NCD991278953_20070301_National Starch & Chemical Corp._FRBCERCLA RA_OU-4 Soil Delineation Work Plan 2006 - 2007-OCR

• ,,,_.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
SAM NUNN ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
· March' I, 2007 ·-.
'4WD-SRSEB,·-:. , '.
Ms. Angela J. Doh! ·· u' ,, ..:~,c ·,, ...
National Starch·& Chemical Company ·,-..
IO Finderne Avenue
Bridgewater, New. Jersey ... 08807--~ .. ,--
Mr. Michael P. Fleischner
Ms. Jessica A. Seebald
Blasland, Bouck & Lee, Inc.
2033 North Main Street
Suite 340
Walnut Creek, California 94596
SUBJ: Comments on Response to Comments on Operable Unit #4 Soil Delineation Work Plan
for National Starch & Chemical Company. Superfund Site, Salisbury, Rowan County,
North Carolina • .,,:, · · ... · ·
10JJ K. BOLl:JfJOjlJJ .
Dear Ms. Doh!, Mr. Fleischner, & Ms. Seebald:
The Agency received the above referenced document dated, February 6, 2007, on
February 7; 2007. All responses are acceptable accept the Response to Comment' 10. The ·
response did not clearly specify how this soil sample will be collected with minimizing.the lost
of the volatile organics. The response· states, ''.The preferred method ... using a backhoe." but this
response does not clearly state how-tliis-voh.iine-of soil will be·collected? Please clarify. An
email response would suffice. Therefore, as specified in the second paragraph of .your February
6, 2007 letter, your February 6 response letter and the forthcoming email will be incorporated
into the Operable Unit #4 Soil Delineation Work Plan by reference.
' : ..
If you have any questions, please feel to call me at 404-562-8820.
Sincerely,
' . . . .
I, .''••
Jon K. Bomholm
.. ·n,1,~eT7,d_ial.Proj_~~\Manager;.
cc: David Matiison, NCDENR
RF.,;,;. CotT'~ents on Response to Comments
Subject: RE: Comments on Response to Comments
From: "Seebald, Jessica" <[e-mail]>
Date: Mon, 5 Mar 2007 14:59:56 -0500
IT'o: <[e-mail]>, "Fleischner, Michael".<[e-mail]>, <[e-mail]>
tc: <[e-mail]>, <richard.steinert@,_n_s_tar_ch_._c_o_m_> __ ~· ______________________ _
Jon-
To minimize the loss of volatile organic compounds, soil borings will be
advanced at sample locations SB-175B and SBA2-09 using 2-inch-diameter,
2-foot-long Geoprobe macrocore samplers fitted with dedicated acetate
liners. The macrocore samplers will immediately be capped and packed on
ice in a cooler in the field to minimize volatilization. The cooler
will subsequently be transported to the laboratory in Durham for the
bench scale test.
Please let me know if you have any additional concerns. Thank you.
Jessica Seebald
Senior Project Manager
ARCADIS BBL
ARCADIS U.S., Inc.
2033 NOrth Main Street, Suite 340
Walnut Creek, California 94596
Phone, 925.296.7812
Cell Phone, 925.330.3770
Fax, 925.274.1103
The information contained in this e-mail message is intended only for
the personal and confidential use of the recipient(s) named above. If
the reader of this message is not the intended recipient or an agent
responsible for delivering it to the intended recipient, you are hereby
notified that you have received this document in error and that any
review, dissemination, distribution, or copying of this message and
attached documents is strictly prohibited. If you have received this
communication in error, please notify us immediately by e-mail, and
delete the original message.
-----9riginal Message-----
From: [e-mail] [mailto:[e-mail]
J
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l of2 3/5/2007 3:01 PM
RE: Comments on Response to Comments ~ ,..· ~::..
Sent, Thursday, March 01, 2007 2,12 PM
To: Fleischner, Michael; Seebald, Jessica; [e-mail]
Cc: [e-mail]; [e-mail]
Subject: Comments on Response to Comments
Attached are the Agency's comments on NSCC's response to comments on the
"Supplemental Operable Unit #1 Remedy Evaluation Report 11 and "Operable
Unit #4 Soil Delineation Work Plan11 • Hard copy in the mail. As you
will see, the only remaining issue about next weeks field effort is the
collection of the soil sample for the lab. As you know the concern is
to make sure the lab receives the best representative sample possible
(i.e., minimize voe lost). I'm OK with the response provided for the
Work Plan. Have a safe week.
I've been out in the field most of this week so I've not talk to Clark
directly but I see from his email he will not be able to get to the Site
next week. Sorry for any confusion.
I will be out of the office all next week. I can be reached on my cell
phone [phone].
Jon Bornholm
Remedial Proje~t Manager
(See attached file: Comments on Response to Comments Supplemental
Operable Unit #1 Remedy Evaluation Report-EMAIL.doc)
(See attached file: Comments on Response to Comments on Operable Unit #4
Soil Delineation Work Plan and Conditional Approval of This Work
Plan-EMAIL.doc)
NOTICE: This e-mail and any files transmitted with it are the property of ARCADIS U.S., Inc. and its affiliates .
All rights, including without limitation copyright, are reserved. The proprietary information contained in this
e-mail message, and any files transmitted with it, is intended for the use of the recipient(s) named above. If the
reader of this e-mail is not the intended recipient, you are hereby notified that you have received this e-mail in
error and that any review, distribution or copying of this e-mail or any files transmitted with it is strictly
prohibited. If you have received this e-mail in error, please notify the sender immediately and delete the original
message and any files transmitted. The unauthorized use of this e-mail or any files transmitted with it is
prohibited and disclaimed by ARCADIS U.S., Inc. and its affiliates.
I
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. 2 of2 3/5/2007 3:01 PM
• • ~ ARCADIS BBL
Infrastructure, environment, facilities
Mr. Jon K. Bornholm _,....... 1 ·.""' ~
United States Environmental Protection Agency -Region·~-r-.r ,I ; ' ~,.;]:. ~
Atlanta Federal Center [·· •. ::--··---J
Atlanta, GA 30303-3104 ' ; • ffµ_ 1 'l, L
61 Forsyth Street, S.W. · ',_ \ "DD7
Subject·
Response to Comments on OU4 Soil Delineation Work
National Starch & Chemical Company
Salisbury, North Carolina
Dear Mr. Bornholm:
, · -----~-. ON ~~-. _,. r ~-~-~---. \ • •. "i. ,' \ SU'fi.11 ' ':,-) ~-... -
Ian
On behalf of National Starch & Chemical Company (NSCC), ARCADIS U.S., Inc.
([ARCADIS BBL] formerly known as Blasland, Bouck & Lee, Inc.) has prepared this
response to regulatory comments dated December 27, 2006 on the Operable Unit 4
(OU4) Soil Delineation Work Plan for the National Starch & Chemical Company
Superfund Site (site) in Salisbury, North Carolina. This letter presents NSCC's
responses to agency comments on a point by point basis.
To the extent that responses presented herein are acceptable to USEPA, they will be
incorporated by reference into the Final OU4 Soil Delineation Work Plan.
1. Page 1 of 4, second paragraph: This paragraph discusses delineating the
extent of soil contamination in the horizontal direction. What is the
possibility of using the GeoProbeTM or another contractor such as Vironex
with a Membrane Interface Probe (MIP) {www.vironex.com} to investigate
the presence of dense non-aqueous phase liquid (DNAPL) in this area?
This has been a lingering question and any additional information will help
to address this question.
MIP will be used to select soil sample intervals and investigate the presence of
DNAPL in OU4.
Imagine the result
ARCADIS U.S., 1nc.
2033 North Main Street
Suite 340
Walnut Creek
California 94596
Tel [phone]
Fax [phone]
www.arcadis-us.com
ARCADIS BBL
Date:
February 6, 2007
Contact:
Michael P. Fleischner
Phone:
925.296.7813
Email:
Michael.Fleischner@
arcadis-us.com
Our ref:
B0060011 #5
• •
ARCADIS BBL
2. Page 2 of 4, Soil Sampling Methodology Section, first paragraph: Does
GeoProbeTM have an auger head that allows you to measure volatile
organic compounds (VOCs) in real time? If not, how about using a system
such as Vironex's MIP system?
Please see the response to comment number 1.
