NCD981927502_20031003_Geigy Chemical Corporation_FRBCERCLA RA_Downgradient Groundwater Monitoring 1999 - 2003-OCR

North Carolina A
Department of Environment :i-atural
Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Octoher 3, 2003
Inter-office Mail
Art Barnhardt, Groundwater Supervisor
Fayetteville Regional Office
Division of Water Quality (DWQJ
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
RE: Groundwater Extraction System Capture Zone Evaluation
Geigy Chemical Corp. Site
NCO 981 927 502
Aberdeen, Moore County, North Carolina
Dear Mr. Barnhardt:
The Pinnacle Consulting Group submitted the attached Groundwater Extraction
System Capture Zone Evaluation. This information was prepared to support the five-year
remedy review by US EPA Region.
The Superfund Section is providing a copy of this document for your information and
for anyone there in the Fayetteville Regional Office who is interested in the results of this
evaluation.
If you have any comments or would like to discuss this document please give me a
call at, [phone] ext. 299.
Attachment
cc: File
Sincerely,
Kyle R. Hagen
Environmental Engineer
NC Superfund Section
1646 Mail Service Cemer. Raleigh. North Carolina 27699-1646
Phone: [phone] \ FAX: 9 I 9-715-3605 \ Internet: ,,ww.enr.state.nc.us
AN EQU,\L Ol'J'URTUNJTY I AFFll(~JATIVE ACTJO~ E\ll'LUYER -511% RECYCLED/ I 0% l'OST CONSU\JER
PA!'ER
•
May 31, 2002
Ms. Giezelle Bennett
Remedial Project Manager
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
USEPA Region IV, North Superfund Remedial Branch
61 Forsyth Street, SW
11th Floor
Atlanta, GA 30303-3104 VIA FEDERAL EXPRESS
RE: Response to Comments
October 2001 Downgradient Area Monitoring Report
Geigy Chemical Corporation CERCLA Site
Aberdeen, North Carolina
Dear Giezelle:
On behalf of Olin Corporation, Syngenta Crop Protection, and Kaiser Aluminum & Chemical
Corporation (the Companies), enclosed are responses comments issued by Mr. Randy McElveen,
NCDENR, on May 9, 2002 regarding the October 2001 Downgradient Area Monitoring Report.
Per our previous submittals, one copy of this package has been sent directly to Mr. Randy
McElveen of NCDENR, and one copy has been sent directly to Mr. Tim Eggert of CDM.
If you require additional copies of the comment responses, please contact me at [phone].
Regards,
Ray Hom
Project Coordinator
/Enclosure
c: R. McElveen (N-NR)
T. Eggert (CDM)
H. Moats (Syngenta)
B. Vinzant (Kaiser)
K. Rubin, Esq. (ML&B)
M. Sheehan (Pinnacle)
•
RESPONSE TO COMMENTS
DATED MAY 9, 2002
ON THE
GEIGY CHEMICAL CORPORATION SITE
OCTOBER 2001 DOWNGRADIENT AREA MONITORING REPORT
Comment No. 1
The Dieldrin detected at sentinel monitoring well MW-38L could be an artifact of the
plume from the Geigy Site that only shows up in periodic sampling due the low solubility
of the Dieldrin. Colloidal transport of Dieldrin and other pesticides with only periodic
releases of soluble levels might explain the periodic detection of Dieldrin. There are no
other known sources of pesticides in this area on the East Side of Aberdeen Creek.
Response
As shown in Table 1 (attached), dieldrin concentrations at MW-38L have remained
below the Site groundwater performance standard defined by the ROD for this
constituent (0.1 ug/L) throughout the downgradient remedy. Dieldrin has otherwise been
detected infrequently in Lower Black Creek aquifer monitoring wells MW-27L and MW-
31L, but has not been detected in the remaining Lower Black Creek aquifer monitoring
wells or in surface water samples collected from Aberdeen Creek, Rays Mill Creek or
McFarland's Branch.
The Companies will continue to evaluate groundwater monitoring results to determine if
the detection of dieldrin at MW-38L is Site-related.
Comment No. 2
As noted in previous comment letters the State disagrees with the statement in bullet 4
under the Stream Surface Water heading that "the source of pesticides detected in
Aberdeen Creek is not Site-related." The pesticides detected in McFarland's Branch are
from the Geigy Chemical Site and are at higher concentrations than those in Aberdeen
Creek. McFarland's Branch flows into Aberdeen Creek, therefore the Geigy Chemical
Site Source has indeed impacted Aberdeen Creek from this location on.
After recent observation of the Geigy plume monitoring well locations and the entrance
of McFarland's Branch into Aberdeen Creek it was concluded that the higher
concentrations of pesticides noted in monitoring well MW-31L may enter Aberdeen
Creek further downgradient than originally suspected. The plume at well MW-31L may
be entering Aberdeen Creek near its convergence with McFarland's Branch.
There is a wetland area just upgradicnt of Aberdeen Creek near the convergence with
McFarland's Branch. The pesticides may be entering the wetland and then moving into
Aberdeen Creek downgradient of the wetland. It is recommended that surface water
samples be collected from the wetland area to confirm whether or not the plume at
MW-31L is entering the wetland.
1
• • Response to May 9 2002 Comments
Response
The Companies expect to conduct fieldwork for the Lower Black Creek groundwater
flow investigation in the next four to six weeks, pending receipt or property access
agreements and subcontractor availability. The objective and proposed water-level
measuring locations for this investigation were discussed in our comment responses dated
October 17, 2001, February 26, 2002, and April 26, 2002.
The Companies will review findings of the groundwater flow investigation with the
Agencies to determine if additional surface water monitoring locations are needed and
discuss their proposed locations.
Comment No. 3
The fourth bullet under the Stream Surface Water heading states that the concentrations
of pesticides at SW-08 is the highest concentration in Aberdeen Creek and that pesticides
downgradient of SW-08 are not Site related. As stated in previous comment letters the
concentration at SW-08 decreases at SW-07 after the convergence with Ray's Mill Creek
but then increases again further downgradient at SW-11-2. This indicates that another
source is replenishing the pesticides in Aberdeen Creek. SW-11-2 is the sampling
location that was selected by the State as a likely entering point for the pesticide plume at
MW-31L.
The total BHC pesticides concentration detected at MW-27L is 9.9 ug/1. The total BHC
pesticides concentration at MW-31L, 3200 feet downgradient of MW-27L, is 5.12 ug/1,
which is more than half the concentration 3200 feet upstream. It is highly unlikely that
the pesticides at monitoring well MW-31L have diluted to concentrations 2 orders of
magnitude less over an additional 860 feet at Aberdeen Creek. The dilution from
monitoring well MW-27L to MW-31L is less than 2 times over 3200 feet and the dilution
from MW-31L to Aberdeen Creek would be greater than 8 times over a distance of 860
feet. Again this is extremely unlikely. An attenuation study should be completed to
explain how this attenuation might occur.
Response
October 2001 analytical results for Aberdeen Creek surface water sample locations
SW-08, SW-07 and SW-11-2 are shown in Table 2 (attached). The sample results were
obtained using EPA analytical method 8081A. Note that in all instances, the reported
BHC isomer concentrations are estimated values, meaning the analytical results were
below the sample reporting (quantitation) limit and therefore may not be accurate
measurements at these levels. Because the detected BHC isomer levels are estimated
values, the Companies believe the surface water monitoring data do not provide a suitable
basis for concluding BHC isomer concentrations increase downstream of SW-07, or
otherwise indicate another BHC isomer source is contributing to Aberdeen Creek.
