NCD991278953_19971027_National Starch & Chemical Corp._FRBCERCLA RA_Remedial Design Remedial Action OU-4 1994 - 1997-OCR

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UNITED tJ1;~~-~-Nli;~~~M~NT~~ ~~~;~C;;~~,ENCY
4WD-NSMB
Dr. Abu Alam
REGION 4
ATLANTA FEDERAL CENTER
100 ALABAMA STREET, S.W.
ATLANTA, GEORGIA 30303-3104
October 27, 1997
National Starch & Chemical Company 10 Finderne Avenue
Bridgewater, New Jersey 08807
SUBJ: comments on the August 1997 Natural Degradation Treatability Study Progress Report for Operable Unit #4 for the National Starch & Chemical Company Superfund Site
Dear Dr. Alam:
The Agency received eight copies of the above referenced document on September 2, 1997. Two copies were transmitted to the State of North Carolina Department of Environment, Health, and Natural Resources (NCDEHNR) for review. Below is the Agency's comment and enclosed are comments received from NCDEHNR. All comments need to be addressed. A written response to these comments is requested as the timeframe for the next Natural Degradation Treatability Study Progress Report is too far off into the future.
Below is the Agency's comme~t:
1. The Agency recognizes that this is a "Progress Report" and not a final report. The Agency anticipates that all the conclusions/ assumptions/determinations put forth in the final document will be supported by well documented data generated through the field work currently being conducted at the Site.
If you have any questions, I can be reached at 404-562-8820.
Sincerely yours,
Jon K. Bornholm
Remedial Project Manager
Enclosure (1)
1. NCDEHNR's Comments on the August 1997 Natural Degradation Treatability Study Progress Report for Operable Unit #4 at the National Starch & Chemical Company Superfund Site
cc: David Mattison, NCDEHNR (w\o encl)
' Recycled/Recyclable • Prinled with Vegetable 011 Based Inks on 100% Recycled Paper (40% Postconsumer)
L
, • State of North Carolina
Department of Environment.
Health, and Natural Resources
Division of Waste Management
James B. Hunt. Jr .• Governor
Wayne McDevitt, Secretary
William L. Meyer, Director
Mr. Jon K. Bomholm
Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 111h Floor
Atlanta, Georgia 30303
RE: Soil Remediation Report &
. September 26, 1997
Natural Degradation Treatability Study
Progress Report for Operable Unit 4
National Starch and Chemical Company NPL Site
Salisbury, Rowan County, NC
Dear Mr. Bornholm:
The Soil Remediation Report was received by the Superfund Section of the North Carolina
Department ofEnvironment and Natural Resources (NC DENR) on September 2, 1997. The
Hazardous Waste and Superfund Sections of the NC DENR have reviewed the Soil Remediation
Report and conclude that the Soil Remediation Report is adequate and thereby considered
approved.
The Natural Degradation Treatability Study Progress Report for Operable Unit 4 was received by
the Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) on September 5, 1997. The Hazardous Waste and Superfund Sections of the NC
DENR have reviewed the Natural Degradation Treatability Study Progress Report for Operable
Unit 4 and offer the following attached comments.
P.O. Box 29603. Raleigh. North Carolna 27611-9603 Telephone 919-73'.>-4996 FAX [phone]
An Equol Opportunity Atflrmollve Aclion Employer SO,. Re,cyclod / l CJ'-Post-Consumer Poper
Mr. Jon K. Bornholm
Page 2
• •
We appreciate the opportunity to comment on these documents. If you have any questions or
comments, please feel free to call me at [phone], extension 349.
Attachment
cc: Mr. Patrick Watters, NC Hazardous Waste Section
Comments
Page I
• •
Natural Degradation Treatability Study Progress Report for Operable Unit 4
List of Figures
I. Unless the figures are to be placed within the text portion of this report, please delete the
page number citation for each figure.
List of Tables
2. Please remove Table 4-1 from the text portion of the report and place within the Tables
portion of the report. Furthermore, please delete the page number citation for each table.
Section 1.0 Introduction
3. The third sentence of the first paragraph of this section states that the RD/RA Work Plan
for Operable Unit 4 is dated July 8, 1997. The actual date should be July 8, 1996. Please
correct this oversight.
Section 2.0 Bio-treatability Study
4. The third sentence of the last paragraph of this section discusses the preparation of soil
samples B-1 and B-2 for the partitioning test. Unless additional soil samples were
collected and not documented in this report, these soil samples should be noted as BT-I
and BT-2. Please clarify this discrepancy.
Section 3.0 Soil Plots and Soil Gas Monitoring Wells
5. The last sentence of the fourth paragraph of this section should state" ... beginning
November 25, 1996."
6. The last sentence of the fourth paragraph indicates that the soil plot boxes were installed .
on November 25, 1996. However, the initial round of sampling was conducted on
November 13, 1996. Please provide justification for initiating the treatability study prior
to completing the construction of the soil plots.
7. The last paragraph of this section states that NSCC has encountered problems with water
entering the soil plots. Please provide a plan and schedule for remedying this problem.
Comments
. Page 2
•
Section 4.0 Treatment and Monitoring Activities
•
8. The second sentence in the first paragraph of this section should state " ... are as shown
in Table 4-1." Please correct this oversight.
9. The second sentence in the second paragraph of this section states that three (3) liters of
water were applied as part of the moisture addition. However the Work Plan for the
Natural Degradation Treatability·Study for Operable Unit 4 indicated that 3.6 liters of
water were to be applied. Additionally, the field log for moisture and nutrient addition
indicates-that 3.6 liters ofwaterwere applied. Please clarify this discrepancy.
Section 4.2 Soil Gas Monitoring
10. The second sentence in the third paragraph of this section should read "Soil gas samples
are collected ... " Please correct this oversight.
11. The last paragraph of this section states that NSCC has had difficulties in collecting soil
gas samples without collecting water in the Summa Canisters. Please provide additional
information describing how this has not been a problem during soil gas sampling using
the GA-90. Please provide a plan and schedule for preventing water from entering the
Summa Canisters, or, at a minimum, provide a detailed technical justification describing
how the revised sampling technique provides a representative sample.
Section 5.0 Preliminary Observations
12. This section is very general in nature and should be written in much greater detail.
Although it may be true that natural degradation may be occurring at the site, the data
provided does not provide conclusive evidence at this point. In several instances, the
treatability study has not been conducted in accordance with the RD/RA Work Plan for
OU4. Additionally, much of the data collected to date does not have the laboratory
detection limits necessary to demonstrate the degradation of 1,2-DCA. In order to
demonstrate the overall effectiveness of natural and enhanced biodegradation, please
address these items in a thorough technical discussion of the results of this study.
Figures
13. The title for Figure 3-1 should state "Location of Soil Plots and Soil Gas Monitoring
Wells in Area 2." Please correct this oversight.
14. The NSCC logo contained in the title block has been misprinted. Please correct this
oversight.
Comments
Page 3
• •
15. In addition to the graphical presentation of soil gas sampling which is provided in Figures
4-5, 4-6, 4-7 and 4-8, please provide the field sampling logs used in the collection of this
data.
Tables
16. Table 3-1 indicates that soil sample BT134 was collected from a sample depth of6 feet
(ft) to 8 ft below ground surface (bgs). However this does not agree with previous NSCC
soil sampling conventions in which this soil sample would have been collected from 4 ft
to 6 ft bgs. Additionally, Figure 3-1 does not indicate that a soil sample was collected
from 4 ft to 6 ft bgs. Please clarify these discrepancies.
17. Please provide supporting documentation (i.e., Iiiboratory analytical results) for Table 3-
1. Please note that the laboratory analysis of acetone and vinyl chloride was conducted
several orders of magnitude greater than the method detection limit specified in Table
4-2. Separate laboratory runs for the various compounds may be required so that
contract laboratory program detection limits are maintained for all analytes.
Furthermore, please amend Table 3-1 to indicate the correlation in location between soil
borings and soil gas monitoring wells.
