NCD991278953_20021001_National Starch & Chemical Corp._FRBCERCLA RA_Remedial Design Remedial Action 1989 - 2002-OCR

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• REMEDIAL ACTION UPDATE FACT SHEET
NATIONAL STARCH & CHEMICAL COMPANY
:SUPERFUND SI-'LE l I 1 . . '' ,, 1, I', .. ' ' .
Region 4 \; ! ~Salisbury;-Rowa~ Cot.i1~ty
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OCTOBER 2002 : i ) : """ , North Carolina
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This fact sheet is not to be considered a technical document but has been prepared to provide the general ~ublic ;\'ith a better understanding ofactiv/tics
that have been occurring at the Site. For technical information, please review documents in the Informa'tion Repository.-·-····· · :
INTRODUCTION
The National Starch &Chemical Company (NSCC) Superfund Site
is located on Cedar Springs Road, approximately 5 miles south of
the City of Salisbury, in Rowan County, North Carolina. The goals
of this Fact Sheet are to inform the public that:
I) construction activities associated with the Superfund clean-up
effort are essentially complete at the Site;
2) NSCC is currently conducting a multi-year natural degradation
treatability study for contaminants in the soil;
3) NSCC is currently reassessing/re-evaluating the plume
periphery extraction system associated with the Operable Unit
# 1 Remedial Action; and • the Agency recently completed the Five-Year Review Study of
the entire NSCC Site.
SITE HISTORY
In September 1968, Proctor Chemical Company purchased a 465-
acre tract of land on Cedar Springs Road. Construction of the plant
on Cedar Springs Road began in 1970. In January 1983, Proctor
Chemical Compa.ny was dissolved and its operations merged with
NSCC.
The primary products of this facility are textile-finishing chemicals
and custom specialty chemicals. Volatile and semi-volatile organic
chemicals are used in the production process along with acidic and
alkaline solutions. Acidic and alkaline solutions are also used in
the cleaning processes. The liquid waste stream from the
manufacturing processes i~clude reactor and feed line wash and
rinse solutions.
The NSCC facility was proposed for inclusion on the National
Priorities List in April 1985, re-proposed in June 1988, and
finalized on the list in October 1989 with a Hazardous Ranking
System score of 46.51. This score was based on the following
exposure route scores: exposure via groundwater pathway-80.46,
exposure via surface water pathway -0.00, and exposure via air
athway-0.00. Since there has only.been one owner/operator of
is property after being developed into an industrial complex, no
. {esponsible Party Search" was performed. NSCC has been and
remains the owner/operator of the facility.
I c · 1 •· •. -·-1 ' . ' , I
Figure 1 shows the layout of the NSCC facility and points of
interest. Due to the continued detection of contaminants in the
streams, the original scope of work defined in 1986 has been
expanded several times resulting in the NSCC facility being divided
into four (4) Operable Units. The Agency prepared a Record of
Decision (ROD) for each Operable Unit (OU). A ROD is a public
document the Agency prepares that explains and documents the
cleanup technology to be used at a Superfund Site. The ROD is
based on the Remedial Investigation, the Baseline Risk
Assessment, and the Feasibility Study. A Remedial Investigation
gathers data needed to determine the types of contaminants present
at a site, what are the concentrations of these contaminants, and
how far these contaminants have migrated. The Baseline Risk
Assessment assesses the information generated during the
Remedial Investigation to determine if the types of contaminants
present and their reported concentrations will result in an
unacceptable risk to either human health or the environment. The
Feasibility' Study looks at· and evaluates the remediation
technologies that can be applied at a site to clean it up.
Following the Agency's issuance of a ROD, the cleanup alternative
is designed and engineered as part of the Remedial Des,ign phase.
The Remedial Action (RA) is the next phase which involves
implementing the design and conducting the actual site clean-up
activities.
OU #1 focuses on the contaminated groundwater.in the eastern
portion of the NSCC facility. This contaminated groundwater is
discharging into the Unnamed Tributary. OU #2 examined the
contaminared soils within the Trench Area which is the cause of the ·
groundwater contamination studied in OU #I. OU #3 deals with
the contaminated groundwater in the western portion of the NSCC
facility. This contaminated groundwater is discharging into the
Northeast Tributary. OU #4 addresses the contaminated soils in
Area 2 and the wastewater treatment lagoon area (i.e., the source of
contamination in the groundwater studied in OU #3). Area 2
includes the following features; Area 2 reactor room, the tank
room, raw material bulk storage, the warehouse, and an abandoned
underground terra-cotta pipe line that ran from the Area 2 reactor
room to the wastewater treatment lagoons. The lagoon area
includes three lagoons which were originally constructed as unlined
lagoons between 1969-1970. All lagoons are now lined with
concrete.
Please refer to Table I for the chronology of activities at NSCC as
well as for the dates of important milestones.
The OU #1 RA included the following activities:
• Install two groundwater extraction systems: one to capture the
leading edge of the plume, the plume periphery extraction
system (PPES), and a second system to capture the heart of the
plume (i.e., immediately downgradient of the Trench Area, the
Trench Area Extraction System);
Treat the extracted groundwater through a train of treatment
technologies that includes: pH adjustment and air stripping to
achieve a quality of water that can be discharged to the City of
Salisbury POTW;
Establish a monitoring program for groundwater ;md surface
water/sediment; and
• Conduct a supplemental RI (OU #2) to determine the source of
contamination continually being detected in the surface waters.
The OU #2 ROD included the following activities:
No action remedy;
Monitored natural attenuation;
Monitor soils in the Trench Area on a quarterly basis;
Deed restriction to I) identify the area(s) of contamination, 2)
prevent transfer of property to an uninformed purchaser, and 3)
limit future utilization of the property; and
Conduct an RI (OU #3) to determine the source of
contamination continually being detected in the surface waters
in the Northeast Tributary.
The OU #3 RA included the following activities:
Install a groundwater extraction system in Area 2 (interception
trench) and the lagoon area (extraction wells);
Treat the extracted groundwater using air stripping and/or
activated carbon filtration to achieve a quality of water that it
can be discharged to the City of Salisbury POTW;
Vapor emissions from the air stripping unit are to be controlled
through catalytic oxidizing and scrubbing;
• Establish a monitoring program for groundwater and surface
water/sediment; and
Conduct FS (OU #4) to re-examine remediation options for the
soils in this area of the NSCC facility.
And the OU #4 ROD included the following activities:
Perform a "Biodegradative Study" to (I) substantiate that
natural degradation of contaminants of concern in the soil is
occurring in the OU #4 area, (2) identify where in the
subsurface soils degradation is occurring, and (3) determine the
rate of degradation;
Develop and implement a for long term monitoring plan to
monitor the biodegradative process until the performance
standards are achieved;
Implement institutional controls. Institutional controls include
deed restrictions and maintenance of both the existing fence
around the plant operations area and the paved areas around
Area 2;
• Develop a plan to protect workers in the event that the
contaminated soils are to be excavated prior to the levels of
1.2-Dichloroethane reaching the appropriate direct contact
health based risk concentration (1,2-Dichloroethane (1,2-DCA)
is the primary contaminant of concern in the soil);
• Conduct a five-year review in accordance with CERCLA
Section 121(c);
In the event that the "Biodegradative Study" cannot substantiate.
occurrence of significant natural degradation of 1,2-DCA and otH
contaminants of concern in the soil, or the study shows that
degradation products increase the Site risks, the contingent remedy
will be implemented. "Significant biodegradation" is defined as a
statistically significant decrease in levels of contaminants of
concern (particularly 1,2-DCA) that is coupled with multiple
indicators of biological activity, which includes the appearance of
degradation products such as, but not limited to, chloroethane,
ethane, vinyl chloride, ethene, carbon dioxide, hydrogen sulfide,
methane, and soluble iron(II)) and the depletion of electron
acceptors (including oxygen, nitrate, iron, sulfates, or others). The
components of the contingent remedy include:
• Install a soil-vapor extraction system above the water table to
remove the volatile organic contaminants from the unsaturated
zone and
• Treat the extracted contaminated air from Area 2 using fume
incineration to destroy the volatile organics prior to the air
stream being released into the atmosphere. After
concentrations of contaminants decrease in the extracted air,
this contaminated vapor may be treated via vapor-phase
activated carbon adsorption filters. The extracted contaminated
air from the lagoon area will be treated using vapor-phase
activated carbon adsorption filters to remove the volatile
organics prior to the air stream being released into the·
atmosphere. •
CURRENT ST A TVS
Construction of the OU #1 RA was completed in March 1996.
Figure I shows the location of the OU #I RA components.
Originally, the four PPES extraction wells were pumping at a
combined average of 86 gallons per minute (gpm). In 1998, the
average combined flow was reduced to 31 gpm. In 2000, the PPES
was shutdown to allow NSCC to conduct a hydrogeologic
evaluation of this area. Cun-ently, the PPES remains oftline as the
hydrogeologic evaluation continues. This evaluation is scheduled
to be completed by April 2003. The combined pumping rate of the
six Trench Area.extraction wells is approximately 12 gpm.
Construction of OU #3 RA was completed on February I 8, 2000.
On average, the combined flow from the two bedrock extraction
wells is 20 gpm and the extraction rate for the Collection Trench is
6 gpm. Figure I shows the location of the OU #3 components.
The objectives of the OU #4 "Biodegradative Study" are
highlighted above. Phase I of the OU #4 Natural Degradation
Treatability Study was initiated in December 1996 and was
completed in March 1998. Phase II was started in November 2001
and is anticipated to be completed in February 2007. This work is
being conducted in accordance to the January 2000 Phase a
Natural Degradation Treatability Study Work Plan. The prima'W'
objective of Phase II to is substantiate biodegradation, collect
sufficient data to establish a defensible degradation rate, and
develop a long-ierm monitoring program.
• In response to the institutional control (i.e .• deed restrictions)
requirements included in both the OU #2 and OU #4 RODs, a plot
map was prepared and the restrictions were filed with the Rowan
.ounty Register of Deeds Office on June 12, 1997. The
• scription can be found in Book 9989, page 179.
Currently, NSCC is re-evaluating the hydraulic control of the OU
#1 PPES. This was in response to detecting contaminants in a
monitoring well, NS-31 (refer to Figure 1), on the opposite side of
the Unnamed Tributary. According to the conceptual groundwater·
model for the Site, the Unnamed Tributary should be acting as a
hydraulic barrier. This evaluation should be completed by April
2003.
CONCLUSIONS OF FIVE-YEAR REVIEW REPORT
Below is a short synopsis of the report.
The portion of the Site remedy dealing with potential soil exposures
is protective of human health and the environment in the short-
term. The Trench Area. Area 2. and the lagoon area remain
covered and the deed restrictions are in place. At the conclusion of
Phase 2 of the Natural Degradation Treatability Study in 2007, a
definitive answer should be made regarding long-term
protectiveness of the remedy. In addition, the Agency will also
detennine whether to implement or eliminate the contingent remedy
specified in the OU #4 ROD.
There are no current onsite groundwater receptors and the nearest
Aivate, potable well is located approximately 2,700 feet north of
.,.rea #2. Since there is currently no indication of contaminated
groundwater or surface water exiting the property, the remedy is
considered protective in the short-term. Groundwater.at the Site is
not protective of human health and the environment in the long-
term due to the following reasons: the current groundwater
monitoring system is irisufficient to determine if the plumes are
being captured, groundwater is likely migrating to a degree and
discharging to adjacent surfjce water, groundwater performance
standards are not being met throughout the plume, and groundwater
is not currently "restored'', as some Federal and State regulations
are lower than the ROD standards .
•
• A copy of the 2002 Five-Year Review Report has been placed in
the NSCC Information Repository located in the Rowan County
Public Library. The next Five Year review should be scheduled
five years from the date of this Review, in September 2007. Table
2 provides the recommendations made in the Five-Year Review .
Report.
FOR MORE INFORMATION
If you want further information on this Site or the Superfund
program, please contact either of the individuals below:
Jon K. Bomhcilm, Remedial Project Manager
Diane Barrett, Community Involvement Coordinator
U.S. EPA, Region IV
North Superfund Management Branch
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303-3014
Phone: [phone], ext. 28820 or 28489
INFORMATION REPOSITORY
Citizens are encouraged to visit the information repository to
review the technical d~ta covering all activities that have occurred
to date.
