NCD991278953_19980721_National Starch & Chemical Corp._FRBCERCLA RA_Natural Degredation Treatability Study Progress Reports January - July 1998-OCR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
July 21, 1998
4WD-NSMB
Mr. David Mattison
North Carolina Department of Environment &
Natural Resources/Superfund Section
Suite 150
401 Oberlin Road
Raleigh, NC 27605
RECEl\ti::r)
JUL 2 7 1998
SUPE.RFUND SE.C110N
SUBJ: Request to Review NSCC's Response to Comments on the Phase I
Natural Degradation Treatability Study Report for Operable Unit #4 for the
National Starch & Chemical Company Superfund Site
Dear Mr. Mattison:
Enclosed for your information and the State's file are two copies of the above
referenced document, dated July 16, 1998. Please review this document.
I would appreciate receiving the State's comments by Monday, August 17, 1998.
If you are unable to provide your comments by this date, please inform me as to when I
can expect to receive them.
If you have any questions, I can be reached at 404-562-8820.
Sincerely,
Jr1 r( 6~c----
Jon K. Bornholm
Remedial Project Manager
Enclosures
1. 2 Copies of "Response to Comments Phase I of Natural Degradation Treatability
Study Report for Operable Unit #4 for the National Starch & Chemical Company
Superfund Site"
,.
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Mr. Jon K Bornholm
Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 111h Floor
Atlanta, Georgia 30303
NORTH.AROLINA DEPARTM.ENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
May 11, 1998
RE: Phase I 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 Phase I 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 April 2, 1998. The
Hazardous Waste and Superfund Sections of the NC DENR have reviewed the
Phase I Natural Degradation Treatability Study Progress Report for Operable Unit
4 and offer the following attached comments.
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
Sincerely,
'[)J z lif~-(6-;e,iMJ1
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
cc: Mr. Patrick Watters, NC Hazardous Waste Section
401 OBERLIN ROAD, SUITE 1 SO, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
V
Mr. Jon Bornholm
May 11, 1998
Page 1
•
PHASE I NATURAL DEGRADATION TREA TABILlTY STUDY PROGRESS REPORT
FOR OPERABLE UNIT 4
List of Tables
1. The titles given for Table 5-17 and Table 5-18 are Summary of Soil Ammonia Nitrogen
· Concentrations and Summary of Soil Nitrate Nitrogen Concentrations, respectively.
However, the titles for Table 5-17 and Table 5-18 are Summary of Soil Nitrogen
Ammonia Concentrations and Summary of Soil Nitrogen Nitrate Concentrations,
respectively. Please clarify this discrepancy. ·
2: The title for Table 5-23 should be Monthly Summa Canister Sampling Results, Soil Gas
Monitoring Wells 1, 2, 3 and 4. Please correct this oversight.
List of Figures
3. The title given for Figure 3-2 is Location of Soil Plots and Soil Gas Monitoring Wells in
Lagoon Area. However, the title for Figure 3-2 is Location of Replication Plots and Soil
Gas Monitoring Wells in the Lagoon Area. Please correct this oversight.
4. The titles given for Figure 5-15, Figure 5-16 and Figure 5-17 are Soil Concentration of
Ammonia Nitrogen -Plot 1, Soil Concentration of Ammonia Nitrogen -Plot 2 and Soil
Concentration of Ammonia Nitrogen -Plot 3, respectively. However, the titles for Figure
5-15, Figure 5-16 and Figure 5-17 are Soil Concentration ofNitrogen Ammonia-Plot 1,
Soil Concentration of Nitrogen Ammonia -Plot 2 and Soil Concentration of Nitrogen
Ammonia -Plot 3, respectively. Please clarify this discrepancy.
5. The titles given for Figure 5-18, Figure 5-19 and Figure 5-20 are Soil Concentration of
Nitrate Nitrogen -Plot 1, Soil Concentration of Nitrate Nitrogen -Plot 2 and Soil
Concentration of Nitrate Nitrogen -Plot 3, respectively. However, the titles for Figure 5-
15, Figure 5-16 and Figure 5-17 are Soil Concentration ofNitrogen Nitrate -Plot 1, Soil
Concentration of Nitrogen Nitrate -Plot 2 and Soil Concentration of Nitrogen Nitrate -
Plot 3, respectively. Please clarify this discrepancy.
NSCC RESPONSES TO USEPA AND NCDENR COMMENTS
USEPA General Comments
6. The title to this section should state "NSCC Responses to USEPA and NCDENR
Comments." Please correct this oversight.
Mr. Jon Bornholm
May 11, 1998
Page 2
Response No. l
• •
7. The second sentence in response to USEPA General Comment No. 1 should state" ...
(refer to Figures 5.33 through 5.56)."
Response No. 5
8. Response No. 5 states that Figure 3-1 was revised to indicate the location of soil sample
BT-7. However, Figure 3-1 indicates the location of soil sample BT-6. Please clarify this
discrepancy.
Response No. 9
9. Response No. 9 states that Table 5-14 (page 1 of 5) has been.revised to indicate that soil
sample SP3-34-68 was sampled on November 13, 1996. However, Table 5-14 (page 1 of
5) was not revised. Please correct this oversight.
Response No. 10
10. Response No. 10 states that Table 5-14 (page 1 of 5)has been revised to define the symbol
"--." However, Table 5-14 (page 1 of 5) was not revised. Please correct this oversight.
Response No. 12
11. Response No. 12 referred to the letter submitted by Pace Analytical Services, Inc. on
December 18, 1997. This letter included two attached chromatographs which were
inadvertently omitted. Please correct this oversight.
Response No. 29
12. Response No. 29 should state "See page 39." Please correct this oversight.
Mr. Jon Bornholm
May 11, 1998
Page 3
•
Section 2.5 LBS Results
•
I 3. The second item in this section states that "Indigenous soil microorganisms are able to
degrade I, 2-DCA under both aerobic and anaerobic conditions with the addition of
nitrate to the soil." This statement is in sharp contrast to the conclusions presented in the
Phase II BIOreport included in Appendix A. The Phase II BIO report concludes that " ...
the evidence weighs heavily for an aerobic form ofbiodegradation ... " The anaerobic
results obtained in the laboratory biodegradation study (LBS) indicated the lack of
anaerobic biodegradation or, at a minimum, provided highly inconclusive results. Please
clarify this discrepancy.
Section 3.0 Soil Plots and Soil Gas Monitoring Wells
14. The last paragraph of this section provides only a portion of the information regarding the
water infiltration dilemma as presented in the last paragraph of Section 3 .0 in the previous
submittal of the Natural Degradation Treatability Study, Revised Progress Report for
Operable Unit 4. Please clarify this discrepancy. Furthermore, please provide additional
detail regarding the approximate amounts of water removed from the soil plots, the time
frame for removal in regards to the rain event, the method of removal, and the current
status of the soil plots regarding rainfall infiltration.
Section 4.0 Treatment and Monitoring Activities
15. The fourth paragraph of this section details the addition of water and ammonium
phosphate to Soil Plot 3. Furthermore, this paragraph states that the water and
ammonium phosphate amendments were increased during the last three months. Please
provide the technical justification for this change to the work plan.