The groundwater and surface water concerns noted by NCDENR, including the potential
migration of BHC isomers from MW-31L toward Aberdeen Creek, have been routinely
evaluated over the course of the downgradient remedy. During this period, BHC isomer
2
• • Response to May 9 2002 Comments
levels in Aberdeen Creek, which are monitored at multiple locations, have remained at
nearly constant, low levels (i.e., estimated concentrations) that are protective of potential
receptors. This finding applies to locations SW-04 and SW-05, which are downstream of
McFarland's' Branch and the portion of Aberdeen Creek that receives Site-related
groundwater flow.
In the absence of discemable BHC increases downstream of SW-08, the Companies have
historically concluded that Site-related pesticides are not entering Aberdeen Creek at
measurable levels. Nevertheless, we will eliminate statements from future monitoring
reports that indicate pesticides in Aberdeen Creek are not Site related unless future data
otherwise becomes available to support this determination.
3
• •
TABLE 1
Dieldrin Groundwater Quality Monitoring Data
Lower Black Creek Aquifer
April 1998 -October 2001
:;WElllf111OCATl0Ni \S.tl.M~llE[DAliE• lC0NCENirl;IATil0N 1UNHl1S' l0ATP.:F,;li'.ll.G:
' 12-Aug-99 0.12 ugjB J// i•""" 03-Feb~0□-----.-
ug/L_ J// ~··---~-
MW-22L I 0.074
: 09-Apr-02 0.2 ug/U--JI!-----
09-Apr-02 ug1LI J11 -i 0.35
1 11-Oct-00 0.029 ug/LI JI/
MW-31L f---11--Oct-OO 0.029 ug/L JI/ ;·-··-11-Oct-00 0.026 ug/L JI/
! 04-May-98 0.066 ug/LI JI!
! 23-Jul-98 0.059 ug/L. JI/
I 28-Oct-98 0.043 ug/L JI/
i 19-Jan-99 0.056 ug/LI JI!
[_J}-Apr-99 0.054 JI/ ug/L
I 11-Aug-99 0.041 ug/L JI/
! 03-Feb-00 0.037 ug/L! JI/ -
MW-38L ! 03-Feb-00 0.037 ug/L JI! I 11-Oct-00 0.038 ug/L JI/
11-Oct-00 0.035 ug/L JI/
---11 -Oct-00 0.035 ug/L JI/
11-Jan-01 0.033 ug/L JI/
11-Jan-01 0.033 ug/L JI/
11-Jan-01 0.033 ug/L JI/
1 0-Jan-02 0.021 ug/L JI/
! 1 O-Aor:02 ____ 0.038 ua/L_ JI/
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
Ms. Giezelle Bennett
North Superfund Remedial Branch
US EPA Region IV
May 9, 2002
61 Forsyth Street, Eleventh (11) Floor
Atlanta, Georgia 30303-3104
. .. ~,,,;~. ~----_ .. ,, an -,;-, ___ _
NCDENR
RE: Comments on the Downgradient Area Monitoring Report October 2001 Sampling
Events
Groundwater Remediation
Geigy Chemical Corp. Site
NCO 981 927 502
Aberdeen, Moore County, NC
Dear Ms. Bennett:
The Downgradient Area Monitoring Report for the October 2001 Sampling Event 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:
I. The Dieldrin detected at sentinel monitoring well MW-38L could be an artifact of the
plume from the Geigy Site that only shows up in periodic sampling due the low solubility
of the Dieldrin. Colloidal transport of Dieldrin and other pesticides with only periodic
releases of soluble levels might explain the periodic detection of Dieldrin. There are no
other known sources of pesticides in this area on the East Side of Aberdeen Creek.
2. As noted in previous comment letters the State disagrees with the statement in bullet 4
under the Stream Surface Water heading that "the source of pesticides detected in
Aberdeen Creek is not Site-related." The pesticides detected in McFarland's Branch are
from the Geigy Chemical Site and are at higher concentrations than those in Aberdeen
Creek. McFarland's Branch flows into Aberdeen Creek, therefore the Geigy Chemical
Site Source has indeed impacted Aberdeen Creek from this location on.
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/ IO% POST CONSUMER PAPER
•
After recent observation of the Geigy plume monitoring well locations and the entrance
of McFarland's Branch into Aberdeen Creek it was concluded that the
higher concentrations of pesticides noted in monitoring well MW-31L may enter
Aberdeen Creek further downgradient than originally suspected. The plume at well MW-
31L may be entering Aberdeen Creek near its convergence with McFarland's Branch.
There is a wetland area just upgradient of Aberdeen Creek near the convergence with
McFarland's Branch. The pesticides may be entering the wetland and then moving into
Aberdeen Creek downgradient of the wetland. It is recommended that surface water
samples be collected from the wetland area to confirm whether or not the plume at
MW-31L is entering the wetland.
3. The fourth bullet under the Stream Surface Water heading states that the concentrations
of pesticides at SW-08 is the highest concentration in Aberdeen Creek and that pesticides
downgradient of SW-08 are not Site related. As stated in previous comment letters the
concentration at SW-08 decreases at SW-07 after the convergence with Ray's Mill Creek
but then increases again further downgradient at SW-11-2. This indicates that another
source is replenishing the pesticides in Aberdeen Creek. SW-11-2 is the sampling
location that was selected by the State as a likely entering point for the pesticide plume at
MW-31L.
The total BHC pesticides concentration detected at MW-27L is 9.9 ug/1. The total BHC
pesticides concentration at MW-31L, 3200 feet downgradient of MW-27L, is 5.12 ug/1,
which is more than half the concentration 3200 feet upstream. It is highly unlikely that
the pesticides at monitoring well MW-31L have diluted to concentrations 2 orders of
magnitude less over an additional 860 feet at Aberdeen Creek. The dilution from
monitoring well MW-27L to MW-31L is less than 2 times over 3200 feet and the dilution
from MW-31L to Aberdeen Creek would be greater than 8 times over a distance of 860
feet. Again this is extremely unlikely. An attenuation study should be completed to
explain how this attenuation might occur.
If you have any questions or comments, please contact me, at (919) 733-280 I, extension 341.
Sincerely, (' {, ~ ,p. ~!\_01)(0:_~v\
Randy McElveen
Environmental Engineer
NC Superfund Section
cc: Grover Nicholson, N.C. Superfund Section
• •
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
January 13, 2000
Ms. Giezeile Bennett
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
61 Forsyth Street, SW
11th Floor
RECEIVED
_JAN 14 2000
SUPERFUNO SECTION
Atlanta, GA 30303-3104 VIA FEDERAL EXPRESS
RE: Response to NCDENR Comments
Second and Third Quarter 1999 Downgradient Area Monitoring Reports
Geigy Chemical Corporation CERCLA Site
Aberdeen, North Carolina
Dear Giezeile:
On behalf of Olin Corporation, Novartis Crop Protection, and Kaiser Aluminum &
Chemical Corporation (the Companies), enclosed are responses to the NCDENR's
December 10, 1999 comments on the Second and Third Quarter 1999 Downgradient
Area Monitoring Reports. Per our previous submittals, one copy of this package has been
sent directly to Mr. Randy McElveen of NCDENR, and one copy has been sent directly
to Mr. Tim Eggert of CDM.
If you require additional copies of the comment responses, please contact me at (423)
336-4479.