Rowan County Public Library
201 West Fisher Street
SalishUQ', North Carolina 28144
Phone: [phone]
Hours: Monday -Friday 8:00 a,m, • 9:00 p.m,
.,,
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•
• TABLE I --CHRONOLOGY/MILESTONES FOR THE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
EVENT DATI•: EVENT DATE
Proctor Chemical Company purchased the 465-acre tract September 1968 OU #3 Proposed Plan Public Meeting August 3, I 993
Construction of facility 1970 Proposed Plan public comment period July 19 -August 17, 1993
Proctor Chemical Company dissolved and merged with January I, I 983 Record of Decision for OU #3 signed, divided Site October 7, 1993 NSCC into 4 OUs, created OU #4
Site proposed for National Priorities List April 1985 OU #4 RI Report (used June 1993 OU #3 Remedial June I 993 Investigation)
Special notice letter to conduct Remedial May 30. 1986 OU #4 Feasibility Study Document June 20, I 994 Investigation/Feasibility Study
Administrative Order on Consent signed December I. 1986 Proposed Plan Fact Sheet for OU #4 July 8, I 994
Remedial Investigation/Feasibility Study (RI/FS) Work Plan December 1986 OU #4 Proposed Plan public comment period July 12 -August 11, 1994
Amended Rl/FS Work Plan July 1987 OU #4 Proposed Plan Public Meeting July 26, 1994
Site re-proposed for National Priorities List June 1988 Record of Decision for OU #4 October 6, 1994
First Remedial Investigation (RI) Report I for Operable Unit June 21. 1988 Unilateral Administrative Order for OU #3 and OU #4 September 29, 1995 (OU)#!] RD/RA
First Feasibility Study (FS) Document (OU#!) September 8. I 988 Initiated OU #3 and OU #4 Remedial Design October I 995
Proposed Plan Fact Sheet September I 988 Construction Completion for OU #I Remedial Action March 1996
Proposed Plan Public Meeting (OU#!) September 14, 1988 First Five-Year Review Report (for OU#!) June I 8, I 996
Proposed Plan public comment period (OU#!) September 3 -24, 1988 Initiated OU #4 Natural Degradation Treatability December 1996 Study -Phase I
OU #I Record of Decision (ROD) Signed, divided Site into September 30, 1988 First Explanation of Significant Difference June 10, 1997 two OUs, created OU #2
Issued Special Notice Letter to Conduct Remedial March 27. I 989 Completed OU #4 Natural Degradation Treatability March 26, 1998 Design/Remedial Action for OU #I Study -Phase I
Unilateral Administrative Order issued to perform OU #I July 27. 1989 OU #3 Remedial Design Completed June 1998 Remedial Design/Remedial Action (RD/RA)
Site finalized on National Priorities List October 1989 Second Explanation of Significant Difference November 4, I 998
Supplemental Remedial Investigation Report for OU #2 May 1990 Initiation of OU #3 Remedial Action June 15, I 999
Initiation of OU # I construction -building access roads to August 14, 1990 Initiation of OU#! + OU #3 Combined Pretreatment September 23, 1999 bedrock plume periphery extraction well locations System
TABLE I --CHRONOLOGY/MILESTONES FOR TIIE NATIONAL STARCII & CHEMICAL COMPANY SUPERFUND SITE
EVENT DATE EVENT DATE
Installation of four bedrock plume periphery extraction August 30 -November Completion of OU# l + OU #3 Combined February 18, 2000 wells 14, 1990 Pretreatment System
Proposed Plan for OU #2 July 1990 Construction Completion for OU #3 February 18, 2000
Proposed Plan public comment period July 30 -August 29, Initiated OU #4 Natural Degradation Treatability November 5, 2001 1990 Study -Phase II
Supplemental Feasibility Study Document for OU #2 September 1990 First Site-Wide Five-Year Review Report July 2002
ROD for OU #2 signed, divided Site into three OUs, created September 28, 1990 Complete OU #1 Plume Periphery Evaluation July 2003 OU#3
CD signed Augusl 1991. Implement Recommendations of OU #I Plume Consent Decree for OU #2 cntcrc<l in Federal Court Periphery Evaluation September 2003
on July 20. 1992 •
OU #3 Remedial Investigation Report June 2. 1993 Complete OU #4 Natural Degradation Treatability Anticipated February
Study -Phase II 2007
OU #3 Feasibility Study Document June 21. 1993 Accept Findings of Soil Degradation Treatability April 2007 ·-Study or Implement Contingent Remedy
Proposed Plan Fact Sheet for OU #3 July 15. 1993 Second Site-Wide Five-Year Review Report September 2007
Construction of trench area extraction wells+ pretreatment July 1993 -February Third Site-Wide Five-Year Review Report September 2012
system 1996
•
• •
• • •
TABLE 2 --SUMMARY OF RECOMMENDATIONS AND FOLLOW-UP ACTIONS
<;ill\°-..__ ISSUE REC0M~IENDATI0NS AND PARTY OVERSIGHT MILESTONE ~, ,._ Fou.ow-UI' ACTIONS RESPONSIBLE AGENCY .. ~ September . ~ Initiate discussions between regulatory agencies, NSCC, and EPA/NCDENR/ HoW clean.is clean for the soils in 1he Trench Arca EPA ; .... public to discuss this issue NSCC 2007 . .:_ February ComP,lete OU #4 Biodcgradation Treatability Study Maintain communication with NSCC NSCC EPA 2007 ~ -~
Complete assessment of PPES Maintain communication with NSCC NSCC EPA April 2003
Complete assessment of OU #2 Conduct soil sampling in conjunction with OU #4 NSCC EPA July 2003 Biodegradation Treatability Study -
Effectiveness of Collection Trench in capturing Evaluate if Collection Trench is capturing plume NSCC EPA December
plume 2003
Effectiveness of other groundwater extraction Determine if efficiency of existing groundwater extraction NSCC EPA September
systems systems can be enhanced 2007
Are groundwater monitoring systems adequate? Determine if additional monitoring wells arc needed EPA/NCDENR/ EPA December
NSCC 2004
Are contaminants leaving the Site via the Northeast Locate and sample new sampling point downstream of Sampling NSCC EPA December
Tributary Location SW/SE -09 2003
The decision documents for the Site do not reflect Amend decision documcnts·and NSCC deed recordation to EPA/NCDENR/ September cuncnt ARARs or subsequent recordation EPA
requirements and cleanup standards reflect current ARARs NSCC 2012
Region 4
Official Business
•
U.S. Environmental Protection Agency
61 Forsyth Street, S.W.
Atlanta. Georgia 30303-3014
•
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North Superfund Management.Branch--;;--1-; T _-.: A_ 1
1 \.· ..,I; '1..J"""cr>q Diane Barrett,_ Community Inv'olvement GoOrdih.:i.tor -·
---·~ l-----JOO Bornholm, Rerhedial Project Manager
Penalty for Private Use $300
3/F NSCC 111
MR. DEXTER MATTHEWS, DIRECTOR
DIVISION OF WASTE MANAGEMENT
NC DEPT. OF ENVIRONMENT & NATURAL RESOURCES
1601 MAIL SERVICE CENTER
P. 0. BOX 27687
RALEIGH NC 27699-1601
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Transmillcd Via Federal Express
May 15, 1998
Mr. Jon Bornholm
Remedial Project Mnnager
United States Environmental Protection Agency
61 Fors>1h Street, S.W.
Atlanta, GA 30303-3 l 04
Re: Project Delivery Strategy
Opcrahlc Unit Three Remedittl Action
Cedar Springs Road Plant Site
Salisbury, North Carolina
Project#: 050.55 #2
Dear Mr. Bornholm:
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On behalf of National StRrch & Chemical Company (NSCC), !3lasland, Bouck & Lee, Inc. (BBL) is
submitting this Project Delivery Strategy (l'DS) for the i111pleme11tation of the Remedial J\ction (RA) at
the Cedar Springs Road Pinnt Site (Site) in Salisbury, North Carolina. This Project Delivery Slrntcgy has
hccn prepared in accordance with:
The Statement of Work prescn1cd in Arrendix 3 of the Unilnternl J\dministrntive Order
executed on September 29, 1995;
The Supplemental Remedial Design/Rcmcclial Action (RD/RA) Work Pinn submitted to the
United States Environmentnl Protection Agency (USEPA) on February 26, I 99X; and
The Addendum to the Supplemental RD/RA Work Plan submitted to the USEPA on April 3,
1998.
The objective of this PDS is to describe the management approach for the implementation of the RA. This
management approach includes:
Contracting and Procurement;
l'rojcct Management;
Construction Phasing; ftnd
Equipment and Contractor Avnilflbili:y.
8 So'JH', 1(ivt11 ltoad • Cron:y,11,', N.I (J0512·0SC:2
Tel (68Q) 860-C59D • \'01::H Moll (609) Di"i'.}8072 • Fo)· (60'?) 860-~91 • Office~ Na!lonwldc
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• •
CONTRACTING, J>ROCUREMENT ANO PRO.ffiCT MANAr.EMENT
Mr. Jo11 BornlJolm
May 15, 1998
Page 2 of 3
To implement the remedial nctio11 described i,dJ,c addendum It• the Supplemenlnl RD/RA Work Pla11, NSCC
will retain a C0nstructi0n Manager. The Construction Manager will porf0rm•thc following tasks:
procurement of equipment nnd ancillary items;
retnining subcontractors for in.c:;tallation;
over.seeing the instnllotion; nnd
performing the system stort-up.
The Construction Manager will report directly to NSCC nnd work under the direction of the Supervising
Contrnctor to nssure thnt the proposed combined pre-treatment system is constructed according to the plans
and specifications.
The project management structure will indudc l:ll3L in the role of Supervising Contractor and o Constmction
Manager to he determined at a later date. The Supervising Contractor will work dosely with the
Construction Monager to ossure USEPA, NCDENR ond NSCC thot the work is being constructed acc0rding
lo the approved plans and specifications. Tho Construct.ion Manager will be responsible for implementing
the C011structi0n Health & Safoty/Continge11cy Plan (CHAS/CP) and the Constrnet.ion Quality /\ssurnncc
Project Plan (CQAPjP).
Figure I presents the Project Organization Chart.
CONSTRUCTION PHASINr.
The conceptual construction phasing is presented herein. The S11pplemenlal KD/RA Work Pinn Addendt1m
presents a preliminary construction schedule. A more comprehensive schedule will be submitted with the
forthcoming Basis of Design Rep011. The preliminary construction plinsing includes the following major
elements:
Procurement
Procurement includes the selection of major equipment vendors and installation suhcontrnet0rs.
Mohi/ization/Site l're11aratim1
Mobilization and Site Prcparatilln include the activilies required to mobilize forces, equipment
and mnteriols to the site.
Trea1menr Eq11ipme11r lnsta/la1ion
Treatment Equipment Inslnllntion includes the installation and associated quality
control/quality assurnnce testing of' the treatment equipment (i.e., air stripper nnd air-phase
9LASLAND. ~OUCK & LE,, INC.
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!1·1r. Jon Uomholm
Mny IS, 1998
!'age 3 of 3
trealnrnnt uni ls) and ancillary items such as pumps, piping, instruments and contwl equipment.
This may also include the installation of additional wells, if necessary.
ExisNnf!. System De-Cummissiunini
Tl1e existing ,ystem will be de-commissioned prior to start-up. Thi·s will include disconnection
and possible removal of the existing trentment units, piping und tnnkage.
Start-Up
Start-up includes meclwnicnl/electricnl shake-down of the insllllled equipment with water and
the initial operation of the syslcn1 with extracted p,round-watcr.
EQUIPMENT AND CONTRACTOlt A VA!LABILITY
The conceptual design for the proposed combined prc-lrcalmcnl sy8lcm includes the use of pre-engineered
and readily available treatment units. This significanlly reduces the schedule of both the procurement and
installation phases. This maximizes the opportunity to use locally available installation subcontractors
without requiring specialized contract,,rs. i\ll contrnclors will nice( the rcyuircmcnts of the CHASl'/C with
respect to hazardous malcriftls training.
If you have nny questions or comments, plense do not hesitate to contact me Ht [phone].
Sincorcly,
Michael P. Fleischner
Senior Project Engineer
MPl'/plh
J~~~O)~~.WI'V
cc: Mr. Douglas E. Cregar, National Starch & Chemical Company
Mr. Michael Ford, P.E., National Starch & Chemical Company
Mr. Raymond Paradowski, National Starch & Chemical Company
Mr. Richard Frn11klin, Nalional Starch & Chemical Company
Mr. Joseph J. Hochreiter, Jr., CGWP, Blnslnnd, Bouck & Lee, Inc.
RI.ASLt..,i'JD, 90UC!< & l !-fa .. INC.
engl11~f-;·,s ,& ~r:ler.tls!,
Figure 1
Organization Chart
Cedar Springs Road Plant Site _
~al~U.7· North_C_a_r_o_li_na __________________ _
Edward R. Lynch, P.E.
Project Certifying Officer
Thomas V. Taylor, P.G.
Project Geologist
: Joseph J. Hochreiter, Jr., CGVvP Ii
. Project Officer ;
Michael P. Fleischner
Project Manager
Donald F. Sauda
Project Engineer
•
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• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
.ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
ATLANTA, GEORGIA30303-8909 RECEIVED
May 12, 1998
MAY 14 1998
4WD-NSMB
SUPERFUND SECTION
Mr. Michael Ford
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
SUBJ: Approval of Change in Project Management and Technical Personnel for Operable Units #1 and #2 for the National Starch & Chemical Company Superfund Site
Dear Mr. Ford:
In accordance to 1) the Operable Unit (OU) #1, July 1989 Unilateral Administrative Order (UAO), Paragraph VII. Project Coordinator and 2) the OU #2, July 1992 Consent Decree, Section VIII Project Coordinators, Paragraph 38, the Agency acknowledges receipt of National Starch & Chemical Company's· (NSCC) March 31, 1998 request that Blasland, Bouck, & Lee, Inc. (BBL) become the supervising contractor for OUs #1 and #2. The Agency has reviewed the credentials of this company and finds BBL acceptable and dapable of completing· the proposed work for each of these OUs.
If you have any questions, please feel free to call me at 404-562-8820.
Sincerely,
#F--6JuJ~
Jon K. Bornholrri
Remedial Project Manager
cc: David Mattison, NCDEHNR~
Stedman Southall, EPA
· Recycled/Recyclab~ • Printed with Vegetable OIi Based Inks on 100": Recycled Paper (40% Postconsumer)
•
Mr. Jon K. Bornholm
Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I Ith Floor
Atlanta, Georgia 30303
• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
April 20, 1998
RE: Site Conceptual Model
National Starch and Chemical Company NPL Site
Salisbury, Rowan County, NC
Dear Mr. Bornholm:
The Site Conceptual Model 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 this document and offer the following comments.
Site Conceptual Model
Table of Contents
I. The following table and figure titles are inconsistent with those provided in
the Table of Contents. Please correct these oversights.
Table I
Table 2
Table 3
Figure 3
Figure 7 ·
Figure 8
Figure 9
Surface Water Flow Measurements -February 25,
1998
Ground Water Elevations -February 24, 1998
Precipitation Data Collected at Charlotte, North
Carolina
Tributary Watershed Areas
Potentiometric Surface -Saprolite Wells -
Groundwater Elevations 2/24/98
Potentiometric Surface -Transition Zone Wells -
Groundwater Elevations 2/24/98
Potentiometric Surface -Bedrock Wells -
Groundwater Elevations 2/24/98
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE 919-733•4996 FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -SO% RECYCLED/I 0% POST•CONSUMER PAPER
Mr. Jon K. Bornholm
April 20, 1998
Page 2
•
Section 2.2.2 Site Conceptual Model
•
2. The first paragraph of Section 2.1.2 -Site Geology mentions the presence of a third small
tributary located northwest of the production area. However, this section fails to address
the effects this third tributary has on the hydrogeology of the site. Please correct this
oversight.
3. The first paragraph of Section 2.1.2 -Site Geology mentions the presence ofa third small
tributary located northwest of the production area. However, the fourth paragraph of this
section and Table 1 do not indicate the collection of surface water flow measurements
from the third small tributary. Please provide justification for not collecting this data.
4. The fifth and sixth paragraphs of this section discuss the estimation of the average
· discharge from the groundwater and the estimated recharge from precipitation. Please
provide additional information as to the basis for these estimations, including any
assumptions used. These calculations may be placed in a separate appendix.
5. The last paragraph of this section indicates that the Little Acres Trailer Park has twenty
potable water wells which have a combined pumping rate of 5.9 gallons per minute (gpm).
A note to Table 4 indicates that this figure is based upon 3.5 people per household
serviced and 60 gallons per day per capita. However, the assumptions used to calculate
the total pumping rate lead one to a combined pumping rate of 2. 9 gpm. Please clarify this
discrepancy.
Section 4.1 Horizontal Domain
6. The first paragraph of Section 2.1.2 -Site Geology mentions the presence of a third small
tributary located northwest of the production area. However, this section fails to address
the effects this third tributary has on the numerical groundwater flow modeling of the site.
Please correct this oversight.