Section 4.1. Precipitation and Groundwater Elevation Monitoring
16. This section details the collection of precipitation data at the NSCC site. However, it is
unclear as to the purpose of this activity as the soil plots are covered and are intended to
be sealed from rainfall events. Please clarify the intent of this activity.
Section 4.4 Soil Gas Monitoring
17. The fourth sentence of the third paragraph of this section should state" ... was allowed to
enter the canister at a predetermined flow rate." Please correct this oversight.
Mr. Jon Bornholm
May 11, 1998
Page 4
•
Section 5.2 Groundwater Quality Data
•
18. The third sentence of the third paragraph of this section states that methylene chloride was
detected at monitoring well NS-40 at a concentration of 180 micrograms per liter (µg/1).
However, the last sentence of this paragraph states that methylene chloride was detected
at monitoring well NS-40 at a concentration of 460 µg/1. Please clarify this discrepancy.
19. The third sentence of the fourth paragraph of this-section states that the detection of
acetone in monitoring well NS-40 at a concentration of2,400 µg/1 was a laboratory
artifact. The NC DENR questions the validity of this statement. Laboratory quality
assurance/quality control procedures should have been implemented to prevent the
detection of laboratory artifacts at this high of a concentration.
Section 5.3.2 Bacterial Enumeration and Identification Data
20. The third paragraph of this section details the inability of the laboratory to properly
incubate anaerobic bacteria. However, this section should be revised to include a
statement that, at a minimum, the laboratory is able ( or should be able) to properly count
the amount of anaerobic bacteria present in a given soil sample at the onset of the
biodegradation study.
Section 5.3.3 · Volatile Organic Compounds -Mass Estimates of 1, 2-Dichloroethane (1,2-
DCA) in Soil
21. The first sentence in the fourth paragraph of this section is repeated twice. Please correct
this oversight.
22. The fourth and fifth paragraphs of this section provide estimates of the 1,2-DCA losses
incurred at each of the soil plots. However, the fourth paragraph indicates that the
increase in 1,2-DCA concentrations is due,to the spatial variability of the contaminants.
Please provide some indication of the relative amount of error that may be attributed to
the spatial variability of the contaminants. This discussion should also address the relative
amount of error due to spatial variability regarding the large percentages of contaminant
degradation noted in this section.
Section 5.3.4 Inorganic Compounds
23. Pages 5-7 through 5-10 have been included twice. Please correct this oversight.
Mr. Jon Bornholm
May 11, 1998
Page 5
Section 6.2.1 Mass Estimates of 1,2-DCA in Soil
•
24. The second and third paragraphs of this section provide estimates of the 1,2-DCA losses
incurred at each of the soil plots. However, the third paragraph indicates that the increase
in 1,2-DCA concentrations is due to the spatial variability of the contaminants. Please
provide some indication of the relative amount of error that may be attributed to the
spatial variability of the contaminants. This discussion should also address the relative
amount of error due to spatial variability regarding the large percentages of contaminant
degradation noted in this section.
Section 7.0 Summary and Conclusions
25. The second item in the section entitled, Results of the laboratory biotreatability study
indicate, states that "Indigenous soil microorganisms are able to degrade I, 2-DCA under
both aerobic and anaerobic conditions with the addition of nitrate to the soil." This
statement is in sharp contrast to the conclusions presented in the Phase II BIOreport
included in Appendix A. The Phase II BIOreport concludes that " ... the evidence weighs
heavily for an aerobic form ofbiodegradation ... " The anaerobic results obtained in the
laboratory biodegradation study (LBS) indicated the lack of anaerobic biodegradation or,
at a minimum, provided highly inconclusive results. Please clarify this discrepancy.
Section 8.0 Recommendations
26. . The fifth item in this section indicates that NSCC is proposing to reduce the list of
analytical parameters in estimating the biodegradation rates. However, there is no
mention of the analysis of the oxygenated, water soluble compounds that are the products
of aerobic degradative pathway. Please clarify why these parameters are not included
considering that the laboratory biodegradation study indicated that the soils preferred the
aerobic degradative pathway. Furthermore, the field biodegradation study indicated that,
at a minimum, the aerobic degradative pathway was used in conjunction with the
anaerobic pathway. Please provide additional information to indicate how the statistical
analysis/regression analysis will be employed to determine ·the complete biodegradation
rates.
Mr. Jon Bornholm
May 11, 1998
Page 6
•
TABLES
Table 4-3 Summary of Soil Sampling Locations and Sample T.D.
27. Table 4-3 (page I of 4) indicates that two soil samples were collected from soil sampling
location 12, Soil Plot I, on September 11, 1997. However, Figure 4-5 indicates that the
two soil samples should have been collected from soil sampling location 22. Please clarify
this discrepancy.
28. Table 4-3 (page 3 of 4) does not indicate the collection of the soil sample SP3-34-6 on
November 13, 1996. However, laboratory documentation and Table 5-8 indicate that this
sample was indeed collected. Please clarify this discrepancy.
29. Table 4-3 (page 4 of 4) indicates the collection of soil sample PLOT4, 4-6. However,
there is no indication as to the location where this soil sample was collected. Please clarify
this discrepancy.
Table 5-4 Summary of Soil Aerobic Bacteria Counts
30. Please amend Table 5-4 to include the sample identification as originally submitted to the
laboratory.
31. Please define the symbol "--" as included in Table 5-4.
Table 5-5 Summary of Soil Anaerobic Bacteria Counts
32. Please amend Table 5-5 to include the sample identification as originally submitted to the
laboratory.
33. Please define the symbol"--" as included in Table 5-5.
Table 5-6 Plot 1: Soil Concentration of Volatile Organic Compounds
34. Table 5-6 indicates that two soil samples were collected from soil sampling location 12,
soil plot I, on September 11, 1997. However, Figure 4-5 indicates that the two soil
samples should have been collected from soil sampling location 22. Please clarify this·
discrepancy.