3. Page 2 of 4, Soil Sampling Methodology Section, first paragraph, third
sentence: This sentence implies that the only portion of the core that will
be logged for lithologic properties including soil type, color, moisture
content, etc. is the portion that are sampled. It would make more sense to
record the lithologic properties for the entire core instead of just the
portions where samples are collected.
Each four-foot long soil sample interval will be visually examined by the
ARCADIS BBL field geologist and field screened for the presence of volatile
organic vapors utilizing a photoionization detector (PIO). All relevant information
collected during the advancement of soil borings, including lithology, PID
readings, and other visual observations will be recorded in the field logbook.
4. Page 2 of 4, Soil Sampling Methodology Section, first paragraph, fifth
sentence: This sentence states that a soil sample will be collected from
each discrete interval identified in Table 1, Is there any room for adding
additional samples in case something unexpected is encountered? The
following statement should be added to this paragraph, "Additional
samples may be collected based on observation made in the field,"
The primary objective of the additional soil sampling work plan is to complete
horizontal del_ineation of soil impacts. If MIP results are consistent at a soil
boring location, samples will be collected from the target interval as identified in
Table 1. Additional soil samples may be collected based on field observations
and results of MIP.
5. Page 2 of 4, Soil Sampling Methodology Section, first paragraph, fifth
sentence: This sentence states that a soil sample will be collected from a
discrete 12-inch interval. How will the lost of VOCs be minimized during
the collection of the soil samples? Would the use of an Encore Sampler or
something similar be applicable?
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February 6, 2007
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To minimize potential loss of constituents of concern, the soil core will be
promptly split and samples will be collected for volatile organic compound
analyses prior to sample homogenization. A subsample near the center of the
sample interval will be collected using an Encore® sampler, or equivalent.
6. Page 3 of 4, Soil Sampling Methodology Section, second paragraph, last
sentence: Change this sentence to read," ... (EISOPQAM [USEPA, 1996),
as amended".
Soil sampling and decontamination activities will be conducted in accordance
with the procedures outlined in the United States Environmental Protection
Agency (USEPA) Region IV Environmental Investigations Standard Operating
Procedures and Quality Assurance Manual (EISOPQAM (USEPA, 1996]), as
am mended.
7. Page 3 of 4, Proposed In-Situ Waste Characterization Sampling Activities
Section, first paragraph, first sentence: This sentence should clearly state
that soil from the soil borings discussed in the previous Section will be
used to form the soil samples discussed in this Section. The language in
this sentence can be interpreted to say that additional soil borings will be
made in order to collect the soil samples for the purpose discussed in this
paragraph. What will be done to minimize the lost of 1,2-DCA as sufficient
soil is collected?
If samples will be collected for volatile organic compounds, the core will be
promptly split and a discrete sample interval will be sealed in a sterile soil
sampling bags prior to sample homogenization. Based on results of field
screening, a discrete sample interval will be selected from the sample location
with the highest concentration of VOCs. A subsample near the center of the
sample interval will be subsequently collected using an Encore® sampler, or
equivalent.
8. Page 3 of 4, Proposed In-Situ Waste Characterization Sampling Activities
Section, first paragraph, second sentence: Typo, this sentence should
read, "Soil samples will be collected from ... ".
We apologize for this oversight.
017711962.doo:
Mr. Jon K. Bernheim
February 6, 2007
Page:
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ARCADIS BBL
9. Page 3 of 4,, Proposed Bench Scale Test Section, first paragraph, Will
other oxidants be tested for treating 1,2-DCA in this Bench Scale Test?
After careful consideration of several oxidants, only persulfate will be evaluated
during this bench scale test. Permanganate has not been proven to effectively
remediate chlorinated ethanes. Fenton's chemistry would also not be a viable
alternative due to the geology and natural geochemistry at the site. Due to the
high concentrations of constituents of concern in soil, the weaker oxidants were
not considered. Upon further consideration of the soil chemistry, an iron catalyst
has been eliminated from the bench scale test. Instead, varying levels of lime will
be used. If the lime fails to meet the demands for oxidation, sodium hydroxide
will be tested as an alternative.
10. Page 4 of 4, Proposed Bench Scale Test Section, paragraph at top of page:.
A number of two-inch split spoon soil samples will be needed to fill a 5-
gallon bucket. Is there not a more efficient method of collecting the
necessary quantity/volume of soil? What will be done to minimize the lost
of 1,2-DCA as sufficient soil is collected?
The preferred method for collecting the bulk samples will be from a test pit using
a backhoe. Since the conceptual remedy includes removal of shallow soil from
source areas, the bench scale test will be performed on soil with concentrations
ranging from 10,000 to 100,000 ug/kg. For this reason, the pilot study will use
shallow soil from areas of lower impacts such as sample locations SB-175B and
SB-209B as shown on Figure 2. The samples will be packed into the 5-gallon
buckets to minimize headspace. The treatability lab is located in Durham, NC
approximately 2 hours away from the site. Since the sample will be driven
directly to the lab, volatilization during shipping will be kept to a minimum.
Once at the laboratory, the sample will be homogenized to reduce the variability
of concentrations throughout the sample. This is a critical step in the bench scale
test in order to produce meaningful data. The control and test samples will be
established after homogenization since some volatilization will occur during the
process. Since discrete soil samples will be collected at the pilot test locations for
laboratory analysis, the fact that some volatilization is anticipated during
homogenization is not a concern.
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Mr. Jon K. Bornholm
February 6, 2007
Page:
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11. Page 4 of 4, Proposed Bench Scale Test Section, second full paragraph,
last sentence: What is the significance of this sentence with the work
being proposed at the Site?
The structural integrity of the soil after implementation of full-scale oxidation is a
primary concern at the site. Since OU4 is an active loading area and the area
must be restored to existing conditions to support the weight of loaded tankers
and heavy equipment, it is imperative that adequate geotechnical testing be
performed in conjunction with the bench scale test. In-situ soil blending with
persulfate and a base catalyst is the conceptual remedy. However, ex-situ
oxidation and backfilling the treatment area with certified clean fill may be
considered as a remedial alternative if the bench scale test indicates that soil
integrity is compromised such that OU4 can not be restored to existing
conditions.
Based on the availability of the MIP subcontractor, soil investigation activities are
scheduled to be implemented the week of March 5, 2007. Results of the proposed
additional sampling will be used to evaluate potential remedial alternatives for soil at
OU4 and incorporated into a Supplemental Feasibility Study for OU4.
If you have any questions or comments, please contact me by phone at
925.296.7813 or by e-mail at [e-mail].
Sincerely,
ARCADIS U.S., Inc.
1chael P. Fleischner, P.E.
Vice President
Copies:
David Mattison, North Carolina Department of Environmental and Natural Resources
Angela Dohl, National Starch and Chemical Company
David Simons, National Starch and Chemical Company
Elizabeth Rhine, ARCADIS
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Mr. Jon K. Bornholm
February 6, 2007
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Infrastructure, environment, facilities
Subject:
Response to Comments on Supplemental OU 1 Remedy Evaluation Report
National Starch & Chemical Company
Salisbury, North Carolina
Dear Mr. Bornholm:
On behalf of National Starch & Chemical Company (NSCC), ARCADIS U.S., Inc.
([ARCADIS BBL) formerly known as Blasland, Bouck & Lee, Inc.) has prepared this
response to regulatory comments dated September 12, 2006 on the Supplemental
Operable Unit 1 (OU1) Remedy Evaluation Report for the National Starch &
Chemical Company Superfund Site (Site) in Salisbury, North Carolina. We
appreciate the insightful comments offered by both the United States Environmental
Protection Agency (USEPA) and the North Carolina Department of Environmental
and Natural Resources (NCDENR) and look forward to continuing to work together to
optimize the implementation of the remedies of all of the OUs at the Site. This letter
presents NSCC's responses to agency comments on a point by point basis.
USEPA REGION 4 COMMENTS DATED SEPTEMBER 12, 2006:
1. Page i, Executive Summary, fifth bullet: Did this data actually lead to a
modification of the Site Conceptual Model or did this data confirm the
Model?