Regards,
Garland Hilliard
Project Coordinator
/Enclosure
•
c: R. McElveen (NCDENR)
T. Eggert (CDM)
H. Moats (Novartis)
B. Vinzant (Kaiser)
K. Rubin, Esq. (ML&B)
M. Sheehan (Pinnacle)
r.
• •
RESPONSE TO NORTH CAROLINA SUPERFUND SECTION COMMENTS
DATED DECEMBER 10, 1999
ONTHE
GEIGY CHEMICAL CORPORATION CERCLA SITE
SECOND AND THIRD QUARTER 1999 DOWNGRADIENT AREA
MONITORING REPORTS
General Comment No. 1
Based on a review of the second and third quarter groundwater monitoring data, in the
Upper Black Creek aquifer, it appears that monitoring wells MW-JJD, MW-30D, and
MW-18D located just south of the source area have increased significantly in total
pesticide concentrations. The total pesticides concentration in this area has increased by
12.56 ug/l and this is equal to a 48.4 % increase in total pesticides over one quarter. If
this trend continues it may be an indication that the source area soil contamination was
not effectively addressed during source area remediation.
in the long run it may be more economical to do some additional soil investigation to a
greater depth and remove additional soils above a predetermined level that will be
protective of groundwater. Leachate models were run during the original Remedial
Investigation but new models and additional soil investigation to a greater depth may
show that additional soil removal would be required for protection of groundwater.
Response to General Comment No. 1
Second and third quarter 1999 analytical results for MW-11D, MW-30D and MW-18D,
which are provided on the attached summary table (Table I), show that an increase in the
concentration of beta-BHC in one well (MW-I ID) was the primary basis for the
observed concentration changes between the two monitoring events. Between the two
events, the concentration of beta-BHC in MW-I ID increased from 6.9 to 16 ug/1. The
concentration of beta-BHC in MW-30D exhibited a minor increase from 2.5 to 4.4 ug/1,
whereas the concentration of beta-BHC in MW-18D decreased from 4.9 to 3.8 ug/1
during the same period. Therefore, while the area monitored by MW-I ID has exhibited a
significant increase in the concentration of beta-BHC, the areas monitored by MW-18D
and MW-30D have not.
Because MW-llD lies within the capture zone maintained by Upper Black Creek aquifer
extraction wells, the observed concentration increase does not pose risk to potential
downgradient receptors or jeopardize the effectiveness of the downgradient area natural
attenuation remedy. Seasonal fluctuations in groundwater pesticide concentrations,
particularly near the former source areas, are expected and do not necessarily provide an
indication of long-term trends. The Geigy Site groundwater pump & treat system has
been in continuous operation since January 1997, following completion of the 1996 soil
removal action. The Companies believe that a minimum of five years of system
operation must elapse in order to obtain sufficient monitoring data needed to differentiate
seasonal fluctuations from long-term concentrations trends.
•
The Agencies should also note that toxaphene, rather than the BHC isomers, was the
dominant pesticide found in Site soils (both in terms of mass and peak concentrations)
and was therefore the primary driver for the 1996 soil removal effort. This observation is
documented by the extensive analytical data contained in the Remedial Action
Construction Report for Site Soils. Based on finding, and the vadose zone transport
modeling conducted for the Remedial Design, the Companies do not believe that
remaining residual BBC isomer concentrations in subsurface soils pose risk to Site
groundwater. We will continue to operate the ground water treatment system and
monitor these well through! our monitoring program. The results will be discussed in our
reports to the agencies.
General Comment No. 2
Alpha and Beta BHC compounds also exceed the modeled maximum concentration trend
from Table 3 in monitoring wells MW-11D, MW-18D and MW-30D. Maximum
groundwater concentration trends listed in Table 3 are based on 1995 groundwater data
from monitoring wells MW-11D and MW-18D. It appears therefore that some of the
model assumptions were not conservative or were incorrect. The source area leachable
soil contamination, as noted above, may be one of the flawed assumptions.
Response to General Comment No. 2
The natural attenuation modeling conducted for the downgradient area remedy was
limited to portions of the Upper and Lower Black Creek aquifers located downgradient of
extraction wells PW-ID, PW-2D and PW-3D, and specifically did not include the area
where monitoring wells MW-l!D, MW-18D and MW-30D are located. The modeled
maximum concentrations shown in Table 3 of the quarterly monitoring reports are
therefore intended to apply only to those areas where groundwater is no longer receiving
residual pesticides concentrations from the former source areas. No attempt was made to
model future concentration trends for wells MW-11D, MW-18D and MW-30D since: (I)
groundwater at these wells is ultimately captured by the Site pump & treat system and
thus poses no risk to potential downgradient receptors and (2) pesticide concentrations at
these wells would not be expected to exceed peak groundwater concentrations observed
in the Surficial and Upper Black Creek aquifers prior to the 1996 soil removal action.
As discussed in the preceding comment response, the Companies believe that the beta-
BHC concentration increase observed primarily in well MW-llD reflects seasonal
changes in groundwater conditions, and is not the result of residual pesticide
concentrations in soils leaching into Site groundwater. We will continue to monitor this
well.
General Comment No. 3
The groundwater in the Upper Black Creek aquifer downgradient of the pump and treat
system appears to be holding fairly constant with a slight decreasing trend in total
pesticides concentration of -0.488 ugll. This is equal to a 7.4% decrease in total
pesticides monitored in the Upper Black Creek aquifer downgradient of the pump and
• •
treat system. The concentration trends in this area are generally well within the modeled
mtL~imum concentrations range listed for the various contaminants in Table 3.
Response to General Comment No. 3
Based on groundwater flow and transport modeling conducted for the downgradient area
remedy, the Upper Black Creek aquifer is anticipated to exhibit measurable pesticide
concentration decreases in advance of pesticide concentration decreases in the Lower
Black Creek aquifer. The Companies anticipate that pesticide concentrations in the
Upper Black Creek aquifer will continue with time, although a minimum of five years of
monitoring data will likely be needed to differentiate seasonal effects from long-term
trends.
General Comment No. 4
Groundwater in the Lower Black Creek aquifer is contaminated only in the area
downgradient of the pump and treat system and has a slight increasing trend in total
pesticide concentration from quarter 2 to quarter 3. The increase in total pesticides
concentration during this time was 1.05 ug/1 which is only a 2.2% increase, however,
( alpha, beta, gamma, and delta BHC isomers exceed the modeled maximum concentration
trends/or groundwater in Lower Black Creek monitoring wells MW-22L and MW-27L as
listed in Table 4. These monitoring locations are the most upgradient areas monitored
within the central part of the plume. MW-31 L is also located in the center of the plume
and exceeds the maximum concentration trend for alpha and gamma BHC.
Along the southern side of the plume monitoring wells MW-25L and MW-40L exceed the
maximum concentration trend in Table 4 for alpha and gamma BHC isomers.
Response to General Comment No. 4
· The downgradient area remedy effectively started in January 1997, when operation of the
groundwater pump & treat system began and formed a capture zone in the Upper Black
Creek aquifer. Operation of the pump and treat system is an integral component of the
remedy as it prevents further release of residual pesticide concentrations to areas west of
the facility property, thereby allowing pesticides in these areas to attenuate under natural
conditions.
Baseline pesticide concentrations (Year 0 on Table 4 of the quarterly monitoring reports)
predicted by the groundwater flow and transport model were intended to reflect initial
conditions in the downgradient area following start-up of the groundwater pump & treat
system. The model relied upon analytical data from the August 1995 and June 1996
monitoring events as a basis for estimating these initial conditions.