Figure 2 · Site Map
7. The first paragraph of Section 2.1.2 -Site Geology mentions the presence of a third small
tributary located northwest of the production area. However, the third small tributary was
inadvertently omitted from Figure 2. Please correct this oversight.
8. Please provide verification that all extraction wells, both potable and non-potable, within
the three watershed areas that comprise this site have been identified.
.. •
Mr: Jon K. Bornholm
April 20, 1998
Page 3
•
Figure 3 Tributary Watershed Areas
•
9. The first paragraph of Section 2.1.2 -Site Geology mentions the presence of a third small
tributary located northwest of the production area. However, the watershed for this small
tributary was inadvertently omitted from Figure 3. Please correct this oversight.
We appreciate the opportunity to comment on this document. If you have any questions or
comments, please feel free to call me at [phone], extension 349.
Sincerely,
David B. Mattison, CHMM
Environmental Engineer
Superfund Section
cc: Mr. Patrick Watters, NC Hazardous Waste Section
· uN1rED1'AfE:s ENV1RoNMENtAL PRol'Eci1otl!G~/
REGION 4
ATLANTA FEDERAL CENTER L
100 ALABAMA STREET, S.W.
ATLANTA, GEORGIA 30303-3104
May 12, 1997
4WD-NSMB
Dr. Abu M. Z. Alam
National Starch & Chemical Company
10 Finderne Avenue
P.O. Box 6500
Bridgewater, NJ 08807-0500
RECEIVED
MAY 14 1997
SUPERFUND SECTION
SUBJ: Comments on RD/RA Field Investigations Summary Report
for Operable Unit #3 and Operable Unit #4 at the
National Starch & Chemical Company Superfund Site
Dear Dr. Alam:
The Agency received four copies of the above referenced
document on March 24, 1997 .. Consequently, two copies were
sent to the State of North Carolina Department of the
Environment, Health, & NaturalResources (NCDEHNR) for their
review and file.
Below are the Agency's comments/concerns and enclosed are
the NCDEHNR comments. Nll of the following comments, as
well as the State's comments, need to be adequately
addressed. Since the comments address minor issues (except
comments# 4 and# 5), the Agency proposes the following
approach for addressing these comments. Comments should be
addressed in a separate correspondence that can be added to
the RD/RA Field Investigations Summary Report as an
addendum. The text shall either incorporate the specific
change for the text or a written explanation as to·wh~ NSCC
does not feel the comment or requested change is appropriate
·· or warranted.
If you desire to meet or hold a conference call to
discuss these comments, this rendezvous needs to occur as
soon as feasible. I will need several days notice in order
to insure that the State can participate.
The following ·comments in-·the order as they appear in
the document .
. 1. :: : p·age 45, Section 5.:·.1,; ; second. paragraph,. seventh -~: '•
s'entence: This sentence states that the pumps· were
placed 10 feet above the.bottom of the.well except at
NS-54 where it was placed 30 feet above the bottom of
Recycled/Recyclable • Prinled with Vegetable OU Based Inks on 100% Recycled Paper (40% Postconsufl1€r)
2
2. Page.56, Table 5-11: Oversight, in the rest of the
accompanying tables providing the drawdown observations for
the step tests the well tested itself was included in the
table. In Table 5-11 well NS-45 was omitted from the table.·
3. Page 93, Section 8.0, fifth sentence: Typo, the beginning
of this sentence starts, "Tables 6-1 and 6-1 ... ".
4. Page 93, Section 8.1: Based on the text presented in this
section, it appears that the vertical extent.of
contamination was ·not defined in Area 2.
5. Page 93, Section 8.2: Based on the text presented in this
section, it appears that the vertical extent of
contamination was not defined in Lagoon 2 area.
As stated previously, all comments including the State's
comments, need to be addressed. If a meeting is desired to
review and discuss these comments, this meeting needs to be
scheduled as soon as possible. One week notice is requested so
that the State personnel can make appropriate arrangements.
If you have questions, I can be contacted at [phone].
Sincerely yours,
Jon K. Bornholm
Remedial Project Manager
Enclosure (1)
1. NCDEHNR 5/9/97 Fax •
cc: David Lawn, NCDEHNR
NC SUPERFUND SECTION Fax:[phone]
-~-~-· ~~--Mete bt N0rth·G~oul .. \
Depar:tment of Environment, Health and Natural Resources
Divisiori of Waste Management
James .B. Hunt, Jr., Governor
J~nathan B. Howes, Secretary
W1lllarnL Meyer, Director
Mr. Jonf. Bornholm
Remedi~J: Project Manager
Ma! 9, 1997
Supe~ Branch, Waste Management Div' ion
US BP~ Region IV · • ·
61! Forsyth St., 11th Floor
Atianta, ~orgia 30303
RE: ~~en~ on tile Draft RD/RA Fiel~ . . .
In:vest1gat1on Summary Report and hmmary
Design Report for OU #3 ·:1 ·.
May 9 '97 14:31 P.01/05
' -·--~ • . . --i - -..
i
• . ~
DEH~N~R~
e 7671
Faw:#
N~onal Starch and Chemical Comp y NPL Siu:
Salisbury, Rowan County, NC /i
Dear Mii Bornholm: :
. 'Ib.ese '1ocuments were revlew.e<t by p¢rfund and H_azar<ious Waste Sections. The
coinme~ of Pete Doom of the Hazardous aste Section are attached. Pete and I are in
agreeme~t that these reports contain some de~ciera:ies_. It appears that NSCC has not n;iade an
c:ffort to ~vise the conceptual site model oosr1 .on t)ie new information collected. Fot .
exampl(Section 2.4 Summary of Site Char;· teristics; (page 9 of the RD/RA Field ••
Investigations Summary Report) ".presents .gathered '"1(1er the Remedial Investigation and
Feiisibilify. Study coml)leted in June, 1993." rThe site characteristics and the extent of
contamination need to be fully discussed in I t of the new data collected.
' . .
: ~;addition to the Superfund requirellfnts, NSCC's work must meet the conditions of a
RCRA a4ministrative order. Pete Doom re eiits that we either meet or set up a conference
,f',O, Eiox 27687,
Raleigh. Nprth Carolina 2~6II·/6ll/
Vol~e 919-733·4996 .
NfJ(;
½'fdbtdd&P
FAX [phone]
M ~quol Opportunity Al1irmotive Action Employer
50% recycled/la)(, post-consumer paper
Mr. Jon Bomholm
May 9, 1997
Page2. •
call to ~cuss how the RCRA requirements ~re being addressed. Let me know which you
. would p~fer after you've reviewed our com'' ent~. lean he reached at (919) 733~2801,
extension 349. • · . .
; .· ·~
A~chmeilt
cc: Oroyer Nid1ulsuu Bruce Nicholson
/ /
I • Jj)av1d J. Lown
Jpnvironmental Engineer r-
1
·-·
NC SUPERFUND SECTION Fax:[phone]
-State .of North Caroll• _Qepartmont \of Envlr(Wnent, ·. Heoftti anq Natural Resources
·. Dlvlslq~ of Waste Management
Jamei;o, Hunt, Jr., Govt:tmor
J~nathon B. Howes, Secretary W11llom:L. Meyer, Director
I\{ar 8, 1997
May 9 '97 14:32 P.03105
' • i ..• . ' . . . . : '•, . ·. t .. · .. . . -----DEHNR
MEM RAND.UM
TO: Dave Lown, Superfimd Sect on
Pete Pool Hazardous Was e Section
. SUBJE¢T: Draft ~IRA Field lnvestig4tion Summary Report ~d
Draft Conceptual Design and Preliminary Design·Report for OU3
Natioilal Starch and Chem41 Company Site (NCD 000 623 116)
SalisbllIY, North Carolina ] .
I have fyaluated the March 1997 Draft. RDfiRA Field fuvestigation Summary Report and the . March :¥997 Draft Conceptµal Design lll!d 1/reliminary Design Report for OU3 for the above
referen;ed facility. llased. on my evaluatio,. the following comments arc provided:
DRAFT. RP/RA INVESTIGATION ~UTY REPORT
Item . · Comment
,, ,.
Hgs 2-i, 2-3 These figures should be ame~dep to include a legend to identify the scale of the
map, symbols, location ~f th[ ~Ian'., c~ntour interval, and reference. datum.
Sect. 2A-The first paragraph of this seption indii:ates that tbe "Summary of Site . Charac..ieristics" portion of tbp report (!oes not include the dara collected as part
of the 003 RD/RA Field InVF5tigatioDS . .It is recommended that National Starch & Chemical Companyr(NSCC) amend the summary of site c~teristics
to include the data collected t part of.the RD/RA Field Investigations. ·
Sect. 2.4. l This section, titled 'Site Soi1J~11aracterization", lists the contaminarns and 1heir concentrations in the soil. This,section sliould also contain a description of the type of soil (from ground surface to water table) including propertie6 such as
background chemistry, pcrm6ability, classification, grain size, etc, . I ,
Table 27.1 The term "frequency of dete➔ion'' should be more clearly defined.
':r.o. Box 27687:
Raleigh, North Carollno27611-7687
Votp::,, 919 .. 7~~-4~
'
'
:-.:C.Ji;X ~~ ,11.<' <.:._-,.:.v :0:, , . . '..... .
rAX 919-715-3605
An Equal Opportunity Affirmative Action Employer
50% ~e<;"ycled/10".4 pos.t:<:e>n!iumQr papgr
NL c-Ur'l:.l<t-UNJJ ::it.CllUN t-ax :y1y-(j,5-4oll May ~ ·~r 14:33 P.04105
Tahle 2-1
Sect. 2:4.2
S_ect. 2.:4.4
Figs 2-7., 2-8
Sect. 4.)
Sect. 5.2
•-
It. is recommended that the in~rganic analytical results be grouped to distinguish
up-grililient ( or background) concentrations from down-gri!ilient concentrations. This may help NSCC examine the inorganic constituents that ·are naturally occurring.
The s<:etion titled "Sile Oro dy.atcr Cb.a.raclt:rislics" provides information on
the number and types of s ling points and the name and concentration of contaminants (excluding the _ormation generated during this investigation). It is reco_mmended that section be .amended to include (1) the information
generated during the RDIRA\ Field Investigation for OU3, as noted above, and
(2) a description of the up-grdient (or background) ground-water quality conditions. .
This s!)Ction, titled "Hydrog logical S<itting", provides a brief dcscriptiou of some of the aquifex characte~istics. As noted above, it is recommended that · NSCG. include the informati9n developed during this investigation. It is .
recommended that this sectiI also include:
1. ipotentiometric maps rJhe difft:rtmt wut:S uf lhtl aquifer, and cross-, · : sectiooal flownets of e.site;
2. . · .. an analysis and disc~sicin of fracture -trends and other preferential
· pathways for ground-jwa~r flow;
3. · .a description of discharge and recharge zones at the site;
4. , descriptions of di.a. ,et1 aquifer wnes (e.g., shallow, saprolite, & deep); 5. an interpretation gf ntaminant flow in the aquifer. : // .
The cross-section and cross-
1
· on location map ure missing. ·
· fhis section describes eacb of the packer tests, however, it does not include an explanation. of how the data i-~late to the conceptual mcvfol of thP. $lte It is recommended that NSCC include a description of any patterns that relate geologically differeut zones Jith difft:rt:ul Mpecific capacities. If any such
patterns existed, this information would h~lp NSCC understand preferl!ntial pathwi!ys for ground-water mov~ment, and if tbese zones may be used to help
remediate the contaminated 1ound-water.
The cables in this section o~J~ounilwa_ ter Quality Results" indicate that signifi¢ant amounts of con . · ants-(specifically 1,2-DCA) were detected in the 160-200' zone in the bedroc~wells NS-50, NS-52, and NS-54, which are down-
gradieiit of the lagoons .. Furtp.e~ characterization of the nquifer and further delineation of the extent of cqntamination are necessary. .
I In section 5.2, titled "Resultsiof Step-Drawdown Tests", tables 5-11 through 5-20 contain drawdowa and distance measurem.ents from pumping and observation wells . .Accordin<> to these tallies, sevefl. of the ten extraction wells influenced at , o I .
2
-. I~..... vvr t:.J\1· VI ~J.J VC.L. I .1.UI~ r dA • :,J, :,-1 , .. h.>-... OJ. J. • ---,---------8
least three observation wells. However, the distance/drawdown plots (Figs. 5 1 through 5-9) only illustrate t)le .two endpoints used to determine the slope. The dope should lx: uel.t:rmined vom a line that best fits the cirawctown data from all the affected observation we,.
• I
. : Furthermore, examining the ~otn from all the observation wells uiay provide • __ ·. NSCC with information abo] preferential interconnections (e.g., fractures) , between wells. . .
. .
Sect. 8_: 1, 8.2 Chapter 8.0 is titled "Vert· , Extent of Groundwater Contamination", and · sections 8.1 and 8.2 spccill<f1Y dc~1;ribe Ari:a Zand the Lagoon 2 area, respectively. These sectio~l~.f the document report the facts of the investis,at~n, but contain no ~escripiion of the extent of gro~d-water contamination. The report s~ould include up-to-date c.o:ntnmmnnt plume maps/cross-sections and a discussion of the movement of the plume. ·• I . . ·. I . If NSCC is to meet their obMcfive of determinin2 the extent of ground-water contamination, additional chijracterization of the aquifer and delineation of the contaminant plume are necessary. . I
-DAAFf CUNC.l:iP'l'~AL DESIGN AND PfllMINARY DESIGN REPORT
. .: t ~ Comment i
S~t. 3.'l .This section, titled 'Design Jasis", states.that 120,000 gallons of contaminated ground'water will be pum~ from the new extraction wells for OU3. NSCC shoul(specify that the propo~ed extraction rate Is 120,000 gnl/dny .. • . I •. '
This ponion of the draft desi~ report also states that·" [AJt tbis rate of pumping the gr?undwater ~action s~stem is e)(pected to ha~e an area of influence cover~g the contanunated grrundwater plume". It IS recommended that NSCC omeod:or omit this sentence fprthc following reasons: 1) in the draft RD/RA report,.NSCC demonstrates that the extent of ground-water contamination has not been delineated; and 2) ttJe 10 extraction wells have not been pumped ' simultaneoll~ly to evaluate th~ t~1mulative effect that the system will have on the aquifer: Consequently, NSCC has not provided information to substantiate this claiu1 ~buut the performance r their ground-water extraction system.
re: Sharron E, Rogers
3
• • USEP A SUPERFUND PROJECT
OPERABLE UNITS THREE AND FOUR ( OU3 AND OU4)
AT
NAME
R1'; P 11 r:__.4 -., •. , v) x.,
;Tov'-6or-'kolv\\.