Activities conducted as part of the OU 1 Remedy Evaluation refined the Site
Conceptual Model by identifying in the field the fracture sets identified during the
Fracture Trace Analysis. Productive fractures were identified during the packer
testing of bedrock wells NS-55 and NS-56. The original Site Conceptual Model
identified a shear zone in the vicinity of the lagoons. The deep bedrock on the
northwestern side of the shear zone was characterized as having potential
anisotropy; preferential flow apparently parallel to the strike of the fractures,
Imagine the result
ARCADIS BBL
Date:
February 6, 2007
Contact:
Michael P. Fleischner
Phone:
925.296.7813
Email:
Michael.Fleischner@
arcadis-us.com
Our ref:
B0060011 #5
• •
ARCADIS BBL
which is parallel to the lineament of the ridge and the Northeast Tributary and to
a degree parallel to the Unnamed Tributary. The identification of productive
fractures running perpendicular to the Unnamed Tributary does provide means
for migration of dissolved phase constituents toward the Unnamed Tributary.
2. Page I, Executive Summary, eighth bullet: Natural degradation includes a
number of different mechanisms. Was natural degradation actually
observed? Or did some of the data indicate that either chemical or
biological degradation may be occurring.
Geochemical data collected during the Remedy Evaluation conducted in 2000
(Remedy Evaluation Report for Operable Unit One [BBL, November 2000])
provided evidence of suitable geochemical conditions for the degradation of 1,2-
DCA in the aquifer. Comparison of concentrations of natural attenuation indicator
parameters between wells in areas impacted with 1,2-DCA versus background
conditions was performed. Dissolved carbon dioxide concentrations were
elevated compared to that observed in the background well, suggesting that
organic compounds are undergoing oxidation to carbon dioxide. Chloride
concentrations were up to three orders of magnitude greater in the impacted
wells than in the background well, providing evidence of mineralization of
chlorinated compounds. Manganese concentrations were also up to three times
that observed in the background monitoring well, indicating manganese-
reduction may be an important mechanism contributing to the degradation of
organics.
3. Page 3-2, Section 3.2, second paragraph: This paragraph states that the
contaminants being detected in MW-29 are originating from the Trench
Area and are reaching this well through fracture flow. Will not this flow of
contaminated groundwater from the Trench Area to the Unnamed Stream
continue even though the Plume Periphery Extraction System (PPES) is
turned off?
The cessation of PPES pumping decreased the groundwater gradient between
the Trench Area and the Unnamed Tributary. The flow of groundwater from the
Trench Area to the Unnamed Tributary has decreased as a result. Some
impacted groundwater is likely continuing to flow from the Trench Area, as
observed during the installation and packer testing of monitoring wells NS-55 and
NS-56. NSCC has made recommendations in the Supplemental OU1 Remedy
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Mr. Jon K. Bornholm
February 6, 2007
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Evaluation Report to address this concern and improve the groundwater remedy
for OU1. These recommendations include:
•
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Modification of the TAES pumping array. Specifically, ceasing operation of
extraction well EX-06 and EX-07 due to improvement in groundwater quality in
the vicinity of the wells.
Implementation of bedrock pumping in the vicinity of NS-56 to provide
additional control on dissolved phase constituents with potential to migrate
through fracture conduits into the Plume Periphery area.
Reforestation of the Trench Area to decrease infiltration of precipitation and
improve the efficiency of the TAES.
Perform additional investigation of the bedrock to surface water pathway by
identifying and investigating potential outcrops in the streambed.
4. Page 3-2, Section 3.2, last paragraph: This paragraph states that the
collected data supports natural degradation of 1,2-DCA. This paragraph
needs to be expanded to discuss this evidence.
This data is discussed in the Remedy Evaluation Report for Operable Unit One
(BBL, November 2000) and summarized in the response to comment number 2.
5. Page 3-3, Section 3.3, first paragraph, second sentence: Typo, " ... from the
trench area to are area of the Unnamed Tributary ... "
We apologize for this oversight.
6. Page 3-3, Section 3.3, first bullet: A figure should be included in this report
identifying the fractures referred to in this bullet.
The fracture trace sets identified during the fracture trace analysis are presented
on Figure 2 for the Fracture Trace Analysis report (BBL 2002). This figure is
included with this response to comments for your convenience (Attachment 1 ).
7. Page 3-3, Section 3.3, second bullet, second sentence: The two statements
in this sentence appear to contradict each other. The first portion of the
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Mr. Jon K. Bornholm
February 6, 2007
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sentence states, " ... a less likely than the major set of affect groundwater
flow ... " and the second portion states " ... a significant influence on
groundwater flow ... ". Please explain this bullet more thoroughly.
Of the five fracture trace sets identified in the fracture trace analysis, one set
trending northeasUsouthwest through the property was identified as the major
fracture trace set at the site. This fracture trace set should have a strong
influence on groundwater flow under natural (non-pumping) conditions. The four
other fracture trace sets were identified as minor fracture trace sets and less
likely than the major fracture trace set to influence groundwater flow unless there
is pumping or enhanced recharge along one of the fracture sets.
8. Page 3-3, Section 3.4, first bullet: This bullet uses the term "More features".
All features need to be identified along with a statement as to why they are
considered a "feature".
A detailed discussion of the trenching activities including descriptions of each of
the 10 trenches excavated at the site and descriptions and photos of the features
observed is presented in the letter dated March 13, 2003 (Overburden Trenching
and Fracture Mapping Technical Memorandum). Observed features included
vertical fracture traces, quartz intrusions, zones with mineral content visible and
lineations.
9. Page 3-3, Section 3.4, last paragraph: It would be helpful to locate the
features discussed in this paragraph on a figure.
Figure 2 for the Overburden Trenching and Fracture Mapping Technical
Memorandum (March 13, 2003) presents the trench locations and identifies
areas in the trenches with features of particular interest. This figure is included
with this response to comments for your convenience (Attachment 2).
10. Page 3-4, Section 3.5: This section discusses the installation of monitoring
wells NS-55 and NS-56 and gives a verbal description of where each well is
located. However, none of the figures have been updated to show the
location of these two wells. Well construction logs should also be included
in this report.
NSCC apologizes for the omission of monitoring wells NS-55 and NS-56 on
Figure 2. A revised Figure 2 is attached for the Supplemental OU1 Remedy
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Mr. Jon K. Bornholm
February 6, 2007
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Evaluation Report. Well construction logs are also attached for NS-55 and NS-
56 (Attachment 3).
11. Page 3-4, Section 3.5, third paragraph: This paragraph discusses the
analytical results for groundwater samples collected from NS-55 and NS-56
during the packer testing. Were any of these samples analyzed for the
MNA geochemical parameters?
Groundwater samples collected from wells NS-55 and NS-56 were analyzed for
VOCs and SVOCs corresponding with the OU1 groundwater monitoring
program. Geochemical parameters to evaluate natural attenuation were not
collected from these monitoring wells.
12. Page 3-4, Section 3.5 third paragraph: This paragraph discusses the
analytical results for groundwater samples collected from NS-55 and NS-56
during the packer testing. Was the data for all the samples collected
during the packer testing presented in a report? If not, then this data
should be included in this report.
Analytical results from groundwater sampling conducted during the packer
testing were transmitted in an OU1 Remedy Evaluation Status Report (BBL,
2003).
13, Page 3-5, AND 3-6, Section 3.6.1, last bullet on page 3-5 and first two bullet
on page 3-6: These bullets discuss the presence of a number of metals,
There is some discussion as to why manganese is being detected. Were
the other metals part of the production process and disposed of in the
trenches as part of the sludge?
In general, metals detected in groundwater at the site are detected at
concentrations greater than the ROD performance standard with much less
frequency and over a smaller aerial extent than organic compounds. Based on
recent conversation with Phil Bradley of the North Carolina Geological Society,
nickel, barium, and selenium were not typically analyzed for in whole rock
analysis. However, nickel and barium were detected at concentrations as high
as 1000 ppm in samples collected in Charlotte. Selenium was not analyzed for
in these samples. Barium, nickel, and selenium may be components of the
bedrock and/or saprolite underlying the site. Reducing geochemical conditions
may result in elevated concentrations of these metals at the site.
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February 6, 2007
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14. Page3-6, Table: Typo, "EX-29" and "EX-30" should read "NS-29" and "NS-
30", respectively.
We apologize for this oversight.
15. Page 3-6, Section 3.6.2, first bullet: This bullet highlights the fact that the
concentrations of DCA and DCP have decreased since the cessation of the
PPES operation. Was this decrease across the entire PPES area? Are the
levels of DCA and DCP decreasing just downgradient of the Trench Area?