18. Table 4-2 does not include all of the analytical parameters as provided on page 39 of the
RD/RA Work Plan for Operable Unit 4. Please amend Table 4-2 to include the omitted
parameters. Furthermore, please clarify if the laboratory analyses conducted to date have
included the omitted analytical parameters.
19. Please provide supporting documentation (i.e., laboratory analytical results) for Tables 4-
3 through 4-12. Please note that the laboratory analysis for the volatile and semivolatile
organic compounds was conducted several orders of magnitude greater than the method
detection limits specified in Table 4-2. Separate laboratory runs for the various
compounds may be required so that contract laboratory program detection limits are
maintained for all analytes. Please provide an explanation how this data may be used to
demonstrate the trends in natural degradation.
20. Table 4-6 indicates that the concentrations of volatile organic compounds were measured
in milligrams/kilogram (mg/kg). The actual unit should be micrograms/kilogram
(µg/kg). Please correct this oversight.
21. Table 4-6 indicates that control soil samples were collected from sampling locations one
(I), two (2) and three (3). Please provide justification for not collecting the control soil
samples according to the random locations that were used for the test soil sampling event.
Comments
Page 4
Appendix A
Phase I BIOrcport
• •
22. The analytical detection limits provided on page I do not provide any units. Please
correct this oversight and clarify if soil sample BT-2A 4-6' actually had a detection limit
of0.003 µg/kg.
Phase II BIOrcport
General
23. The Total Heterotrophic Plate Counts provided in the "Organisms" section do not agree
with the Plate Counts provide in the "Carbon Dioxide Generation" section for soil
samples BT-2 4-6' (Anaerobic, Biotic), BT-2 4-6' (Anaerobic, Abiotic) and BT-2 4-6'
(Aerobic, Abiotic). Please clarify these discrepancies.
BT-2 4-6' (Aerobic, Abiotic)
24. The "Organisms" section indicates that the Initial Total Heterotrophic Plate Count is less
than I 00 organisms per gram per milliliter. However, in accordance with the initial plate
count for soil sample BT-2 4-6' under the aerobic biotic, anaerobic biotic and anaerobic
abiotic conditions, the initial plate count should be I, 100,000 organisms per gram per
milliliter. Please clarify this discrepancy.
25. The section entitled "Confirmation of Contaminant Degradation" indicates that methylene
chloride was not detected at day 28. However, the laboratory documentation included
with this soil sample indicates that methylene chloride was detected at a concentration of
48 parts per billion (ppb). Please clarify this discrepancy.
Discussion
26. The third paragraph of this section discusses the preparation of soil samples B-1 and B-2 ..
for the biodegradation studies. Unless additional soil samples were collected and not
documented in this report, these soil samples should be noted as BT-I and BT-2. Please
clarify this discrepancy.
2 7. The meaning of the fourth sentence in the first paragraph on page 3 9 of this report is
unclear. Please clarify the meaning of this sentence.
• • Comments
Page 5
BT-1 (4-6 ft) Anaerobic, Abiotic
28. The second paragraph of this section indicates that the N03 additive was reduced to 330
mg/kg. However the laboratory documentation indicates that the N03 additive was
reduced to 390 mg/kg. Please clarify this discrepancy.
BT-1 (4-6 ft) Anaerobic, Biotic
29. The first sentence of the fourth paragraph of this section should be stated as " ...
anaerobic respiration is taking place at lower levels ... " or " ... anaerobic respiration has
taken place at lower levels ... " Secondly, the spelling of"mineralization" at the top of
page 41 of this report is incorrect. Lastly, the first sentence of the fifth paragraph ofthis
section should state " ... detected on day 14 of 430 ppb ... " Please correct these
oversights.
BT-2 (4-6 ft) Anaerobic, Biotic
30. The meaning ofthe last sentence ofthis section is unclear. Please clarify the meaning of
. this sentence.
BT-2 (4-6 ft) Anaerobic, Abiotic
31. The second sentence of the first paragraph of this section should state "The reduction of
N03 from 500 ppb to 380 ppb is not evidence ... " Please correct this oversight.
BT-2 (4-6 ft) Aerobic, Abiotic
32. The second paragraph of this section indicates that 190 ppb of 1,2-dichloroethane and
methylene chloride were depleted. However, the laboratory results for this soil sample
indicate that 1,2-dichloroethane was reduced from 500 ppb to 375 ppb and that methylene
chloride was reduced from 55 ppb to 48 ppb. Please clarify the reduction in 190 ppb of
1,2-dichloroethane and methylene chloride.
BT-2 ( 4-6 ft) Aerobic, Biotic
33. The second sentence of the second paragraph of this section should state" ... to the
complete mineralization of the substrate." Additionally, the second sentence of the fifth
paragraph of this section should state" ... oxygen and an alternate electron donor ... "
Please correct these oversights.
Comments
Page 6
• •
34. The last sentence of the second paragraph of this section states that the generation of CO2
was in decline at day 14. However, the following sentence states that there was a
corresponding elevation in a gross generation of CO2 that reached a high of 3,200 ppm
on the 21" day. Please clarify this discrepancy ..
Partitioning with Composite Samples
35. The first and second paragraphs of this section discuss the preparation of soil samples B-1
and B-2 for the partitioning test Unless additional soil samples were collected and not
documented in this report, these soil samples should be noted as BT-1 and BT-2. Please
clarify this discrepancy.
36. The last sentence in this section indicates that "There was a loss of 125 ppb in the
mechanical processing that is not accounted for." Please provide an explanation for this
loss in product during processing.
Appendix B
37. The initial soil sampling was conducted on November 13, 1996. The soil boxes were
placed on November 25, 1996. Please provide justification for not initiating moisture and
nutrient addition until December 14, 1996.
38. Please provide an explanation for the moisture and nutrient addition on both January 9,
1997 and January 10, 1997. Additionally, please provide an explanation for not
conducting moisture and nutrient addition during the week of June 30, 1997.
Appendix C
January 11, 1997 Blue Planet Technologies Report
39. The "Bacterial Plate Counts" section indicates that serial dilutions were made of soil or
groundwater samples. Please delete the reference to the groundwater sample.
40. Table I of the "Results" section indicates that two soil samples with the same sample
number (SPl-34-(7-8)), but differing laboratory identification numbers, were analyzed for
heterotrophic plate counts. Additionally, soil sample SPl-34-(3.5-4), as submitted with
the soil sample chain of custody documentation, was not analyzed for heterotrophic plate
count. Please clarify these discrepancies.
41. Table II of the "Results" section does not provide the results of soil sample SPl-34-(7-8)
(lab ID L20169-12) or SPl-34-(3.5-4) (which was unaccounted for in Table I). Please
clarify these discrepancies.
Comments
Page 7
• •
42. The soil sample chain of custody documentation included with this report does not have
the proper laboratory signature, date or time of receipt. Please clarify this discrepancy.
January 27, 1997 Blue Planet Technologies Report
43. The "Bacterial Plate Counts" section indicates that serial dilutions were made of soil or
groundwater samples. Please delete the reference to the groundwater sample.
44. The laboratory identification numbers in Table I of the"Results" section implies that
additional soil samples were collected and analyzed but were omitted from this table.
Additionally, the soil sample chain of custody documentation was inadvertently omitted
from this report. Please correct these oversights:
April 4, 1997 Blue Planet Technologies Report
45. The "Bacterial Plate Counts" section indicates that serial dilutions were made of soil or
groundwater samples. Please delete the reference to the groundwater sample.
·46. The soil sample chain of custody documentation was inadvertently omitted from this
report. Please correct this oversight.
June 31, 1997 Blue Planet Technologies Report
47. The "Bacterial Plate Counts" section indicates that serial dilutions were made of soil or
groundwater samples. Please delete the reference to the groundwater sample.
48. The soil sample chain of custody documentation included with this report does not have
the proper laboratory signature, date or time oheceipt. Please clarify this discrepancy.