CEDAR SPRINGS ROAD PLANT SITE
SALISBURY, NORTH CAROLINA
PROJECT KICKOFF MEETING
Friday, October 4, 1996
SIGN IN SHEET
ORGANIZ \ IIQN TITLE TELEPHONE
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• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4WD-NSRB
Dr. Abu M. z. Alam
National Starch & Chemical
10 Finderne Avenue
P.O. Box 6500
345 COURTLAND STREET, N.E.
ATLANTA, GEORGIA 30365
February 27, 1996
Company
RECE!VEr
FEB 2 9 1996
SUPERFUN0 SECfir·
Bridgewater, NJ 08807-0500
SUBJ: Sampling of Trench Area Extraction Wells at the Nati,,nal Starch & Chemical Company Superfund Site
Dear Dr. Alam:
The Agency acknowledges that National Starch & Chemical Company (NSCC) will collect groundwater samples from the six extraction wells associated with the Trench Area the week of February 26, 1996. The Agency has elected not to split these samples with NSCC. However, has discussed over the telephone, NSCC will transmit to the Agency a copy of the analytical data for these samples when it becomes available.
If you have any questions, please call me at [phone], x-2053.
Sincerely yours,
Ir'~~
Jon K. Bornholm
Remedial Project Manager
cc:· David Lown, NCDEHNR
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENJ:"'I'~==-----=::---,
REGION JV RECEIVED
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
April 14; 1995
URGENT LEGAL MATTER
_Alexander M. Samson, Jr., Esquire
··counsel, Regulatory Affairs
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807-0500
SUBJ: National Starch & Chemical Company Site
Operable Units #3 & #4
Salisbury, Rowan County, North Carolina·
Dear Mr. Samson:
APR 1 91995
SUPERFUND SECTION
The purpose of this letter is to confirm Thursday, April 27,
1995, at 1:00 p.m., here at Regional Headquarters as the time and
place for negotiations between the United States Environmental
Protection Agency and National Starch & Chemical Company
("National Starch") concerning National Starch's Good Faith Offer
of March 2, 1995.
~/-f~L
Stedman S. Southall
Assistant Regional Counsel
cc: Robert Homiak, Trial Attorney
Environmental Enforcement Section
Environment and Natural Resources Division
U.S. Department of Justice
P.O. Box 7611 .
Ben Franklin Station
Washington, D.C. 20044
David Lown
NCDEHNR/DSWM/Superfund Section
Suite 150
401 Oberlin Road
Raleigh; North Carolina 27605
Printed on Recycled Paper
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
March 20, 1995
David Lown
NCDEHNR/DSWM/Superfund Section
Suite 150
401 Oberlin Road
Raleigh, North Carolina 27605
SUBJ: Prospective Negotiations
National Starch & Chemical Company Site
Operable Units #3 & #4
Salisbury, Rowan County, North Carolina
Dear Mr. Lown:
RECEIVED
MAR 211995
~UPERFUND SECTION
The purpose of this letter is to inform you of the
status of the above matter and determine your availability to
participate in forthcoming settlement negotiations. On March 2,
1995, National Starch & Chemical Company (National Starch)
responded to the Agency's January 6, 1995 Notice Letter with a
Good Faith Offer (see attachment). The Region is in the process
of reviewing the March 2, 1995 Good Faith Offer. Once the Region
has completed it's review of the Offer, it will schedule a
settlement negotiation session with National Starch. Mr. Jon
Bornholm of our technical program has informed me of your
interest in participating in any forthcoming negotiations. You
are invited to participate in any prospective negotiations with
National Starch. If your schedule does not permit your active
participation in the negotiations, the Region will keep you
informed of the negotiation's progress.
If you have any questions, please feel free to call m~
at telephone number [phone] (ext. 2278).
~4.~
Stedman S. Southall
Assistant Regional Counsel
Attachment
I
I
•
Printed on Recycled Paper
State of North ~lino
Department of~ronment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
_February 16, 1995
Mr. G. Alan Farmer, Chief
RCRABranch
Waste Management Division
US EPA, Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Attention: Ms. Beverly F.Williams.
Reference: Closure Plan
National Starch and Chemical Company
Salisbury, North Carolina
EPA ID No. NCO 000 623 116
Dear Mr. Farmer:
Enclosed is a copy of the closure plan for three units at the National Starch and Chemical Company
located in Salisbury, North Carolina. This facility is primarily being handled under a CERCLA Record
of Decision (ROD) for the soil and ground water contamination, however, the Hazardous Waste Section
is involved to close three units which were determined to be contaminated with dichloroethane: Lagoon
#2, a 65,000 gallon storage tank, and an old sludge drying bed. Due to the existing soil and ground water
contamination at the site, the closure will be handled as closure with waste in place. As such, there will
be some requirements which are normally required to be detailed in a closure plan, such as confirmatory
sampling of surrounding soil, that will be considered Not Applicable in this case. Additionally, some of
the requirements will be met by reference to the work being conducted under the ROD.
If you have any questions, please contact Marti Morgan at [phone].
Sincerely,
~ --/' L ~ C.-
Daniel L. Bius, Acting Chief
Hazardous Waste Section
DLB/MTM/6.wp5(1)
Enclosure
cc: William F. Hamner
•Bruce:Nicholson"" r•,
Steve Parascandola
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
State of North &lino
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
• .,,A~~ ,800 ----J~ p'-...
C C ft Ftil
DEHNR James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
February 16, 1995
Mr. Ray E. Paradowski
Plant Manager
. National Starch and Chemical Company
Post Office Box 3 99
Salisbury, North Carolina 28145-0399
Reference: Closure Plan
National Starch and Chemical Company
Salisbury, North Carolina
EPA ID No. NCO 000 623 116
Dear Mr. Paradowski:
This acknowledges receipt on February 10, 1995 of six (6) copies of the Closure Plan for Lagoon #2, the
65,000 gallon storage tank, and the old sludge drying bed. A review ofthis material will be completed as
soon as possible.
If you have any questions, please contact Marti Morgan at [phone].
Sincerely,
}J_
William F. Hamner, Ph.D., Head
Permitting Branch
Hazardous Waste Section
WFH/MTM/6.wp5(2)
cc: Daniel L .. Bius
Stephen E. Phibbs
BruceNicholson=-:7
Stephen T. Parascandola
Martha T. Morgan .
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]. FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post•consumer paper
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY.
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
, (t t :ttV,tlJ
SEP 13 1993 '.)[P 1 ,) l!:l:JJ
-;uPERFl!Nf' SECTION
4WD-NCRS
Mr. Alex Samson
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
RE: ~lti.rn""ffl.~ on the Quarterly Report for the Second Quarter for
1993 for (Operabl.§!_Units_#J) and #2 for the National S-::arch &
Chemical Company Superfund Site
Dear Mr. Samson:
The Agency received five bound and one unbound co::,ies of the
document referenced above on July 19, 1993. I shared copies of
this reoort with the State of North Carolina Deoartment of
Environment, Health & Natural Resources and Winston -Smith, EPA-
Ground-Water Technology Unit. Below are comments contrived as a
result of our review of this docu..ment. I am sharing these comments
with you in the hope that our concerns will be addressed in future
Quarterly Reports. I am not requesting that National S-::a.rch &
Chemical Compan.y (!'lSCC) or IT Corporation (IT) revise the July :6,
1993 Quarterly Report for the Second Quarter for 1993 for Operable
Uni ts # 1 and ~f:2 d.oc'.-1.men-:..
1. Page 1, first paragraph: A sentence should be added-to this
paragraph stating that the sarnples were collected in
accordance to EPA, Region IV protocols (i .. e., in accordance
to the procedures specified in the EnviroI1r.1ental Comoliance
Branch Standard Operatina Procedures and Quality Assurance
Mam:2.J., dated February 1, 1991 (EPA, Region 4, SOP)). This
2-s ass1irn:~ng that the samples were collected in accordance t.o
these procedures. If they we:r:e not, they will be i~ the
future.
2. Page 1, first paragraph: A phrase or sentence should be added
to th5_s pa.ragraph stating how long extraction wells EX0l and
EX04 have been off-line prior to the samples being
collected.
Printed on Recycled Paper
• •
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3. Page 2, first paragraph: This paragraph needs to b.e expanded
to included a discussion on the efficiency/adequacy of the
groun<iwater extraction system (i.e., is the plume being
capture?). I realize that this may not have been possible
in this report since extraction wells EXOl and EX04 are
currently not in operation.
4. Page 2, second paragraph: What was done to remove the "black
substance" from the extraction wells? Was any maintenance
procedures implemented to prevent the build of this "black
substance" in the extraction wells in the future? Was this
"blac:cc substance" analyzed to confirm that is i:con and
. . ? Tf h ? 1 d. ~ ' . manganese precipitates. _ not, w. y not. Wou~ no•-t.'.lis
informat:'._on help is developing some type of main-'::e:nar:ce
procec·.,.-.:·:"e?
5. Page 2, third paragraph:
incorporat :_:-:,_g language
pc.ragrapl:..
Refer to comment number 1 about
about sampling pr0tocols in this
6. ~age 2, :f:5_::th paragraph: This paragraph !leeC.s to ~e./:e 50::-1:1.e
effor<: in comparing the results of the second qu2.r'.:er
sa.rrtp_1_.:_nq res1il ts to the f i::-st quarter s B.m9l3_n.g res,.,-._J_ "':s e. s
wa.s c.o:'.le '.n the last paragraph on page l.
As stated above, I am not requiring a revised document. The above
corrm1ents ca:'.l be addressed in next Quarterly Report.
If you have 2.,:,.y C''J.estions, please feel free to call me at ( 4 04) 34 7-
779 l.
Sincerely yo11-rs,
Jon K. So~r:-.:lo~m
Remedia~ ?~ojec~ Y~~ager
cc: Han~ Graulich, NSCC
Br~ce ~ic~olson~ NCDE?~R
Ray Par2.dows\:i, NE-CC
Ki~ty~el:e Rivera, EPA
~~T.:~nston S::-r.ith, EPA
~ic~ael S~ur~evant, IT
• • UNITED ST ATES ENVIRONMENTAL _PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E
ATLANTA. GEORGiA 30365
JAN 1 fl 1993
4WD-NSRB
John Vest/ Phil Dearman
City of Salisbury
P.O. Box 479
Salisbury, North Carolina 28145-0479
Re: National Starch & Chemical Company Site
Salisbury, North Carolina
Addendum to Final Design
Dear Gentlemen:
JAi~ 2!.l l:.J'JJ
SUPERRIND Sf CTI ON
National Starch & Chemical Company has been tasked to update
the Draft Final Operation and Maintenance (O&M) Plan since
it predates the Final Addendum to the Final Design Report.
The revised Draft O&M Plan is due to EPA on February 19,
1993. I am enclosing a copy of the previous O&M Plan for
your reference. If you have any questions or concerns,
please contact me at 404/347-7791 or fax number
404/347-1695. As always, your input is appreciated.
Sincerely,
~~
0
c«,-;'1/;7,;717,,.,/
Remedial Project Manager
Waste Management Division
Enclosure
cc: Curt Fehn, EPA
Rick Leahy, EPA
Bruce Nicholson, NC-DEHNR ,._,...,
Alex Samson, NSCC
Ray Paradowski, NSCC
Hank Graulich, NSCC
Mike Sturdevant, IT
Punted on Rec_vctca r:>aper
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGiA 30365
;JAN 1 9 1993
4WD-NSRB
Alex Samson
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch & Chemical Company Site
Salisbury, North Carolina
Operable Unit 1
Dear Mr. Samson:
The Draft Final Operation and Maintenance (O&M) Plan predates the Final Addendum to the Final Design Report and must be revised to incorporate the Combined Pretreatment System. The revised Draft O&M Plan is due to EPA on February 19, 1993. Please note that the groundwater monitoring shall include analysis for all contaminants identified on page 19 of the Record of Decision. Initial monitoring frequency will be quarterly for the first year. All monitoring wells will require sampling during this period to adequately develop the long-term monitoring program. The O&M Plan shall be written in accordance with Unilateral Administrative Order (UAO) No. 89-32-C, Section V. Enclosed is an excerpt from the UAO highlighting specific items which shall be addressed within the O&M Plan in addition to those previously included.
Please do not hesitate
concerning this letter.
number 404/347-1695.
to contact me if you have any questions
I can be contacted at 404/347-7791 or fax
Sincerely·, . )
/) ··; /' // ;/ ·-.--•: // . . \..J;1_ . .-./. .·. -· -;;-c. ... __ .o· .. ·-·1·· / I /1 ,. (I_/,-\._/ •. , . .-_._,_
·a;;b~;a -~ .-~eno~ --/;
Remedial Project Manager
Waste Management Division
cc: C. Fehn, NCS
W. Smith, WD
R. Paradowski, NSCC /
B. Nicholson, NCDEHNR
J. Vest, City of Salisbury
R. Leahy, ORC
H. Graulich, NSCC
M. Sturdevant, IT
J, Cole, CDM
P. Dearman, City of
Salisbury
Pnntvo on Hecych~lJ f'.1per
• • Based upon the Findings of Fact, Conclusions of Law, and Determinations,
the PRP is hereby Ordered to implement the following measures under the
direction of EPA's Superfund Project Manager:
A. The PRP shall finance and perform the implementation of the Work as
defined by the ROD and further defined by this Order. "Work" means
the design and construction of the Remedial Action as set out in the
September 30, 1988 ROD for the National Starch site and all other
tasks to be performed by the PRP pursuant to this Order. "Site• means
the National Starch facility which encompasses approximately 500 acres
at Cedar Springe Road, approximately five miles south of the city of
Salisbury, Rowan County, North Carolina. The coordinates are 35• 37'
05"N latitude and so• 32' o•w longitude and any further areas
designated by EPA.
B. The PRP shall design, implement and complete the Work in accordance
with the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP), as set forth in 50 Fed. Reg. 47912 (1985) (effective
February 18, 1986), and all amendments thereto that are effective and
applicable to any activity undertaken pursuant to this Order, and also
in accordance with the standards, specifications, and schedule of
completion set forth in or approved by EPA pursuant to this Order.
All Work shall be performed by qualified employees or subcontractors
of the PRP in accordance with the schedule in Subparagraph D below.
(Except where noted otherwise, all dates referred to in the schedule
are calendar days; however, should a deadline fall on a weekend or on
a Federal holiday, the deadline shall be construed to continue to the
next business day.)
c. Requirements for the Work:
1. All work performed pursuant to this Administrative Order shall be
under the direction and supervision of a qualified professional
engineer or a certified geologist with expertise in hazardous
waste site cleanup. Prior to the initiation of the Site work, the
PRP shall notify EPA in writing regarding the identity of such
engineer or geologist and of any contractors and/or subcontractors
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I
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• • to be used in carrying out the requirements of this Order and the
ROD. The selection of an engineer/geologist and/or contractor(s)
shall be completed within 30 days of the effective date of this
Administrative Order.
