Study, a Record of Decision (ROD) was signed August 27, 1992. The Remedial Action
implemented by the ROD included demolition of the former warehouse foundation; excavation
of the top foot of on-site soils contaminated above performance standards; off-site disposal of
excavated soils as appropriate; extraction of groundwater from the surficial and Upper Black
Creek aquifers; treatment of extracted groundwater via carbon adsorption; site restoration; and
further sampling and analysis of the Upper Black Creek aquifer to determine extent of pesticide
contamination and determine ifTCE found in two wells was site-related.
The Remedial Action (RA) was implemented from September 1996 to February 1997.
The RA included removal of concrete foundations and other debris totaling approximately 2,460
tons to a Subtitle D landfill; disposal of 4,475 tons of contaminated soils to a Subtitle C landfill;
construction and installation of extraction wells and groundwater treatment facilities with an
infiltration gallery for discharge of treated groundwater. The treatment system began operation
in January 1997 and has currently treated approximately 30 million gallons of extracted
groundwater from the surficial and_ Upper Black Creek aquifers.
As required in the ROD, a downgradient investigation was conducted to determine the
extent of pesticide plumes in the Upper and Lower Black Creek aquifers. The results of the
investigation, reported in the Downgradient Groundwater Remedial Action Work Plan (RA WP),
and the recommendations therein, were adopted by EPA through the issuance of the January
1998 Explanation of Significant Difference (ESD). The ESD established that the downgradient
groundwater contaminant plume would be monitored as part of the overall site remedy. The
• Five-Year Review
Geig;; Chemical Corp. (Aberdeen Plant), Aberdeen, NC
selected remedy for the downgradient area is monitored natural attenuation of the plume with the
following contaminant concentration goals: alpha-, beta-, and delta-BHC 0.05 µg/L
(micrograms per liter), and gamma-BHC 0.20 µg/L.
There were several issues identified during the review process. None of the issues affect
the assessment of the performance of the remedy. However, each should be addressed before the
next five-year review. The issues are described as follows:
1. Fencing and signing of the site as proposed in the documents of record have not been
accomplished. This proposal was prepared prior to completion of the soil remediation and may
no longer be applicable.
2. The Site Groundwater Remediation Permit issued October I, 1999 and expiring June
30, 2004, needs to be changed to reflect that the treatment facilities consist of seven (7) recovery
wells rather than the five ( 5) listed.
3. Evidence indicates encroachment of the off-site trichloroethene (TCE) contaminant
plume into the site treatment area. Increasing TCE levels have shortened the life of carbon
adsorption canisters in the treatment facility, however, the long-term effects of this change on the
remedy are unknown.
The remedial actions at the Geigy Chemical Corp. (Aberdeen Plant) site currently protect
human health and the environment. The soil remediation for the site has been completed, and the
pump-and-treat remediation of the groundwater contamination including monitoring is
continuing. The trends of contaminant concentrations in groundwater both at the site and in the
downgradient area appear to be downward. Performance standards for contaminants of concern
are exceeded in the monitoring wells for the area under remedy implementation. To ensure long-
term protectiveness of the selected site remedy, continued monitoring and operation of the
groundwater treatment facility should continue.
V
• • Five-Year Review
Gei!J Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Five-Year Review Summary Form
Five-Year Review Summary Form
Site Identification
Site Name: Gei0 " Chemical Com. (Aberdeen Plant)
EPA ID: NCD98l927502
Reoion: 4 I State: NC I CitylCountv: Aberdeen/Moore
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NPL status: ✓ Final D Deleted n Other:
Remediation Status: D Under Construction D Operating D Comnlete
Multiole OUs?• D YES ✓ NO I Construction Completion Date: Seotember 27, 2000
Has site been put into reuse? D YES ✓ NO
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Reviewinl! al!encv: ✓ EPA 0 State D Other:
Author name: Stacv Samuelson .
Author title: Biologist I Author affiliation: USACE, Wilmin~ton Di<liict
Review oeriod:** 1103 -9/03
Datelsl of site inspection: Februarv 17, 2003
Type of review:*** 0 Statutory
✓ Policv
Review number: ✓ l (first) 0 2 (second) D 3 (third) D Other ( snecifvl
Triggering action:****
✓ Other (soecifv) Prelimin·-Close-Out Renort
Trinnerine action date: Julv 20, 1998
Due date (five vears after triooering action date): Julv 20, 2003
Five-Year Review Summary Form
Issues:
I. Fencing and signage for the site as proposed_ in the documents of record have not been implemented.
2. Site Groundwater Remediation Permit needs to be modified to reflect actual number of wells associated
with the treatment facility.
3. Encroachment of the off-site trichloroethene (TCE) contaminant olume into the site treatment area.
Recommendations and Follow-up Actions:
1. The need for fencing and signage of the site was negated by re~oval of the contaminated soils during
the remedial action. No action should be taken.
2. The PRPs should update the Site Groundwater Remediation Permit when renewed in 2004.
3. Monitoring of the affect(s) of the TCE plume on the site remedy should continue, with close
coordination bv all oarties.
Protectiveness Statement(s):
The remedy at the Geigy Chemical Corp. (Aberdeen Plant) Site is expected to be or is protective of human
health and the environment, and in the interim, exposure pathways that could result in unacceptable risks are being
controlled. The next Five-Year Review should be scheduled five years from the date of this Review, in "MONTH"
2008.
Other Comments: None.
• "OU" refers to operable unit.
•• Review period should correspond to the actual start and end dates of the five•year review in WasteLAN.
"' See Chapter I, Section 1.2 of EPA 540-R-01-007, Final June 2001 for further explanation.
"" See Chapter I, Section 1.3 ofEPA 540-R-01-007, Final June 2001 for further explanation.
Approved By:
(i inston A. Smith '
1'Director, Waste Management Division
U.S. EPA Region 4
0
I. INTRODUCTION
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
FIVE-YEAR REVIEW REPORT
The United States Environmental Protection Agency (EPA) Region 4 has completed a
five-year review of remedial actions implemented at the Geigy Chemical Corp. (Aberdeen Plant)
site in Aberdeen, Moore County, North Carolina. The United States Army Corps of Engineers
(USACE) conducted and provided technical assistance and analysis for the five-year review.
The Environmental Resources Section, Planning and Environmental Branch, Technical Services
Division of the Wilmington District, Wilmington, North Carolina provided the USACE lead for
this review. The review was accomplished under EPA Work Authorization Form for
Interagency Agreement (!AG) Number DW96945884A. The Wilmington District was supported
in the conduct of the review by the USACE Hazardous, Toxic and Radioactive Waste Center of
Expertise (CENWO-HX-G) located at the Omaha District, Nebraska. This review was
conducted from January 2003 through September 2003. The report documents the results of that
review.
The purpose of five-year reviews is to determine whether the remedy at a site is or is
e)(pected to be protective of human health and the environment. The methods, findings, and
conclusions of reviews are documented in five-year review reports. In addition, five-year review
reports identify issues found during the review, if any, and recommendations to address them.
This review is a policy review. EPA must implement five-year reviews consistent with
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and
the National Oil and Hazardous Substance Contingency Plan (NCP). CERCLA § 12l(c), as
amended states:
If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such remedial
action no less often that each five years after the initiation of such remedial action to
assure that human health and the environment are being protected by the remedial action
being implemented.
The NCP part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR) states:
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after the initiation of the selected remedial action.
Although not required by statute, this review is being conducted in accordance with EPA
policy. EPA conducts five-year reviews as a matter of policy at:(!) sites where no hazardous
substances will remain above levels that allow unlimited use and unrestricted exposure after
completion of remedial actions, but the cleanup levels specified in the Record of Decision
(ROD) will require five or more years to attain; (2) sites addressed before Superfund
Amendments and Reauthorization Act (SARA) at which the remedy,upon attainment of cleanup
levels, does/will not allow unlimited use and unrestricted exposure; and (3) removal-only sites
where hazardous substances remain onsite at levels that will not allow unlimited use and
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
unrestricted exposure. This site has been reviewed because cleanup levels will require more than
five years to attain.
This is the first five-year review of the Geigy Chemical Corp. (Aberdeen Plant) site. The
Site has been identified as requiring a "policy" five-year review, which must occur within 5
years after completion of construction. Completion of construction, as designated by signature
of the Preliminary Close-Out Report occurred on July 20, 1998.
This review will be placed in the EPA site files and local repository for the Geigy
Chemical Corp. (Aberdeen Plant) site. The local repository is located at the Aberdeen Town
Hall, 115 N. Poplar St., Aberdeen, NC 28315.
II. SITE CHRONOLOGY
Table 1 lists the chronology for selected events for the Geigy Chemical Corp. (Aberdeen
Plant) site, as shown below.
Table 1: Chronology of Events
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Site leased bv several comoanies for oesticide formulation and retail sales. 1947 to 1989
EPA detected pesticides in surface and subsurface soils on the site. Januarv 1987
Site insncction conducted by the State. March 1987
Preliminarv site assessment. June 1987
Hazard Ranking System (HRS) evaluation. August 1987
Site oronoscd to be listed on the National Priorities List (NPL ). June 1988
Site added to National Priorities List (NPL). October 4, 1989
PRPs conducted a soil removal action. 462 tons of soil and debris removed. February 23, 1989 to
December I 6, I 989
Administrative Order on Consent issued. January 23, 1991
Second soil removal action by PRPs. 2,841 tons of soil and debris removed. February 25, 1991 lo
June I, 1991
Human Health Risk Assessment and Ecological Risk Assessment completed. March 13, 1992
PRP preparation of Remedial Investigation and Feasibility Study (RI/FS). December I 6, 1988 to
August 27. 1992
Record of Decision (ROD) signed. August 27, 1992
Consent Decree for PRPs to conduct remedial desi1m/remedial action (RD/RA) July I 5, 1993
RA contract for construction of groundwater remediation system and removal of contaminated soil September I 996
and debris awarded bv PRPs.
Pre-final inspection of soil remediation by EPA and State of North Carolina. January 15, 1997
Groundwater Remediation Svstem ooerational. January I 997
Final inspection of soil remediation by EPA and State of North Carolina. Februarv 26, 1997
Downgradient Groundwater Remedial Action Work Plan aonroved by EPA and NC DENR. November 1997
Exolanation of Significant DifTerences issued bv EPA. Januarv 1998
Preliminary Close-Out Report Julv 20, I 998
Additional monitoring well installation. Aoril 1998
Site insoection for the first five-vear review. February 18, 2003
III. BACKGROUND
A. Physical Characteristics
The Geigy Chemical Corp. (Aberdeen Plant) Site is located just to the east of the
corporate limits of Aberdeen, North Carolina in southeastern Moore County (Figure 1 ). The Site
2
• ·Five-Year iVview
Geigy Chemical Corp, (Aberdeen Plant), Aberdeen, NC
is located on the Aberdeen and Rockfish Railroad right-of-way adjacent to Highway 211 and
forms an elongated triangle with the highway and railroad forming the apex.
The Geigy Site encompasses an area of approximately one acre that has been graded to
be mostly level in nature (Figure 2). The site has topography typical of the Upper Coastal Plain
physiographic region, with shallow water tables and low topographic relief. Soils in the area are
classified as the Candor sand type that overlays unconsolidated sandy to clayey sediments.
There are also an intermittent clay zone and several other clay lenses that divide the surficial
groundwater aquifer from the Upper and Lower Black Creek aquifers in the area. Drainage from
the site and predominant groundwater flow is to the west and northwest with both surface and
subsurface runoff entering McFarlands Branch, Ray's Mill Creek, and Aberdeen Creek.
B. Land and Resource Use
Current land use of the area is rural residential and commercial in nature. The city of
Aberdeen has approximately 3,400 residents. The Moore County area has grown approximately
18% in the last ten years and may continue to do so. Based on current levels of development of
the area, it is not foreseen that there will be any major change in land-use in the future.·
Figure 1. General Location
N
'·
3
•
C. History of Contamination
• Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
The Geigy Site was leased for the formulation and retail sale of pesticides from 194 7
until its closure in 1989. Agricultural fertilizers in bulk and bagged form were also distributed
from the site during its operational history. The pesticides DDT, toxaphene, and BHC were
formulated for field use on-site by mixing with inert materials such as clay and repackaged for
sale in the local agricultural market.
An EPA Site Investigation was conducted in March 1988 in support of the Hazard
Ranking System (HRS) evaluation of the site. Isomers of BHC were found in groundwater
samples from five locations: three municipal wells and two private wells.
4
Figure 2. Specific Site Location
l
ABERDEEN
POP. 3,578
I
)
• i i i •
J.tcFarlaltd'.~ Brondt
.'\'5 1IJ 'i;'
"'. ; 2072';_ 2073
/ Sandhill~
. ...-(' of ChrTst
" ? ""
Five-Year &view
Geigy Chemical_Co,p. (Aberdeen Plant), Aberdeen, NC
-2074 ?
--
--L 7
\ r--I --\
\
,_
\_ SolJthem Pines City Limit I\.----Aberdeen City Limit
I
I <6>
~-t,
Mt. Ledmon Holy
C~ist
<\. --
Geigy Chemical Corp.
(Aberdeen Plant) Site
N
o ____ o_.1s -o,;3 Miles W+ E
-...,
~
I
/
Basema Source: NCDOT Division of Hi hwa s-GIS Unit S
5
•
•
D. Initial Response
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
As discussed briefly in Section C above, the Environmental Protection Agency (EPA)
conducted a Site Investigation of the site in March 1988 in support ofa Hazard Ranking System
(HRS) evaluation.
The site was proposed to be included on the National Priorities List (NPL) in June 1988
and final designation was completed October 4, 1989. During that time, notice letters were sent
to six companies: Ciba-Geigy Corp, Olin Corp, Kaiser Aluminum & Chemical Corp, Lebanon
Chemical Corp, Aberdeen and Rockfish Railroad, and Columbia Nitrogen Corporation. The
notice letters requested that the Potentially Responsible Parties (PRPs) conduct a Remedial
Investigation and Feasibility Study (RJ/FS) for the site. An Administrative Order on Consent
(AOC) was entered into by EPA and three of the PRPs (Ciba Geigy {currently Syngenta Crop
Protection, Inc.}, Olin Corp, and Kaiser) for performance of the RI/FS on December 16, 1988.
IV. REMEDIAL ACTIONS
A. Remedy Selection
The remedial actions in the Record of Decision (ROD) dated August 27, 1992, provided
for remediation of contaminated soils and groundwater. The remedial actions identified in the
ROD were as follows:
Groundwater
The groundwater remedy was targeted at removal of site-related contaminants in the
groundwater through groundwater extraction and on-site treatment by chemical means and air
stripping. The following activities were identified as being associated with this alternative:
♦ Contaminated groundwater would be extracted from within the Surficial and Upper
Black Creek aquifer plume via extraction well(s) and piped to an on-site, aboveground
treatment facility.
♦ Treatment would consist of carbon adsorption canisters to remove contaminants of
concern.
♦ Final discharge of the effluent would be to either an on-site infiltration gallery or via
connection to a Publicly Owned Treatment Works (POTW).
♦ Continued analytical monitoring of contaminants in groundwater.
♦ Further characterization of the Upper Black Creek aquifer to determine the extent of
pesticide contamination.
The remedy.for contaminated soils had the intent of permanently removing
contamination in the soil through off-site disposal of contaminated soils. The following
activities were identified as being associated with this alternative:
6
• Five• Year Review
Gei!J Chemical Corp. (Aberdeen Plant), Aberdeen, NC
♦ Excavation of the top foot of soils exceeding cleanup standards identified in the ROD.
♦ Disposal of contaminated soils in a secure landfill or a fixed-base incinerator
depending on their regulatory requirements.
♦ Confirmation sampling and analysis to ensure that remediation levels are attained.
+ Backfill of excavated areas with clean fill, regrading of site and revegetation with
native grasses.
Tables 2 and 3 show the clean-up standards for soil and groundwater under the ROD.
Table 2. Soil Clean-Up Standards
Soil Clean-U o Standards
Contaminant Clean-up Standard (mg/Ko)
Aldrin 0.113
Aloha-BHC 0.28
Beta-BHC 1.15
Delta-BHC NC
Gamma-BHC 1.5
Oieldrin 0.13
Endrin Ketone NC
Toxaphene 2.0
ODD 7.6
DDE 5.5
DDT 4.75
Gamma-Chlordane 1.43
Alpha-Chlordane 1.4
* Note: NC = Not Calculated.
Table 3. Groundwater Clean-Up Standards
Groundwater Clean-UP Standards
Contaminant Groundwater Clean-Up Corresponding Risk Basis of
Standard (µ!!IL) Level Goal
Aldrin 0.05 5.0 X 10'0 CRQL
Aloha-BHC 0.05-J J X 10'0 CROL
Beta-BHC 0.05 4.0 X 10'' CROL
Delta-BHC 0.05 ND CRQL
Gamma-BHC 0.05 3.0 X 10·1 CRQL
Dieldrin 0.1 8.3 x 10·0 CRQL
Endrin Ketone 0.1 ND CRQL
Toxaohene 1.0 6.7 X 10'0 NCGWOS
CRQL -Contract Required Quantitation Limit
NCGWQS -North Carolina Groundwater Quality Standards
ND -Not Determined, Toxicity data unavailable, risk levels could not be calculated.
7
• • Five-Year Review
Geigj Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
The soils removal remediation was completed in early 1997. Site restoration was
conducted in January 1997. A final inspection by EPA and the State of North Carolina Division
of Superfund occurred on February 26, 1997.
Based on results of the pre-remedial design field investigation, showing the presence of
pesticides in the Upper Black Creek aquifer, additional investigations of the downgradient areas
were conducted. A Downgradient Groundwater Investigation Work Plan (Rust, 1995) was
prepared and presented to the EPA and NCDENHR to determine type, distribution and
concentration of pesticides in the downgradient areas. Field investigations for the downgradient
groundwater studies were conducted from March to October 1995. Results of the investigation
were reported in the Downgradient Investigation Summary Data Report dated March 1996.
The PRPs and Agencies met in May of 1996 to discuss preparation of a remedial action
plan for the downgradient area and agreed to develop a Remedial Action Work Plan (RA WP)
that would evaluate the containment and attenuation of pesticide concentrations as a component
of the remedial action for the downgradient area. The resulting RA WP, finalized in November
1997, has the following objectives:
• reduce pesticide concentrations in downgradient groundwater to levels which are
protective of human health and the environment;
• ensure that Site-related pesticide concentrations in downgradient surface water and
stream sediments are protective of human health and aquatic receptors; and
• monitor drinking water supplies in the downgradient area to verify they are not
adversely impacted.
The RA WP defined the downgradient area as the portions of Upper and Lower Black
Creek aquifers bounded by McFarland's Branch, Aberdeen Creek, Ray's Mill Creek, and Trough
Branch. The surficial aquifer was excluded from the work plan. Data from the downgradient
groundwater investigations revealed that the BHC isomers were the only target pesticides
exceeding Federal or State drinking water standards or Site Performance Standards. As a result
of the analyses, the goal of the down gradient remedial action is to reduce BHC isomer
concentrations to levels below the North Carolina and Federal drinking water standards or, for
alpha-, beta-, and delta-BHC, which do not have established drinking water standards, to levels
below the groundwater Performance Standards listed in Table 3. The downgradient groundwater
Performance Standards are listed in Table 4.
Table 4. Downgradient Groundwater Clean-up Standards
Contaminant Clean-up Standard ( u!!/L)
Aloha-BHC 0.05
Beta-BHC 0.05
Delta-BHC 0.05
Gamma-BHC 0.20
The recommendations and proposed remedial Performance Standards for the
downgradient groundwater in the RA WP were implemented by issuance of an Explanation of
Significant Differences to the Remedial Action (ESD) in January of 1998. The different
8
0 • Five-Year Review
Gew Chemical Co,p. (Aberdeen Pla11t), Aberdeen, NC
performance standards for gamma-BHC (Lindane) between the site remedy (0.05 µg/L; Table 3)
and the downgradient remedy (0.2 µg/L; Table 4) reflect a change in the North Carolina
Groundwater Standards (Title 15A NCAC 2L .0202) between issuance of the ROD and ESD.
B. Remedy Implementation
There were three removal actions associated with the site for soil remediation. The first
two, conducted in 1989 and 1991, removed soils visibly contaminated and other debris from the
site. Approximately 3,300 tons of soil and debris were removed for disposal in these two
actions. The 1989 removal action consisted of two phases. In the February 1989 phase, material
removed was disposed of in the GSX landfill in Pinewood, South Carolina. The second phase in
October 1989, resulted in soils being incinerated at the Therma!Kem facility in Rock Hill, South
Carolina or being transported as hazardous waste to the Laidlaw Environmental Services Landfill
(Formerly GSX Services) in Pinewood, South Carolina. During the 1991 removal,
approximately 500 tons of soil were incinerated at the Rollins Facility in Deer Park, Texas. The
remainder of the soil and debris removed were disposed ofat the Chemical Waste Management
landfill in Carlyss, Louisiana. Following the preparation and finalization of a Remedial
Investigation/Feasibility Study, a Record of Decision (ROD) was signed August 27, 1992. The
Remedial Action implemented by the ROD included demolition of the former warehouse
foundation; excavation of the top foot of on-site soils contaminated above performance
standards; off-site disposal of excavated soils as appropriate; extraction of groundwater from the
surficial and Upper Black Creek aquifers; treatment of extracted groundwater via carbon
adsorption; site restoration; and further sampling and analysis of the Upper Black Creek aquifer
to determine extent of pesticide contamination and determine if TCE found in two on-site wells
was site-related.
The Remedial Action (RA) was conducted from September 1996 to February 1997. The
RA included removal of concrete foundations and other debris totaling approximately 2,460 tons
to a Subtitle D landfill in Kernersville, North Carolina; and disposal of 4,475 tons of
contaminated soils to a Subtitle C landfill in Pinewood, South Carolina; construction and
installation of extraction wells and groundwater treatment facilities with an infiltration gallery
for discharge of treated groundwater. The treatment system began operation in January 1997 and
has currently treated approximately 30 million gallons of extracted groundwater from the
surficial and Upper Black Creek aquifers.
C. System Operations / O&M
After completion of the remedial action in 1996, the site was revegetated with native
species and planted long-leaf pines. Since establishment of vegetation, the site has not
experienced erosion or other problems, but recent ice storms have necessitated the removal of
some of the trees. Currently, the site is mowed twice a year to maintain a neat appearance along
the right-of-way for NC 211.
As required in the ROD and ESD, the PRPs have been operating a pump ai1d treat system
for remediation of the surficial and Upper Black Creek Aquifers since January of 1997 and
monitoring the downgradient areas since April of 1998. Figure 3 shows a conceptual flow model
9
0 • r'-.ive-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
of the pump and treat system. Since commencement of groundwater treatment operations,
Pinnacle Consulting Group of Greenville, South Carolina has had the treatment monitoring and
O&M contract for the PRPs. Initial monitoring requirements called for quarterly sampling for
the first three years followed by semi-annual sampling for an additional two years. Following
submission of the Downgradient Remedy Summary Report to the State and EPA in 2001, it was
agreed by all parties that annual monitoring could be undertaken. Therefore, the most recent
round of monitoring well sampling occurred in October of 2002. Monitoring well and surface
water sampling locations are shown in Figures 4 and 5. Wells that are currently sampled for
monitoring are as follow:
• Surficial Aquifer: MW-4S, MW-5S, MW-6S, MW-I0S;
• Upper Black Creek Aquifer: MW-1 lD, MW-18D, MW-30D, MW-19D, MW-20D, MW-
22D, MW-23D, MW-24D, MW-25D, MW-26D, MW-35D, MW-29D, MW-34D; and
o Lower Black Creek Aquifer: MW-22L, MW-25L, MW-27L, MW-37L, MW-40L, PZ-2,
PZ-3, MW-28L, MW-3 IL, MW-38L, MW-39L, MW-32L, PZ-5, MW-36L.
Figure 6 depicts the locations of the extraction system pipelines, treatment building, and
infiltration galleries.
Since initiation of operation of the pump and treat system in January 1997, there have
been few problems or breakdowns of the system. In a phone conservation with Mr. Art
Barnhardt ofNCDENR July 30, 2003, Mr. Samuelson was informed that there are no specific
records for the site delineating percent downtime versus operating time. Mr. Barnhardt also
indicated that the site treatment system has operated with what he considers as "normal"
maintenance issues such as the occasional replacement of an extraction pump or activated carbon
barrel train. The 1992 ROD forecast an estimated annual O&M cost of $50,000 per year of
operation. As currently implemented the treatment and monitoring program costs approximately
$48,000 -$50,000 annually to operate. The system has treated approximately 50 million gallons
of groundwater, operating at a pumping rate of 15-18 gallons per minute. The infiltration gallery
contains 3 laterals; each being 175 feet long. The distribution of flow within the gallery is
determined by a preset timer that activates solenoid valves at the gallery header. The timer is set
to direct flow to two of the laterals at a given time. It alternates flow among the three laterals on
an 8-hour cycle. As operated, each lateral will receive an average of half of the effluent from for
16 hours and no flow for the following 8 hours. The flow cycle is as follows:
First 8 hours: Flow to laterals I and 2;
Next 8 hours: Flow to laterals 2 and 3; and
Next 8 hours: Flow to laterals 3 and I.
The change-out/longevity period for the carbon adsorption canisters was initially one
year, but has shortened to a six month l!me period. It is suspected that this change is due to
increasing levels of Trichloroethene (ICE) coming from up gradient of the site. No significant
differences in O&M costs, as projected in the ROD and ESD, were identified. At this time, it is
expected that operations will continue without modification or increased expense until
remediation is complete.
10
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Figure 3. Flow Model of the Pump and Treat System
Extraction Wells (7)
Equaliza1ion ·rank
Carbon Adwrption Canis;cers;
Carbon Adsorption Cunistcrs
11
~loni101ing
Discharr;i: It)
lufillnition Gnllcric~ (2)
Figure 4. Monitoring Well and Sampling Locations_
·~~;1~>
' ~ ~ -· . --
MW-37L
0
MW-40L
<:,l,SW-03
~
MW-25D
SW-10
MW-28L
MUW-2 0
MW-27L
0 -
0 MUW-1
r'lve-Year Review
Ge,:ry Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Geigy Chemical Corp. (Aberdeen Plant)
Remediation Program
l!l Lower Black Creek Aquifer Monitoring Wells
@ Upper Black Creek Aquifer Monitoring Wells
o Surficial Aquifer Monitoring Wells
lg) Extraction Wells
<i? Surface Water Monitoring Points
o Municipal water Wells
500 250 0
'"q MW-36L
500 ~000
MW-34D
"
W•19D
1,500
l~aet
~ MW-25L
\
MW-26D
©
MW-22D 0 MW-22L
MW-20D .,
" MUW-4
rB
" li'l r;;i
12
MW-35D
SW-01~ @
MW-24D
" MW-23D
"
0
0 0
See Flgure5
•
Figure S. Site Area Monitoring and Extraction Well Locations
j
MW-1!l0@,
• PWC2D
• PW-3D
MW-1103 • PW-1D
Geigy Chemical Corp. (Aberdeen Plant)
Remediation Program Immediate Vicinity
• Extraction Wells
0 Surficia/ Aquifer Moniton"ng Wells
~ Upper Black Creek Aquifer Monitoring Wells
MW->OS 0
100 50
MV,.,S ·• • PW-15
• PW-2S
MW-105 e
0 PW.JS
MW-17S
0
0 100
13
MW-165 -~
200 300 400
Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
MW-t6DQ
MW-1700
500
Feet
•
•
Figure 6. Extraction System and Treatment Facility Diagram
F
E
D
C
B
\
CXIST1NI. -•Ill
~~­
EXISTI)tG wnt. 1'011(1' PIEZCNCT[R ---· ---~ wru f1)IICt iwM -1. T0l'0 wo.f'l'lffl. IJf WOOLPDl1 C'OIIWI.TMTS &UlP Q!I
..CRloll. ~111 n.DWM l<UCH n. 1 ,.,, ~
<;ROI/ND COl<fa<I\. ntD TO ~ ~~rt l'LAHE Cl)Cf!Dl><An; =~
~ l'U.l<U<CTR1C FU,llll!B W[R{ nn.r, l(lomncll
OM ,._.y 111. t,n fY ..oou'UT c:o,:;,,&J~
:i.. ro11 TTl'ICAL TttHCH cross sa;ooN set
~ .. ..canu--c...u.
4.1.0C&.llOII Cr..::ctS$RO&Cs,,a,rl<CIITlll$plll,"1NI. IS _....,QU.~ i:x.o,;r UICATICM nJ.. !IC C)[lOIO'U<£D .. rn, F'E.ll
ff C•l'l<U"5 •!Plt£5V<TATIVL roll ~ DCTA.l. S[t
TTPICAl I.RAVO. IIO,ll!I C1t05S :!CCTI0II 011 OR,UID<G BH1•--C..<)<.
A ... ..,. -IU -,,.,...,.,
L___ --
.,.._ .,..
14
Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
.--·
EXTRACTION ANO
TREAHCENT SY.STU.I
SIT£ LAYOUT
(:V(IT Clll;IIIC,\L COl!F'OIIATIO!I sat ......,.__~
....... ENVJRONM!Nf. I._U>I INFRASTRIJCT'JRE ---..... .., ,.,
~:&"" 86619-C-02 ~-""' ... --.. ,-,,._......,,,._
F
E
D
C
E
•
•
•
V. Progress Since the Last Five-Year Review:
.Five-Year Revie1v
Geig;; Chemical Co,p. (Aberdeen Plan~. Aberdeen, NC ·
Since this is the first Five-Year Review Report, no other report is available and thus no
progress is reportable.
VI. FIVE-YEAR REVIEW PROCESS
The five-year review process for the Geigy Chemical Corp. (Aberdeen Plant) site
included telephone discussion/interviews with the EPA Remedial Project Manager (RPM), and
the lead State agency. Also included, were a visit to the Aberdeen Town Hall, the public
repository for the remedial action documents, and a site visit for familiarization with the
remediation activities. A list of pertinent materials from the document repository and other
sources is provided in Attachment 1.
The following persons were members of the five-year review team:
+ Greg Mellema, Hazardous, Toxic, and Radioactive Waste Center of Expertise
(CENWO-HX-G), Omaha, NE, for QA of document preparation.