• •
Date sent:
From:
Mon, 05 Aug 96 10:29:18 EST
[e-mail]
To:
Copies to:
Subject:
Abu Alam,
"Abu Alam" <[e-mail]>, [e-mail]
[e-mail]
Re: Soil Sampling for Biodegradation and Bacterial Enumerati
I apologize for not responding earlier but I was out of the office for the three
weeks the Olympics were in town. I reviewed my voice mail messages and received
your messages, however, I did not have your phone number available to me and
unfortunately you did not leave it with your messages. I concur with the
collection of the two soil samples and their location for Blue Planet
Technologies. Please use this message as the Agency's written confirmation and
concurrence to this activity.
Jon Bornholm
Remedial Project Manager
U.S. EPA
cc: David Lown, NCDEHNR
-,------,---,-----,--.,.------,------Reply Separator ___________ _
Subject: Soil Sampling for Biodegradation and Bacterial Enumeration
Author: "Abu Alam" <[e-mail]> at IN
Date: 7/22/96 6:56 PM
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Date: 22 Jul 96 18:56:29 Z
From: "Abu Alam" <[e-mail]>
To: "[e-mail]" <[e-mail]> (Return
requested),
"Mike Ford" <[e-mail]> (Return requested),
"Doug Cregar" <[e-mail]> (Return requested)
Subject: Soil Sampling for Biodegradation and Bacterial Enumeration
Jon:
I tried to call you several times. Unfortunately I was unable to reach
you. We need your authorization for collecting two soil samples (one
from the Area 2 and the other from the Lagoon Area) for conducting the
in-situ biodegradation and bacterial enumeration study for OU4. We ·
will send these soil samples to Blue Planet Technologies for laboratory
stud.ies and analysis. You have provided us the information on Blue
Planet Technologies when we were putting together the Work Plan. Unless
you have any objections we will collect these two samples next week and
ship these samples to Blue Planet Technologies.
Please give me a call. Thanks for your help. Regards,
Abu Alam
National Starch and Chemical Company.
• • r UNITED STATES ENVIRONMENTAL PROTECTION AGENC!Y
~ECEiVED
MAY -9 1994 REGION IV
345 COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
4WD-NCRS
Mr. Hank Graulich
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
May 6, 1994
SUPERFUND SECTION ·
SUBJ: Performance Standard for. Contaminated Soils Being Addressed in Operable
Unit .. Four ·at the national ··starch & Chemical Company Superfund Site
Dear Mr. Graulich:
After numerous discussions within the Agency and with.the State of North
Carolina Department of Environment, Health & Natural Resources (NCDEHNR), an
agreement was reached with respect to the performance standard (cleanup goal)
for l,2-dichloroethane (1,2-DCA) in the contaminated soils associated with
Operable Unit Four (OU #4). The three performance standards considered were
the two risked based concentrations that would be protective of human health
under the future worker and residential exposure scenarios and the
concentration that would be protective of groundwater above 1 part per billion
(ppb)'. The future worker and residential derived cleanup goals are 63 parts
per million (ppm) and 7 ppm (IT Correspondence, 3/29/94), respectively. The
concentration to protective groundwater was developed using the approach
employed during OU #2. This approach involved comparing the target compound
list (TCL) analytical results of total 1,2-DCA concentration in soil to the
corresponding toxicity characteristic leachate procedure (TCLP) concentration
by using a least squares linear reg.ession on the data. It was hypothesized
that at a concentration of 169 ppb "in the soil ( IT Correspondence, 2/24/94),
1,2-DCA will not adversely impact the quality of groundwater above 1 ppb.
·The Agency is directing National Starch & Chemical Company (NSCC) to
incorporate 169 ppb as the performance standard for 1,2-DCA in the revised
Feasibility Study (FS) document for the contaminated soils associated with OU
~4. The uoe of this performance atanddrd (protecting-the quality of
groundwater) is consistent with the approach taken at other Superfund sites
within Region IV. The selection of this performance standard does not
precluded NSCC from developing a performance standard in the future based on
empirical data developed over the years of operating and maintaining the remedial actions called for by OU #3 and OU #4.
The Agency realizes that IT will need to recalculate the estimated
volumes of adversely impacted soil in order to recompute the cost estimates
for the affected alternatives described in the February 7, 1994 Draft FS
Report for OU #4. If IT requires more than 4 weeks from Monday, May 9, 1994
to complete the revision of the draft FS document, please contact me with a
revised due date for the revised FS document for OU #4. The OU #4 FS document
shall include responses to the above stated performance standard, the comments
the Agency sent to NSCC on March 14, 1994 (includes comments from NCDEHNR),
comments facsimiled on March 28, 1994, the requested change in the Agency's
April 26, 1994 correspondence, and the numerous alterations discussed during
telephone conversations (namely the evaluation of an alternative which
involves horizontal soil vapor extraction wells).
~ AND -NSMITTAL SLIP \,,/ .
TO: (Name, office symbol, t9om number, Initials Date
.JiulMlng, tncy/p;t/ l£
,_J at. "'-t 'I 1n ... r?JA,~n'\\ nren n
u~l!::.VbUW~~., I
2. ft .
IVIAI -., i.:,.:,'I
3.
SUPERFUND SECT ONI
4.
5.
Action FIie Note·and Return
Approval For Clearance Per Conversation
Aa Requested For Correction Prepare Reply
Circulate For Your Information See Me
Comment Investigate Signature
Coordination Justify
REMARKS
?~~
DO NOT use this ~arm as a RECORD of approvals, concurrences, disposals,
clearances, and similar actions
FROM: (Name, org. symbol, Agency/Post/
5041-102 * U.S. G.P.O. 1991 281-781/40010
Room No.-Bldg.
Phone No.
OPTIONAL FORM 41 (Rev. 7-76)
Pr11trib1d b7 GSA
FPMA(41 CFR)101-11.208
• •
2
In addition to the changes required in the above referenced correspondences, the Agency requests that Alternative S2 -Institutional Control either be modified to read Alternative S2 -Natural Degradation and Institutional control or keep Alternative S2 as proposed in the draft OU t4 FS and add an additional alternative entitled "Natural Degradation and Institutional control". The additional costs that need to be incorporated into the Natural Degradation and Institutional Control alternative is the cost to conduct a treatability study to determine, at a minimum, the following three parameters:
1)
2)
confirm natural degradation of 1,2-DCA is occurring at the Site;
determine where the degradation is occurring (i.e., in the soil, at the soil/water interface, or in the groundwater); and
3) if degradation is occurring, calculate the rate of degradation.
As a time frame and for costing purposes, these parameters should be addressed within two years of the signing of the OU #4 Record of Decision.
If the Agency does not hear fr_om either NSCC or IT by Friday, May 13, 1994, then Agency will assume that Monday, June 6, 1994 is an acceptable due dated for submitting the revised OU #4 FS document. If you have any questions, please call me at [phone].
cc: Bruce Nicholson, NCDEHNR
Alex Samson, NSCC
Winston Smith, EPA
Michael Sturdevant, IT
Sincerely yours,
jl~~
Remedial· Project Manager
* --Thie concentration is the Contract Required Quantitation Limit where the maximum allowable concentration of a substance under the State of North Carollna groundwater quality standards (NCAC 15-2L.0202) is lees than the limit of detectability (NCAC 15-2L.0202(b)(l)).
APR 29 '94 09:37 NATIONAL STARCH SEA P.l/4
• • • National Starch and Chemical Company
SAFETY and ENVIRONMENTAL AFFAIRS -BRIDGEWATER, NJ FAX LEADER SHEET
DATE:
TO:
April 29, 1994
B. Nicholson
NCDHNR
. 919-715-3605
~~IC IE ~VfE JJ
APR 2 9 1994
SUPERFUND SECTION
Commitment
to
Quality
FROM: H. Graulich
TOTAL NO. OF PAGES TRANSMITTED: 4
FAX NUMBER: 908-707-3763
PHONE NUMBER: 908-685-5209
SUBJECT: SOIL BORINGS AND PURGED WATER DRUMS FROM WELL DEVELOPMENT AT CEDAR SPRINGS
Letter follows ...