Mr. Jon Bornholm
May 11, 1998
Page 7
• •
35. The following discrepancies were noted in Table 5-6. Please clarify these discrepancies.
.Sample I.D. Parameter Value Reported in March Valu_c reported in January Value Reported in
1998 Report 1998 Report Laboratory
Documentation
SPl-19, 4-6 Acetone 3200 B 3200 J 3200U
2-Butanone 6400 8 6400 B 6400 U
SPl-19, 6-8 Acetone 1700 8 1700 B 1700U
2-Butanone 4900 8 4800 4900 U
SPl-22,4-6 Chloromcthane 7200U 3500 J8 7200U
Brom om ethane 7200U 2200!8 7200U
Acetone 7200 U 5200!8 7200U
1,2-Dichlorethane 66000 65000 66000
2-Butanone 7200U 4800 J 7200 U
SPl-22, 6-8 Acetone 8200 U 8200 U 8200 UJ
2-Butanone 8200 U 6500 J8 8200 U
SPl-34, 4-6 Acetone 2100U 2100 B 2100 U
2-Butanonc 5600 U 5600 5600 U
SPl-34, 6-8 Acetone 3100 U 1300 J8 3100 UJ
2-Butanone 5600 U 5600 5600 U
SPl-19-5 Acetone 1800U 1800 JB 1800 UJB
SPl-19-7.5 Chloromcthane-3600 U 3600 U 1800 U
Bromomcthane 3600 UJ 3600 U 1800 U
Vinyl Chloride 3600 U 3600 U l800U
Mdhylcne Chloride 3600 U 3600 U 1800 U
Acetone 3600 UJ 2200 DJB 1800U
2-Butanone 3600 U 3600 U 1800 U
1, l, 2-Trichloroethane 3600 U 3600 U 1800 U
Bromofonn 3600 U 3600 U 1800 U
4-Mcthyl-2-Pcntanonc 3600 U 3600 U 1800 U
2-llexanone 3600 U 3600 U 1800 U
I, I, 2, 2-3600 U 3600 U 1800 U
T ctrach \oroethane
Toluene 3600 U 3600 U 1800 U
Mr. Jon Bornholm
May 11, 1998
Page 8
SPl-29-5
SPl-29-7.5
SPl-7-5.5
SPl-7-7
SPl-18-3
SPl-18-7.5
SPl-20-5
SPl-20-7
•
Acetone
Acetone
Acetone
Acetone
Acetone
4-Methyl -2-pentanone
Chloromethane
Vinyl Chloride
Methylene Chloride
Acetone
2-Dutanone
l, I, 2-Trichloroethane
Ilromoform
4-M ethyl-2-pc ntanone
2-Hexanone
I. I, 2, 2-
Tetrachloroethanc
Toluene
Acetone
4-Mcthy 1-~ -Pentanonc
Chloromethane
Bromomcthane
Vinyl Chloride
· Meth)/lene Chloride
Acetone
1,2-Dichloroethane
2-Butanone
I, 1, 2-Trichloroethane
Bromofonn
4-Methy 1-2-Pcn tanone
2-Hexanone
I, I, 2, 2-
Tetrachloroethane
•
1800 U 1800 B 1800 U
1700 U 1700 B 1700 U
1900 U 1900 B l900U
1600 U 1400 JB 1400UJB
16000 J 16000 16000 J
1700 UJ l700U 1700 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1500 UJ 1500 U 1500 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1700 J 1700 17001
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
May 11, 1998
Page 9
SPl-20-7
SPl-6-l.l
SPl-6-7
SPl-12-24
SPl-4-68
·SPl-16-68
SPl-4-46
SPl-4-68
Table 5-7
•
Toluene 1600 UJ 1600 U 1600 UJ
Acetone 1900 UJ 1900 U 1900 UJ
1,2-Dichloroethane 8700 J 8700 8700 J
4-M cthy 1-2-Pentanonc 1900U 1900U 1900 UJ
Acetone 1600 UJ 1600U 1600 UJ
1,2-Dichloroethane 1800 DJ 1200 J 1800 DJ
4-Mcthyl-2-Pentanonc 1600 UJ l600U 1600 UJ
Carbon Disulfide 1700U 1700 UJ
I, 2-Dichloroethane 2600 2600 J
Acetone 1600 UJ 1100 J
Acetone 2300 JD l40 E
Acetone 1900 UJ ll00 J
Plot 2: Soil Concentration of Volatile Organic Compounds
36. The following discrepancies were noted in Table 5-7. Please clarify these discrepan~ies.
Sample I.D. Parameter Value Reported in March Value reported in January Value Reported in
1998 Report 1998 Report Laboratory
Documentation
SP2-19-4 1,2-Dichlorocthanc 220000 D 220000 220000 D
2-Butanone 1700U 1700 U 4800 U
Toluene 1700U 52000 1700 U
SP2-19-6 · Chloromethane 1600 U 16000 U 1600 U
Bromomethanc 1600 U 16000 U 1600 U
Methylene Chloride 1600 U 16000 U 1600 U
Acetone 2900 UJ 16000 U 2900 UJ
I, 2-Dichloroethanc 150000 D ll0000 150000 D
2-Butanone 4400 U 16000 U 4400 U
4-Mcthyl-2-Pcntanone 1600U 16000 U 1600U
2-Hcxanonc 1600 U 16000 U 1600 U
1, 1, 2, 2-1600 U 16000 U 1600 U Telrachloroethane
Mr. Jon Bornholm
May 11, 1998
Page 10
SP2-19-6
SP2-22-2
SP2-22-6
SP3-34-2
•
Toluene
Chloromethane
Bromomcthane
Methylene Chloride
Acetone
I, 2-Dichloroethane
2-Butanone
4-Mcthyl-2-Pentanone
2-llexanone
I, I, 2, 2-
Tctrachloroethane
Toluene
Chloromcthane
Bromomethane
Methylene Chloride
Acetone
I, 2-Dichlorocthane
2-Butanone
4-Mcthyl-2-Pcntanone
2-Hcxanone
1, I, 2, 2-
T ctrachloroethane
Toluene
Chloromcthane
Bromomethane
Methylene Chloride
Acetone
I, 2-Dichloroethane
2-Butanone
4-Mcthyl-2-Penlanone
2-1 lcxanone
1, I, 2, 2-
Tctrachloroethane
•
1600 U 16000 U 1600 U
1700 U 34000 U 1700 U
l700U 34000 U l700U
l700U 34000 U 1700 U
2300 UJ 34000 U 2300 UJ
540000 D 540000 540000 D
4900 U 34000 U 4900U
1700U 34000 U 1700 U
1700 U 34000 U 1700 U
1700 U 34000 U 1700U
1700 U 34000 U 1700U
l700U 6700 U l700U
l700U 6700 U l700U
1700 U 6700 U _l700U
2400 UJ 6700 U 2400 UJ
79000 D 79000 79000 D
3900 U 5800 J 5900 U
970 J 6700 U 970 J
IO00J 6700 U IO00J
1700U 6700 U 1700U
1700 U 6700 U 1700 U
6400 UJ 64000 U 6400 U