2. The Work consists of:
a) The design, construction and operation of a groundwater
extraction and possibly a treatment eystem. The groundwater
extraction system is to remove the contaminants in both the
eurficial and bedrock aquifers throughout the plume and
prevent the contaminated groundwater from migrating from the
site.
i) The level and degree of pretreatment of the extracted
groundwater will depend on the effluent limits set by the
Publicly owned Treatment Works (POTW). The range of
pretreatment for the extracted groundwater includes air
stripping, filtration through activated carbon filter,
metal removal, and treatment through the company's existing
.lagoon eyetem. The extracted groundwater will be
discharged to the Salisbury POTW. Groundwater remediation
will be performed until all contaminated water meets all
applicable and relevant or appropriate requirements
(ARARs). In the possibility that a mutual arrangement
cannot be reached between National Starch and the POTW to
accept the extracted groundwater, treated or untreated, the
extracted and treated groundwater will be discharged to a
local surface stream under a NPDES permit.
b) The design and implementation of a monitoring eyetem. The
monitoring system includes both groundwater and surface
waters. The groundwater monitoring system will include
existing monitor welle and the installation of additional
monitor wells if necessary.
3. Groundwater Extraction System
A •zone of capture• shall be established within the vertical and
lateral boundaries of groundwater contamination. This boundary
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• • shall be determined by groundwater monitoring. The zone of
capture shall encompass the area of the Site in which groundwater
monitoring indicates contaminant levels in excess of the
groundwater remediation levels identified on Page 19 of the ROD.
4. Hydraulic Gradient
The PRPM shall.maintain the zone of capture by ensuring a
hydraulic gradient from within the edges of the boundaries of
groundwater contamination by pumping the extraction wells. The
PRPs shall monitor water levels to ensure that a proper hydraulic
gradient is maintained.
5. Groundwater Discharge
a) All water from the groundwater extraction system will be
treated to the extent necessary as determined by its ultimate
discharge; either to the POTW, or if the POTW is not
available, to a sur·face stream via a NPDES perm.it.
i) If an on-site treatment system is necessary, then during
start-up activities, extracted water to and from the
treatment plant will be checked on a schedule as provided
for in the Operations and Maintenance Plan submitted in
accordance with Subparagraphs D.4 and D.7.
ii) During routine operations, the treatment. plant discharge
must meet federal and state standards for the type of
discharge used on a daily basis based on a sampling
schedule to be presented in the Operation and Maintenance
Plan developed by the PRP pursuant to Subparagraphs D.4
and D.7 and shall include compliance monitoring programs
to demonstrate continued compliance with the requirements
of this Subparagraph C.5. Any measurable noncompliance
with these levels shall be reported orally to EPA within
forty-eight (48) hours of discovery. A written submission
shall also be provided within five (5) days. This
submission shall include a description of the
noncompliance and its cause; the period of n·oncompliance,
including the dates and times, and, if the noncompliance
has not been corrected, the anticipated time it is
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• • expected to continue; and steps taken or planned to
reduce, eliminate and prevent re-occurrence of the
noncompliance. Complying with these reporting
requirements shall not excuse any penalties resulting from
the noncompliance.
b) Air stripping may be used to reduce volatile organic compound
("VOC") contamination. Depending on the levels of voes being
emitted, air stripping towers may need to be equipped with air
emission controls to meet federal, state and local standards.
6. The PRP shall continue operation of the Work until EPA modifies or
terminates this Order.
D. Schedule for the work
l. If the PRP determines it is necessary to remove the present
engineer/geologist/contractor(s) from the Site work during the
RD/RA process, then a full account and rationale for making this
change should be submitted in writing to EPA within 10 working
days of the dismissal of the present engineer/ geologist/
contractor(s). A change in engineer/geologist/contractor('s) shall
not relea·se the PRP from maintain~ng and meeting the requirements
and deadlines/schedule as specified below.
2. Within 60 days after the effective date of this Order, the PRP
shall submit a conceptual design for the Remedial Action (30% of
complete final design). The conceptual design shall include, but
not be limited to, the following:
a. Efficiency of present groundwater monitoring system and the
selection of any additional monitor wells
b. Results of POTW discussions; tre_atment requirements
c. Location of monitoring stations on surface streams
d. Design analysis, including analysis and reporting mechanisms
necessary to satisfy state permitting requirements
e. Location of extraction wells
f. Major equipment list for treatment plant (if necessary)
g. Approximate pumping rates for all wells
h. Site plan (piping/layout)
i. Easements
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j. • • Piping and flow diagrams for treatment plant (if necessary)
and extraction system
k. Ancillary equipment (substations, etc.)
3. EPA shall review and approve/disapprove the conceptual design.
4. Within 120 days after the effective date of this Order or 30 days
after EPA's decision to approve/disapprove the conceptual design,
whichever is later, the PRP shall submit final draft design_and
specifications. These shall include, but not be limited to:
a. Design analysis
b. Piping and instrument diagram for the treatment plant and
extraction system.
c. Location of additional monitor wells
d. Specifications for the treatment plant and groundwater system
sufficient to comply with the treatment plant discharge
requirements and zone of capture !equiremente of Paragraph v.
e. QA/QC Plan
f. Worker Health & Safety Plan
g. Prel_iminary Construction Operation and Maintenance Plan
h. Preliminary Groundwater Treatment Operation and Maintenance
Plan Including:
i) Recommended frequency of water level measurements and
water quality testing for extraction and monitor wells.
These shall include separate schedules for start-up and
routine operations.
ii) Proposed decision making process and criteria for shutting
down specific extraction wells.
iii) Recommended frequency for testing of air emissions during
start-up and routine operations, if a air stripper is
used.
i. Construction schedule and phasing.
5. EPA shall review and approve/disapprove the final draft design and
specifications.
6. Within 180 days after the effective date of this Order, or 30 days
after EPA's decision to approve/disapprove the final draft design
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• i • and specifications, whichever is later, the PRP shall begin
construction of facilities for implementation of the Remedial
Action. The PRP shall initiate preconstruction activities during
EPA review of the final draft design and specifications.
7. Withi"n 210 days after the effective date of this Order, or 60 days
after EPA's decision to approve/disapprove the final draft design
and specifications, whichever is later, the PRP shall submit final -
draft Operation and Maintenance Plane to EPA for approval.
8. Within 250 days after the effective date of this Order, or 100
days after EPA'e decision to approve/disapprove the final draft
design and specifications, whichever is later, the PRP shall
commence start-up activities.
9. The PRP shall begin and thereafter maintain routine operation
activities in accordance with an approved Operation and
Maintenance Plan by a date to be established by EPA.
E. Monthly Progress Reports
The PRP shall provide written progress reports to EPA on a monthly
basis. These p~ogress reports shall describe all actions taken to
comply with this Order, including a general description of the Work
activities commenced or completed during the reporting period, Work
activities projected to be commenced or completed during the next
reporting period, the results of any analysis performed, and any
problems that have been encountered or are anticipated by the fRP in
commencing or completing the Work activities. These progress reports
shall be submitted to EPA by the 10th of each month for work done the
preceding month and planned for the current month.
F. Reports, Plans·, and other Items
1. Any reports, plans, specifications (including discharge or
emission limits), schedules, appendices, and attachments required
or established by this Order are, upon approval by EPA,
incorporated into this Order. Any noncompliance with such EPA
approved reports, plans, specifications (including discharge or
emission limits), schedules, appendices, or attachments shall be
considered a violation of this Order subject to penalties in
accordance with Paragraph XII of this Order.
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• I • 2. If EPA disapproves any plans or reports (other than monthly
progress reports) or other items required to be submitted to EPA
for approval pursuant to this Order, the PRP shall correct any
deficiencies and resubmit the plan, report or item for EPA
approval within thirty (30) calendar days from the receipt of such
disapproval.
3. Submission of a deficient plan or report is a violation of this
Order au_bject to penalties in accordance with Paragraph XII
whether or not resubmission corrects the deficiencies of the
original submission.
4. In attempting to correct any deficiency as required by
Subparagraph V.F.2, the PRP shall address and incorporate all of
EPA• s comments.
G. The Worker Health and Safety Plan that the PRP is required to submit
pursuant to Subparagraph V.D.4 shall satisfy the requirements of the
Occupational Safety and Health Guidance for Hazardous Waste Site
Activities [OCtober 1985 (DHH 5 NIOSH) Publication No. 85-115] and all
amendments thereto that are effective and applicable to any activity
undertaken pursuant to this Order and EPA'B Standard Operating Safety
Guides.
H. The PRP shall submit to EPA for approval, at the same time as it
submit~ the final draft design documents in accordance with
Subparagraph V.D.4, a Quality Assurance/Quality Control ("QA/QC") Plan
for Remedial Construction activities. The Remedial Construction QA/QC
Plan shall, where applicable, be prepared in accordance with current
EPA guidance, Interim Guidelines and Specifications for Preparing
Quality Assurance Project Plana, QAMS-005/80, and subsequent
amendments to such guidelines and EPA, Region IV, Engineering Support
Branch, Standard Operating Procedures and Quality Assurance Manual
dated April 1, 1986, as amended, upon written notification by EPA to
the PRP of such amendments. The Region IV manual takes precedence
over other QA/QC manuals/guidance.
Additionally, the Remedial Construction QA/QC Plan shall include
elements necessary for the implementation of trial test(a) of the
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• • pumping and treatment systems used as part of the Work. The Remedial
Construction QA/QC Plan shall include a description of the mechanism
that shall be used to verify that the pumping and treatment process is
operating within acceptable limits. Upon approval and notice by EPA
to the PRP, the PRP shall implement the Remedial Construction QA/QC
Plan.
I. The PRP shall utilize QA/QC procedures in accordance with the QA/QC
plans submitted pursuant to this Order, and shall utilize standard EPA
chain of custody procedures, as documented in National Enforcement
Investigations Center Policies and Procedures Manual, as revised in
November 1984, the National Enforcement Investigations Center Manual
for the Evidence Audit, published in September 1981, and EPA, Region
IV, Engineering Support Branch, Standard Operating Procedures and
Quality Assurance Manual dated April 1, 1986, as amended, for all
sample collection and analysis activities. The Region IV manual takes
precedence over other manuals/guidance pertaining to collecting
samples. In order to provide quality assurance and matntain quality
control regarding all samples collected pursuant to this Consent
Decree, the PRP shall:
1. Ensure that all contracts with laboratories utilized by the PRP
for analysis of samples taken pursuant to this Administrative
Order provide access to EPA personnel and EPA authorized
representatives to assure the accuracy of laboratory resuits
related to the Work.
2. Ensure that laboratories utilized by the PRP for analysis of
samples taken pursuant to this Order perform all analyses
according to EPA methods or methods deemed in advance satisfactory
by EPA. Accepted EPA methods are documented in the "Contract Lab
Program statement of work for Inorganic Analysis" dated July 1987
and as amended and the Contract Lab Program Statement of Work for
Organic Analysis" dated October 1986, revised in January 1987,
February 1987, July 1987 and August 1987 and as amended in the
future.
3. Ensure that all laboratories utilized by the PRP for analysis of
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eamplee taken pursuant to thie Order participate in an EPA or EPA
equivalent QA/QC program. Ae part of the QA/QC program and upon
request by EPA, euch laboratories shall perform analyeee of
eamplee provided by EPA to demonstrate the quality of each
laboratory's data.
J. The PRP shall demonstrate their ability to complete the Work and to
pay all claims that arise from the performance of the Work by
obtaining and presenting to EPA for approval within thirty (30)
calendar daye after the effective date of thie Order, one of the
following items: l) performance bond; 2) letter of credit; or 3)
guarantee by a third party. In lieu of any of the three items listed
above, the PRP may present to EPA, within twenty (20) calendar days
after the effective date of this Order, financial information
sufficient to eatiefy EPA that the PRP hae sufficient aeeete to make
it unnecessary to require additional assurances. If the PRP relies on
financial information for financial assurance, the PRP shall quarterly
submit such financial information. If EPA determines the financial
aesurancee to be inadequate, the PRP shall obtain one of the three
financial instruments listed above.
K. The PRP shall maintain a segregated account dedicated to funding the
PRP'e obligations pursuant to this Order. Starting September 1, 1989,
the PRP shall quarterly submit an account statement to EPA
demonstrating that the account ie funded adequately to ensure
performance of the PRP'e obligations under thie Order for the
following quarter.
L. The PRP shall submit a quality aeeurance report to EPA on a quarterly
baeie on September let, December let, March let, and June let of each
year. Thie report shall contain information that demonetratee that
the PRP ie complying with Subparagraph V.I of thie Order and the QA/QC
Plane submitted pursuant to thie Order.
M. Any analytical or design data generated or obtained by the PRP that
are related to the Work shall be provided to EPA within seven (7) daye
of any request by EPA for euch data.
N. EPA employees and EPA'e authorized repreeentativee shall have the
right, upon request, to take splits of any eamplee obtained by the PRP
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or anyone acting on the PRP's behalf in the implementation of the
Work. The PRP shall also have the right upon request to obtain splits
of samples taken independently by EPA or its authorized
representatives.
o. During design, Construction, and start-up activities, the PRP shall
notify EPA seven (7) days prior to any sampling conducted by the PRP
or anyone acting on its behalf. EPA shall be notified thirty (30)
days prior to the disposal of any such sample, and EPA shall have an
opportunity, upon request, to take possession of all or a portion of
such sample. The PRP need not provide EPA with 7-day notice for
sampling relating to the routine operation of the treatment system.
Prior to commencement of the routine operation of the treatment
system, however, the PRP shall provide EPA with a schedule for all
routine sampling relating to the operation of the treatment system.
The PRP shall notify EPA seven (7) days in advance of any changes in
the routine sampling schedule. The PRP need not provide EPA with
advance notice of changes in the routine treatment system sampling as
a result of unexpected conditions. The PRP shall, however, notify EPA
within forty-eight (48) hours of the occurrence of any such conditions
and shall provide EPA with the results of analysis of such sampling
when the results become available.
P. All data, factual information, and documents submitted by the PRP to
EPA and the State pursuant to this Order shall be subject to public
inspection. The PRP shall not assert a claim of confidentiality
regarding any hydrogeological or chemical data, any data submitted in
support of a remedial proposal, or any other scientific or engineering
data. The PRP may assert a claim of confidentiality as to any
process, method, technique, or any description thereof that the PRP
claims constitute proprietary or trade secret information developed by
the PRP or developed by the contractor or the contractor's
subcontractors. In addition, the PRP may assert business
confidentiality claims covering part or all of the information
provided in connection with this Order in accordance with Section
104(e)(7) of CERCLA, 42 U.S.C. S 9604(e)(7) and pursuant to 40 C.F.R.