If not, then some discussion needs to focus on what is happening to this
contamination.
A complete discussion of the most recent groundwater quality data is presented
in the 2005 Site Monitoring Report (BBL, 2006). The data evaluation conducted
indicates that concentrations of 1,2-DCA and DCP have not been detected at
concentrations greater than the ROD Performance Standards in eight of the nine
Plume Periphery wells over the past four monitoring events. Concentrations of
1,2-DCA and DCP are greater than the ROD Performance Standards in NS-31.
Historically in the Plume Periphery Area, concentrations of 1,2-DCA and DCP
exceeded their respective ROD Performance Standard in wells EX-02, EX-03,
and NS-29 (monitoring well NS-55 has a very limited sampling history). In the
Trench Area, concentrations of 1,2-DCA exceed the ROD Performance Standard
in nine of the 11 wells. DCP concentrations in the Trench Area wells exceed the
ROD Performance Standard in three of the 11 wells. However, a statistical
analysis of concentration trends in the Trench Area wells indicates for wells and
constituents where a trend is statistically significant, every observed
concentration trend for 1,2-DCA and DCP is statistically decreasing, indicating
that current remedial activities are having a beneficial effect.
16. Page 3-6, section 3.6.2, last bullet: Xylenes and toluene are typically
readily degraded. Any explanation as to why concentrations of 1,2-DCA
decreased (attributable to natural degradation) whereas the concentration
of the more easily biodegradable xylenes/toluene compounds increased?
Xylenes and toluene are reportedly easily biodegraded under a variety of
geochemical conditions. It is unusual for these compounds to be persistent
when chlorinated compounds are decreasing in concentration. However, there
may be a potential intermediate source between the Trench Area and NS-29.
Therefore, NS-56 will be converted to a bedrock extraction well to further
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February 6, 2007
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evaluate potential intermediate sources between the Trench Area and Plume
Periphery.
17. Page 3-7, Section 3.6.4, first paragraph, first sentence: The three sampling
locations referred to in this sentence need to be identified in a figure (e.g.,
Figure 2)
The attached revised Figure 2 shows the surface water sampling locations from
the OU 1 Remedy Evaluation.
18. Page 3-8, Section 3.7.2, second paragraph: This paragraph compares
concentrations of contaminants detected in the surface water to the ROD
Performance Standards for groundwater. Was any effort made to compare
these detected concentrations in surface water to either ecotoxicity
screening values or North Carolina Water Quality Standards?
These data were not compared to either ecotoxicity screening values or North
Carolina Water Quality Standards in the report. The Unnamed Tributary is
classified as a Class 3 Surface Water Body by the North Carolina Division of
Water Quality. Analytical results for surface water samples were compared to
the following Fresh Surface Water Quality Standards For Class C Waters (15A
NCAC 02B .0211):
• Arsenic: 50 ug/L
• Beryllium: 6.5 ug/L
• Cadmium: 2.0 ug/L
• Chromium: 50 ug/L
• Nickel: 88 ug/L
• Selenium: 5.0 ug/L
• Zinc: 50 ug/L
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Mr. Jon K. Bernheim
February 6, 2007
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ARCADIS BBL
Detected concentrations of metals in surface water samples are less than the
Class 3 Surface Water Standards.
19. Page 4-1, Section 4.1, first bullet: Refer to comment #1 above.
Please see the response to comment number 1.
20. Page 4-1, Section 4.1, third bullet: Insufficient information and/or
analysis/interpretation/evaluation of the TAES data is presented in this
document to support this statement. Either strike this conclusion or
include sufficient detail to support this statement. Refer to comments
associated with OU #3 about a systematic approach for conducting a
capture zone analysis.
This statement was made based on the review of over 15 rounds of monitoring
data collected over almost ten years. Statistical analyses of data trends indicate
statistically significant decreasing trends of 1,2-DCA and DCP concentrations in
wells in the Trench Area. The annual site monitoring reports provide
groundwater contour maps for the extraction wells in the Trench Area.
21. Page 4-1, Section 4.2, first bullet: Refer to comment #9 about showing the
location of the proposed bedrock extraction well on a figure.
The attached revised Figure 2 shows the approximate location for the proposed
bedrock extraction well.
22. Page 4-1, Section 4.2, fourth bullet: Refer to comment #2 above.
Please see the response to comment number 2 above.
23. Page 4-1, section 4.2, second bullet, second sentence: I am not sure what
point is being expressed in this sentence.
The OU2 ROD specified that natural infiltration of precipitation will work with the
selected groundwater remedy effectively flushing residual soil contamination into
the groundwater capture zone. The recent sampling of unsaturated soils in the
Trench Area indicated little residual impacts above the water table in soil. This
indicates that the remedy prescribed in the ROD was successful in addressing
the soil impacts. However, the continued infiltration of precipitation through the
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Mr. Jon K. Bornholm
February 6, 2007
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• •
ARCADIS BBL
unsaturated zone may be decreasing the efficacy of the TAES in addressing
shallow groundwater impacts in the Trench Area. By reforestation of the Trench
Area infiltration will be reduced and the TAES will be focused on areas of the
Trench Area where groundwater impacts are greatest.
24, Page 4-2, Section 4.2, carry over bullet: The Agency concurs with
reforesting the Trench Area (i.e., phytoremediation). However, the Agency
is evaluating what course of action the Agency will need to take in order to
allow this to happen (i.e., ROD Amendment, Explanation of Significant
Difference, etc.). What specie(s) of plants (trees) are being considered.
BBL and NSCC appreciate the Agency's evaluation of how to incorporate this
remedy into the sitewide remedial strategy. In April, 2005, BBL planted
approximately 1,800 trees in the Trench Area to provide a canopy cover in the
area and decrease infiltration of surface water to groundwater. The trees planted
were composed of the following species: scarlet oak (Quercus coccinea), loblolly
pine (Pinus taeda), and black locust (Robinia pseudoacacia).
25. Page 4-2, Table: Another column should be included in this table
highlighting "Sampling Frequency". The proposed sampling frequency
may influence the number of wells that need to be sampled.
NSCC proposes to continue monitoring selected wells on an annual basis.
Approximately thirty rounds of data over a dozen years have been collected from
monitoring wells at the site. Annual sampling will provide sufficient data going
forward to evaluate concentration trends.
26. Page 4-2, first paragraph following the table: This paragraph discusses
installing two new monitoring wells. Would these new wells be added to
the above table?
New monitoring wells will be included in the sampling program for a minimum of
five sampling rounds. At that point in time the appropriateness of continued
monitoring will be evaluated.
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Section 1.1.2 Regulatory History
27. The second sentence of the second paragraph of Section 1.1.2 is a
fragmented sentence and does not make sense, Please correct this
oversight.
We apologize for this oversight, this sentence should read, A good faith offer was
submitted and negotiations between the USEPA and NSCC were conducted·,
resulting in the December 1, 1986 Administrative Order of Consent (AOC).
Section 3 Plume Periphery Extraction System Investigation Activities
28. The Supplemental OUI Remedy Evaluation Report does not include
supporting documentation for the conclusions expressed in Section 3.2
through Section 3.5. Please revise the Supplemental OUI Remedy
Evaluation Report to include either the necessary documentation to
support the conclusions with the appropriate documents (i.e.: Remedy
Evaluation Report for Operable Unit One, Blasland, Bouck & Lee, Inc.
(BBL), November 2000; Fracture Trace Analysis, BBL, July 2002;
Overburden Trenching and Fracture Mapping, BBL, March 2003; and,
HydroPhysical and Geophysical Logging Results, BBL, September 2003)
from which those conclusions originate.
As identified in the above comment, Section 3 described activities for which
results were presented to the Agencies in a variety of technical. memoranda. The
Supplemental OU1 Remedy Evaluation Report presented an overview of the
activities performed to date along with the results of paired surface water and
groundwater sampling in the Unnamed Tributary and recommendations to
improve the OU1 groundwater remedy and monitoring program.
Section 3.3 Fracture Trace Analysis
29. Please correct the second sentence of Section 3.3 to state" ... from the
trench area to the area of the Unnamed Tributary ... "
We apologize for this oversight.
