NCD991278953_20110315_National Starch & Chemical Corp._FRBCERCLA LTRA_Site Monitoring Report 2007 - 2011-OCR

I'
Mattison, David
From:
Sent:
To:
Cc:
Subject:
Elizabeth,
[e-mail]
Tuesday, March 15, 2011 3:11 PM
Rhine, Elizabeth
[e-mail]; Mattison, David; Rubenstein, Debra; McMurray, Jerry
RE: Comments on 2009 Site Monitoring Report
I have reviewed your responses to comments on the 2009 Site Monitoring Report. The majority
of the responses are acceptable. However, my review raised the following comments/thoughts.
The intent of Comment #3 was to ascertain whether or not soil samples were collected from the
soil used to backfill in the areas excavated under the concrete driveway. The point of this
sampling effort would have been to confirm that the backfill soil was "clean". EPA typically
collects and analyses a soil sample or two from the source of soil to be used as backfill to
confirm it is clean fill.
Response to Comment #6: The Agency understands the desire for maintaining consistency.
However, the response raises the question, are we collecting the groundwater sample from this
well at the appropriate depth? If the majority of the contaminant mass flux is at a lower
depth, then collecting the groundwater sample at the center point of the_screen is more
likely than not leading to the collection of a diluted
sample. This situation would be exacerbated if the screen intercepts a
more productive fracture which is not as contaminated at a higher elevation. The Agency
concurs that the intake of the extraction pump should be located in this area in order to
remove this mass flux.
However, the current sampling protocol may be providing misleading information about the
quality of groundwater being intercepted by this extraction well.
Response to Comment #7: Since the concentrations of contaminants in the groundwater
intercepted by EX-08 are similar to the concentrations of contaminants being detected in EX-
05 and EX-09 and since there is radial flow around EX-08, it may be beneficial to brin'g EX-08
back on line sooner rather than later. Of course, this urgency would not be as great if the
capture zone for EX-05 and EX-09 was shown to extend as far east as where EX-08 is located.
However, I don't believe this will be the case.
Response to Comment #15, second bullet: The response does a thorough job in describing
activities in the event that the yield of EX-08 is greater
than 2 gpm. What will be the course of action if the yield from EX-08
is significantly less than 2 gpm?
Comment #18: Instead of generating another figure for future reports to show the location of
P-03, it may be advisable to include a notation on an existing figure along with an arrow
pointing in the general location of P-03. The notation can read something like, "P-03 is
located X number feet in this direction''.
If you have any questions, please give me a call.
Jon Bornholm
Remedial Project Manager
EPA Region 4/Superfund Division
Superfund Remedial & Site Evaluation Branch
(o) 404-562-8820 (c) 404-217-8565
/
Jon,
''Rhine,
Elizabeth"
<Elizabeth.R
hine@arcadis
-us.com>
03/15/2011
11:15 AM
To
Jon Bornholm/R4/USEPA/US@EPA,
"[e-mail]"
<[e-mail]>
cc
''[e-mail]''
<[e-mail]>,
"Rubenstein, Debra''
<[e-mail]>,
''McMurray, Jerry''
<[e-mail]>
Subject
RE: Comments on 2009 Site Monitoring
Report
On behalf of AkzoNobel, attached are our response to your comments on the 2009 Site
Monitoring Report for the National Starch & Chemical Company Superfund site located in
Salisbury, NC.
If I can be of further assistance, please contact me at 864.987.3906.
Best regards,
Elizabeth Rhine
-----Original Message-----
From: [e-mail] [mailto:[e-mail]]
Sent: Monday, January 24, 2011 3:25 PM
To: [e-mail]; Rhine, Elizabeth
Cc: [e-mail]
Subject: Comments on 2009 Site Monitoring Report
If you would like a signed copy, please let me know,
Jon
Remedial Project Manager
EPA Region 4/Superfund Division
Superfund Remedial & Site Evaluation Branch
(o) 404-562-8820 (c) 404-217-8565
2
(See attached file: Comments on 2009 Site Monitoring Report-FINAL.doc)
NOTICE: This e-mail and any files transmitted with it are the property of ARCADIS U.S., Inc.
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[attachment "NSCC 2009 SMR RTCs_Final. pdf" deleted by Jon Bornholm/R4/USEPA/US]
3
, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4SF-SRSEB
Ms. Angela J. Dohl
Consulting Engineer
AkzoNohcl Corporate Legacies
IO Finderne Avenue
Bridgewater, NJ 08807
Ms. Elizabeth Rhine
Project Manager
ARCADIS U.S., Inc.
SAM NUNN ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
January 24, 2011
30 Patewood Drive, Suite 155
Greenville, South Carolina 29615
SUBJ: Comments on 2009 Site Monitoring Report for the National Starch & Chemical
Company Superfund Site in Salisbury, Rowan County, North Carolina
Dear Ms. Dohl & Ms. Rhine:
The Agency and North Carolina Department of Environment & Natural Resources
(NCDENR) received a copy of the above referenced document, dated July 22, 2010, on or
around July 26,2010. This report was prepared on behalf of AkzoNobel by ARCADIS. Below
arc the Agency's comments. NCDENR did not have any comments to offer.
Overall, this report was well written. As you will see, a number of the comments
highlight typos. There arc only a handful of substantive comments, none of which affect the
outcome of this report. Therefore, the Agency considers this report to be final. The following
comments can be addressed a in either a letter format or via email.
I. Appendix L-Is there an explanation as to why the elevations for the bentonite seal for the
following air sparging wells were omitted from the drawings in Appendix L: AS-I, AS-2.
AS-6, AS-7, AS-8, AS-10, AS-I 1, AS-12, AS-13, AS-14, AS-15, and AS-16.
2. Page 3-3, Section 3.3 Soil Sampling, first paragraph, first sentence: Typo, second "are"
should read "as".
3. Page 3-3, Section 3.3 Soil Sampling, first paragraph: Were soil samples taken from the soil
used as clean fill in Phases 1-111 in the Production Area? lfso, was that data included in this
report?
2
4. Page 4-2, Section 4.1 Remediation Program, third bullet: Typo, should the phrase
""monitoring wells" read "screens"?
5. Page 4-4, Section 4.1 Remediation Program, fourth paragraph: Is there an estimated
timeframe to collect the necessary data, evaluate the data, and generate a conclusion for the
capture zone analysis?
6. Page 4-7, Section 4.3.1 Vertical Profiling, second paragraph: Was the data generated from
the passive diffusion bag effort used to help determine where to set the intake for the low
!low sampling effort in the appropriate monitoring wells for the December 2009
groundwater sampling effort?
7. Page 4-11, Section 4.3.3 Shallow Bedrock, first full paragraph: How do the concentrations of
chemicals detected in EX-08 fit into this discussion since EX-08 is near EX-07?
8. Page 4-12, Section OU I Data Evaluation, first paragraph, last sentence: This sentence states
there are reducing conditions in the aquifer downgradient of the Trench Area. Do the field
parameter measurements collected during purging efforts for the monitoring wells in this
area support this conclusion? If so, future reports should include some text highlighting this
point. If this data does not support this claim, then the text needs to explain this as well.
9. Page 6-4, Section 6.3.1 Lagoon Area, last sentence: Typo, "Figure 17" should read "Figure
19".
I 0. Page 6-6, Section 6.3.1.4 Deep Bedrock, first paragraph, first sentence: Typo, "2008" should
read "2009".
11. Page 6-8, Section 6.3.2.2 Shallow Bedrock, second paragraph, last sentence: Typo, the
second "NS-61" should read "NS-60".
12. Page 8-1 Section 8.0 Conclusions and Recommendations, first bullet: Typo, should "OU3''
read "OU2"?
I 3. Page 8-1 Section 8.0 Conclusions and Recommendations, filth bullet: More out of curiosity,
of the 1,800 trees planted, any estimate as to how many survived?
14. Page 8-2 Section 8.0 Conclusions and Recommendations, first bullet, third sentence: How
long will the transducers be !ell in place to measure changes in groundwater levels?
15. Page 8-2 Section 8.0 Conclusions and Recommendations, first bullet, fiflh sentence: This
sentence states that additional extraction wells may be brought online. If the decision is
made to bring additional extraction wells on line, what is the estimated timeline to complete
this effort? Will the well(s) be redeveloped? Will the conveyance lines need to be cleaned
out? What's the timeframe for delivery of new equipment, etc.?
3
16. Page 8-2 Section 8.0 Conclusions and Recommendations, third bullet: The Agency is
anticipating receiving some sort of a preliminary report prior to going full scale with the
Enhanced Reductive Dechlorination Pilot Scale Study.
17. Table 2: What will be done with P-01 since the borehole has collapsed?
18. Table 2: I could not locate P-03 on Figure 2.
19. Figure IO -Conceptual Groundwater Flow in the Piedmont: How does this
conceptualization explain the occurrence at NS-31?
20. Figure 17: Pros/cons of pairing a shallow bedrock monitoring well with monitoring well NS-
58?
As implied above, only the pertinent comments above need to be adequately addressed.
This can be accomplished in either a letter or email. lfyou have any questions, please feel to call
me at (o) 404-562-8820 or (c) 404-217-8565 or contact me at [e-mail].
cc: David Mattison, NCDENR
Sincerely,
Jon K. Bornholm
Remedial Project Manager
~ARCAD~S
lnfrastruc/urc • VV<Jter • Environment [3uildings
Mr. Jon Bomholm
Remedial Project Manager
U.S. EPA Region IV
61 Forsyth Street, SW
Atlanta, Georgia 30303
Subject:
Response to EPA Comments on the 2009 Site Monitoring Report.
Former National Starch & Chemical Company Superfund Site
Salisbury, Rowan County, North Carolina
Dear Mr. Bomholm:
On behalf of AkzoNobel Surface Chemistry LLC, ARCADIS is pleased to
provide the following responses to the US EPA (Agency) comments dated
January 24, 2011 regarding the 2009 Site Monitoring Report for the former
National Starch & Chemical Company Supcrfund Site located on Cedar
Springs Road in Salisbury, North Carolina.
Comment/. Appendix L -Is there on explanation as to why the elevations for
the bentonite seal for the following air sparging wells were omilled from the
drawings in Appendix L: AS-I, AS-2. AS-6, AS-7, AS-8, AS-JO, AS-I I, AS-/2,
AS-13, AS-14, AS-15, and AS-16.
Response I. Due to a formatting problem with the original Excel
spreadsheets, the depths to the top and bottom of the bentonite seals were
inadvertently hidden. The revised construction diagrams for the air sparge
wells are included as an attachment.
Comment 2. Page 3-3, Section 3.3 Soil Sampling,first paragraph,first
sentence: Typo, second "are" should read "as"_
Response 2. Agreed.
Imagine the result
g 1an'llnab0nal stan:n\2009 annual r,-pon\rtcs to me 2009 smMscc 2009 srm rb_~n;>t <IOC•
ARCADIS U.S., Inc
30 Patewood Drive
Suite 155
Greenville
South Carolina 29615
Te! 864.987.3900
Fax [phone]
www.arcadis-us.com
Environmental
Date·
March 15, 2010
Contact:
Elizabeth Rhine
Phone:
864-987-3906
Email
[e-mail]
Our ref:
B0060013
ARCADIS
Comment 3. Page 3-3, Section 3.3 Soil Sampling.first paragraph: Were soil
samples takenfrom the soil used as c/eanfi/1 in Phases I-Ill in the Production
Area? I/so, was that data included in this report?
Response 3. The soil sampling methodologies described in Section 3.3 are
specifically related to collection of soil samples in the Lagoon Area. Section
7 .1.1.4 discussed the soils removed during the road replacement in the
production area. The soils removed during the three phases of road
replacement were initially screened using a photoionization detector. The
soils where then transported to an onsite staging area where they were
segregated in accordance with the screening process and stockpiled on plastic
sheeting. The soil piles were then sampled for the VOCs, SVOCs and RCRA
Metals. The analytical results of the soil sampling were included in the 2009
SMR in Appendix E. The Phase I soil sampling results indicated the presence
of 1,2-DCA at concentrations below the remediation goal; no other
constituents were detected. These soils were spread in OU2. Phase II and
Phase Ill soils were profiled and disposed ofat a composting facility (Earthcc)
in Sanford, North Carolina. The disposal certificates for the Phase II and
Phase III soils were included as Appendix 0.
Comment 4. Page 4-2, Section 4.1 Remediation Program, third bullet: Typo.
should the phrase "monitoring wells" read "screens"?
Response 4. Agreed.
Comment 5. Page 4-4, Section 4. I Remediation Program.fourth paragraph:
Is there an estimated timeframe to collect the necessary data, evaluate the
data, and generate a conclusion for the capture zone analysis?
Response 5. Throughout the fourth quarter of2010 the operation of the TAES
was intermittent as the groundwater extraction and pretreatment systems were
evaluated and optimized as necessary. Between January 3 and February I 8,
2011 the TAES was online and pumping continuously from EX-05 and EX-
09. Once the equalization tank was filled, the extraction wells had to be shut
down because the air stripper was unable to operate at a rate equal to the
extraction rate due to excessive foaming. An alternate defoamcr has been
tested and ordered, and the system wi II be restarted as soon as the product is
delivered. The data necessary to evaluate the capture zone of the TAES will
be collected for a minimum of three months. The data collected will be used
Mr. Jon Bornholm
March 15, 2011
Page·
2/8
ARCADIS
to evaluate the capture zone. The results of the capture zone analyses and
conclusions/recommendations will be submitted to the Agency in a separate
submittal, which is anticipated to be submitted in June 2011.
Comment 6. Page 4-7, Section 4.3.1 Vertical Profiling, second paragraph:
Was the data generated from the passive diffusion bag effort used to help
determine where to set the intake for the low flow sampling effort in the
appropriate monitoring wells for the December 2009 groundwater sampling
effort?
Response 6. The data generated was not used to adjust the sampling intervals
during the December 2009 sampling event. Previous sampling events used
the center of the well screen as the reference point for setting the pump intake.
To maintain the consistency with the historic groundwater data a similar
pump intake depth was used. The vertical profiling confirmed the proper
placement of the extraction well pumps is near the bottom of the screened
interval, and the intake for the extraction wells was unchanged.