♦ Phil Payonk, Wilmington District, Environmental Resources Section (CESA W-TS-
PE).
♦ Stacy Samuelson, CESA W-TS-PE.
VII. FIVE-YEAR REVIEW FINDINGS
A. Interviews
The following persons were interviewed regarding the activities and implementation of
the remedial actions at the Geigy Site:
Mr. Jon Bornholm, Remedial Proiect Manager, EPA Region 4:
In several telephone conversations between Stacy Samuelson and Mr. Bornholm, several
issues pertaining to the Geigy Site were identified. The concern for potential effects on the
remedy due to the off-site TCE plume migration into the site area was identified. A second
issue, full implementation of the Record of Decision in terms of fencing and signage at the site,
was addressed as well. Additional discussion of these issues are provided in Sections IX, Issues,
and X, Recommendations and Follow-up Actions.
Mr. Randy McElveen, Environmental Engineer, North Carolina Department o(Environment and
Natural Resources, Division o(Waste Management, Superfund Federal Remediation Branch:
Stacy Samuelson, Wilmington District, made initial contact with Mr. McElveen through a
telephone conversation. Mr. McElveen indicated that the State has no major issues with the site
at this time. At the site visit, the issue of the off-site TCE plume was discussed in relation to the
site remedy. The State has some concerns about the undefined source of that plume and its
potential effects on the Geigy Site remedy.
15
•
B. Site Inspection
• Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
A site inspection of the Geigy Site was conducted on February 18, 2003. Attending the
site visit were:
♦ Randy McElveen, Environmental Engineer, North Carolina Department of
Environment and Natural Resources, Division of Waste Management, SF Federal
Remediation Branch.
♦ Jon Bornholm, Remedial Project Manager, Environmental Protection Agency, Region
4.
♦ Ray Horn, Olin Corporation.
♦ Harold Moats, Syngenta Crop Systems.
♦ Michael Sheehan, Pinnacle Consulting Group.
♦ Ted Volskay, Pinnacle Consulting Group.
♦ Ray Livermore, U.S. Army Corps of Engineers, Wilmington District.
♦ Phil Payonk, U.S. Army Corps of Engineers, Wilmington District.
♦ Stacy Samuelson, U.S. Army Corps of Engineers, Wilmington District.
For documentation of the site visit, photos of the treatment facility and several extraction
wells were taken and are attached as Attachment 2.
The site area has not been re-developed since the source remedial action was completed in
1996. The area is currently vegetated with grasses and some long-leaf pines have been planted
along the railroad right-of-way. Mr. Sheehan gave a brief historical overview of the activities
and locations of facilities during the source remedial action and provided a tour of the pump-and-
treat facility.
C. ARAR Review
In performing the five-year review for compliance with applicable or relevant and
appropriate requirements (ARARs), only those ARARs addressing risk posed to human health or
the environment (i.e., addressing the protectiveness of the remedy) were reviewed. This is in
keeping with current EPA guidance on five-year reviews.
Federal ARARs
♦ Federal Groundwater Classification -55 Federal Register (FR) Part 8733.
♦ Safe Drinking Water Act of 1986, as amended ( 40 USC § § 300) -40 CFR Part 141.
♦ Solid Waste Disposal Act (40 USC§ 6901 -6987)-40 CFR Part 261.
♦ EPA Regulations on Sole-Source Aquifers-40 CFR 149.
State ARARs
♦ Identification and Listing of Hazardous Waste-!SA NCAC 13A.0006.
♦ North Carolina Drinking Water Act-General Statutes, Chapter 130A, Article IO.
16
• • Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
♦ North Carolina Water Quality Standards-15A NCAC 2B.
♦ North Carolina Groundwater Quality Standards-!SA NCAC 2L.0I00, 2L.0200,
2L.0300.
The site appears to be in compliance with the ARARs identified in the ROD. There were
no changes in the reviewed statutes and standards that would require changes in the remedy or
management of the site.
D. Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics
No changes in the site conditions that affect exposure pathways were identified as part of
the five-year review. There are no current or known changes planned in the land use and it is
likely to remain rural residential immediately adjacent to the site. No new contaminants,
sources, or routes of exposure were identified as part of this five-year review. There is no
indication that hydrologic/hydrogeologic conditions are not adequately characterized. The rate
of decrease of contaminant levels in groundwater is consistent with expectations, and the
groundwater plume appears to be contained. This finding is supported by groundwater flow
model simulations that were conducted by Olin Corporation and Syngenta Crop Protection to
evaluate the site groundwater extraction system with respect to pesticide capture during the
summer of 2003. Findings of the simulations were reported to EPA by letter report dated
September 15, 2003 by the Pinnacle Consulting Group. Data from the Preliminary Design
Report (Rust E&I, 1995) along with data from the monitoring program implemented in 1997 was
analyzed for the simulations. Due to groundwater level and recharge rate fluctuations, three
model iterations were run. The model runs were for minimum, average, and maximum
extraction rates. Figures 5, 8 and 11 of the letter report show the predicted capture zone areas for
the Upper Black Creek aquifer extraction wells (Attachment 3). The contaminants_ of concern in
both groundwater and soils were reviewed in the EPA's Integrated Risk Information System
(IRIS) for changes in toxicity. Review of the IRIS database revealed that toxicity and other
factors for contaminants of concern have not changed with the exception of the soil contaminant
chlordane. For that compound, the cancer slope factor decreased, and the reference dose
increased. However, since the soil cleanup was based on cancer risk, this would have resulted in
a slightly higher calculated soil cleanup value, and does not call into question the protectiveness
of the remedy.
E. Data Review
Based on issues identified during document review, interviews and site inspection, the
principal data reviewed were related to groundwater contaminant levels of the site and
downgradient area. The main resource for review of data was the Downgradient Groundwater
Remedial Action Work Plan, Geigy Chemical Corporation Site, Aberdeen, North Carolina
(RA WP) (November 1997) and groundwater monitoring data provided by Pinnacle Consulting
Group (October 2001).
17
•
Soil Data
• Five.Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Soil contamination data have not been collected since the completion of the Remedial
Action. Performance Standards for soils were met or exceeded as a result of the remedial action
and the results of final soil testing were reported in the Final Remedial Report For Soils (1997).
Groundwater Data
I
Groundwater sampling data was reviewed for sampling events occurring from May 1998
to the present. Wells were sampled quarterly for three years and then semi-annually for the last
two years. Samples were analyzed for organochlorine pesticides. Starting in 2003, with
coordination with the EPA and State, monitoring will be conducted annually. Over the
monitoring period, some wells have been abandoned or added and several, notably MW -11 D,
MW-18D and MW-30D, were unable to be sampled due to drought conditions in the third
quarter of 1998. Table 5 presents the detected values for BHC isomers in the surficial aquifer for
wells in the current monitoring program. Graphical representation of the data for each well is
presented in Attachment 4. Well MW-4S is probably not affected by the surficial aquifer
extraction wells, but the other surficial monitoring wells are close enough to extraction wells to
be influenced by them. The effect of the extraction wells influence on the surficial monitoring
well results is not known. Of the compounds on the TCL, the BHC isomers were the most
consistently detected over the sampling period. Most detected values exceed the site
performance standards (Tables 3 and 4).
18
• Five-Year Review
Ge1g)' Chemical Co,p. (Aberdeen Pla111), Aberdeen, NC
Table 5. Surficial BHC Isomer Concentrations in Groundwater Monitoring Wells 1990 -
2002
Samnle Dnte aloha-BHC beta-BBC delta-BHC ~amma-BIIC (l,indnne}
MW-4S 11/16/1990 I 3 6 0.5
MW-4S 12/8/1993 0.2B 2.1 4.7 0.066
MW-4S 12/3/1996 ND(l.25) 15 10 ND(I.25)
MW-4S 4/16/1997 ND(0.25) B.6' 7. I ND(0.25)
MW-4S 7/14/1997 0.16 6 7.2 0.1
MW-4S 10/1/1997 0.19 6.3 6.B ND(0.25)
MW-4S 4/21/1998 ND(l.25) 16 ND(l.25) ND(l.25)
MW-4S I 0/29/1998 ND(0.275) 4.2 2.8 ND(0.275)
MW-4S 10/14/1999 ND(0.025) 0.36 0.23 ND(0.025)
MW-4S I 0/13/2000 ND(0.125) 1.5 0.66 ND(0.125)
MW-4S 10/10/200 I ND(0.025) 0.013 ND(0.025) ND(0.025)
:rt· . -~~i;; ; ,~·1.' :··.e::·-:·_,-~_?,! ; ,. :., ~~'.~ _ _::·,: __ ;,_;-:· r:,.~~~,~~~.~~::·.: -' ., ' " " ~~-~:-'. . .')f,9~ ;,c~·-i . .... .. .,, ... ,,. ,'.\'-c"_:; .. ,, ,_, .. ,•.
MW-5S 11/16/1990 5 12 12 5
MW-5S 12/9/1993 I.I 17 6.3 ND(0.l)
MW-5S 12/3/1996 ND(l.25) 17 5.6 ND(l.25)
MW-5S 4/16/1997 ND(0.l) 9.5 3.1 ND(0.5)
MW-5S 7/14/1997 0.23 5 l.B 0.15
MW-5S 10/1/1997 0.16 3.9 1.3 ND(0.125)
MW-5S 4/21/1998 ND(0.25) 2.5 0.59 0.05
MW-5S 10/29/1998 0.31 B.6 2 0.25
MW-5S 10/14/1999 ND(0.125) 1.4 0.7 ND(0.125)
MW-5S 10/13/2000 0.047 3.2 1.4 ND(0.125)
MW-5S 10/10/200! ND(0.125) 1.3 0.17 ND(0.125)
'•'"" h•:••i'_ jt'~,. ·-i. _'.:'.:·_!>!~'f.i:A .. 1•::';-:·· ~~.;<•:Z. •,. n·-'· •" ' ..... (~~t~~•<~\ ·'' ·.:i:•'·-::-1:··1·,,_1•1; :,•, '.';, 1:i. :~/."'l-'.+;Jt:~~~ :·.: ·:;1'.\ ... _: ·.: .... . ---. .,.,, s
MW-6S \ 1/16/1990 36 12 29 30
MW-6S 12/9/1993 7 .I 9.6 9.2 6
MW-6S 12/3/1996 2.1 5.8 2.5 1.5
MW-6S 4/16/1997 2.2 6.6 1.6 1.3
MW-6S 7/14/1997 I.I 4.1 0.81 0.77
MW-6S 10/1/1997 1.3 3.8 I 0.83
MW-6S 4/21/1998 2.9 6.6 6 2.4
MW-6S 10/29/1998 t.B 7. I 4.6 I. I
MW-6S 10/14/1999 3.9 6.9 1B 2
MW-6S 10/13/2000 ND(0.025) ND(0.025) ND(0.025) ND(0.025)
MW-6S 10/11/2001 3.5 10 15 0.91
'.""'Ji°· '_;y\\f '."¥:!l''.,;:;:~.\ii·: i;;t'!..1:il:?~';1}t." ,;,r~·t) ~~: ~:•~~::t;·:\}~;:;;.'}l(\;. ~ ~ /t1:,·='1~::::;;1#'1 c.:./~~-;;1 1~.,-,1;[,~t<'. <t• ~~,1--J'_,,";;J:'1;¥~~'!10 .:, ti, ':b.~ ;;1:'.-;'fJ.
MW-10S 7/10/1991 2 25 2 0.B
MW-10S 12/9/1993 ND(0.5) 14 0.79 ND(0.l\
MW-10S 12/3/1996 0.026 0.58 0.045 0.07
MW-10S 4/16/1997 ND(0.25) 5.2 ND(0.25) 0.BB
MW-10S 7/15/1997 0.1 I 1.7 0.12 0.35
MW-10S I 0/l /1997 0.59 4.4 0.47 I
MW-10S 4/21/1998 0.39 7 I .6 0.34
MW-10S 10/29/1998 0.085 4.5 0.41 0.11
MW-10S 10/14/1999 0.045 2.3 0.21 0.064
MW-10S 10/13/2000 ND(0.125) t.B 0.077 ND(0.125)
MW-10S 10/23/2002 0.01 0.56 0.027 0.014
Note: ;"I,. on-Detect va \ues represent one-half of the detection Jim it.
Values in bold denote detections exceeding performance standards (Table 3).
19
• • Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Tables 6 and 7 depict the concentration levels for the same compounds in the Upper
Black Creek and Lower Black Creek aquifers. Graphical representation of the data for the Upper
Black Creek Aquifer is found in Attachment 5 and the Lower Black Creek Aquifer in ·
Attachment 6.
Table 6. Upper Black Creek Aquifer S11mpling Results 1998 to 2002
Excccdcnces of Performance Standards for BHC Isomers
Well I 2Q9s I 3Q98 4Q98 1 t Q99 I 2Q99 3Q99 4Q99 I I Q00 2Q00 3Q00 I 4Q00 I tQ0t 4Q0I 2Q02
W e1IS·withil1'1tb"e' t'ifraC'tiollra'iid:fre'at'Oi"eri't'cap·tllr'e' i'Oii'e·,;lt\ :•_,:f ;., ""'"'•'' ~ , .. .,. ·-~\ :i, :r; .i-. ",I!'•; . ·: ;"t\!-i', _·1':, . > •. ,,•· ,.,_:
MW-11D t NS t NS t t t t t t t t NS NS
MW-18D t NS t NS t t t t t t t t t NS
MW-30D t t t NS t t t t t t t t t NS
4Q02
''"'.;;,\·~~
NS
NS
t
MOriitOriiig ·w·e11S'.f1fr.are8 lli)dtr re med);· iinpltnitrit8:tio"n',~ --'·._; ,: "';. t": ~ . ,ii; •• · : .';l J. ,/: ... ',r '::<:<_ ::·.~ :: -'i' /:_,';(! ,·Y, . J-.: .. ,, .... , . -.. ..
MW-190 A' A,B,G t t t t t t t A,G t A,D,G NS NS
.:\IW-20D A' t t t t t t t t t t t t t
MW-220 t t t t t t t t t t t t t t
MW-23D t t A,B,D t t t t t t t t t t t
MW-24D t B,G A,B,G t t t t A,B,G A,B,G t A,B,G t NS NS
MW-25D ND ND ND t t B,D,G ND ND ND ND ND ND NS NS
:\IW-26D t t t t t t ND t t t t t t t
MW-350 t t t t t t t t t t t t t t
Well ror assfssfu"ent of grOundW&ter'. quality__dOwngradie·nt'of tb·e Surficiftl nquifer,"Well M\\'.~33S ·::~·:_ ~.•:;.~-.( -.,
' T I MW-3401 ND
Well 2Q98
ND ND I B I B B B B B B I B B I
Table 7. Lower Black Creek Aquifer Sampling Results 1998 to 2002
Excccdences of Performance Standards for BIIC Isomers
3Q98 4Q98 IQ99 2Q99 I 3Q99 I 4Q99 IQOO 2QOO JQOO 4QOO I !QOI
NS NS
4QOI 2Q02
NS
t
t
t
NS
NS
t
t
·:•, ..
NS
4002
Sfntiriel .\\·tff for'.U""tr.·BiaCk.Creek /,..LoWel'iBlacli·creekAO.Uiferi Illtf:rface~;:·~~:;,; :1,:·-: ... :'.Ht~~--~,,.,~.,. : _: J ?~:iii£.:·::}~,;;·..,1 ;,L·)•,!f.i
MW-22Li t I t t t I t I t t I t t t I t I t t t t
M O iii tO r i i1 g ~w f!ll S: fo 'r. a· i-t a 'll rl d Cfr ., r'e"in e·d )' i lT1 p le m f: ii tiiti o·n":f'i:~-:;,j,j;W· ;~~.i_;;,1:;::;,J, ,i[li~~:;r't: 11~}1i:!:;!tii,1!}~; :it~~i~,)"r:,. ·1~, i'.w·l>:\, 1.,f,.: i'.-i1l~:~-;~ .~"1
t t t MW-2SL t t t t t t t t t t t t
MW-27L t t t t t t t t t t t t t t t
MW-31L t t t t t t t t t t t t t t t
MW-37L t t A/G t t t t t t t t t t t t
l\1W-40L t t t t t t t t t t t t t t t
PZ-2 t t t t t t t t t t t t t t t
PZ-3 t t t t t t t t t t t t t t t
PZ-5 ND t BIG A/BIG A/B/G t t AIB/G t A/BIG t t t t A/BIG
we us·, tO: for e·c·a st·' tT'iiii:I S: f O i. Ray'. s r M ill I Cree i.:;·•A li«iid ee 11 ~ C re e k,~·,rn d. M CF a r liiD d's. B r8 n Ch'~:;~;~ .. '.1'ih.,7r"J( .;;i-1;· !,~··11;-.; ,((;l'.;: :1;/( ,~:' /
t PZ-2 t t t t t t t t t t t t t t
PZ-5 ND t BIG A/BIG A/BIG t t AIB/G t A/BIG t t t t AIB/G
MW-31L t t t t t t t t t t t t t t t
SC.ii'tin·et:WCII' f(tf noithWi!f"d:ftsticidt inigiiition. an·d\fortCaSt Of co·nceiitr'atloD_trCn"ds In RBY!S,M ill Cre·ek"f:~>;;;'.~~•:tll:;:;t'.~~.
I t MW-28L A' A t· I t I t t t t A/8 I t I B/D/G t I t t
se-n tin·e1. W,ellf for ;noteri'tiiil' itiigriltiO'ii :or, p'tsticidfsTiito RaV: s'-l\-1 ill.Creek"' 1ind. AbCrdCCD .c reek-':.:,;'i_{:-., '::J:_~,~:~;: .A;,-;;:H A!.~~<.'.::·~~
MW-32L ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
MW-38L ND. t ND ND ND ND ND ND ND ND ND ND ND D ND
MW-39L ND t ND ND ND ND ND ND ND ND ND ND ND ND ND
se-n-ti ii'Cl .. w.eu if o l'j;T oW n. We II N 0) 2 :Fa.l'.\;fji]R.,;:,i.~t:·,U(.a;J\lJ;T,_~j;Jli:it~ik :~Eitiii,?t::-;;:s1i:siU!f.,,ilit:i'!i.:%~~~1.Ii'.\~1:;~;::~;;;~::i~~iiH~,;yt!1:,iit;i";-,!Llfil'.·!i~j;~
MW-36L ND I ND I ND ND ND I B I ND I ND I ND
Notes:
t Denotes all BHC isomers detected and exceeding perfonnance standards.
ND loenotes non-detect for all BHC isomers.
A -alpha-BHC, B -beta-BHC, D • deltn-BHC, G -gammn-BHC
• Letter only denotes that compound detected exceeding performance standard,
NS= Not Sampled.
20
ND I ND I ND ND ND ND
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Trends in the BHC isomer concentrations in downgradient groundwater are varied.
Several wells (MW-34O, MW-36L, MW-38L, and MW-39L) indicate no trend (little change) for
the 1998-2002 monitoring period. Monitoring well MW-35O decreased over the same
monitoring period. BHC concentrations for wells MW-3 70 and MW-40L slightly increased.
Data for the downgradient areas seem to reflect reductions in concentrations of contaminants for
the remedy area monitoring wells. However, BHC isomer concentrations were consistently
above perfonnance standards. Sentinel wells for Town Well No. 2 (MW-36L) and Ray's Mill
and Aberdeen Creeks (MW-32L, MW-38L, and MW-39L) have only four instances of BHC-
isomer detection during the monitoring period. Wells MW-38L and MW-39L had detection of
all BHC-isomers in the third quarter 1998 sampling event; well MW-36L had detection ofbeta-
BHC in third quarter 1999; and well MW-38L had detection of delta-BHC in second quarter
2002.
Due to the hydrology of the area, the Upper and Lower Black Creek aquifers discharge to
the following surface creeks: Aberdeen Creek, McFarland's Branch, Ray's Mill Creek, and
Trough Branch. Surface water sampling for the BHC isomers has been conducted since 1996 at
most of the sampling points shown on Figure 3. Table 8 lists sampling results for BHC-isomers
from the downgradient surface water monitoring stations. Graphs of the data for the surface
water san1pling sites are found in Attachment 7.
21
• • Five-Year &view
Geigy Chemtcal Corp. (Aberdeen PlanJ, Aberdeen, NC
Table 8. BHC-isomer Sampling Results for Surface Water Monitoring 1996 -2002
(:·· ?:\~Sitri;;.1". ~-: \~:s'li~ie o-~"tt:'. ~---~---:'-"~-.ri'-~,
""".:'lilnl:ia~BHG, :' : i·H:ra;BJIC ~--: r1~~rtt'.....,.'J.~ :"'delta~BHC"..
_:,·11.1;. ••,,·.:-,, ••>"11-',:'. ,,,;.;J;:
1 iiamm·ll-BHC.(Lin'danCl
SW-01 6/4/1996 0.025 0.025 0.025 0.025
SW-01 4/29/1998 0.025 0.025 0.025 0.025
SW-01 7/20/1998 0.025 0.025 0.025 0.025
SW-01 10/28/1998 0.026 0.005 0.026 0.026
SW-01 1/12/1999 0.025 0.0069 0.025 0.025
SW-01 4/12/1999 0.025 0.025 0.025 0.025
SW-01 8/10/1999 0.029 0.007 0.029 0.029
SW-01-re 8/10/1999 0.028 0.0055 0.028 0.028
SW-01 10/12/1999 0.025 0.025 0.025 0.025
SW-01 2/2/2000 0.025 0.025 0.025 0.025
SW-01 4/11/2000 0.025 0.0049 0.025 0.025
SW-OJ 7/21/2000 0.025 0.025 0.025 0.025
SW-01 I 0/14/2000 0.025 0.011 0.025 0.025
SW-01 1/9/2001 0.025 0.025 0.025 0.025
SW-01 10/9/2001 0.025 0.025 0.025 0.025
SW-01 4/9/2002 0.019 0.017 0.019 0.019
SW-01 I 0/25/2002 0.025 0.025 0.025 0.025
;•,•1·:·_-~:;/·i~~:· ,. :{;!·::~'.r:~}::;r-:~t ".', ;t ~ \!,' :;:,:;·::•;-: .. -:,:"/, ,···>.<··· .... ,,. ::/: ~-:.<·· '·:''.•!'j'(\ .. ~,:·0 ·:'/~:~'.:_r:. 1•'};\~ ';i-?il: .~! '!' l' ,•. j ,, : ,, ' ,.,,.,,
SW-02 6/4/1996 0.052 0.085 0.097 0.059
SW-02 4129/1998 0.032 0.055 0.066 0.031
SW-02 7/20/1998 0.03 0.07 0.076 0.027
SW-02 10/28/1998 0.036 0.073 0.079 0.036
SW-02 1/12/1999 0.038 0.064 0.07 0.036
SW-02 4/12/1999 0.032 0.067 0.075 0.031
SW-02 8/10/1999 0.046 0.12 0.11 0.055
SW-02-re 8/10/1999 0.041 0.096 0.092 0.042
SW-02 I 0/12/1999 0.012 0.054 0.053 0.011
SW-02 2/2/2000 0.029 0.042 0.051 0.027
SW-02 4/11/2000 0.025 0.052 0.053 0.032
SW-02 7/20/2000 0.032 0,075 0.071 0.03
SW-02 10/11/2000 0.031 0.068 0.067 0.025
SW-02 1/9/2001 0.035 0.068 0.072 0.028
SW-02 10/9/2001 0.02 0.054 0.049 0.017
SW-02 4/9/2002 0.048 0.11 0.11 0.04
SW-02 7/17/2002 0.017 0.05 0.046 0.025
SW-02 10/25/2002 0.014 0.045 0.039 0.025
Values are in µg/L.
Values in red exceed the remediation goals for the downgradient.area (Table 4).
22
•
Table 8 continued:
"':?~?Sii~\:·.:, ,., ... ,=.a,.•;,,..;,_,..i. -rt;
11: Sam-pie DntC~ _ i .. .,..~·-·~····--::...:.._•
: .. ali>lia-BHC1
SW-03 6/4/1996 0.044
SW-03 4/29/1998 0.034
SW-03 7/20/1998 0.027
SW-03 10/28/1998 0.029
SW-03 1/12/1999 0.034
SW-03 4/12/1999 0.032
SW-03 8/10/1999 0.034
SW-03-re 8/10/1999 0.029
SW-03 10/12/1999 0.014
SW-03 2/2/2000 0.028
SW-03 4/11/2000 0.029
SW-03 7/20/2000 0.03
SW-03 10/11/2000 0.027
SW-03 1/9/2001 0.033
SW-03 10/9/2001 0.02
SW-03 4/9/2002 0.048
SW-03 7/17/2002 0.015
SW-03 10/25/2002 0.014
t~t\t; :?' .. ,? r;,~,_~, ;,i. fH-ii.'._4-'<: .. :;~,i; ~t)~{~ ~-·t::, .:_*1:l>_ , ... , ._-,;._. ··' .-
SW-04 6/4/1996 0.025
SW-04 4/29/1998 0.011
SW-04 7/20/1998 0.013
SW-04 10/28/1998 0.0255
SW-04 1112/1999 0.0089
SW-04 4/12/1999 0.Q25
SW-04 8/10/1999 0.Q18
SW-04-re 8/10/1999 0.014
SW-04 10/12/1999 0.005
SW-04 2/2/2000 0.0087
SW-04 4/11/2000 0.017
SW-04 7/20/2000 0.015
SW-04 10/11/2000 0.025
SW-04 1/9/2001 0.QI
SW-04 10/9/2001 0.017
SW-04 4/9/2002 0.028
SW-04 10/25/2002 0.01
Values are 111 µg/L.
.~rt 81·1 C ~
0.055
0.043
0.052
0.048
0.Q45
0.05
0.077
0.062
0.022
0.033
0.044
0.063
0.046
0.053
0.044
0.087
0.042
0.037
,/:~Jt·.tt ·,;)~V
0.025
0.019
0.028
0.0255
0.016
0.021
0.048
0.033
0.0085
0.014
0.032
0.037
0.036
0.022
0.016
0.038
0.019
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
"· cf~1t':Bltf:, '.'.·,;~ ~imill:BiiC·cLirfd•urfe}·<"·
0.061 0.035
0.05 0.023
0.052 0.016
0.049 0.017
0.048 0.024
0.051 0.021
0.068 0.036
0.058 0.024
0.0215 0.0085
0.o35 0.019
0.045 0.02
0.054 0.021
0.043 0.015
0.056 0.019
0.041 0.011
0.088 0.031
0.036 0.025
0.029 0.Q25
·}•::,.:. ,.. ,. ' Pt~ ;;1;~)~t~ Jt·f1.,{~':¾(1!'.h ·,: r;. -.
0.025 0.025
0.022 0.025
0.027 0.025
0.014 0.0255
0.018 0.025
0.019 0.025
0.042 0.Q25
0.03 0.025
0.008 0.Q25
0.014 0.025
0.031 0.Q25
0.024 0.025
0.033 0.Q25
0.016 0.025
0.018 0.025
0.036 0.019
0.015 0.025
Values in red exceed the remediation goals for the downgradient area (Table 4).
23
•
Table 8 continued:
:~. ·. : , SRe \:..: r·~s-:iri'ot~o;;r,· ~-f~ . ....,,, ·t -~,i,
::·alohii-BHC ·:
SW-05 61411996 0,025
SW-05 712011998 0.012
SW-05 I 0/2811998 0.0255
SW-05 1/1211999 0.009
SW-05 411211999 0.025
SW-05 8/1011999 0.018
SW-05-re 8110/1999 0.014
SW-05 10/1211999 0.005
SW-05 21212000 0.0097
SW-05 411112000 0.018
SW-05 7/2012000 0.015
SW-05 1011112000 0.027
SW-05 1/912001 0.011
SW-05 101912001 0.017
SW-05 4/912002 0.027
SW-05 10125/2002 0.011
e/_ >:·r:-:: . .-~ :=~ .. ,."J~: .. ;.~{1:, ;•~~~-:·, ~l ;:': ,,
'
SW-06 61411996 0.025
SW-06 4/2911998 0.012
SW-06 712011998 0.013
SW-06 10/28/1998 0.0082
SW-06 1/1211999 0.0082
SW-06 4112/1999 0.025
SW-06 6/1511999 0,028
SW-06 8/1011999 0.016
SW-06-re 8/1011999 0.017
SW-06 10/12/1999 0.0055
SW-06 21212000 0.0087
SW-06 4/1112000 0.017
SW-06 7120/2000 0.016
SW-06 1011112000 0.026
SW-06 1/912001 0.011
SW-06 10/912001 0.014
SW-06 4/912002 0,028
SW-06 10125/2002 0.0091
Values are in µg/L.
•~.--,'•:t""""~~1, l 'b"etii-BHC ·
0.025
0,028
0.015
0.015
0.02
0.043
0.033
0.009
0.014
0.032
0,035
0.039
0,025
0.016
0.033
0.018 'i?. .. , .... , ' ..... ' .. ,,
0.025
0.022
0.029
0.014
0.016
0.025
0.013
0.048
0.039
0.0085
0.014
0.034
0.036
0.04
0.016
0.022
0,035
0.024
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
-....... 'f.~,.;.;.;,.,_...,~ . .'delta-BHC·" h~,..::i:.~::,,; ... ~....:...·.-"•~' .. ,1 ~:J;:.-.. •;;n,.
: .... eamma~BHC-(LmdanCY., !'
0.025 0,025
0,025 0.025
0.014 0.0255
0.016 0.025
0.02 0.025
0.039 0,025
0.028 0.025
0.008 0,025
0.013 0.025
0.033 0,025
0.024 0.025
0.037 0,025
0.017 0.025
0.02 0.025
0.034 0.018
0.014 0.025
':··~~-x.:~,s---· ·? l!:.·,~--1~\)._;.f/: ./\'·_: (,. s'·;,•·' 'ii
0.025 0.025
0.023 0,025
0.029 0.025
0.011 0.027
0.016 0,025
0,025 0.025
0.012 0,028
0.039 0.025
0.037 0,025
0.008 0.025
0.011 0,025
0.029 0.025
0.024 0.025
0.036 0,025
0.016 0.025
0.024 0.025
0.036 0,018
0.013 0,025
Values in red exceed the remediation goals for the downgradient area (Table 4).