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Mr. Jon K. Bornholm
February 6, 2007
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Section 3.6.1 Trench Area
30. Please correct the second sentence of the second bullet item located in
Section 3.6.1 to state "This is evidenced by groundwater quality data from
EX-06, EX-07 and NS-15."
We apologize for this oversight.
31. Section 3.6.1 and Table 2 do not include sufficient evidence to support the
conclusions expressed in Section 3.6.1. Please revise Section 3.6.1 to
include sufficient supporting documentation including, but not limited to:
groundwater monitoring well construction information to support
conclusions regarding hydraulic communication between the extraction
wells and the monitoring wells; ground water monitoring data to support
general groundwater flow conditions, potentiometric surface and hydraulic
capture of the Trench Area contaminant plume; laboratory analytical
results to support the recent data give as Table 2; groundwater monitoring
data to support the change in groundwater quality over time, not simply
one point in time as given in Table 2; and, groundwater quality data for
monitoring wells NS-08;, NS-16, NS-56 and the downgradient PP wells.
Additional figures would be beneficial in evaluating the spatial distribution
of contaminants from both a planar and vertical perspective.
Discussions of groundwater elevations and capture with the complete database
and analysis of groundwater monitoring results are presented in the Annual Site
Monitoring Reports.
Section 3.6.2 Plume Periphery
32. Please correct the table included in Section 3.6.2 to indicate that the
routine Operable Unit 1 (OUI) monitoring is conduced at extraction wells
EX-01, EX-02, EX-03 and EX-04 and monitoring wells NS-29, NS-30, NS-31
and NS-32.
We apologize for this oversight.
33. Section 3.6.2 and Table 3 do not include sufficient evidence to support the
conclusions expressed in Section 3.6.2. Please revise Section 3.6.2 to
include sufficient supporting documentation including, but not limited to:
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February 6, 2007
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ARCADIS BBL
groundwater monitoring well construction information to support
conclusions regarding hydraulic communication between the extraction
wells and the monitoring wells groundwater monitoring data to support
general groundwater flow conditions, potentiometric surface and hydraulic
capture of the Plume Periphery Area contaminant plume,; laboratory
analytical results to support the recent data given as Table 3; groundwater
monitoring data to support the change in groundwater quality over time,
not simply one point in time as given in Table 3; and, groundwater quality
data for monitoring wells NS-21, NS-22, NS-26 and NS-55. Additional
figures would also be beneficial in evaluating the spatial distribution of
contaminants from both a planar and vertical perspective.
Please see the response to comment number 5.
34. Please correct the second sentence of the second bullet item located in
Section 3.6.2 to state, "Acetone is detected at elevated concentrations in
well NS-56 and NS-26.
We apologize for this oversight.
35. Please correct the third sentence of the third bullet item located in Section
3.6.2 to state, "BCEE is detected at elevated concentrations in well NS-56,
NS-21 and NS-26."
We apologize for this oversight.
Section 3.6.3 Adjacent Properties
36. Please revise the second and third sentences of the second paragraph of
Section 3.6.3. Although the conceptual hydrogeologic model depicts the
Unnamed Tributary acts as a groundwater discharge feature, groundwater
contamination has been documented at monitoring well NS-31. However,
the residential wells of Linda Wolfe and the Little Acres Trailer Community
may be located (they are not shown in Figure 2) such that any contaminant
underflow noted at the Unnamed Tributary is mitigated by the localized
northeasterly flow of groundwater and discharge to the Unnamed Tributary
as noted on the southwestern side of the Unnamed Tributary. Please
revise this paragraph for clarification.
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February 6, 2007
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ARCADIS BBL
NSCC agrees with this comment. Groundwater impacts observed at monitoring
well NS-31 indicate that some groundwater underflows (or has underflown, as
operation of the PPES may have influenced groundwater elevations in such a
way to provide a conduit under pumping conditions not present under natural
hydraulic gradients) the Unnamed Tributary. As noted in the comment, based on
the Conceptual Model, groundwater flow on the southwestern side of the
Unnamed Tributary would be to the northeast, toward the Unnamed Tributary
and away from the Little Acres Trailer Community.
37. Please revise the third paragraph of Section 3.6.3 to reference the
document in which the actual groundwater analytical results and
discussion of the groundwater sampling activities at the Little Acres Trailer
Community may be located.
In August 1996, NSCC collected groundwater samples from six wells located in
the Little Acres Trailer Community. Results of groundwater sampling were
presented in the Results of Sampling and Analysis of Private Wells Letter dated
September 13, 1996.
Section 3.6.4 Surface Water in the Unnamed Tributary
38. Please revise Section 3.6.4 to include the laboratory analytical results and
a summary table to support the conclusions given in the second paragraph
of Section 3.6.4.
The laboratory analytical results and summary table for the sampling
summarized in Section 3.6.4 are presented in the Remedy Evaluation Report for
Operable Unit One (BBL, 2000).
39. Please correct the third sentence of the second paragraph of Section 3.6.4
to state, "Detected concentrations for all metals are below the ROD
performance standards, with the exception of manganese."
We apologize for this oversight.
40. Please correct the third paragraph of Section 3.6.4 to state, "The absence
of detectable concentrations of VOC's and SVOC's indicate potential
discharge is attenuated by volatilization, photodegradation, and/or mixing."
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February 6, 2007
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ARCADIS BBL
NSCC concurs. The absence of detectable concentration of voes and SVOCs
in the Unnamed Tributary may be attributable to a combination of the listed
mechanisms.
Section 3.7 Surface Water and Groundwater Sampling in the Unnamed
Tributary
41. Please correct Section 3.7 to state, "Additional surface water and
groundwater sampling was completed during October 2004 to verify
groundwater discharge to the Unnamed Tributary is attenuated by
volatilization, photodegradation, and/or mixing."
Please see the response to comment number 14.
Section 3.7.1 Methodology
42. Please revise the second paragraph of Section 3.7.1 to include greater
information regarding the collection of the groundwater samples,
including, but not limited to: sample collection _order (especially the order
in which groundwater and surface water samples are collected at each
sampling location); sample collection method; sample collection depth,
etc.
Samples were collected from the most downstream location (UN-1) to the most
upstream location (UN-15). At each sample location the field parameters were
collected first by placing the Hydrolab directly in the stream. The surface water
sample was then collected using a 1-inch Teflon bailer and the sample bottles
were filled and labeled for the analytical laboratory. After collection of the
surface water sample a 1-inch stainless steel screen with a ¾-inch-inner-
diameter was installed approximately 1.5 feet into the stream bed. Polyethylene
tubing was connected to the temporary screen and a peristaltic pump was used
to purge the volume within the temporary screen and then the sample bottles
were filled.
Section 3.7.2 Results
43. Please correct the sixth sentence of Section 3.7 .2 to state, "Conductivity
values in groundwater in this area were also greater than in other samples,
with the exception of UN-7 and UN-8."
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February 6, 2007
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ARCADIS BBL
We apologize for this oversight. Conductivity in groundwater at sample location
UN-7 was among the lowest in this area.
44. The seventh sentence of Section 3.7.2 states that conductivity values were
lowest at the upgradient sampling locations. However, Figure 4 indicates
that the lowest conductivity value was actually noted at sampling location
UN-8 and that overall the lower conductivity values were noted
downgradient at sampling locations UN-14 and UN-15. Please clarify these
discrepancies.
In general, conductivity values are lowest both up and down gradient of locations
UN-6 through UN-13, which are the locations nearest to monitoring wells NS-29,
NS-30, and NS-31. This may indicate that a combinatio_n of processes may be
reducing any VOCs and SVOCs potentially entering the Unnamed Tributary.
45. Please correct the third paragraph of Section 3.7.2 to indicate that
groundwater at locations UN-12 and UN-13 contained concentrations of bis
(2-chloroethyl) ether (BCEE) in excess of Record of Decision (ROD)
Performance Standard (6.3J and 8.1J, respectively).
NSCC apologizes for this oversight. BCEE was detected at estimated
concentrations greater than the ROD performance standard in samples UN-
12GW and UN-13GW.
46. Please correct the first sentence of the sixth paragraph of Section 3.7.2 to
state, "Evaluation of paired surface water and streambed groundwater
samples indicate discharge of groundwater into the stream from the
surrounding saprolite."
NSCC apologizes for this oversight.