Comment 7. Page 4-1 I, Section 4.3.3 Shallow Bedrock,flrstfiill paragraph:
How do the concentrations of chemicals detected in EX-08 flt into this
discussion since EX-08 is near EX-07?
Response 7. The concentrations observed at EX-08 are more consistent with
the wells EX-05 and EX-09 than EX-07 and EX-I 0. EX-08 is located to the
south of EX-07, near the center of the reforested portion of the Trench Area,
while EX-07 is located on the northernmost edge of the Trench Area. The
fracture trace analyses completed in 2002 (included in Appendix J of the 2009
SMR) suggests a southwestern groundwater flow direction towards EX-09.
The groundwater flow appears to be radial from EX-08 based on the
potentiometric surface of the shallow bedrock with a slightly steeper gradient
to the southwest toward the Unnamed Tributary along the flow path from EX-
08 to EX-09, as supported by the dissolved groundwater impacts.
Comment 8. Page 4-12, Section OU I Data Evaluation, first paragraph, last
sentence: This sentence states there are reducing conditions in the aquifer
downgradient of the Trench Area. Do the field parameter measurements
collected during purging efforts for the monitoring wells in this area support
this conclusion? lfso,future reports should include some text highlighting
Mr. Jon Bornholm
March 15, 2011
Page:
3/8
ARCADIS
this point. If this data does not support this claim, then the text needs to
explain this as well.
Response 8. Yes, the tield parameters support the conclusion that reducing
conditions are present downgradient of the Trench Area. Oxidation reduction
potential (ORP) measurements were negative for all wells sampled except
NS-22, indicating the presence of reducing conditions. ORP is summarized in
Tables 9 and 10 of the 2009 SMR. In future reports, this information will be
included in the main document text.
Comment 9. Page 6-4, Section 6.3. l Lagoon Area, last sentence: Typo,
"Figure 17" should read "Figure /9".
Response 9. Agreed.
Comment 10. Page 6-6, Section 6.3.1.4 Deep Bedrock.first paragraph.first
sentence: Typo, "2008" should read "2009 ".
Response I 0. Agreed.
Comment 11. Page 6-8, Section 6.3.2.2 Shallow Bedrock, second paragraph,
last sentence: Typo, the second "NS-61 "should read "NS-60 ".
Response I I. Agreed.
Comment 12. Page 8-1 Section 8. 0 Conclusions and Recommendations, first
bullet: Typo, should "OU3" read "OU2 "?
Response 12. The statement is referring to the groundwater impacts
originating from the Trench Area. It should read OU I instead ofOU3.
Comment I 3. Page 8-1 Section 8. 0 Conclusions and Recommendations, fifth
bullet: More out of curiosity, of the 1,800 trees planted, any estimate as to
how many survived?
Response 13. Based on the 2007 Status Report, it was estimated that of the
1,800 trees planted, greater than 75 percent (more than 1350 trees) of the trees
survived the first growing season. Additional survival estimates were not
included in subsequent status reports conducted in 2008 and 2009; however,
Mr. Jon Bornholm
March 15, 2011
Page:
4/8
ARCADIS
the conclusions state that the majority of species were in good to excellent
health range and no signi ti cant tree losses were observed.
Comment 14. Page 8-2 Section 8.0 Conclusions and Recommendations,first
bullet, third sentence: How long will the transducers be Jefi in place to
111easure changes in groundwater levels?
Response I 4. The transducers will remain in the wells until the capture zone
has been fully evaluated and the results demonstrate containment of the
Trench Area. The intent is to obtain data under continuous pumping
conditions for a term of three months.
Comment I 5. Page 8-2 Section 8.0 Conclusions and Recommendations, first
bullet, fifih sentence: This sentence states that additional extraction wells may
be brought online. If the decision is 111ade to bring additional extraction wells
on line, what is the estimated limeline lo complete this effort? Will the wel/(s)
be redeveloped? Will the conveyance lines need to be cleaned out? What's
the timeframe for delivery of new equipment, etc.?
Response 15. At the conclusion of the capture zone analyses (see Response 5)
recommendations will be submitted to the Agency detailing any modifications
that need to be made to the groundwater extraction system. Contingent items
have been considered and include:
• Installation of an additional extraction well between EX-05 and EX-
09. The well would be a minimum diameter of 4 inches and likely set
to intercept fractures within the shallow bedrock; therefore it would be
constructed as a single-cased well without a surface casing. A top-
mounted piston pump and a groundwater conveyance line would be
installed to transfer extracted groundwater to one of the existing tanks
at EX-05 or EX-09. The estimated time frame to bring a new
extraction well online would be eight to ten weeks.
• Consideration has been given to bringing EX-08 back online. Initially,
the well would be evaluated to determine well yield. This evaluation
would include redevelopment hydraulic testing. If the well yield is
sufficient (greater than 2 GPM) then additional work would be
required to incorporate this well in to the current system. These
activities would include:
Mr. Jon Bornholm
March 15, 2011
Page:
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ARCADIS
o Cleaning the section of the groundwater conveyance lines from
EX-08 to the main conveyance line;
o Installation of a new top-mounted piston pump;
o Construction of a secondary containment pad for storing the
2,500 gallon tank; and
o Installation of a 2,500 gallon tank and transfer pump.
The estimated timeline to bring EX-08 back online would be 3
months.
Comment 16. Page 8-2 Section 8.0 Conclusions and Recommendations, third
bullet: The Agenc,T is anticipating receiving some sort of a preliminary report
prior to goingfu/1 scale with the Enhanced Reductive Dechlorination Pilot
Scale Study.
Response 16. Agreed. An interim submittal will be provided to the agency
once the packer test and the gradient evaluation has been completed. A
summary of the work completed to date and the tentative schedule of the
remaining items is included below:
• December 6 to December 17, 20 I 0-Installation of pilot study wells;
• January 3 to January 7, 2011 -Packer Test at IWB-1 started. Work
was anticipated to continue the week of January 10, 2011; however,
due poor weather conditions the work was postponed.
• February 7 to February 11,201 I -Packer Test at IWB-1 resumed and
was completed. Surveying was completed at this time.
• February 24, 2011 -Analytical data from each of the shallower packer
test zones was received. Analytical data from the deeper zones is still
pending.
• The packer test data will be evaluated and recommendations will be
made regarding bedrock well screen placement. This interim
submittal is anticipated to be submitted in March 2011.
• Once the Agency has reviewed the submittal, the bedrock well screens
will be installed and the baseline sampling will be completed.
Comment 17. Tahle 2: What will he done with P-01 since the borehole has
collapsed?
Response 17. This well will be abandoned in accordance with the NC DENR
well regulations. Prior to abandoning the well an attempt will be made to
clear the obstruction from the well using a steel weight suspended from a
Mr. Jon Bornholm
March 15, 2011
Page:
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ARCADIS
wire-line. If the obstruction can be cleared, the well will be grouted from the
base of the borehole to ground surface. In the event the obstruction cannot he
dislodged and tremie pipe cannot be lowered to the base of the well, the
borehole will be reamed using air rotary drilling and then properly abandoned.
AkzoNobel does not intend on installing a replacement well at this location.
Comment 18. Table 2: 1 could no/ locate P-03 on Figure 2.
Response 18. P-03 is located along the western edge of property near Grants
Creek. The extents of the figures included in the report do not include this
portion of the property. The attached figure includes well P-03.
Comment 19. Figure IO -Conceptual Groundwater Flow in the Piedmont:
How does this conceptualization explain the occurrence at NS-31?
Response 19. The LeGrand model for conceptual groundwater flow in the
Piedmont (Figure I 0) was included to introduce the regional hydrogcology of
the Piedmont and illustrate the relationship between the saprolite and bedrock
units and groundwater flow direction from the recharge to discharge areas.
This model was assumed to be true based on the fact that several bedrock
wells were artesian at the time the 2009 SMR was prepared. The recent
information obtained from the new well cluster confirms an upward hydraulic
gradient from the deep bedrock (NS-31) to the shallow bedrock (NS-31 B) to
the saprolitc (NS-31 A) exists as the model predicts. Under natural (i.e., non-
pumping) conditions Figure IO docs not explain the occurrence of site related
COCs; however, the conceptual relationship of the fractures near the
discharge boundary docs explain how site COCs could pass beneath the
discharge boundary under pumping conditions.
The occurrence of the contaminants in NS-31 was further discussed in Section
4.4 (Page 4-13, second paragraph). During operation of the plume periphery
extraction system (EX-01 to EX-04) the natural hydraulics along the
discharge boundary were modified. The influence of the groundwater
extraction at EX-01 was observed at NS-31 when the extraction well was
taken offline in January 2000. The documentation of this influence was
discussed in the fracture trace analyses included as Appendix J. The location
ofNS-31, which is to the southwest of the Unnamed Tributary, suggests that,
under natural conditions, the well should not be part of the flow system where
the groundwater impacts are occurring; however, the orientation of the
Mr. Jon Bornholm
March 15, 2011
Page:
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ARCADIS
fractures (Appendix J) and the area of influence of EX-0 I promoted the
migration of dissolved contaminant beneath the Unnamed Tributary. As the
system has returned to natural conditions, the groundwater present in the deep
fractures beneath NS-31 is relatively immobile due to natural gradients
promoting northeastern flow back toward the Unnamed Tributary. The
critical point of Figure 10 is that the stream is a discharge boundary for both
sides of the creek, and that groundwater from NS-31 will also discharge to the
creek in a similar manner as NS-29.
Comment 20. Figure 17: Pros/cons of pairing a shallow bedrock monitoring
well with monitoring well NS-58?
Response 20. Based on the lateral extent of the dissolved groundwater
constituents illustrated on Figure 17, the area around NS-58 has been
identified as a potential location for additional monitoring in the shallow
bedrock unit. A contingent cost to install a shallow bedrock well in the
vicinity ofNS-58 has been included in the budget established for 2011.
Should you have any further comments regarding this project, please contact
me at 864.987.3906 or 864.982.9890.
Sincerely,
ARCADIS U.S., Inc.
~~
Elizabeth Rhine
Project Manager
Attachment:
1 -Revised Air Sparge Well Construction Diagrams
2 -Site Map Including P-03
Copies:
Angela Dahl, AkzoNobel
David Mattison, NCDENR
Jerry McMurray, AkzoNobel
Debra Rubenstein, AkzoNobel
Mr. Jon Bornholm
March 15, 2011
Page:
8/8
6#.?.l ARCADIS
Well Construction Log
(Unconsolidated)
-1 -
--
. 1 I ~ fi ~ I I
I! T!
II I
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1t I " lir " 1,
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LAND SURF ACE
8 inch diameter
drilled hole
Well casing,
2 inch diameter,
4'0 PVC Sch.
□Backfill
{R]Grout Port
21.0 ft'
Bentonite
23.0 ft"
24.8 ft"
Well Screen.
2
304$$
QGravel Pack
[gjsand Pack
land Type 1
Oslurry
~pellets
inch diameter
10 slot
#1 Filter
0Formation C ollapse
29.8 ft"
30.0 tt·
Measuring Point is
Top of Well Casing
Unless Otherwise Noted
• Depth Below Land Surface
Project National Starch Well AS-1 ----------
5 a Ii s bury Town/City
County
Permit No.
Rowan State NC --------------
Land-Surface Elevation and Datum:
______________ feet D Surveyed
0 Estimated
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
7/912009
Hollow Stem Auger
AE Drilling
None
Development Technique{s) and Oate(s)
Fluid loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water feet below M.P. ------
Pumping Depth to Water _______ feet below M.P
Pumping Duration hours
Yield gpm Date
Specific Capacity gpm/ft
Wen Purpose Air Sparge
Remarks
Prepared by James E. Cooper
~ARCADIS
Well Construction Log
(Unconsolidated)
-1 -
--
I ~ w ~ ,.,
' ~;
~ d ~ II I I 'I
i1 i II ~ f-lj I[
il ii
u I I
fl
II
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l 11
~:~1ill
-ft
LAND SURFACE
8 inch diameter
drilled hole
Well casing,
2
Sch.4
inch diameter,
0 PVC
Osackfill
(R]Grout Port! and Type 1
20.5 ft"
Bentonite
22.9 ft"
24.8 ft"
Well Screen.
2
304 ss
0Gravel Pack
~Sand Pack
□Formation C
29.8 ft•
30.0 ft"
Dsluny
~pellets
inch diameter .
.. ~slot
#1 Filter
ollapse
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project National Starch Well AS-2 ----------
Salisbury Town/City
County Rowan State NC --------------
Permit No
land-Surface Elevation and Datum:
______________ feet D Surveyed
0 Estimated
Installation Date{s)
Drilling Method
Drilling Contractor
Drilling Fluid
7/9/2009
Hollow Stem Auger
AE Drilling
None
Development Technique{s) and Date(s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water feet below M.P. ------
Pumping Depth to Water _______ feet below M.P.
Pumping Duration ______ hours
Yield _____ gpm
Specific Capacity _____ gpmlft
Air Sparge Well Purpose
Remarks
Prepared by James E. Cooper
Date ____ _
~ARCADIS
Well Construction Log
(Unconsolidated)
---
ij ;
(ji! I I ~ m t l 't
,,!
I I
Ir
11
11
ii
II II I II I II
Ir I
I I I 11
!l·w·J1
·11 Hi i Ill 11!: IU
-tt
LANO SURFACE
8 inch diameter
drilled hole
Well casing,
2
Sch.4
inch diameter,
0 PVC
□Backfill
IB)Grout Portl and Type 1
7.8 ft"
Bentonite
9.8 ft'
11.8 tt·
Well Screen.
2
304 ss
Dslurry
~pellets
inch diameter
10 slot
Wiro Wrappod
QGravet Pack
IB)sand Pack #1 Filter
0 Formation C ollapse
16.8 ••
17.0 fl"
Measuring Point is
Top of Well Casing
Unless Otherwise Noted
• Depth Below Land Surface
Project National Starch Wei! AS-3 --------------
Salisbury Town/City
County
Permit No.