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• •
S 2.203(b) or applicable state law. Any such claim shall be subject
to EPA's confidentiality determination procedures and, if determined
to be confidential, afforded the protection by EPA provided in 40
C.F.R., Part 2, Subpart B.
Documents which are asserted to be attorney work product or subject
to privilege under law shall not be subject to inspection or copying
under this Order provided that, upon request, the PRP shall provide
EPA with an identification of the title and subject matter of each
document for which a privilege is asserted, and an explanation as to
why the privilege is applicable to the document or portions thereof.
Q. The PRP shall preserve and retain all records and documents now in its
possession or control that relate in any manner to the Site,
regardless of any document retention policy to the contrary, foi no
lees than six (6) years after the.completion of the construction of
the Work or termination of this Order, whicheyer is later.
Until completion of the Work and termination of this Order, the PRP
shall preserve, and shall instruct its contractors, its contractors'
subcontractors, and anyone else acting on the PRP's behalf at the
National Starch Site to preserve (in the form of originals or exact
copies, or, alternatively, microfiche of all originals) all records,
documents and information of whatever kind, nature or description
relating to the performance of the Work at the Site. Upon the
completion of the Work, copies of all such records, docum~nts, ·and
information shall be delivered to the EPA Project Coordinator.
VI. Compliance With other Laws·
The PRP shall comply with all federal, state and local laws and
regulations in carrying out the terms of this Order. All hazardous
substances removed from the facility shall be handled in accordance with the
Resource Conservation and Recovery Act of 1976, 42 U.S.C. S 6921, et seq.,
the regulations promulgated under that Act, and EPA'e Offeite Disposal
Policy, OSWER Directive 9834.11 (Nov. 13, 1987).
VII. Project Coordinator
EPA has appointed a Project Coordinator for the Site who has the authority
vested in the Remedial Project Manager and the On-scene coordinator by 40
C.F.R. Part 300, et seq., including such authority as may be added by
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• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA, GEORGIA 30365
OCT 1 4 1992
4WD-NSRB
Alex Samson
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch & Chemical Company Site
Salisbury, North Carolina
Operable Unit 1
Dear Mr. Samson:
(r(fGfijVtRJJ
OCT 1 D 199?.
SUPERFllND sa:TION
This letter provides EPA's final comments on the Monitoring Well
Proposal, September 14, 1992, received from IT Corporation.
EPA recommends moving the location of well NS-31 approximately 300
feet southeast of the proposed site. This location should be as
close as· practical to the southwest tributary and against the
western property line. This location will hopefully intersect any
fractures that may extend under the tributary and along the
drainage that extends in a line with extraction well EX-2 and NS-
26.
EPA also recommends relocating NS-32 approximately 600 feet east-
northeast of its proposed location. This location should also be
located as close as practical to the southwest tributary in an
attempt to intersect fractures extending along the streambed and
downgradient of any existing contamination plume.
Well Depths
The .Ground Water Technology Support Unit has concurred with the
recommendation of total well depths of 150 feet. There is a
.concern, however, that a long open hole ·interval would not be
suitable for groundwater monitoring because of potential dilution
of contaminants·. Note that bedrock monitoring wells on the north
side of the tributary typically have screened intervals ·of only 10
-31 feet. Straddle packer tests of discreet intervals in the open
hole to determine which bedrodk fractures are transmissive to
groundwwater is requested.
Saprolite Samples
Examination of cross sections in the area show the saprolite to be
thin or nonexistent in the vicinity of the southwest tributary •.
NSCC.101392.ASAM.OUlMW
Printed on Recycled Paper
• •
National Starch & Chemical Company Site
Salisbury, North Carolina
Operable Unit 1
October 14, 1992
Page 2
EPA requests sampling the saprolite while drilling and analyzing for volatile organics, specifically 1,2-DCA contamination. If 1,2-DCA contamination is encountered in the shallow saprolite, shallow monitoring wells should be installed.
Please note the following corrections to the monitoring well proposal that would have to be made prior to the installation of additional monitoring wells. The well diagram does not correspond to the text; clarification may be needed. The 2 feet by two feet well pad is not in accordance with the Region IV, SOP, and therefore is not acceptable. Note that all monitoring wells must be installed in accordance with Regiona IV protocol.
If these comments are acceptable, approval of the monitoring well installation plan will be given. A response is requested no later than Monday, October 19, 1992.
Please do not hesitate
concerning this letter.
number 404/347-1695.
to contact me if you have any questions
I can be contacted at 404/347-7791 or fax
SJ;uku J
Barbara H. Benoy ~
Remedial Project Manager
Waste Management Division
cc: C. Fehn, NCS
W. Smith, WD
R. Paradowski, NSCC
B. Nicholson, NCDEHNR✓
NSCC.101392.ASAM.OUlMW
R. Leahy, ORC
H. Graulich, NSCC
M. Sturdevant, IT
J. Cole, COM
' '
. ,.. . ..
\ I .
I
~
' '
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
NOV• 2 ·1992
4WD.::;NSRB·
Alex Samson
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: .National .Starch .. & Chemical
·Sail:isbury,, North: Carolina
Operable Unit ·L
Dear •Mr· •. Samson:
Company Site ... ' .. ·
~IECf~~rs,a])
NOVO G 1992
SUl'ERffl~DmOI\\
_::i:::
;-; •• , E ;!·,:rr:cuThis":let'l:er::d.;s •.,•iiTt:response to M. Sturdeivant:',s~• ,letter .. ,of:. :101/·29'/ 92i•:
.i:.:.1brc ::concerning,;;me,thodsxfor;,installation of NS,"3•b:and::·NS'-'32 :.t:·:.·According.r. ··.: 'c ,.::: : :
.i .. .s .. c,. :. &01;Mc;.;,S.turdeyant:;'.:.Winston.:Smith is now satis,fi.ed:::tliat"•Paclcer:.:.tests". ;,: · ·
,are not necessary. I do not have confirmation on this, but will
:1 assume this is the case until I can speak to Winston. Sampling
must be conducted in accordance to the Environmental Compliance
Branch Standard Operating Procedures and Quality Assurance Manual,
2/1/91, (Region IV SOP). Note that all procedures must be in
accordance to the Region IV SOP.
The saprolite soil samples should consist of the samples collected
just above the water table. No head space analysis need be
conducted.
Please do not hesitate
concerning this letter.
number 404/347-1695.
to contact me if you have any questions
I can be contacted at 404/347-7791 or fax
Sincerely, ~ ·
Qa:J!r.~:~oy ~-
Remedial Project Manage!
Waste Management.Division
cc: C. Fehn, NCS
W. Smith, WD
R. Paradowski, NSCC
B. Nicholson, NCDEHNR ✓
NSCC.11292.ASAM.OUl
R. Leahy, ORC
H. Graulich, NSCC
M. Sturdevant, IT
J. Cole, CDM
Printed on Recycled Paper
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGiA 30365
OCT D 1992 rtt..tt\~tU
uG T 1 (i 199'2 4WD-NSRB
Alex Samson
National Starch & Chemical Company 10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch & Chemical Company Site Salisbury, North Carolina
Operable Unit 1
Dear Mr. Samson:
suYmru10Sftl\O~
This letter is written regarding Operable Unit 1. We are awaiting accurate potentiometric maps from IT on the plume and the extraction wells. These should be submitted as soon as possible.
I spoke with Phil Dearman of Salisbury, North Carolina regarding the noncompliance situation with the pretreatment system. -I understand that the POTW has some additional analytical needs to determine the exact source of the zinc exceedance. I look forward to a resolution of COD, TDS, Zn, Cr, Ni, 1,2-DCA permit exceedances.
Please do not hesitate
concerning this letter.
number 404/347-1695.
to contact me if you have any questions I can be contacted at 404/347-7791 or fax
Barbara H. Benoy
Remedial Project Manager
Waste Management Division
cc: c. Fehn, NCS w. Smith, WO
R. Paradowski, NSCC
B. Nicholson, NCDEHNR/
J. Vest, City of Salisbury
NSCC.OUJ.10992,ASAM
R. Leahy, ORC
H. Graulich, NSCC
M. Sturdevant,, IT
J. Cole, CDM
P. Dearman, City of Salisbury
Printed on Recycled Paper
• National Starch & Chemical Company
Salisbury, North Carolina
Operable Unit 3
October 9, 1992
Page 2
•
Ecological Testing -The chronic toxicity testing will be for 2 organisms for surface water and 2 organisms for sediment. Background location at Station 12 will be acceptable if sufficient water flow exists. If the water flow is not adequate, the nearest reference stream would be used; which is Second Creek in Rowan County. EPA has suggested appropriate organisms; communication between Joan Dupont of EPA and Dan Duh have focused on the specific details. The stations agreed upon were Station 13 and a background or control.
Surface water/ sediment sampling -Sampling of surface water and sediment of the locations selected for eco testing would be necessary. Analytes shall include volatile organics, extractable organics (Base/Neutral/Acid), and metals. Pesticides, PCBs and cyanide analyses would not be required.
Field Screening Data:
Groundwater -Proposal looks good. Confirmational sampling shai1 be 2 non-detects and 1 detect per day since non-detects are notorious for false-positives in this analytical technology. The. thirty -forty sample location proposal for groundwater appears adequate. Whether or not a groundwater divide exists between the trench area and the tributary should be determined. EPA requested a schedule as soon as possible to be able to have the appropriate oversight person from ESD to see the mobile lab set up at the time of initial start-up.
soil~amplinq -The same confimationai sampling requirements would be necessarv or soils. The number was not estimated in the preliminary· work plan; EPA will assume that an adequate number would be collected to definitely identify the source of contamination •.
process facilities -The schematic of plant layout should be included in the work plan identifying underground piping, underground storage tanks for fuel oil, (both past and present). stormwater sampling -EPA has doubts that stormwater runoff is a major contributor of the surface water contamination in the NE tributary.
Subseguent Field/Lab Confirmation -Level IV DQO
The final locations of the soil borings and permanent monitoring wells will be based on the screening results with respect to the confirmational analysis sent in on the detects and non-detects. It is also assumed that the permanent installations will be done immediate after the screening. At present, 5 well pair locations are estimated; final number may increase. Number of soil borings must be sufficient to determine source of contamination. Ten to twenty percent of samples shall be TAL/TCL with the exception of Pesticides and PCB's and cyanide,
NSCC.OUl,2.10592.ASAM
I r
•
National Starch & Chemical Company
Salisbury, North Carolina
Operable Unit 3
October 9, 1992
Page 3
•
Reporting Requirements -Accurate potentiometric maps are required. A Table has been requested, and agreed upon, which identifies all wells at the site, depths, whether shallow or bedrock, screen size, slot size, diameter, construction information, etc. This table is to be submitted as soon as possible, if not already received by the Agency. Also requested was a letter report following any sampling event which identifies the samples collected, sample codes, media, dates, a map identifying locations, identification of the blank and spike samples provided by EPA, the sample codes given to the blank and spike samples, analyte lists.
Baseline Risk Assessment -This report must acknowledge all media of concern and the relative exposure pathways. Groundwater will be included.
Schedule -Please see the attached schedule.
Nscc.ou1,2.1os92.ASAM
Civil Referral Name: National Starch OU #3
Responsible : B. Benoy
As-of Date : .10/9/92 . Schedule File
Start date -ti.ed to approval of w/p
WBS Task Name --------------------------------------------
1 RIFS SUMMARY
101 PROJECT PLANNING
10149 Approve RIFS Work Plan
102 COMMUNITY RELATIONS ACTIVITIES
103 FIELD INVESTIGATIONS
10301 Mobilization/Site Access
10302 Phase I
10303 Receipt of Field Data
106 RISK ASSESSMENT
10601 Exposure Assessment
10602 Toxicity Assessment
10603 Risk Characterization
10604 List ARAR's
10605 Contaminant Identification
107 RI REPORT
10701 Draft RI Report
10702 Review Draft RI Report
10703 Revise RI Report
10704 Review Revised RI Report
10705 Approve Final RI Report
105 DATA VALIDATION/EVALUATION
10501 Receipt of CLP Data Package
10502 ESD Review of CLP Data Pkg.
108 FS REPORT
10801 Draft FS Report
10802 Review Draft FS Report
10803 Revise FS Report
10804 Review Revised FS Report
10805 Approve Final FS Report
10816 RECORD OF DECISION
NATIONRI
Start End
Date Date Duration ---------------------------
11/2/92 11/2/92 o.o • 11/2/92 11/2/92 o.o
11/2/92 8/27/93 10.0 mont
11/2/92 2/6/93 97.0 days
11/2/92 11/8/92 1 .. 0 week
11/9/92 1/7/93 2.0 month
12/9/92 2/6/93 2.0 month
2/7/93 3/13/93 1.2 month
2/7/93 2/27/93 3.0 weeks
2/7/93 3/13/93 5.0 weeks
2/7/93 2/27/93 3.0 weeks
2/7/93 2/13/93 1.0 week
2/7/93 2/16/93 10.0 days
2/7/93 5/17/93 3.3 month
2/7/93 3/8/93 1.0 month
3/9/93 4/7/93 1.0 month
4/8/93 5/7/93 1.0 month
5/8/93 5/17/93 10.0 days • 5/18/93 5/18/93 o.o
2/7/93 3/8/93 1.0 month
2/7/93 2/7/93 o.o
2/7/93 3/8/93 1.0 month
2/7/93 6/16/93 4.3 month
2/7/93 4/7/93 2.0 month
4/8/93 5/7/93 1.0 month
5/8/93 6/6/93 1.0 month
6/7/93 6/16/93 10.0 days
6/17/93 6/17/93 o.o
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
JAN 2 2 1992
345 COURTLAND STREET. N.E.
4WD-NSRB
John
City
P.O.
Vest
of Salisbury
BOX 479
ATLANTA. GEORGIA 30365
Salisbury, North Carolina 28145-0479
Re: National Starch & chemical Company Site
Salisbury, North Carolina
Addendum to Final Design
Dear Mr. vest:
The EPA approved the Addendum to the Final Design on the combined
Pretreatment system for the National starch & chemical Company (NSCC)
Site on January 21, 1992. A copy of the letter granting approval is
enclosed. This approval was granted in anticipation of the Salisbury
POTW also being able to approve this design. EPA fully appreciates
and supports your position concerning effluent criteria.
Please contact me if you have any questions or suggestions concerning
this site. I can be reached at 404/347-7791 or fax number
404/347-1695.
Sincerely,
4t1rft:tt-,,,, d ~"?