47. Please revise the sixth paragraph of Section 3.7.2 to discuss the large
differences noted in the surface water and groundwater conductivity
measurements collected at sampling points UN-6, UN-7, UN-8 and UN-10,
including the impact of reducing conditions on conductivity values in the
groundwater, equipment calibration, potential for sampling locations UN-12
and UN-13.
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Mr. Jon K. Bornholm
February 6, 2007
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ARCADIS BBL
The observed differences in conductivity between the groundwater and surface
water samples collected at UN-6, UN-7, UN-8 and UN-10 would indicate that
different processes are occurring in the groundwater versus the surface water.
Introduction of oxygen to groundwater entering the Unnamed Tributary may
effect the conductivity of the water. Equipment calibration was performed at the
beginning of the sampling day and conductivity measurements were collected
from both the surface water and groundwater at each location before moving to
the next location, so it is unlikely that the differing conductivity values are a result
of faulty equipment.
48. Please correct the second sentence of the seventh paragraph of Section
3.7.2 to reflect the presence of SCEE in excess of ROD Performance
Standards at groundwater sampling locations UN-12 and UN-13.
NSCC apologizes for this oversight. BCEE was detected at estimated
concentrations in samples UN-12GW and UN-13GW.
Section 4.1 Conclusions
49. Please revise the second bullet item of Section 4.1 to state, "Operation of
the PPES increased the area and magnitude of the impacted aquifer by
drawing impacted groundwater further down-and side-gradient at a greater
rate of flow than under non-pumping conditions."
We apologize for this oversight.
50. As previously stated, the Supplemental OUI Remedy Evaluation Report
does not include sufficient supporting documentation for the conclusions
· expressed in Section 4.2. Please revise the Supplemental OUI Remedy
Evaluation Report to include the specific information required to support
the conclusions expressed in Section 4.1.
Please see the response to comment number 2.
Section 4.2 Recommendations
51. Please revise Section 4.2 to include much greater detail and justification to
support the recommendations given in Section 4.2. Please revise Section
4.2 to include additional information such as, but not limited to:
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Mr. Jon K. Bernheim
February 6, 2007
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ARCADIS BBL
Groundwater monitoring well construction information; groundwater
monitoring data to support general groundwater flow conditions,
potentiometric surface and hydraulic capture of the Trench Area and Plume
Periphery contaminant plume for both existing and proposed extraction
scenarios; groundwater monitoring data to support the change in
groundwater quality over time, not simply one point in time as given in the
Supplemental OUI Remedy Evaluation Report; additional information to
/ support the anecdotal evidence of the natural attenuation of contaminants
at the Site; additional information regarding the methodologies and impact
of the proposed reforestationlphytoremediation of the Trench Area, etc.
Please see the response to comment number 5.
Table 4 Unnamed Tributary Groundwater and Surface Water Analytical Results
52. Please revise Table 4 to indicate that groundwater at locations UN-12 and
UN-13 contained concentrations of bis (2-chloroethyl) ether (BCEE) in
exce_ss of Record of Decision (ROD) Performance Standard (6.3J and 8.1J,
respectively).
We apologize for this oversight.
Figure 2 Site Map
53. Groundwater monitoring wells NS-55 and NS-56 were inadvertently omitted
from Figure 2. Please correct this oversight.
Attached please find a revised Figure 2 showing the locations of monitoring wells
NS-55 and NS-56.
54. Please revise Figure 2 to include the locations of the residential drinking
water wells for Linda Wolfe and the Little Acres Trailer Community, as
referenced in Section 3.6.3.
Attached please find revised Figure 2 which includes the locations of the
domestic wells within the Little Acres Trailer Park.
As recommended in the Supplemental Remedy Evaluation Report, the following
activities will be implemented:
018711962.doc
Mr. Jon K. Bornholm
February 6, 2007
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ARCADIS BBL
• Modification of the TAES pumping array may provide benefits to the overall
implementation of the OU1 remedy. Specifically, ceasing operation of
extraction wells EX-06 and EX-07 is warranted due to improvement in
groundwater quality in the vicinity of the wells. Additionally, implementation
of bedrock pumping in the vicinity of NS-56 may provide additional control on
dissolved phase constituents with potential to migrate through fracture
conduits into the Plume Periphery.
• In addition, two new monitoring wells will be installed and monitored. An
additional transition zone well down gradient of NS-28 and a bedrock
monitoring well near NS-28. Proposed monitoring wells locations are shown
on revised Figure 2. Piezometers P-2 and P-4 will also be inspected to
establish their appropriateness for addition to the monitoring program. If
possible, these piezometers will be converted to monitoring wells and added .
to the groundwater monitoring program.
Field investigation activities are scheduled to commence the week of April 23, 2007.
If you have any questions or comments, please contact me by phone at
925.296.7813 or by e-mail at [e-mail].
Sincerely,
ARCADIS U.S, Inc.
MiW;;h~-
Vice President
Copies:
David Mattison, North Carolina Department of Environmental and Natural Resources
Angela Dahl, National Starch and Chemical Company
David Simons, National Starch and Chemical Company
018711962.<ioc
Mr. Jon K. Bornholm
February 6, 2007
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LEGEND:
e MONITORING WELL LOCATION
♦ EXTRACTION ,YELL LOCATION
-$-STREAM GAUGE LOCATION
0 LITTI ... E ACRES TRAILER PARK
DOMESTIC WELL LOCATION
..t. APPROXIMA T£ LOCATION OF SURF ACE
WATER/SEDIMENT SAMPLING LOCATION
):( PROPOSED BEDROCK EXTRACTIOO WELL
LOCATION
SOURCES:
-MAP ENTITLED "SITE MAP" PREPARED FOR NATIONAL STARCH
AND CHEMICAL COMPANY BY INTERNATIONAL TECHNOLOGY
CORPORATION, KNOXVILLE, TENN., DATED 5/18/93.
-MONITORING WELL SURVEY BY SCHULENBERGER SURVEYING
COMPANY, SAUSBURY, N.C., DATED 1/21/97
-MONITORING WELL SURVEY BY TA'l'lOR WEISI-JAN & TAYLOR.
RALEIGH N.C., DATED 3/98
-MAP ENTITLED "FIGURE J-1, LOCATION OF SOIL PLOTS ANO
SOIL GAS MONITORING 'NELLS IN AREA 2" PREPARED BY
NATIONAL STARCH AND CHEMICAL COMPANY. SALISBURY, N.C.
DA TE: UNKNOWN
-~AP ENTITLED "FIGURE J-2, LOCATION OF REPLICATION PLOTS
AND SOIL GAS ~ONITORING 'NELLS IN TI,E LAGOON AREA".
PREPARED BY NATIONAL STARCH AND CHE~ICAL CO'-!PANY.
SALISBURY. N.C. DATE: UNKNOWN.
GR,t,.F'HIC scm
NATIONAL STARCH AND CHEMICAL COMPANY
CEDAR SPRINGS ROAD PLANT, SALISBURY, NORTH CAROLINA
SUPPLEMENTAL OU1 REMEDY
EVALUATION REPORT
SITE MAP
BBL;
~" ARCADIS ==
FIGURE
2
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LEGEND
• MONITORING WELL LOCATION
♦ EXTRACTION WELL LOCATION
$ STREAM GAUGE LOCATION
__ FRACTURE TRACE SET No. 1
__ FRACTURE TRACE SET No. 2
__ FRACTURE TRACE SET No. J
__ FRACTURE TRACE SET No. 4
__ FRACTURE TRACE SET No. 5
,oo· 0
SCALE IN f'EET
,oo·
CEDAR tp\~~i:LRJ!~R~t'..~f.D S;~l~~~:{. ~i~~~N~AROLINA
FRACTURE TRACE ANALYSIS
1980 AERIAL PHOTO ANALYSIS
BBL
BlASlAND, aouac 6. l£E, N'.:.