Rowan Stale NC --------------
Land-Surface Elevation and Datum:
______________ feet O Surveyed
D Estimated
lnstal!ation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
2/25/2009
Hollow Stem Auger
AE Drilling
Nono
Development Technique{s) and Date(s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water feet below M.P. ------
Pumping Depth to Water _______ feet below M.P.
Pumping Duration hours
Yield gpm Date
Specific Capacity gpm/lt
Well Purpose Air Spargo
Remarks
Prepared by James E. Cooper
~ARCADIS
Well Construction Log
(Unconsolidated)
~ '
!ii ~ t t ~ ;
i 1
II 1! ~ I!
I ~ I I
1: Ii
II ti
Ill II !I
II !I ll I II I I I II
11111111111
ft
LAND SURFAC~
---~•_inch diameter
drilled hole
Well casing,
----'~inch diameter,
Sch. 40 PVC
□Backfill
~Grout Portland Type 1
6.2 ft'
Bentonite
8.2 ft"
10.2 ft•
Well Screen.
Oslurry
~pellets
2 inch diameter
-~,~,~.~s~s,--1 o slot
Wire Wrapped
0Gravel Pack
~Sand Pack #1 Filter
0Formation Collapse
15.2 ft'
15.4 ft*
Measuring Point is
Top of Well Casing
Unless Otherwise Noted
• Depth Below Land Surface
Project ___ N_a_1;_o_n_a_l s_ta_,_,_h __ Wei!
Salisbury
AS-4
Town/City
County Rowan State NC --------------
Permit No.
Land-Surface Elevation and Datum
______________ feet D Surveyed
D Estimated
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
2/25/2009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date(s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water
Pumping Depth to Water
_______ feet below M.P.
feet below M.P. ------
Pumping Duration ______ hours
Yield _____ gpm
Specific Capacity _____ gpm/ft
Air Sparge Well Purpose
Remarks
Prepared by James E. Cooper
Date ----
~ARCADIS
Well Construction Log
(Unconsolidated)
-
ii I
ft
LANO SURFACE
---~•_inch diameter
drilled hole
Wei! casing,
----~2.inch diameter,
___ cs~'~"~-40 PVC
□Backfill
IB)Grout Portland Type 1
4.8 ft"
I Bentonile
I
Oslurry
~pellets
j
'
II :1
11
j
'I ~ II
1.1-i I II II !I
!! ~
I·! I,
11 II I Ii
I II
I »
11 " ·1 11 I " ti~ II
lllllllii 1
~
6.8 ft"
8,8 ft"
Well Screen.
2 inch diameter
---,,=D4~S~S~-10 slot
Wire Wrapped
0Gravel Pack
~Sand Pack #1 Filler
0Formation Collapse
13.8 ft*
14.0 ft*
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project --~N0,0H0o_n_,_I 0S01,0,0,_h ___ Well AS-5
Salisbury Town/City
County
Permit No.
Rowan State NC --------------
land-Surface Elevation and Datum:
______________ feet 0 Surveyed
D Estimated
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
2/25/2009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date(s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water
Pumping Depth lo Water
_______ feel below M.P
feet below M.P. ------
Pumping Duration ______ hours
_____ gpm
Specific Capacity _____ gpmlft
Air Sparge Well Purpose
Remarks
Prepared by James E. Cooper
Date ----
6:.?.l ARCADIS
Well Construction Log
{Unconsolidated)
-
--
I I ')!
I " " j\: ~
iii ~
II II
I! II i I '
II
!I
II r11 I i ii
1 ll
11
II 1, II :, I
I II
II " ii
I II II._ II
11111111 llllllllllll
-ft
LANO SURFACE
6 inch diameter
drilled hole
Well casing,
2 _inch diameter,
40 PVC Sch.
□Backfill
(8]Grout Portl and Type 1
18.5 fl*
Bentonite
22.0 fl"
24.2 ft*
Well Screen.
2
304S5
0Gravel Pack
~Sand Pack
Dslurry
~pellets
_inch diameter
_ . ....!E_ slot
#1 Filler
0Formation C ollapse
29.2 ft"
29.4 ft"
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project National Starch Well AS-6 ----------
Town/City Sa Ii s bury
County Rowan State NC --------------
Permit No
Land-Surface Elevation and Datum:
----------feet O Surveyed
□ Estimated
Installation Date(s)
Drilhng Method
Drilling Contractor
Drilling Fluid
1/16/2009
Hollow Stem Auger
AE Drilling
None
Development Technique{s) and Date(s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water feet below M.P ------
Pumping Depth to Water _______ feet below M.P.
Pumping Duration hours ------
Yield _____ gpm
Specific Capacity
Well Purpose
_____ gpm/ft
Air Sparge
Date ____ _
Remarks Approximately 22.2 ft. BGS is saturated
possibly top of water table
Prepared by James E. Cooper
~ARCADIS
Well Construction Log
(Unconsolidated)
-
- -
t [
tt
LAND SURFACE
o,"il"led"""h"o"l_e08_ inch diameter
Well casing,
-----,~c-'-2,inch diameter,
--~S~c~h~-40 PVC
□Backfill
0Grout Portland Type 1
20.0 tr
I Bentonite Oslurry
~pellets 22.2 ft'
24.3 ft'
Well Screen.
2 inch diameter -""',"o"•"s"sc--1 o slot
0 Gravel Pack
~Sand Pack #1 Filter
OFormation Collapse
29.3 ft'
29.5 ft'
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project AS-7
Salisbury Town/City
County _R_o_w_,_n ________ state _N_c ___ _
Permit No.
Land-Surface Elevation and Datum:
______________ feet
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
1/1412009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date(s)
0 Surveyed
0 Estimated
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water
Pumping Depth to Water
_______ feet below M.P.
feet below M.P. ------
Pumping Duration ______ hours
Yield _____ gpm Date ___ _
Specific Capacity ______ gpm/fl
Well Purpose Air Sparge
Remarks
Prepared by James E. Cooper
~ARCADIS
Well Construction Log
(Unconsolidated)
-
ft
LAND SURFACE
dc"il"le-d"h-o"le~'-inch diameter
Well casing,
-----,,--,-2",inch diameter,
--~•~c~h~. 40 PVC
□Backfill
IB)Grout Portland Type 1
19.5 ft"
ii ~ I Bentonite
I~,
Oslurry
~pellets
ll ,,
!I
II II l ~11
!
I II Ii
I II li
II II II
I _Ii
!!!~!II -
21.9 ft"
24.3 ft"
Well Screen.
2 inch diameter ---=,~047"s~s-· 1 o slot
0Gravel Pack
~Sand Pack #1 Filter
0 Formation Collapse
29.3 ft'
29.5 ft"
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project --~"c•ctlcocncacl cSct•c'ccch ___ Well AS-8
Salisbury Town/City
County
Permit No
0R000wccacn ________ State 0N_C~---
land-Surface Elevation and Datum:
feet -------------
1/1312009 Installation Date(s)
Drilling Method Hollow Stem Auger
Drilling Contractor
Drilling Fluid
AE Drilling
None
Development Technique(s) and Dale(s)
D Surveyed
0 Estimated
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water
Pumping Depth to Water
_______ feet below M.P.
feet below M.P. ------
Pumping Duration ______ hours
Yield _____ gpm Date ----
Specific Capacity _____ gpmlft
Well Purpose Air Sparge
Remark.s
Prepared by James E. Cooper
~ARCADIS
Well Construction Log
(Unconsolidated)
-
--
-l~ ~
1
'''\ I ¾
II i ii ij
Ii
I'
' Ii I
II
l II
I 11 •I
11
II
II ~ II
II
jl 11
I I
j1. I •
-ft
LAND SURFACE
8 _inch diameter
drilled hole
Well casing,
2 _inch diameter,
40 PVC Sch.
□Backfill
~Grout Port
1.5 ft"
Bentonite
2.5 tr
3.6 ft'
Well Screen.
land Type 1
Oslurry
0pellets
2
304 ss
_inch diameter
10 slot
OGravel Pack
~Sand Pack #1 Filter
0Formation C ollapse
8.6 ft'
8.8 ft'
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project
Town/City
__ cNe•o•e;oee"'o'cse•e•e'o'eh __ we11
Salisbury
AS-9
County cReo:.:w:.:•e":_ _______ State cN:.:C:_ __
Permit No.
Land-Surface Elevation and Datum:
______________ feet D Surveyed
D Estimated
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
1/13/2009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date(s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water
Pumping Depth to Water
______ feet below M.P.
______ feet below M.P.
Pumping Duration ______ hours
Yield _____ gpm
Specific Capacity ______ gpm/ft
Air Sparge Well Purpose
Remarks
Prepared by James E. Cooper
Date ____ _
~ARCADIS
Well Construction Log
(Unconsolidated)
-r
It
LAND SURFACE
8 inch diameter
dc"i11"e"d"h-0"1e--
Well casing,
2 inch diameter,
---S-oh".-40 PVC
□Backfill
~Grout Portland Type 1
20.0 tt·
23.0 ft'
25.0 ft"
Well Screen.
Oslurry
~pellets
__
3
"
0
_
4
2"s"s--inch diameter
10 slot
0Gravel Pack
e)sand Pack #1 Filler
0Formation Collapse
30.0 ft'
31.0 ft'
Measuring Point is
Top of Well Casing
Unless Otherwise Noted
• Depth Below Land Surface
Project National Starch Well AS-10 ----------
Town/City
County
Sa Ii s bury
Rowan State NC --------------
Permit No.
Land-Surface Elevation and Datum:
______________ feet
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
3/23/2009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date(s)
0 Surveyed
0 Estimated
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water
Pumping Depth lo Water
_______ feet below M.P.
feet below M.P. ------
Pumping Duration ______ hours
Yield _____ gpm Date ____ _
Specific Capacity _____ gpm/lt
Well Purpose Air Sparge
Remarks
Prepared by Thomas Darby II P.G.
~ARCADIS
Well Construction Log
(Unconsolidated)
1.5
-
-
I I
11 .:
I II
I; II
I II I II 1-11
1
11.
II
I! I
I I
i1
1
II ~ II
rll JI
tt
LAND SURFACE
,,";t"le-d"h"o"l_e_a_.inch diameter
Well casing,
--~772=,inch diameter,
Sch. 40 PVC -----
0Backfil1
~Grout Portland Type 1
20.5 ft"
Bentonite
22.8 ft•
24.1 ft'
Well Screen.
Dslurry
~pellets
-~,,-'2'=,~-inch diameter
304 SS 10 slot
0Gravel Pack
IB]sand Pack #1 Filter
0Formahon Collapse
29.1 ft"
29.3 tt·
Measuring Point is
Top of Well Casing
Unless Otherwise Noted
• Depth Below land Surface
Project
Town/City
---""c'c1;c0c"c'c1 c5c1'c'c'chc_ __ Well
Salisbury
AS-11
County 0Rcocwc•cnc_ _______ State 0N~Cc_ __
Permit No
Land-Surface Elevation and Datum:
feet -------------
4/29/2009 Installation Date(s)
Drilling Method Hollow Stem Auger
Drilling Contractor AE Drilling
Drilling Fluid None
Development Technique(s) and Date(s)
D Surveyed
D Estimated
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth lo Water
Pumping Depth to Water
______ feel below M.P.
_______ feet below M.P.
Pumping Duration hours -----
Yield _____ gpm Date ----
Specific Capacity ______ gpm/ft
Well Purpose Air Sparge
Remarks
Prepared by Brian Lovgren
~ARCADIS
Well Construction Log
(Unconsolidated)
-1
ft
LANO SURFACE
____ a_ inch diameter
drilled hole
Well casing,
_____ 2_inch diameter,
---~S~c~h~-40 PVC
Oaackfil!
(R}Grout Portland Type 1
21.1 ft"
Bentonite
23.0 ft"
24.8 ft"
Well Screen.
Oslurry
~pellets
_ _,300,,
4
2cs•s~-inch
1
d
0
iam
1
e
1
te,
-~~=-•_so
0Gravel Pack
~Sand Pack #1 Filter
QFormation Collapse
29.8 ft"
30.0 ft"
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project National Starch Well AS-12 ----------
$ a Ii s bury Town/City
County Rowan Slate NC --------------
Permit No
Land-Surface Elevation and Datum
______________ feet D Surveyed
D Estimated
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
7/812009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date(s)
Fluid Loss During Drilling ________ gallons
Waler Removed During Development gallons
Static Depth to Water
Pumping Depth to Water
______ feet below M.P.
feet below M.P. ------
Pumping Duration ______ hours
Yield _____ gpm
Specific Capacity _____ gpm/ft
Air Spargc Well Purpose
Remarks
Prepared by James E. Cooper
Date ----
6:.?,l ARCADIS
Well Construction Log
(Unconsolidated) _, -
--
I i ~ • . \\: fi
II
I! I
II f-II
i II
I 11 I 11
I Ii
I I!
I II ~ II i
II
II ij
I II
II 1-11
l!!l~!!!
-ft
u\NO SURF/ICE
8 inch diameter
drilled hole
Well casing,
2
Sch.4
inch diameter,
0 PVC
□Backfill
IR]Grout Portl and Type 1
13.0 tt·
Bentonite
15.0 tr
17.1 ft'
Well Screen.
2
304 ss
0 Gravel Pack
~Sand Pack
D Formation C
22.1 ,.
22.3 tt"
Dslurry
[glpellets
inch diameter
· 10 slot
#1 Filter
ollapse
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project National Starch Well AS-13 ----------
Salisbury Town/City
County 0R0o0w0a0nc_ _______ State 0N0Cc_ __ _
Permit No.
Land-Surface Elevation and Datum:
______________ feet D Surveyed
D Estimated
Installation Date(s)
Dri!lmg Method
Drilling Contractor
Drilling Fluid
4/2912009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date(s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water feet below M.P. ------
Pumping Depth to Water _______ feet below M.P.
Pumping Duration hours -----
Yield _____ gpm
Specific Capacity _____ gpmlft
Air Sparge Well Purpose
Remarks
Prepared by Brian Lovgren
Date ____ _
6:.?.l ARCADIS
Well Construction Log
(Unconsolidated)
-1
l ;
ij ~-"" ;!!;I ~ i lo II 4
1
II ~ !I
!l-11
11 I I! II II 'I ,, !
II I
1_1 11 !, ! I! !I ~ Ii
I I I, 11 Ii II ,~ ii
ffl!illl! -
It
LANO SURFACE
____ B_inch diameter
drilled hole
Well casing,
_____ ,_ inch diameter,
____ Scechc._40 PVC
□Backfill
[g)Grout Portland Type 1
9.7 ft'
Bentonite
11.7 ft"
14.3 ft"
Well Screen.