24
•
Table 8 continued:
)Ji;7Sfll~ ;;:[! t··~·;,.--: .... ~""~--i1'sllmll1e i>ate··:: -"'..,&"~-~ ;.:aibh·a':.BIICi'
SW-07 6/4/1996 0.025
SW-07 4/29/1998 0.012
SW-07 7/20/1998 0.012
SW-07 10/28/1998 0.0265
SW-07 1/12/1999 0.0084
SW-07 4/12/1999 0.025
SW-07 8/10/1999 0.018
SW-07-re 8/10/1999 0.015
SW-07 10/12/1999 0.0055
SW-07 2/2/2000 0.0084
SW-07 4/11/2000 0.017
SW-07 7/20/2000 0.013
SW-07 10/11/2000 0.028
SW-07 1/9/2001 0.0097
SW-07 10/9/2001 0.015
SW-07 4/9/2002 0.028
SW-07 10/25/2002 0.01 I . "-.· '· ·. : "c'rc;: 'c. ':;c ,,' ,". . '. ' .. ,. . .,.
-~ . : ... ',,, ... ' '., ,., ·-·-
SW-08 614/1996 0.025
SW-08 4/2911998 0.013
SW-08 7/20/1998 0.014
SW-08 10128/1998 0.0088
SW-08 1/12/1999 0.0097
SW-08 4/1211999 0.025
SW-08 8/10/1999 0.018
SW-08-re 8110/1999 0.02
SW-08 10/12/1999 0.0065
SW-08 2/2/2000 0.01
SW-08 4/11/2000 0.022
SW-08 7/20/2000 0.018
SW-08 10/11/2000 0.035
SW-08 1/912001 0.01 I
SW-08 1019/2001 0.021
SW-08 4/9/2002 0.031
SW-08 10/25/2002 0.014
Values are in µg/L.
"1"•-~_.i.,.....;"~ •,tieta'BHC,.
0,025
0.019
0.028
0.016
0.016
0.019
0.057
0.036
0.009
0.0096
0.032
0,038
0.041
0.015
0.025
0.036
0.016
.. \\it·_. Y~/·
0.025
0.02
0.029
0.014
0.019
0.021
0.042
0.045
0.0105
0.Ql5
0.039
0.037
0.048
0.019
0.039
0.043
0.024
• Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
ticlt~=-iiHG 1r. ..... ·.:'l!!4,:~,.,..f!•:-.l.~",:_..:·_ -~·;· ,i""fd'W "\//,ianiriia-BIIC (LhidllnC '-1,,k
0.025 0,025
0.022 0.025
0.027 0.025
0.016 0.0265
0.018 0.025
0.02 0.Q25
0.041 0.Q25
0.03 0.Q25
0.009 0.Q25
0.012 0.025
0.031 0.025
0.025 0.Q25
0.041 0.025
0.015 0.Q25
0.027 0.025
0.038 0.QJ8
0.015 0.025 ..• ,· .. . .,_, ' ... .~.' ·:;• :}L, . '. ~,:,: · .. ·,•.·-~-"·. • ,,,_," . . .
0.025 0.Q25
0.027 0.025
0.034 0.Q25
0.018 0.Q25
0.019 0.025
0.021 0.Q25
0.05 0.025
0,038 0.Q25
0.009 0.025
0.014 0.025
0.04 0.025
0.029 0.025
0.047 0.Q25
0.019 0,025
0.041 0,025
0.042 0,0]8
0.019 0.025
Values in red exceed the remediation goals for the downgradient area (Table 4).
25
•
Table 8 continued:
:,;.~rsitJ:~/ "'<->· ...... ..,,. <· ~-.:_:Sn'miile Dlltel.-·
r_;·. _;; .. ,~_,;_:_
:.! alDha·-BHC J
SW-09 61511996 0.025
SW-09 412911998 O.Q25
SW-09 712011998 0.025
SW-09 I 0128/1998 0.0255
SW-09 1/1211999 0.025
SW-09 4/1211999 0.025
SW-09 8/1011999 0.025
SW-09-re 8110/1999 0.025
SW-09 10/1211999 0.025
SW-09 21212000 0.025
SW-09 4/1112000 0.025
SW-09 712012000 0.025
SW-09 I 0111/2000 0.025
SW-09 1/912001 0.025
SW-09 10/9/2001 0.025
SW-09 4/912002 0.025
SW-09 10125/2002 0.025
·i::·::rt·::r: :.t ~~-;~i':t;i:A:/ .. ;ti,\i,i: i :i',;,:. :~•L
SW-10 4/2911998 0.025
SW-10 712011998 0.025
SW-10 10128/1998 0.0255
SW-10 1/12/1999 0.025
SW-10 411211999 O.Q25
SW-IO 8110/1999 O.Q28
SW-IO-re 8110/1999 0.025
SW-10 10/1211999 0.025
SW-10 2/212000 0.025
SW-10 411112000 0.025
SW-10 7120/2000 0.025
SW-10 !Oil 112000 0.025
SW-10 119/2001 0.025
;:rf~,-~: .. t :l,, !: :::>'t, ~1~,'1•' !' -f ;;'.:i', it>;~~;;,:; ... ;.
SW-II I 011211999 0.00495
SW-II 212/2000 0.0083
SW-11-2 21212000 0.0091
SW-11-2 4/1112000 0.016
SW-11-2 712012000 0.018
SW-11-2 I 0111/2000 0.027
SW-11-2 11912001 0.011
SW-11-2 10/9/2001 0.014
SW-11-2 419/2002 0.027
SW-11-2 I 0/25/2002 0.01
Values are m µg/L.
•·..;._...s;__,_, •.
,,JJeta-BHC. ·
0.025
0.025
0.025
0.0255
0.025
0.025
0.025
0.025
0.025
0.025
0.025
0.025
0.025
0.025
0.025
0.025
0.025
•i~-~'.-:~ id '..~i: ,~::
0.025
0.025
0.0255
0.025
0.025
0.028
0.025
0.025
O.Q25
0.025
0.025
0.025
0.025 I c:•,:::•ir; ·.• , -,,,:•-·:,,,',
0.0085
0.014
0.014
0.031
0.043
0.04
O.Q18
0.026
0.034
0.016
• Five-Year Review
GeigJ Chemical Corp. (Aberdeen Plant), Aberdeen, NC
~:d~r,'k:BHCr r-~\etn;·ma~BIIG-fLin\itii)~::h
O.Q25 0.025
0.025 0.025
O.Q25 0.025
0.0255 0.0255
O.Q25 0.025
0.025 O.Q25
O.Q25 0.025
O.Q25 O.Q25
0.025 0.025
0.025 0.025
0.025 0.025
0.025 0.025
0.025 0.025
0.025 0.025
0.025 0.025
0.025 0.025
0.025 0.025
:,,,, .. \,~ii .•. ikii;: :.~<-':/:.; ... ::/~~ti_•:1;\.t·<::.1:':{;:
0.025 0.025
O.Q25 0.025
0.0255 0.0255
O.Q25 0.025
0.025 0.025
0.028 0.028
0.025 0.025
0.025 0.025
0.025 0.025
0.025 0.025
0.025 0.025
O.Q25 0.025
0.025 0.025
't.•./-: :,:-· :~. -· ., 1~:•i;\."\,t!(l£ :1 ;;~}\·1•\."i\iJ,;;·: i ·i.~
0.0085 0.025
0.012 0.025
0.017 0.025
0.029 0.025
0.029 0.025
.
0.037 0.025
0.017 0.025
0.029 0.025
0.035 O.QJ8
0.012 0.025
Values in red exceed the remediation goals for the downgradient area (Table 4).
26
• • Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
As a result of the downgradient investigations required by the ROD, and with the
adoption of the ESD in 1998, it was determined that trichloroethene (TCE) was not a site related
contaminant. As a result, monitoring and the downgradient groundwater clean-up standard for
TCE was removed from the downgradient monitored natural attenuation remedy (Table 4).
However, the ESD did not remove TCE from the groundwater remediation levels (performance
standards) for the Geigy Site as listed in Table 3. Table 9 presents the data for monitoring wells
that have been tested for TCE during the 1991 -2002 time period. Other wells in the monitoring
program for the site have not been monitored for TCE levels and are not included in Table 9.
Table 9. Trichloroethene (TCE) Concentrations in Groundwater Monitoring Wells 1991 to
2002
Trichloroethene (TCE) Concentrations in Groundwater Monitoring Wells 1991 -2002
·-.-~ti\(,."/. ·1. ;·surfiCial A'riuirer ..::;.: :'..1.!1 ::;.~ '..;_·_
TCE Concentration
Well DATE (µg/L)
MWIOS 7/10/199! ND (!0\
MW-10S 12/3/1996 ND (5)
MW-10S 4/16/1997 ND(5\
MW-10S 7/15/1997 ND(5)
MW-10S 10/1/1997 NDtS\
MW-10S 4/21/1998 NDm
MW-10S 10n91199s ND(I)
MW-10S 10/14/1999 NDf])
MW-10S 10/13/2000 ND(!)
MW-10S 10/11/2001 ND(I)
MW-10S 10/23/2002 ND fl\
· .. :c'":1 ' ·,_ · .·f.".;,· · · ': '· ,:~ ~' ,. :: ;~".' :s·· ;:·,., ·•~ ... · ~·-,, ,,,
MW-16S 12/3/1996 ND (5)
MW-16S 4/!6/1997 NDtS\
MW-16S 7/14/1997 ND(5)
MW-16S 10/1/1997 ND/5)
MW-16S 4/21/1998 NDm
MW-16S 10/29/1998 ND(l)
MW-16S 10/14/1999 ND<l\
MW-16S 10/13/2000 ND (5)
MW-16S 10/11/2001 ND (I)
MW-16S 10/22/2002 ND(l)
•t1: ,.}{~,!:c ::-1~.i/l;:>k~\r;:'.~(;'.Wit:%'"'.:·•i :,1 ·:1:,:ii~'.:': '1"
MW-17S 12/3/1996 ND IS\
MW-17S 4/16/1997 ND(5)
MW-17S 7/14/1997 ND(5)
MW-17S 10/1/1997 1.1
MW-17S 4/21/1998 ND IS)
MW-17S 10/29/1998 }.TI)(!)
MW-17S 10/14/1999 ND(l)
MW-17S 10/13/2000 ND(J)
MW-17S 10/! 1/2001 ND(l)
MW-17S 10/24/2002 ND/\\
:,. ,t::i ~;~·i,'j-~t)E•!'),\ t!t,:7ff'':.;;:~~t · ,,,,"~ .,,r: .. ,.
MW-18S 12/3/1996 ND (5)
MW-18S 4/16/1997 ND(S\
MW-18S 7/15/1997 ND(5)
MW-18S 1011/1997 0.66
MW-18S 4/21/1998 ND (5\
MW-18S 10/29/1998 ND (I)
MW0J8S 10/14/1999 ND(l)
MW-18S 10/13/2000 ND(I)
MW-18S 10/1112001 ND(I)
MW-18S 10123/2002 ND (I)
L:l. -.· .:r .,U iller Black Creek Arlllifer·\;', : ... : -.!! ~-·
TCE Concentration
Well DATE (µg/L)
MW-16D 2/9/1994 200
MW-\6D 12/2/1996 230
MW-16D 4/16/1997 280
MW-16D 7/1411997 250
MW-16D 10/1/1997 260
MW-16D 4/21/1998 290
:-..1W-16D 10/29/1998 270
MW-16D 2/4/2000 290
MW-16D 10/1312000 E (260)
MW-16D 10/10/2001 190
MW-16D l0/24/2002 160
A;c: ··•~--F··:; 1' ::!. .,_;.., :~ .' ,. ·V ,,':_::--~,,·:i ·, .
MW-17D 2/9/1994 180
MW-17D 1212/1996 320
MW-170 4/16/1997 190
MW-170 7/14/1997 370
MW-17D 10/1/1997 350
MW-170 4/21/1998 320
MW-170 10/29/1998 350
MW-170 2/4/2000 330
MW-170 10/13/2000 290
MW-17D 10/24/2002 290
: ·-::~;.;:y•:,: · i;-.f:::i-,;;;;:t-· r,:41;:~J~i~E ·.t :i.~•l'-U:' :· .:~nir•~J'\ "1til ·''· ~i1:J.'
MW-ISD 1/26/1994 ND(3)
MW-18D 8/18/199S ND/I\
MW-18D 12/3/1996 ND (5)
MW-ISD 4/16/1997 ND/5)
MW-ISD 7/14/1997 1.3
MW-lBD 10/1/1997 1.6
MW-ISD 4/2l/l998 6.2
MW-18D J0/29/1998 4.2
MW-18D 10/14/1999 20
MW-IBD 10/14/2000 29
MW-18D 10/10/2001 46
MW-18D 10/22/2002 71
•:·:;~.i ..;':.J-,;.,-:1:..~1.;F;:i~·~t,:::·E:;5 3 i\~'. '.;r,•111. !.'''!~;··-::~:_;_;·.
MW-30D ]0/14/2000 43
MW-30D 10/22/2002 66
Note: Values in µg/L, ND=-Non-detect.
E-= Estimated value above instrument
linear calibration range. Actual detection.
27
• Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
TCE concentrations at wells MW-l 6D and MW-l 7D, which are at the eastern edge of the
site area, are consistently two orders of magnitude (100 times) greater than the 2.8 µg/L
performance standard. MW-l 8D, at the western edge of the area where groundwater is being
extracted, consistently has TCE concentrations at one order of magnitude (10 times) the 2.8 ftg/L
performance standard. The trend at MW-l 8D is one where TCE concentrations are increasing
over time. Surficial aquifer monitoring wells, MW-l0S, MW-16S, MW-l 7S and MW-18S do
not exhibit TCE concentrations above the performance standard.
VIII. ASSESSMENT
To assess the effectiveness of the remedy at the Geigy Chemical Corporation (Aberdeen
Plant) Site, three basic questions are answered and discussed below:
Question A: ls the remedy functioning as i11te11ded by the decision documents?
For the Geigy Chemical Corp. (Aberdeen Plant) Site, the remedy for soil (source)
contamination was completed in 1996, with the conclusion of soil and debris removal. Based on
a final inspection of the site by EPA and the State ofNorth Carolina Division ofSuperfund in
1998, the soil contaminant level goals established in the ROD and RD have been met and no
further soil remediation is required.
The groundwater pump-and-treat system was placed on-line in January 1997 and has
operated continuously since. The groundwater contamination trends attributable to the pump-
and-treat remedy for the surficial and Upper Black Creek aquifers appear to be downward. The
trends of contaminant concentrations in the downgradient groundwater are difficult to discern
because of the low levels of contaminants present. At present, the monitoring data show that
contaminant concentration levels of TCL compounds are consistently above performance level
goals.
Question B: Are the assumptions used at the time of the remedy selection still valid?
The alternatives presented to address groundwater and soil contamination in the ROD,
were originally evaluated using criteria set in the NCP, 40 CFR §300.430 (e)(9). The criteria are
described below.
Threshold Criteria
1. Overall Protection of Human Health and the Environment addresses how an alternative as
a whole will protect human health and the environment. This includes an assessment of
how the public health and the environment risks are properly eliminated, reduced, or
controlled through treatment, engineering controls, or controls placed on the property to
restrict access and (future) development. Deed restrictions are examples of controls to
restrict development.
28
• • Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether or not a remedy complies with all state and federal environmental and
public health laws and requirements that apply or are relevant and appropriate to the
conditions and cleanup options at a specific site. If an ARAR cannot be met, the analysis
of the alternative must provide the grounds for invoking a statutory waiver.
Primary Balancing Criteria
3. Long-term Effectiveness and Permanence refers to the ability ofan alternative to
maintain reliable protection of human health and the environment over time once the
cleanup goals have been met.
4. Reduction of Toxicity, Mobility; or Volume are the three principal measures of the
overall performance ofan alternative. The 1986 amendments to the Superfund statute
emphasize that, whenever possible, EPA should select a remedy that uses a treatment
process to permanently reduce the level of toxicity of contaminants at the site; the spread
of contaminants away from the source of the contaminants; and the volume, or amount,
or contamination at the site.
5. Short-term Effectiveness refers to the likelihood of adverse impacts on human health or
the environment that may be posed during construction and implementation of an
alternative until cleanup goals are achieved.
6. Implementability refers to the technical and administrative feasibility of an alternative,
including the availability of materials and services needed to implement the alternative.
7. Cost includes the capital (up-front) cost of implementing an alternative, as well as the
cost of operating and maintaining the alternative over the long-tern1, and the net present
worth of both the capital and operation and maintenance costs.
Modifying Criteria
8. State Acceptance addresses whether, based on its review of the Rl/FS and Proposed Plan,
the State concurs with, opposes, or has no comments on the alternative EPA is proposing
as the remedy for the site.
9. Community Acceptance addresses whether the public concurs with EPA's p,roposed plan.
Community acceptance of this proposed plan will be evaluated based on comments
received at the public meetings and during the public comment pe"riod.
The evaluation criteria relate to the requirements of Section 121 ofCERCLA, 42 USC
§9621, which determine the overall feasibility and acceptability of the remedy. Threshold
criteria must be satisfied in order for a remedy to be eligible for selection. Primary balancing
criteria are used to weigh major trade-offs· between remedies. State and community acceptance
are modifying criteria formally taken into account after public comment is received on the
29
• • Five• Year Review
Gei!)I Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
proposed plan. Table 10 summarizes the alternatives evaluated and discussion of the potential
remedial alternatives to address soil and groundwater follow.
Table 10. Remedial Alternative Summary
Remedial Action Total Present Worth Costs
(1992)
Groundwater
Alternative I A No Action $140,000
Alternative 1 B Long-term Monitoring of $1,630,000
Groundwater
Alternative 2 Slurrv Wall and Cap $10,200,000
Alternative 3 Groundwater Extraction for $2,210,000
Remediation Levels; Carbon
Adsorption; Discharge to
POTW
Soil
Alternative I No Action $140,000
Alternative 2 Off-site Disposal
Total Landfilling $600,000
Total Incineration $2,440,000
Alternative 3 Capping $275,000
Alternative 4 On-Site Thermal Desorption $700,000
Alternative 5 On-Site Incineration $1,327,100 ·
Ground Water Remediation
The following alternatives were subjected to detailed analysis for groundwater
remediation:
Alternative lA:
Alternative 1 B:
Alternative 2:
Alternative 3:
No Action
Long-term Monitoring of Groundwater
Slurry Wall and Cap
Groundwater Recovery and Treatment to Attain Remediation
Levels
Overall Protection o[Huma11 Health and the Environment
Groundwater poses no risks to human health under current conditions. Under the future
use condition the no action alternative would not address pesticide levels in groundwater and
therefore would not be protective of human health. Alternative 2 would attain the remediation
goals by containing groundwater in the uppermost aquifer and recovering groundwater in the
second uppermost aquifer. Alternative 3 would attain the remediation goals by recovering
30
• • Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
groundwater in the uppermost and second uppermost aquifer. Therefore, Alternatives 2 and 3
would be protective of human health and the environment.
Compliance With ARARs
The no action alternative would not comply with ARARs. Alternative 2 would attain
remediation levels outside of the slurry wall in the second uppermost aquifer and prevent ·
remediation levels from being exceeded off-site in the uppermost aquifer. Alternative 3 would ·
attain remediation levels in both aquifers. The cap in Alternative 2 would be designed to
conform to RCRA performance standards. Construction of the groundwater re·covery, treatment
and discharge systems for Alternatives 2 and 3 would satisfy action-specific ARARs. Discharge
to an on-site infiltration gallery would comply with the substantive aspects of a NC Non-
Discharge Permit.
Long-term Effectiveness and Permanence
Pesticide levels would decrease permanently through recovery outside of the slurry wall
for Alternative 2 and in both aquifers in Alternative 3. Construction of a slurry wall under
Alternative 2 would be complicated by the depths to the uppermost aquitard (up to 70 feet). The
competence of the resulting connection would be verified through hydraulic and analytical
monitoring of groundwater. Carbon adsorption is considered Best Available Treatment for
pesticides in groundwater. Alternative 2 would be a permanent installation that would require
review and maintenance indefinitely. Alternative 3 would be discontinued once the remediation
levels were achieved.
Reduction o(Toxicity. Mobility, and Volume
Alternative 2 would reduce the mobility of pesticides in the uppermost aquifer through
containment and reduce the volume of pesticides in the second uppermost aquifer through
recovery. Alternative 3 would reduce the volume of pesticides in both aquifers through recovery
and treatment and comply with the statutory preference for alternatives involving treatment.
Short-term Effectiveness
All of the alternatives can be implemented without significant risks to the community or
on-site workers and without adverse environmental impacts. Construction schedules would be as
follows: Alternative IA-None; Alternative 1B-I month; Alternative 2-8 months; and
Alternative 3 -

3

months. Construction of Alternative 2 could not proceed until the rail line was
rerouted, a potentially significant obstacle on an institutional basis.
Implementability
Alternatives I A, I B, and 3 would not pose significant concerns regarding
implementation. Construction of the slurry wall for Alternative 2 would approach the limits of
technical feasibility due to the required depths (up to 70 feet). Design of the treatment system
for Alternatives 2 and 3 could not be conducted until discharge requirements were defined.
31
• • Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Total present worth costs (1992) for the groundwater alternatives are presented in Table
10.
Soil Remediation
The following alternatives were developed for Site soils and were subjected to detailed
analysis:
Alternative I:
Alternative 2:
Alternative 3:
Alternative 4:
Alternative 5:
No Action
Off-Site Disposal
Capping
On-Site Thermal Desorption
On-Site Incineration
The evaluation of these alternatives is summarized below.
Overall Protection o(Human Health and the Environment
Potential risks due to Site soils under current and potential future conditions (residential
scenario) are within the acceptable range ofrisk specified by the National Contingency Plan
(NCP).
Compliance with ARARs
There are no Federal or State ARARs for pesticides in soils. Alternative 2 would comply
with EPA's off-site policy and applicable land disposal restrictions. Alternative 3, consolidation
of site soils and capping in place would not trigger any RCRA requirements. Alternatives 4 and
5 would comply with all applicable ARARs, including LDRs.
Long-term Effectiveness and Permanence
Alternative I would not be effective in reducing contaminant levels. Alternatives 2 and 4
would result in a permanent reduction in site risks. Alternative 3 could be effective in the long-
term through regular maintenance of the cap, but a review of remedy would be required every
five years since a cap is not considered a permanent remedy. Alternatives 4 and 5 would
maintain reliable protection of human health and the environment over time once the remediation
levels were achieved.
32
•
Reduction o(Toxicity. Mobility. and Volume
• Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Pesticide levels would remain unchanged for Alternative 1. Alternatives 2, 4 and 5
would reduce pesticide levels significantly. Alternative 3 would not reduce the volume, but
would reduce the mobility and effective toxicity of the pesticides.
Short-term Effectiveness
All of the alternatives can be implemented without significant risks to on-site workers or
the community and without adverse environmental impacts.
Implementability
No implementation is needed for the no action alternative. Off-site disposal to a RCRA-
approved landfill and incinerator have been conducted successfully in the past at the Geigy Site.
Construction of the cap would pose no significant difficulties. Alternatives 4 and 5 are
implementable, however the low volume of contaminated soils requiring remediation renders
these alternatives impractical at this site.
Cost
Total present worth costs (1992) for the soil remediation alternatives are presented in
Table 10.
Modifvi11g Criteria
State and community acceptance are modifying criteria that were considered in selecting
the remedial action.
State Acceptance
The State of North Carolina concurred with the selected remedy.
Community Acceptance
A proposed plan fact sheet was released to the public on March 26, 1992. The proposed
plan public meeting was held on March 31, 1992. The public comment period on the proposed
plan was held from March 26, 1992 to May 25, 1992. The letters, comments, and questions
asked during the March 31st meeting and received during the comment period were attached to
the ROD as a Responsiveness Summary.
With the completion of the Downgradient Groundwater Remedial Action Work Plan in
October 1997, the alternative of Monitored Natural Attenuation was implemented for the
downgradient portion of the plume. The determination was based on the following factors:
33
• • Five-Year Review
Geigy Ch,mim/ Co,p. (Aberdeen Plant), Aberdeen, NC
o There were no receptors of untreated groundwater in the downgradient area. At the time
there was one private well user in the area. All other residences and businesses are
connected to the city water system. The private well had been sampled and the water was
contaminated with pesticides. However, the PRPs installed a carbon filter on the well,
and conducted periodic monitoring to ensure proper operation and maintenance.
o The City of Aberdeen, by letter dated April 1997, informed EPA that the City would not
install any municipal water supply wells in this downgradient area.
o Groundwater discharge to surface water limits the further migration of the plume.
Groundwater flow directions h~ve been identified to verify that the groundwater pesticide
contamination plume is contained by the following creeks: McFarland's Branch,
Aberdeen Creek, Ray's Mill Creek, and Trough Branch.
• Pesticide concentrations in surface water do not currently pose a risk to human health or
wildlife. The risk assessment for McFarland's Branch was updated based on the new
sampling results and indicates that the risk associated with the downgradient plume is
well below EPA's acceptable risk range of 104 to 10·6.
• Groundwater modeling has shown that the concentrations of pesticides in this
downgradient area will decrease in a time frame comparable to a pump-and-treat system.
A groundwater flow model was used to simulate the perfonnance of six extraction wells
in the downgradient plume area. The model was also used to estimate the extent and
longevity of the groundwater plume under naturally-occurring conditions. The results of
this modeling show that the plume would be remediated in 19 years under pump-and-
treat conditions, and would be remediated in 25 years under natural conditions.
The assumptions used for the remedy selection remain valid. The selection of extraction
with activated carbon adsorption as the remedy for the surficial and Upper Black Creek aquifers
is still valid as there have not been any changes to the assumptions made_ originally. The
selection of monitored natural attenuation as the remedy for the downgradient area is still valid
as conditions have not fundamentally changed. Based on the review, all appropriate measures
and procedures were utilized at the time of the remedial action and continue to be in effect.
Question C: Has any information come to light that could call into question the protectiveness
of the remedy?
Based on validated information provided in the documentation that was reviewed, there is
no information to date that significantly questions the protectiveness of the remedy. Data
collected since the conclusion of the source remedial action support the selection of extraction
with treatment as the preferred method for groundwater remediation in the ROD. The data are
also in support of selection of monitored natural attenuation as the preferred method of
groundwater remediation in the downgradient area as selected in the ESD. The trends of
contaminant concentrations in groundwater are generally downward. However, detections of
34
• • Five~Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
target contaminants are frequently in exceedance of performance standards for the site. Remedy
implementation data to date provide no validated early indication ofpotential remedy failure.
IX. ISSUES
There are several problems or issues that have been identified during this review. Each is
further discussed in the recommendations section of this report.
1. Fencing and signage for the site as proposed in the documents of record have not been
installed.
2. Modification of the site Groundwater Remediation Discharge Permit to reflect actual
number of recovery wells in use.
3. Extension of off-site trichloroethene (TCE) contaminant plume into site area and
potential affects on remedy as implemented. Potential increases in TCE concentrations in the
remedy and downgradient areas.
X. RECOMMENDATIONS AND FOLLOW-UP ACTIONS
The recommendations and follow-up actions associated with the issues found in this
review are described below and are summarized in Table 9.
Implementation of site fencing and signage as proposed in the Record of Decision should
be analyzed. The proposal for fencing and signage was completed prior to remediation of the
site soils. With removal of the contaminated soils, fencing the site may pose a greater public
safety hazard than exists currently. It is recommended that EPA issue an ESD to eliminate the
requirement for fencing and signage at the site.
The current Groundwater Remediation Permit issued to the Site by the State does not
reflect the treatment system as installed. The permit lists a total of five (5) recovery wells while
the actual number of recovery wells in use is seven (7). As the current permit expires June 30,
2004, it is recommended that the PRPs update the information in the permit application for
renewal. Change of the permit should only be editorial in nature and should not affect the
operation or implementation of the treatment system.
Extension of the off-site trichloroethene (TCE) contaminant plume into the site treatment
area has been noted during ongoing monitoring of the remedy. The change-out period for
activated carbon canisters has reduced from annually to semi-annually. Currently there are
insufficient data to accurately predict whether the TCE plume will adversely affect the remedy as
implemented or not. It is recommended that the EPA and State continue to pursue
characterization of the source of the TCE and the PRPs continue their voluntary monitoring of
wells in accordance with the Site Groundwater Remediation Permit.
35
• Five-Year Rtview
Geigy Chemical Co,p. (Aberdeen P/a11t), Aberdeen, NC
Table 11. Recommendations and Follow-up Actions
i:-"~•"31Issiie(s)lr,i·,•: 1 ; RecOl11inelld8tiol1S/FollOW.--:, :· ;:rr;1i/t Party· ~'. •,i'.ii'lf .r~;,·Oversight"-.\•1 :' :-.1,Milcstone,Ji;~, ('''' Fono·w-iip· 1,,,
'. .,'"i··r ..._ '; • .-.-.:"" ·; -.t<~•·,r,~, .-r -,r:,: 7'.{, 11 -~S:1r•.,,1>. ,'L '·,.,, ,.,. ;t~t Ag~·~'cY~fi\' ~.!'',''. it; ,; Date~ ~-:,,~-:~:-1 -~t; ); ··'· .-h ~ ·-.~•~ 11·1•1
:!£f,'1f{~(::\i,t~ , ': ~p· ;t''• up Actions c.'; • i~ti',"',J .·.1~1;Respons1ble;;:,-, ·. :·· Acti_ons_: 1Affec_tsj'.,,
·J,l" I l;-4-~-·' ,· ·-&J!"•';i.-1,; ,.,,., :f-·' f I •-"•• '~-.C~•'j"d'·••,ii • , .. r._ , •.·,tt.-.,,,,,.;i .. ,.,.,,,~,1, /ij:~(~{;~~t!~fo•e.~~!f ;' .. i-1tl',•:i"''"•i~tA··:r ''""''W'''f. 'l·"t,'il,,1 ,.1,ti,f;; ,\...r: [{I '''~t,:;•, :~J ;p'~ i:i :1,JJ,J."'i -~11;.J. ,,j :r,,"J~•· 'I.,··~ t;n~1·, ),;_, :.i ,-~
• l:\'1 ·,. r -,... ,,.,.,""-'.r,?4~·,'i:•·~ j';,: :;~ ~'::,~~~~~~i,::.~~il .'..~,f.,t\~~i~: :-:.:~/:\: i; '. ~:t\~:};., ·:.i$!'1;,,-'}~~~-, .~cft'. ~) . .i/-,/1?.:.·tll-::.:"1•.: '4.••_·,1·(Y/N) > _·,.