•ngln••" a 1cf•nlht•
FIGURE
2
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_.-/'--::-OBSERVATION Tll[>fCH f10 --l[~GTH • 1'~ 73•
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e MONITORING 'NELL LOCATION
♦ EXTRACTION 'NELL LOCATION + PROPOSEO MONITORING 'NELL LOCATION
-----OBSERVATION TRENCH
A
B
C
D
E
F
IDENTIFIED FRACTURE TRACE
TRENCH FEATURES:
AREA Of QUARTZ INTRUSIONS
SEE PHOTOS 3, 6, 7
MEOIUM-GRAINEO MASSIVE ROCK
SEE PHOTS 8-12
AREAS OF FELDSPAR & QUARTZ
INTRUSIONS !N EXTREMELY WEATI-iEREO
OiORITE ROCK SEE PHOTOS 13-16
ROCK KNOB WITH INTRUSION, AREA
OF SHALLOW ROCK ( 4 FEET BGS)
SEE PHOTOS 17 & 18
AREAS OF HEAVY QUARTZ & FELDSPAR
INTRUSIONS AND CONTACT OF
DIFFERENT SAPROUTE MATERIALS
SEE PHOTOS 23-25
QUARTZ ZONE SUSPENDED IN
REO-BROl',N CLAY (4 FEET BGS)
SEE PHOTO 29
SOURC£S:
-MAP ENTITLED •SITE MAP' PREPARED FOR NATIONAL STARCH
AND CHEMICAL COMPANY BY INTERNATIONAL TECHNOLOGY
CORPORATION, KNOXVILLE, TENN., DATED 5/18/93.
MONITORING 'NELL SURVEY BY SCHULENBERGER SURVEYING
COMPANY, SALISBURY, N.C .. OATED 1/21/97
MONITORING 'NELL SURVEY BY TAnOR WEISMAN & TAnOR.
RALEIGH N.C., DA TEO 3/98
-OBSERVATION AND COLLECTION TRENCH AREAS TAKEN FROM
TAnOR WISrnAN & TAnOR ENGINEERING DRAWING TITLED:
"OBSERVATION TRENCH LOCATION MAP", SHEET 1/1,
PROJECT No. 70372.0003.00, DATED: 12/23/02.
CR~IC SC.OU:
NATIONAL STARCH AND CHEMICAL COMPANY
SPRING ROAD PLANT, SALISBURY, NORTH CAROLINA TECHNICAL MEMORANDUM
ON OVERBURDEN TRENCHING
TRENCH LOCATIONS
BBL
BI.ASI.AND, EIOOCK & LEE, INC. •nr,ln••11 a 1cl•ntJ,t1
FlGURE
2
Date Start/Finish: 08/05/03-02/16/04
Drilling.Company:_ Geologic ExploratiOn
Drlller'.s Nania: Mike McConeley ·
Drilling Method: Hollow. Stem Auger/Air-Rig
BIISlze: 8.00" 00/6.00" OD
Auger Slz8: 4.25" fo
Rig Type: Mobile 8-61 HDX
Sampling Method: 2" OD x 2'
5
z 0 ~ UJ -'
740
735
730
10
725
15
720
20
715
25
710
30
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35
,..
BBL
BIASLAND, BOUCK & LEE, INC.
engineers & scientists
Northing: 686973.56
Easting: 1542236.90 •
:NS-55
0 . . ' CaSlng Elevation: -742.52' AMSL Client: .Nat!onal Starch and Chemical Company
Borehole Depth: 160' SGS
Surface Elevation: 738.88' AMSL Location: Ced'ar-Springs-Road Plant
SaliSbuiy, North Carolina
Geologist: Brian Lovgren
Well Construction Details
1-------Protective Casing
Concrete Pad
/-,,.,_ _____ Grout
:J------6" Galvanized Outer Casing
Remarks: AMSL = Above Mean Sea Level;
BGS = Below Ground Surface; and
NA= Not Applicable/Available.
Project: 05007.001
Data Flle:NS55.dat
Template:Wel1Const2003.ldf
Date: 06/21/04
Page: 1 of 4
Date Start/Finish: 08/05/03-02/16/04
Drilling Company: Geologic Exploration
Drlll~r·s Name: Mike McConeley
Drilling Method: Hollow Stem Auger/Air Rig
Bit. Size: 8.00" OD/6.00" OD
Auger Size: 4.25" ID
Rig Type: Mobile B-61 HDX
S;impllng Method: 2" 00 x 2'
40
45
z 0 ~ .J
700
695
690
50
685
55
680
60
675
65
70
75
670
665
BBL
BLASLAND, BOUCK & LEE, INC.
engineers & scientists
Northing: 686973.56
Easting: 1542236.90
Casing Elevation: 742.52' AMSL
Borehole Depth: 160' BGS
Surface Elevation: 738.88' AMSL
·Geologist: Brian Lovgren
Well Construction Details
.D:NS-55
Client: National Starch and Chemical Company
Location: Cedar Springs Road Plant
· Salisbury, North Carolina
Bentonite Chip Seal
0.010" Slot Stainless Steel Well Screen
#2 Sand
Remarks: AMSL = Above Mean Sea Level;
BGS = Below Ground Surface; and
NA = Not Applicable/Available.
Project: 05007.001
Data File:NS55.dal
Template:Wel1Const2003.ldf
Date: 06/21/04
Page: 2 of 4
Date Start/Finish: 06/05/03-02/16/04
Drilling Company: Geologic Exploration
Driller's Name: Mike McConeley
Drilling Method: Hollow Stem Auger/Air Rig
Bit Size: 6.00" OD/6.00" OD
Auger Size: 4.~5" ID
Rig Type: Mobile B-61 HDX
SalTlpllng Method: 2" OD x 2'
z 0 ;::
I ,g; I-a. w w ..J
660
80
655
85
650
90
645
95
640
100
635
105
630
110
625
115
620
BBL
BLASLAND, BOUCK & LEE, INC.
engineers & scientists
Northing: 666973.56
Easting: 1542236.90
Casing Elevation: 742.52' AMSL
Borehole Depth: 160' BGS
Surface Elevation: 738.88' AMSL
Geologist: Brian Lovgren
Well Construction Details
.D:NS-55.
Client: Nation.al Starch and Chemical Company
Location: Ce~ar Springs Road Plant
Salisbury, North Carolina
Remarks: AMSL = Above Mean Sea Level;
BGS = Below Ground Surface; and
NA = Not Applicable/Available.
Project: 05007.001
Data Fllo:NS55.dat
Template:Wel1Const2003.ldf
Dato: 06/21104
Page: 3 of4
Date Start/Finish: 08/05/03-02/16/04
Drllllng,Company: Geologic Exploration
Drlller's'Name: Mike McConeley
Drllllng· Method: Hollow Stem Auger/Air Rig
Bit Size: 8.00" OD/6.00" OD
Auger Size: 4.25" ID
Rig Type: Mobile B-61 HDX
Sampling Method: 2" OD x 2'
z 0 ~ w _J
620
120
615
125
610
130
605
135
600
140
595
145
590
150
585
155
580
160
BBL
BLASLAND, BOUCK & LEE, INC.
engineers & scientists
Northing: 686973.56
Easting: 1542236.90
Casing Elevation: 742.52' AMSL
Borehole Depth: 160' BGS
Surfcice Elevation: 738.88' AMSL
Geologist: Brian Lovgren
Well Construction Details
Remarks: AMSL = Above Mean Sea Level:
.D:NS-55
Client: Nation~! Starch and Chemical Company
Location: Cedar. Springs Road Plant
Salisbury, North Carolina
BGS = Below Ground Surface: and
NA = Not Applicable/Available.
Project: 05007 .001
Data File:NS55.dat
Template:We11Const2003.ldf
Date: 06121/04
Page: 4 of 4
Date Start/Finish: 08/05/03-02/16/04
Orllllng Company: Geologic Exploration
Orlller's Name: Mike McConeley
Drilling Method: Hollow Stem Auger/Air Rig
Bit Size: 8.00" 00/6.00" OD
Auger Size: 4.25" ID
Rig Type: Mobile B-61 HDX
Sa!"pling Method: 2" OD x 2'
:,: t w
5
z 0 ~ .J
765
760
10
755
15
750
20
745
25
740
30
735
35
730
BBL
BLASLAND, BOUCK & LEE, INC.
engineers & scientists
Northing: 687742.00
Easting: 1542715.76
Casing Elevation: 769.04' AMSL
Borehole Depth: 160' BGS
Si.Jrface Elevation: 765.74' AMSL
Geologist: Brian Lovgren
Well Construction Details
.D:NS-56
Client: National Starch and Chemical Company
Location: Cedar Springs Road Plant
Salisbury, North Carolina
._ ______ Protective Casing
Concrete Pad
Remarks: AMSL = Above Mean Sea Level;
SGS = Below Ground Surface; and
NA= Not Applicable/Available.