Oslurry
~pellets
__
3
_
0
c
4
205_
5
__ inch diameter
10 slot
0Gravel Pack
~ Sand Pack #1 Filter
0Formation Collapse
19.3 tr
19.5 tt·
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project National Starch Well AS-14 ----------
Town/City Sa 1 is bury
County Rowan State NC --------------
Permit No.
Land-Surface Elevation and Datum:
______________ feet
Installation Date(s) 717/2009
Drilling Method Hollow Stem Auger
Drilling Contractor AE Drilling
Drilling Fluid None
Development Technique(s) and Date(s)
0 Surveyed
0 Estimated
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water
Pumping Depth to Water
_______ feet below M.P
feet below M.P. ------
Pumping Duration ______ hours
Yield _____ gpm Date ____ _
Specific Capacity ______ gpmlft
Well Purpose Air Sparge
Remarks
Prepared by James E. Cooper
~ARCADIS
Well Construction Log
(Unconsolidated)
-1
tt
-LAND SURF A.CE
---~•-inch diameter
drilled hole
Well casing,
----~2.inch diameter,
--~S~c~h~. 40 PVC
Osackfill
[E}Grout Portland Type 1
21.0 ft"
Bentonite
23.0 ft"
24.8 ft"
Well Screen.
Qslurry
~pellets
__
3
_
040
2
05
_
5
__ inch diameter
-~~~~-, ~ slot
0Grave1 Pack
~Sand Pack #1 Filter
0Formation Collapse
29.8 ft"
30.0 It*
Measuring Point is
Top of Well Casing
Unless Otherwise Noted.
• Depth Below Land Surface
Project --~Nc•clicococacl cSctac•ccch~ __ Well
Salisbury
AS-15
Town/City
County
Permit No.
Rowan State NC --------------
Land-Surface Elevation and Datum:
______________ feet 0 Surveyed
D Estimated
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
7/712009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date{s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Static Depth to Water
Pumping Depth to Water
_______ feet below M.P.
feel below M.P. ------
Pumping Duration ______ hours
Yield _____ gpm Date ____ _
Specific Capacity ______ gpm/ft
We\! Purpose Air Sparge
Remarks
Prepared by James E. Cooper
~ARCADIS
Well Construction Log
{Unconsolidated)
-1
h
--LAND SURFACE
---~•_inch diameter
drilled hole
Well casing,
_____ 2.inch diameter,
---~Scoch~. 40 PVC
□Backfill
e)Grout Portland Type 1
17.6 ft"
Bentonite
19.6 ft"
21.8 ft"
Well Screen.
Oslurry
~pellets
__
3
_
04
_2c
5
_
5
__ inch diameter
10 slot
0Gravel Pack
~Sand Pack #1 Filler
D Formation Collapse
26.8 ft"
27.0 ft'
Measuring Point is
Top of Well Casing
Unless Otherwise Noted
• Depth Below Land Surface
Project National Starch Well AS-16 ----------
Sat is bury Town/City
County
Permit No.
Rowan State NC --------------
Land-Surface Elevation and Datum:
______________ feet D Surveyed
D Estimated
Installation Date(s)
Drilling Method
Drilling Contractor
Drilling Fluid
7/9/2009
Hollow Stem Auger
AE Drilling
None
Development Technique(s) and Date{s)
Fluid Loss During Drilling _________ gallons
Water Removed During Development gallons
Statlc Depth to Water
Pumping Depth to Water
_______ feet below M.P.
_______ feet below M.P.
Pumping Duration ______ hours
Yield _____ gpm
Specific Capacity _____ gpmfft
Alr Sparge wen Purpose
Remarks
Prepared by James E. Cooper
Date ____ _
' ' 1
g
' i
' u
MW Saprol,te
• MW Shallow Bedrock
V MW Deep Bedrock
c:Jou2
LJoU4 D s,teBoundary
Cl Se<!,ment Sample Location --Henl<.el Boundary
0 Stream Gauge Location --Railroads
.a. Surface Water Loca\1011 --Streams
X Abandoned Wells 1-i Parcels
0 500
GRAPHIC SCALE
1,000
Feet
NATIONAL STARCH CHEMICAL COMPANY
CEDAR SPRINGS ROAD PLANT
SALISBURY, NORTH CAROLINA
SITE MAP
(Including Location of P-03)
@I ARCADIS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
4SF-SRSEB
Ms. Angela J. Doh!
Consulting Engineer
AkzoNobel Corporate Legacies
IO Finderne A venue
Bridgewater, NJ 08807
Ms. Elizabeth Rhine
Project Manager
ARCADIS U.S., Inc.
SAM NUNN ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
February 11, 2010
30 Patewood Drive, Suite I 55
Greenville, South Carolina 29615
SUBJ: Additional Comments on 2008 Site Monitoring Report and Comments on Response to
Comments on the 2008 Site Monitoring Report for the National Starch & Chemical
Company Superfund Site in Salisbury, Rowan County, North Carolina
Dear Ms. Doh! & Ms. Rhine:
The Agency and North. Carolina Department of Environment & Natural Resources
(NCDENR) received a copy of the 2008 Site Monitoring Report (May 2009) on June I, 2009.
This report was prepared on behalf of Akzo Nobel Corporate Legacies (AkzoNobel) by
ARCADIS. The Agency prepared initial comments on the above referenced document and
shared them with you in a correspondence dated June 24, 2009. ARCADIS prepared responses
to the Agency's comments in a correspondence dated September 30, 2009. I requested Dave
Jenkins, Environmental Scientist with the Technical Support Section, to review this response.
The following comments were prepared as a result of the Agency's review of the September
2009 response to comments and David Jenkins review of the 2008 Site Monitoring Report. The
Agency is not requesting AkzoNobel to revise the 2008 Site Monitoring Report based on the
following comments, but the suggestions/recommendations presented in these comments as well
as the identified shortcomings/concerns must be incorporated/addressed/considered in future
documents.
If ARCADJS/AkzoNobel would like to convene a meeting or conference call to review
these comments/recommendations/suggestions, please provide a minimum three day notice so
that both EPA and NCDENR can participate in the meeting/call.
I. The report does not show the boundaries of groundwater plumes or define the extent of
groundwater contamination. TI1e report does not show that groundwater contamination is
under control. The report docs not show whether the plumes are stable, spreading, or
shrinking. The report does not provide maps or graphs which can be used to demonstrate
2
Additional Comment<; on 2008 Site Monitoring Rt.-port
February 2010
that progress toward clean-up is being made or that human health and the environment arc
being protected.
2. Figures 12-14 simply report the latest sample results without any interpretation. Figure 14
shows two of the most down gradient monitoring wells at the Site (NS-29 and NS-31). The
groundwater samples collected from these wells contain numerous contaminants that exceed
their OU 1 cleanup standard. Groundwater near these wells is not captured by any pumping
system or treated by any remedial measure. There is no evidence in this report that
groundwater contamination is under control or that human health and the environment are
being protected. The extent of contamination in the deep bedrock aquifer to the west is
undefined. This is obscured in the report because plume boundaries are not shown on the
maps. The report makes no attempt to compare the distribution of contamination with
groundwater flow directions. Consequently, gaps in the monitoring well network arc
obscured.
3. Maps showing groundwater plumes, based on interpretations of water sample results and
groundwater flow directions, are typically found in annuai site monitoring reports. Maps
showing contoured contaminant concentrations superimposed on groundwater elevation
contours should be included in all future annual reports as well as Five-Year Review Reports
so that the extent of contamination is clear, and progress toward Site clean-up can be gauged
by comparing the extent of contaminant dispersion and concentration over time.
4. The quality of the underlying groundwater has been adversely impacted by many different
contaminants (Figures 12-14) and three different aquifer zones are contaminated. The
geology of the Site and contaminant migration pathways are complex and the Site has been
investigated for decades. The extent of contamination in the groundwater must be shown in
a manner which will assure EPA and the public that the extent of contamination has been
defined, that the plumes are not expanding and that human health and the environment are
being protected. TI1is was not accomplished by the figures in this report.
5. The maps and cross-sections in the report do not show the extent of contamination. The
cross-sections do not show groundwater flow directions. Water level elevations should be
shown for monitoring wells in each cross-section. Equipotential lines should be drawn on
each cross-section to demonstrate vertical groundwater flow directions in each geologic unit
as the groundwater flow from recharge area to discharge area. Contoured contaminant
concentrations should be superimposed on groundwater equipotential lines in future cross-
sections.
6. Regarding the Extent of Contamination Around Well EX-OS: Fib'llre 6 provides a good
example why the map and cross-sections presented in this report fail to characterize the
extent of contamination at the Site. The contaminant concentration history for 1,2-
dichloroethane (DCA) in well EX-05 is graphed in Appendix F. The maximum contaminant
level (MCL) for DCA is 5 micrograms/liter (µg/L). This graph from Appendix F and the
cross-section illustrated in Figure 6 show the most recent DCA concentration to be 200,000
µg/L. Figure 6 also shows that none of the other wells around EX-05 show contamination
concentrations comparable to EX-05. So where is the plume? What is the extent of
contamination? How much contaminated water needs to be remediated? ls the
3
Additional Comments on 2008 Site Monitoring Rl.!'port
February 2010
contaminated water being captured or contained? Are the existing monitoring wells
adequate or are more wells needed? None of these questions are answered in this report nor
is there sufficient information presented in this report to answer these questions.
EX-05
600000 :::; -,., 500000 ~ .,
400000 C .. ~ ;; 300000 0 0 200000 ~
0 100000 rt " 0 .., ~ "' ~ .,
"' "' 0, 0, "' u u u u u "' 0 -N m ..,
~ 9 0 0 0 0
V V u u u u ., 2( ., ~ .,
0 0 0 ~ 2( ~ ~ ., .,
0 0
-+-EX-OS
According to Figure 10, the only Shallow Bedrock well down gradient from EX-05 is well
NS-25, but there is no trend graph for NS-25 in Appendix F and no analytical results for NS-
25 on Figure 13. However, the cross-sections in the report provide no indication whether the
plume would still be in the Shallow Bedrock by the time it got to NS-25 or whether the
plume was migrating into the Deep Bedrock. Clearly groundwater in well EX-05 is highly
contaminated, but no figure in this report shows this plume or how this plume is migrating.
No figure in this report shows where other plumes are, where they are going, whether the
plumes are expanding or contracting. Without plumes drawn on water level elevation
contour maps, there is no way to demonstrate whether the monitoring well network is
adequate to insure that human health and the environment are protected.
7. Regarding Data Interpretation Using Indicator Parameters: Secondary enrichment of
manganese is apparent in all three aquifer units in the northern and western portions of the
Site, but not toward the south or east of the stream which flows north from the Site on the
eastern side of the property. The distribution of manganese indicates this contamination is
Site related. Elevated levels of iron, manganese and sometimes arsenic can be indicators of a
history of organic contamination in the flow paths up gradient from a monitoring point even
if the monitoring point itself is otherwise uncontaminated. The distribution of manganese in
groundwater was not mapped in this report. Manganese trends versus time are shown in
Appendix F, but these do not appear to have been utilized to define the extent of
contamination anywhere in the report. Iron isn't reported on Figures 12 -14. Arsenic is
reported only on Figure 14 and only for the western portion of the deep aquifer, where an
exceedance for arsenic was reported at the down gradient well NS-29. The distribution of
other factors which may indicate the distribution contamination or limits to remediation
processes, such as dissolved oxygen and oxidation-reduction potential (ORP), are not
mapped or utilized in this report to interpret the distribution of contamination. Data are
reported, but almost nothing is interpreted in this report to show the extent of contamination
or demonstrate that the plume is under control.
4
Additional Comments on 2008 Sitt: Monitoring Report
Fehruary 2010
8. Regarding Manganese and DCA in Well NS-57: An examination of manganese data
described in the previous comment lead to well NS-57. This is a down gradient Shallow
Bedrock well with a manganese concentration of91,700 µg/L plus large exceedances for
acetone, DCA, dichloropropane, methylene chloride, toluene and bis(2-chloroethyl)ether
(Figure 13). Figure IO shows there are no monitoring wells downgradient from NS-57. The
DCA concentration in December 2008 was reported to be 650J µg/L. Oddly, the graph in
Appendix F shows that the DCA concentration in this well was nearly 50,000 µ/Lin 2007.
It is unlikely that natural attenuation reduced the DCA concentration by a factor of 80 in one
year. No explanation for the trend in DCA concentrations at NS-57 is offered in the report.
The extent of contamination in this area has not been defined and the transport and fate of
contamination identified in this report is neither mapped nor interpreted.
9. Regarding Acetone in Wells NS-56, NS-57 and NS-31: No exceedances for acetone arc
reported in the Saprolite aquifer (Figure 12). There appears to be no source in the uppermost
water bearing zone anywhere on Site for the acetone in the Shallow Bedrock and Deep
Bedrock aquifers.
Exceedances for.acetone are reported in the Shallow Bedrock aquifer (Figure 13) at well EX-
05, EX! 0, NS-56 and NS-57. The largest cxceedance was reported at EX-05 and the
smallest was reported at EX-I 0. The trend graphs in Appendix F for acetone in NS-56 and
NS-57 show that acetone concentrations in the down gradient well NS-57 have increased
since 2007. The 2008 acetone concentration in NS-57 exceeds the concentration in well NS-
56 (Figure 13). NS-56 is down gradient from EX-IO (Figure I 0). NS-57 is down gradient
EX05 (Figure I 0). The water level contours on Figure IO show that an acetone plume
through wells NS-6 and NS-57 may be more than 400 feet wide and the contours do not
show that _this contamination is captured by any pumping well. There arc no monitoring
wells down gradient from NS-57.