Nearly two years have lapsed since start-up of the groundwater pump & treat system.
Current quarterly groundwater monitoring results are therefore anticipated to lie within
the 0 to 4-year range of the predicted BHC isomer concentrations. A summary table
(Table 2) comparing second quarter and third quarter 1999 BHC isomer results for wells
MW-22L, MW-25L, MW-27L and MW-3 IL against concentrations predicted for the Oto
•
4-year range is attached. The summary table shows that alpha-, beta-, delta-and gamma-
BHC concentrations reported for MW-27L for the third quarter I 999 monitoring event
exceeded anticipated maximum concentrations for the O to 4-year timeframe. All other
results were either within the predicted concentrations, or marginally exceeded the
predicted concentrations.
Monitoring results for wells MW-28L, MW-37L, MW-25L, MW-22L, MW-36L and PZ-
3, which surround MW-27L, indicate that the peak pesticide concentrations observed in
the Lower Black Creek aquifer arc limited in extent. To date, groundwater and stream
surface water monitoring results show that the concentrations observed at MW-27L pose
no risk to potential receptors. The Companies anticipate that concentrations at MW-27L
will decline as the remedy proceeds and intend to evaluate concentration trends for this
well during the five-year remedy review.
Specific Comment (No. 5)
The last bullet on page 2 of the Report states that " ... dieldrin was not detected in the
groundwater sample collected from MW-22D, which adjoins MW-22L and monitors
groundwater migrating from the Upper Black Creek aquifer to the Lower Black Creek
aquifer. " This statement does not seem to take into consideration the fact that all
pesticides are sinkers (denser than water) and therefore would likely pass under MW-
22D and be detected by the deeper monitoring well in the Lower Black Creek aquifer as
we see it doing. The sinker effect would not apply at source areas for obvious reasons or
near creeks due to an upward groundwater flow gradient.
Response to Specific Comment (No. 5)
Analytical results of groundwater samples collected for the fourth quarter 1999
monitoring event, which are currently being reviewed by the Companies, indicate that the
detection of dieldrin at MW-22L during the third quarter 1999 monitoring event was
anomalous and therefore not representative of long-term groundwater quality conditions
at this location. Dieldrin was not detected at either MW-22L or MW-22D during the
fourth quarter 1999 monitoring event, and was not detected in these wells prior to the
third quarter 1999 monitoring event. Moreover, downgradient area pesticide
concentrations, which arc in the part per billion to part per trillion range, indicate that the
pesticides detected in Site groundwater are being transported either in the dissolved phase
and/or as colloidal-sized particles. In either case, pesticide transport in groundwater
would not be subject to density-induced flow (i.e., similar to dense, non-aqueous phase
liquids), but would instead be governed by advective-flow (i.e., groundwater movement)
and chemical dispersion. We will continue to sample for this compound during our next
sampling event and report our results.
LOWER BLACK CREEK AQUlFER
TABLE 2
Comparison of Second and Third Quarter 1999 Monitoring Results
for Select Wells
Against Predicted Maximum Concentrations
Sampling EH!nt 2Q99 3Q99 2Q99 3Q99 2Q99 3Q99
Sample ID MW-22L MW-22L MW-25L MW-25L MW-27L MW-27L
Date Collected 4/t3/99 8/12/99 4/14/99 8/12/99 4/15/99 8/11/99
0-Years 4-Yeurs
Pesticides (u~L} Maximum Cone. (1} Maximum Cone. (l}
alpha-BHC 6.0 3.88 4.0 4.0 3.7 ,, 12 I 11
beta-BHC 2.10 l.26 !i'l 2.2 2.2 0.63 0.62 '" 3 3.0
de\ta-BHC 4.90 2.91 3.5 3.6 1.2 1.2 • 5.7 , 5.3
gamma-BHC 5.0 2.88 3.6 3.6 3.1 3.1 : 9.9 9.5
No1es:
I: Maximum concentration predicted under all model scenarios.
Shading indicates observed concentration exceeds maximum predicted concentration.
2Q99 3Q99 2Q99 3Q99
MW-31L MW-31L MW-40L MW-40L
4/13/99 8/tl/99 4/14/99 8/12/99
3.5 3.4 2 3.3
0.9 0.80 0.26 0.44
1.4 1.3 0.52 1.0
2.8 2.8 1.6 2.6 •
•
TABLE 1
Second and Third Quarter 1999
Monitoring Results -Select Wells
Geigy Chemical Corporation CERLA Site
UPPER BLACK CREEK AQUIFER
Sampling Event 2Q99 3Q99 2Q99 3Q99 2Q99 3Q99
Sample ID MW-11D MW-11D MW-18D MW-18D MW-30D MW-30D
Date Collected 4/13/99 8/13/99 4/15/99 8/13/99 4/15/99 8/13/99
Performance
Pesticides ( ug{!,) Standard (ug{!,)
Aldrin 0.05 < 0.5 < I < 0.5 < 0.25 < 0.25 < 0.25
alpha-BBC 0.05 I 1.8 il')] 3.3 I l I 1.2 I 0.78 II 0.46 • beta-BBC 0.05 6.9 i!t· . 16 4.9 3.8 2.5 4.4
delta-BBC 0.05 1.3 D· 2.6 0.78 0.77 0.52 l 0.61 ,,
gamma-BBC (Lindane) 0.2 0.33 JI/ •· 0.39 JI/ 0.7 0.94 0.42 .0.3
alpha-Chlordane --< 0.5 < I < 0.5 < 0.25 < 0.25 < 0.25
gamma-Chlordane --< 0.5 < I < 0.5 < 0.25 < 0.25 < 0.25
4.4'-DDD --< I 0.24 JI/ < I 0.049 JI/ < 0.5 0.046 JI/
4.4'-DDE --< I < 2 < I < 0.5 < 0.5 < 0.5 4,4'-DDT --< I < 2 < I < 0.5 < 0.5 < 0.5
Dieldrin 0.1 § 0.28 JI/ ~ 0.78 JI/ iii 0.29 JI/ m 0.23 JI/ ~ 0.15 JI/ al 0.29 JI/
Endosulfan I --< 0.5 < I < 0.5 < 0.25 < 0.25 < 0.25
Endosulfan II --< I < 2 < I < 0.5 < 0.5 < 0.5
Endosulfan sulfate --< I < 2 <-I < 0.5 < 0.5 < 0.5
Endrin --< I < 2 < I < 0.5 < 0.5 < 0.5
Endrin aldehyde --< I < 2 < I < 0.5 < 0.5 < 0.5
Endrin ketone 0.1 ~ 0.43 JI/ m l.l JI/ ~ 0.57 JI/ iiil 0.37 JI/ ~ 0.28 JI/ ~ 0.61
Beptachlor --< 0.5 < I < 0.5 < 0.25 < 0.25 < 0.25 • Heptachlor epoxide --< 0.5 < I < 0.5 < 0.25 < 0.25 < 0.25
Methoxychlor --< 5 < IO < 5 < 2.5 < 2.5 < 2.5
Toxaphene 1.0 < 20 < 40 < 20 < 10 < IO < 10
TOTAL PESTICIDE CONCENTRATION 11.04 24.41 8.24 7.359 4.65 6.716
Notes:
Previous sampling results shown for comparison.
Detects shown in bold type.