Remedial Project Manager
waste Management Division
Enclosure
cc: curt Fehn, EPA
Rick Leahy, EPA
@,;c;__Nicholson,--NC--DEHNR .. ~--·-. . -, ~
Ray Paradowski, NSCC ,tl,_:;:-, ;•. Hank Graul!ich, NSCC
Jim coi:-;:,y-CDM-FPC
Mike Sturdevant, IT
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
JMl 21 '1992
4WD-NSRB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
A. M. Samson
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
counsel, Regulatory Affairs
National starch & chemical company
10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch & Chemical Company site
Salisbury, North Carolina
Final Addendum to the Final Design Report
Operable t[nit l
Dear Mr. Samson:
In accordance with Paragraph V of the Unilateral Administrative
Order, 89-32-c, EPA hereby approves the Final Addendum to the Final
Design Report, combined Pretreatment· sy_stem. EPA appreciates the
cooperative work between IT corporation and the Salisbury POTW and
expects that this cooperative effort will continue during
implementation.
Please contact
this project.
404/347-1695
me if you have any questions or suggestions concerning
I can be reached at 404/347-7791 or fax number
Sincerely,
B~i2ra1 Benoy
Remedial Project Manager
waste Management Division
cc: ~ . •;-: EPA
Richard Leahy, EPA
Bruce Nicholson, NC-NCDEHNR
Mike Sturdevant, IT
Jim Cole, COM
.J"oh" Vts ►, c"5 bt S,j,'51:)J~
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
JAN 2 1 1992 345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-NSRB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
A. M. Samson
Counsel, Regulatory Affairs
National starch & chemical Company
10 Finderne Avenue
Bridgewater, _New Jersey 08807
Re: National Starch & Chemical Company site
Salisbury, North Carolina
Final Addendum to the Final Design Report
Operable Unit 1
Dear Mr. Samson:
·REGtJ\!IEO
JAN 2 l 198:'.
SUPERRIND SECTION
In accordance with Paragraph v of the Unilateral Administrative
O~der, 89-32-c, EPA hereby approves the Final Addendum to the Final
Design Report, Combined Pretreatment System. EPA appreciates the
cooperative work between IT Corporation and the Salisbury POTW and
expects that this cooperative effort will continue during
implementation.
Please contact
this project.
404/347-1695
Sincerely,
me if you have any questions or suggestions concerning
I can be reached at 404/347-7791 or fax number
JO~{)_
Barbara H. Benoy
Remedial Project Manager
Waste Management Division
Enclosures\;..-
.~\ ..
cc: CurtrFehn, EPA
Richard Leahy, EPA
@ruce_ NicJic;,f~on, .Nc.:~CDEHNR
Mike Sturdevant, IT
Jim Cole, CDM
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
January 14, 1992
William L. Meyer
Director
Subject: Comments on the Remedial Design/Performance Monitoring Work Plan
National Starch and Chemical Company
Salisbury, Rowan County, NC
Dear Ms. Benoy:
The North Carolina Superfund Section appreciates the opportunity to provide
comment on the Remedial Design/Performance Monitoring Work Plan. We offer the
following comments:
1. Page 1-13, Section 1.4. Editorially, the first sentence in the section is not clear. We
suggest it be changed to read, "The activities described in the SAP will be conducted
annually. Field sampling will take place in the first two weeks of June each year.
2. Page 2-1, Section 2.2. How were the number and locations of the proposed 1992
borings chosen? How will future boring locations be chosen? Rationale for the
answers to both of these questions should be presented in the Work Plan. Also, from
the procedure described in the SAP, a total of 15 subsurface soil samples will be
taken and analyzed each year. This fact should be explicitly stated somewhere in the
SAP.
3. Page 2-4, Table 2-2; and Page 2-7, Table 2-1. These Tables appear to be mislabeled
in that Table 2-2 appears before Table 2-1. Also, the last column of both Tables
would be more properly titled, "Maximum Allowable Holding Time".
An Equal Opportunity AffillT\adve Action Employer
Ms. Benoy
1-14-92
Page 2
• •
4. Sections 2 and 3. Throughout these sections the word "aliquot" is used to describe
the samples taken from the split spoon or sample material in the sample container.
This seems to us to be a confusing misnomer in that "aliquot" implies an exact or
measured amount of material. Unless we are misunderstanding the SAP, the sample
material described is not a measured amount. We suggest this be changed to avoid
confusion.
The NC Superfund Section looks forward to working with you in the future on this
site. If you have any questions concerning these comments, please contact me at (919)733-
2801.
BIN/let/nspmplan
Bruce Nicholson
Chemical Engineer
Superfund Section
CONF IRMATI OH LI ST
SENDER:
RECEIVER:
PAGES SENT:
DURATION:
• •
JAN 17 '92 09:D7
9197334811
404 347 1695
03
01 :34
. .'
} • ~~;1;.~~itt\ • \~u.\W1JJ .::::.'.':'.~:.~.' ,.,•'
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
FAX TRANSMITTAL RECORD
William L. Meyer
Director
From: _____________ , Solid Waste Management Division
,
, Solid Waste Se.ction -------------
, Hazardous Waste Section -------------
Cfq cf t!J«//e4u,;e-,P1-c.4"fo.Superfund Section
. 7 .· ~
To:
Re:
No. of Pages (Including Cover) 3
Division of Solid Waste Management
Confirm receipt of document(s)
[phone]
., Hazardous Waste Section : [phone]
[phone]~;_.:';;: _, ."\•J'\0 ·~,;c. t. Superfund Section · · ;, ·f''::" "·'·~ Solid Waste ·section --·a· : • -
jf~ _}~ . .. .. ___ ...:; .· .
. [phone].·: 'r
, ·?·c
.-. ·.
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
JUN 2 7 1990
4WD-NRSB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Hank Graulich
J•S COURTLAND STREET
ATLANTA, GEORGIA 3031!
National Starch & Chemical Corporation
10 Finderne Avenue
Bridgewater, New Jersey 08807
RE: National Starch RD/RA
Salisbury, North Carolina
Dear Mr. Graulich:
-t(tCtJVtJJ
JUL :J 1990
SUPERFUND SECTION
This letter provides acceptance and conditional approval of the
National Starch Final Design. Enclosed are final comments from EPA
and the State of North Carolina. All comments should be incorporated
into the Final Design and resubmitted to EPA no later than July 6,
1990. Final approval will be subject to NSCC's incorporation of the
enclosed comments.
Please do not hesitate to call me if you have any questions
concerning the site. I can be contracted at [phone].
cc: Alex Samson, National Starch
Mike Sturdevant, IT
Tim Eggert, COM ._,,/
Bruce Nicholson, NC DEHNR
Page 2
NATIONAL STARCH
Final Design
• •
1) The Groundwater Technology Unit recommends the selection of a
lower horse-power pump if the proposed dedicated submersible
pumps are used in the monitoring wells. This is in addition to
the previous construCtion requirements identified in the first
set of comments.
2) Final Design and o & M Plan must be combined.
3) Intensive monitoring of groundwater levels and quality must be
undertaken during remediation activities to assure that the
recovery systems are efficient and effective. Water level
monitoring during the start--up.phase of the recovery systems is
extremely important as this monitoring will determine whether a
hydraulic barrier is being produced by the recovery wells.
Develop and incorporate a stringent start-up monitoring and
subsequent monitoring program within the design.
4) Table 6-1 must identify discharge limits for acetone. Appendix F
and main text must be consistent.
5) Removal of acetone must be discussed in the Plume Periphery
Pretreatment System.
6) Check Table 6-2 for accuracy.
7) EPA-SOP decon procedures dictate final rinse to be organic-free
water not deionized or distilled water. Design must incorporate
the use of organic-free water for decon procedures.
8) Bentonite pellets must be allowed to hydrate .!1Q less than eight
hours.
• •
-State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin 1 Governor
William W. Cobey, Jr., Secretary April 10, 1990
William L. Meyer
Director
Ms. Barbara Benoy
Superfund Branch, Waste Management Division
U.S. EPA Region IV
345 Courtland Street
Atlanta, GA 30365
Subj: Comments on the Draft Final Remedial Design
National Starch and Chemical Company Site
Salisbury, Rowan County, North Carolina
Dear Ms. Benoy:
The North Carolina Superfund Section is pleased to offer these
comments on the National Starch and Chemical Company Remedial Design
Report (RD). Please note that we have forwarded the RD to the North
Carolina Division of Environmental Management for their review also.
Their comments will be forthcoming as soon as possible.
We find the report to be technically thorough and specific. As
a result, we· have no major technical comments. As for general
comments, we note that the report states that the effect of the
extraction wells on the ground water flow is not known and difficult
to quantify (Section 5.1.1). It would be useful to explain this a
little more. Why cannot models be used to predict the effects? What
are the estimated qualitative effects? ·Also, what does the site
ground water data say about the hydrogeologic connection between the
saprolite and bedrock aquifers?
As an editorial comment, we note that at the top of page 2-4 the
word "isopropanol" is misspelled "isoproponol".
The NC Superfund Section appreciates this opportunity to
the report. If you have any questions please contact
[phone].
BIN/let/nsrdcom
Sincerely,
Bruce Nicholson
Chemical Engineer
Superfund Section
review
me at
I
'1 • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
APR 5 1990
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-NRSB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Hank Graulich
National Starch & Chemical Corporation
10 Finderne Avenue
Bridgewater, New Jersey 08807
Re: National Starch RD/RA
Salisbury, North Carolina
Dear Mr. Graulich:
~~CtJYf u_.i
R 1 o 1990
SUPERFllfVD SEcno,v
Enclosed are the Agency's comments on the February 1990 Draft Final
Design Report for the above referenced site. The Final Design is due
no later than May 8, 1990. If you have any questions, please give me
a call at 404/347-7791.
Sincerely,
~;.·(>t,//(
I '•· __ .,,---
Barbara H. Benoy
Remedial Project
/ I:', . ,.,_ / .{)e ' _(· cf -~ I/
Manager ,1
cc: Alex Samson, National Starch
Mike Sturdevant, IT
Tim Eggert, CDM
Bruce Nicholson, NC DEHNR,_,....----
Printed on Recycled Paper
i • • COMMENTS
1. Construction of monitoring wells should be of stainless steel;
PVC is not acceptable in the construction of monitoring wells.
2. Permanently placed pumps for the monitoring wells are not
appropriate and cannot be used in the construction of
monitoring wells.
3. Include a brief section which explains residual waste
management for the overall site.
4. Page 6-5, Report suggests that there will be a delay if NPDES
permit is necessary. The April 3, 1990 meeting between NSCC
and EPA personnel inferred that this would not cause a delay;
NPDES option was currently being explored to avoid such a
delay. Please correct.
5. As commented on the Conceptual Design Report, the direction of
the movement of the plume and the location to the nearest
receptor or drinking water well should be added here to show
risk. As discussed in the April 3, 1990 meeting, additional
information is being compiled as to how the private wells may
be affected by the extraction program and is to be included in
the final design. Have any predictions been made from
available modeling programs? If so, please include in the
report.
6. Give specifications on the concrete sump sealed with epoxy
paint. Are other options being considered? Need additional
information to determine whether this is an appropriate
vessel.
7. Elaborate on the rationale for the use a spray stripper
instead of a packer column.
8. Reporting requirements are discussed only in the QA Plan.
Identify all reporting requirements in a brief section to be
submitted to EPA throughout the RD/RA program.
9. As discussed in the comments to the Conceptual Design Report,
the cleanup criteria needs to be included for groundwater.
10. The process/treatment areas need to be identified on a figure.
11. Decontamination procedures still need to be identified and
included in the report.
12. The report does not provide adequate information on
remediation verification.
13. The report continues to need a section on implementation
considerations which includes regulatory requirements, site
access and rights of way.
• •
-2-
14. Page 2-7, Table 2-1 -Explain the footnote "f. Led rock
wells".
15. Page 4-1, Line 10 -Spell out TAL and.TCL prior to their use.
16. Page 5-4, Line 1 -The first sentence should indicate that the
pumpage rate of 35 gpm is for each of 4 wells, not the
aggregate pumpage rates.
17. Page 5-4, line 12 -The reference to Figure 5-2 should be
corrected to read Figure 5-1. Incorrect as presented.
18. Page 5-14, line 19 -Describe how the aquifer testing water
will be disposed. Unlike the "Plume Periphery Bedrock
Extraction wells" (Section 5.1.2.1), these wells will be in
the plume and discharged water may be contaminated.
19. Section 5 -Explain for each type of well to be installed, how
the development and aquifer testing water will be contained,
tested, and/or disposed.
20. Page 6-1, line 11 -Reference is made to Table 6-1 that
contains the design basis for the pretreatment system.
Explain how the groundwater concentrations were determined,
whether they are maximum detected, average of the wells
monitored, or reflective of mixtures from different pumping
rates.
21. Tables 2-6, 2-7, 2-8, & 2-9 -Include the calculations
performed to analyze the packer test data be included in the
report.
22. Table 2-10 -Include the calculations performed to analyze the
slug test data in the report.
23. Section 2.2.4, page 2-36 -The recovery data of the aquifer
test from the pumped well, NS-28, should be analyzed by the
various applicable methods. Little of the data from the
aquifer test performed at the site is of much value; this
would be an attempt to salvage any usable data from the test.
24. Section 5.1.3.1, page 5-8 -"Because the wells are located
outside the plume boundary, the well water during each test
will be discharged to the southwest tributary." The
extraction wells discussed here are located at the periphery
of the plume. Therefore, the water removed from the wells
during the step-drawdown test should be contained until
water-quality analyses can be performed.
25. Section 5.1.3.1, page 5-8 -Two step-drawdown tests are
proposed for each extraction well prior to final well
installation in order to evaluate the effectiveness of the
• • -3-
hydrofracturing techniques to be employed. Note that the
specific capacities determined from these tests will not be
the specific capacities to be anticipated upon final
installation of the wells. Excessive drawdown in a production
well can be enhanced by well design and construction factors.
Therefore, it is recommended that additional teats be run on
the completed wells prior to startup of the system.
26. Section 5.1.3.l, page 5-9 -The extraction wells are
production wells. Therefore, well screen slot size and gravel
pack should be selected following recommended industry
practices (see "Groundwater and Wells", Driscoll, 1986).
27. Section 5.1.3.4, page 5-16 -step drawdown tests are proposed
for the monitor wells. However, no information is provided on
what will be done with the water removed from the wells.
28. Section 5.1.3.4, page 5-17 -"During this second development,
the well water should be nearly free of sediments. Therefore,
this water sill be discharged to the southwest tributary;•
The monitor wells discussed here are located at the periphery
of the plume. Therefore, the water removed from the wells
should be contained until water-quality analyses can be
performed.
• • -4-
MODELING RESULTS
The computer program RESSQ (Javandel etal., 1984) was used to test
the groundwater extraction system design for theoretical
effectiveness in c~pturing the contaminant plume. RESSQ is a
semianalytical code which calculates contaminant transport by
advection and adsorption (no dispersion or diffusion) in a
homogeneous, isotropic confined aquifer of uniform thickness when
regional flow, sources, and sinks create a steady state flow field.