Project: 05007.001
Data File:NS56.dat
Template:Wel1Const2003.ldf
Date: 06/21/04
Page: 1 of 4
Date Start/Finish: 08/05/03-02/16/04
Orllllng Compally: Geologic Exploration
Driller's Name: Mike McConeley
Drilling Method: Hollow Stem Auger/Air Rig
Bit Size: 8.00" OD/6.00" OD
Auger Size: 4.25" ID
Rig Type: Mobile B-61 HDX
SampllnQ Method: 2" 00 x 2'
z 0 ~ w ...J
40
725
45
720
50
715
55
710
60
705
65
700
70
695
75
690
BBL
BLASLAND,_ BOUCK & LEE, INC.
engineers & scientists
Northing: 687742.00
Easting: 1542715.76
Casing Elevation: 769.04' AMSL
Borehole Depth: 160' BGS
Surface Elevation: 765.74' AMSL
Geologist: Brian Lovgren
Well Construction D.etails
.:NS-56
Cllent: National Starch and Chemical Company
Location: Cedar Springs Road Plant
Salisbury, North Carolina
V,.4-----4" Stainless Steel Well Riser
t<'I-----Bentonite Chip Seal
~ 1
I\
~--ii; ,.;,,
-~'f•·.
Remarks: AMSL = Above Mean Sea Level;
BGS = Below Ground Surface; and
NA= Not Applicable/Available.
Project: 05007 .001
Data File:NS56.dat
Template:We11Const2003.ldf
Date: 06/21/04
Paga: 2 of 4
Date Start/Finish: 0B/05/03-02/16/04
Drllllng ComPaiiy: Geologic Exploration
Driller's Name: Mike McConeley
Drilling Method: Hollow Stem Auger/Air Rig
Bit Size: 8.00" OD/6.00" OD
Auger Size: 4.25" ID
Rig Type: Mobile B-61 HDX
Sampling Method: 2" OD x 2'
z 0 ~ w _,
80
685
85
680
90
675
95
670
100
665
105
660
110
655
115
650
BBL
BLASLAND, BOUCK & LEE, INC.
engineers & sclenllsis
Northing: 687742.00
Easting: 1542715.76
Casing Elevation: 769.04' AMSL
Borehole Depth: 160' BGS
Surface Elevation: 765.74' AMSL
Geologist: Brian Lovgren
Well Construction Details
.,NS-56
·client: Nation~! Starch and Chemical Company
Location: Cedar Springs Road Plant
SciliSbliry, NOrth Carolina
0.010" Slot Stainless Steel Well Screen
...,. _____ #2 Sand
Remarks: AMSL = Above Mean Sea Level;
BGS = Below Ground Surface; and
NA= Not Applicable/Available.
Project: 05007.001
Data File: NS56.dat
Template:WeUConst2003.ldf
Date: 06/21/04
Page: 3 of4
Date Start/Finish: 08/05/03-02/16/04
Drllllng Company: Geologic Exploration
Orlller's Name: Mike McConeley
Orllllng Method: Hollow Stem Auger/Air Rig
Bit Size: 8.00" OD/6.00" OD
Auger Size: 4.25" ID
Rig Type: Mobile B-61 HDX
Sampling Method: 2" OD x 2'
120
645
125
640
130
635
135
630
140
625
145
620
150
615
155
610
160
BBL
BlASLAND, BOUCK & LEE, INC.
engineers & so/ent/sfs
Northing: 687742.00
Easting: 1542715.76
Casing Elevation: 769.04' AMSL
Borehole Depth: 160' BGS
Surface Elevation: 765.74' AMSL
Geologist: Brian Lovgren
Well Construction Details
.D:NS-56
Client: National Starch and Chemical Company
Location: Cedar Springs Road Plant
Salisbury, North Carolina
Remarks: AMSL = Above Mean Sea Level;
BGS = Below Ground Surface; and
NA = Not Applicable/Available.
Project: 05007.001
Data File: NS56.dat
Template:WeUConst2003.ldf
Date: 06/21/04
Page: 4 of 4
I • • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
4WD-SRSEB
Ms. Angela J. Doh!
SAM NUNN ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
December 27, 2006
National Starch & Chemical Company
10 Findeme Avenue
Bridgewater, New Jersey 08807
Mr. Michael P. Fleischner
Ms. Jessica A. Seebald
Blasland, Bouck & Lee, Inc.
2033 North Main Street
Suite 340
Walnut Creek, California 94596
SUBJ: Comments on Operable Unit #4 Soil Delineation Work Plan for National Starch &
Chemical Company Superfund Site, Salisbury, Rowan County, North Carolina
Dear Ms. Doh!, Mr. Fleischner, & Ms. Seebald:
The Agency received the above referenced document dated, December 5, 2006, on
December 11, 2006. Due to a delay in North Carolina Department of Environment and Natural
Resources (NCDENR) receiving a copy of this Work Plan, the Agency has not received any
comments from NCDENR. The Agency will forward the State's comments upon receipt. Below
are the Agency's comments. These comments as well as any the State may offer need to be
addressed prior to initiating field work.
I. Page I of 4, second paragraph: This paragraph discusses delineating the extent of soil
contamination in the horizontal direction. What is the possibility of using the Geo Probe™ or
another contractor such as Vironex with a Membrane Interface Probe (MIP)
{www.vironex.com} to investigate the presence of dense non-aqueous phase liquid
(DNAPL) in this area? This has been a lingering question and any additional information
will help to address this question.
2. Page 2 of 4, Soil Sampling Methodology Section, first paragraph: Does G~oProbe TM have
an auger head that allows you to measure volatile organic compounds (VOCs) in real time?
If not, how about using a system such as Vironex' s MIP system?
3. Page 2 of 4, Soil Sampling Methodology Section, first paragraph, third sentence: This
sentence implies that the only portion of the core that will be logged for lithologic properties
including soil type, color, moisture content, etc. is the portion that are sampled. It would
make more sense to record the Ii tho logic properties for the entire core instead of just the
portions where samples are collected.
• 2 •
4. Page 2 of 4, Soil Samp/i11g Methodology Section, first paragraph, fifth sentence: This
sentence states that a soil sample will be collected from each discrete interval identified in
Table I. Is there any room for adding additional samples in case something unexpected is
encountered? The following statement should be added to this paragraph, "Additional
samples may be collected based on observation made in the field."
5. Page 2 of 4, Soil Samp/i11g Methodology Section, first paragraph, fifth sentence: This
sentence states that a soil sample will be collected frnm a discrete 12-inch interval. How will
the lost ofVOCs be minimized during the collection of the soil samples? Would the use of
an Encore Sampler or something similar be applicable?
6. Page 3 of 4, Soil Sampli11g Methodology Section, second paragraph, last sentence: Change
this sentence to read," ... (EISOPQAM [USEPA, 19961. as amended".
7. Page 3 of 4, Proposed Ill-Situ Waste Characterizatio11 Sampli11g Activities Section, first
paragraph, first sentence: This sentence should clearly state that soil from the soil borings
discussed in the previous Section will be used to form the soil samples discussed in this
Section. The language in this sentence can be interpreted to say that additional soil borings
will be made in order to collect the soil samples for the purpose discussed in this paragraph.
What will be done to minimize the lost of 1,2-DCA as sufficient soil is collected?
8. Page 3 of 4, Proposed Ill-Situ Waste Characterizatio11 Sampli11g Activities Section, first
paragraph, second sentence: Typo, this sentence should read, "Soil samples will m; collected
from ... ".
9. Page 3 of 4, , Proposed Be11ch Scale Test Section, first paragraph, Will other oxidants be
tested for treating 1,2-DCA in this Bench Scale Test?
10. Page 4 of 4, Proposed Be11ch Scale Test Section, paragraph at top of page: A number of
two-inch split spoon soil samples will be needed to fill a 5-gallon bucket.I Is there not a more
efficient method of collecting the necessary quantity/volume of soil? What will be done to
minimize the lost of 1,2-DCA as sufficient soil is collected? i
11. Page 4 of 4, Proposed Be11ch Scale Test Section, second full paragraph, last sentence: What
is the significance of this sentence with the work being proposed at the Site?
If you have any questions, please feel to call me at 404-562-8820.
cc: David Mattison, NCDENR
Sincerely,
Jon K. Bomholm
Remedial Project Manager