Values exceeding downgradient groundwater performance standards indicated by shading.
/ -Separates the qualifiers added by the laboratory from the qualifiers added as a result of the validation process.
J -Estimated value.
July 2, 1999
Ms. Giezelle Bennett
Remedial Project Manager
•
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee Correspondence
USEPA Region JV, North Superfund Remedial Branch
61 Forsyth Street, S.W.
RECEIVED Rfl.c:
JUL 06 1999
SUPERFUND SECTION
Atlanta, GA 30303-3 l04 VIA FACSIMILE AND FEDERAL EXPRESS
RE: Response to EPA and NCDEHNR Comments
Final Downgradient Groundwater Remedial Action Report/
Third Event, Fourth Quarter 1998 Downgradient Area Monitoring Report
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Giezelle:
On behalf of Olin Corporation, Novartis Crop Protection, and Kaiser Aluminum & Chemical
Corporation (the Companies), please find enclosed two (2) copies of the Companies responses to
the Agencies June 16, 1999 comments on the Final Downgradient Groundwater Remedial Action
Report and the Downgradient Groundwater Remedial Action Report. Copies of this comment
response package have been sent directly to Mr. Randy McElveen of NCDENR and Mr. Tim
Eggert of CDM to facilitate distribution.
If you have any questions regarding the enclosed materials, please contact me at [phone].
Regards,
Garland Hilliard
Project Coordinator
/Enclosure
•
c: R. McElveen (NCDENR)
T. Eggert (CDM)
H. Moats (Novartis)
H. Grubbs, Esq. (WCS&R)
B. Vinzant (Kaiser)
M. Sheehan (Pinnacle)
•
RESPONSE TO USEPA/NCDENR COMMENTS
DATED JUNE 16, 1999
ON THE
1999 ANNUAL OPERA TING REPORT
AND THE
FINAL DOWNGRADIENT AREA REMEDIAL ACTION CONSTRUCTION REPORT
GEIGY CHEMICAL CORPORATION CERCLA SITE
ABERDEEN, NORTH CAROLINA
JUNE 1999
The Pinnacle Consulting Group, Inc.
Greenville, South Carolina
Comment
• Response to Comments
on the
1999 Annual Operating Report
and the
Final Downgradient Area Remedial Action Construction Report
Geigy Chemical Corporation CERCLA Site
Aberdeen, North Carolina ·
• Please provide data Summary Tables similar to Table 1, of the 1999 Annual Operating
Report, for all monitoring events for all detected contaminants of concern ( COCs ).
• Please provide insert pages for monitoring well development logs in the Final Remedial
Action Construction Report for monitoring wells MW-38L and MW-39L with discharge rates
included.
Response to first bullet
Per the Companies June 30, 1999 telephone conversation with Randy McElveen of NCDENR,
the Companies will provide the Agencies with a data summary table for wells MW-38L and
MW-39L which is similar in format/content to Table I of Attachment 3 of the 1999 Annual
Operating Report. The information shown in this table will include previous quarterly
monit01ing results for these wells. The Companies will continue to provide the Agencies with
monitoring results for these wells as part of the periodic monitoring reports for the downgradient
area remedy.
Response to second bullet
Monitoring well development logs for wells MW-38L and MW-39L, which have been revised to
. include discharge rates, are attached.
l
•
RESPONSE TO USEPA/NCDENR COMMENTS
DATED JUNE 16, 1999
ONTHE
1999 ANNUAL OPERA TING REPORT
AND THE
FINAL DOWNGRADIENT AREA REMEDIAL ACTION CONSTRUCTION REPORT
GEIGY CHEMICAL CORPORATION CERCLA SITE
ABERDEEN, NORTH CAROLINA
.JUNE 1999
The Pinnacle Consulting Group, Inc.
Greenville, South Carolina
• • Response to Comments on the Third Event, Fourth Quarter 1998
Downgradient Area Monitoring Report
Geigy Chemical Corporation CERCLA Site
Aberdeen, North Carolina
Comment No. I
Responses to comments are acceptable except for response to comment #4. A representation of
the NC Supeifund Section would like to meet with the appropriate representatives of the PRPs at
the Geigy Chemical Site to review the details of the decision to relocated monitoring well MW-
38l. MW-38L was moved approximately 200 feet north of its original location as shown in
Figure 4-1 of the Downgradient Groundwater Remedial Action Work Plan (RA WP). During this
field meeting we will make a decision as to where the most appropriate location is, if any, for a
sentry well along Aberdeen Creek downgradient of MW-38l. Possible altematives would be a
surface water sample.
ft would be appropriate to further evaluate this decision after a review of the Annual Report.
Response
The Companies are willing to meet with representatives for the NC Superfund Section and/or
U.S. EPA Region IV to further review the basis for relocating MW-38L (including concerns
regarding drill rig access, underground/overhead utilities and traffic on the adjacent highway).
The Agencies may contact Garland Hilliard (423 336-4479) so that we may coordinate a field
meeting in Aberdeen.
• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
June 16, 1999
4WD-NSMB
Mr. Garland Hilliard
Project Coordinator
Olin Corporation
1186 Lower River Road, NW
Charleston, TN 37310
SUBJ: Geigy Chemical Corporation NPL Site
Aberdeen, North Carolina
Dear Mr. Hilliard:
RECEIVED
JUN 18 1999
SUPERFUND SECTION
Attached are responses to comments from the North Carolina Department of
Environment and Natural Resources (NC DENR) on the Third Event, 4th Quarter 1998
Downgradient Area Monitor Report, the 1999 Annual Operating Report for Groundwater
Remediation Permit No. WQ0009949, and The Final Downgradient Groundwater Remedial
Action. Construction Report. .
There is one action item per report. Two of them (providing a summary table and
providing well development logs with discharge rates for two wells) are relatively minor and
should not be difficult to provide. The other requests a meeting at the Site to discuss the
sentinel well. Please provide a response to these issues no laterthan July 2, 1999.
If you have any questions, please give me a call at 404/562-8824.
Sincerely,
1ezelle S. Bennett
Remedial Project Manager
cc: Randy MCEiveen, NC DENR .,.,-----
Internet Addrots (URL)• http://www.epa.gov
Recycled/Recyclabl• • Printed with Vegetable OU Based Inks on Recycled Paper (Minimum 25% Postconsumer)
• . •· NORTH CAROLINA DEPARTMENT OF :t .. ·;:: ,~~· ;~,:-~
~t;:;;-~..:.R _:., ~r~ -~i
ENVIRONMENT AND NATURAL RESOURCES
\ June 8, 1999
DIVISION OF WASTE MANAGEMENT
·~~,;.·~ .... ~· ;".\' ..'.• • ..t<~).'>".~,._'-' /" I \ i. -~~:• ' ~
~~::i_q:o,,,.'-"~ ., •. , . .:.co
:_'j,...,..e.HuNT~: -s. Giezelle Bennett
,,'..~:-OR ~ · ,Remedial Project Manager
'~.S(f''.' f::, . · ->~ USEP A Region IV, North Superfund Remedial Branch -.!• ,r ' ·~ ;±~~.i• '.' 61 Forsyth Street, Eleventh (11) Floor
.<Ji;•: .i1 Atlanta, Georgia 30303 .'.:; )':>'t.:. ~~),~ -.. C.t..
:i'•\WAYNS t-lCOIEV1ffl.s1' ,;,•_ ',,-,,,---~~.'-~ " ... ~:-'."• .. :: ...