6400 U 64000U 6400U
6400U 64000U 6400 U
6400U 64000 U 6400 UJ
690000 D 69000 690000 D
6400U 64000 U 6400U
2300 J 64000U 2300 J
2300 J 64000 U 2300 J
6400 U 64000 U 6400 U
Mr. Jon Bornholm
May 11, 1998
Page 11
SP3-34-2
SP2-34-6
SP2-7-3.5
SP2-7-7.S
SP2-19-3
SP2-19-7
SP2-29-5
SP2-29-7.5
SP2-18-5
SP2-20-5
SP2-6-3
SP2-6-7
Toluene·
Chloromethane
Acetone
1,2-Dichlorethane
2-Butanone
Methylene Chloride
Acetone
Acetone
Acetone
Acetone
1,2-Dichloroethane
Methylene Chloride
Acetone
Methylene Chloride
Acetone
Acetone
1,2-Dichloroethane
4-Methyl-2-Pentanone
Acetone
1,2-Dichloro.ethane
4-Methyl-2-Pentanone
Acetone
1,2-Dichlorocthanc
4-Mcthyl-2-Pcntanone
Chloromethane
Bromomethane
Methylene Chloride
Acetone
I, 2-Dichloroethane
2-Butanone
4-Methyl-2-Pcn tan one
2-Hexanone
6400U
15000 UJ
1700 UJ
180000 D
15000 U
1800 U
4200 U
2300 U
2500 U
2000U
52000 D
1900 U
2900 U
1700 U
3000 U
1600 UJ
65000 DJ
1600 UJ
1500 UJ
120000 DJ
1500 UJ
1700 UJ
150000 DJ
1700 UJ
1600 UJ
1600 UJ
1600 UJ
1600 UJ
5100 J
1600 UJ
1600 UJ
1600 UJ
•
160000 J 6400U
15000 U 15000 UJ
15000 U 17000 UJ
180000 180000
76000 JD 15000 U
360 J 360 J
4200 B 4200 U
2300 B 2300 U
2500 B 2500 U
20008 2000 U
50000 B 50000 D
320 J 320J
2900 B 2900 U
270 J 270 J
3000 B 3000 U
1600 U 1600 UJ
65000 D 65000 DJ
1600 U 1600 UJ
2700 B 1500 UJ
120000 D 120000 DJ
1500 U 1500 UJ
1700 U 1700 UJ
I 50000 D 150000 DJ
1700 U 1700 UJ
1600 U 1600 UJ
1600 U 1600 UJ
1600 U 1600 UJ
1600 U 1600 UJ
5100 5100 J
1600 U 1600 UJ
1600U 1600 UJ
1600 U 1600 UJ
Mr. Jon Bornholm
May 11, 1998
Page 12
· SP2-6-7
SP2-4-68
SP2-16-24
SP2-16-68
SP2-26-46
SP2-26-68
SP2-4-68
•
I, I, 2, 2-
Tetrachloroethane
Toluene
4-Meth y 1-2-Pentanone
Acetone
I, 2-Dichloroethane
Acetone
I, 2-Dichloroethane
Acetone
Acetone
Acetone
•
1600 UJ 1600U
1600 UJ J600U
I 17 U
20000 UJ
530000
8300 UJ
220000 D
15000 UJ
6800 UJ
8700 UJ
Table 5-8 Plot 3: Soil Concentration of Volatile Organic Compounds
1600 UJ
1600 UJ
17
13000 J
· 530000 E
6200 J
2!0000 E
I 1000 J
2700)
5000!
37. The following discrepancies were noted in Table 5-8. Please clarify these discrepancies.
Sample I.D. Parameter Value Reported in Value reported in Value Reported. in
March 1998 Report January 1998 Report Laboratory
Documentation
SPJ-19-4 Acetone 27000 U 27000 B 27000 U
SP3-19-6 Chloromethane 15000 U 15000 U 15000 UJ
Methylene Chloride 15000 U 7200 JB 15000 U
Acetone 16000 UJ 2600 DJB 16000 UJ
SP3-22-0 Acetone 8400 U 7900 JB 8400 UJ
2-Butanone 8400 U 5100 J 8400 U
SP3-22·6 Acetone 7100 U 4600 JB 7100 UJ
2-lfotanone 7100 U 4100) 7100 U
SP3-34-2 Chloromcthane 77000 U 77000 U 77000 UJ
Methylene Chloride 77000 U 49000 JB 77000 U
Acetone 77000 UJ 35000 JB 77000 UJ
1,2-Dichloroethane 3400000 D 3400000 3400000 D
SP3-34-4 Acetone 2600 U 2600 B 2600 UJ
2-Dutanone 4200 U 4200 4200 U
Mr. Jon Bornholm
May 11, 1998
Page 13
SP3-34-6
SP3-19-6D
SP3-22-D6
SP3-7-3
SP3-7-7
SP3-19-5.5
SP3-19-7.5
SP3-29-3.5
·SP3-29-5.5
Acetone
I, 2-Dichloroethane
Acetone
2-Butanone
Acetone
l, 2-Dichloroethane
Lab I.D.
Methylene Chloride
Acetone
Lab I.D.
Methylene Chloride
Acetone
Chloromethanc
Methylene Chlo!"ide
Acetone
I, ~-Dichloroethane
Toluene
Chloromcthane
Bromomethane
Methylene Chloride
Acetone
l, 2-Dichlorocthane
Toluene
Chloromethane
Bromomcthane
Acetone
I, 2-Dichlorocthanc
Toluene
Chloromethane
Bromomethane
I, 2-Dichloroethane
4000 U
1500000 D
12000U
6100 U
7700 U
36000 U
31012
1600 U
4200 U
31020
1600 U
3600 U
2300 J
1700 UJ
7100 UJ
550000 DJ
4300 J
1700 UJ
1700 UJ
1800 UJ
5700 UJ
260000 JD
3500J
1500 UJ
1500 UJ
4800 UJ
420000 JD
2700 J
1700 UJ
1700 UJ
140000 JD
•
72000DJ
1200000 D
12000 B
6100 B
7700 B
36000
3102
270 J 270 J
4200 B 4200 U
. 3102
370 J 370 J
3600 B 3600 U
2300 2300
IIOOJ 1100 UJ
7100 B 7100 U
480000 D 480000 DJ
4300 4300
1700 U 1700 l,IJ
1700 U 1700 UJ
1800 B 1800 U
5700 B 5700 U
260000 D 260000 JD
3500 3500
1500 U 1500 U
1500 U 1500 U
4800 ll 4800 U
420000 D 420000 JD
2700 2700
1700 U 1700 U
1700 U 1700 U
140000 D 140000 D
Mr. Jon Bornholm
May 11, 1998
Page 14
SP3-18-5
SP3·18-7.5
SP3·20-5
SPJ-20-6.5
S1'3-6-3.5
SPJ-6-7.5
Acetone
I, 2-Dichloroethanc
4-Me thy 1-2-Pentanone
Acetone
I, 2-Dichloroethane
4-Meth y 1-2-Pentanone
Chloromethane
Vinyl Chloride
Methylene Chloride
Acetone
2-Butanone
I, I, 2-Trichloroethane
Bromoforrn
4-Methyl-2-Pentanonc
2-Hexanone
I, I, 2, 2-
Tetrachlorocthane
Chloromethane
Bromomethane
Methylene Chloride
Acetone
2-Butanone
4 -Meth y 1-2-Pcntanone
2-Hexanone
I, I, 2, 2-
Tetrachloroethane
Toluene
Sample Depth (fl)
Acetone
I, 2-Dichloroethanc.