Figure 14 shows that acetone was detected without qualification in the Deep Bedrock aquifer
in 3 wells. The highest concentration was far down gradient at NS-31. The groundwater
flow directions shown on Figures IO and 11 do not indicate a pathway connecting NS-31 to
the acetone contamination at NS-56 or NS-57. Few wells in the groundwater flow paths to
NS-31 indicated on Figures 9, IO, and 11 had detections for acetone, and none had an
exceedance for acetone. Consequently, the source of the acetone in NS-31 is unknown and
the pathway to this well is unclear. Possible explanations for apparently isolated high
concentrations of acetone in NS-31 include:
I) a release by dumping in the vicinity ofNS-31, which seems unlikely given the depth
of the well and relative inaccessibility of the location;
2) the monitoring well network up gradient from NS-31 is inadequate and a plume of
acetone approximately 1,000 feet long through the Saprolite, Upper Bedrock and
Lower Bedrock aquifers has been missed from a source on-site; and
3) a pathway exists beneath the Deep Bedrock aquifer, which seems unlikely given the
specific gravity of acetone is less than 0.8, however deep migration oflight
contaminants dissolved in a flow system with a downward gradient can occur.
5
Additional Comments on 2008 Site Monitoring Repon
February 2o"IO
Explanation 2 seems to be the least improbable of these speculations. However, the
observation of high DCA concentrations in Deep Bedrock well NS-54 (Figure 5 and see next
comment) suggests that U-shaped pathways downward beneath the ridge and upward
beneath the streams might exist. The report offers no explanation for the acetone exceedance
at NS-31. The water level contour maps show that contamination at NS-31 is not captured
by any pumping well.
10. Regarding Migration and Fate of DCA On-site: On-site, DCA contamination is present in
the Shallow Bedrock aquifer in the vicinity ofNS-36. DCA contamination also is present
on-site in the Deep Bedrock aquifer in the vicinity ofNS-54. The Response to EPA
Comments letter (September 30, 2009) raises questions about how contamination got to the
deep aquifer at NS-54. The report states the pumping test data show a hydraulic connection
between Shallow Bedrock well NS-49 and Deep Bedrock well NS-54. The report states
(Response to EPA Comments letter September 30, 2009, page 13 of 19) " ... the pump test at
NS-49 demonstrates that at least one of the OU4 extraction wells is likely pulling
contaminant mass deeper into the aquifer", but no maps or hydrogeologic cross-sections
showing plumes or capture zones are presented to support this speculation.
Cross-section Figure 5 shows NS-49 and NS-54, but the cross-section does not show water
level elevations or equipotential lines to indicate horizontal and vertical groundwatt.T flow
directions. The cross-section does not show contaminant concentration contours which
would indicate the extent of contamination. The cross-section does not show a capture zone
around the Deep Bedrock well NS-54 or any pumping wells which might capture water from
either NS-49 or NS-54.
DCA concentrations were high in well NS-54 in 1998 and have increased since then (see
graph below from Response to EPA Comments letter September 30, 2009, page 13 of 19).
But it is important to note contaminant migration to NS-54 occurred before pumping began,
consequently the DCA increase in NS-54 might have occurred even if pumping had not
occurred. The important point which is ignored in the response to EPA' s comment is that
DCA is in the deep aquifer at NS-54 despite the presence of an upward hydraulic gradient in
the area under pumping and natural conditions. The graph of DCA concentrations on page
13 of the response shows 10 years of pumping has not reduced the DCA concentrations in
NS-54. If the pumping wells caused the contamination, they are not effective in causing
remediation.
There is nothing in this report which shows the extent of contamination around Deep
Bedrock well NS-54 or shows that contamination in this well is being captured or treated by
any remedial measure.
DCA contamination from the vicinity ofNS0 36 and NS-54 may be limited to on-site areas,
but the maps so not show this. Further, supporting information from other parameters such
as manganese, dissolved oxygen, ORP, etc. which might show that the plume has attenuated
or which might help define contaminant migration were not utilized in this report.
6
Additional Comments on 2008 Site Monitoring R~rt
February 20IO
1000000 ~------------------~ -~00000 :s. -10000 a,
C
IV 1000 J:. ... a, 100 0 ..
0 10 J:.
OU3 Extraction Be ins Februa 2000
u
0 1 • "!. co en
"1 en en ' '
0 .-1 N IY1 0 0 0 0 I I I I
<I' 1/1 \0 " CX) en 0 0 0 0 0 0 ' ' ' • ' ' u u u u u u u u u u u u
(l) (l) (l) (l) (l) (l) (l) (l) (l) (l) (l) (l)
0 0 0 0 0 0 0 C) C) 0 C) C)
-.NS-49 -,a-NS-54 ...-NS-51
11. Regarding Contaminant Migration and Fate at NS-31: The Response to EPA Comments
letter dated September 30, 2009 included a trend graph for well NS-31. NS-31 is one of the
most down gradient monitoring well at this Site (Figure 11 ). Multiple MCL exceedances
occur in the well (Figure 14). The well has not shown clear and meaningful decrease in
contaminant concentrations during the last 10-20 years. Yet this report does not contain a
figure showing where the plume is or where it is going. All of the discussion around the
graph on page 6 of the response to EPA comments is a distraction from the facts that
groundwater in this well exceeds MCLs, the plume is not currently being controlled or being
remediated, and the extent of contamination is unknown.
12. Recommendation Regarding NS-31: EPA's original Comment 13 stated: " ... since the
PPES has been shut down for over nine years. It may be time to re-evaluate why we are still
seeing elevated levels of /,2-DCA in NS-31." No remedial measure for contaminated
groundwater near the western stream is in place at this time. The report does not contain a
map showing a plume of contaminated groundwater. EPA must conclude that the extent of
contamination is not defined and groundwater migration is not under control. If the Site has
7
Additional Comments on 2008 Site Monitoring Report
February 2010
not been characterized sufficiently to draw a plume of contaminated groundwater, then EPA
has no assurance that human health and the environment are protected because EPA does not
know where the plume is. This report does not contain maps and cross-sections that help
EPA understand distribution of contamination at this site.
Maps and cross-sections should be prepared which show the distribution of contamination
from the source areas to the natural discharge areas for groundwater or man-made discharge
areas at pumping wells. Water level elevation contours which clearly demonstrate horizontal
groundwater flow directions should be drawn using depth to water measurements from the
specific sample event being presented. The water level contours should be shown on the
same figure with the contaminant concentration contours so that the relationship between
groundwater flow directions and contaminant migration is clear. This presentation should
result in a map-view of the plumes which shows the distribution of contamination and the
flow-paths which the contamination follows from the source areas across all the aquifers to
the natural or man-made discharge areas.
Cross-sections should be prepared which are oriented generally along the axis of the plumes.
The tops and bottoms of the various geologic units encountered in the monitoring wells
should be shown. Well screen elevations in monitoring wells along the cross-sections should
be shown. Water level elevations calculated from depth to water measurements from the
specific sample event for the contaminant data being presented. The water level elevations
should be used to draw equipotential lines which clearly demonstrate horizontal vertical
groundwater flow directions in the cross-sections. Contaminant concentrations in the
monitoring wells should be contoured which clearly demonstrate the distribution of
contamination. These presentations should result in cross-section views of the plumes which
show the distribution of contamination and the flow-paths which the contamination follows
from the source to the natural discharge areas.
The map and cross-sections will make gaps in the monitoring well network evident.. EPA
will have a tool to evaluate the need for additional monitoring wells. EPA will have tools to
show where the plume is and/or where it is going. These recommendations describe the
most basic site characterization tools which should have been presented in this and all
previous reports. This report states the site was proposed for addition to the NPL in April,
1985. Investigation of the site commenced before that time. If the map and cross-sections
recommended in this comment can not be created quickly from the data available after the
site has been under investigation for more than 25 years, EPA should be concerned that the
site is not characterized adequately, that contaminant migration is not under control, and that
human health and the environment may not be protected because we don't know where the
plumes are.
I 3. Regarding Comment 13, the Plume Periphery Extraction System (PPES) and adverse
impacts on the groundwater in the vicinity of monitoring well NS-31: Well NS-31 is on
the opposite side of the unnamed tributary from the Site and the PPES extraction wells. The
comment concerns the observation of contamination in NS-3 I found unexpectedly on the far
side of the stream from the Site and the extraction wells. The observations and interpretation
can be summarized as follows:
8
Additional Comments on 2008 Site Monitoring Report
Fi:bruary 2010
IF groundwater flows laterally from the source areas on Site toward the unnamed
tributary,
AND IF the unnamed tributary is the natural discharge area for groundwater,
THEN it is reasonable to expect that the DCA concentrations in NS-31 should have
declined during the 9 years since the PPES was turned off
The last sentence of the first whole paragraph on page 6 ends with the statement: "Resuming
groundwater extraction in the PPES is not likely to affect groundwater concentrations at NS-
31." Response 13 which begi~s on page 5 ofl9 does noi address the real issue in this
portion of the Site. If pumping will not affect groundwater concentrations in NS-31, do
something which will! Instead, Response I 3 states " .. further characterization and/or
remediation ofVOCs in this area may be needed. ARCADIS will continue to monitor
concentrations, and evaluate this area for additional remediation ... " (page 6 of 19). There
is no need to evaluate the area for additional remediation. Contaminant concentrations in
this well have increased over the last 18 years. A proposal for the appropriate additional ·
investigation which leads to a remedial action for this portion of the plume should be
submitted to EPA as soon as possible.
The suggestion that additional characterization is needed because PPSE pumping is not
likely to affect NS-31 is hard to accept. The graph (page 6 of! 9) of DCA concentrations in
NA-31 during pumping is very different from the concentrations when the pumps were off.
The contaminant concentration trends are erratic and are not easily explained when the
pumps are on. Data from early in the pumping period suggest that cleaner water was drawn
to the well in 1993-94, but subsequently water with higher contaminant concentrations was
captured by the well. But clearly, pumping effected DCA concentrations in NS-31. Even
worse, the contaminant concentration trends do not show a meaningful decrease in
concentration during the 9 years since the wells were turned off. In fact, the most recent
concentration in 2009 is higher than the concentration in 1992, so contamination at this well
has gotten worse during the last 18 years. The pumps were off for the last half of this period.
Contamination is migrating into the area and discharging somewhere, but 25 years after the
site was recomm~'llded for the NPL the extent of contamination has not been defined. The
plume has crossed the unnamed tributary. The plume does not appear to be contained and
does not appear to be under control.
The water level contour interpretation on Figure 9, showing that the creek is the discharge
area for the saprolite aquifer is reas'onable. But Figure 4 shows that the top of the well
screen in NS-31 is more than 170 feet below the bottom of the creek. There are no shallow
wells in the area. The water level contour interpretation on Figure 11, showing that the creek
is also the discharge area for the deep bedrock aquifer may not be as reasonable. There is
not a single water level elevation on Figure 11 which confirms that water level contours in
the deep aquifer bend at the stream and confirms that the stream is the discharge area for the
deep aquifer. Groundwater in the deep bedrock may continue to flow westward beneath the
creek and under the subdivision shown on Figure 11 toward some larger stream, a regional
discharge area farther to the west such as the stream on the west side of the subdivision.
Additional monitoring wells should be installed in this area as soon as possible. Then the
existing pumping system should be turned on. If the data provided by the new and existing
•
Additional Comments on 2008 Site Monitoring Report
· February 2010
9
monitoring wells can not prove that the plume is being captured, then additional extraction
wells should be installed. This area around NS-31 has been under investigation for nearly lO
years with the pumps off. Future investigation should occur with the pumps on so the
aquifer can be evaluated under hydraulic stress caused by pumping. If the consultant has not
identified an effective remedy by this time, hydraulic containment appears to be the only
option ,for this uncontrolled plume. An effective capture system should be installed. EPA
guidelines for capture zone evaluation are available in the following publication:
. EP N600/R08/003.
14. Regarding EPA's Comment #15, " ... whether to tum the pumps at NS-49 and NS-SJ.back
on ... ": The last sentence in the September 30th response seems reasonable, that " ...
extraction would likely be initiated in the vicinity of well NS-54, west of the current
extraction wells and where the highest concentrations ofVOCs are currently observed."
Presumably, the vicinity ofNS-54 is near the location of the" ... nearby source ... "
mentioned earlier in the same paragraph. A reasonable schedule to " ... pilot test in situ
remedies such as enhanced reductive dechlorination and/or chemical oxidation to address
impacts to groundwater" should be included in the plan to be submitted to the Agency in the
fourth quarter of 2009 (page 7 of 19). After these pilot tests, full scale implementation of the
promising remedies OR a full scale pump and treat (P&T) remedy should be implemented
promptly.
15. Regarding EPA's Comment #16, reevaluating the OU3 system: The response to Comment
I 6 does not address the request for periodic sampling to assess the concentration of
contaminants in this area of the Site. The pilot study work plan for " ... the feasibility of an
in situ treatment such as in situ chemical oxidation (ISCO) or enhanced reductive
dechlorination (ERD) ... " should be submitted to the Agency as soon as possible. This plan
should include a groundwater monitoring program with reasonable schedule sampling
monitoring wells at this site. After these pilot tests, full scale implementation of the
promising remedies OR a full scale P&T remedy should be implemented quickly.
16. Regarding EPA's Comment #26: Response 26 begins with a statement about the
Conceptual Site Model. Response 26 states that an upward vertical gradient would normally
deter downward migration. This statement would be more informative if the word "inhibit"
were substituted for the word "deter". Regrettably, mincing words is important in this case.
Contamination may migrate downward in the presence of an upward gradient. This is well
documented at other sites and clearly, this has happened near NS-54. If this is inconsistent
with the Conceptual Site Model, then it is the model which is wrong. The model must be
modified and the aquifer must be remediated. The data shows that the 6th bullet on page 8 of
28 of the 2008 Annual Monitoring Report is incorrect. The upward gradient did not cause
contamination to remain shallow. Contamination has already migrated to the deep aquifer.
An upward gradient may slow the rate of downward migration but will not necessarily
prevent downward migration. Contamination is present in the deeper wells even though an
upward gradient is reported under both natural and pumping conditions as stated on page 13
of 19. The cross-sections shown in Figures 4 to 8 would have been more useful if water
level elevations were shown for each well. Shallow Bedrock well NS-32 flows at the land
surface (Figures 6 and I 0) and the water levels on Figures 9, IO and 11 show that upward
•
10
Additional Comment'> on 2008 Site Monitoring Report
February20J0
gradients are present in other areas of the site. In spite of the upward gradient,
contamination from sources near the surface has contaminated all three aquifer zones.