Fencing and Fencing and signage should EPA EPA and State Before next N
signage for the not be required as the site five-year review
site 8.s proposed soils have been remediated. as required
in the documents EPA should issue an ESD
of record have to eliminate requirement for
not been fencing and signage.
imnlemented.
Groundwater Update permit to reflect PRPs State Upon renewal N
Remediation actual number of recovery of current
Pennit docs not wells when renewed. permit-June
cover all installed 30,2004
recoverv wells.
Off-site Continued monitoring of PRP~ EPA and EPA and State Before next N
trichloroethenc affect(s) on the site remedy. State five-year review
contaminant or as required
plume.
XI. PROTECTIVENESS STATEMENTS
The remedy at the Geigy Chemical Corp. (Aberdeen Plant) Site is expected to be or is
protective of human health and the environment, and in the interim, exposure pathways that
could result in unacceptable risks are being controlled.
XII. NEXT REVIEW
This is a site that requires five-year statutory reviews. EPA will conduct the next review
within five years of the completion of this first five-year review report. The completion of this
review as shown on the signature cover to this report is the trigger for the next five-year review.
36
• • Five-Year Review
Geigy Chemical Co,p. (Aberdeen Pla11t), Aberdeen, NC
ATTACHMENT 1
List of Documents Reviewed
• • Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
List of Documents Reviewed
Geigy Chemical Corp. (Aberdeen Plant) Five-);' ear Review
Rust Environment & Infrastructure. November 1993. Remedial Design Work Plan, Geigy
Corporation Site, Aberdeen, North Carolina. Project No. 86619.200.
Rust Environment & Infrastructure. November 1993. Sampling And Analysis Plan, Geigy
Chemical Corporation Site, Aberdeen, North Carolina. Project No. 86619.210.
Rust Environment & Infrastructure. February I 995. Downgradient Groundwater Investigation
Work Plan, Geigy Chemical Corporation Site, Aberdeen, North Carolina.
Rust Environment & Infrastructure. March I 996. Downgradient Investigation Data Summary
Report, Geigy Chemical Corporation Site, Aberdeen, North Carolina. Volume I and 2. Project
No. 33288.610.
Rust Environment & Infrastructure. March 1996. Final Design Report, Geigy Chemical
Corporation Site, Aberdeen, North Carolina. Project No. 86619.600.
Rust Environment & Infrastructure. November 1997. Final Downgradient Groundwater
Remedial Action Work Plan, Geigy Chemical Corporation Site, Aberdeen, North Carolina.
Project No. 201165.10300.
Sirrene Environmental Consultants. March I 6, 1992. Feasibility Study Report, Geigy Chemical
. Corporation Site, Aberdeen, North Carolina. Sirrine Project No. G-1024.20.
The Pinnacle Consulting Group. October 2001. Downgradient Remedy Summary Report,
Geigy Chemical Corporation Site, Aberdeen, North Carolina. Project No. MAS0006l.
The Potentially Responsible Parties (PRPs) for the Geigy Chemical Corporation Site.
November, 1989. Remedial InvestigationJFeasibility Study Work Plan, Geigy Chemical
Corporation Site, Aberdeen, North Carolina. Prepared by ERM-Southeast, Inc.
The Potentially Responsible Parties (PRPs) for the Geigy Chemical Corporation Site. March
1992. Final Report -Remedial Investigation Study, Geigy Chemical Corporation Site,
Aberdeen, North Carolina. Prepared by ERM-Southeast, Inc.
U.S. Environmental Protection Agency, Waste Management Division. May I, 1989. Initial Soil
Removal Report Task IO -RI/FS, Geigy Chemical Corp. Site, Aberdeen, North Carolina.
Prepared by the Potentially Responsible Parties (PRPs) for the Geigy Chemical Corp. Site.
U.S. Environmental Protection Agency, Region IV. March 24, 1992. Geigy Chemical Corp.
Site NPL Site Administrative Record, Index and Volume I through 7.
• ·• Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
U.S. Environmental Protection Agency, Region IV. August 27, 1992. Record of Decision;
Summary of Remedial Alternative Selection; Geigy Chemical Corporation Site, Aberdeen,
Moore County, North Carolina.
U.S. Environmental Protection Agency, Region IV. January 23, 1998. Explanation of
Significant Differences to the Remedial Action, Geigy Chemical Corporation Site, Aberdeen,
Moore County, North Carolina.
U.S. Environmenial Protection Agency, Region IV. February 6, 1998. Geigy Chemical Corp.
(Aberdeen Plant) Site (Explanation of Significant Differences) NPL Site Administrative Record,
Index and Volume 1 through 3.
U.S. Environmental Protection Agency, Region IV. July 21, 1998. Superfund Preliminary
Close-Out Report, Geigy Chemical Corporation NPL Site, Aberdeen, North Carolina.
• Five-Year &view
Gei!!JI Chemfral Ci,p. (Aberdeen Pla111), Aberdeen, NC
ATTACHMENT 2
Photos of Extraction System Installations
All photos taken by Stacy Samuelson
during Site visit February 18, 2003
• •
• •
Extraction well PW-3S
2
• •
Controller box/panel for extraction well
3
• •
View of extraction wells PW-2S and P\V-1 S from well PW-3S
4
• •
rl ,' ' I.,· .
i
View of carbon adsorption canister banks
5
•
Attachment 3
• Five-Year &view
Gei!J Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Upper Black Creek Aquifer
Extraction Well Capture Zones
Close-Up: Min Q and Drawdown Contours
EARTH©TECH
A tyca INTERNA710NAL L7D. COMPANY
,
;'..•
·-=-o·•!:· ,.-
I
Figure5
Geigy Site, North Carolina September 2003
•
•
Close-Up: Avg Q and Drawdown Contours
0
(J1
0
Figun, 8
EARTH@TECH
A "tqr:::D INTFRNADONAL LTD. COMPANY
Geigy Site, North Carolina Scptcrnbcr 2003
•
Close-Up: Max Q and Drawdown Contours
/ > ,• / gi· . , .
/ ' /
. lf'F~i~',cl'1~::S--.j.:t--../-~ . ., .// I
~'-.. ,.~
-.
EARTH@TECH
A 'tqca JNTERNAT10NAL LTD. COMA6.NY
Figure 11
Geigy Siti:. North Carolina Septc:mbcr 2003
•
•
Attachment 4
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Surficial Aquifer Graphs
i • ·g
i i 0
i
' i • 0
"
"
"
"
,,
"
,0
'"
"
"
"
,,
"
,0
•
-•lpha-BHC
-b•t1-BHC
1-d11!1-BHC
-c;,-g1mm1-BHC
M W-4S
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Mar-112 Mer-113 Mor-114 Mar-115 Mar-116 M ■r-117 M ■r-116 Mir-1111 Mar-00 Mar-01 Mar-02 Mar-03
MW-llS
-•lph1-BHC
-D&t1-8HC
-dtU1-BHC
-g•mma-BHC
Mor-92 Mar-113 M ■r-114 Mar-95 Mar-116 Mtr-117 Mar-DB Mar-1111 M11-00 Mar-01 M u-02 M 11-03
'"~------------------------------------------------~ M W-6S
"
,0
M or-81 Mor-9~ M ar-115 Mor-116 Mor-97 Id ■ r-116
1-">"•·0" C -b■tl•BHC
-doll1-6HC
-g•mmo•BHC
Mor-119 Mor-00 Mar-01 MI r-03
,0
~ ,,
• I ! ' ,, 0
• • Five~Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
--1lph1-BHC
-ID-bttt-BHC
~dlltt-BHC
--g1mm1-BHC
Attachment 5
• Five•Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Upper Black Creek Aquifer Graphs
,:1
/
•
•
"
"
"
" i ,0 I
1 u
Jun•91 Jun•93
" -•lpho•BHC
" -111-boll•BHC
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Jun-94
MW -180
Mar-97 Mu-99
M W-19D
l-1lph1-BHC !:-bet1-BHC I -delt1°8HC
-Q-gam m 1-BHC
.
M ■r-98
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Jun-01 Jun-02
......, ...... .,.,
Mot-O1 Mu-03
M .,.01 M or-0 2
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
MW -20D
-•lptia•BHC U f---<>---------------------------------------,-1il-bo1a-BHC
-dtlt1-BHC " 1---,,,__ _ _,.,,,__ ________________________________ _.,-==•••em!!.Cmc•.::·'c"cocc_,
' '
, ..
Mar-95 M 11-DO Mu-98 M 11-00 M ar-0 \
MW -2 2 D -•lpti1-0HC
I----------------------------------------{--b•t•·DHC -d•1t1-BHC
-a-;1mm1-BHC
"
M■r-03
i 1.2 +--------------------------------------------------1
1 1 0 o.a
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, ..
,., l--------------------------------------....::::,,a,_-1
' ..
M ■r-98 M • ,.;g M er-00 Mu-02 M ar-0 3
MW-230
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l--g1mm1·BHC
u+.-------------------------------------------------1
o.,
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-
M _,.ge Mtr-118 M 11-119
.
.
. -
Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
~ .
M ar-00 Mu-01 M ■r-02
. . . ~
M u-0 0
. -
Mu-00 M ■r•0 1 Mu-02 M ■r-03
•
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MW-JO D
M er-9Q Mar-00
MW-340
- -
MW-35D
~-"'-'=:
M or-00
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
a....,----/
M • r-01 Mt r-02 M ar-03
---Cll --
M ar-0 0 M lf•O 1
' .,___ -
M or-01 M • r-02 MI r-03
•
Attachment 6
• Five-Year Review
Geigy Chemical Co1p. (Aberdeen Plant), Aberdeen, NC
Lower Black Creek Aquifer Graphs
•
" --+-alpha-BHC MW-22L
--m-beta-BHC
" -.-delta-BHC
~ gamma-BHC
"
6
,/I'-,• -,
~ -
Mar-95 Mar-97 M■r-99
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-b•II-BHC
" _..,__BHC
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"
.
,
. = = -----"
-ff
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
.
-"-:,_
Mor-00 Mar-01
. . -._ . ;:~ A . ..... , ~
.0'~"--6 --
M.lr-01
•• r------------------------------------------------~
"
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•
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,.
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~.
t>,....,. r. ',V // " " . . ~ ---
MW .. l C
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
M • r-0 0
~-,
, ~ -----. -. -~
Mlr--01
"
"
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•
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d1lt1-BHC
Dl:IO.-gam mo•B HC
MW-JBL
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
.r,,,11,BJ-Cfil,@],0=,~-@'l@]-~GJ-rio ---" '" Mer-96 Mor-99 Mar-00 Mar-01 M ar-0'2 M or-0~
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l
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•
1:•lo~o-SHC I -~0011-!HC
-•0111-!HC
1--oommo•!HC •
" . •Ill
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
c:::i>-t=il-CS>•C3J-~c:il-'3>•Ci)-E3J.•Cal-CSJ. CS)-G-
M o r•I I ,. .,.,, u ... o 0 ".,.o,
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~ /4
/ --~ -
II or· 0 1 M o r-0 2
•
Attachment 7
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
Surface Water Sampling Graphs
O.H
.. ,
i 0.01
i 0,01
o.o,
-
0 .,.11,
0.1 4
0.1 2
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Mc F ■ rla n d 't Branch
• Five-Year Review
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
,~vc-v -"' =
,. u-91 Jul-91 Ooo-U ~,,.o, S •o·Ol Joo•O•
SW ·2
-•lpha-BHC McF ■rl1nd'1 Branch
--•11-BHC
-d1ll1-BHC
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M 11-91 MI r-97 M lt•98 MI r-99 Mu-00 M ar-0 1 M u-02 MI r-03
SW-3
-alpha-BHC McFarland's Branch
--beta-BHC
-delta-BHC
-gamma-BHC
"'
M ar-96 Mar-97 M ar-98 Ma r-99 M ar-00 M ar-01 Mar-02 M 11-03
•
0 ., •
-•lpha-BHC
-·•"·BHC
0 .1 2 -f----------j-do In ·8 H C
--g,mffl ■•BHC ..
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1 ' ! 0.0B .
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i .,_ o.oe . • a
I 0.06 • u
0.04
0.02
Mar-95 Mtr-96 M ar-97
SW -4
Aberdeen Creek
SW -&
Aberdeen Creek
• Five-Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
~~
MI r-86 M or-119
SW-6
Aberdeen Creek
M u-02
Ma/·03
• • Five.Year Review
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
0.1 4 SW-7
-•lph1-BHC Aberdeen Creek
-~•l■-BHC
0.1 2 -dol\1-BHC
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u
0,04
0 .02
M • r-9~ Ma r-99 Mor-97 M ir-9 6 M ar-99 M ar-00 M ar-0 1 M ar-02 M or-03
0.1 4 SW -8
-■lpn1-BHC Aberdeen Cretk
-bo\1-BHC
O.t 2 -d•lt1-BHC --1mmo-6HC
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I 0,08
u
o.o•
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Mor-U M or-9 f Mar-97 Mar-98 MI r-98 M or-00 M or-0\ M ar-02 M ot-03
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•
i
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Ray'• MIIICr11k
Control Location
• Five~ Year Review
Geigy Chemical Corp. (Aberdeen Plant}, Aberdeen, NC
G>-G>-C:l-G--m--ffi-m--e--e-s--G>-CSl
0.02
Jun-97 Jun-98 Jun-0O Jun-O1
o.,. ~---------------------,------------------------------7 SW-11-2
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0. I ~
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-•lpn1-8HC
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=_; ~ o.oa +--------------------------------------------------1
i i w o.oe +--------------------------------------------------1
.i
MI r-00
;' Jun:;.l0-03 10:05am From-RCRA T-446 P.001/003 F-284QP
TO:
•
? ~
t .. ~p ~
&vf! e; L-<a..,'f ~~
FAX TRANSMISSION FROM:
Diane Barrett, Community Involvement Coordinator
U. $. Environmental Protection Agency, Region 4
Economic Redevelopment & Community Involvement Branch
·· 61 Forsyth Street, SW, 10th Floor
Atlanta, GA 30303
Phone: [phone]
[phone] ! FAX# [phone]
~}, flcffh,,,,) DATE, · ~-w-,3
Nt'D NfJ
, J,a.;J0-03 10:06am From-RCRA .iance Section +404 562 8. T-446 P.002/003 F-284
Diane Barrett
05/07 /03 08:08 PM
Jon & Giezelle,
To: Jon Bornholm/R4/USEPA/US, Giezelle Bennett/R4/USEPA/US,
cc:
cc:
Subject; Aberdeen
In conducting 5-year review community interviews I spoke with Hugh T. Hambrick@
910-944-7368. He retired from the CORP Savannah, GA office and is an entomologist and
familiar witn pesticides and chemicals. He is very concerned about the quality of their city water
which comes from the various wells in Aberdeen. There is a city well approximately 2000 feet
from his propoerty which he thin Ks could be contaminated due to land use in the area.
He was very informative regarding the Farm Chemical area as well as the area surrounding the
Giegy Site_ I don't know if any of the information that he gave me will be relevant to either site -
you can decided for yourself. If interested, please give him a call.
-··-Geigy Site:
Mr_ Hambrick lives at 540 Shelton Drive, approximately three blocks from the Site. There
is a space of land (30 acres+) that for years was an active farm that grew row crops. The
gentleman that owned the land said that the used all kinds of chemicals on crops for years_ The
land has in recent years been sold to A.P. Johnson who is in the process of developing the land
into a subdivision. This property is bounded by Highway 211 on the south, Devonshire on the
north, and the land extends to a wood line approx_ 200 feet from Mr_ Hambrick's pro'perty on the
west. Mr. Hambrick's concern was that since this 30+ acres was a very active farm that used
pesticides and other chemicals, could these chemicals be impacting the Geigy site or other
groundwater aquifer areas?
Since the state is trying to locate the origin/source of the TCE plume, could this 30 acres
be a source area? The source could be the Crestline area, the metal company, or the asphalt
plant.
Aberdeen Pesticide, Farm Chemicals Site:
Mr. Ham[:>rick in 1984 was considering purchasing the old 8-acre Page house and
property which is behind Farm Chemical. He told me that there was a small airport & airstrip
that would have been between the Farm Chemical Site and the Page property_ He seemed to
have knowledge of past activities in the area behind Farm Chemical and the small industrial park
area as well as a residential well next to the Twin Area.
I wanted to give you two this information in the event it could have an impact on eitner or both
sites. ·
Diane
, J,neJ0-03 IO: 06am From-RCRA • anco Section [phone]. T-446 P.003/003 F-284
Michael Sheehan
<msheehan@pinrongr
p.com>
To: Diane Barrett/R4/USEPA/US@EPA
cc: Ray Horn <[e-mail]>, Harold Moats
<[e-mail]>, Jon
Bomholm/R4/USEPA/US@EPA 05/19/03 03:38 PM
Please respond to
msheehan
Subjec;t Geigy Site • Telephone conversation with Matt Davis
Diane:
Ray Horn of Olin Corporation and Harold Moats of Syngenta Crop Protection asked me to
contact Matt Davis, a near neighbor of the Geigy Site, following his recent comnrunication with
you.
I spoke with Matt today regarding the following items:
1. Site groundwater remediation. Matt simply wanted to know how progress on clean up of Site
groundwater was proceeding. I told him that pesticide concentrations in Site groundwater were
declining and that the extraction / treatment system had performed very well to date. Matt asked
if the timeframe for Site clean up was snll on the order of20 years and I confirmed that under
present circumstances, this would likely be the case.
2. Surrounding land use. Matt mentioned that some property immediately east of the Geigy Site
treatment building was for sale and may be logged / developed as residential properties. He
wanted to know if residential development of the properties, including the installation of multiple
septic systeins, would affect our remedy. This issue has come up before and l told Matt that the
construction of septic systems upg:radient of the Geigy Site would likely not have an adverse
impact on the remedy. Matt is aware of the TCE site just upgradient of the Geigy Site, and that a
TCE plume extends under the potential residential development. I told Matt that NCDENR and
EPA are aware of the TCE plume and that future response actions to address that matter may or
may not impact development of the property.
Mart has been at his present home, located at the end of Domino Drive, for many years now. I
believe he has enjoyed being surrounded by woods and simply wishes to maintain status quo. He
did not express any concerns about the Geigy Site and seemed to appreciate the update.
Call me if you have any questions.
Regards,
Michael A. Sheehan
The Pinnacle Consulting Group, Inc.
Suite200-8
200 East Camperdown Way
Greenville, SC 29601
Office: 864.467.0811, ext. II 7
Cell: 864. 787.8162
' Jun-10-03 09:58am From-RCRA iance Section +404 562 8 T-445 P.001 '-----
• • f ~ 5"-1· ~ _,_ R~'-h -e..w .
-?}j ~ .. ~ '<" ~ -o-'<--"~L PR01Jf'"'
G-~ ~ c_.,~~'\.\CA\ S::ft'e-.> Pv-·bk-c :t=-\1\·,~~ ~ "j
V / FAX TRANSMISSION FROM: by E-PA-
Diane Barrett, Community Involvement Coordinator
U. S. Environmental Protection Agency, Region 4
Economic Redevelopment & Community Involvement Branch
-61 Forsyth Street, SW, 10th Floor
Atlanta, GA 30303
Phone: [phone]
[phone]
FAX # [phone]
TO: c ~-~ DATE: F 18; ;y.rtJ3
;vc f" ;v f?--
Jun-10·03 09:58am From·RCRA .ianc, Section +404 562 8.
5-Year Review Questionnaire
Site
City/State
Phone No. Date: -~---'-fi-=-(p ,,-.· -'-.)..{)=-ti~?., __
/rJa.u ;(: 'la(!, (},11 C l"'-' Name of Citizen
Address
How long have you lived near the Site?
T-445 P 002 F-283
Are you familiar with EPA activities over the past years? ~.e.,, ~ ~ ~ t' f.u.,,,.., MfJ ~ y:;/4 Ct •
Do you still have any concerns regarding EPA clean up activities of the Site~ L/a,41/4 ~pk·
Over have you been pleased or displeased with EPA actions at this
-'H.,_ -'--W+"Y t,.-~
Do you think you have been adequately informed about clean up activities at the Site?
j,,;,) .
Is there any information about the Site that you would like to share with us that would assist in
our7):cevwsi~vit~ 1·
Is there someone else that you would like to recommend we contact for more information?
6
Do you have any suggestions that EPA can implement to improve communication with the
public?
[A copy of the 5-year review will oe placed in the Site Information Repository file located in the Site lnfom,ation Repository at ________________________ _
1nterv1ew conauctea by: ./ , A .,_;___,_,; ~
Date conducted : __ 01=-,,_l.,,,(,+/-"'6,,._2 ____ _ r I
Jun-10·03 09:59am From·RCRA .ianc, Section +404 562 8. T-445 P.003/014 F-283
Site
City/State
Address
5-Year Review Questionnaire
How long have you lived near the Site? . /,,;.,.J 1-4-u ~ M, m-a ,._,~
Are you familiar with EPA activities over the past years? ~
t!.LA-¾J)
> -~~~~'-:izz~Tcr~~u~~~;Sj"----
Do you thin u have bee
Is there any information about the Site that you would like to share with us that would assist in
our Sff r review of site activities? @ , . _ . _ -#--¼
o -&-fl. ~ · #~ ~ 4ff?d 14P: or '/+4 '½4
Is there som ne else th_at you would like to d we contact for more information?
~
Do you have any suggestions that EPA can implement to improve communication with the
public?,=:--,------------------------------
[A copy of the 5-year review will be placed in the Site Information Repository file located in the Site
Information Repository at ________ ~----------------
Interview conducted by: tx'.i~._,, ~
Date conducted: S-/v (QJJ
Jun-10·0! 09:59am From·RCRA ••nee Section [phone].
5-Year Review Questionnaire
Site
City/State
How long have you lived near the Site?
Are you familiar with EPA activities over the past years?
T-445 P.004/014 F-28!
Do you still have any concerns regarding EPA clean up activities of the Site?
71t1YLL-'Pt:4!:~
Overal have you been pleased or displeased with EPA actions at this Site? ~
Do you think you have been adequately informed about clean up activities at the Site? ywl ~Yn-,!Pic: ~ ~qk{p )
Is there any information about the Site that you would like to share with us that would assist in
our 5-year review of site activities? ~
'--Z]a-t: 4d•~ 1 ry
omeone else that you would r e to recommend we contact for more information?
' ~
Do you have any suggestions that EPA can implement to improve communication with the
pu~ d:1-i:bf¥if!!:!jtt ~~~:tr~~~~~
[A copy of the 5-year review will be placed in the Site Information Repository file located in the Stte
Information Repository at ,£&ii, ,{. c: i 1tu::,. 7,.l, et
Interview conducted by:! A~_,..)~-
Date conducted : d: /f., /4,;o?: ~~-1-. -"-7-f-==-.,..,_ ___ _
Jun-10-03 09:59am From-RCRA .,nee Section [phone].
5-Year Review Questionnaire
Site
~ate
Date: -~-~,,__,t'--,,'-' a-D_tJ_?i __
Name of Citizen
Address
T-445 P.005/014 F-283
/IJ/ f". ~ 11-.
Do you live near the Site? If yes, how long? ---'?{_,._,_A-~---------------
Are you familiar with EPA activities over the past years? _...:a;~;iafir.oir2:r:'.=-------------
~</ w--v.-/ '?ryf nllf":'-e.J-4/e£.e What is your overall impression of the project? qri:"
been pleased or displeased ~ith cleanup aC\ions at this Site?
•
Do you still have any concerns regarding EPA clean up activities of the Site? " -. ~
•
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
em~ ency responses from local authorities? If so, please give details. __________ _
Is t ere someone else that you would like to recommend we contact for more information?
fu..-
Interview conducted by; :A~ ~
Date conducted : --'s;J.+z-"~r-Z-"03..,_ ____ _
Jun-I 0-03 10:00am From-RCRA .iance Section +404 562 8.
Site
City/State
5-Year Review Questionnaire.
J. c~~ ~ . zttt~. Y). I?_. ;LJ-217
T-445 P.006/014 F-283
Date: ~ /4, J-4 o3 • Phone No. (o/frJ J 9#-(6 03 . ,
Name of Citizen L/ad.±t· ~
Address ~,~
How long have you lived near the Site? ,3fr~ ,:fr,..., ,tu.,r,,Ju ~ a,,,) £.tz:,
Are you familiar with EPA activities over the past years? -"~~p_..,_)=:._ _______ _
Do yo · · · up activities of tt\e. Site?
u 0} 7¾.
Do you t ink you have been adequately informed about clean up activities at the Site?
Is there any information about the Site that you would like to share with us that would assist in
our 5-ear review of site activities?
{Jl'--4~~'4-f!::.~~~-#:f:;~2.;fl...4,~~~=,-:::4!:.U....d&.'.:.Lk~~~e__.,,"7
. au_
~-recommend we contact for more information?
Do you have any suggestions that EPA can implement to improve communication with the
public? ----r-r----,---,---:,----,-------------,..----.,-------
c> -,,_,._, d}t,, ~ ~ (JV~
(A py of the 5-year review will be placed in the Site Information Repository file located in the Site
Information Repository at-------------------------
lmerview conduc1ed Dy: &~ ~·
Date conducted : S/<t IA 3 I I
Jun-10-03 10:00am From-RCRA .ance Section [phone].
5-Year Review Questionnaire
Site
City/State
T-445 P.007/014 F-283
Address
How long have you lived near the Site? 40 -· ~ ~ /XfUl,,,V !kW ~~ Are you familiar with EPA activities over the past years?
Do vou still have any concerns regarding EPA clean up activities of the Site?
Overall, have you been pleased or displeased with EPA actions at this Site? '::1M,,? li/fe« .. J ti
Do you think you have been adequately informed about clean up activities at the Site? _ . ~ ~ ~ U ,,ful;;, 0me~ ~ ~ :i ~ n---tl 11 . .
I O ' ~
Is there any information about the Site that you would like to share with us that would assist in /
o,c ~,.,.,~,~ of siW actMties? #2 " ~ Al J.....,_, ~~~~~ ~ /(/4-'£ I)
Is ther. . someone else that you would like to recommend we contact for more information?
(}
Do you have any suggestions that EPA can implement to improve communication with the
public? ---------------,-----------,---~--~ 11° -~th ~ 'ldr ,;,.,, vd:s +~ 4
jun-10-03 10:01am From-RCRA .ianco Section [phone]._ T-445 p 008/014 F-283
5-Year Review Questionnaire for Contractor/Site Manager@
Site
City/State
~ (}_~(lr-
Date: /'))O:v' '4 c)o o 3 'VMH-4 ill o-d;;J . Name
Phone No. µ;;,;,)
Address
tise current status of construction (i.e., budget, schedule) ,,;t-H ~ ~ 1,
Have any problems been encountered which required, or will require, changes to this remedial design
or this ROD?
ie,~ c~ ~fJ~-c:w;U-~d-i«~; ~
4~ ~ «r41 ,,_,_e_) ~ '-u,-d_,( A Cu~ w YoJe
/u-1~ a.~.
Have arl\i problems or difficulties been encountered which have impacted construction progress or
implementability? ·
Do you have any comments, suggestions, or recommendations regarding the project (i.e., design,
construction documents, constructability, management, regulatory agencies, etc.)?
Do you think the community as a whole has been pleased with Site operation
that the clean up has been effective? -1,.~~---=~~~~~~(l.[,.!!:.!,!l;¥1:.Q;~,:.J;,.~~;;::__
· Interview conducted by -----'--~~J..,4..f.../..:::..._:.:;.:._-'-~....:....-....:.... ___________ _
Date conducted _ _.'1/b.__....,,=,-F.---"1$:.,t./....;:,)..;__tf..:j;___
Jun-10-03 IO: 01 am From-RCRA .ianc, Section +404 562 8.
Site
City/State
Address
5-.Year Review Questionnaire
~~-~.tJ.C. o1W
)
How long have you lived near the Site?
Are you familiar with EPA activities over the past years?
T-445 P.009/014 F-283
Do you still have any concerns regarding EPA clean up activities of the Site?
ll
Overal have you been pleased or displeased with EPA actions at this Site?
Do yo¥~ you have been adequately informed about clean up activities at the Site?
Is there any information about the Site that you would like to share with us that would assist in
our 5-year review of site activities?
0
Is there someone else that you would like to recommend we contact for more information?
Do you have any suggestions that EPA can implement to improve communication with the
public? ·
~
(A copy of the 5-year review will be placed in the Site Information Repository file located in the Site
Information Repository at----,---------,--------,---------
U-<,.M. ~ ~~ ~/ ~ h...J6-~ /1-H<dl.~
~,W~~-f
1nrerv1ew conouctea oy: J,<~ M-,AA,,uk
Date conducted: ".S"/7 /tJ3 '
Jun-10-03 10:02am From-RCRA .iance Section +404 562 8.
Site
City/State
Date: ¾ '? oL?£?3
Name of Citizen
Address
5-Year Review Questionnaire
~ eL~&;;t/4,
Phone No.
'1b Im t;.t-. ud!sel"
T-445 P 010/014 F-283
Do you live near the Site? If yes, how long? . ~.w y 6,Jf frt..t<4r 3/
Are you familiar with EPA activities over the past years? 1-k!::::' . .
What is your overall impressi~n of the project? ~ ;id td/, Ct:iA.r.$, -,d,,,t;_, ~ ,9-;) a-r,...,,s,d ~ y,.,.,# 4+?icv e-41, %· ~~~
tf 4A e e <' 1f ◄ :%3 e L f/ ~{?It t tu(J
4 a11, have you been pleased or displeased with cleanup actions at this Site?
~~u c' u.
What effects, if any, have site operations had on the surrounding community? A,, efl, ~-,, .. ' QA ea O½¾ Y~ a_.,.-o/--4 o/-:.