' ,,
,'k
~
'
,
, RE: Response to Comments on the Third Event, 4th Quarter 1998 Downgradient
Area Monitor Report
Geigy Chemicai Corporation Site
NCD 981 927 502
Aberdeen, Moore County, NC
Dear Ms. Bennett:
1. Responses to comments are acceptable except. for response to comment
#4. A representation of the NC Superfund Section would like to meet
with the appropriate representatives of the PRPs at the Geigy Chemical
Site to review the details of the decision to relocate monitoring well
MW-38L. MW-38L was moved approximately 200 feet north of its
original location as shown on Figure 4-1 of the Downgradient
Groundwater Remedial Action Work Plan (RA WP). During this field
meeting we will make a decision as to where the most appropriate
location is, if any, for a sentry well along Aberdeen Creek downgradient
ofMW-3 lL. Possible alternatives would be a surface water sample.
It would be appropriate to further evaluate this decision after a review of
the Annual Report. If you have any questions or comments, please
contact me, at [phone], extension 341.
401 OISl!RLIN ROAD, SUITII: 150, RALEIGH, NC 2760S
• PHONE 919-733•4986 FAX 819•7115-360!5
AN EQUAL OPPORTUNITY/ AF'FIRMATIVI! ACTION EMPLOYER· 150% Rl!:CYCLl!C/10% POST-CONSUMER PAPER
. ·--~~t?i-1:~ ~ ,-~ ' '~-
•
Sincerely, ell . ~ti~
Environmental Engineer
NC Superfund Section
cc: Grover Nicholson, N.C. Superfund Section
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4WD-NSMB
Mr. Garland Hilliard
Project Coordinator
Olin Corporation
1186 Lower River Road, NW
Charleston. TN 37310
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
April 26, 1999
SUBJ: Gei(ly Chemical Corporation NPL Site
Abe,deen, North Carolina
Dear Mr. Hilliard:
The Final Downgradient Groundwater Remedial Action Construction Report,
dated April 19, 1999 is hereby approved.
If you have any questions, please give me a call at 404/562-8824.
cc: Randy lv1cElveen, NC DENR
ie lie S. Bennett
Remedial Project Manager
Internet Address (URL)• http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4WD-NSMB
Mr. Garland Hilliard
Project Coordinator
Olin Corporation
1186 Lower River. Road, NW
Charleston, TN 37310
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
March 17, 1999
SUBJ: Geigy Chemical Corporation NPL Site
Aberdeen, North Carolina
Dear Mr. Hilliard:
RECEIVED
MAR 2 2 1999
The Agencies have reviewed the Third Event, Fourth Quarter 1998
Downgradient Area Monitoring Report, dated February 11, 1999. Comments are
attached. Please submit replacement pages no later than April 19, 1999.
If you have any questions, please give me a cal! at 404/562-8824.
cc: Randy McElveen, NC DENA
Michael Sheehan, Earth Tech
Sine
Gi elle S. Bennett
Remedial Project Manager
Internet Address (URL)• http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable OU Based Inks on Recycled Paper (Minimum 25% Postconsumer)
•
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Committee CorrespondenRECE\\/EO
April 16, 1999
Ms. Giezelle Bennett
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
61 Forsyth Street, S.W.
Atlanta, GA 30303-3104
RE: Response to EPA and NCDEHNR Comments
Third Eveni, Fourth Quarter 1998
Downgradient Area Monitoring Report
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Dear Giezelle:
~PR 201999
su?fJ\f\ll-lD s1:.c1101-.1
VIA FEDERAL EXPRESS
On behalf of Olin Corporation, Novartis Crop Protection, and Kaiser Aluminum & Chemical
Corporation (the Companies), please find enclosed two (2) copies of the Companies responses to
the Agencies March 17, 1999 comments on the Third Event, Fourth Quarter 1998 Downgradient
Area Monitoring Report. One copy of the comment response package will be sent directly to Mr.
Randy McElveen of NCDENR and Mr. Tim Eggert of CDM to facilitate distribution.
The Companies are currently preparing the annual monitoring report for the downgradient
remedy and wish to resolve the Agencies' comment with respect to placement of MW-38L (i.e.,
comment no.3) prior to its submittal. We anticipate the report will be forwarded to the Agencies
in May, 1999 (one year after the initial quarterly monitoring event which was conducted at the
close of April 1998). Please contact me following your review of these materials at (423) 336-
4479.
Regards,
~ii~/-#~
Garland Hilliard
Project Coordinator
•
/Enclosure
c: R. McElveen (NCDENR)
T. Eggert (CDM)
H. Moats (Novartis)
H. Grubbs, Esq. (WCS&R)
B. Vinzant (Kaiser)
M. Sheehan (Earth Tech)
Rt:c1=1vEo
APR 20 1999
SUPfRFUND SECTION
•
RESPONSE TO USEPA/NCDENR COMMENTS
DATED MARCH 17, 1999
ONTHE
THIRD EVENT, FOURTH QUARTER 1998
DOWNGRADIENT AREA MONITORING REPORT
GEIGY CHEMICAL CORPORATION CERCLA SITE
ABERDEEN, NORTH CAROLINA
APRIL 1999
Earth Tech Job No. 32240
Earth Tech, Incorporated
Greenville, South Carolina
RECEIVED
APR 20 1999
SUPERFUND SECTION
• • Response to Comments on the Third Event, Fourth Quarter 1998
Downgradient Area Monitoring Report
Comment No. I
Geigy Chemical Corporation CERCLA Site
Aberdeen, North Carolina
The third bullet under the heading of Upper Black Creek Aquifer references Table 4 for the
transport model forecast concentrations for BHC isomers. This should be Table 3 for the Upper
Black Creek Aquifer. Please make this change.
Response
The requested change will be made.
Comment No. 2
The third bullet under the Lower Black Creek Aquifer heading states that "With the exception of
BHC isomer concentrations reported for MW-22L ... " The monitoring well noted in the first line
of this bullet should be MW-27L. Please make this change.
Response
The requested change will be made.
Comment No. 3
The first bullet under the heading of Stream Surface Water and Sediment makes the conclusion
that because the " ... sentinel wells MW-32L, MW-38L, and MW-39L were non-detect for
constituents found in Aberdeen Creek surface water samples .. " that this" ... demonstrates that
pesticides in the downgradient area groundwater do not extend to Aberdeen and Rays Mill
Creeks." This is not an obvious conclusion that can be drawn based on the placement of the
monitoring wells downgradient of MW-3JL which exceeds the performance standards by two
orders of magnitude for alpha-BHC and exceeds the MCLs and NCAC 2L Standards by more
than an order of magnitude for gamma-BHC.
Sentinel monitoring well MW-38L (which was mis-located for confirmation of MW-31L) is
located several hundred feet upgradient of the flow path from MW-3JL. The Final
Downgradient Groundwater Remedial Action Work Plan clearly indicates that the groundwater
flow direction near MW-31L is to the west, southwest not northwest. It is also a well known fact
that flow patterns near creeks dive or increase toward the direction of surface water flow.
Therefore, in order to confirm that pesticides do not extend to Aberdeen Creek at least one
additional sentinel well needs to be installed in the proper downgradient flow direction from
MW-3JL which would be near the intersection of Aberdeen Creek and US Highway 1. A more
accurate statement would be that " ... based on the non-detects in the sentinel wells noted above
their appears to be no significant affect on the surface waters at Rays Mill Creek and Aberdeen
Creek." The conclusions noted in bullets 4 and 5 under the same heading are more valid with
regard to the upper section of Aberdeen Creek.