The argument presented on page I 3 of 19 of the September 30th letter that pumping NS-49
caused 1.23 feet of drawdown in NS-54, which is screened deeper in the aquifer and 175 feet
away, shows only that there is a reasonably permeable connection between the wells. The
plot on page 13 of 19 shows that NS-54 was contaminated with DCA before OU3 pumping
began. The plot also shows that DCA concentrations in NS-54 increased between 1998 and
2009, while DCA concentrations in NS-49 and NS-51 decreased particularly in recent years.
The text on page 13 of 19 suggests pumping has notably reduced contaminant concentrations
in the shallow bedrock. But it is clear from the plot on page 13 of 19 that NS-54 has been
highly contaminated for years before pumping began. Contamination has reached the deep
bedrock at high concentrations. This contamination should be contained and rernediated.
17. Comment Regarding Appendix F: The format and scale of the graphs in Appendix F do
not facilitate interpretation of the data. For example, the fourth page of graphs for
manganese in wells NS-13, NS-15 and NS-24 uses 3 different scales for the Y-axis and 3
different scales for the X-axis. The manganese concentrations in NS-35 and NS-36 have
increased since the 1990s, but the X-axis on each graph is different, limiting the ability to
compare the trends. It might be useful to compare the manganese trend with the DCA trend,
but the X-axis for NS-35 is different for these two contaminants in the same well. An
increase in manganese in NS-39 during 2003 appears to have been an early warning for the
subsequent increase in DCA observed in 2004. Elevated manganese concentrations have
persisted in NS-39 after DCA concentrations diminished. It is difficult to evaluate whether
there is any relationship between the spikes in vinyl chloride concentrations in wells NS-35
and NS-46 because the scales are all different. Other relationships between contaminant
concentrations versus time may be in the data which could be useful in evaluating
contaminant migration, degradation and the effectiveness of remediation. The form of the
graphs makes this task more difficult.
The Y-axis on all graphs in Appendix F should be logarithmic so that progress toward clean-
up can be seen in wells where DCA concentrations are low. Some graphs have an arithmetic
Y-axis and some graphs are logarithmetic. For example, the figure for well EX-03 on the
first page of Appendix F does not clearly show whether the well produces water which
exceeds the target cleanup goal. The Y-axis for the graph of NS-49 is arithmetic, but the
graphs for NS-50 and NS-51 on the same page are logarithmic. A Y-axis range of 1-
1,000,000 appears to work well for DCA and may be appropriate for all site related
contaminants.
The X-axes on the graphs in Appendix F begin on many different dates, making comparisons
of contaminant migration between wells difficult. Comparisons of contaminant trends
versus remediation events such as the start of pumping are difficult because each X-axis is
different. The X and Y-axis scales should be the same on all graphs so that concentration
trends can be compared from well to well and for different contaminants in the same well. It
is often useful to begin the X-axis on January 1st of the year with the oldest sample so that
seasonal trends in the contaminant data can be more easily visualized.
•
II
Additional Comments on 2008 Site Monitoring Ri:port
Febmary 2010
18. Comment regarding OU3 pumping well performance: Section 6.1 of the 2008 Site
Monitoring Report describes the recent performance of the OU3 pumping system. The last
sentence of the second paragraph (page 6-19) states the pumping rate was " ... an average
flow rate of 1.4 gallon per minute (I 2.5 gpm)". The conversion factor used to calculate gpm
from gallon per minute seems different from the typical conversion factor used for this
calculation. The OU3 pumping rate is not clear in this report.
The pumping rate is important even though the wells are not pumping at the present time due
to a fire on October 17, 2008 (page 6-19). Wells NS49 and NS-51 are said to have pumped
90 percent of the OU3 pumping volume. These wells are approximately I 00 feet apart
(Figure 9), so clearly the plume probably is wider than I 00 feet. As stated previously, no
map in the 2008 Site Monitoring Report shows the groundwater plumes beneath the Site, so
the width of the plume is unknown.
If the OU3 wells pumped 1.4 gallons per minute, then NS-49 and NS-51 pumped about 0.6
gallons per minute each (1.4 gpm x 90% / 2 wells). It seems likely that a large portion of
groundwater flow from the plant area probably was not captured by the pumping wells. The
size of the capture zones created around the wells when they were in operation should be
evaluated following EPA guidelines
(http://www.epa.gov/ada/download/reports/600R08003/600R08003-FM.pdf). Additional
monitoring wells may be needed in portions of the plume which were not captured.
As stated above, the Agency is not requesting AkzoNobel to revise the 2008 Site
Monitoring Report based on the above comments, but the suggestions/recommendations
presented in these comments as well as the identified shortcomings/concerns must be
incorporated/addressed/considered in future documents. If you have any questions, please feel to
call me at (o) 404-562-8820 or (c) 404-217-8565 or contact me at [e-mail].
cc: David Mattison, NCDENR
Sincerely,
Jon K. Bomholm
Remedial Project Manager
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
4SF-SRSEB
Ms. Angela J. Doh!
Consulting Engineer
AkzoNobel Corporate Legacies
10 Finderne Avenue
Bridgewater, NJ 08807
Ms. Elizabeth Rhine
Project Manager
ARCADIS U.S., Inc.
SAM NUNN ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
June 24, 2009
30 Patewood Drive, Suite 155
Greenville, South Carolina 29615
SUBJ: Comments on 2008 Site Monitoring Report for the National Starch & Chemical
Company Superfund Site in Salisbury, Rowan County, North Carolina
Dear Ms. Doh! & Ms. Rhine:
The Agency and North Carolina Department of Environment & Natural Resources
(NCDENR) received a copy of the above referenced document, dated May 29, 2009, on June 1,
2009. This report was prepared on behalf of AkzoNobel Corporate Legacies (AkzoNobel) by
ARCADIS. Below are the Agency's comments and enclosed are comments from NCDENR.
All comments need to be adequately addressed. This can be done either in a formal
written response or via email. If ARCADIS/AkzoNobel would like to convene a meeting or
conference call to review the comments or assess your proposed responses to these comments
prior to revising this document, please provide a minimum three day notice so that both EPA and
NCDENR can participate in the meeting/call.
1. Page 2-4, Section 2.5 Site Specific Geology: In previous reports, it was stated that the
majority of lateral movement for groundwater was in the "Transition Zone". Under the new
nomenclature for the geologic zones being used for this Site, please identify in what zonc(s)
does the majority of groundwater flow?
2. Page 2-6, Section 2. 7 Site Specific Hydrogeology, first paragraph, last sentence: Typo,
change "Grant Creek" to read "Unnamed Tributary". Refer to page 2-2, Section 2.1 Site
Description, last paragraph, this paragraph identifies/describes the Site features accurately.
2
3. Page 2-6, Section 2.7 Site Specific Hydrogeology, second paragraph, last sentence: Typo,
change "unnamed creek" to read "Northeast Tributary". Refer to comment #2.
4. Page 4-12, Section 3.2 Groundwater Sampling Procedures, third paragraph: This paragraph
refers to TestAmerica as the laboratory that analyzed the samples. However, Table 4 refers
to Severn Trent Labs. Please correct.
5. Page 4-13, Section 4.1 Remediation Program, first paragraph, fourth sentence: Typo, change
"Grants Creek" to read "Unnamed Tributary". Refer to comment #2.
6. Page 4-14, Section 4.1 Remediation Program, first paragraph, first sentence: This sentence
states that the performance of the groundwater extraction system has diminished with time. I
am assuming this statement is referring to the Trench Area Extraction System (TAES).
However, the following paragraphs do not describe how the performance of the T AES will
be improved. What specifically will be done? Pipelines cleaned out, new pumps installed in
the wells, etc.
7. Page 4-14, Section 4.1 Remediation Program, first paragraph, third sentence: This sentence
mentions system upgrades. I'm assuming for the TAES but this sentence should clarify this
point.
8. Page 4-14, Section 4.1 Remediation Program, first paragraph, fourth sentence: This sentence
states, " ... work is being done ... ". This paragraph should be expanded to detail what "work"
is being done.
9. Page 4-14, Section 4.1 Remediation Program, second paragraph, second sentence: The
rationale for why extraction wells, EX-09 and EX-05, are to be the first extractions wells
brought back on line should be included in this paragraph.
10. Page 4-14, Section 4.1 Remediation Program, second paragraph, third sentence: This
sentence mentions the evaluation of the TAES, including the capture zone. Are there
sufficient monitoring points close enough to these two extraction wells, EX-09 and EX-05,
to measure actual drawdown in the surrounding area? Drawdown in the extraction well itself
is not to be used in evaluating the capture zone.
11. Page 4-14, Section 4.2 OU! Monitoring Program, first paragraph: A thorough evaluation of
the TAES would help to insure AkzoNobel (using an old colloquial phrase) "gets the best
bang for the buck".
12. Page 5-17, Section 4.3.3, first paragraph, second sentence: Typo, "Grants Creek" should read
"Unnamed Tributary". Refer to comment #2.
13. Page 5-17, Section 4.3.3, second paragraph: One of the arguments made in the past for
shutting down the Plume Periphery Extraction System (PPES) was that the system caused
c_ontaminated groundwater to flow under the Unnamed Tributary and adversely impact the
groundwater in the vicinity of monitoring well NS-31. If this assumption was correct, the
3
Agency would expect that the level of 1,2-dichloroethane (1,2-DCA) in NS-31 to be
declining, not stable, since the PPES has been shut down for over nine years. It may be time
to re-evaluate why we are still seeing evaluate levels of 1,2-DCA in NS-31.
14. Page 5-18, Section 5. I Soil Evaluation, top of page, fir~t senten_ce: This_sentence needs to be
changed to read, " ... same locations every 5 years in_ c_onj1mction. \Vith _the Five-Year Review r~• -• ~· •W• ' 1)rocess, to vertically profile the vadose zone."
15. Page 6-19, Section 6.1 Remediation Program: Since it is not stated in this Section, is it the
intention of AkzoNobel not to start-up the Operable Unit #3 (OU3) groundwater extraction
system (NS-49 and NS-51) after the groundwater pretreatment is repaired?
16. Page 6-19, Section 6.1 Remediation Program, fourth paragraph, first sentence: This sentence
talks about reevaluating the OU3 system. However, no detail is provided about what is to be
evaluated. Information about what is to be evaluate and how should be included in this
Section. As you know, the MCL for I ,2-DCA remains at 5 micrograms per liter (µg/1) (i.e.,
the current OU3 Record of Decision (ROD) Performance Standard) but the North Carolina
2L groundwater standard for 1,2-DCA has been dropped to 0.38 µg/1. I am assuming that
any evaluation will include periodic sampling of the appropriate wells to assess the potential
occurrence of a rebound in the concentration of contaminants in the groundwater in this area
of the Site.
17. Page 6-20, Section 6.2 OU3 Monitoring Program, first full paragraph: This paragraph refers
to Appendix A. I did not see any progression or rationale included in Appendix A as it
pertains to the OU3 monitoring program.
18. Page 6-21, Section 6.3.1.1 Saprolite, third sentence: Typo, "unnamed tributary" should read
"Northeast Tributary". Refer to comment #2.
19. Page 7-26, Section 7.1 Soil Evaluation, second paragraph, fifth sentence: Unfortunately, it is
not as simple as picking a remedial strategy and moving forward unless the remedial strategy
fits under the approach outlined in the OU4 ROD. If the remedial strategy falls outside the
approach outlined in the OU4 ROD, then EPA will need to initiate and complete a number of
bureaucratic steps prior to initiating a different remedial strategy.
20. Page 8-27, Section 7.3 Evaluation of the SVE System, third bullet: Has ARCADIS estimated
a timeframe when asymptotic conditions may be obtained? To play devils advocate, what
will be done if the asymptotic condition occurs at a concentration above the cleanup goal of
169 micrograms per kilogram for 1,2-DCA?
21. Page 8-27, Section 7.3 Evaluation of the SVE System, fourth bullet: The Agency
understands the hesitancy to bore through the freshly cured concrete driveway/apron.
However, the Agency is concerned that collecting soil samples from the SVE wells may bias
the sampling results towards indicating that the SVE system has achieved the soil cleanup
goal for 1,2-DCA throughout the treatment area. Whereas, if these "confirmation" soil
4
samples were collected 20 feet away from any component of the SVE system, this data may
provide a more representative portrayal of the remaining concentration of 1,2-DCA in the
subsurface soils. How many SVE wells will be sacrificed?
22. Page 8-27, Section 8.0 Conclusions and Recommendations, second bullet, first sentence:
This sentence needs to be more specific. ls this sentence referring to the TAES or to the
PPES or both systems?
23. Page 8-27, Section 8.0 Conclusions and Recommendations, second bullet, fourth sentence:
This sentence slates, "The results obtained from these wells will be used to evaluate the
system ... ". What results (e.g., concentration of contaminants in the extracted groundwater,
groundwater extraction rates, cone of influence, etc.)? Refer to comments #6 and #29.
24. Page 8-28, Section 8.0 Conclusions and Recommendations, second bullet: The next soil
sampling to be conducted in the Trench Area should be moved up to early spring of 2012.
This will allow sufficient time for the analytical results for these soil samples to be
incorporated into the next Five-Year Review Report. On a side note and as a heads up, in an
attempt to avoid the end of the Agency's fiscal year crunch, it is the Agency's desire to
finalize the next Five-Y_ear Review Report (2012) in the June/July timeframe.
25. Page 8-28, Section 8.0 Conclusions and Recommendations, fifth bullet: Is this bullet stating
that the pumps in extraction wells NS-49 and NS-51 are not going to be turned back on after
the pretreatment system is brought back online? If so, please provide a monitoring program
for the Lagoon Area in order evaluate if any rebound occu.rs in this area. Refer to comment
#15.