Do you still have any concerns regarding EPA clean up activities of the Site?
d
Do you think you have been kept adequately informed about clean up actMties at the Site? ____ _
LJ.)
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details. ____________ _
D
Is there someone else that you would like to recommend we contact for more information?
Do you haye any suggestions that EPA.can implement to improve communication with the public?
'J),,.c ae7, 4-x-'t 'hLJ.) 1 =o .
Interview conducted b~ A~ ~
Date conducted : 1,. :J..Ob 3
Jun-10-03 10:02am From-RCRA. iance Section +404 562 8.
Date:
Site
City/State
~
Name of Citizen
Address
5-Year Review Questionnaire
)
T-445 P 011/014 F-283
Do you live near the Site? If yes, how long? ~~~.v.)~;--3~a!!....y,a..i:.e .taf!.:11=4-'::..._ __________ _
Are you familiar with EPA activities over the past years? ---la~~' .:!.,.a:;:.J ___________ _
What is your overall impression of the project? _ _./)""-"nJ,,-=""-'-----------~----
Overall, h ve you been pleased or displeased with Cleanup actions at this Site?
-6--u
What effects, if any, have site operatiO!)S had on the surrounding community? Ptdi<nf fef
' ~d~ .P1l-(¼'Si -w-a.:f:w
Do y'.7:]~11 have any concerns regarding EPA clean up activities of the Site?
Do you think you have been kept adequately informed about clean up activities at the Site? ____ _ ¼f": G,.,.. %1'::'. ~ ~'± ~ 764-::5 £~-
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
ememency responses from local authorities? If so, please give details. __________ _
Is there someone else that you would like to recommend we contact for more information?
0
Do you have any suggestions that EPA can implement to improve communication with the public?
Interview conducted by: ,A, ; ' '.J &A£tt
Date conducted : _ __,s-;;"-L..z.Lz,_I d::..L,._ ____ _
Jun-10-03 10:02am From-RCRA .ianc, Section +404 562 8. T-445 P.012/014 F-283
5-Year Review Questionnaire for Govt. Officials
Site
City/State ~~.tCey-
i
Date: -Yrry..:....:...."-"4----L11""-· ,;1.J;""'t.B=--
Name
Address
What is your overall impression of t~e project? C ~ ~ ~ .
Have there been routine communications or aotivities conduoted by your office regarding the Site?
(Site visits, inspections, reporting activities, etc.) If so, please give purpose and results.
~
Have there be
by your office? If so, please give details of the events and results.
Do you feel well informed about the Site's activities and progress? _;µ...._=:::.. _______ _
Do you think clean up activities at the Site have had a positive or negative impact on the community?
In what ways? ---·--~------------------------
f ffl~ ;,.J ~ d;Y£ru cfr ... J ¥
Do you have any comments, suggestions, or recommendations regarding the Site's management or
operation? -------------------------------
6-
Interview conducted by __ ""ed;-=,~=-·='---'~=-=.:...;;....::.... _______ _,, ______ _
Date conducted __ 1h~~?c....c.,+-~z_,_,.;l=o~o_3~----
Jun-10-03 , .. ~:~3~m From-RCRA .,nca Section +~04 562 8 T-445 P 013/014 F-283
/<}M,',~-cff)J._ Ir~, 1.¼,,. 'h '6.,__,(Mt_. • ·• • ~ ~~1;11
-~ ~Year Aeview Questionn ire ~~~-
Site
City/State
Name of Citizen
Address
Do you live near the Site? If yes, how long? L/.e-¥? ¥fX!£/li 3 '{&d)-~/1&'~
Are you familiar with EPA activities over the past years? ~ ~ ~ ~
. e&o z; ~ k-4-!!i ~ ,J), What !s your overall impression of the project? -'-""'-'-'-"-'-""-•-==--=-~.::;1~='--'==v=:--"'=.;.:;cC'ff=.::;__;':;F--;,;;....--
What effects, if any, have site operations had on the surrounding community? ________ _
Do you think yo~have been kept adequately informed about clean up activities at the Site?_· ___ _ ~ ~ ~
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details, __________ _
Is there someone else that you would like to recommend we contact for more information?
Do you have any suggestions that EPA can Implement to improve communication with the public?
Interview conducted by:. __ _.A""'"',µ""'"'41""""/--'-b=¼d{_=e«::J..·-· _______________ _
Date conducted : -~tb~,--~~_...,;..,o ... g_3,..._ __
.
~ i
: S'. ~ i~
i · -~ 'l f" 1 l ~1 J J ~1 f~\ ~ ~J
I j~1 .j ~ -sf i.ij_ ~
• l ;i ~ J .;, :~ " , * ~ ' ~ t ~i J . -\,)~ ~ .,r, j ~ 'l
' =
' ~ . ~ ~
~A-• /
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
b 'I~ ~~":i~
ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W. ·,·\
Atlanta, Georgia 30303-3104 /: (,
May 29, 2003 ;d /
f •
4WD-NSMB
I . ; ( f 1.•
' ~.! /
Mr. Stacy Samuelson
Environmental Resources Section/Wilmington District
U.S. Army Corps of Engineers
P.O. Box 1890
Wilmington, Notth Carolina 28402-1890
SUBJ: Compiled Comments on the Draft Five-Year Review Report for the Geigy Chemical
Superfund Site in Aberdeen, Moore County, North Carolina
Dear Mr. Samuelson:
The U.S. Army CoqJs of Engineers (the "Corps") was tasked by the Environmental
Protection Agency ("EPA") to conduct the first Five-Year Review for the above referenced
Superfund Site. This effort was provided under EPA's Work Authorization Form for lntcragency
Agreement Number DW96945884A. EPA felt that a third patty evaluation of the Remedial
Action would provide the greatest benefit in the Five-Year Review process. The CoqJs
submitted the draft report on April 24, 2003. Copies of this report were disseminated to Notth
Carolina Department of Environment & Natural Resources (NCDENR), The Pinnacle Consulting
Group, Inc. (the Potentially Responsible Parties' (PRPs) consultant), Giczcllc Bennett, previous
Remedial Project Manager, Region 4 Office of Technical Services, and COM, Inc, (the Agency's
oversight contractor) for review and comments.
The Agency appreciates the CoqJs' efforts in developing this Draft Five-Y car Review
Report and offers the following comments in an effo1t to improve the overall quality of the
document. Below are the Agency's comments and enclosed are comments from NCDENR,
dated May 28, 2003 and the PRPs, dated May 21, 2003. The majority of the Agency's comments
fall into one of three categories: typos, requesting clarification, and requesting additional
information/data to substantiate a statement/conclusion stated in the report. For your
convenience all comments are referenced to a specific page and Section and/or table/figure of the.
report, as applicable. The comments below use "strikeout" and "redline" for deleting or adding
specific text, respectively.
·1n order to address all parties' concerns, the Agency requests the CoqJs develop responses
to all comments. The CoqJs' response will be ~hared with all reviewers and will be the basis of
future discussions on the Five-Year Review. After reviewing the comments, it may be advis:1ble
to discuss any major issues via the telephone: The Agency also requests that after reviewing all
s
• • 2
comments, the Corps provide the Agency a time estimate for preparing responses to the
comments as well as revising the Draft Five-Year Review document.
Also enclosed are copies of the five-year review questionnaires the Agency filled out as
part of our effort to interview a few citizens arou11d the Site. As can be seen, I redacted pertinent
information about the person/people interviewed. These questionnaires should be incorporated
into an appendix in the revised report and a reference to them should be made in Section Vil,
Subsection A.
Below are the Agency's comments.
I. Move the signature block for the Waste Division Director to the end of "Summary Form
Table" which is currently on page vii.
2. Signature block should look like the following:
Winston A. Smith
Director, Waste Management Division
U.S. EPA Region 4
3. Page iii. List of Acronyms: Add "CRQL --Contract Required Quantitalion Limit".
4. Page iii, List of Acronyms: Add "NCGWQS
Standards".
North Carolina Groundwater Qual_ity
. ,. , .. -
5. Page iii, List of Acronyms: "TCL" should read "Target Co11t,uni11ant Compoy_~1ci List".
6. Page iii, List of Acronyms: Add "HRS -Hazardous Ranking System" to the list.
7. Page iv, EXECUTIVE SUMMARY, first paragraph, first sentence: This five year review
is policv, not statutory, meaning that unlimited use of the site will be allowed when the
remediation is complelc. This is also why the trigger dale is the Preliminary Close-Out
Report (PCOR) and not on-site construction.
8. Page iv, EXECUTIVE SUMMARY, fourth paragraph. first sentence: Please change this
sentence to read as follows, " ... (RA) was eonduetcd _implemented from ... "
9. Page iv, EXECUTIVE SUMMARY, fifth paragraph, second sentence: Please_ch,a!]g<!,!his
~cntence to read as follows, " ... adopted by EPA through the issuance of :m ~h'" Janl!Ql)'.
1998 Explanation of Significant Difference (ESD) to the Rc1ncdial Action in Ja11t1my
+998-.''
10. Page v, EXECUTIVE SUMMARY, top of page: The acronym "µg/L" should be defined
as this is the first time this acronym is used.
•
3
11. Page v, EXECUTIVE SUMMARY, Issue #3, second sentence: Change this sentence to _,z:,-:-:_...-.-e. -----:"'-, ... ,-:-. ~~ad:;:;:p,2~7,ntiall~ cxtcnd_ing ti1nc to acl.1ice_c rented~ g?a1s fu£r~~~i.~-gih~ .. g·Q~~tiQf
remediat10n. The impact 1s not a reduction m remediation of on-slle grou_ndwater, but
the decreased life of the carbon filters.
12. Pages vi and vii, Five-Year Review Summary Form: Please format this table so that it fits
on a single page along with the signature block at the bottom of the page (refer to
comment# I above).
13. Page vi, Five-Year Review Summary Form, "Review Period" block: The dates in this
block should read "l/03 -6/03".
14. Page vi, Five-Year Review Summary Form, "Datc(s) of Site Inspection" block: Please
insert the date, February 17, 2003, into this block.
15. Page vi, Five-Year Review Summary Form, "Type of Review" block: This is a "Policy"
review. Please delete all the other options as this will allow the length of the table to be
reduced.
16. Page vi, Five-Year Review Summary Form, "Trigger Action" block: The "Other'' box
should be checked and include "Preliminary Close-Out Report" for "(specify)" (refer to
comment #7 above). Please delete all the other options as this will allow the length of the
table to be reduced.
17. Page vii, Five-Year Review Summary Form, "Protectiveness Statement" block: Insert at
end this block the following statement, _"The next Five-Year Review should be scheduled
five years from the date of this Review, in "MONTH" 2008. The "MONTH" needs to
reflect the month that this report will be signed by the Waste Division Director.
18. Page vii, Five-Year Review Summary Form: Insert at the end of this table another block
entitle, "Other Comments" and type "None", if that is the case.
19. Page I, I. INTRODUCTION Section, third paragraph, first sentence: This review is
"policy". A policy review requires a review five years after construction completion as
mentioned here, a statutory review requires a review five years after construction start.
"Although not required by statute, this review is being conducted in accordance with EPA
policy. EPA conducts five-year reviews as a matter of policy at: ( I) sites where no
hazardous substances will remain above levels that allow unlimited use and unrest1icted
exposure after completion of remedial actions, but the cleanup levels specified in the
Record of Decision (ROD) will require five or more years to attain; (2) sites addressed
before Superfund Amendments and Reauthorization Act (SARA) at which the remedy,
· upon attainment of cleanup levels, does/will not allow unlimited use and unrestricted
exposure; and (3) removal-only sites where hazardous substances remain onsite at levels
•
4
that will not allow unlimited use and unrestricted exposure. This site has been reviewed
because cleanup levels will require more than five years to attain."
20. Page 1, Section I. INTRODUCTION, third paragraph, second sentence: Change this
sentence to read, " ... five-year review's-consistent. .. "
21. Page 2, Section III. BACKGROUND: A figure should be included in this section
providing the topography of the area.
22. Page 2, Section III. BACKGROUND, Subsection A., se,cond paragraph, second sentence:
. Typo, should this sentence read, "The site has topology topog~ar.hy typical of the ... "?
23. Page 3, Section III. BACKGROUND, Subsection C, first paragraph, first sentence: This
sentence states the years of operation were from 1947 to 1989. This is inconsistent with
what is stated in Table 1 (page 2), the first row in this table states the years of operations
were from 1947 to 1987. Please correct this contradiction.
24. Page 4, Figure 2: This figure needs a scale.
25. Page 5, Section IJI. BACKGROUND, Subsection D., second paragraph, last sentence: ls
there any information available as to why only three PRPs enter into an Administrative
Order on Consent with the Agency? If so, this information should be included in this
paragraph.
26. Page 6, Table 3: Change this table as follows:
Groundwater Clean-Up Standards•
Contaminant Groundwater Clean-up Corresponding Risk Level Basis of Goal Standard (µg/L)
Aldrin 0.05 5.0 X 10·6 CRQL
Alpha-BHC 0.05 1.3 X 10·6 CRQL
Beta-BHC 0.05 4.0 X 10·7 CRQL
Delta-BHC 0.05 ND CRQL
Gamma-BHC 0.05 3.0 X 10·7 CRQL
Dieldrin 0.1 8.3 X 10"6 CRQL
Endri n Ketone 0.1 ND CRQL
Toxaphene I 6.7 X 10·6 NCGWQS ·
CRQL --Contract Required Quantitation Limit
NCGWQS --North Carolina Groundwater Quality Standards
ND --Not determined, Toxicity data unavailable, risk levels could not be calculated.
•
5
27. Page 6, Table 3 and Page 7, Table 4: Table 3 presents a performance standard for gamma
BHC of 0.05 µ.g/L and Table 4 presents a performance standard of 0.2 µ.g/L. Is this
correct or is this a typo? If this is correct, then the text needs to explain why there are two
different performance standards for gamma BHC. .
28. Page 8, -Section IV. REMEDIAL ACTIONS, Subsection B., first and second paragraph:
Both of these paragraphs state that specific masses of soil and debris were removed from
the Site: If known, the actual location of where this soil/debris was taken should be
incorporated into these paragraphs.
29. Page 8, Section IV. REMEDIAL ACTIONS, Subsection B., first paragraph, last line:
Change this line to read, " ... TCE found in two qn-site well was site-related."
30. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C: This section or the previous
section should include, at least, a process flow diagram for the groundwater treatment
system.
31. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C: Somewhere is this section a
statement needs to be included stating how the vegetative cover is perfo1ming (i.e., the
status of the vegetative cover/tress).
32. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., first paragraph, fourth
sentence: Typo, change this sentence to read, " ... it was agree.cl by all parties ... "
33. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., first paragraph, fifth sentence:
This sentence states, "Therefore, the last round of monitoring well sampling ... " is not a
true statement. It might have been the "most recent" sampling, but monitoring well
sampling will continue for quite some time at this Site. Please reword.
34. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., first paragraph: This section
or the previous section should include. a figure showing the locations of the extraction
wells and the treatment building, the associated piping, and the infiltration galleries.
35. Page.8,.Section IV. REMEDIAL ACTIONS, Subsection C., first paragraph: It is not clear
from either the text or the figures referred to if all the points identified in these figures _are
sampled each time. Text needs to be added identifying which monitoring points arc
sampled on a regular basis.
36. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., first paragraph: Text is not
clear in how the treated groundwater is discharged to the infiltration galleries. Is
discharge directed to all of the infiltration galleries constantly or is the flow rotated
between the infiltration galleries.
• •
6
37. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., first paragraph, fourth
sentence: This sentence mentions the submittal of a "five-year review" by,the PRPs'
contractor. Was this a "five-year review" or was this a document entitled "Downgradient
Remedy Summary Report, Geigy Chemical Corporation Site, Aberdeen, North Carolina?"
Please correct, if necessary.· Refer to comment #tgb40 below.
38. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., second paragraph. first
sentence: This sentence states, " ... there have been few problems or breakdowns of the
system." Please elaborate and provide supporting data for this conc_lusion. What is meant
by "few"? It may be helpful to use graphs/tables to show the daily pumping history. A
calculation of percent downtime should be provided for the system as a whole as well as
for each individual extraction well to support this conclusion.
39. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., second paragraph, sixth
sentence: Why is it only suspected that increasing TCE levels have decreased the
longevity of the carbon adsorption canisters? It would be helpful to include data that
shows the concentrations of contaminants (TCE) entering the treatment system are
increasing thereby decreasing the longevity of the carbon.
40. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., second paragraph, seventh
sentence: Please elaborate on the signiricant variations that were projected in the ROD and
ESD that have not occurred during O&M.
41. · Page 8, Section IV. REMEDIAL ACTIONS, Subsection C., second paragraph, last
sentence: This sentence states, " ... unless off-site conditions necessitate changes." This is
ambiguous. What does it mean? Off-site conditions will not negate the need for
continued remediation on-site. The last sentence should be deleted or reworded.
42. Page 8, Section IV. REMEDIAL ACTIONS, Subsection C: This section or the previous
section should include a figure showing the location of nearby municipal supply wells in
relationship to the Site.
43. Page 9, Figure 3: This figure needs a scale.
44. Page 9, Figure 3: This figure would be enhanced if it showed the location of the Geigy
Site. If possible, any municipal water-supply wells that are within the mapped area should
also be shown.
45. Page 9, Figure 3 is small and is difficult to read. Some well labels fall over -
roads/railroads or on each other and cannot be read.
46. Page 10, Figure 4: This (igure needs a scale.
7
47. Page JO, Figure 4 should show where the treatment building and infiltration gallery are
located.
48. Page 11, Section V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW: This
section states that this is the first five-ys:ar review and that ho other report is available.
However, the fourth sentence on page 8, Section IV, Subsection C, first paragraph states,
"Following the submission of a five-year review to the state and EPA in 2002 ... " Please
clarify this contradiction.
49. Page 11, Section VII. FIVE-YEAR REVIEW FINDINGS, Subsection A, first sentence:
Typo, change "Potter's Pits" to "Geigy".
50. Page 12, Section YU. FIVE-YEAR REVIEW FINDL'\/GS, Subsection B, fourth bullet:
Typo, correct the spelling of Harold "Moats".
5 I. -Page 13, Section Vil FIVE-YEAR REVfEW FINDINGS, Subsection C, last paragraph,
first sentence: This sentence states the following, 'The site appears to be in compliance
with the ARARs identified in the ROD." This sentence means that the groundwater
performance standards have been achieved the impacted aquifer has been restored. This is
not CotTeCt.
52. Page 13, Section VII. FIVE-YEAR REVIEW FINDINGS, Subsection D, second sentence:
Michael Sheenan, with The Pinnacle Consulting Group, Inc., recently informed the
Agency that a portion of the prope11y was recently purchased and the new owner is
contemplating logging the property. Please contact Mr. Sheenan to get an update.
53. Page 13, Section VII. FIVE-YEAR REVIEW FINDINGS, Subsection D, fifth sentence:
This sentence makes the following statement, "and the groundwater plume appears to be
contained". This report docs not provide any information or data that substantiates this
statement. This conclusion is a key conclusion for this document and thus it needs to be
thoroughly substantiated. It would be helpful if the following information was
incorporated into the repot1:
a) graphs showing expected and observed contaminant concentrat_ion trends at
individual wells
b) maps showing expected and observed contaminant plume extent and concentrations _
at various time intervals
c) _maps showing observed water level contours for the various aquifers and the
· extraction well capture zones
d) a comparison of the surface water/sediment concentration data to standards.
All of this data is necessary in order.to document adequate containment of the
downgradient groundwater contamination by natural attenuation ..
• • 8
54. Page 13, Section Vil. FIVE-YEAR REVIEW FINDINGS, Subsection D, sixth sentence:
This sentence states, "Toxicity and other factors for contaminants of concern have not
changed". This report does not provide any information or data that substantiates this
statement. Was the information in EPA's Integrated Risk Information System (IRIS) or
another data base checked. If so, then a statement needs to be incorporated into this
paragraph, that states something like "after reviewing IRIS, it was determined that the
toxicity and other factors for the contaminants of concern have not changed". This
paragraph should also identify those contaminants that were checked in IRIS.
55. Page 13, Section VII. FIVE-YEAR REVIEW FINDINGS, Subsection E Groundwater
Data, first paragraph, first sentence: Typo, this is an incomplete sentence.
56. Page 13, Section VII. FIVE-YEAR REVIEW FINDINGS, Subsection E Groundwater
Data: The text of this subsection should indicate whether or not the surficial aquifer wells
included in Table 5 are within the area of capture for the Geigy extraction wells (and thus
concentrations from these wells may reflect not only natural attenuation of contaminants
but indirect effects of ground-water withdrawals from the underlying upper Black Creek
aquifer).
57. Page 13, Section VII. FIVE-YEAR REVIEW FINDINGS, Subsection E and Table 5 on
page 14: It is not clear from either the text or the table if the wells listed in Table 5 are the
only surficial wells being monitored. If there are other surficial well being monitored,
then Table 5 needs to be expanded to incorporate these wells.
58. Page 14, Table 5: Table 5 includes an entry for MW-IOS dated 10/23/2002. The
remainder of the wells have an October 200 I sample as the last entry, and the table
indicates that the reported data arc from the period 1990 to 200 I. ls the I 0/23/2002 data
point for MW-I0S correct?
59. Page I 5, Table 6 and 7: The Agency realizes that there is a lot of monitoring data
availilblc and that these two tables attempt to condense this data into an easy to view
format that gives a "Snapshot" of what is happening in the groundwater. However, as
presented, the reader cannot tell if the levels of contaminants arc extremely high or just
over performance standards in a particular well nor can the reader tell whether or not there
arc any concentration trends in the listed wells. Tables similar to Table 5 should be
included in the report for all wells sot.hat this type of information available.
60. Page 15, Table 6 and 7: It should be specified which of these wells is included in the
"pump-and-treat" remedy and which arc in the "downgradicnt, MNA remedy."
61. Page 16, Section VII. FIVE-YEAR REVIEW FINDINGS, Subsection E, first paragraph:
This brief discussion on BHC concentration trends omits a number of wells. Since the
concentration trends or absence of trends is a prime indicator of remedy performance,
there should be a complete discussion of all wells where there are or have been detections
• •
9
of BHCs. Ideally this discussion would be accompanied by charts that show concentration
trends over the period since monitoring of the remedy performance began. However, it is
acceptable to only include a text discussion of the trends, provided that a comprehensive-
tabular presentation of the available data is included in the five-year review·.
As one element of the text discussion of BHC concentration trends, it would be useful to·
provide a separate evaluation of the trends or lack of trends at monitoring wells that are
outside of the area of capture for the extraction wells but in relatively close proximity to
that area. Such a discussion should make a staiement about whether or not there are
indications that operation of the extraction wells has demonstrably reduced contaminant
mass flux into the area downgradient of ground-water capture by the extraction wells.
62. Page 16, Section VTI. FIVE-YEAR REVIEW FINDINGS, Subsection E, first paragraph,
last sentence: This sentence states that no BHC isomers have been detected in the sentinel
wells for Town Well No. 2 and Ray's Mill and Aberdeen Creeks .. However, according to
Table 7, BHC isomers were detected sentinel wells MW-38L and MW39L. Please correct
this contradiction.
63. Page 16, Section VII. FIVE-YEAR REVIEW FINDI_NGS, Subsection E, last paragraph:
This paragraph is confusing. ls TCE a contaminant of concern for the Geigy Site?
64. Page l 7, Table 8: This Table presents TCE concentration data for some of the monitoring
wells. Some explanation is needed in either the table or in related text that explains why
this subset of wells is included in the table.
65. Page 17, Section VII. FIVE-YEAR REVIEW FINDINGS, Subsection E Groundwater
Data: The text on this page discusses TCE contamination and identifies MW-ISD as being
at " ... the western edge of the remedy area ... " This designation is somewhat misleading, as
it suggests that no remedy is applicable to wells furthc"r west. lt would be better if the text
read something like "MW-18D at the western edge of the area where ground water is
being extracted ... "
66. · Page 18, Section Vill. ASSESSMENT, Question A: Having figure(s) that provide extent
of plume with isotherms, figure(s) showing piezometric surface contours, figure(s)
showing capture zones associated with the groundwater extraction system, graphs
showing concentration trends in key wells would be helpful to show and verify the
conclusions being stated in this section.
67. Page 18, Section Vill. ASSESSMENT, Question B, first sentence: This sentence states,
"The assumptions used for the remedy ... " The "assumptions" should be listed in this
paragraph.
68. Page 18, Section Vill. ASSESSMENT, Question C, third sentence: Typo, change this
sentence to read, " ... support of selection of monitored natural attenuation ... "
• •
10
69. Page 19, Section X. RECOMMENDATIONS AND FOLLOW-UP ACTIONS, last
paragraph: This paragraph discusses the presence ofTCE, I don't know if it is appropriate
to include this as a recommendation for the Geigy site since the Agency has already stated
for the record that TCE is not a Site related contaminant, but the City of Aberdeen is
concern about the presence of TCE because recent analytical data show that levels of TCE
are rising in one municipal well and beginning detected in two other city wells in the
vicinity. One recommendation may be to evaluate whether or not the existing
groundwater extraction system is exasperating the spread ofTCE in the groundwater.
70. Page 19, Section X. RECOMMENDATIONS AND FOLLOW-UP ACTIONS: The ROD
states 'The Geigy Site shall have a fence and proper warning signs posted in visible
locations in order to provide site control where humans have access to the release."
Since there is no longer a release of contamination from soil issue at the site, there is also
no longer an issue of a fence being needed at the site. Hence, this issue and
recommendation should be deleted. This recommendation may be changed to read for the
Agency to issue an ESD to eliminate the requirement for fencing and posting signs.
71. Page 19, Section X. RECOMMENDATIONS AND FOLLOW-UP ACTIONS:-The
discharge permit is a state issue, not a EPA/CERCLA issue. It is not really even needed
since this is a Supcrfund site. Whether the pcnnit says 5 or 7 wells, as the text points out,
docs not affect the operation or implementation of the treatment system. Should this item
. be a recommendation?
Again, the Agency appreciates the effo11s of the Corps in preparing this report. As stated
above, the Agency requests that the Corps develop a response to all comments. Please inform
the Agency when the Corps will be able to prepare responses to these comments and a time-
frame for submitting a revised document. If you have any questions, I can be contacted at 404-
562-8820.
Sincerely, _.,..,.,-
. I c_/" t DrfVNI
Jon Bornholm
Remedial Project Manager
Enclosures (3)
I. Comments from the Geigy Chemical Corporation Site Committee (May 21, 2003)
2. Comments from NCDENR (May 28, 2003)
3. 5_-Year Review Questionnaires·
. cc: Giezelle Bennett, EPA
Tim Eggert, COM, Inc.
Randy McElveen, NCDENR
Bill O'Steen, EPA
Michael Sheenan, The Pinnacle Consulting Group, Inc.
•
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
May 21, 2003
Mr. Jon Bomholm
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
61 Forsyth Street, SW I Ith Floor
Atlanta:, GA 30303-3104
RE: Draft Five-Year Remedy Review Report
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Jon:
Thank you for providing Olin Corporation and Syngenta Crop Protection the opportunity to
review the draft version of the Geigy Site five-year remedy review. We are pleased with the
findings of the review and offer the following minor comments:
I. Page 5, Section IV.A, second paragraph, first sentence: For accuracy, please revise the
sentence to read "The groundwater remedy was targeted at removal of site-related
contaminants in the groundwater through groundwater extraction and on-site treatment by
carbon adsorption."
2. Page 8, Section IV.C, first paragraph, second sentence: For historical accuracy, please
revise the sentence to read "The Pinnacle Consulting Group of Greenville, South Carolina
currently has the treatment monitoring and O&M contract for the PRPs."
3. Page 12, Section VII.B, first paragraph, forth bullet: Change "Harold Mose, Syngenta
Crop Systems" to "Harold Moats, Syngenta Crop Protection".
4. Page 19, Section X, third paragraph. The Companies will update the number of extraction
wells listed in the Site Groundwater Remediation Permit.
I
•
We look forward to the release of the final version of the five-year remedy review and continue to
offer our assistance to EPA and NCDENR throughout this process. Ifwe can be of further help,
please contact me at [phone].
Regards,
~~
Ray Hom
Project Coordinator
c: R. McElveen (NCDENR)
H. Moats (Syngenta)
H. Grubbs, Esq. (WCS&R)
M. Sheehan (Pinnacle)
2
North Carolina • Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Mr. Jon Bornholm
North Superfund Remedial Branch
US EPA Region N
May 28, 2003
61 Forsyth Street, Eleventh (11) Floor
Atlanta, Georgia 30303-3104
•
RE: Comments on the Draft Five-Year Review Rep011 Dated April 2003
Groundwater Remediation
Geigy Chemical Corp. Site
NCD 981 927 502
Aberdeen, Moore County, NC
Dear Mr. Bornholm:
The Draft Five-Year Review Repo11 for the Geigy· Chemical Corporation Site, a·
Supe1fund Site, located in Aberdeen, Moore County, No11h Carolina has been received
and reviewed by the N011h Carolina Superfund Section. The No11h Carolina Superfund
. Section offers the following comments.
General Comments:
1. The State reviewed this subject repo11 for technical accuracy and proper evaluation of the
groundwater data and accurate communication of the investigation results and history and
system operations. The State did not provide review of completeness of the Rep011 in
terms of 5-Year Review guidance or procedure.·
Specific Comments:
2. Item #3 on page v addresses the encroachment of the off-site trichloroethene (TCE)
contaminant Plume. The TCE should not "extend time to achieve remedy goals." As
long as the pesticides and TCE do not break through the carbon treatment system the
extraction of pesticides should not be adversely affected by the presence of the TCE. If
anything the TCE could help accelerate pesticides going into solution and ·thus extraction
as well as enhance biodegradation by using up dissolved oxygen and creating a reduced or
·. anaerobic aquifer, Please clarify orremove this statement.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER:,. 50% RECYCLED/ 10% POST CONSUMER PAPER
• •
3. The second bullet on page 7 includes the following language. " ... surface water and
steam sediments ... " Please correct the spelling of stream and re-proof-read the text of
the report. There are other minor typos in the report.