I
Response • • Simulated water-level contours and predicted groundwater flow patterns for the Lower Black
Creek aquifer presented in Figure F-7 (modified copy attached) of the Downgradient
Groundwater Remedial Action Work Plan (RAWP) illustrates that the location of MW-38L is
suitable for monitoring groundwater downgradient ofMW-31L. The flow patterns shown in this
figure were generated by a detailed and calibrated numerical groundwater flow model that was
constructed for the downgradient area remedy. The model incorporated the hydraulic influence
of local streams, including Aberdeen Creek, upon groundwater flow directions and provided the
technical basis for the proposed location for MW-38L (as shown in the attached copy of Figure
4-1 from the RA WP).
The model results show that a discrete groundwater flow path tracking from MW-31L extends to
the west and passes within approximately 160 feet of the as-built location for MW-38L before
intersecting Aberdeen Creek. Because pesticides in Lower Black Creek aquifer migrate along
advective fronts and are not constrained to discrete flow paths, the as-built location for sentinel
well MW-38L is appropriately positioned to monitor the potential advancement of the pesticides
detected at MW-31L (i.e., the groundwater flow path tracking through MW-38L passes
approximately 160 feet north of MW-3 IL, placing it well within a portion of the Lower Black
Creek aquifer having similar pesticide concentrations as those reported for MW-31L). Moreover,
EPA and the NCDENR approved the proposed location for MW-38L and understood its intended
purpose prior to construction. The well was positioned as close as practical to the proposed
location realizing this is an existing commercial area and that drill rig access to property south of
MW-38L is prohibited by the steep embankment bordering US Highway I.
Figure F-7 also indicates that the area near the intersection of Aberdeen Creek and US Highway
1 lies downgradient of EPA piezometer PZ-5, which is monitored as part of the downgradient
remedy. Monitoring results presented in the report show that beta-BHC and gamma-BHC were
detected at PZ-5 at estimated concentrations of 0.028 ug/L and 0.036 ug/L, respectively. These
concentrations are well below levels of potential concern for Aberdeen Creek. The Companies
therefore believe that an additional well, which would require mobilization of a drill rig,
acquiring access agreements (if feasible) and modification of the Remedial Action Work Plan, is
not needed to monitor potential impacts to area streams. The Companies request EPA and
NCDENR's review of this comment with consideration of our response to NCDENR's concern.
We will be glad to provide additional information, if needed, to resolve this issue.
Comment No. 4
The units noted in the Legend.of the Figure for Surface Water/Sediment Monitoring results seem
to be in error. Surface water concentrations are ug/L not mg/L. Please make appropriate
corrections.
Response
The requested change will be made.
N
•
As-built location
for MW-3BL
t::>--<v·~.
[] . \)~ ' ..
.:\ ~ \j
q □
__ _,F-.....
• '
Legend
c:::::::J Pond
[--I Swamp
c:::::::J Building
/V' Paved Roads
, , -, Unpeved Roads
L Wooded Area
/"-/ Railroads
/V Stream
~ US EPA
Monitoring Well/Piezometer
• Piezometer Nest
Lovver Black Creek Aquifer
Stream Steff Gauge
Monitoring Well
Lower Black Creek Aquifer
J-:" .:";: ::-:: ::J lower Black Creek Confining Unit
_,...;,.;... ....,,J lererel Discontinuity
...--....__ 380.00 Groundwater contour
and elevation
Particle paths
(Arrows show direction of travel)
Particle path from MW-31L
•
800
0 114
EARTH OT EC H
A tqca INTERNATIONAL LTD. COMPANY
0 800
SCALE IN FEET
1 2
SCALE IN MILES
1600
314
19-APR-1999
FIGURE F-7 (MODIFIED)
SIMULATED WATER-LEVEL CONTOURS AND
PREDICTED GROUNDWATER FLOW PATTERNS IN THE
LOWER BLACK CREEK AQUIFER
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN NORTH CAROLINA
N
SW/SED-4 to be
located following field
reconnaissance.
Legend
E=i Pond
~ Swamp
c::J Building
/'./ Paved Roads
, " Unpaved Roads
.::.: I Wooded Area
/"./' Railroads
/V Stream
~ US EPA
Monitoring Well/Piezometer
Ell Monitoring Well
Lower Black Creek Aquifer
"' Monitoring Well
Upper Black Creek Aquifer
•
• •
s
~
0
•
·" -•
. ' \
. SW/SED-7
:' ;·,MW.:] r
·-,;>1 ·1,-,-sio,._r,
( I? /
~ },_,... ,.?·
:';fJ ·-
Town of Aberdeen Municipal Well
Piezometer Nest
Lower Black Creek Aquifer
Monitoring Well Cluster
Upper/ Lower Black Creek Aquifer
Surface Water/ Sediment Sampling Location
Sentinel Well
Existing well or surface water/ sediment
sampling location included in Draft RAWP
monitoring plan.
..
'
Additional well or surface water I sediment
monitoring location requested by Agencies,
with proposed modifications or supplemental
notes shown in text Boxes. Proposed well
identification shown in arentheses.
, ,
t1::7 .. ~('~-. -' .,/
,, ,;.,, .
'1----
-,/--
/-;;-:-:-1 ~ ~ II
-~·· .. -... '"'--1...----. _, .. -----r
, I/ ..:f ' ,, ,,
----•" ,, ,,
' ,, ;'-------------_c,,~r.i~L❖~❖~--~---,;✓
SW/SED-10 to be located
following field reconnaissance .
MUW-2
. ' "
• ' . "' r}J
J
. • . •
', :. Facility Property
! ,
' '] ' ·J r'.
r,;,w;?2 ... L r .... .!I ::-, :, f:J .--"i,"' ,;_
' I
RIKr
'
MW-22D I
MW-20D .. -' MW:il~
, • . 7
-' MW-24D • ' '
0
;!
·'.-;~.. .I .-'-----~-----------~..:"
Groundwater quality monitoring
at this location to be contingent
on water-level data results.
800 0 800
SCALE IN FEET
1/4 1 2
SCALE IN MILES
//' " " ,,
"
' " " "
.· ·,
"' ' ~
,
'
1600
Rust Environment & Infrastructure
FIGURE 4-1
DOWNGRADIENT REMEDIAL ACTION
PROPOSED MONITORING LOCATIONS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN NORTH CAROLINA
I ";:,.i'
34
~'1/t~ta'
l_~A -~~~~''
HCDE8R;i< ~~i:,;,iu..,.~"'·~1(.-,·-· ·.:,:-,> .,~~1r··wr·-,>:;::;,:.
~:(j"AMEB e: Hu~~ .. ~~-
\.~'lGoV!tRNOR
.
:1[fi~~t. ···•ff.,
•• 1· _,
.tilt _,
· WAYNEM
• • NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 23, 1999 DIVISION OF WASTE MANAGEMENT
Ms. Giezelle Bennett
Remedial Project Manager
USEPA Region IV, North Superfund Remedial Branch
61 Forsyth Street, Eleventh (11) Floor
Atlanta, Georgia 30303
RE: Comments on the Third Event, Fourth Quarter 1998 Downgradient Area
Monitoring Report
Geigy Chemical Corporation Site
NCD 981 927 502
Aberdeen, Moore County, NC
Dear Ms. Bennett:
The Third Event, Fourth Quarter 1998 downgradient area groundwater
monitoring report dated February 11, 1999 for the Geigy Chemical Corporation Site,
located in Aberdeen, North Carolina has been received and reviewed by the North
Carolina Superfund Section. The following comments are offered by the North Carolina
Superfund Section.