4-Methy 1-2-Pentanone
Acetone
•
1700 UJ 1700 U 1700 UJ
120000 DJ 120000 D 120000 DJ
1700 UJ 1700 U I 700 UJ
1400 UJ 1400 U 1400 UJ
75001 7500 7500 J
1400 UJ 1400 U 1400 Ul
1700 UJ 1700 U 1700 Ul
1700 UJ 1700 U 1700 UJ
1700 UJ 1700 U 1700 UJ
23000 23000 23000 J
1700 UJ 1700 U 1700 UJ
I 700 UJ 1700 U 1700 UJ
I 700 UJ 1700 U 1700 UJ
I 700 UJ 1700 U 1700 UJ
1700 UJ 1700 U 1700 UJ
1700 UJ 1700 U 1700 UJ
1600 UJ 1600 U 1600 UJ
16000 Ul 1600 U 16000 U
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
1600 UJ 1600 U 1600 UJ
2 to 4 4 to 6
1800 UJ 1800 U 1800 UJ
870000 DJ 870000 D 870000 DJ
1800 UJ 1800 U 1800 UJ
1400 UJ 1400 U 1400 Ul
Mi-. Jon Bomholm
May II, 1998
Page 15
SPJ-6-7.5
SPJ-22-68
SP3-16-24
SP3-26-68
SP3-4-24
SP3-4-46
I, 2-Dichloroethane
4-Methyl-2-Pentanone
Chloromcthane
Acetone
I, 2-Dichlorethane
Acetone
Acetone
I, 2-Dichlorethane
•
1900 J 1900
1400 UJ 1400U
1500 BU
33000 UJ
240000 D
15000 UJ
69000 UJ
1600000 D
Table 5-10 Summary of Soil 1,2-Dichloroethane Concentrations
1900 J
1400 UJ
1500 U
JlOOOJ
1100000 E
7400 J
53000 J
1500000 E
38. Please amend Table 5-10 to include the sample identification as originally submitted to
the laboratory.
Table 5-12 Plot 1: Soil Concentrations of Nutrients, Metals, and Other Parameters
39. Please amend Table 5-12 (pages 4 and 5 of5) to define the qualification "EQ."
Table 5-13 Plot 2: Soil Concentrations of Nutrients, Metals, and Other Parameters
40. Please amend Table 5-13 (page 4 of 5) to define the qualifications "B" and "EQ."
41. Please amend Table 5-13 (page 5 of 5) to define the qualification "EQ."
Table 5-14 Plot 3: Soil Concentrations of Nutrients, Metals, and Other Parameters
42. Please amend Table 5-14 (pages 4 and 5 of5) to define the qualification "EQ."
Table 5-16 Summary of Soil Kjeldahl Nitrogen Concentrations
43. Please amend Table 5-16 to include the sample identification as originally submitted to
the laboratory ..
Mr. Jon Bornholm
May 11, 1998
·Page 16
•
44. Table 5-16 indicates that the soil samples collected from the deep (6 to 8 ft) interval in
Soil Plot 3 on December 11, 1997 contained no detectable concentratioris ofKjeldahl
nitrogen. However, Table 5-14 indicates that the soil sample collected from location Z
contained 410 milligrams per kilogram (mg/kg) Kjeldahl nitrogen; the soil sample
collected from location AM contained 190 mg/kg Kjeldahl nitrogen; and, the soil sample
collected from location E contained 340 mg/kg Kjeldahl nitrogen. Please clarify these .
discrepancies.
45. Table 5-16 indicates that zero concentrations were used in those instances where no
detectable concentrations ofKjeldahl nitrogen were found. Please provide the detection
limits used in the laboratory analysis ofKjeldahl nitrogen as well as an analysis of the data
variability when the detection limits are used for zero concentrations.
Table 5-17 Summary of Soil Nitrogen Ammonia Concentrations
46. Please amend Table 5-17 to include the sample identification as originally submitted to the
laboratory.
47. Table 5-17 indicates that zero concentrations were used in those instances where no
detectable concentrations of ammonia nitrogen were found. Please provide the detection
limits used in the laboratory analysis of ammonia. nitrogen as well as an analysis of the data
variability when the detection limits are used for zero concentrations.
Table 5-18 Summary of Soil Nitrogen Nitrate Concentrations
48. Please amend Table 5-18 to include the sample identification as originally submitted to the
laboratory.
49. Table 5-18 indicates that the soil sample collected from location F, deep (6 to 8 ft)
interval, in Soil Plot I on June 17, 1997 contained 0.9 mg/kg nitrate nitrogen. However,
Table 5-12 indicates that this soil sample contained no detectable concentrations of nitrate
nitrogen. Please clarify this discrepancy.
50. Table 5-18 indicates that zero concentrations were used in those instances where no
detectable concentrations of nitrate nitrogen were found. Please provide the detection
limits used in the laboratory analysis of nitrate nitrogen as well as an analysis of the data
variability when the detection limits are used for zero concentrations.
Mr. Jon Bornholm
May 11, 1998
Page 17
0 •
Table 5-19 Summary of So_il Total Phosphorous Concentrations
51. Please amend Table 5-I 9 to include the sample identification as originally submitted to the
laboratory.
52. Table 5-19 indicates that the soil sample collected from location U, deep (6 to 8 ft)
interval, in Soil Plot I on March 26, 1997 contained 110 mg/kg total phosphorous.
However, Table 5-12 indicates that this soil sample contained 280 mg/kg total
phosphorous. Please clarify this discrepancy.
53. Table 5-19 indicates that the soil sample collected from location Y, deep (6 to 8 ft)
interval, in Soil Plot 2 on June 17, 1997 contained 16 mg/kg total phosphorous.
However, Table 5-13 indicates that this soil sample contained 110 mg/kg total
phosphorous. Please clarify this discrepancy.
54. Table 5-19 indicates that the soil sample collected from location X, shallow ( 4 to 6 ft)
interval, in Soil Plot 3 on September 11, 1997 contained 1.2 mg/kg total phosphorous.
However, Table 5-14 indicates that this soil sample contained no detectable concentrations
of total phosphorous. Please clarify this discrepancy.
55. Table 5-19 indicates that zero concentrations were used· in those instances where no
detectable concentrations of total phosphorous were found. Please provide the detection
limits used in the laboratory analysis of total phosphorous as well as an analysis of the data
variability when the detection limits are used for zero concentrations.
Table 5-20 Summary of Soil Total Alkalinity Concentrations
56. Please amend Table 5-20 to include the sample identification as originally submitted to the
laboratory.
57. Table 5-20 indicates that the soil sample collected from location U, shallow ( 4 to 6 ft)
interval, in Soil Plot 3 on March 26, 1997 contained 160 mg/kg total alkalinity. However,
Table 5-14_indicates that this soil sample contained 1600 mg/kg total alkalinity. Please
clarify this discrepancy.
58. Table 5-20 indicates that zero concentrations were used in those instances where no
detectable concentrations of total alkalinity were found. Please provide the detection
limits used in the laboratory analysis of total alkalinity as well as an analysis of the data
variability when the detection limits are used for zero concentrations.
Mr. Jon Bornholm
May 11, 1998
Page 18
0
Table 5-21 Summary of Soil Chloride Concentrations
•
59. Please amend Table 5-21 to include the sample identification as originally submitted to the
laboratory.
60. Table 5-21 indicates that the soil sample collected from location Z, shallow (4 to 6 ft)
interval, in Soil Plot I on December 11, 1997 contained 320 mg/kg chloride. However,
Table 5-12 indicates that this soil sample contained 90 mg/kg chloride. Please clarify this
discrepancy.
61. Table 5-21 indicates that the soil sample collected from location AM, shallow (4 to 6 ft)
interval, in Soil Plot I on December 11, 1997 contained 430 mg/kg chloride. However,
Table 5-12 indicates that this soil sample contained 320 mg/kg chloride. Please clarify this
discrepancy.