4. The third paragraph on page 7 states the goal of the downgradient remedial action (RA) is
to reduce the BHC isomers to the standards. This is a natural process that we have no
control over at this site. Therefore, the actual goal of this RA is to assure continued
natural degradation of BHC isomer·s to the standards and to confirm that the
pesticide contaminant plume does not impact receptors over the long-term
degradation process. If necessary we would enhance protection of receptors with
additional protective measures such as treatment of groundwater at receptors, pump and
treat or enhanced natural attenuation, etc. as required.
5. Correct spelling of Harold Moats name in the fourth diamond on page 12.
6. Tables 6 and 7 are not sufficient for proper evaluation and documentation of remedy
protectiveness. New or additional Tables should be included in this report that provide
real contaminant concentration data. The concentration ranges and areas of increasing
contaminant concentration should also be included in the text of the report or tabulated.
7. Please provide some graphs of trend analysis for vaiious areas of the plume and for the
total plume and total BHC isomers. It is especially important to ·include any wells or well
clusters that are continuing to increase in concentration.
8. Some areas of the plume are orders of magnitude above the performance standards.
Therefore, I would not state that "contaminant concentrations" are "extremely low". See
the third paragraph on page 18. Please remove the word extremely from the statement. -
If you have any questions or comments, please contact me, at (919) 733-2S0-l, extension 341.
cc: Dave Lown, N.C. Superfund Section
Sincerely,
Randy McE!veen
Environmental Engineer
NC Superfond Section
. ~ ~-tf'l2L I, , IMu_ 'h ~04\., • . •
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-~ -Y ar eview Questionn ire
Site
City/State
~G~~l:t,,
Date: '.OJ1 + o2 ~ o 3
Name of Citizen
. Address
Do you live near the Site? If yes, how long?/ [f-eM.? ~-8 ~· -k-w I 1 f s"'
Are you familiar with EPA activities over the past years? ~ ,,. ~ ~~
·!:---~ ~ µ.-cf ,,-M ~ m. What _is your overall impression of the project? ... &."""-"-"....._,,,.1"''-'~=:....:;..-"'-~~;;;,~='---"~--"-..;;.;,;,--R-=---,;;t::..---
Over~ have you been pleased or displeased with cleanup actions at this Site? 1 ✓k+wt ~ ~ o.r@ 1414 =~ (1~1_¥
What effects, if any, have site operations had on the surrounding community? ________ _
Do ou still have any concerns re ardin EPA clean u activities of the Site? . ~ ~ ~~
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Do you think yo4, have been kept adequately informed about clean up activities at the Site?
s-2~&~~~
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details. __________ _
Is there someone else that you would like to recommend we contact for more information?
Do you have any suggestions that EPA can implement to improve communication with the public? ·
Interview conducted by: ___ Ja..M<1.,,"'a-t'1&.✓ ... ·-k#~=:2&a:::i.. ________________ ...,...
Date conducted: _· _1b'--'-'p"""-'?~-2"-"'oa"""3..._ __
• • 5-Year Review Questionnaire
~~Qjf-Site
C~ate
Date: -~--......,_,t...,,.~o-D_tJ_o __
Name of Citizen
Address
Do you live near the Site? If yes, how long?--~)'{_· _.,.._~A-~---------------
Are you familiar with EPA activities over the past years? ~M--' .
What is your overall impression of the project? =ff ~-.w ?«fj• ay-.,v -~--#idz:;._e
Overall, h been pleased or displeased with cleanup ac\ions at this Site?
•
•
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Do you still have any con_cerns regarding EPA clean up activities of the Site? ,. ~
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details. __________ _
Is t ere someone else that you would like to recommend we contact for more information?
Do you have any suggestions that EPA can implement to improve communication with the public? }}~,~~~ ¼;1~~~~ ht1-rW, . ?'-'1& , . · . _
Interview conducted by: . · i,UµJ ~ · · · .
Date conducted : Jj~lo · , • . . .· . . ·. . . ·. .
•
5-Year Review Questionnaire
Site
City/State
Date:~
Name of Citizen
Address
How long have-you lived ne_c1r the Site? .
Are you familiar with EPA activities over the past years?
Do you still have any concerns regarding EPA clean up activities of the Site? '11 p";\..-L-'-f»:4-t:~ . .
Overal have you been pleased or displeased with EPA actions at this Site?
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Do you think you have been adequately informed about clean up activities at the Site? . yw, ~~ curt11;&t--t,v
Is there any information about the Site that you would like to share with us that would assist in
our 5-year review of site activities? ~ . 7"/ttf= 41'~ 1,
Is there <;>meone else that you would r e to recommend we contact for more information?
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Do you have any suggestions that EPA can implement to improve communication with the
pu:c? . ~~flj!!J tt ~tt~J~*
[A copy of the 5-year review will b placed in the Site Information Repository file located in the Site
Information Repository at ai .
Interview conducted by: ,/4 ·. A~~·
Date conducted : ,r' & /4100 3 ..
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•
5-Year Review Questionnaire
Site
City/State
Date: ~ ~,.
Name of Citizen
Address
How long have you lived near the Site?
Are you famiiiar with EPA activities over the past years? ~~ ~ ~ ~ . r J.u.,,-,.,; ,l,,-fJ ~ # C' -
Do you still have any concerns regarding EPA clean up activities of the Site?
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Over have you been pleased or displeased with EPA actions at this
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Do you think you have been adequately informed about clean up activities at the Site?
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Is there any information about the Site that you would like to share with us that would assist in
our½e~e>W:si~vi~ er .
Is there someone else that you would like to.recommend we contact for. more information?
Do you have any suggestions that EPA can implement to improve communication with the
public? -------------------------------
[A copy of the 5-year review will be placed in the Site Information Repository file located in the Site
Information Repository at-------,-----------'-----.....; ____ _
Interview conducted by: / , A ~ ~
Date conducted : S! (, J 0,3 · · I r . ·
• • 5-Year Review Questionnaire for Govt. Officials
Site
City/State
;;).I)~ . Date: ___,c_:_~f----"t
Name
Address
~!:;dtC1v·
What is your overall impression of t~e project? _,(A""--"'.v""· ~-(jc,.7-. _.'tt.H/4=-::=a::.· -'~=c==--------
Have there been routine communications or activities conducted by your office regarding the Site?
(Site visits, inspections, reporting activities, etc.) If so, please give purpose and results.
Have there
by your office?
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a response~
If so, please give details of the events and results. ~ wd/4.
Do you feel well informed about the Site's activities and progress? ~-.µ~=::::.,. _______ _
Do you think clean up activities at the Site have had a positive or negative impact on the community?
In what ways? ·
r? µLt;;e) ~ ~ ;;t ''10?<? ('~ q:J-:
Do you have any comments, suggestions, or recommendations regarding the Site's management or
operation? ..;._ ______ ...;... ______________________ _
710-
Interview conducted by ---"v~c.:1::.·~=·c=:::....· .;,:·~::;..::::: . .:..::::.. ;.;_· _______________ _
Date conducted· fri 7 '.?; ploo.3
• 5-Year Review Questionnaire
Site
City/State
Date: 1/n~
Name of Citizen
Address
l!m~f,)w
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Do you live near the Site? If yes, how long? _::,.~,-:.W=-J+-_3.::..e,.rJ_~,;µ.P..,fl..,&-.1/.l-':::;;.. __________ _
Are you familiar with EPA activities over the past Years? __ ....i.;\:&a~-----------
What is your overall impression of the project? ---"~~-="'-·-•'-----------~----
Overall, h ve you been pleased r displeased with cleanup actions at this Site? . ·U
. What effects, if any, have site operatioris had on the surrounding community? ....chJ=.11...!!-<~=-· c;;. 1cc:!!;:!...:.__
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Do y7:j~II have any concerns regarding EPA clean up activities of the Site?
Do you think you have been kept adequately informed about clean up activities at the Site? ____ _ ?cef::: "--uy ~ ~'.t-~ a±p~ ~.
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details. ----'--------' . .
Is there someone else that you would like to recommend we contact for more information?
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Do you have any suggestions that EPA can implement to improve communication with the public?
Interview co~ducted by: · f-'--> • u &-uft
Date conducted : -5-/7/tJ . · $ • • •
Site
City/State
Date: ¾ 4 c),.NJ 3
Name of Citizen
Address
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DoyouliveneartheSite?lfyes,howlong? 3w, bJf1~ ~
Ares,ou familiar w.J.!h EPA activities over the past years? ~ L,4--/ . _
What is your overall impression of the proje_ct? 1-kp ;id_ 't:Jt ~ -·,d.,_,t;__,
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~all, have you been pleased or displeased with cleanup actions at this Site?
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What effects, if any, have site operations had on the surrounding community? '1n J,,_ '-tL:ttz;..J-
a 6 1 4 OY} ~ ~ ".ey-,;:1-(/7..k '·
Do you still have any concerns regarding EPA clean up activities of the Site?
d
Do you think you have _been kept adequately informed about clean up activities at the Site? ____ _
.LJ..)
Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details. __________ _
0
Is there someone else that you would like to recommend we contact for more information?
d
Do you have any suggestions that EPA.can implement to improve communication with the public?
. 1]~ tcwA;f, c+-,,.T 'hl--dJ 1, -_ _ _ -_ _
Interview conducted by: __ ..,.J~:.:~:::· ="-· ----~.=.~c...=,;_ff;..:;,_ _______________ _
Date conducted : ---'-~'"""'--=,,-'---'7.,..1 .,,,.2,._.o'-"'0~3,__ __
• •
5-Year Review Questionnaire
Site
City/State
Address
How l9ng have you lived near the Site?
Are you familiar with EPA activities over ihe past years?
. Do you still have any concerns regarding EPA clean up activities of tt-ie Site?
b
Overal have you been pleased or displeased with EPA actions at this Site?
TAC
Do yo think you have been adequately informed about clean up activities at the Site? u) . .
Is there any information about the Site that you would like to share with us that would assist in
our 5-year review of site activities?
0
Is there someone else that you would like to recommend we contact for more information?
6
Do you have any suggestions that EPA can implement to improve communication with the
public? --~--------------------------...:. __
[A copy of the 5-year review will be placed in the Site Information Repository file located in the Site
Information Repository at • • . -. ~~~~4:~/~~6--.~~/~-
lnterview conducted by: / · ,,&,<jW,..U ~-· · · ·
Date conducted: :S-. 1 /ii3 ' .
• • ~"
5-Year Review Questionnaire for Contractor/Site Manager~
Site (i~ {I_~ ~
City/State 6 ~, 7'.t C.
Date: f))q1 ;loo3 · Phone No.
Name
Address
What is your overall impression of the project? f}?-t,r,«g a a~) ~;,'
'fi-d rrL-~ @~ La,t±t €!_flff, J&.4 ✓ ~.
-~--¢.
e current status of construction (i.e., budget, schedule)
~
Have any problems been encountered which required, or will require, changes to this remedial design
or this ROD?
;e,€ c~ M!fj~~-1v-9J-t~.,d:~~,, ~
,4 <kJJ ~ M-{:A U< o_) ~ '--Cu<L( --/4_ ~ /~U Y-41: '-(tx.,lil
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Hav~ problems or difficulties been encountered which have impacted construction Rrogress or
implementability?
~ -rc_c:./ ~) c.:,, /4u!LF~ ~ ~ ~·
~~ ~ t?JL-' -If~ J.-</?½z:tin_, ~ 41P~, . 0 . ·. ,
Do you have any comments, suggestions, or recommendations regarding the project (i.e., design,
construction documents, constructabili~{, management, regulatory agencies, etc.)?
Do you think the community as a whole ~as been pleased wi h Site operation
that the clean up has been effective? -4=:..,.-~:.i:!!~L.::Z:~i-C~~{-1:..J~IZ1a.:.1:P..:.~'.!..:::.__
-~ ~ ·~ . ~·~
lnteNiew conducted by ------"-~=-·..c.~'--.:..:·-· _,1,-A __ v_v;tf-____________ _
Date conducted -~7fh~~Afl_,_,,__· ~j"",_,)._, <_1 J __ _
II '
• •
5-Year Review Questionnaire
Site
City/State
Name of Citizen
Address
Phone No.
How long have you lived near the Site? _ 4o -· &j/,-~ ~ /X...e..(l,,1/. ~
Are you familiar with EPA activities over the past years? ~u) .
Do ,,ou still have any concerns regarding EPA clean up activities of the Site?
Overall, have you been pleased or displeased with EPA actions at this Site?
'---1~ /J fe,. 1 ' J
Is there any information about the Site that you would like to share with us that would. assist in
om sy:ac~•••• of';;:~~ .,,J_,_,,_ ±:f,,!"'1' ,,e,._ Yi(,.,..,,/!_ j_._._,_, ;;ll-A,= apo3F ~ wd. I)
Is ther,e someone else that you would like to recommend we contact for more information?•
cJ
Do you have any suggestions that EF'A can implement to improve communication with the
public? ------------------------------
?70 ~{J#M,1/ ~ '-41-r ~ V~ +4k:! qu:f
[A copy of the 5-year review will be plac d in the Site nformation Repository file located in the Site
. Information Repository at ·
.· /ht:1f'eo-ck1)--/L t-_c;-rrf o/~
Interview conducted by: oJ,_.£....U ~
Date. conducted: .:r/7 /;u 0.3 · I I
I
l ,•
I
Site
City/State
Date: ~ /41 ,.,lo o3
Name of Citizen
Address
•
5-Yeair Review Questionnaire
Phone No.
How long have you lived near the Site? ,r,-lf'h'ld, ~ ~Ju-4 cv.i-i ~ 0 -
Are you familiar with EPA activities over the past years? --'~'-!-=~=----------
Do you still have any concerns regar ·ng E lea up activities oft e Sit ?
C·
en pleased or dis e
tr(J..Utf!Ul__ .
Do you t ink you have been adequately informed about clean up activi_tie~ at the Site? ·"'
Is there any information about the Site that you would l~to share with us that would assist in
our 5-vear review of site activities?
/ 7' a/4..,J;
-tu.d,,(_:
recommend we contact for more information?
0
Do you have any suggestions that EPA can implement to improve communication with the
public? -·--,--,----,---,----,-r----,-----------,-.,--------"/Lo -,u.-) ~ ~ ~-(fV ~
[A opy of the 5-year review will be placed in the Site Information Repository file located in the Site
Information Repository at----~-----'-------------'-----
Interview conducted by: ~-h4=~_· ___ ·_. ·-------------
Date conducted: ,:f/9/tJ 3 · · I I
7
• •
5-Year Review Questionnaire
Site
City/State
Date: ____,_M-..:7~&"-1/c...c_ cJ.c...co~o a'--_
Name of Citizen
Address
How long have you lived near the Site? . ? /4d /&_, ~ AA _k/"t>-a pJ /4k,lZ,
Are you familiar with EPA activities over the past years? ---,~----------
Do yo~ sti I have any concerns regarding EP~n =ities of the
-~ --1!:.~~~;ff,.~~~r--&,~~*---
Do you thin u have be
Is there any information about the Site that you would like to share with us that would assist in
our 5y'.1ar review of site activities? · .
.L{<J -.-,4 ~ Y-k, #~ ~ ½ ~ /-4.1r
Do you have any suggestions that EPA can implement to improve communication with the
public? -=-----------------------------
[A copy of the 5-year review will be placed in the Site Information Repository file located in the Site
Information Repository at----,--·------------~--------,--
Interview conducted by:. · ~~ hJ
Date conducted : s-' /(e ( o 3
~ -North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Mr. Jon Bomholm
North Supcrfund Remedial Branch
US EPA Region IV
May 28, 2003
6 I Forsyth Street, Eleventh (11) Floor
Atlanta, Georgia 30303-3104
RE: Comments on the Draft Five-Year Review Report Dated April 2003
Groundwater Remediation
Geigy Chemical Corp. Site
NCD 981 927 502
Aberdeen, Moore County, NC
Dear Mr. Bomholm:
The Draft Five-Year Review Report for the Geigy Chemical Corporation Site, a
Superfund Site, located in Aberdeen, Moore County, North Carolina has been received
and reviewed by the North Carolina Superfund Section. The North Carolina Superfund
Section offers the following comments.
General Comments:
1. The State reviewed this subject report for technical accuracy and proper evaluation of the
groundwater data and accurate communication of the investigation results and history and
system operations. The State did not provide review of completeness of the Report in
terms of 5-Year Review guidance or procedure.
Specific Comments:
2. Item #3 on page v addresses the encroachment of the off-site trichloroethene (TCE)
contaminant Plume. The TCE should not "extend time to achieve remedy goals." As
long as the pesticides and TCE do not break through the carbon treatment system the
extraction of pesticides should not be adversely affected by the presence of the TCE. If
anything the TCE could help accelerate pesticides going into solution and thus extraction
as well as enhance biodegradation by using up dissolved oxygen and creating a reduced or
anaerobic aquifer. Please clarify or remove this statement.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: ,vww.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER-50% RECYCLED/ 10% POST CONSUMER PAPER
•
3. The second bullet on page 7 includes the following language. " ... surface water and
steam sediments ... " Please correct the spelling of stream and re-proof-read the text of
the report. There are other minor typos in the report.
4. The third paragraph on page 7 states the goal of the downgradient remedial action (RA) is
to reduce the BHC isomers to the standards. This is a natural process that we have no
control over at this site. Therefore, the actual goal of this RA is to assure continued
natural degradation of BHC isomers to the standards and to confirm that the
pesticide contaminant plume does not impact receptors over the long-term
degradation process. If necessary we would enhance protection of receptors with
additional protective measures such as treatment of groundwater at receptors, pump and
treat or enhanced natural attenuation, etc. as required.
5. Correct spelling of Harold Moats name in the fourth diamond on page 12.
6. Tables 6 and 7 are not sufficient for proper evaluation and documentation of remedy
protectiveness. New or additional Tables should be included in this report that provide
real contaminant concentration data. The concentration ranges and areas of increasing
contaminant concentration should also be included in the text of the report or tabulated.
7. Please provide some graphs of trend analysis for various areas of the plume and for the
total plume and total BHC isomers. It is especially important to include any we11s or well
clusters that are continuing to increase in concentration.
8. Some areas of the plume are orders of magnitude above the performance standards.
Therefore, I would not state that "contaminant concentrations" are "extremely low". See
the third paragraph on page 18. Please remove the word extremely from the statement.
If you have any questions or comments, please contact me, at (919) 733-280 I, extension 341.
~ncerely, c (; A
~.~,t(~~1
cc: Dave Lown, N.C. Superfund Section
Rand; ki~Elveen
Environmental Engineer
NC Superfund Section
•
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
May 21, 2003
Mr. Jon Bornholm
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
61 Forsyth Street, SW I Ith Floor
Atlanta, GA 30303-3104
RE: Draft Five-Year Remedy Review Report
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Jon:
Thank you for providing Olin Corporation and Syngenta Crop Protection the opportunity to
review the draft version of the Geigy Site five-year remedy review. We are pleased with the
findings of the review and offer the following minor comments:
I. Page 5, Section IV.A, second paragraph, first sentence: For accuracy, please revise the
sentence to read 'The groundwater remedy was targeted at removal of site-related
contaminants in the groundwater through groundwater extraction and on-site treatment by
carbon adsorption."
2. Page 8, Section IV.C, first paragraph, second sentence: For historical accuracy,__please
· --· ·-------------·-revise the sentence to read "The Pinnacle Consulting Group of Greenville, South Carolina
currently has the treatment monitoring and O&M contract for the PRPs."
3. Page 12, Section VILB, first paragraph, forth bullet: Change "Harold Mose, Syngenta
Crop Systems" to "Harold Moats, Syngenta Crop Protection".
4. Page 19, Section X, third paragraph. The Companies will update the number of extraction
wells listed in the Site Groundwater Remediation Permit.
I
•
We look forward to the release of the final version of the five-year remedy review and continue to
offer our assistance to EPA and NCDENR throughout this process. If we can be of further help,
please contact me at [phone].
Regards,
--fih~
Ray Hom
Project Coordinator
c: R. McElveen (NCDENR)
H. Moats (Syngenta)
H. Grubbs, Esq. (WCS&R)
M. Sheehan (Pinnacle)
2
• •
May 5, 2003
Memorandum
TO:
FROM:
RE:
File
Randy McElveen
Environmental Engineer
NC Superfund Section
Geigy Chemical Meeting to Discuss the 5-Year Review with the EPA,
PRPs and Contractor Groundwater Remediation
Geigy Chemical Corp. Site
NCD 981 927 502
Aberdeen, Moore County, NC
On I 8 February 2003, a representative of the NC Superfund Section
participated in a meeting at the Residence Inn in Aberdeen, NC to review and discuss
the process of the 5-Year Review and remedy effectiveness for the Geigy Chemical
Site located in Aberdeen, NC. Those participating in the meeting included Jon
Bomholm, EPA Region IV, Representatives with the Corp of Engineers and the PRP
representatives for Olin and Syngenta. We also completed a site reconnaissance with
the Corp representatives in order to familiarize them with the site and groundwater
plume area.
cc: Dave Lown, N.C. Superfund Section
• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W. .:,:,
Atlanta, Georgia 30303-310_4. ,,{:. '-'.,··
C • ' \./
April 28, 2003 , \~
. ,, ';-...·:
\
4WD-NSMB
Mr. Randy McElveen
North Carolina Department of Environment &
Natural Resources/Superfund Section
40 l Oberlin Road
Raleigh, North Carolina 27605
\
SUBJ: Review Draft Five-Year Review Report for the Geigy Superfund Site in Aberdeen,
Moore County, North Carolina
Dear Mr. McElveen:
Enclosed is a copy of the above referenced report, dated April 24, 2003, for North
Carolina Department of Environment and Natural Resources (NCDENR) review and Site file.
This document was prepared for the Agency by U.S. Army Corps of Engineers. Please review
this report. The Agency would appreciate receiving any comments or concerns on this document
by Thursday, May 22, 2002. If the State is unable to submit comments on this document by this
date, please advise the Agency as to when the State will be able to submit its comments/
concerns.
If you have any questions, please contact me at 404-562-8820.
Enclosure (1):
Sincerely,
f' k ~~ ✓
Jon K. Bornholm
Remedial Project Manager
1. Draft Five-Year Review Report for the Geigy Superfund Site in Aberdeen, Moore County,
North Carolina (April 24, 2003)
RA
•
Draft
Five-Year Review Report
. First Five-Year Review Repot·t
For
Geigy Chemical Corp. (Aberdeen Plant) Site
Aberdeen
Approl'ed By:
Director, Waste Dil'ision
U.S. EPA Region 4
Moore County, North Carolina
April 2003
Prepared By:
US Army Corps of Engineers
Wilmington District
\Vilmington, North Carolina
Prepared For:
Region 4
U.S. Environmental Protection Agency
A llanta, Georgia
Date:
April 24, 2003
• Draft Five-Year Revieu,
Geigy Chemical Corp. (Aberdeen P/0111), Aberdeen, NC
Five-Year Review Report
Table of Contents
List of Acronyms ............................................................ _. .............. ; .............................................. iii
Executive Summary .......................................................................... : ............................... , .......... iv
Five-Year Review Summary Form ............................. ~ ............................................................... vi
I. Introduction .................................................................... -.... · .................................................... 1
II. Site Chronololgy ...................................................................................................................... 2
III. Background ............................................................................................................................ 2
A. Physical Characteristics .................................................................................................... 2
B. Land and Resource Use ......................................................................... : ........................... 3
C. History of Contamination .................................................................................................. 3
D. Initial Response ........................................... : .............. : .......... , ........................................... 5
IV. Remedial Actions ............................................. · ............................................................... : ...... 5
A. Remedy Selection ...................................... : ............................................................ , ......... 5
B. Remedy Implementation .............................................................................. '. .................... 8
C. System Operations/ O&M ............... : ................................................................................ 8
V. Progress Since the Last Five-Year Review ......................................................................... 11
VI. Five-Year Review Process ................................................................................................... 11
VII. Five-Year Review Findings ............................................................................................... 11
A. Interviews ........................................................................................................................ 11
B. Site Inspection ................................................................................................................. 1_2
C. ARAR Review ................................................................................................................. 12.
D. Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics_ ....... 13
E. Data Review ................................................... , ............. : .................................................. 13
VIII.· Assessment .................................... : .................................................................................. : 18
Question A: Is the remedy functioning as intended by the decision documents? ............... 18
Question B: Are the assumptions used at the time of the remedy selection still valid? ...... 18
Question C: Has any information come to light that could call into question the
protectiveness of the remedy? ................................. :····· .. ·· ............................. : ...................... 18
IX. Issues ................................... ;· ............................................................... : ............................... ;. 19
X. Recommendations and Follow-up Actions .............................. : .......................................... 19
• Draft Fi11e. Year Re1,ie1v
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
XI. Protectiveness Statements ................................................................................................... 20
XII. Next Review ........................................................•............................................................... 20
List of Figures
Figure 1. General Location ...... : ............................................................... : ...................................................... 3
Figure 2. Specific Site Location ..................... .-................................................................................................ 4
Figure 3. Monitoring Well and Sampling Locations ................................................................................... 9
. Figure 4. Site Area Monitoring and Extraction Well Locations ....................................... : ...................... 10
List of Tables
Table 1. Chronology of Events ...................................................................................................................... 2
Table 2. Soil Clean-up Standards ................................................................................................................... 6
Table 3. Groundwater Clean-up Standards ............................................................................... .-.................. 6
Table 4. Downgradient Groundwater Clean-up Standards ....................................................................... 7
Table 5. Surficial Aquifer BHC Isomer Concentrations in Groundwater Monitoring Wells 1990 -
2001 ................................................................................................................................................ : ......... 14.
Table 6. Upper Black Creek Aquifer Sampling Results 1998 to 2002, Exceedences of Perfonnance
Standards for BHC Isomers .................................................................................. : .............................. 15
Table 7. Lower Black Creek Aquifer Sampling Results 1998 to 2002, Exceedences of Performance
Standards for BHC Isomers ................................................................................................................. 15
Table 8. Tri.chloroethene (TCE) Concentrations in Groundwater Monitoring Wells 1991 to 2002. 17
. Table 9. Recommendations and Follow-up Actions ...................................................................... , .......... 20
11
• Drafl Five.Year Review
Gei!J Chemical Co,p. (Aberdee11 P/0111), Aberdee11, NC
List of Acronyms
AOC Administrative Order on Consent
ARARs Applicable or Relevant and Appropriate Requirements
BHC Benzene Hexachloride
CENWHO-HX-G Corps of Engineers Hazardous, Toxic arid Radioactive Waste Center of
CERCLA
.CERCLIS
Expertise
· Comprehensive Environmental Response, Compensation, and Liability Act
Comprehensive Environmental R_esponse, Compensation, and Liability
Information System
CESA W-TS-PE Wilmington District, Corps of Engineers Environmental Resources.
CFR
DDE
DDT
EPA
FS
IAG
Kg
L
Mg
NCP
NPL
ppb
ppm
PRP
RA
RD
. RI
ROD
RPM
SARA
TCE
TCL
µg
USACE·
WasteLAN
Section
Code of Federal Regulations
Dichlorodiphenyldichloroethylene
Dichlorodiphenyltrichloroethane
United States Environmental Protection Agency
Feasibility Study
Interagency Agreement
Kilogram
Liter
Milligram
National Oil and Hazardous Substances· Pollution Contingency Plan
National Priorities List
Parts Per Billion
Parts Per Million
Potentially Responsible Party
Remedial Action
Remedial Design
Remedial Investigation
Record of Decision
Remedial Project Manager
Superfund Amendments and Reauthorization Act of 1986
Triehloroethene
Target Contaminants List
Microgram
United States Army Corps of Engineers
The.Regional database related to CERCLIS
Ill
Draft Five-Year Rtviem
Geigy Ch,mica/ Carp. (Aberdeen Plant), Aberdeen, NC
Executive Summary
This report documents the ffrst five-year statutory review of the National Priorities List
(NPL) site NCD981023260. The site, refeITed to as Geigy Chemical Corp. (Aberdeen Plant)
Site, is a former pesticide formulation and retail sales site located in Aberdeen, Moore County,
. North Carolina. The site is approximately one acre in size. Contaminants of concern originally
associated with groundwater at the site are pesticides including aldrin, BHC isomers, dieldrin,
endrin, toxaphene, and the solvent trichlorocthene (TCE). Subsequent investigations showed
that trichloroethene contamination was not a result of site activities and was therefore removed
from the Site Target Contaminants List (TCL). There was also soil contamination involving the
same pesticides listed for groundwater and the additional compounds, DOD, ODE, DDT, and
chlordane isomers. These contaminants are the result of use of the site for pesticide formulation
and blending and agricultural chemical sales from i 947 to 1989.
In March 1988, an EPA Site Investigation in support of the Hazard Ranking System
(HRS) was conducted on the site. Isomers of BHC were found in groundwater samples from
three municipal and two private wells. Based on the results of the site investigation, the site was
proposed to the National Priorities List (NPL) in June 1988 and listing was finalized October 4,
1989. . .
There were three removal actions associated with the site for soil remediation. The first
two, conducted in 1989 and 1991, removed soils visibly contaminated and other debris from the.
site. Approximately 3,300 tons of soil and debris were removed for disposal in these two
actions. Following the preparation and finalization of a Remedial Investigation/Feasibility
Study, a·Record of D~cision (ROD) was signed August 27, 1992. The Remedial Action
implemented by the ROD included demolition of the former warehouse foundation; excavation
of the top foot of on-site soils contaminated above performance standards; off-site disposal of
excavated soils as appropriate; extraction of groundwater from the surficial and Upper Black
Creek aquifers; treatment of extracted groundwater via carbon adsorption; site restoration; and
further sampling and analysis of the Upper Black Creek aquifer to determine extent of pesticide
contamination and determine if TCE found in two wells was site-related.
The Remedial Action (RA) was conducted from September 1996 to February 1997. The
RA included removal of concrete foundations and other debris totaling approximately 2,460 tons
to a Subtitle D landfill; disposal of 4,475 tons of contaminated soils to a Subtitle C landfill;
construction and installation of extraction wells and groundwater tre.atment facilities with an
infiltration gallery for discharge of treated groundwater. The treatment system began operation
in January 1997 and has currently treated approximately 30 million gallons of extracted
groundwater from the surficial and Upper Black Creek aquifers.