Two model simulations were developed: (l) the plume periphery
extraction network and (2) the trench area extraction system.
Design data and aquifer parameters from the Design Report were input
into the model to predict the capture zones for the extraction
systems.
For the plume periphery system, RESSQ predicts that the proposed
design will eventually prevent expansion of the plume. However, the
model indicated a slow development of the individual capture zones
for the extraction wells. Over 5 years of pumping was required for
the capture zones of the extraction wells to expand laterally such
that the downgradient migration of the plume was fully impeded.
For the trench area network, RESSQ predicts that within a 5-year
development period the system will capture all groundwater in the
source area. However, due to the ridge-top.location model
development for this area was more difficult. Therefore, capture
zones may develop in this area much more quickly than predicted by
RESSQ.
overall, the modeling performed indicates that the proposed
extraction system designs will be adequate in remediating the
groundwater contamination at the NSCC Site. However, that capture
zone modeling undertaken considers ideal hydrogeological
conditions. Such is not the case at the NSCC Site. It is
anticipated that the aquifer media will have preferred groundwater
flow paths through higher permeability orientations within the
deposits. It is requested that intensive monitoring of groundwater
levels and quality be undertaken during remediation activities to
assure that the recovery systems are efficient and effective.
Water-level monitoring during the startup phase of the recovery
systems is extremely important as this monitoring well determine the
true capture zones of the recovery wells. Analysis and evaluation
of this data may indicate the need for additional extraction wells
and/or adjustments to the proposed pumpimg rates.
• •
-· State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
April 9, 1990
MEMORANDUM
To: Perry Nelson, Chief
Groundwater Section
From:
Division of Environmental Management
Lee Crosby, Chief I ,V
Superfund Section J-;)"
Division of Solid Waste Management
William L. Meyer
Director
RE: Review and Comments on the Draft Remedial Design Report
National .Starch and Chemical Co. NPL site
A copy of the Draft Final Remedial Design Report for the
National Starch and Chemical Site in Salisbury, Rowan County, is
enclosed for your review and the review of the appropriate regional
office. Please return comments, if any, to this Section so that we
may submit one package to the U.S. Environmental Protection Agency.
If you have any questions, please contact Bruce Nicholson or
me at 733-2801. We appreciate your working with us on this site.
LC/acr/nsrdcom
Enclosure
• •
State of North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Ms. Barbara Benoy
June 1, 1990
SUperfun:i Brard!., waste Managenent Division US EPA Region DJ
345 Coortlam street
Atlanta, GA 30365
Subject: Draft Health arn Safety Plan Final Remedial Design Report National starch am Chemical catpany Site Salisb.Jiy, Rowan crunty, NC
Dear Ms. Benoy:
'Ihe North Carolina SUperfurd Section has received ard reviewed the subject docu!rents. Catmants were presented on the Remedial Design Report in oor letter of 10 April 1990. No additional ccmnents are offered at this time.
'Ihe Draft Health am Safety Plan was reviewed by Mr. David Lilley, In:iustrial Hygienist, NC SUperfun:i Section. 'Ihe follow.i.rq ccmnents are offered for yoor consideration:
1. 'Ihe chart on page 8-2 alorg with no mention of the potential dlemical hazards involved on the site leads one to beli,;ive the c:hart was si.nply µilled fran an EPA source am used w.ith no regard for the partirular situation. 'Ihe Preliminary Assessment Reassessirent i.nilcates vinyl dtl.oride is one of the chemical hazards that may be present on this site. 'Ille PEL for vinyl dlloride is 1 i:PU, but the Relative Response on one of 'the mre m,mun PIJ:s (the HNU) is only 50% with a 10.2 eV prd:le, so when the HNU registers 5 i:PU, personnel are actually exposed to 10 ppn vinyl chloride, or 10 t:ilnes the PEL. Therefore, use of the c:hart in this situation vKlllld be inaw~riate.
2. Page 8-1: 'Ihe statement is made that personnel renainin;J in the SIJl'.P)rt zone will not receive periodic exposure ll'Dl'\itor.i.rq. Why not? 'Ibis seems like a good idea to prove the exclusion zone is in the right place.
3. Page 3-2: Why are visitors request.i.rq to enter the contaminated zone to observe work ~ fran the 40 (or even 24) hoor train.i.rq cnirse as required by 29 CFR 1910.120 (e)?
William L. Meyer
Director
Ms. Hamara Benoy
June 1, 1990
Page 2
• •
4. Page 8-1: PIils are l'XJt organic vapor nx:mitors. Altbough
they detect sane organic vapors, they do rx,t detect all
organic vapors. 'lhe Organic Vapor Analyzer (OVA) which uses
a flame ionization detector, will.
5. Route to hospital: you may want to highlight the rart:e with
a magic marker. 'lhe reader has to look at the map a few
times before realizin:; that there were arrows markin;J the
way.
6. Page 7-2: Tapin:; a hocxl. to a respirator facepiece is rx,t
recamnended for level B protec.tior.. It arpeap,: this
practice WC1Jl.d limit nd::>ility arxl ackl the possibility of
breakin;J the face to facepiece seal of the respirator. In
addition, the purpose of level B protection is to offer nore
respiratory protection than level c, rx,t additional skin
protection. If an in:::reased skin protection is desired, an
increase to level A WC1Jl.d be awrq,riate.
'lhe NC SUperfurd
review these reports.
me at [phone].
JB/ds/drafth&s.rpt/1-2
Section awreciates this c:g;iortunity to
If you have any questions, please cor.tact
Sirx:erely,
~~
Jack Butler
Envi.rormental En;Jineer
SUperfurd Section
MEMORANDUM
SUBJECT:
DATE:
FROM:
TO:
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
National Starch RD/RA
Salisbury, North Carolina
MAY 1 G 1990
Barbara H. Beno' /JJJ/<.
Remedial Projec~r
Review Team
Bill Bokey, ESD
Geizelle Bennett, NC Remedial Section
Rutherford Hayes, Water
( Jack Butler, NC DEHNR
Tim Eggert/ Joe Claypool
W!E\C~ij~[[JJ
IVll•H i l 1990
SUPERfllND SECTION
Attached is the Final Design Report for the Remedial Design at the
National Starch Site in Salisbury, NC. A review was performed by the
above review team i-n March. A final review should be conducted •to
ensure your comments were appropriately addressed. Any problems
should be identified to me no later than June 4, 1990.
If you have any questions, please give me a call at x7791.
Thank you.
• •
oee, 1 ~ 1 ,, iii
. '
• •
UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV ·Ktt:ltl V l:l;;
345 COURTLANC STREET
ATLANTA, GEORGIA 303155
4WD-SFB
CERTIFIED 1-'TATL
RETURN RECEIPT REQUESTED
Mr. Han~~ G:?::"aulich
Natianal Starch & Chemical Corp.
10 Finderne Avenue
Bridgewater, NJ 08807
Re: National Starch RD/RA
Salis:n1:!:y, NC
Deer Mr. Graulich:
DEC O If 1989
SUPERFUND SECTION
Enclosec'. are the Agency's comments on the Octobe:,:-1989 30%
Conce::,tual Design Report for the a,:,ove referenced site. The
draft ::ina::. design is due no later than January 8, 1989. If you
have any questions, please give me a call at 404/347-7791.
Sincerely,
(1~~6~~~
Giezelre s. Sennett
Remedial Project Manager
cc: Alex Sampson, National Starch
M:.i,,e St,irdevant, IT
T.im Eggert, CDM
Bruce Nicholson, NC DEHNR
• •
COMMENTS
1. Page 1-2, 4th Paragraph, Line 5 -Clarify what constituents
were present in "trace amounts."
2. Page 1-2, Section 1.3 -This section is highly qualitative
wit'.1 scant information about the quantities/concentrations
of contaminants detected during the R!. Summary data tables
for each mec'.ia shouic: be addec: to provide a better overview
of the R! results. In addition, please include tl1e data
from the latest round of sampling and update the contaminant
plume diagrams.
3. Page 1-2, Tables 3-1 and 3-2
s:iould be "bis(2-chloroethyl)ether."
"bis ( chloroethyl) ether"
4. Page 1-3, Section 1.3.1 -The geology of the site should be
ill'..!strated in a cross section to show the hydrogeologic
conc.itions of the site.
5. Page l-3, L.:..nes 5 & 8 -Change 11 were" to "was 11 •
6. Page 1-3, Paragraph 4 The statement concerning the
l~<elihood of contaminants detected in the shallow aquifer
also !:Jeing present in the deep aquife,:: should be supported
by da"':a from the RI.
7. Page l-3, Pa:cagraph 5 -The direction of the movement of the
olume and the location to the nearest receptor er drinking
wa"':e,:: well should be added here to show risk.
!f c.cetone is the most mo!:Jile contaminant, why do "specific
cond'.lcta,:ice and chloride appear to be good parameters to
monitor p2.ume movement". These contaminants would appear to
trail the leading edge of the acetone plume according to the
discussion in the text.
8. Page 1-3 -If Well NS-22 is the most downgradient well and
shows concentrations of 22 ppb of acetone 100 feet from the
property line, how can the statement sti2.l !:Je made that
"g::::oundwater contaminants have not migrated off-site"? The
p2.u!!".e is reported to be moving 75 feet per year. The last
sa!llpling was conducted over 2 years ago, clearly indicating
the potential of the plume to move the remaining 100 feet to
the property line from Well NS-22.
9. Page 1-4, Paragraph 4 -Define what "it" is that is present
in t~e groundwater.
10. Page 1-6, Top
should be used
was caused by
this statement
reports.
of page -The additional sediment samples
to dete:cmine if the phthalate contamination
the gloves. If phthalates are found, then
shou2.c no longer be used in any further
11.
• •
-2-
Page 1-6, Section 1.4 This section is incomolete. The
groundwc.ter cleanup criteria needs to be included. Also,
the RO::> recommended a number of different alternatives that
were dependent on the POTW's decision. Since the agreement
with the PO'I'W has been finalized, an update is needed in
this section on the type of pretreatment that will be used,
as well as an updated cost estimate on the total remedy.
12. Page 2-1, Line 5 -Need to define the attainment area and
show it. on a figure.
13. Page 2-1, Paragraph 1 -"An adequate number of c.owngradient
monito:::ing wells will consist of three bedrock and three
saprolite wells." An explanation is needed for this
statement regarding monitoring wells to be located
downgrac.ient of the extraction wells. Three downgradient
monitor we2.ls may be an inadequate number for the bedrock
ac::ui::er; adc.itional monitor we2.ls may be necessary.
However, monitor wells may not be reauirec in the saprolite
aquifer dcw~g=adient of the extraction~wells.
14. Page 2-2, Section 2.3.2 A cross section of the geology
s'.,owing the typical construction of an extraction well,
including screened or open interval should be provided to
cla!:'ify -:__-ie T ...... ell construction C.etails, including depth of
~ori.ngs.
"Each well will be fitted with wire-wrapped PVC screen that
will extenc'. from the bottom of the well to several feet
above the ·,,a"'::er table." There is no need to extend the well
screen abo'le t:'le water table. Only the bottom half of the
aquifer needs to be screened in order to obtain high
specific capacity. Optimally, the well should then be
pumped so that the pumping water level is maintained at or
slight:!.y above the top of the well screen. For a refe:::ence
on cevelo:9ment of the extraction well c.esign, see
"Groundwater and Wells" by Johnson Division, St. Paul,
312..nnesota.
15. Page 2-3, Paragraph 1 "It is anticipated that an
e"t:::action :::ate of approximately 125,000 gallons per day may
be recmirec to achieve ARARs within the contaminated area."
The source anc/or derivation of the 125,000 gpd value are
net provided in the report. This pumpage rate translates to
approximate::.y 87 gallons per minute. I"': is stated in the
report t:iat extraction wells in the bedrock ar.d saprolite
ere expected to yield up to 50 gpm and 10 gpm, respectively.
In comparison to these expectations, 87 gpm from the entire
extraction system does net seem to be a great amount of
pumpage. Please explain the derivation of this withdrawal
rate.
• •
16. Table 3-1
footnote.
The letters "L.T." should be explained in a
17. Page 3-2 -Reference is made to the discharge of treated
effluent to the City of Salisbury's POTW, but no indication
is provided concerning whether the City has agreed to accept
this wastewater. Provide a summary of this agreement. Also
state the ability of the City to handle the quantity and
quality of wastewater proposed without affecting their
Qischarge i~mitations.
18. Page 3-2, Paragraph 3 -Discharge from the pre-treatment
system will be made to the City of Salisbury's POTW. State
how the effluent will be physically conveyed to the POT W.
The report should clearly state whether the existing
wastewater system currently discharges to the City's POTW.
19. Page 3-2, Paragraph
emissions a!:'e within
sit.e.
4 State whether the expected air
the existing permit limitations of the
The report indicates an existing wastewater treatment system
consisting of lagoons is being used on the site. Certain
additional treatment units will be added to upgrade the
system. The report does not indicate the existing vs.
proposed units. The process block flow diagram should show
clearly what unit processes are being added and which
currently exist.
20. Page 3-3, Section 3.2 -A plan view of the treatment system
should be provided in the report to show the layout of the
proposed pre-treatment facility. This figure should clearly
identify existing vs. proposed treatment units.
21. Page 3-4 -The sludge generated by the metals treatment unit
"will be sent to an appropriate disposal facility". What
type of c.isposal facility is required? Will this sludge be
hazardous? Indicate if testing of the sludge will be
performec. and what types of tests are proposed.
22. Drawing No. 408668-10-BF0l It appears from the mass
balance t!lat the majority of the contamina:its will be
emittec. into the air. Please provide a flow diagram that
shows the contaminants only and their fate and transport
throughout the system. The diagram appears to show that the
treated water to the POTW will not contain any contaminants.
The flow line 9 should read "Metal Sludge", not "Sludge
Sludge."
23. All figures and tables should have page numbers.
• • -4-
2<!. Page <',-1 -·S'.!rface water and sediment sampling will continue
throughout the remedial action. This will determine the
impac:: of the extraction system on the quality of the
surface water and sediment. This can be addressed in the
0 & M Plan.
25. The draft final design report should also include:
A discussion on groundwater capture zone analysis and an
accompanying diagram;
Well Development and Decontamination procedures;
A more complete discussion of the waste transport system to
include the piping system and the type of pumps that will
be used.
Need a discussion on remediation verification and the
requirements for completion of the extraction system. This
will include an evaluation of the system at least every six
mont~s~
Need a
includes
and site
discussion on imolementation considerations
requlatory. requirements, health and safety
access and rights of way.
which
plans,
Also need a schedule of activities in the design report up
until start up of the extraction system.