62. Table 5°21 indicates that the soil sample collected from location E, shallow (4 to 6 ft)
interval, in Soil Plot I on December 11, 1997 contained 450 mg/kg chloride. However,
. Table 5-12 indicates that this soil sample contained 180 mg/kg chloride. Please clarify this
discrepancy.
63. Table 5-21 indicates that the soil sample collected from location G, deep (6 to 8 ft)
interval, in Soil Plot I on March 26, 1997 contained 190 mg/kg chloride. However, Table
5-12 indicates that this soil sample contained 130 mg/kg chloride. Please clarify this
discrepancy.
64. Table 5-21 indicates that the soil sample collected from location Z, deep (6 to 8 ft)
interval, in Soil Plot I on December 11, 1997 contained 620 mg/kg chloride. However,
Table 5-12 indicates that this soil sample contained 260 mg/kg chloride. Please clarify this
discrepancy.
65. Table 5-21 indicates that the soil sample collected from location AM, deep (6 to 8 ft)
interval, in Soil Plot I on December 11, 1997 contained 860 mg/kg chloride. However,
Table 5-12 indicates that this soil sample contained 110 mg/kg chloride. Please clarify this
discrepancy.
66. · Table 5-21 indicates that the soil sample collected from location E, deep (6 to 8 ft)
interval, in Soil Plot I on December 11, 1997 contained 570 mg/kg chloride. However,
Table 5-12 indicates that this soil sample contained 3 70 mg/kg chloride. Please clarify this
discrepancy.
(
Mr. Jon Bornholm
Mayll,1998
Page 19
• •
67. Table 5-21 indicates that the soil sample collected from location AM, shallow (4 to 6 ft)
interval, in Soil Plot 2 on December 11, 1997 contained 54 mg/kg chloride. However,
Table 5-13 indicates that this soil sample contained 100 mg/kg chloride. Please clarify this
discrepancy.
68. Table 5-21 indicates that zero concentrations were used in those instances where no
detectable concentrations of chloride were found. Please provide the detection limits used
in the laboratory analysis of chloride as well as an analysis of the data variability when the
detection limits are used for zero concentrations.
Table 5.23 Monthly Summa Canister Sampling Results, Soil Gas 1'fonitoring Wells I, 2,
3 and 4
69. The first entry for Freon 113 and the second entry for Toluene are incorrect duplicates and
should be deleted from Table 5.23, Soil Gas Monitoring Well 1 (6 to 8 ft), page 3 of 16.
Additionally, the second entry for Freon 113 and the first entry for Toluene are incorrect
duplicates and should be deleted from Table 5.23, Soil Gas Monitoring Well 1 (6 to 8 ft),
page 4 of 16. Please correct these oversights.
70. Due to the detection of benzene in soil gas monitoring well 3 (6 to 8 ft) on November 18,
· 1997, benzene should be added to the list of parameters included on Table 5.23, Soil Gas
Monitoring Well 3 (6 to 8 ft), page 12 of 16. Please correct this oversight.
71. The following discrepancies were noted in Table 5.23. Please clarify these discrepancies.
Sample I.D. Sample Date Parameter Value Reported in March Value reported in
1998 Report Laboratory
Documentation
SGMW-1 (2 to 4 fl) 7/ll/97 I, 2-Dichlorcthanc 3000000 D 300000 D
10/16/97 Carbon Dioxide(% vol) . <l.5 4.6
10/16/97 Oxygen(% vol) 4.6 <1.5
SGMW-1 (6 to 8 fl) 4/3/97 Methylene Chloride I U I
4/3/97 Ethene (ppm (v)) 27000 330
4/3/97 Ethane (ppm (v)) 4000 <30
4/22/97 Ethenc (ppm (v)) 3300 27000
4/22/97 Ethane (ppm (v)) <30 4000
6/16/97 Freon 113 2U 3D
8/18/97 Carbon Dioxide (ppm 0.07l 1.0
(v))
Mr. Jon Bomholm
May 11, 1998
Page 20
SGMW-1 (6 to 8 fl)
SGMW-2 ( 2 to 4 fl)
SGMW-2 (6 to 8 fl)
SGMW-3 (2 to 4 fl)
SGMW-3 (6 to 8 fl)
12/10/97
8/18/97
9/15/97
9/15/97
11/18/97
12/10/97
3/25/97
5/17/97
6/16/97
7/14/97
7/14/97
8/18/97
1 Oil 6/97
6/16/97
7/15/97
7/15/97
1/7/97
2/11/97
Vinyl Chloride
Vinyl Chloride
Freon 113
Toluene
I, 2-Dichloroethane
I, 2-Dichlorethane
Ethane (ppm (v))
I, 2-Dichloroethanc
Methane (ppm (v))
Vinyl Chloride
1, 2-Dichlorethane
Toluene
1, 2-Dichlorethane
Methane (ppm (v))
Vinyl Chloride
I, 2-Dichlorocthane
Vinyl Chloride
Chlorocthane
63000 D 630000 D
95000 D 950000 D
15000 U 150000 U
15000 U 150000 U
37000000 37000000 D
92000 D 920000 D
16000 1600
4610000 D 4600000 D
10000 100000
80000 D 800000 D
1900000 D 19000000 D
10000 U 100000 U
21000000 21000000 D
760 --
62000 D 620000 D
19000000 D 190000000 D
120000 D 1200000 D
46000 D 20000U
Table 5.24 Monthly Summa Canister Sampling Results, Soil Gas Monitoring Wells S, 6,
7 and 8
72. The following discrepancies were noted in Table 5.24. Please clarify these discrepancies.
Sample I.D. Sample Date Parameter Value Reported in Value reported in
March 1998 Report Laboratory
Documentation
SGMW-5 (6 to 8 fl) 9/16/97 Methane (ppm (v)) 28000 26000
SGMW-6 (2 lo 4 fl) 12/9/96 Toluene 23000 D 2300 D
SGMW-6 (6 lo 8 fl) 12/9/96 l, 2-Dichloroethane 13000000 B 13000000 BD
6/16/97 Toluene 10000 U 10000 D
SGMW-7 (2 to 4 fl) 12/10/96 • Freon 113 1000 U
3/25/97 Freon 113 250 U
Mr. Jon Bomholm
May 11, 1998
Page 21
SGMW-7 (2 to 4 ft)
SGMW-7 (6 to 8 fi)
SGMW-8 (6 to 8 fi)
0
6/16/97
9/22/97
12/9/97
12/12/97
Freon 113
Freon 113
Oxygen(% vol)
Ethene (ppm (v))
•
1500 U
100 U
1.5 <1.5
14000 160000
FIGURES
Figure 5.2 Groundwater Elevations: Wells NS-14, NS-35, NS-36, NS-39, NS-40, NS-42
73. Figure 5-2 indicates that the groundwater elevations for monitoring wells NS-14 and NS-
42 are depicted. However, the groundwater elevations for these two monitoring wells
were inadvertently omitted. Please correct this oversight.