The information contained in this facsimile message is confidential and intended only for the use of the individual or entity named above, If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this commwiication in error, please immediately notify us by telephone, so that we may arrange for the rerum of the original message to us. Thank you.
APR 29 '94 09: 38 NATIONAL STARCH SEA • • 8!,tlonal Starch and Chem/ca/ Company
10 Finderne Avenue
P.O. Box 6500
Bridgewater, New Jersey 08807-0500
908-685-5000
Cable Add,oss, NASPROD.BRIOOEWATERNEWJERSEY
Wri1er's Oirect Dial Number;
Fax Number:
April 29, 1994
Jon K. Bomholm
908-685-5209
908-707-3763
United States Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
Dear Jon:
Subject: SOIL BORING AND PURGED WAT£R DRUMS FROM WELL
INSTALLATIONS AT CEDAR SPRINGS SUPERFUND SITE
This letter will address your request for additional information about the well installation drum
handling and disposal plans as presented in my Jetter of April 11, 1994. First, the plan as
presented in my letter of April 11, 1994 is intended to replace entirely the original plan
submitted by IT Corp in February 1993.
Next, addressing the specific questions raised in your letter of April 14, 1994:
a. Question (Q) -
Answer (A) -
How Jong will it take to empty all the drums?
We must first get the trench water treatment system operational
(i.e. metals removal and voe stripping). This start-up is
presently being delayed by accumulated sludge removal and
reactivation of the plant pretreatment lagoons (Nos. I and 2). The
lagoons are expected to be back in normal service in two months
(No. 1 lagoon is already in normal service and No. 2 is being
emptied for sludge removal). It is then estimated that it will take
four months to process the well installation drums that contained
only water -approximately 400 water containing drums.
Concurrently with this operation (i.e. water drum work oft), we
will be decanting any phased water from the drums containing soil
boring. This water will also be processed through the pretreatment
system. The total time from the present is, therefore, estimated at
six months.
APR 29 '94 09:39 NATIONAL STARCH SEA • • •
Subject: SOIL BORING AND PURGED WATER DRUMS FROM WELL INSTALLATIONS AT CEDAR SPRINGS SUPERFUND SITE Page 2 April 29, 1994
b. Q -The frequency of the soil samples is not specified. Are soil samples to be collected from each drum? two drums to be composited and then sampled? three drums (etc.)?
A -The decanted dmms (i.e. water phase removed) will be moved to the contained lagoon sludge concrete pad and composited based on original well locations. Trench area wells (soils) will be composited together, extraction wells will be composited together, monitoring wells will be composited together, etc. It is estimated that there will be four to eight composites consisting of between 20 and 200 drums each. These composites will be made one at a time. Sampled as a composite, covered by polyethylene, to prevent rainwater infiltration, and held on the concrete pad until the analysis is complete. The soil will then be disposed of based on its hazard analysis. Non-hazardous soil will be surface spread in the trench area. Hazardous soils will be disposed of off-site in accordance with all RCRA regulations (i.e. manifests, transponers, hazardous disposal sites, et.al.).
c. Q -How long after removing the soil from any particular drum will the soil sample be collected for analysis?
A -This will depend somewhat on the composite size (i.e. 20 drums to 200 drums). The small composites will be sampled within one or two days. Larger composites will be sampled in four to five days. All composites will be kept covered by plastic film when no compositing work is in progress.
d. Q -February 19th letter discussed segregating the drums according to the area of the site where the soils were generated. Is this the approach?
A -Yes.
e. Q -February 19th letter discussed conducting TCLP VOA, TCLP BNA, and TCLP metals analyses. Is this still the case?
A -Yes for all soil samples ..
f. Q -Will the concrete pad be decontaminated after this effort? If so, how and what will be done with the washwater?
A -Yes. The concrete pad will be thoroughly washed with a power spray washer, all rinse water collected and processed through the metals removal and VOC stripper system. After this pretreatment, final disposal will be through the biological unit to the POlW.
APR 29 '94 09:39 NATIONAL STARCH SEA P.4/4 • •
Subject: SOIL BORING AND PURGED WATER DRUMS FROM WELL
INSTALLATIONS AT CEDAR SPRINGS SUPERFUND SITE
Page 3 April 29, 1994
g. Q -Will the drum's lid be removed to allow sampling the head space with the OVA?
Or will the OVA probe enter the head space through the bunghole?
A -The drum lids will be removed for OVA testing. Testing will be done as soon as the lid is removed (i.e. immediately).
1. Q -The language in this item needs to be altered to state that the OVA probe will be
inserted into the head space upon opening the drum so that several minutes will not
elapse after exposing the head space to the atmosphere.
A -The OVA headspace reading will .be taken immediately after the lid is removed.
I trust that these answers have properly addressed the questions raised in your letter of April 14th. We are anxiously awaiting approval from EPA to proceed with this testing of disposal of the well installation drums.
dip
cc: Bruce Nicholson, NCDEHNR
Keith Masters, NCDEHNR
Alex Samson, NSC
Ray Paradowski, NSC
Very truly yours,
~~
H. E. Graulich
Div Vice President
Safety and Environmental Affairs
_APR-28-94 FR I 9: 43 •
Van WatQrs & Rogers Inc.
subsidiar!J c'.-Un1var
April 28, 1994
Mr. Thomas Walker North Carolina Department of Environment, Health, and Natural Resources 401 Oberlin Road PO Box 27687
Raleigh, North Carolina 27611-7687
RE: van waters & Rogers Inc. 3001 Holts Chapel Road Greensboro, North Carolina
Dear Mr. Walker:
P. 01 •
2723 s. Cole Road Boise, ID 83709 PHONE: [phone]
FAX: [phone]
Van Waters & Rogers Inc. (VW&R) has briefly reviewed .the Comprehensive Ground Water Monitoring Evaluation (CME) for the referenced facility conducted on December 7, 1993 by the North Carolina Department of Environment, Health, and Natural Resources. VW&R will implement the security measures described in Section IV of the CME. VW&R also requests a thirty day extension for submittal of a ground water assessment plan describing the next phase and implementation schedule of assessment activities. This extension is necessary since, due to my travel schedule, I only received the CME report earlier this week,
If you have any questions related to this letter report, please do not hesitate to call me at 208/362-6545, or leave a voice mail message at 1-800/284-6264, extension 8455.
Sincerely,
~///'/ ~~c,;--'t:E-
Michael V. Ga·uctette
Senior Project Manager
MVG
GSO\CORRESP\REGULATO\G~ASSESS.EXT
cc: Wayne Grotheer, univar Tom Goossen, VW&R Southern Region
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
April 26, 1994
4WD-NCRS
Mr. Bruce Nicholson
North Carolina Department of Environment,
Health & Natural Resources
Suite 150
401 Oberlin Road
Raleigh, North Carolina 27605
RIECEiV\E.D
MAY - 2 1994
suPERfUND SECTION
SUBJ: Request Concurrence on 1,2-Dichloroethane Performance
Standard for Contaminated Soil Associated ·with Operable
Unit #4.at the National Starch & Chemical ,Company
Superfund Site
Dear Mr.·Nicholson:
·The: EPA,.Reg ion: IV· Superfund · Program requests.• concurrence··
from the:. North· Carolina Department -·of• Environment ,,,·Heal th & •· r •
Natural Resources (NCDEHNR), on the selection··of··7,000 micrograms
per kilogram (µg/kg) which is equivalent to 7;000 parts-per
billion (ppb) or 7 parts per million (ppm) as the performance
standard (i.e., cleanup goal) for 1,2-dichloroethane (1,2-DCA)
for the contaminated soils associated with Operable Unit (OU) #4
at the National Starch & Chemical Company (NSCC) Superfund Site.