As required in the ROD, a downgradient investigation was conducted to determine the
extent of pesticide plumes in the Upper and Lower Black Creek aquifers. The results of the
investigation, reported in the Downgradient Groundwater Remedial ActioTi Work Plan (RA WP),
and the recommendations therein, were adopted by EPA through issuance of an Explanation of
Significant Differences (ESD) to the Remedial Action in January 1998. The ESD established
that the downgradient groundwater contaminant plume would be monitored as pait of the overall
IV
• Draft Five-) ·ear Revie,v
Geig Chemical Corp. (Aberdec11 P/11111), Aberdeen, NC
site remedy. The selected remedy for the downgradient area is monitored natural attenuation of
the plume with the following contaminant concentration goals: alpha-, beta-, and delta-BHC
0.05 µg/L, and gamma-BHC 0.20 µg/L.
There were several issues identified during the review process. None of the issues affect
the assessment of the performance of the remedy. However, each should be addressed before the
next five-year review. The issues are described as follows:
I. Fencing and signing of the site as proposed in the documents of record have not been
accomplished. This proposal was prepared prior to completion of the soil remediation and may
no longer be applicable.
2. The Site Groundwater Remediation Permit issued October 1, 1999 and expiring June
30, 2004, needs to be changed io reflect that the treatment facilities consist of seven (7) recovery
wells rather than the five (5) listed.
· 3. Evidence indicates encroachment of the off-site trichloroethene (TCE) contaminant
plume into the site treatment area. Increasing TCE levels have shortened the life of carbon
adsorption canisters in the treatment facility, potentially extending time to achieve remedy goals.
The remedial actions at the Geigy Chemical Corp. (Aberdeen Plant) Site currently protect
human health and the environment. The soil remediation for the site has been completed, and the
pump-and-treat remediation of the groundwater contamination including monitoring is
continuing. The trends of contaminant concentrations in groundwater both at the site and in the
downgradient area appear to be downward. Performance standards for contaminants of concern
. are exceeded in the monitoring wells for the area under remedy implementation. To ensure long-
term protectiveness of the s_elected site remedy, continued monitoring and operation of the
groundwater treatment facility should continue.
V
• Draft Five•Year R.tvie,v
Geigy Ch;mical Corp. (Aberdeen Pla11tj, Aberdeen, NC
Five-Year Review Summary Form
Five-Year Review Summarv Form
· Site Identification
Site Name: Geigy Chemical Corp. (Aberdeen Plant)
EPA ID: NCD981927502
Region: 4 I State: NC I City/County: Aberdeen/Moore
~~\''ff"l'~lt{'(i"~~flj;";,i\"°''W""~~~l' "f -' -' ' ~~1"1,1J»" ~il'a/'~-~im'~'it;~'tlt'"~~ :~~,..::.· :'¥i-:i;,.,..,h£1&. • u~ -.~·_Jl•£f: .. J!t.,',._ ~.-r.~.. -:~t, SITE;SJ'A,TUS~ · . ;: ,.:' .. ,.,:JJi,ij._ ~.f4' . ...--·.~., trt!t.: ; 1\ ..... :\1. ~-•' .wt-~ "
NPL status: ✓ Final D Deleted D Other:
Remediation Status: D Under Construction ✓ Operating D Complete
Multiple OUs?* D YES ✓ NO I Construction Completion Date: Septen1ber 27, 2000
Has site been put into reuse? ✓ NO
!Ykl.f~~~'i~~~1!11-'l'f:\',ir11,lM!2'~REMIEWJSTATUS~~{~~~i~fi/~:~f'&.~t~'iif+.~~
Reviewing agency: ✓ EPA D State D Other:
Author name: Stacy Samuelson
Author title: Biologist Author affiliation: USACE, Wilmington
District
Review period:** 4/03 -4/08
Date(s) of site inspection:
Type of review:*** ✓ Statutory
D Policy (D Post-SARA D Pre-SARA 0 NPL-Removal only
D Non-NPL Remedial Action Site D NPL Stateffribe-lead
·o Regional Discretion)
Review number: ✓ 1 (first) D 2 (second) D 3 (third) D Other (specify)
Triggering action:****
D Actual RA On-site initiation by PRP ✓ Actual RA start at OU# 1
D Construction completion D Previous Five-Year Review Report
D Other (specify)
Triggering action date: July 20, 1998
Due date (five years after triggering action date): July 20, 2003
* "OU" refers to operable unit.
** Review period should correspond to the actual start and end dates of the five-year review in
WasteLAN.
*** See Chapter 1, Section 1.2 of EPA 540-R-01-007, Final June 2001 for further explanation.
**** See Chapter 1, Section 1.3 of EPA 540-R-01-007, Final June 2001 for further explanation.
Vl
• • Draft Five-Year Review
. GeigJ Chemical Co,p. (Aberdee11 P!a11t), Aberdee11, NC
Five-Year Review Summary Form
Issues:
1. Fencing and signage for the site as proposed in the documents of record have not been
implemented.
2. Site Groundwater Remediation Permit needs to be modified to reflect actual number .
of wells associated with the treatment facility.
3. Encroachment of the off-site trichloroethene (TCE) contaminant plume into the site
treatment area.
Recommendations and Follow-up Actions:
I. The need for fencing and signage of the site was negated by removal of the
contaminated soils during the remedial action. No action should be taken.
2. The PRPs should update the Site Groundwater Remediation Permit when renewed in
2004.
3. Monitoring of the affect(s) oft.he TCE plunie on the site remedy should continue, with
close coordination by all parties.
Protectiveness Statement(s):
The remedy at the Geigy Chemical Corp. (Aberdeen Plant) Site is expected to be or is
protective of human health and the environment, and in the interim, exposure pathways that '
could result in unacceptable risks are being controlled.
Vil
•
I. INTRODUCTION
• Draft Five•Year Rcvic"w
Geigy Cbemfral Co,p. (Aberdeen P/0111), Aberdee11, NC
FIVE-YEAR REVIEW REPORT
The United States Environmental Protection Agency (EPA) Region 4 has completed a
five-year review of remedial actions implemented at the Geigy Chemical Corp. (Aberdeen Plant)
Site in Aberdeen, Moore County, North Carolina. The United States Army Corps of Engineers
(USACE) conducted and provided technical assistance and analysis for the five-year review.
The Environmental Resources Section, Planning and Environmental Branch, Technical Services
Division of the Wilmington District, Wilmington, North Carolina provided the US ACE lead for
this review. The review was accomplished under EPA Work Authorization Form for
Interagency Agreement (TAG) Number DW96945884A. The Wilmington District was supported
in the conduct of the review by the USACE Hazardous, Toxic and Radioactive Waste Center of
Expel'tise (CENWO-HX-G) located at the Omaha District, Nebraska. This review was
conducted from January 2003 through June 2003. The report documents the results of that
review.
The purpose of five-year reviews is to detemline whether the remedy at a site is or is.
expected to be protective of human health and the environment. The methods, findings, and
conclusions of reviews are documented in five-year review reports. In addition, five-year review
reports identify issues found during the review, if any, and recommendations to address them.
This review is a statutory review. EPA must implement five-year review consistent with
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and
the National Oil and Hazardous Substance Contingency Plan (NCP). CERCLA § 12l(c), as
amended states:
If the President" selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such remedial
action no less often that each five years after the initiation of such remedial action to .
assure that human health and the environment are being protected by the remedial action
being implemented.
The NCP part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR) states:
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after the initiation of the selected remedial action.
This is the first five-year review of the Geigy Chemical Corp. (Aberdeen Plant) Site. The
site has been identified as requiring a "statutory" five-year review, which must occur within 5
years after completion of construction. Completion of construction, as designated by signature
of the Preliminary Close-Out Report occurred on July 20, 1998 .
. This review will be placed in the EPA site files and local repository for the Geigy
Chemical Corp. (Aberdeen Plant) Site. The local repository is located at the Aberdeen Town
Hall, ll5 N. Poplar St., Aberdeen, NC 28315.
1
• • Draft Five-Year Revie1v
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
II. SITE CHRONOLOGY
Table I lists the chronology for selected events for the Geigy Chemical Corp. (Aberdeen
Plant) site, as shown below.
Table 1: Chronology of Events
;~J;S,~1;//f-~{&;;;~}ifi;~~}'ff~'(:,1$}::{:~··t,,:Lrt~:?(EVENTil;;1;~tirt.!i\~!?~Jrt:~(J;W~f.-:l'rit~ttiiil~;.1.•~;{i;~~;, t.~;:~11i!l?D A TE1~:;}-¢t$~
Site leased bv several comoanies for ocsticide formulation and retail sales. 1947 to 1987
EPA detected pesticides in surface and subsurface soils on the site. fanunry 1987
Site insoection conducted bv the State. March 1987
Preliminary site assessment. June I 987
Hazard Ranking System (HRS) evaluation. August 1987
Site orooosed to be listed on the National Priorities List (NPL). June 1988
Site added to National Priorities List (NPL). October 4. 1989
PRPs conducted a soil removal action. 462 tons of soil and debris removed. February 23, 1989 to
December 16. I 989
Administrative Order on Consent issued. Januarv 23. 1991
Second soil removal action by PRPs. 2,841 tons of soil and debris removed. February 25, I 991 to
June I. I 991
Human Health Risk Assessment and Ecological Risk Assessment completed. March 13, 1992
PRP preparation of Remedial Investigation and Feasibility Study (RI/FS). December 16, 1988 to
August 27, 1992
Record of Decision (ROD) signed. Aueust 27. 1992
Consent Decree for PRPs to conduct remedial design/remedial action (RD/RA) July I 5, 1993
RA contract for construction of groundwater remediation system and removal of contaminated soil September 1996
and debris awarded bv PRPs.
Pre•final inspection of soil remediation by EPA and State of North Carolina. January 15, 1997
Groundwater Remediation Svstem ooerational. Januarv 1997
Final inspection of soil i-emediation bv EPA and State of North Carolirla. February 26, 1997
Downgradient Groundwater Rem"edial Action Work Plan annroved by EPA and NC DENR. November 1997
Exolanation of Significant Differences issued bv EPA Januarv 1998
Preliminary Ciose•Out Report July 20, 1998
Additional monitoring well installation. April 1998
Site insoection for the first five.year review. Februarv 18, 2003
III. BACKGROUND
A. Physical Characteristics
The Geigy Chemical Corp. (Aberdeen Plant) Site is located just to the east of the
corporate limits of Aberdeen, North Carolina in southeastern Moore County (Figure I). The site
is located on the Aberdeen and Rockfish Railroad right-of-way adjacent to Highway 211 and
forms an elongated t1iangle with the highway and railroad forming the apex.
The Geigy Site encompasses an area of approximately one acre that has been graded to
be mostly level in nature (Figure 2), The site has topology typical of the Upper Coastal Plain
physiographic region, with shallow water tables and low topographic relief. Soils in the area are
classified as the Candor sand type that overlays unconsolidated sandy to clayey sediments.
There are also an intermittent clay zone and several other clay lenses that divide the surficial
groundwater aquifer from the Upper and Lower Black Creek aquifers in the area. Drainage from
the site and predominant groundwater flow is to the west and northwest with both surface and
subsurface runoff entering McFarlands Branch, Ray's Mill Creek, and Aberdeen Creek.
2
•
B. Land and Resource Use
• Draft Five-Year Revie1v
Geig)! Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Current land use of the area is rural residential and commercial in nature. The city of
Aberdeen has approximately 3,400 residents. The Moore County area has grown approximately
18 percent in the last ten years and may continue to do so. Based on current levels of
development of the area, it is not foreseen that there will be any major change in land-use in the
future.
Figure 1. General Location
C. History of Contamination
The Geigy Site was leased for the formulation and retail sale of pesticides from 1947
until its closure in 1989. Agricultural fertilizers in bulk and bagged form were also distributed
from the site during its operational history. The pesticides DDT; toxaphene, and BHC were
formulated for field use on-site by mixing with inert materials such as clay and repackaged for
sale in the local agricultural market.
An EPA Site Investigation was conducted in March 1988 in support of the Hazard
Ranking System (HRS) evaluation of the site. Isomers of BHC were found in groundwater
samples from five locations: three municipal wells and two private wells.
3
Figure 2. Specific Site Location
\
ABERDEEN
FOP. 3,578'
11
4
::,,...
Drcift Fi11e-YearR111iew
Geig-; Chemical Corp. (Aberde,11 Pla11!), Aberdew, NC
--L. 7
\ r--
"1/z,
t.lt. LGdmen Holy
Ch. o t cnr 1~t
1!!§
Geigy Chemical Corp.
(Aberdeen Plant) Site
s
•
• • Draft Five-Year RevieJP
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
D. Initial Response
As discussed briefly in Section C above, the Environmental Protection Agency (EPA)
conducted a Site Investigation in March 1988 in support of a Hazard Ranking System (HRS)
evaluation.
The site was proposed to be included on the National Priorities List (NPL) in June 1988
and final designation was completed October 4, 1989. During that time, notice letters were sent
to six companies: Ciba-Geigy Corp, Olin Corp, Kaiser Aluminum & Chemical Corp, Lebanon
Chemical Corp, Aberdeen and Rockfish Railroad, and Columbia Nitrogen Corporation, The
notice letters requested that the Potentially Responsible Parties (PRPs) conduct-a Remedial
Investigation and Feasibiiity Study (RI/FS) for the site. An Administrative Order on Consent
(AOC) was entered into by EPA and three of the PRPs (Ciba Geigy { currently Syngenta Crop
Protection, Inc.), Olin Corp, and Kaiser) for performance of the RI/FS on December 16, 1988.
IV. REMEDIALACTIONS
A. Remedy Selection •
The remedial actions in the Record of Decision (ROD) dated August 27, 1992, provided
for remediation of contaminated soils and groundwater. The remedial actions identified in the
ROD were as follows:
Groundwater
The groundwater remedy was targeted at removal of site-related contaminants in the
groundwater through groundwater extraction and on-site treatment by chemical means and air
stripping. The following activities were_ identified as being associated with this alternative:
Soils
♦ Contaminated groundwater would be extracted from within the Surficial and Upper
Black Creek aquifer plume via extraction well(s) and piped to an on-site, aboveground
treatment facility.
♦ Treatment would consist of carbon adsorption canisters to remove contaminants of
concern.
♦ Final discharge of the effluent would be to either an on-site infiltration gallery or via
connection to a Publicly Owned Treatment Works (POTW).
♦ Continued analytical monitoring of contaminants in groundwater.
♦ Further characterization of the Upper Black Creek aquifer to determine the extent of
pesticide contamination.
The remedy for contaminated soils had the intent of permanently removing
contamination in the soil through off-site disposal of contaminated soils. The following
activities were identified as being associated with this alternative:
5
Draft Fivc-l~ear Rtview
Geigy Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
♦ Excavation of the top foot of soils exceeding cleanup standards identified in the ROD.
♦ Disposal of contaminated soils in a secure landfill or a fixed-base incinerator
depending on their regulatory requirements. ·
· ♦ Confirmation sampling and analysis to ensure that remediation levels are attained.
♦ Backfill of excavated areas with clean fill, regrading of site and re vegetation with
native grasses.
Tables 2 and 3 show the clean-up standards for soil and groundwater under the ROD.
Table 2. Soil Clean-Up Standards
Soil Clean-Up Standards
Contaminant Clean-up Standard (mg/Kg)
Aldrin 0.113
Alpha-BBC 0.28
Beta-BBC I. I 5
Delta-BBC NC
Gamma-BBC 1.5
Dieldrin 0.13
Endrin Ketone NC
Toxaphene 2.0
DDD 7.6
DDE 5.5
DDT 4.75
Gamma-Chlordane 1.43
Alpha-Chlordane 1.4
* Note: NC= Not Calculated.
Table 3. Groundwater Clean-Up Standards
Groundwater Clean-Up Standards
Contaminant · Clean-Up Standard (11°/L)
Aldrin . 0.05·
Alpha-BBC 0.05
Beta-BBC 0.05
Delta-BBC · 0.05
Gamma-BBC 0.05
Dieldrin 0.1
Endrin Ketone 0.1
Toxaphene 1.0
Trichloroethene 2.8
The soils removal remediation was completed in early 1997. Site restoration was
conducted in January 1997. A final inspection by EPA an_d the State of North Carolina Division
of Superfund occurred on February 26, 1997.
6
• Draft Five. Year Review
Geig;, Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Based on results of the pre-remedial design field investigation, showing the presence of
pesticides in the Upper Black Creek aquifer, additional investigations of the downgradient areas
were conducted. A Downgradient Groundwater Investigation Work Plan (Rust, 1995) was
prepared and presented to the EPA and NCDENHR to determine type, distribution and
concentration of pesticides in the down gradient areas. Field investigations for the downgradient
groundwater studies were conducted from March to October 1995. Results of the investigation
were reported in the Downgradient Investigation Summary Data Report _dated March 1996.
The PRPs and agencies met in May of 1996, to discuss preparation of a remedial action
plan for the downgradient area and agreed to develop a Remedial Action Work Plan (RA WP)
that_ would evaluate the containment and attenuation of pesticide concentrations as a component
of the remedial action for the downgradient area. The resulting RAWP, finalized in November
1997, has the following objectives:
• reduce pesticide concentrations in downgradient groundwater to levels which are
protective of human health and the environment;
• ensure that site-related pesticide concentrations in downgradient surface water and
steam sediments are protective of human health and aquatic receptors; _and·
• monitor drinking water supplies in the downgradient area to verify they are not
adversely_ impacted.
The RA WP defined the down gradient area as the portions of Upper and Lower Black
Creek aquifers bounded by McFarland's Branch, Aberdeen Creek, Ray's Mill Creek, and Trough ·
Branch. The surficial aquifer was excluded from the work plan. Data from the downgradient
· groundwater investigations revealed that the BHC isomers were the only target pesticides
exceeding Federal or State drinking water standards or Site Performance Standards. As a result
of the analyses, the goal of the downgradient remedial action is to reduce BHC isomer
concentrations to levels below the.North Carolina and Federal drinking water standards or, for
alpha-, beta-, and delta-BHC, which do not have established drinking water standards, to levels
below the groundwater Performance Standards listed in Table 3. The downgradient groundwater
Perfom1ance Standards are listed in Table 4.
Table 4. Downgradient Groundwater Clean-up Standards
Contaminant Clean-up Standard (u!!IL)
Aloha-BHC 0.05
Beta-BHC 0.05
Delta-BHC 0.05
Gamma-BHC 0.20
The recommendations and proposed remedial Performance Standards for the
downgradient groundwater in the RAWP were implemented by issuance of an Explanation of
Significant Differences to the Remedial Action (ESD) in January of 1998.
7
B. Remedy Implementation
• Dnift five~Year Rtview
Geij;y Chemical Corp. (Aberdem Plant), Aberdeen, NC
There were three removal actions associated with the site for soil remediation. The first
two, conducted in 1989 and 1991, removed soils visibly contaminated and other debris from the
site. Approximately 3,300 tons of soil and debris were removed for disposal in these two
actions. Following the.preparation and finalization of a Remedial Investigation/Feasibility
Study, a Record of Decision (ROD) was signed August 27, 1992. The Remedial Action
implemented by the ROD included demolition of the former warehouse foundation; excavation
of the top foot of on-site soils contaminated above performance standards; off-site disposal of
excavated soils as appropriate; extraction of groundwater from the surficial and Upper Black
Creek aquifers; treatment of extracted groundwater via carbon adsorption; site restoration; and
further sampling and analysis of the Upper Black Creek aquifer to determine extent of pesticide
contamination and determine if TCE found in two wells was site-related.
The Remedial Action (RA) was conducted from September 1996 to February 1997. The
RA included removal of concrete foundations and other debris totaling approximately 2,460 tons
to a Subtitle D landfill; disposal of 4,475 tons of contaminated soils to a Subtitle C landfill;
construction and installation of extraction wells and groundwater treatment facilities with an
infiltration gallery for discharge of treated groundwater. The treatment system began ·operation
in January 1997 and has cmTently treated approximately 30 million gallons of extracted
groundwater from the surficial and Upper Black Creek aquifers. ·
C. System Operations/ O&M
As required in the ROD and ESD, the PRPs have been operating a puri1p and treat system
for remediation of the surficial and Upper Black Creek Aquifers since January of 1997 and
monitoring the downgradient areas since April of 1998. · Since commencement of groundwater
treatment operations, Pinnacle Consulting Group of Greenville, South Carolina has had the
treatment monitoring and O&M contract for the PRPs. Initial monitoring requirements called for
quarterly sampling for the firsrthree years followed by semi-annual sampling for an additional
two years. Following_ submission of a five-year review to the state and EPA in 2002, it was
agree by all parties that annual monitoring could be undertaken. Therefore, the last round of
monitoring well sampling occurred in October of 2002. Monitoring well and surface water
· sampling locations are shown in Figures 3 and 4.
Since initiation of operation of the pump and treat system in January 1997, there have
been few problems or breakdowns of the system. The 1992 ROD forecast an estimated annual
O&M cost of $50,000 per year of operation. As currently implemented the treatment and
monitoring program costs approximately $48,000 -$50,000 annually to operate. The system has
treated approximately 30 million gallons of groundwater, operating at a pumping rate of 15-18
gallons per minute. The change-out/longevity period for the carbon adsorption canisters was
initially one year, but has shortened to a six month time period. It is suspected that this change is
due to increasing levels of Trichloroethene (TCE) coming from up-gradient of the site. No
significant variations in O&M as projected in the ROD and ESD were identified. It is expected
that operations will continue without modification or increased expense unless off-site conditions
necessitate changes.
8
Figure 3. Monitoring Well and Sampling Locations
♦
♦ 0
MW-27L .,
-02 ,,...,.""
9
j
Draft Five-Year &view
Geigy Chemical Corp. (Aberdeen P/a11t), Aberdeen, NC
Geigy Chemical Corp. (Aberdeen Plant)
Remediation !'rogram
• Extraction Wells
t~ Surficia/ Aquifer Monitoring Wells
o Upper Black Creek Aquifer Monitoring Wells
~ Lower Black Creek Aquifer Monitoniig Wells
♦ Surface Water Monitoniig Points
~ 190.
C,Mw-220
CMW-200
•
Figure 4. Site Area Monitoring and Extraction Well Locations
j
QMW-18D
._.,
CMW-11D • PW-,0
Geigy Chemical Corp. (Aberdeen Ptm,t)
Remediation Program Immetliate Vici11ity
• Extraction Wells
t!> Surficial Aquifer Monitoring Welfs
ai Upper Black Creek Aquifer Monitoring Wells
• PW-2'
MW-105 e 0 P'N-lS
UW-17$ 0
10
MW->OS
"
Draft Five-Year &view
Geigy Chemical Corp. (Aberdeen Pla11t), Aberdee11, NC
t•.MW-17D
e
•
•
V. Progress Since the Last Five-Year Review:
• Draji Five-Year Rc:1iew
GeigJ• Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Since this is the first Five-Year Review Report, no other report is available and thus no
progress is reportable.
VI. FIVE-YEAR REVIEW PROCESS
The five-year review process for the Geigy Chemical Corp. (Aberdeen Plant) site
included telephone discussion/interviews with the EPA Remedial Project Manager (RPM), and
the lead state agency. Also included, were a visit to the Aberdeen Town Hall, the public
repository for the remedial action documents, and a site visit for familiarization with the
remediation activities. A list of pertinent materials from the document repository and other
sources is provided in Attachment 1.
The following persons were members of the five-year review team:
♦ Greg Mellema, Hazardous, Toxic, and Radioactive Waste Center of Expertise
(CENWO-HX-G), Omaha, NE
♦ 'Phil Payonk, Wilmington District, Environmental Resources Section (CESAW-TS-PE)
♦ Stacy Samuelson, CESAW-TS-PE
VII. FIVE-YEAR REVIEW FINDINGS
A. Interviews
The following persons were interviewed regarding the activities and irriplementation of
the remedial actions at the Potter's Pits Site:
Mr. ]011 Bomholm, Remedial Proiect Manager. EPA Region 4:
In several telephone conversations between Stacy Samuelson and Mr. Bornholm, several
issues pertaining to the Geigy Site were identified. The concern for potential effects on the
remedy due to the off-site TCE plume migration into the site area was identified. A second ,
issue, full implementation of the Record of Decision in terms of fencing and signage at the site,
was addressed as well. Additional discussion of these issues are provided in Sections IX, Issues,
and X, Recommendations and Follow-up Actions.
Mr. Randv McElveen, Environmental Engineer, North Carolina Department of Environment and
Natural Resources, Division of Waste Management, Super[und Federal Remediation Branch:
Stacy Samuelson, Wilmington District, made initial contact with Mr. McElveen through a
telephone conversation. Mr. McElveen indicated that the State has no major issues with the site
at this time. At the site visit, the issue of the off-site TCE plume was discussed in relation to the
site remedy. The State has some concerns about the undefined source of that plume and its
potential effects on the Geigy Site remedy.
11
•
B. Site Inspection ·
• Draft Five•1'~ear Rcvie,v
Geigy Chemical Corp. (Abcrdee11 Pla11t), Aberdeen, NC
A site inspection of the Geigy Site was conducted on Febrnary 18,.2003. Attending the
site visit were:
♦ Randy McElveen, Environmental Engineer, North Carolina Department of
Environment and Natural Resources, Division of Waste Management, SF Federal
Remediation Branch.
♦ Jon Bornholm, Remedial Project Manager, Environmental Protection Agency, Region
4.
♦ · Ray Horn, Olin Corporation ..
♦ Harold Mose, Syngenta Crop Systems.
♦ Michael Sheehan, Pinnacle Consulting Group.
♦ Ted Volskay, Pinnacle Consulting Group.
♦ Ray Livermore, U.S. Army Corps of Engineers, Wilmington District.
♦ Phil Payonk, U.S. Army Corps of Engineers, Wilmington District.
♦ Stacy Samuelson, U.S. Army Corps of Engineers, Wilmington District.
For documentation of the site visit, photos of the treatment facility and several extraction
wells were taken and are attached as Attachment 2.
The site area has not been re-developed since the source remedial action was completed in
1996. The area is currently vegetated with grasses and some long-leaf pines have been planted
along the railroad right-of-way. Mr. Sheehan g<)ve a brief historical overview of the activities
and locations of facilities during the source remedial action and provided a tour of the pump-and-
treat facility.
C. ARAR Review
In performing the five-year review for compliance with applicable or relevant and
appropriate requirements (ARARs), only those ARARs addressing risk posed to human health or·
· the environment.(i.e., addressing the protectiveness of the remedy) were reviewed. This is in
keeping with current EPA guidance on five-year reviews.
Federal ARARs
♦ Federal Groundwater Classification -55 Federal Register (FR) Part 8733.
♦ Safe Drinking Water Act of 1986, as amended (40 USC§§ 300) -40 CFR Part 141.
♦ Solid Waste Disposal Act (40 USC§ 6901 -6987)-40 CFR Part 261.
♦ EPA Regulations on Sole-Source Aquifers -40 CFR 149.
State ARARs
♦ Identification and Listing of Hazardous Waste -15A NCAC l 3A.0006.
♦ North Carolina Drinking Water Act-General Statutes, Chapter 130A, Article 10.
12
• Draft Five•Year Rcvie111
Geigy Chemical Co,p, (Aberdeen P/a11I}, Aberdeen, NC
♦ North Carolina Water Quality Standards-ISA NCAC 2B.
♦ North Carolina Groundwater Quality Standards -ISA NCAC 2L.0100, 2L.0200,
2L.0300.
The site appears to be in compliance with the ARARs identified in the ROD. There were
no changes in the reviewed statutes and standards that would require changes in t_he remedy or
management of the site.
D. Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics
No changes in the site conditions that affect exposure pathways were identified as part of
the five-year review. There are no current or known changes planned in the land use and it is
likely to remain rural residential immediately adjacent to the site. No new contaminants,
sources, or routes of exposure were identified as part of this five-year review. There is no
indication that hydrologic/hydrogeologic conditions are not adequate] y characterized .. The rate
of decrease of contaminant levels in groundwater is consistent with expectations, and the
groundwater plume appears to be contained. Toxicity and other factors for contaminants of
concern have not changed.
E. Data Review
As a result of issues identified in the document review, interviews and site inspection, the
principal data reviewed related to soil and groundwater contaminant levels of the site and
downgradient area. The main resource for review of data was the Downgradient Groundwater
Remedial Action Work Plan, Geigy Chemical Corporation Site, Aberdeen, No1th Carolina
(RA WP) (November 1997) and groundwater monitoring data provided by Pinnacle Consulting
Group (October 2001).
Soil Data
Soil contamination data have not been collected since the completion of the Remedial
Action. Performance Standards for soils were met or exceeded as a result of the remedial action
and the results of final soil testing were reported in the Final Remedial Report For Soils (I 997).
Groundwater Data
Groundwater sampling data was reviewed for sampling events occurring from May I 998
to the present. Wells were sampled quai1erly for three years and then semi-annually for the last
two years. Samples were analyzed for organochlorine pesticides. Starting in 2003, with
coordination with the EPA and state, monitoring will be conducted annually. Over the
monitoring period, some wells have been abandoned or added and several, notably MW-11D,
MW,18D and MW-30D, were unable to be sampled due to drought conditions in the third
. quarter of 1998. Table S presents the detected values for BHC isomers in the surficial aquifer.
Of the compounds on the TCL, the BHC isomers were the most consistently detected over the
. sampling period, Most detected values exceed the site performance standards (Tables 3 and 4).