1. The third bullet under the heading of Upper black Creek Aquifer
references Table 4 for the transport model forecast concentrations for
BHC isomers. This should be Table 3 for the Upper Black Creek Aquifer.
Please make this change.
2. The third bullet under the Lower Black Creek Aquifer heading states that
"With the exception ofBHC isomer concentrations reported for MW-22L.
. . " The monitoring well noted in the first line of this bullet should be
MW-27L. Please make this change.
3. The first bullet under the heading of Stream Surface Water and Sediment
makes the conclusion that because the" ... sentinel wells MW-32L, MW-
38L, and MW-39L were non-detect for constituents found in Aberdeen
Creek surface water samples .. " that this " ... demonstrates that pesticides
in the downgradient area groundwater do not extend to Aberdeen and
Ray''s Mill Creeks." This is not an obvious conclusion that can be drawn
base on the placement of the monitoring wells downgradient ofMW-3 lL
which exceeds the performance standards by two orders of magnitude for
alpha-BHC and exceeds the MCLs and NCAC 2L Standards by more than
an order of magnitude for gamma-BHC.
Sentinel monitoring well MW-38L (which was mis-located for
401 OBERLIN ROAD, SUITE I SO, RALEIGH, NC 2760S
PHONE 919-733·4996 FAX 919-715•3605
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER· SO% RECYCLED/I 0% POST-CONSUMER PAPER
i
' ' '
Ms. Bennett
2-23-99
Page2
•
confirmation ofMW-3 !L) is located several hundred feet upgradient of the flow path
from MW-3 IL. The Final Downgradient Groundwater Remedial Action Work Plan
clearly indicates that the groundwater flow direction near MW-3 IL is to the west
southwest not northwest. It is also a well known fact that flow patterns near creeks
dive or increase toward the direction of surface water flow. Therefore, in order to
confirm that pesticides do not extend to Aberdeen Creek at least one additional
sentinel well needs to be installed in the proper downgradient flow direction from
MW-3 IL which would be near the intersection of Aberdeen Creek and US Highway
I. A more accurate statement would be that " ... based on the non-detects in the
sentinel wells noted above their appears to be no significant affe<;t <in the surface
waters at Rays Mill Creek and Aberdeen Creek." The conclusions noted in bullets 4
and 5 under the same heading are more valid with regard to the upper section of
Aberdeen Creek.
4. The units noted in the Legend of the Figure for Surface Water I Sediment Monitoring
results seem to be in error. Surface water concentrations are ug/L not mg/L. Please
make appropriate corrections.
Please make corrections as noted above and provide insert pages for the document. The remaining
Sections of the Downgradient Area Monitoring Report appear to be in order. If you have any
questions or comments, please contact me, at [phone], extension 341.
~;~R''.~1~~,
~ndy McElveen
. Environmental Engineer
NC Superfund Section
cc: Grover Nicholson, N.C. Superfund Section
• NORTH IROLINA DEPARTMENT OF
ENVIRONM.ENT AND NATURAL RESOURCES
February 23, 1999 DIVISION OF WASTE MANAGEMENT
Ms. Giezelle Bennett
Remedial Project Manager
USEP A Region IV, North Superfund Remedial Branch
61 Forsyth Street, Eleventh (11) Floor
Atlanta, Georgia 30303
RE: Comments on the Third Event, Fourth Quarter 1998 Downgradient Area
Monitoring Report
Geigy Chemical Corporation Site
NCD 981 927 502
Aberdeen, Moore County, NC
Dear Ms. Bennett:
The Third Event, Fourth Quarter 1998 downgradient area groundwater
monitoring report dated February 11, 1999 for the Geigy Chemical Corporation Site,
located in Aberdeen, North Carolina has been received and reviewed by the North
Carolina Superfund Section. The following comments are offered by the North Carolina
Superfund Section.
I. The third bullet under the heading of U1;mer black Creek Aquifer
references Table 4 for the transport model forecast concentrations for
BHC isomers. This should be Table 3 for the Upper Black Creek Aquifer.
Please make this change.
2. The third bullet under the Lower Black Creek Aquifer heading states that
"With the exception ofBHC isomer concentrations reported for MW-221.
. . " The monitoring well noted in the first line of this bullet should be
MW-271. Please make this change.
3. The first bullet under the heading of Stream Surface Water and Sediment
makes the conclusion that because the" ... sentinel wells MW-321, MW-
381, and MW-391 were non-detect for constituents found in Aberdeen
Creek surface water samples: . " that this " ... demonstrates that pesticides
in the downgradient area groundwater do not extend to Aberdeen and
Ray"s Mill Creeks." This is not an obvious conclusion that can be drawn
base on the placement of the monitoring wells downgradient ofMW-3 IL
which exceeds the performance standards by two orders of magnitude for
alpha-BHC and exceeds the MCLs and NCAC 21 Standards by more than
an order of magnitude for gamma-BHC.
Sentinel monitoring well MW-381 (which was mis-located for
401 OBERLIN ROAD, SUITE 1 SO, RALEJCH, NC 27605
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confinnation ofMW-311) is located several hundred feet upgradient of the flow path
from MW-3 lL. The Final Downgradient Groundwater Remedial Action Work Plan
clearly indicates that the groundwater flow direction near MW-3 lL is to the west
southwest not northwest. It is also a well known fact that flow patterns near creeks
dive or increase toward the direction of surface water flow. Therefore, in order to
confirm that pesticides do not extend to Aberdeen Creek at least one additional
sentinel well needs to be installed in the proper downgradient flow direction from
MW-3 lL which would be near the intersection of Aberdeen Creek and US Highway
I. A more accurate statement would be that " ... based on the non-detects in the
sentinel wells noted above their appears to be no significant affect on the surface
waters at Rays Mill Creek and Aberdeen Creek." The conclusions noted in bullets 4
and 5 under the same heading are more valid with regard to the upper section of
Aberdeen Creek.
4. The units noted in the Legend of the Figure for Surface Water/ Sediment Monitoring
results seem to be in error. Surface water concentrations are ug/L not mg/L. Please
make appropriate corrections.
Please make corrections as noted above and provide insert pages for the document. The remaining
Sections of the Downgradient Area Monitoring Report appear to be in order. If you have any
questions or comments, please contact me, at [phone], extension 341.
~~;'·111~~,
~ndy McElveen
Environmental Engineer
NC Superfund Section
cc: Grover Nicholson, N.C. Superfund Section
•
Date sent: Tue, 16 Feb 1999 16:28:31 -0600
[e-mail] (MICHAEL SHEEHAN)
--;, Geigy Site Monitoring Report
[e-mail]
From:
Subject:
To:
Copies to: [e-mail], [e-mail]
Giezelle:
Thanks for contacting me this afternoon to notify me that you and
Randy have not received your copies of the Fourth Quarter 1998
Downgradient Area Monitoring Report. It looks as though the copy
marked to your attention did not get included in the shipment with the
other report recipients. You should however receive a copy tomorrow
morning via Fed Ex. I apologize for the minor delay.
The Fed Ex tracking system indicates that copies marked for Randy
McElveen and Tim Eggert (COM) were delivered to their offices
yesterday. Please contact me if Randy needs another copy.
Regards,
Michael