This concentration is the calculated, direct contact risk-based
value that would be protective of human health to 1 x 10-•. The
Risk Assessment and its associated calculations can be found in
the June 2, 1993 Final Remedial Investigation Report for OU #3.
The 7,000 ppb performance standard is preferred over the 169
ppb concentration which was as the cleanup goal for 1,2-DCA in
the Trench Area soils as specified in the September 1990 Record
of Decision (ROD) for OU #2. The 169 ppb cleanup goal was
derived by IT Corporation by comparing the target compound list
(TCL) analytical results of total 1,2-DCA concentration in soil
to the corresponding toxicity characteristic leachate procedure
(TCLP) concentration py using•a least squares linear. regression
on the _,da_ta: .. : , It was hypothesized. that, at, a concentration of 169
ppb i:(l_,th~-sojl; _ 1,2,DCA will ,not, adversely. impact·the quality of
groundwater above the maximum contaminant level (MCL) for 1,2-
DCA. Below-is the Agency's rationale for selecting the
concentration of 7 ppm as the performance standard for 1,2-DCA
for OU #4 soils.
• •
2
A number of factors were assessed. The most significant
ones considered included the presence of an impervious cap over
the majority of the contaminated soil, the contaminated
groundwater will be extracted and treated in accordance to the
requirements of the ROD for OU #3, and lastly, the risk posed by
the contaminated soil itself, with one exception, falls within
the acceptable risk range of 1 x 10-• to 1 x 10-•. Other factors
considered included the cost of the proposed remedial actions,
the requisite to remove the source prior to petitioning the State
to reclassify the groundwater, and the Agency's belief that the
NSCC property will remain industrial and not become residential.
The impervious cap is formed by the concrete foundations of
the buildings and the macadam driveway that surround the
buildings. The permeability of this cap is dependent on the
integrity of the asphalt driveway and the seals between the
driveway and the foundations of the buildings. Since this
impervious cap will prevent precipitation from infiltrating into
the soil in this area, the principal force driving the migration
of 1,2-DCA will be removed. As a condition in the forthcoming OU
#4, the Agency plans to require NSCC to inspect and repair the
driveways on a periodic bases. ·
Although the quality of the groundwater may not be protected
to the MCL or the State's groundwater quality concentration for
1,2-DCA by leaving a· residual concentration of 7 ppm of 1,2-DCA
in the soil, both human health and the environment will be
protected. This protection is the result of the remedial action
required by the OU #3 ROD. The ROD for OU #3 requires NSCC to
install a groundwater extraction system downgradient of Area 2
and the wastewater treatment lagoon area. This groundwater
extraction system will protect both human health and the
environment by removing the contaminated groundwater and
preventing further migration of the plume.
The only unacceptable future risk posed by the subsurface
soils is to a resident child. The calculated carcinogenic risk
for the child was 2 x 10-• which is just outside the acceptable
risk range of 1 x 10-• to 1 x 10-•. The calculated carcinogenic
risk for a residential adult was 1 x 10-•. These risks are based
on the premise that the NSCC will become residential. However,
there is every reason to believe that this property will remain
an industrial facility and hence the owner of the property will
be able to control the installation of any potable well within
its property boundary.
Based on the information presented in OU #3 RI Report, the
groundwater plume originating from this portion of the Site,
remains within the property boundary. Therefore, the likelihood
that a potable well will be installed into the contaminated
aquifer is minute. The chances of this occurrence can be farther
reduced by having NSCC place a deed restriction on the property.
• •
3
In addition, NSCC has committed itself to develop a cleanup
goal for 1,2-DCA in soil that would be protective of groundwater
based on empirical data and not a mathematical computer model.
This data will be collected during the operation of the OU #3
remedial action and the monitoring to be required by the OU #4
ROD. Consequently, both EPA and NCDEHNR will have ample
opportunity to oversee the development of a revised cleanup goal,
if deem necessary, at a future date. And more importantly, based
on my telephone conversation with Jack Butler on April 19, 1994,
the State will not reclassify the underlying groundwater until
the source has been removed. Therefore, the groundwater will
remain designated as Class GA in accordance with 'North Carolina's
water classification system and/or Class IIA under USEPA
Groundwater Classification Guidelines (December 1986) which
requires that the groundwater to be remediated to a level
protective of public health and the environment as specified in
state and federal regulations governing the quality and use of
drinking water.
The estimated cost for achieving the performance standard of
7 ppm for 1,2-DCA in the contaminated soils using a soil vapor
extraction system (SVE) is approximately $7,000,000. This cost
has been substantiated by the additional cost information
supplied by IT Corporation which supplements the information
incorporated into the February 1994 Draft Feasibility Study for
OU #4. This additional costing information was shared with
NCDEHNR. At a cost of $7,000,000, the Agency does not deem SVE
as a cost effective alternative. This cost would increase
significantly if the performance goal for 1,2-DCA in the soil was
lowered to 169 ppb.
Based on the above information, the Agency is requesting
NCDEHNR to concur on specifying 7.0 ppm as the performance
standard for 1,2-DCA in the soil for OU #4. This concentration
will be incorporated into both the upcoming Proposed Plan Fact
Sheet and the ROD. A timely response is requested.
If you have any questions, please call me at [phone].
Sincerely yours,
~~~
Jon K. Bornholm
Remedial Project Manager
cc: Winston Smith, EPA
.APR 11 '94 1.6=06 NAT.AL STARCH SEA •
:_ National Starch and Chemical Company
P.l/3
SAFETY and ENVIRONMENTAL AFFAIRS-BRIDGEWATER, NJ FAX LEADER SHEET
DATE:
r IRIECEfV/ElQJ Gommitment
\ to
APR 1 2 1994 Quality
SUPERFUND SECTION
TO:
April 11, 1994
B. Nicholson
NCDHNR
919-715-3605
FROM: H. Graulich
FAX NUMBER: 908-707-3763
TOTAL NO. OF PAGES TRANSMIITED: 3 PHONE NUMBER: 908-685-5209
SUBJECT: SOIL BORINGS AND PURGED WATER DRUMS FROM WELL DEVELOPMENT AT CEDAR SPRINGS
Letter follows ...
The information contained in this facsimile mess:.ge is confidential and intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this cornmuniqition is strictly prohibited_. If you have received this communication in error, please immediately notify us by telephone, so that we may arrange for the return of the original message to us. Thank you,
'APR 11 '94 15:07 NRiRL STARCH SER
e,,,ona/ Starch and .Chem/ca/ Corrtpall'f
10 Finderne Avenue
P.O. Box 6500
Bridgewater, New Jersey 08807-0500
908-685-5000
Cab!& Add1ess: NASPROD,BRIOGEWATERNEWJERSEV
Write,·s Direct Dial Number:
Fax Number:
April 11, 1994
Jon Bomholm
908-685-5209
908-707-3763
Remediation Project Manager
US EPA, Region IV
345 Courtland Street, NE
Atlanta, GA 30365
•
SUBJECT: SOIL BORINGS AND PURGED WATER DRUMS FROM WELL
DEVEWPMENT AT CEDAR SPRINGS
Dear Jon:
P.2/3
IT previously submitted a plan to EPA in 1993 for disposal of the soil borings and purged water
drums resulting from well drilling and development during OUl and OU2. EPA and the State
of North Carolina Division of Solid Waste Management provided comments in response to the
plan. In our efforts to complete the start up of the OU1/OU2 remediation and to complete the
studies needed for OU3 and OU4, this project was delayed until now. We have examined all
of the drums (totaling about 800 from OUl, OU2, OU3 and OU4) and they are still in
satisfactory condition. The following plan, which talces into consideration the comments of EPA
and the State of North Carolina, is proposed for disposal of the contents.
1. All of the drums containing water will be processed through the OU 1 treatment
system -i.e. air stripping, metals removal, biotreatment and final discharge to the
Salisbury POTW. This treatment.will talce place as soon as the air stripper/metal
removal system is started up and brought into normal "steady-state" condition.