13
Draji Fiue-"\lear &vie/II
Geigy Chemical C01p. (Aberdeen Plant), Aberdeen, NC
Table 5. Surficial BHC Isomer Concentrations in Groundwater Monitoring Wells 1990 -
2001
Sample Date alpha-HHC beta-BBC delta-Bl-IC ~amma-HHC (Lindane)
MW-4S 11/16/1990 1 3 6 0.5
MW-4S 12/S/1993 0.28 2.1 4.7 0.066
MW-4S 12/3/1996 ND(l.25) 15 10 ND(J.?5)
MW-4S 4/16/1997 ND(0.25) 8.6 7.1 ND(0.'>5)
MW-4S 7/14/1997 0.16 6 7.2 0.1
MW-4S 1 0/111997 0.19 6.3 6.8 ND(0.25)
MW-4S 4/21/1998 ND(l.25) ,16 ND(l.25) ND(l.25)
MW-4S I 0/29/1998 ND(0.275) 4.2 2.8 ND(0.275)
MW-4S I 0/14/1999 ND(0.025) 0.36. 0.23 ND(0.025)
MW-4S I OIi 3/2000 ND(0.125) 1.5 0.66 ND(0.125)
MW-4S I 0/1 0/200 I ND(0.025) 0.013 ND(0.025) ND(0.025)
~;f,!;,'r-!~~;_\ ~~~ t~..!l!l~ 11/rl\i'!LW~ ~~'.ll.ff m,,,,'ltA~~!iW,,1!!&~
MW-5S II /16/1990 5 12 12 5
MW-5S 12/9/1993 1.1 17 6.3 ND(0.5)
MW-5S 12/3/1996 ND(l.25) 17 5.6 ND(l .25)
MW-5S. 4/16/1997 ND(0.5) 9.5 3.1 ND\0.5)
MW-5S 7/14/1997 0,23 5 1.8 0.15
MW-5S 10/1/1997 0.16 3.9 1.3 ND(0.125)
MW-5S 4/21/1998 ND(0.25) 2.5 0.59 0.05
MW-5S I 0/29/1998 0.31 8.6 2 0.25
MW-5S 10/14/1999 ND(0.125) 1.4 0.7 ND(0.125)
MW-5S I Oil 3/2000 0:047 3.2 1.4 ND(0.125)
MW-5S 10/10/2001 ND(0.125) 1.3 0.17 ND(0.125)
~~ M.-!.f.~~'!f.-.ll ~~ !!!~Wilt ~ ~7~ti.~1/l
MW-6S 11/16/1990 36 12 29 30
MW-6S 12/9/1993 7.1 9.6 9.2 6
MW-6S 12/3/1996 2.1 5.8 2.5 1.5
MW-6S 4/16/1997 2.2 6.6 1.6 1.3
MW-6S 7/1411997 1.1 4.1 0.81 0.77
MW-6S 10/1/1997 1.3 3.8 I 0.83
MW-6S 4/21/1998 2.9 6.6 6 2.4
MW-6S I 0/29/1998 1.8 7.1 4.6 1.1
MW-6S 10/14/1999 3.9 6.9 18 2
MW-6S 10/13/2000 ND(0.025) ND(0.025) ND(0.025) ND(0.025)
MW-6S !0/11/200 I 3.5 10 · 15 0.91
~t-.W&Mitl ~~~ ~~~'\l !ml~~ I~~~ ~~.!W.ii©1'Ai
MW-10S . 7/10/1991 2 25 2 0.8
MW-IOS 12/9/1993 ND(0.5) 14 0.79 ND(0.5)
MW-10S 12/3/1996 0.026 0.58 0.045 0.07
MW-10S 4/16/1997 ND(0.25) 5.2 ND(0.25) 0.88
MW-10S 7/15/1997 0.11 1.7 0.12 0.35
MW-IOS 10/1/1997 0.59 4.4 0.47 1
MW-10S 4/21/1998 0.39 7 1.6 0.34
MW-10S I 0/29/1998 0.085 4.5 . 0.41 0.11
MW-10S 10/14/1999 0.045 2.3 0.21 0.064
MW-10S I 0/13/2000 ND(0.125) 1.8 0.077 ND(0.125)
MW-10S I 0/23/2002 0.01 0.56 0.027 0.014
Note: Non-Detect values represent one-half of the detection limit.
Values in bold denote detections exceeding performance standards (Table 3).
14
• Draft Five-Year RevietP
Geigy Chemical Corp. (Aberdeen P/011!}, Aberdem, NC
Tables 6 and 7 depict the concentration levels for the same compounds in the Upper
Black Creek and Lower Black Creek aquifers.
Well 2Q98
Table 6. Upper Black Creek Aquifer Sampling Results 1998 to 2002
Excccdcnces of Performance Standards for BHC Isomers
3Q98 4Q98 l tQ99 I 2Q99 3Q99 I 4Q99 IQ00 2Q00 3Q00 4Q00 IQ0I 4Q0I 2Q02 4Q02
Wells°;Withiri':ttie"-e:xtraction'·and ireatlllCnt CaDtlli-C zOn·e~~-:;;~-~ ·1 ; r.'l:~.✓-:~\~-:."1 .. / ;,:~·•/ ~'"~tt:':i.:"1:-~t·,1-~ .. ~~::' ... A~:, ;;k-1;'<( ''.J';,~
MW-11D i NS T NS i T i i i i i T NS NS NS
MW-18D i NS i NS i i i T i i T i T NS NS
MW-30D T i T NS f i i i T i i i i NS T
M Oiiilo-rin"1{W'C11s1ror ·arC:i ·un-der 'r·e1t1edf( iirlDteineiita'tioll:\.i ,;..;,!,_~ia1', -F,tr·1; ~ {:it:I;:.::,• -~f\\' "':· :\' .~.:2z;.::·;~·~t•::.·4"-;;' .. ~~\.-t.';, 1ff f~ .. :~ ,-i:f.· !~
MW-19D A' A.B.G i i i i i i f A,G T A.D,G NS NS NS
MW-20D A' 1' T 1' 1' 1' i 1' 1' 1' i i 1' i 1'
MW-220 i 1' i 1' i i i 1' 1' i 1' i 1' i i
MW-23D T T A,B,D T i i i T i i i T i T T
MW-24D T B,G A,B.G T T i T A.B,G A,B,G i A,B.G T NS NS NS
MW-25D ND ND ND T T B,D.G ND ND ND ND ND ND NS NS NS
MW-26D i T i T i T ND i 1' r. T i T i T
MW-35D i T i i i i i T i i i i i i i
.Well ror. aSse'sSme"nt Or l?·r·oUitd'watCl' ClllalitV d0Wni:ii-3die0t' Ot1h·e"" Siii-ficifllritciuifei-wCII • M .W ~33S ~;.:.."'!-~,-'i!.•'':},j'_';{:: ·;,1
.;,'.~
NS I MW-34D1 ND
Well 2Q98
ND ND B B ., B B I B B B B B
Table 7. Lower Black Creek Aquifer Sampling Results 1998 to 2002
Excecdcnces of Performance Standards for BHC Isomers
3Q98 I 4Q98 I tQ99 2Q99 3Q99 I 4Q99 IQ00 2Q00 I 3Q00 4QOOI IQ0I
Sentillel .wCII for:Unne·r.Black~Creek / LoWCr:Black:cre·ek Ao'Uifl!rS11Uterfllce· _. -.. ''.' :;·;." '. ---.-. ......
MW-22L i I' i 1' i i i I i i I i I i i i
Mooitorin wells·ror area·•under reniedf:iinple"iiien18tioii,' :_. .': ;)•..=~ ,· -~.·~~.-~\ -. ,,
-!-! ..... C "
MW-2SL i i t i T i T i i i i i
MW-27L i i i i i i i i i i i i
MW-31L i i i i i 1' i i i i i i
MW-37L i i AIG i .; i i i i i i i
MW-40L i i T i T i l i i i i i
PZ-2 i i 1' i i i i i i i T T
PZ-3 i t i i i i 1' i i i 1' i
PZ-5 ND 1' BIG A/BIG A/B/G i i A/BIG i A/BIG i i
NS NS
4Q0I 2Q02 4Q02
·J,. ~-···;-; ."1 ;• -'•
T I i i
'. .. ~-~::.:.: .. · , ... -~ . -"
i i i
i i i
i i i
i 1' i
i i i
i i i
i i i
i i A/BIG
.WCIIS to·rOi-eCii.Si•'.tiends fo'r·R3 ·_•S' Mill;Creek; 'AlierdeelliCi-e"ck:; 3l'ld!McF:i'rlti0d's1Br'aii.ch ~-:·, -:~-;)'( . -;: '\ ·.:.~ :'"-·:~".I.: -·-~I
PZ-2 i i i i 1' i i i 1' i i i i i i
PZ-5 ND T BIG A/BIG A/BIG i i A/BIG i A/BIG 1' i i i A/BIG
MW-31L i 1' i i i i i T i i i i i i i
Sentinel WCll'for noith'ward-peSticidC niigi-StiOn a·nd:rorCcast of con·cenlratiO"n'.trentls inrRay°!s Mill,_Creck\: ... :<. _ J. •• •,
MW-28LI A' I A i i i i I i i I A/B I i B/D/G i i I i i
SeOtillCl Wells' tOr,-oOteDiial ITli~ratioh" Or ·o·eStii:ide·s iri10:RaY •s··M m:creei.:· lliid" A beiaeeritcl'eek s··· . . -;-·' ~\ ·••:;>;:-" .
MW-32L ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
MW-38L ND i ND ND ND ND ND ND ND ND ND ND ND ·D ND
MW-39L ND i ND ND ND ND ND ND ND ND ND ND ND ND ND
Seritinel..Wcli-'f{)f.TOwn ,Well No.-2 :;,:,~.'5-'c~. 1-f .!..~.'..~i'.,;hi;/5-';,::C~tc,.;;~:~~-/¼,;.,'f·'_i,.'f .t ,; ~ :oJ.:.; i~~-i ~ 1f:~~• ?~'£i:'f·:;;: ·"••'::'~1;2~?~-•-:-_:•: ,;,.• .r,~:
MW-36LI ND I ND ND I ND I ND I B ND ND I ND ND ND I ND I ND I ND I ND
Notes:
i Denotes all BHC isomers detected and exceeding performance standards.
ND Denotes non-detect for all BHC isomers.
A. alpha-BHC. B. be1a-BHC. D. delta-BHC, G -gamma-BHC
* Letter only denotes that compound detected exceeding performance srnndard,
NS = Not Sampled.
15
• Draji Five.}~ear Rcvie1v
Geigy Chemical Co,p. (Aberdee11 Pla11t), Aberdeen, NC
Trends in the BHC isomer concentrations in downgradient groundwater are varied.
Several wells (MW-34D, MW-36L, MW-38L, and MW-39L) indicate no trend (little change) for
the 1998-2002 monitoring period. Monitoring well MW-35D decreased over the same
monitoring period. BHC concentrations for wells MW-37D and MW-40L slightly increased.
Data for the downgradient areas seem to_ reflect reductions in concentrations of co_ntaminants for
the remedy area monitoring wells. However, BHC isomer concentrations were consistently
above performance standards. Sentinel wells for Town Well No. 2 (MW-36L) and Ray's Mill
and Aberdeen Creeks (MW-32L, MW-38L, and MW-39L) have consistently exhibited no
detection of BHC isomers. ·
During the downgradient investigations and with the adoption of the ESD in 1998, it was
determined that trich!oroethene (TCE) was not a site related contaminant. As a result,
monitoring and the downgradient groundwater clean-up standard for TCE was removed from the
remedy (Tabl_e 4). However, the ESD did not remove TCE from the groundwater remediation
levels (performance standards) as listed in Table 3.
16
• Draft Five-Year &view
G,i!J Chemical Co,p. (Aberdeen Plant), Aberdeen, NC
Table 8. Trichloroethene (TCE) Concentrations in Groundwater Monitoring \Velis 1991 to
2002
Trichlo·roethcne (TCE) Concentrations in Groundwater Monitoring Wells 1991 -2002
& ½-f,.ff ,.:t~'.1';.~SU rfiChi \ ''A'ti u if crr.1;.~1.w.~.511~
TCE Conccnlr:1lion
Well DATE l,1~/1...l
MW 10S 711011991 ND {]OJ
MW-IOS 1213/1 996 ND(.~)
MW-10S 4/16/1997 ND (5),
MW-10S 7/15/1997 ND (5)
MW-IOS J0/l/l997 ND (5)
MW-10S 4/2lf1998 ND (5)
MW-10S I0/29/1998 NDII)
MW-10S 10/1411999 ND(\)
MW-10S I0/1312000 ND {I)
MW-10S 10/11/2001 ND(l)
MW-10S 10/23/2002 ND {I)
w.;,lll\W.l,m;;,1si;;w.,:,,,,.r.11<v.1:>i<!".I--=
MW-16S 1213/1996 ND (5)
MW-16S 4/16/1997 ND (5)
MW-16S 7/1411997 ND(S)
MW-16S 10/1/1997 ND (5)
MW-16S .m11199s ND{5)
·MW-16S 10129/1998 NO(ll
MW-16S \0/14/1999 ND{l)
MW-16S 10!1312000 ND(5)
MW•l6S 10/1112001 ND(I)
MW•16S 10/22/'1002 ND{I)
~cu~~.:-:tw~r>~~
MW-17S 12/311996 ND {5)
MW-17S 4/1611997 ND (5)
MW-17S 7/14/1997 ND(5)
MW-17S 10/1/1997 I.I
MW-17S 4121/1998 ND(S)
MW-17S J0/2911998 ND (I)
MW-17S 10/14/1999 ND{l)
MW-17S 10113nooo ND (I)
MW-l7S 10/11/2001 ND{l)
MW-17S 10/24/'1002 ND(\)
~~~~~;:A~-
MW-18S 12/311996 ND (5)
MW•l8S 4/1611997 ND(5)
MW-18S 7115/1997 ND (51
MW•ISS 10/1/1997 0.66
MW-18S 4/21/1998 ND (51
MW•lSS 10/29/1998 ND{I)
MW-18S IOf\4/1999 ND(ll
MW-JSS 10/13/1000 ND{l)
MW-18S 1011112001 ND (I)
MW-18S !0'23/2002 ND(l)
-~_½-;.._~-t;.U ·,-ocr BliCk. Cn'Ck1 A"lliiirCi.f.~.IC~~
TCE Concenlration
\\'ell DATE (11~/L)
MW-16D 2/9/1994 200
MW-160 1212/1996 2J()
MW-l6D 4/16/1997 280
MW-160 7/14/1997 250
MW-160 10/1/1997 260
MW-16D 4/21/1998 290
MW-16D 10f19/1998 270
MW-16D 2/4/2000 290.
MW-16D 10113/2000 E (260)
MW-160 10/JOnOOI 190
MW-16D 10/24/2002 160
-;~...,,..,_\¾\~'l'l-"1.,1!,:<ijJ~f.l;',5'
MW-17D 219/1994 180
MW•l7D 12/l/1996 J20
MW-17D 4/16/1997 190
MW-170 7/14/1997 J70
MW-170 10/1/1997 350
MW-170 4/21/1998 3.:!0
MW-17D J0f29/1998 350
MW-17D 2/4/2000 330
MW•l7D 10/13/2000 290
MW-17D 10'24/2002 290 --~~--!Ill;
MW-18D 1/26/1994 ND (3)
MW-18D S/18/1995 ND(I)
MW-18D 12/3/1996 ND{S)
MW-18D 4/16/1997 ND{S)
MW-18D 7/14/1997 1.3
MW-18D JOfl/1997 1.6
MW-18D 4rll/J998 6.2
MW-18D 10/29/1998 4.2
MW-18D 10/14/1999 20
MW-18D 10/14/2000 29
MW-18D 10/10/2001 46
MW-18D 10/22/2002 71
~~"!b~.L~~:\1lvt'~1~
MW-30D 10/14/2000 43
MW-30D I 0/22/2002 I 66
Note: Values in µg/L, ND= Non-detect.
E c Estimated value above ins1rument
linear calibra1ion range. Actual detection.
, TCE concentrations at wells MW-16D and MW-17D, which are at the eastern edge of the
site area, are consistently two orders of magnitude (100 times) greater than the 2.8 µg/L
performance standard. MW-18D at the western edge of the remedy area consistently has TCE
concentrations at one order of magnitude (10 times) the 2.8 µg/L performance standard. The
trend at MW-18D is one where TCE concentrations are increasing over time. Surficial aquifer
monitoring wells, MW-10S, MW-16S, MW-17S and MW-18S do not exhibit TCE
concentrations above the performance standard.
17
•
VIII. ASSESSMENT
• Draft Five.Year Revie1v
Geigy Chemical Corp. (Aberdeen Plant), Aberdeen, NC
To assess the effectiveness of the remedy at the Geigy Chemical Corporation (Aberdeen
· Plant) Site, three basic questions are answered and discussed below:
Question A: ls the remedy functioning as inte11ded by the decision documents?
For the Geigy Chemical Corp. (Aberdeen Plant) Site, the remedy for soil (source)
contamination was completed in 1996, with the conclusion of soil and debris removal. Based on
a final inspection of the site by EPA and the State of North Carolina Division of Superfund in
1998, the soil contaminant level goals established in the ROD and RD have been met and no
further soil remediation is required. ·
The ground""'.ater pump-and-treat system was placed on-line in January 1997 and has
operated continuously since. The groundwater contamination trends attributable to the pump-
and-treat remedy for the surficial and Upper Black Creek aquifers appear to be downward. The
trends of contaminant concentrations in the down gradient groundwater are difficult to discern
because of the extremely low levels of contaminants present. At present, the monitoring data
show that contaminant concentration levels of TCL compounds are consistently above
performance level goals.
Question B: Are the assumptions used at the time of the remedy selection still valid?
The assumptions used for the remedy selection remain valid. The selection of extraction
with activated carbon adsorption as the remedy for the surficial and Upper Black Creek aquifers
is·still vaJid as there have not been any changes to the assumptions made originally. The
selection of monitored natural attenuation as the remedy for the downgradient area is still valid
as conditions have not fundamentally changed. Based on the review, all appropriate measures
and procedures were utilized at the time of the remedial action and continue to be in effect:
Question C: Has any i11formatio11 come to light that could call into questio11 the protective11ess
of the remedy?
Based on validated information provided in the documentation that was reviewed,_there is
no information to date that significantly questions the protectiveness of the remedy. Data
collected sirice the conclusion of the source remedial action support the selection of extraction
with treatment as the preferred method for groundwater remediation in the ROD. The data also
support of selection of monitored natural attenuation as the preferred method of groundwater
remediation in the downgradient area as selected in the ESD. The trends of contaminant
· concentrations in groundwater are generally downward. However, detections of target
contaminants are frequently in exceedance of performance standards for the site. Remedy
implementation data to date provide no validated early indication of potential remedy failure.
18
IX. ISSUES
• Draft Five-Year Review
Gc1'jj Chemical Co,p. {Aberdeen P/011!), Aberdeen, NC
There are several problems or issues that have been identified during this review. Each is
further discussed in the recommendations section of this report.
I. Fencing and sign age for the site as proposed in the documents of record have not been
installed.
2. Modification of the site Groundwater Remediation Discharge Permjt to reflect actual
number of recovery wells in use.
3. Extension of off-site trichloroethene (TCE) contaminant plume into site area and
potential affects on remedy as implemented. Potential increases in TCE concentrations in the
remedy and downgradient areas.
X. RECOMMENDATIONS AND FOLLOW-UP ACTIONS
The recommendations and follow-up actions associated with the issues found in this
review are described below and are summarized in Table 5.
Implementation of site fencing and signage as proposed in the Record of Decision should
be analyzed.· The proposal for fencing and signage was completed prior to remediation of the
site soils. With removal of the contaminated soils, fencing.the site may pose a greater public
safety hazard than exists currently. It is recommended that EPA, the state, and PRPs leave the
site "as is" rather than incurring additional expense for a questionable increase in reduction of
potential for site-related exposure to contarrunants.
The current Groundwater Remediation .Permit issued to the site by the state does not
reflect the treatment system as installed. The permit lists a total of five (5) recovery wells while
the actual number of recovery wells in use is seven (7). As the current permit expires June 30,
2004, it is recommended that the PRPs update the information in the permit application for
renewal. Change of the permit should only be editorial in nature and should not affect the
operation or implementation of the treatment system.
Extension of the off-site trichloroethene (TCE) contaminant plume into the site treatment
area has been noted during ongoing monitoring of the remedy. The change-out period for
activated carbon canisters has reduced from annually to semi-annually. Currently there are
insufficient data to accurately predict whether the TCE plume will adversely affect the remedy as-
implemented or not. It is recommended that the EPA and state continue to pursue
characte1ization of the source of the TCE and the PRPs continue their voluntary monitoring of
wells in accordance with the Site Groundwater Remediation Permit.
19
I) • Draft Five• Year RevieJ1J
Geigi• Chemical Coip. (Aberdeell Pialll}, Aberdeell, NC
Table 9. Recommendations and Follow-up Actions
1:§/:.efc_IsS·lte(sYtt~m:_ .'~--.: :<:ReCOl1iinCil<liitiO'ns!F_ OUOW~\ ~~t_·~~Pit"rtJ?f~~:i;)t; W3'{0VCrSiilit_)!!:if '\ J~-MilCStO_ ifo·~_'1i~ :.i~l;.Follo_-,v.::up;~.{.~
.,.,,,.,-:-. ··•r"f•,....,_~,~r:.-..... {,3;.-~~i,"';i.-r.~'W!' .. Vi 7·'t-~---.. ,"<, --1~~ ·1r-··'"•..td,;;,:-.-"""<.-, -\v .v•;-.-~•·1•,:...----• ...,.-;:;;,.-,./:;, ·-. ,-•-crr.·-~t: • ,·v~--•-f;•.,;;,·,.-'-•· 1-.:.~.-:'l.'
lf.:.l/}$'.i'~-,.}.?;~~,:_.-.i~,:-'-1~8'~ ;!t-,.\'t!-!t_··-¥.,up 'ActiODS·. ;.,1,":A }~' .. RCSponSibt~·::,:.~ ~-~~;:·2~•Aueifcy",J~~~; Date:,'G->tt;.r_~ •-:Adions:•AITect.s·~-
·;,.7i'.[-p~, .. ,,ii;~ig.~• .· }"7::QJi!-•',._\.::,~t;J;:_..;,.l,J,:i{ i~-,,,:,;~ '.,; ."":;";~··• 'n·~Or-J~..,.:i'' j i'J.; •·:11·'i r,.•~1;·A.\-;J..,...~"'I:;:. :..rt•X!l-'ri?t.··~·E_. ~-:·'p'"'"'l;~•,i..~-l:-,,~EM1.~
',':,;~c;;·.· 1:"t"U.:"'f'l-•;'{J; .. '\,_s;,t,Ji·J:ic ... ~r-:..;; -r.7"~[,,· ,:-.~-• .o/. :;>,1~ " • \~-::I;_ "i ,:~ . .\l :¼·.~.i ::<G.'::f-'~.•.-, "fl-.. ~ f,'}.f~~,. 1=J.":l""f.i, f;"· roteC l\'Cne5.'i:\"\"i
l'i";;;,,_. -·i;>S-·i,,>'' •, -,1,,~,;o,1;,,/,'-:,~ ;:;.,~.p ~,\..>,, · ',l/1lli~•"' · •••·ii, ·,. >i''~-•~f/,• -,i,,;, ~,,.,,-, ,\_,,$;i_i!. '"-''"'"" "'"·-,,,;-,<,<
ii~)}_<J~ ~;:.:~'fi;l.·'.i'.~l;~;l~ ~f: }:':.?J~;;:;~~~-.~~~;; .. ,~-~~t~'::lli:?-I'.'.,i-~r:.t. iJ~\$Vf{{\.~.: .. ~~t'.k1-~~ <.?;:;¥r._~~ .. ,t}~}f.-_t:~~t :~~f~-1'._•(Y IN it:~'(~~}'
Fencing and Fencing and signage should PR.Ps EPA and State. Before next N
signage for the not be required as the site five-year review
site as proposed soils have been remediated. as required
in the documents
of record have
not been
im lemented.
Groundwater
Remediation
Permit does not
cover all instalied
recover wells.
Off-site
trichloroethene
· contaminant
lume.
Update permit to reflect
actual number of recovery
wells when renewed ..
. Continued monito1ing of
affect(s).on the site remedy.
PRPs
PRPs, EPA and
State
XI. PROTECTIVENESS STATEMENTS
State
EPA and State
Upo"n renewal
of current
perffilt -June
30.2004
Before next
five-year review
or as required
N
N
The remedy at the Geigy Chemical Corp. (Aberdeen Plant) Site is expected to be or is
protective of human health and the environment, and in the interim, exposure pathways that
could result in unacceptable risks are being controlled.
XII. NEXT REVIE,v
This is a site that requires five-year statutory reviews. EPA will conduct the next review
within five years of the completion of this first five-year review report. The completion of this
review as shown on the signature cover to this rep01t is the trigger for the next five-year review.
20
• Apn"/24,2003
ATTACHMENT 1
List of Documents Reviewed
Five-Year Revieiv
G,;gi, Chemical Co,p. (Aberdeen P/0111), Aberdce11, NC
List of Documents Reviewed
Geigy Chemical Corp. (Aberdeen Plant) Five-Year Review
Rust Environment & Infrastructure: November I 993. Remedial Design Work Plan, Geigy
Corporation Site, Aberdeen, North Carolina. Project No. 86619.200.
Rust Environment & Infrastructure. November 1993. Sampling And Analysis Plan, Geigy
Chemical Corporation Site, Aberdeen, North Carolina. Project No. 86619.210.
Rust Environment & Infrastructure. February 1995. Downgradient Groundwater Investigation
Work Plan, Geigy Chemical Corporation Site, Aberdeen, North Carolina.
Rust Environment & Infrastructure. March I 996. Down gradient Investigation Data Summary
Report, Geigy Chemical Corporation Site, Aberdeen, North Carolina. Volume I and 2. Project
. · No. 33288.610.
Rust Environment & Infrastructure. March 1996. Final Design Report, Oeigy Chemical
Corporation Site, Aberdeen, N01th Carolina.-Project No. 86619.600.
Rust Environment & Infrastructure. November 1997. Final Downgradient Groundwater
Remedial Action Work Plan, Geigy Chemical Corporation Site, Aberdeen, North Carolina.
Project No. 201165.10300.
Sirrene Environmental Consultants. March 16, 1992. Feasibility Study Report, Geigy Chemical
Corporation Site, Aberdeen, North Carolina. Sirrine Project No. G-1024.20.
The Pinnacle Consulting Group. October 2001. Downgradient Remedy Summary Report,
Geigy Chemical Corporation Site, Aberdeen, North Carolina. Project No. MAS0006I.
The Potentially Responsible Parties (PRPs) for the Geigy Chemical Corporation Site.
November, 1989. Remedial Investigation/Feasibility Study Work Plan, Geigy Chemical
Corporation Site, Aberdeen, North Carolina. Prepared by ERM.-Southeast, Inc.
The Potentially Responsible Paities (PRPs) for the Geigy Chemical Corporation Site. March
1992. Final Report -Remedial Investigation Study, Geigy Chemical Corporation Site,
Aberdeen, North Carolina. Prepared by ERM -Southeast, Inc.
U.S. Environmental Protection Agency, Waste Management Division. May I, 1989. Initial Soil
Removal Rep01t Task 10-RI/FS, Geigy Chemical Corp. Site, Aberdeen, North Carolina.
Prepared by the Potentially Responsible Pa1ties (PRPs) for the Geigy Chemical Corp. Site.
U.S. Environmental Protection Agency, Region IV. March 24, 1992. Geigy Chemical Corp.
Site NPL Site Administrative Record, Index and Volume I through 7.
• Five• Year Rtvie,v
Geigy Ckmical Co,p. (Aberdee11 P/0111), Aberdee11, NC
U.S: Environmental Protection Agency, Region IV. August 27, 1992. Record of Decision;
Summary of Remedial Alternative Selection; Geigy C:hemical Corporation Site, Aberdeen,
Moore County, North Carolina.
U.S. Environmental Protection Agency, Region IV. January 23, 1998. Explanation of
Significant Differences to the Remedial Action, Geigy Chemical Corporation Site, Aberdeen,
Moore County, North Carolina.
U.S. Environmental Protection Agency, Region IV. February 6, 1998. Geigy Chemical Corp.
(Aberdeen Plant) Site (Explanation of Significant Differences) NPL Site Administrative Record;
Index and Volume 1 through 3 .
. U.S. Environmental Protection Agency, Region lV. July 21, 1998. Superfund Preliminary
Close-Out Report, Geigy Chemical Corporation NPL Site, Aberdeen, North Carolina.
•
• Five-'fear &view
G,igy Ch,mica/ Corp. (Aberd,ra P!aat),Aberdeea, NC
ATTACHMENT2
Photos of Extraction System Installations
Al.I photos taken by Stacy Samuelson
during site visit February 18, 2003
•
Equalization Tank
•
Equalization tank and transfer pump
1
•
•
' -~ ..
~
>:_!11~---
•
Extraction well PW•3S
•
2
•
•
Controller box/panel for extraction well
3
• •
•
Detail of extraction well PW•3S
•
View of extraction wells PW-2S and PW-JS from well PW-3S
4
•
• • •
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4WD-NSMB
Mr. Stacy Samuelson
REGION 4 .
ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
January 22, 2003
U.S. Anny Corps of Engineers/Wilmington District
Environmental Resources Section
P.O. Box 1890
Wilmington, NC 28402-1890
JAN 2 7 2003
SUBJ: Transmittal of Documents for Preparation of the Five-Year Review Report for the Geigy
Superfund Site in Aberdeen, Moore County, North Carolina
Dear Mr. Samuelson:
Enclosed is a copy of the following documents:
Record of Decision (ROD) (August 27, 1992)
,. •• ' I'••~'.•"• ...
Explanation of Significant Difference (ESD) "(January 23, 1998)
Superfund Preliminary Close-Out Report (PCOR) (July 20, 1998).
Below is the address for the Administrative Record/lnfonnation Repository for the Site:
Aberdeen Town Hall
Poplar Street
Aberdeen, North Carolina
There may be limited information on the Remedial Design and Remedial Action aspects of this
project at this location. If there are any other documents that you need in a timely fashion in
order to write the Five-Year Review Report, please let me know.
lf you have any questions, I can be contacted at 404-562-8820.
Sincerely,
. . Jl11 I~ ~if\0 ~----1/V . , . ,
fon K. Bomholm
Remedial Project Manager
• • Enclosures: (s)
I. August 1992 ROD
2. January I 998 ESD
3. July 1998 PCOR
cc: Randy McE!veen, NCDENR (w/o encl.)
Ray Hom, Project Coordinator, Olin Corp. (w/o encl.)