26. Page 8-28, Section 8.0 Conclusions and Recommendations, sixth bullet: The point this bullet
is attempting to make is confusing. ls this bullet stating that if wells NS-49 and NS-51 were
not pumped, then we would not be detecting elevated concentrations of 1,2-DCA in
monitoring well NS-54 (i.e., extracting groundwater from these two wells resulted in 1,2-
DCA to immigrate deeper into the bedrock)? When was monitoring well NS-54 installed,
before or after. the initiation of pumping from wells NS-49 and NS-51? If monitoring well
NS-54 was installed before wells NS-49 and NS-51 were modified into extraction wells,
what was the concentration of 1,2-DCA in well NS-54?
27. Page 8-28, Section 8.0 Conclusions and Recommendations, seventh bullet: The Agency
concurred with replacing NS-47 for the reason stated in the text of this bullet. However, the
inference of the phrase "acting as a direct conduit from the saprolite to the shallow bedrock"
can be misconstrued lo imply that there is no communication between these two geologic
formations underlying the Site. There is direct contact between the three geologic units (i.e.,
direct contact between the saprolite and the shallow bedrock and between the shallow
bedrock and the underlying more competent bedrock).
· 28. Page 8-28, Section 8.0 Conclusions and Recommendations, eighth bullet: Is there an
estimate as to how many wells this will include?
5
29. Page 8-29, Section 8.0 Conclusions and Recommendations, first bullet: The Agency
understands that the T AES should have been pumping at a higher rate than it was when it
was shut down due to the fire in the pretreatment building in October 2008. Refer to
comments #6 and #23. What has or will be done to increase the pumping rate from this
system?
30. Page 8-29, Section 8.0 Conclusions and Recommendations, fourth bullet: The Agency
concurs with the work proposed in this bullet. However, the Agency would encourage
AkzoNobel/ACRADIS to submit a work plan prior to commencing the work to insure all
parties are on the same page. Submitting a work plan after the fact may result in a
duplication of effort if either EPA or NCDENR identify a deficiency.
31. Page 8-29, Section 8.0 Conclusions and Recommendations, sixth bullet: If the pilot study is
designed appropriately, it is feasible that the pilot study may eliminate the need for
additional remediation efforts in this area.
32. Page 8-29, Section 8.0 Conclusions and Recommendations, last bullet on the page: This
bullet states that Level 4 reports will no longer be requested from the laboratory. As this a
change, this request needs to be submitted in writing under a separate cover and not as a
bullet in a report. EPA needs to concur with this request prior to making this change.
33. Page 8-30, Section 8.0 Conclusions and Recommendations, only bullet on the page: The
proposed change highlighted in this bullet, modification of the current sampling plan, needs
to be submitted in writing under a separate cover and not as a bullet in a report. EPA needs
to concur with this request prior to making any changes. Refer to comment #35 for
additional input on Table 9.
34. Table I: After wells NS-02 and NS-24 are abandoned, I will assume that this information
will be added to this table under "NOTES".
35. Table 9: This table should be comprehensive, include all Site monitoring wells. Refer to
comment #33 above. A second column under "Rationale" should be added. The current
column covers annual sampling and the new column should provide the rationale for
sampling/not sampling each well as part of the Five-Year Review effort.
36. Figure 2: As there is some confusion throughout this report as to which surface stream is
which, it may be advisable to label the streams on this figure. Based on my knowledge of
the area, Grants Creek is not shown on this figure, only the Northeast Tributary and the
Unnamed Tributary. Refer to Section 2.2 of this report.
37. Figure 4: Refer to comment #36 above. "Grant's Creek" should read "Unnamed Tributary".
38. Figure 6: Refer to comment #37 above.
39. Figure 12: Why is the concentration for Manganese for monitoring well NS-10 in bold print?
6
40. Table I_: The date the PPES was shut down should be included in this table. The date of the
fire that shut down the pretreatment system should be included in this table.
41. Appendix C, Section 2 Method Reporting Limits and Dilution Factors, first sentence:
Should "2007" read "2008"?
42. Appendix E: The well designations in these tables need to be updated. For example, on the
first table, the eighth column is entitled "NS-31-T" where the 'T" represents the 'Transition
Zone". ls "T" going to be redefined as "Shallow Bedrock"? If so, this needs to be defined
under "NOTES".
43. Appendix F Trend Plots of Historical Data: For those graphs where the graphed line appears
to be asymptotic on "Zero", it would be helpful if a second graph is generated using a more
appropriate scale on the y-axis. The scale on the y-axis of these new graphs should be such
that it shows the variation in concentrations between sampling events.
As stated above, all comments need to be adequately addressed. If you have any
questions, please feel to call me at (o) 404-562-8820 or (c) 404-2 I 7-8565 or contact me at
[e-mail]. '
Enclosure (I):
I. Comments from NCDENR (June 22, 2009)
cc: David Mattison, NCDENR
Sincerely,
Jon K. Bornholm
Remedial Project Manager
MA
HCDENR
North Carolina Department of Environment and Natural Resources
Division of Waste Management
Beverly Eaves Perdue
Governor
Dexter R. Matthews
Mr. Jon Bornholm
Remedial Project Manager
Director
Superfund Remedial & Site Evaluation Branch
Waste Management Division
U. S. Environmental Protection Agency, Region 4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303
RE: 2008 Site Monitoring Report
May 22, 2009
Former National Starch & Chemical Company NPL Site
Salisbury, Rowan County
NCO 003 188 828
Dear Mr. Bornholm:
Dee Freeman
Secretary
The North Carolina Department of Environment and Natural Resources (NC DENR) Superfi.md Section has
received the 2008 Site Monitoring Reporl for the Former National Starch & Chemical Company National Priority
List (NPL) Site. The NC DENR Superfund Section has reviewed this document and offers the following attached
comments.
The NC DENR Superfund Section appreciates the opportunity to comment on these documents. If you have any
comments or questions, please do not hesitate to contact me at [phone] or [e-mail].
Attachment
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Sincerely,
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
Phone: [phone] \ FAX: [phone] \ Internet: www.wastenotnc.org
An Equal Opportunity I Affirmative Action Employer
OnehC 1. Nort aroma Jvaturally
Mr. Jon Bornholm
2008 Site Monitoring Rcpon
Former National Starch & Chemical Company NPL Site
NCD 003 188 828
June 22, 2009
Page I
Former National Starch & Chemical Company
2008 Site Monitoring Report
Section 2.5 Site Specific Geology
I. Please correct the second sentence of the third paragraph of Section 2.5 to state "The saprolite is
characterized as a mixed silt and clay at shallower depths ... "
Section 2.7 Site Specific Hydrogeology
2. Please correct the last sentence of the first paragraph of Section 2. 7 to state "Grants Creek to the west and
the unnamed creek to the east act as the discharge boundaries for groundwater. "
Section 2.8.2 Northern Production and Lagoon Areas
3. Please complete the second sentence of the fourth paragraph of Section 2.8.2 to state "The initial phase of
investigation for the OU4 soils was completed by __ in 1993 and included the collection of soil samples
from 24 borings distributed throughout OU4."
Section 3.1 Water Level Measurement
4. Please correct the second sentence of the third paragraph of Section 3.1 to state "Artesian conditions were
present at NS-32; therefore, an accurate groundwater elevation could not be determined."
Table 7 Summary of Performance Monitoring Results for OU3 Wells-Lagoon Arca
5. Please revise Table 7 to include the correct volatile organic compound (VOC) performance monitoring
results for groundwater monitoring well NS-53, as provided in Appendix D.
RA
MCDEMR
North Carolina Department of Environment and Natural Resources
Division of Waste Management
Beverly Eaves Perdue
Governor
Dexter R. Matthews
Director
Mr. Jon Bomholm
Remedial Project Manager
Superfund Remedial & Site Evaluation Branch
Waste Management Division
U.S. Environmental Protection Agency, Region 4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303
RE: 2008 Site Monitoring Report
May 22, 2009
Former National Starch & Chemical Company NPL Site
Salisbury, Rowan County
NCO 003 188 828
Dear Mr. Bornholm:
Dee Freeman
Secretary
The North Carolina Department of Environment and Natural Resources (NC DENR) Superfund
Section has received the 2008 Site Monitoring Report for the Former National Starch &
Chemical Company National Priority List (NPL) Site. The NC DENR Superfund Section has
reviewed this document and offers the following attached comments.
The NC DENR Superfund Section appreciates the opportunity to comment on these documents.
If you have any comments or questions, please do not hesitate to contact me at [phone] or
[e-mail].
Attachment
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Sincerely,
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
Phone: [phone] I FAX: [phone] I Internet: www.wastenotnc.org
An Equal Opportunity I Affirmative Action Employer
NOnehC . ort arohna lvatttral/11
•
Mr. Jon Bornholm
2008 Site Monitoring Report
Former National Starch & Chemical Company NPL Site
NCD 003 188 828
June 22, 2009
Page I
Former National Starch & Chemical Company
2008 Site Monitoring Report
Section 2.5 Site Specific Geology
I. Please correct the second sentence of the third paragraph of Section 2.5 to state "The
saprolite is characterized as a mixed silt and clay at shallower depths ... "
Section 2. 7 Site Specific Hydrogeology
2. Please correct the last sentence of the first paragraph of Section 2. 7 to state "Grants Creek
to the west and the unnamed creek to the east act as the discharge boundaries for
ground water. .. "
Section 2.8.2 Northern Production and Lagoon Areas
3. Please complete the second sentence of the fourth paragraph of Section 2.8.2 to state
"The initial phase of investigation for the OU4 soils was completed by __ in 1993 and
included the collection of soil samples from 24 borings distributed throughout OU4."
Section 3.1 Water Level Measurement
4. Please correct the second sentence of the third paragraph of Section 3.1 to state "Artesian
conditions were present at NS-32; therefore, an accurate groundwater elevation could not
be determined."
Table 7 Summary of Performance Monitoring Results for OU3 Wells -Lagoon Area
5. Please revise Table 7 to include the correct volatile organic compound (VOC)
performance monitoring results for groundwater monitoring well NS-53, as provided in
Appendix D.
·'
~ARCADIS
MEMO
To:
Mr. Jon Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
Region IV
61 Forsyth Street, SW
Atlanta, Georgia 30303
From:
Elizabeth L. Rhine
Project Coordinator
Date:
July 2, 2009
Subject:
Monthly Progress Report -June 2009
Copies:
Angela Dahl
David Mattison, NCDENR DWM
Debra Rubenstein, Esq.
Jerry McMurray
ARCAD\S Project No.:
B0060013.0001
National Starch and Chemical Company Site, Salisbury, North Carolina
Operating Unit 4 Remediation
Dear Jon:
ARCADIS
30 Patewood Drive
Suite 155
Greenville
South Carolina 29615
Tel [phone]
Fax[phone]
ARCADIS is submitting this monthly progress report to meet the requirements of paragraph 14 of executed Unilateral
Administrative Order (UAO) on the subject site. The progress report a) documents the actions taken in the last month
to achieve compliance with the CD; b) includes summaries of results of sampling data received or generated in the
previous month; c) identifies work plans or other deliverables required by the CD, completed and submitted during the
previous month; d) describes all actions forecasted to be performed over the next six weeks and construction
progress, including a Gantt chart for achieving the CD requirements; e) provides an update on the overall schedule for
the project, including percentage completed and efforts to address any delays; f) includes any modifications to work
plans or schedules proposed to or approved by EPA; and g) describes activities completed in accordance with the
Community Relations Plan in the last 30 days and forecasted for the next six weeks.
The following actions have taken place in the last month:
Completion of the existing pavement removal of Phase Ill Road Replacement on June 26, 2009 -
includes the relocation and repair of existing in-ground utilities.
Work is ongoing on sealing outside chemical storage tank and process area secondary
containments. Effort expected to continue for several months.
Installation of some of the transfer piping continues.
Fabrication of the replacement scrubber began on June 29, 2009.
Request for Quotations issued for mechanical components of the SVE systems. Bid award now
forecasted to occur week of July 13, 2009.
Page:
1/2
ARCADIS
Final drafts of Request for Quotations for interconnect piping and SVE system installation
completed. RFQs will be issued after receipt and review of system component bids.
Retrieval of vertical profiling passive diffusion bags (PDBs) began June 29, but could not be
completed due to plant closure in observance of Independence Day.
The following sampling data has been received in the last 30 days:
Initial results of Phase Ill soil stockpile and concrete debris. Results show Phase Ill soils very
similar to Phase II results. Selected samples being analyzed using TCLP to confirm non-
hazardous status of materials.
The following work plans and other submittals have been completed and submitted in the last 30 days:
Letter to EPA requesting abandonment of existing wells NS-2 and NS-24 to allow for Henkel
expansion activities issued June 12, 2009.
The following actions are forecast to be completed in the next six weeks:
Completion of the road replacement actions for Phase Ill.
Complete retrieval of PDBs for vertical profiling and review of data.
Letter to EPA requesting approval to dispose of Phase Ill soils at the Phase II soil treatment
location.
Letter to EPA requesting approval to reuse on-site concrete debris from Phase Ill.
The following sampling activity is being proposed:
RCRA groundwater sampling event scheduled for the week of July 6, 2009.
The updated OU4 remediation Gantt chart for the project is included with this letter.
The following are requested modifications to work plans or schedules submitted to the EPA:
Change of OU4 remediation system start-up from September 1 to November 1, 2009 to account
for forecasted delivery date of October 16, 2009 for air emission control equipment.
The following is describes activities completed in accordance with the support of EPA's Community Relations Plan:
No activities have been requested
Should you have any questions regarding this Progress Report, do not hesitate to contact the Project Coordinator.
Sincerely,
Elizabeth L. Rhine
Project Coordinator
Page:
2/2
cu,A«'""'""' .. "'" NS(:C ....... .-..... --..o,C
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION4
SAM NUNN ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
4SF-SRSEB
Ms. Angela J. Dohl
National Starch & Chemical Company
10 Findeme Avenue
Bridgewater, New Jersey 08807
Ms. Elizabeth Rhine
Project Manager
ARCADIS U.S., Inc.