The biological treatment system is already in normal service. We expect that the
drum handling could start in May and require about 120 days to complete.
APR 11 '94 P.3/3 •
SUBJECT: SOIL BORINGS AND PURGED. WATER DRUMS FROM WELL
DEVEWPMENT AT CEDAR SPRINGS
Page 2 April 11, 1994
2. All of the drums containing soil will be opened and any free standing water will
be decanted and processed as in (1) above through the complete water treatment
system. The residual soil in these drums will then be transferred to the plant
lagoon ·sludge drying pad (the pad is concrete and bermed to prevent any runoff)
where it will be composited and tested for RCRA hazard characteristics. Soils
will be covered with plastic during the test period, Soils that test as
nonhazardous will be placed in the trench area as a surface overlay. Soils that
test as RCRA hazardous will be proper I y manifested and disposed of off-site in
accordance with RCRA regulations at an approved RCRA disposal site.
3. Miscellaneous drums (i.e. lunch bags, personal protective equipment, trash) will
be individually opened and tested by a portable OVA meter. If the OVA meter
is less than 5 ppm, the miscellaneous items will be disposed of in the normal
plant industrial trash system to a nonhazardous dump. Drums over 5 ppm will
be treated as RCRA hazardous and be manifested off-site to an approved RCRA
disposal site.
We are ready to start this work as soon as approval is received. National Starch will coordinate
all drum movement. Sampling and analysis will be performed by an independent outside EPA
certified laboratory. Final disposals will be handled, as appropriate, by NSCC with approved
haulers and sites. The drums will be inspected on a monthly basis while awaiting disposition
and disposal. Records will be kept of these inspections.
Please indicate acceptance or any required modifications to these plans at your earliest
convenience.
dip
cc: B. Nicholson -NCDHNR
D. K. Masters -NCDHNR
Very truly yours,
f1'r t'~"<~ l~
H. E. Graulich
Div Vice President
Safety and Environmental Affairs
l, ....
CONFIRMATION OF -SENT 4/11/94
e_,,onal Starch and Chem/ca/ Company
10 Finderne Avenue
P. 0. Box 6500
Bridgewater, New Jersey 08807-0500
908-685-5000
Cable Address: NASPROO,BAIOGEWATEANEWJEASEY
Writer's Direct Dial Number:
Fax Number:
April 11, 1994
Jon Bomholm
908-685-5209
908-707-3763
Remediation Project Manager
US EPA, Region IV
345 Courtland Street, NE
Atlanta, GA 30365
•-rE»i~-=----REceiVfED
APR 151994
~S_U_P_E __ RF_·U..:..N:..::D__:S~E:'.:::C!!_Tl~00
SUBJECT: SOIL BORINGS AND PURGED WATER DRUMS FROM WELL
DEVELOPMENT AT CEDAR SPRINGS
Dear Jon:
IT previously submitted a plan to EPA in 1993 for disposal of the soil borings and purged water
drums resulting from well drilling and development during OU! and OU2. EPA and the State
of North Carolina Division of Solid Waste Management provided comments in response to the
plan. In our efforts to complete the start up of the OU I/OU2 remediation and to complete the
studies needed for OU3 and OU4, this project was delayed until now. We have examined all
of the drums (totaling about 800 from OU I, OU2, OU3 and OU4) and they are still in
satisfactory condition. The following plan, which takes into consideration the comments of EPA
and the State of North Carolina, is proposed for disposal of the contents.
I. All of the drums containing water will be processed through the OU I treatment
system -i.e. air stripping, metals removal, biotreatment and final discharge to the
Salisbury POTW. This treatment will take place as soon as the air stripper/metal
removal system is started up and brought into normal "steady-state" condition.
The biological treatment system is already in normal service. We expect that the
drum handling could start in May and require about 120 days to complete.
• •
SUBJECT: SOIL BORINGS AND PURGED WATER DRUMS FROM WELL
DEVELOPMENT AT CEDAR SPRINGS
Page 2 April 11, 1994
2. All of the drums containing soil will be opened and any free standing water will
be decanted and processed as in(!) above through the complete water treatment
system. The residual soil in these drums will then be transferred to the plant
lagoon sludge drying pad (the pad is concrete and bermed to prevent any runoff)
where it will be composited and tested for RCRA hazard characteristics. Soils
will be covered with plastic during the test period. Soils that test as
nonhazardous will be placed in the trench area as a surface overlay. Soils that
test as RCRA hazardous will be properly manifested and disposed of off-site in
accordance with RCRA regulations at an approved RCRA disposal site.
3. Miscellaneous drums (i.e. lunch bags, personal protective equipment, trash) will
be individually opened and tested by a portable OVA meter. If the OVA meter
is less than 5 ppm, the miscellaneous items will be disposed of in the normal
plant industrial trash system to a nonhazardous dump. Drums over 5 ppm will
be treated as RCRA hazardous and be manifested off-site to an approved RCRA
disposal site.
We are ready to start this work as soon as approval is received. National Starch will coordinate
all drum movement. Sampling and analysis will be performed by an independent outside EPA
certified laboratory. Final disposals will be handled, as appropriate, by NSCC with approved
haulers and sites. The drums will be inspected on a monthly basis while awaiting disposition
and disposal. Records will be kept of these inspections.
Please indicate acceptance or any required modifications to these plans at your earliest
convenience.
dip
cc: .B. Nicholson -NCDHNR
D, K, Masters -NCDHNR
Very truly yours,
tt= cr-,vvvi..-1--e', L-~
H, E, Graulich
Div Vice President
Safety and Environmental Affairs
,• • Rational Starch and Chemical Company _c,_ ____________ -',,~
10 Finderne Avenue
P.O. Box 6500
Bridgewater, New Jersey 08807-0500
908-685-5000
Cable Address: NASPROD,BAIDGEWATEANEWJERSEY
Writer's Direct Dial Number:
Fax Number:
908-685-5198
908-707-3706
Mr. Jon Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: Salisbury, NC NPL Site
Dear Mr. Bornholm:
• RECE;VED
APR 141994
SUPERFUND SECTION
April 8, 1994
This letter supplements recent correspondence to you from IT
Corporation on our behalf regarding 004 and addresses the adequacy
of institutional controls.to support a no action alternative for
004. This issue was addressed in our letter to you dated September
13, 1993, a copy of which is attached for your reference.
As noted on page 2 of our September 13, 1993 letter, NSC is
willing to accept a provision in a Consent Decree for 004 which
obliges us to record, in the appropriate county registrar's office,
a deed restriction in which we, and any subsequent owner of the
site, would be prohibited from utilizing the groundwater for
drinking water purposes until such time as the plume meets drinking
water standards. The Consent Decree could further require that in
the event we or any subsequent owners of the property violated such
deed restriction, NSC would be deemed to be in violation of the
Consent Decree and would thereby be obliged to pay stipulated
penalties to the State of North Carolina, or to the U.S. Treasury.
Thus, NSC would have a cont_inuing and enforceable obligation to
ensure the integrity of sucn institutional controls. Moreover, we
would accept provisions in the Consent Decree which would (1) vest
in the State of North Carolina Department of Environmental
Management ("DEM") continuing jurisdiction of such restriction, and
(2) enable DEM· to utilize the Consent Decree in any subsequent
enforcement proceedings against NSC involving any alleged
violations of such restriction.
• •
While we believe that the foregoing approach more than
adequately addresses the concerns raised by DEM about the
appropriateness of institutional controls for OU4, we remain
receptive to any additional approaches that might be suggested by
EPA or DEM.
If you have any questions, please call me.
Very truly yours,
#J;tplip~·
Alexander M. Samson, Jr.