74. Figure 5-2 is very congested in the four-month period from August through December
1997. Please reconfigure this figure into two figures, or whatever may be required, in
order to clearly depict the groundwater elevations for the monitoring wells during this
time frame.
Figure 5.39 Shallow (2-4') Soil Gas Concentrations (SGMW-4), Field Measured w/GA-90
75. The word "Concentrations" is misspelled in the title for Figure 5.39. Please correct this
oversight.
APPENDIX A
Blue Planet Technologies, Phase I BIOreport #1060, September 17, 1996
76. The word "Cadmium" is misspelled in the table, Factors that Limit Microbial Growth,
throughout the Phase I B!Oreport. Please correct this oversight.
77. The table, Analytical Results for 1,2-Dichloroethane, indicates that the soil sample BT-I,
4-6', contains 7400 µg/1 1,2-DCA. However, NSCC has made many comments stating
that this soil sample only contained 500 µg/1 1,2-DCA. Please clarify this discrepancy by
providing the actual laboratory analytical report generated during the analysis of this soil
sample.
78. The chain of custody documentation for the soil samples collected for the Phase I
BIOreport was inadvertently omitted. Please correct this oversight.
Mr. Jon Bornholm
May 11, 1998
Page 22
• •
Blue Planet Technologies, Phase II BIOreport #1060, November 19, 1996
Methods -Confirmation of Contaminant Degradation
79. The second sentence of this section should be corrected to read "The closed system is
rotated at 200 rpm at 25 degrees centigrade ... " Please correct this oversight.
Discussion -BT-1 (4-6 ft.) Anaerobic Biotic L18968-1D
80. The second sentence of this section does not make sense. Please clarify the meaning of
this sentence.
Discussion -BT-2 (4-6 ft.) Anaerobic Biotic L18985-SA
81. The last sentence of this section states that " ... the decrease of substrate (e.g.) 60 ppb of
1,2 Dichloroethane in 28 days, after subtraction of the abiotic losses ... " However, the
decrease of substrate for the BT-2 anaerobic sample should be 70 ppb. Please correct this
oversight.
APPENDIXC FIELD ACTIVITY DAILY LOGS (FADL'S)
82. The Borehole Log for soil boring BT-3 indicates that the decontamination procedures for
the split spoons were as follows: soap; water rinse; isopropanol; organic-free water;
distilled water; and, tap water. However, these procedures are not in accordance with the
US EPA Region IV Environmental Investigations Standard Operating Procedures and
Quality Assurance Manual (EISOPQAM). Please provide justification for noncompliance
with the US EPA Region IV EISOPQAM.
83. The F ADL for November 11, 1996 (page 2 of 5) indicates that the decontamination
procedures for the well casing were as follows: isopropanol; distilled water; and air dry.
However, these procedures are not in accordance with the US EPA Region IV
EISOPQAM. Please provide justification for noncompliance with the US EPA Region IV
EISOPQAM.
APPENDIXD BLUE PLANET ANALYTICAL REPORTS
84. The title page for Appendix D should state that the date of the June 1997 report is June
31, 1997. Please correct this oversight.
Mr. Jon Bornholm
May 11, 1998
Page 23
0
September 29, 1997 Blue Planet Technologies Report
85. Table I, Anaerobic Plate Counts, indicates that two samples that have the same sample
identification (SP3-l 7-6-8) were collected. Additionally, Table I does not indicate the
collection of soil sample SP2-22-6-8. Please clarify these discrepancies.
APPENDIX£ SOIL voe ANALYTICAL DATA (PACE ANALYTICAL, INC.) &
voe ANALYTICAL DATA VALIDATION (VALIDA TA, INC.)
Data Validation, Pace Analytical, Inc. Report #72221
Title Page
86. The word "Analytical" is misspelled on the cover page of this report. Please correct this
oversight.
List of Samples
87. The List of Samples does not include all of the samples collected on November 13, 1996
and submitted to Pace Laboratories for laboratory analysis. Specifically, soil samples
SP3346, SP3196D,SP322D6,SP412, SP416,SP424, SP426, SP432,SP436and
PLOT44 were not included in the data validation report. Please provide justification for
. not including these samples in the data validation-report.
88. The List of Samples includes sample SP2246. This sample should be shown as sample
SP2346. Please correct this oversight.
Section 2 Blank Contamination
89. · The second paragraph listed in the section entitled, Method Blank Contamination,
indicates that soil samples SP I I 94 and SP 1196 should be associated with a "U"
qualification at the reported value for acetone and 2-butanone. However, these samples
were not associated with the appropriate qualification. Please clarify this discrepancy.
Section 5 Calibration
90. One of the soil samples listed in the section entitled, Initial Calibration, is sample 2220.
This sample should be shown as 3220. Please correct this oversight.
Mr. Jon Bornholm
May 11, 1998
Page 24
•
91. The fourth paragraph listed in the section entitled, Continuing Calibration, indicates that
soil samples SP 1226, 1346, 3196DL, 3342DL, 3344, 3220, and 3226 should be
associated with a "J" qualification for all the associated positive results for acetone and
"UJ" qualification for all the associated nondetects for acetone. However, none of these
qualifications were associated with any of the above samples. Please clarify this
discrepancy.
Section 9 Matrix Spike/Matrix Spike Duplicate, MS/MSD
92. The word, "dichlorethene" was misspelled in the fourth sentence of this section. Please
correct this oversight.
Data Validation, Pace Analytical, Inc. Report #3089
List of Samples
93. One of the soil samples listed in this section is sample SP77. This sample should be shown
as SPl 77. Please correct this oversight.
Section 2 Blank Decontamination
94. The third paragraph in the section entitled, Method.Blank Contamination; indicates that
chloroform was detected in method blankVBLK095A. However, laboratory
documentation indicates that I, 2-dichloroethane, not chloroform, was detected in method
blank VBLK095A. Please clarify this discrepancy.
95. The first paragraph in the section entitled, Field,or Rinse Blank Contamination, indicates
that methylene chloride and acetone were detected in the equipment blank, EB032697.
However, laboratory documentation indicates that I, 2-dichloroethane was also detected
in the equipment blank, EB032697. Please clarify this discrepancy.
Data Validation, Pace Analytical, Inc. Report #SP165
Title Page
96. The word "Analytical" is misspelled on the cover page of this report. Please correct this
oversight.
Section 2 Blank Contamination
97. The word "were" is misspelled in the third sentence of the section entitled, Method Blank
Contamination. Please correct this oversight.
Mr. Jon Bornholm
May 11, 1998
Page 25
Data Validation, Pace Analytical, Inc. Report #3333
List of Samples
•
98. One of the soil samples listed in this section is sample SP3668. This sample should be
shown as SP3468. Please correct this oversight.
Section 2 Blank Contamination
99. The third paragraph of Section B of this section indicates that soil samples SP 1466 and
SP 1466DL should be associated with a "U" qualification for acetone. Please clarify and
correct this section about whether this is soil sample SP 1446 or soil sample SP 1468.
Section 9 Matrix Spike/Matrix Spike Duplicate, MS/MSD
100. The last sentence of this section should state that "MS/MSD was performed on sample
SP32268, criteria was met." Please correct this oversight.