Counsel, Regulatory Affairs
cc: H. Graulich
R. Paradowski
M. Sturdevant -IT Corporation
B. Nicholson -NC DEM l
AMS:
33178.1
. .. •
908-685-5198
908-707-3706
Mr. John Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
Re: Salisbury, NC NPL Site
Dear Mr. Bornholm:
•
September 13, 1993
We submit herewith our comments, along with those prepared by
IT Corporation ("IT") on our behalf, on EPA's Proposed Plan Fact
Sheet dated July, 1993 regarding the above site. EPA has extended
until September 16, 1993 the time within which such comments may be
submitted for inclusion in the administrative Record of Decision
("ROD"). We believe that our comments, if adopted by EPA, would
result in a ROD that is entirely consistent with the requirements
of the National Contingency Plan ( "NCP") for CERCLA remedial
actions.
1. Establishment of Fourth Operable Unit. For the reasons
expressed in the enclosed comments of IT, we do not believe that it
is necessary to establish a Fourth Operable Unit. NSC has agreed
to perform the DNAPL test suggested by EPA and the State. We are
prepared to perform this test immediately following EPA's approval
so that the results will be available prior to issuance of the ROD.
Thus, if the tests do not show the presence of DNAPLs, we do not
think a Fourth Operable Unit to address soils should be required.
At a minimum, we think it is premature to establish a Fourth
Operable Unit unless and until such time as continued groundwater
monitoring results indicate that concentrations of contaminants do
not significantly decrease. We suggest that the ROD be written so
as to require a Fourth Operable Unit at a later date, only if
necessary, following the analyses of sufficient groundwater
•
monitoring results that would allow a determination of the
effectiveness of a no action soil alternative.
2. Establishment of a compliance point with enforceable
institutional controls. EPA should establish a point of compliance
for remediation of the contaminated plume that is, at a minimum, at
the plume periphery rather than throughout the plume. That the NCP
permits a remedy to incorporate a point of compliance that is a
distance away from the source of groundwater contamination is not
disputed by EPA. This issue was raised recently in a lawsuit
brought by various states against EPA challenging EPA's use of the
NCP in CERCLA. Ohio v. EPA, 39 ERC 2065, US Ct App, DC (1993).
There, the Plaintiff states argued that in the preamble to the NCP
EPA acknowledges that, while "remediation levels should generally
be attained throughout the contaminated plume, or at and beyond the
edge of the waste management area ... an alternative point of
compliance may also be protective of public health and the
environment under site-specific circumstances." (underlines added)
40 C.F.R. 300.430(f) (5) (iii) (A). EPA did not challenge the
states' interpretation of the NCP in this regard. Rather, EPA's
response was that"··· alternatives must in any case be protective
of public health and the environment." Ohio v. EPA, supra at p.
2080. It is thus clear from the language of the NCP, and from
EPA' s interpretation of the NCP in the Ohio case, that it is
permissible to set a point of compliance at the property boundary,
the plume periphery, or any other alternate point so long as it is
protective of public health and the environment.
The NCP threshold criteria of overall protection of public
health and the environment is met at this site by setting such
alternative point of compliance at the plume periphery, especially
when combined with institutional controls. NSC is certainly
agreeable to having a deed restriction recorded against the site
indicating that the plume of contaminated groundwater is not
suitable for drinking and prohibiting such use in perpetuity. Such
deed restriction would run with the land and would thus legally
prevent drinking water wells from being established in or near the
plume. Moreover, NSC is will"ing to support the adoption by the
City of Salisbury of an ordinance that would also prohibit such use
of the groundwater unless it is demonstrated to meet drinking water
standards. Such undertakings on the part of NSC could be
incorporated into an enforceable Consent Decree in which NSC would
agree to notify EPA and the State of North Carolina in the event it
ever sold the site to a third party. Stipulated penalties could
also be incorporated into the Consent Decree to ensure the
enforceability of such institutional controls.
It is doubtful that a site cleanup level of 5 ppb ( and
certainly of 1 ppb) for 1,2-dichloroethane ("DCA") throughout the
entire plume could ever be met. Establishing an alternate point of
compliance of the plume periphery, along with the institutional
controls mentioned above, or other institutional controls which NSC
would be willing to consider, meets the threshold NCP requirement
of overall protection of the environment and is consistent with
•
EPA's interpretation of the NCP as articulated most recently in
Ohio v. EPA, supra.
3. Establishment of a site cleanup level for DCA. As
discussed in the enclosed comments of IT, the site cleanup level
for DCA should be set at 5 ppb (at the point of compliance, as
discussed above) which is the federal primary drinking water
standard. Such level satisfies the NCP criteria of overall
protection of public health and the environment. The State of
North Carolina drinking water standard of .38 ppb, while relevant,
is not appropriate based on problems with the accuracy of detecting
concentrations of DCA at that level and it is not applicable to the
contaminated groundwater plume here since such groundwater is not
the source of drinking water supplies.
EPA has proposed a level of 1 ppb for Operable Unit Three in
recognition of the problem of accurately detecting DCA at levels
of .38 ppb. However, EPA has previously determined that the
practical quantitative limit ("PQL") (defined as the lowest level
that can be reliably achieved within specified limits of precision
and accuracy) is 5 ppb for all volatile organic compounds except
vinyl chloride. Federal Register, Vol. 52, No. 130, July 6, 1987.
We do not believe there is any basis for establishing a level of 1
ppb for DCA as an ARAR at this site. To the extent that any level
other than the federal drinking water standard is deemed by EPA to
be an ARAR, we believe such ARAR should be waived and we
accordingly request such a waiver. We do not believe that a level
of 1 ppb of DCA can be demonstrated by EPA to be applicable to the
conditions at this site, nor is it technically achievable since it
is below the PQL as determined by EPA.
4. Selection of the most cost effective remedial alternative.
For the reasons discussed by IT, we believe that vapor-phase carbon
adsorption should be selected by EPA as the preferred remedial
alternative based on cost-effectiveness.
If you have any questions about any of our comments, please
let us know.
cc: H. Graulich
R. Paradowski
M. Sturdevant -IT Corporation
B. Nicholson -NCDEHNR
Very truly yours,
Alexander M. Samson, Jr.
Counsel, Regulatory Affairs
28472.1
.;
TEI 'FCOPY Nt7?dBER:
TO:
FROM:
DATE:
NUMBS. O:F PAGES:
•
72i1FCOl'Y BQCJEST
,J
IT c:cm.P□RAnON
312 DIRECTORS DRIVE .
XNOXVILI.E.. 'm 3m:
(615) 690-321 l
-1----------'IJM!::__.A ..... V .... /V_..L ___ _
...... _..,.._ _____ (INCLUDINGCO~SAAA1)
REMARKS: ----+----------------
D CARD WHEN S!NI' __ _
,Z
IF All PAGa ARE NOT ~EMm, PLEASE. ASK FOR :EXTENSION 2223 AT THE ABOVE NUMBER.
[phone] OR
[phone]
[D INTERNATIONAL
TECeaoLOGY
CORfflRATION
TELECOPY NUMBER:
TO:
FROM:
DATE:
NUMBER OF PAGES:
(INCLUDING COVER SHEET)
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=~4()4..347-1695 -

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APR 61994
__ -Jon-Bo-rnh<Jlm,RP.M'""------J
EPA Region IV
Mike Sturdevant
IT Corporatio11
312 Directors Drive
Knoxville, Tennessee
[phone]
April 6, 1994
6
REMARKS: Attached as req ested, is the cost estimate from Vector
Enterprises, Inc. for the re ediation of OU4. Their estimate is for a
combined soil vapor extract on/bioremediation system that includes the
installatlon of horizontal we s.
f;H ro' .--~., cc: Bruce Nicholson, NCDE [phone]
IF ALL PAGES ARE NOT REC IVED, PLEASE ASK FOR EXTENSION 2223 AT [phone].
IT Knoxville Fax No. [phone] or [phone]
(Please return when sent)
575 OLO ORCROSS ROAo • l.AWSENCEVILlE. GA 30245
PH ) 91l5-0130 • FAX (4-04) 962·2169
January 27, 1994
Ray Paradowski
National Starch Company, Inc.
P.O. Box 399
485 Cedar Springs Road
Salisbury. North Carolina 28145-03 9
Dear Mr. Paradowski:
Veotor i::r,lerprises, inc. (Vccru ) 1s p1easea to submit tnis proposal tor providing your remediation services to remove the rganic contamination from beneath the building slab of your Salisbury, North Carolina plant. In ur discussions of December 22, 1993, you requested cost estimates for these services. You r uested that we provide the costs on an order of magnttude basis rather than doing the final data I design necessary to arrive at exact figures, so that you could determine the initial viability of our proach before getting down to more detailed involvement on both our parts. These prices and I e general design are presented in that context. Should you wish to pursue this option your auth rization of the attached letter of intent would trigger the final • site research and final engineering essary to arrive at an exact cost.
Vecto~s review of your data base ind !es that an area of approximately 500' X 600' is contaminated wtth 1 ·2 DCA at level above the regulatory limits. The areas which contain acetone concentrations in excess of regulato limits generally fall within the same areas affected by the 1 • 2 DCA contamination. Profiles dev loped in the assessment report show contamination at depths averaging 17.5 feet.
This would indicate that the volume f contaminated soil to be treated for DCA/acetone contamination would be approximat91Y 194,400 cy. At a discounted treatment rate of $30/cy for a combined soil vapor extraction/bior ediation system the cost would be $5,832,000.
Vector also developed an altemativ contaminant contour plot based on the concept that the contaminated areas are 'hot spots' r !her than a prevalent condition encompassing the entire area. Based on this concept the vol me of contamination of soils to be treated is approximately 96,000 cy. At that volume Iha cost treat the soils is $2,880,000.
Although Vector's cos! to bioremedi e the contaminated soil is significantly below other alternatives such as offsite disposal, he cost to remediate the s~e remains exorbitant
In light of the fact that the 'high' co entrations of contamination which could adversely offset human health are fairly small and iso led, Vector would suggest that you approach the State with the concept that the slabs which you ve installed In recent years are acting as an impermeable cap, therefore downward migration o contamination has been minimized.
Present groundwater contamination likely occurred prior to installation of the slabs.
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In the event that you are unsucc I with this approach Vector has prepared a technical approach for a combined soil ventln ioremedietion approach to treat the contaminated soil. This approach and the associated u it costs are inclUded below.
We have also developed costs for p eparing the Corrective Action Plan (CAP) and submitting it to the State for approval.
810-REMEDIA TION
Due to the location of the conta inated soil plume beneath the slab of the process areas, VECTOR suggests the use of insilu bio-remediation in lieu of exsitu bio-remediation of the soils. Exsitu bio-remediation would requir removal of large areas of the slab and would impact the plant operations. The resultant impact o your manufacturing process should be considered as a real cost in il'T'4)1emanling an exsilu soluti_ n.
The lnsitu approach will require the ·nstallaiion of 12' X 12' injection points on approximately 7'• 1 O' centers throughou1 the area f the contaminant plume. These injection paints will be connected via a manifold system hich will allow for the injection of air.as wall as nutrients necessary to the process utilized in he bio-remediation activtties. The manifold system would be installed via VECTOR's horizomaJ ring equipment in order lo minimize the disturbance to the slab in the process areas.
Wells will ba installed within the inj lion points. These wells will be interconnected to a series of piping manifolds to allow for the inj ion of the necessary air and nutrients to lower depths within the soil. Each of the injection wells ·11 b·e extended to a height which is flush with the top of the concrete slab and capped with a steel manhole cover which can be removed to perform maintenance on the well itself. 0 e the well network is installed the concrete floors will be returned to the original grade wtth g vel and topped wfth concrete.
Valve boxes will be installed at app priate points wtthin the network in order to allow for isolation of the individual branches of the sy em. These valve boxes will be installed flush with the top of the slab and will be constructed in s ha manner to allow for forklift traffic. The entire network of the bio-remedi11tion system will be xtended to a treatment pad kx;ated et a predesignated site nearby. The necessary equipment, i e. compressors, pumps, blowers etc. will be installed on the pad. .
The air for the treatment system wi I ba supplied by a rotary blower. The nutrient feed will be supplied via a centrifugal pump. 0 e the system Is installed VECTOR will initiate the areation process. Nutrients and enzymatic gents will be pumped into the subsurface via the pumping system. VECTOR will monitor the levels of contamination on .a bi-weekly basis via 1/2 inch diameter sample ports extended thro gh the slab and into the subsurface soils. The soil samples will be analyzed for volatile hydroca ns. On a weekly basis additional nutrient and eniymes will be injected into the system as requir .
At such limes as the levels of cont mination in the subsurface soils have reached acceptable regulatory limits VECTOA will termi ate the bio-remediatlon process. It is possible that certain. areas of the Contaminant plume will each acceptable levels of cleanup sooner than other areas. Al such time that these areas have n cleaned up, the network which supplies these areas will
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be shut ott via the valves located ·n the junction boxes. Other areas of contamination will be treated until acceptable limits have een achieved.
To supplement the bio-remediatio
system in conjunction with the bi
beneath the slab at the National St
Is a long tenn remedial action whic will ever achieve regulatory stands
remedial ion process in that ii does
of nutrients and other agents nece
The venting process will accelerate
process VECTOR suggests the utilization of a soil venting remediation process to remove the organics from the soils h, Salisbury, N.C. plant. It should be noted that soil venting offers limited assurances that the final organic concentrations s. However, the soil venting is less expensive than the bio-ot require weekly monitoring nor does it require the addition ry to the healthy operation of the bio-remedialion system. e removal of the higher concentrations of organics.
The soil venting system will be op rated prior to initiating the bio-remediation process. The soil venting system will utilize the sarn well ins!allation and piping network necessary for the bio-remediation system. The positiv · dlsplacetll8nt blower system Is designed to pull air stream through the soil which will remove t e organics from the soil. The contaminated gas stream will be discharged into the same dual cani er activated carbon system in order to remove the organics from the air stream prior to discha e in the atmosphere. Once the organic concentrations have reached the 'plateau effect' generic to this type system, VECTOR will reverse the blower to inject into. the soil end initiate the bio-rem iation process.
SCHEDULE
VECTOR can Initiate the work on t e bio-remediation system within fourteen (14) days of your authorization to proceed. The inst llation of Iha system can be completed w~hin six (6) weeks. The stert-up of the system will be roximately 2-4 weeks alter installation i$ complete.
COSTS
VECTOR proposes to develop the orrective Action Plan for a Lump Sum Cost of $9,500.00.
We are finalizing the costs for the a ve scope of work for the remediation process. VECTOR proposes to install the SUB-FOUN!TION soil venting/blo-remediatlon system for a Un~ Cost of approximately $30/cy ol oonteminet soil. A rrooilization fee of twenty percent (20%) of the total contract amount will be required p · r to initiating the project. Fifty percent (50%) of the amount will be paid at the time installation of the system is complete. The remaining 30% will be split into three equal payments to be paid in hree consecutive monthly payments following the date that Installation is complete.
We recognize that It is likely that you will Initiate a groundwater treatment system for the Salisbury. N.C. plant. We would appreciate t e opportunity to review your documentation and submit a · proposal lor that project, provided t you have not already contracted with another company.
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To authorize VECTOR to initiate t soH remediation project please sign one copy of the attached
letter of intent and return to the abo e addresa. ·
ff you have any questions or require ddltlonal information. please call me at [phone].
Sincerely, f ~~• ~...---~ I
Eric H. Gamer
N
0 100 200
1,2 -DCA
CONCENTRATION
GRADIENT
GENERA.t.lZEO CONT AMINA.NT PLUME (ABOVE 500 PPB) BASED ON IT REPORT
PROJECTED •HOT SPOTS'"
(ABOVE 500 PPB)
NATIONAL ST ARCH ANO
CHEMICAL COMPANY
SALISBURY, NC
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