Laboratory Documentation
IO I. The laboratory documentation for sample SP3468 is incorrectly cited as that for sample
SP3668. Please correct this oversight.
Data Validation, Pace Analytical, Inc. Report #105089
Laboratory Documentation
I 02. The laboratory documentation for soil samples SP21624 and SP2 l 624DL have been
incorrectly corrected to SP21626 and SP21626DL, respectively. Please correct this
oversight.
JAMES B. HUNT JR:~;.; •
; GoVCRNOR :.:,,,..;/
:??-: •
•
Mr. Jon K. Bornholm
Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
· DIVISION OF WASTE MANAGEMENT
February 18, 1998
RE: Revised 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 Revised 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 February 2, 1998. The
Hazardous Waste and Superfund Sections of the NC DENR have reviewed the
Revised Natural Degradation Treatability Study Progress Report for Operable Unit 4
and offer the following attached comments.
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
Sincerely, .
·;)J Z ftlb:crt~~
-t':Vid B. Mattison, CHMM
Environmental Engineer
Superfund Section
cc: Mr. Patrick Watters, NC Hazardous Waste Section
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
F'HONE919-733-4996 FAX [phone] AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/10% POST-CONSUMER PAPER
• • Jon Bomholm
February 18, 1998
Comments
Page 1
•
Revised Natural Degradation Treatability Study Progress Report for Operable
Unit 4 .
List of Figures/List of Tables
1. Please delete the periods and dashes following the titles of the figures and
tables listed on page ii and page iii.
Section 3.0 Soil Plots and Soil Gas Monitoring Wells
2. The National StaJch and Chemical Corporation (NSCC) responses to NC
DENR comments #6, 7 and 3 7 described in adequate detail the water
infiltration problems encountered with the soil plots and how those problems
were resolved. However NSCC does not discuss the impact that the extra
water had on the soil plot tests. These tests were based on a weekly addition
of a fixed amount of water (3.6 liters) and fertilizer nutrient (27 grams) to the
plots each week. The quantity of water that infiltrated the soil plots, the
duration of the water infiltration problem and the impact of this additional
water infiltration should be discussed in this section. Additionally, please
provide some discussion as to the potential effects of the concrete base used to
secure the soil boxes (i.e., change in pH).
Section 4.0 Soil Sampling
3. The last sentence in the second paragraph of this section should state " ... used
during November 1996, March 1997 and June 1997." Please correct this
oversight.
Section 5.0 Preliminary Observations
4. The treatability study focuses on the mechanisms of degradation for 1,2
Dichloroethane (1,2 DCA). The report acknowledges that 1,2 DCA degrades
to vinyl chloride, ethene and ethane. However, the report does not discuss the
ultimate degradation of vinyl chloride, a more hazardous substance than 1,2
DCA. Please provide additional information describing the degradation of
vinyl chloride as well as the documentation to support the feasibility of such
vinyl chloride degradation within a reasonable timeframe at the NSCC site.
• Jon Bornholm
February 18, 1998
Comments
Page 2
•
5. This section should be expanded to include a thorough discussion of the
anomalies encountered to date at this site and the impact such anomalies may
have had on the test results or on future activities. Examples of anomalies to
discuss include events such as the excess water infiltration into the soil plots
and the high analytical detection limits due to sample dilution.
Tables
5. The NSCC response to NC DENR comments #17 and #19 included a response
from Pace Analytical Services, Inc. However, the enclosures submitted with
the response from Pace Analytical Services were inadvertently omitted. Please
correct this oversight.
Appendix A
Phase II BIOreport .
Partitioning with Composite Samples
6. According to the NSCC response to NC DENR comment #35, soil samples
BT-I and BT-2 were incorrectly denoted as B-1 and B-2 in the first and
second paragraphs of this section. The notation was corrected in the first
paragraph but not the second. Please correct this oversight.
AppendixB
Weekly Moisture and Nutrient Addition Logs
7. The response to NC DENR comment #38 stated that the date of January 9,
1997 was inadvertently recorded on the log sheet. Accordingly, NSCC was to
strike through the January 9th entry. However, this was inadvertently omitted.
Please correct this oversight.
Appendix C
June 31, 1997 Blue PlllJ)et Technologies Report
8. The amended soil sample chain of custody documentation to be included with
this report was inadvertently omitted. Please correct this oversight.
To:
From:
Date:
Reference:
•
Dave Mattison, Superfund Section, x -349
Patrick Watters, Hazardous Waste Section, x -240 ~ ~oJli.;v,.,
February 17, 1998
Natural Degradation Treatability Study Revised Progress Report dated January
1998 for Operable Unit# 4 at the National Starch & Chemical Company
Superfund Site.
Here are my comments on the referenced document for National Starch and Chemical Company.
The treatability study focuses on the mechanisms of degradation for 1,2 DCA. The report
acknowledges that 1,2 DCA does degrade to vinyl chloride, e·thene and ethane however it does
not discuss the degradation of vinyl chloride. Vinyl chloride is more hazardous than 1,2 DCA
therefore we will need to see some narrative in the report discussing how vinyl chloride degrades
and whether or not it is feasible within a reasonable time period at the NSCC site.
The narrative went into adequate detail to describe the water infiltration problem with the soil
plots and how it was fixed. What is not discussed is the impact that all this extra water had on
the soil plot tests. These tests were based on a weekly addition of a fixed amount of water (3 .6
liters) and fertilizer nutrient (27 grams) to the plots each week. We do not know the duration of
the water infiltration problem and we do not know how much extra water was· introduced into the
plots before it was corrected. Provide some discussion on the impact this extra water may have
had on the soil plot test results.
Section 5.0 Preliminary Observations needs to include discussion of anomalies and the impact
they may have had on the test results or on future activities. Examples of such anomalies to
discuss include events like the excess water infiltration into the soil plots and the high analytical
detection limits due to sample dilution.
If you have any questions about this please give me a call.
UNITE-ATES ENVIRONMENTAL PROTECTION,ENCY
REGION4
4WD-NSMB
Mr. David Mattison
ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
ATLANTA, GEORGIA 30303-8909
January 28, 1998
RECEIVED
FEBO 2 1998
SUPERFUND t,E.cr10N
North Carol'ina Department of Environment, Health
and Natural Resources/Superfund Section
Suite 150
401 Oberlin Road
Raleigh, NC 27605
SUBJ: Request to Review Natural Degradation Treatability Study
Revised Progress Report for Operable Unit #4 at the
National Starch & Chemical Company Superfund Site
Dear Mr. Mattison:
Enclosed for your information and the State's file are two
copies of the above referenced document. Please review this
document. I would appreciate receiving the-State's comments by
Thursday, February 19, 1998. If you are unable to provide your
comments by this date, please inform me as to when I can expect
to receive them.
If you have any questions, I can be reached at 404-562-8820.
Sincerely yours,
tK1S~~~
Remedial Project Manager
Enclosure
1. Natural Degradation Treatability Study Revised Progress
Report for Operable Unit #4 at the National Starch &
Chemical Company Superfund Site (January 1998)
Recycled/Recyelable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)