30 Patewood Drive, Suite 155
Greenville, South Carolina 29615
January 23, 2009
SUBJ: Comments on 2007 Site Monitoring Report for the National Starch & Chemical
Company Superfund Site in Salisbury, Rowan County, North Carolina
Dear Ms. Dohl & Ms. Rhine:
The Agency received numerous copies of the above referenced document dated,
November 18, 2008. As you know, I am overseeing activities at the National Starch & Chemical
Company (NSCC) Site during Ken Lucas absence from the office. To the best of my knowledge,
the only other entity to review this document other than Superfund Division/Superfund Remedial
and Site Evaluation Branch, was North Carolina Department of Environment & Natural
Resources (NCDENR). Below are the Agency's comments and enclosed are comments from
NCDENR.
The following comments are arranged in the order they appear in the referenced
document. All comments need to be adequately addressed. This can be done either in a formal
written response or via email. Revising the document can occur in one of three (3) ways. First,
in an effort to minimize the use of paper, the comments and EPA's approved responses can be
added to the document (November 18, 2008) as either an appendix or an addendum. The second
option is for NSCC/ AR CAD IS to revise the document based on EPA 's approved responses and
submit the revised document electronically (pdf format is acceptable). The last option is to
revise the document and resubmit hard copies of the document.
I. Page I, Section I Introduction: A short explanation needs to be prepared explaining why it
took so long to generate this document.
2
2. Page I, Section I Introduction: This section should capture the recent transaction of the
property and identify who the current owner of the property/facility is and any leases (long-
term or short-term) associated with the property/facility.
3. Page 2, Section 1.1.1 Operable Units One and Two, second paragraph: If the plume
periphery extraction system is to remain shut down, the Agency will need to solicit support
from National Starch & Chemical Company (NSCC) to address this from an administrative
aspect.
4. Page 2, Section 1.1.1 Operable Units One and Two, third paragraph, second half of the first
sentence: This portion of the sentence states, " ... and that the Trench Area Extraction System
has been successful in improving groundwater quality by reducing concentrations of
dissolved constituents in groundwater upgradient of the Unnamed Tributary." Relatively
high concentrations of contaminants are constantly being detected in monitoring well (MW)
NS-56-B. Since the argument has been made by ARCADIS in the past that the transition
zone is where the majority of groundwater flows, what is the _rationale for not including the
MW NS-16-T in the groundwater monitoring program which is located adjacent to MW NS-
56-B?
5. Page 3, Section 1.1.3 Operable Unit Four, last sentence on the page: This sentence states,
"Activities are not limited to those listed above; additional activities are being performed as
outline in the Supplemental OUJ Remedy Evaluation Report (BBL, 2005)." Instead of
making the reader dig out another report, why not list those activities here?
6. Page 6, Section 2.1 Operable Units One and Two, third paragraph: Have any plans been
made to measure the rate of evaportransportation of the planted trees versus precipitation to
help verify the assumption that the trees are achieving the desired effect?
7. Page 6, Section 2.1 Operable Units One and Two, fourth paragraph: A short explanation
should be included in this paragraph stating why these three (3) species of trees were
selected for planting.
8. Page 8, Section 2.1.2 Outstanding Issues, the three (3) bullets: Rationale needs to be
included in this section supporting why the three (3) extraction rates (5 gallons per minute
(gpm) for NS-55-B, 0.5 gpm for NS-56-B, and 2 gpm for NS-57-B) were used in the model.
9. Page 8, Section 2.1.2 Outstanding Issues, last paragraph, first sentence: Why does the close
proximity ofNS-55-B to the plume periphery extraction system (PPES) restrict its
. usefulness? The PPES has been shut down since 2000. Additionai information needs to be
added to this paragraph supporting the stance that NS-55-B should not be turned into an
extraction well.
I 0. Page 8, Section 2.1.2 Outstanding Issues: ls there a need for additional monitoring wells
(MWs) downgradient of the Trench Area?
3
11. Page 9, Section 2.1.2 Outstanding Issues, paragraph at top of page: This paragraph proposes
shutting down extraction wells EX-06-T and EX-07-T. The forthcoming formal request will
need to build/present a strong case for turning off extraction wells EX-06-T and EX-07-T.
12. Page 9, Section 2.1.2 Outstanding Issues, paragraph at top of page, last sentence: This
sentence states hydraulic control would be achieved if the combined pumping rate of the
extraction wells was 12 gpm. When was the last time the trench area extraction system
(TAES) extracted 12 gpm on a consistent basis?
13. Page 10, Section 2.2.2 Outstanding Issues: Since I have not been associated with this Site for
some time, has NSCC submitted a capture zone analysis for OU3 that was approved by the
Agency? If not, then this remains an outstanding issue.
14. Page 11, Section 2.3.2 Issues Encountered and Resolved, third bullet: Has a soil-vapor
intrusion pathway for workers in the process building been evaluated to confirm that there is
no unacceptable risk to the workers? If not, is there a plan on doing one?
15. Page 13, Section 3.1.1 Operable Units One and Two: There is no mention in this section of
fulfilling the OU2 Record of Decision (ROD) requirement of collecting soil samples from
the Trench Area no less than every five (5) years. This section should at least knowledge
this requirement and state when the last time these soil samples were collected?
16. Page 15, Section 3.1.2.1 Groundwater Monitoring: The two bullets in this section focused on
being "Inside" and "Outside" of the Zone of Hydraulic Control: None of the figures
included in this document delineate this "Zone of Hydraulic Control" for OU3. (Refer to
comment #13 above.)
17. Page 16, Section 3.1.2.2 RCRA Sampling: Why weren't the analytical results for the RCRA
related samples summarized in tables like the analytical results were for Sections 3.1.1 and
3.1.2?
18. Page 16, Section 3.1.2.2 RCRA Sampling, last sentence: Typo? Every where else in the
document the months of July and December are referenced. Should "November" read
"December" in this sentence?
19. Page 22, Section 4.1.2 Operable Unit Three, third sentence: How does the context of this
sentence relate back to the issues raised in comments # 13 and # I 6 above? Is there a
schedule for improving the operation of the OU3 groundwater extraction system and a
focused effort for a systematic approach for capture zone analysis? Below are ihe
appropriate steps and their references for conducting such an evaluation:
Step I: Review site data, site conceptual model, and remedy objectives
Step 2: Define site-specific target capture zone(s)
Step 3: Interpret water levels
► Potentiometric surface maps
4
► Water level pairs (gradient control points)
Step 4: Perform calculations (as appropriate based on site complexity)
► Flow budget calculation
► Capture zone width calculation ( can include drawdown calculation)
► Modeling (analytical and/or numerical) to simulate heads, in conjunction
with particle tracking and/or transport modeling
Step 5: Evaluate concentration trends (and potentially tracer tests)
Step 6: Interpret actual capture based on steps I to 5, compare to target capture zone(s),
assess uncertainties and data gaps.
The following is a list ofreferences/guidances:
• "Elements for Effective Management of Operating Pump and Treat Systems," November
2002, OSWER 9355.4-27FSA.
• "Methods for Monitoring Pump-and-Treat Performances," June 1994. ORD Publication
EPN600/R-94/123, NTIS Order Number PB95-125456.
• "Design Guidelines for Conventional Pump-and-Treat Systems," September 1997. ORD
and OSWERjoint publication EP N540/S-97 /504, EP A-68-C4-003 l, NTIS Order Number
PB98-l 15389INZ, 44p.
• "Pump-and-Treat Ground-Water Remediation: A guide for Decision Makers and
Practitioners"' July 1996. ORD Publication EPN625/R-95/005, NTIS Order Number PB97-
154009, 74p.
These documents are available at
http://www. epa. gov/super fu nd/reso urccs/ gcwdocs/p u 111 Ire. h I 111
20. Page 24, Section 4.2.1.1 Plurne Periphery Wells, Tables: In future reports, it would be
beneficial if the "Reporting Limit" with the qualifier "U" be incorporated into these tables
and tables in other sections instead of a dash("-"). This is especially true since there is a
history of elevated detection limits for groundwater samples collected at the NSCC Site.
21. Page 33, Section 4.3 Groundwater Remediation System, fourth sentence: I thought the
catalytic oxidizer was destroyed in October 2008. Is the off-gas from the air stripper being
treated or is it being released to the atmosphere? If being treated, what technology is being
used? If not, will the catalytic oxidizer be replaced? If the plan is to discharge directly into
the atmosphere, what is the anticipated mass of volatile organic compounds (VOCs) that will
be discharged on a monthly or annual basis?
22. Page 34, Section 4.3.1.1 plume Periphery and Trench Area Wells, third paragraph, seventh
sentence: This sentence states that updates will be made to the T AES. This paragraph needs
to be expanded to include a schedule for implementing these updates as well as identifying
what these updates are.
5
23. Page 36, Section 4.3.1.1.1 Evaluation of Pumping in the Plume Periphery and Trench Area
Wells, third bullet, second item: The text in this sentence states, " ... which could influence
groundwater flow." What effort(s) has (have) been made since this observation was made to
either confirm or refute this "influence"? Are there any plans to address this unknown?
24. Page 37, Section 4.3.1.1.1 Evaluation of Pumping in the Plume Periphery and Trench Area
Wells, first bullet: Please explain how "Reforestation of the trench area ... " is being used to
evaluate the performance of the Trench Area?
25. Page 37, Section 4.3.1.1.1 Evaluation of Pumping in the Plume Periphery and Trench Area
Wells, second bullet: Based on the data presented in the table on page 26, the concentration
ofl,2-dichloroethane (1,2-DCA) in both of these extraction wells (EX-06-T and EX-07-T) is
above the performance standard for 1,2-DCA.
26. Page 40, Section 4.3.1.2 OU3 Collection Trench and Extraction Wells, Evaluation ofOU3
Collection Trench and Extraction Wells: This paragraph implies, based on the results of a
computer model, that OU3 is achieving hydraulic control. Before the Agency concurs that
the OU3 groundwater extraction system is achieving hydraulic control for this region of the
Site, a systematic analysis needs to be performed. Refer to comment #19 above. The results
of a model, by itself, are not sufficient.
27. Figure 2-4 (Pumping rate of 12 gpm): There is no scale associated with this figure; however,
based on spacing and the scale presented in Figure 3-1, it appears an inch equals 200 feet.
First I want to state that I am not a modeler, but the direction of the arrows in the grids
downgradient of extraction well EX-05-T imply that this well is pulling water back to the
well over 200 feet away in a downgradient position. I highly question this, especially being
familiar with the terrain of this area.
As stated above, all comments need to be adequately addressed.
If you have any questions, please feel to call me at (0) 404-562-8820 or (C) 404-217-
8565 or contact me at [e-mail].
Enclosure (1):
1. Comments from NCDENR (December 17, 2008)
cc: David Mattison, NCDENR
Sincerely,
Jon K. Bomholm
Remedial Project Manager
.;:;&;;;;::;;.:~;h
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director Division of Waste Management
December 17, 2007
Mr. Ken Lucas
Remedial Project Manager
Superfund Remedial & Site Evaluation Branch
Waste Management Division
U. S. Environmental Protection Agency, Region 4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303
RE: 2007 Site Monitoring Report
National Starch and Chemical Company NPL Site
Salisbury, Rowan County, North Carolina
Dear Mr. Lucas:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the 2007 Site Monitoring Report for
the National Starch and Chemical Company National Priority List (NPL) Site. The . .
Superfund Section offers the following attached comments.
The NC DENR Superfund Section appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919)
508-8466. ·
Attachment
Sincerely,
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] I FAX [phone]\ Internet http://wastenotnc.org
An Equal Opportunity/ Affirmative Action Employer-Printed on Dual Purpose Recycled Paper
Mr. Ken Lucas
2007 Site Monitoring Report ·
National Starch and Chemical Company NPL Site
December 17, 2007
Page I
2007 Site Monitoring Report
National Starch and Chemical Company NPL Site
Table of Contents
I. Please correct the Table of Contents to indicate that the title of Table 4-1 is "OU!
and OU3 Performance Standards."
2. Please correct the Table of Contents to indicate that the titles of Figures 4-1
through 4-5 reference December 2007.
Section 4.2.1.1 Plume Periphery Wells
3. Please com~ct the first table contained within Section 4.2.1.1 to indicate that the
groundwater sample collected from groundwater monitoring well NS-31-T
contained an estimated 145 J micrograms per liter (µg/L) 1,2-dichloroethane (1,2-
DCA), expressed as an average of the detected concentration for the sample and
its blind duplicate.
4. Please revise the first table contained within Section 4.2.1.1 to indicate that the
methylene chloride concentration observed in the groundwater sample collected
from monitoring well NS-31-T is expressed as an average of the detected
concentration for the sample and its blind duplicate.
5. Please correct the first table contained within Section 4.2.1.1 to indicate that the
groundwater sample collected from groundwater monitoring well NS-57-B
contained 48,000 µg/L acetone.
6. Please correct the last two sentences of Section 4.2.1.1 to state ''NS-57-B
detections included bis (2-chloroethyl) ether, barium, cadmium, chromium,
manganese, nickel, zinc, acetone, 1,2-DCA, toluene, 1,2-DCP, xylenes (total),
and ethyl benzene. NS-58-T detections included barium, beryllium, chromium,
manganese, nickel, zinc, 1,2-DCA and ethyl benzene."
Section 4.2.1.2 Trench Area Wells
7. Please correct the first table contained within Section 4.2.1.2 to indicate that the
groundwater sample collected from groundwater extraction well EX-09-T
contained an estimated 2,500 J µg/L xylenes (total).
8. Please correct the third table contained within Section 4.2.1.2 to indicate that the
groundwater wells where groundwater exceedances were observed were EX-05-
T, EX-07-T, EX-09-T, EX-10-T, NS-09-T and NS-56-B.
•
Mr. Ken Lucas
2007 Site Monitoring Report
National Starch and Chemical Company NPL Site
December 17, 2007
Page 2
Section 4.2.2.1 OU3 Wells
9. Please revise the third table contained within Section 4.2.2.1 to indicate with hash
marks(-) the-lack of exceedances observed at groundwater monitoring wells NS-
45-T and NS-46-B for thallium.
I 0. Please correct the second sentence of the last paragraph of Section 4.2.2.1 to state
" ... with the exception ofl,2-DCA (26 µg/L) in NS-51-T, trans-1,2-
dichloroethene (estimated below reporting limit at 0.45 µg/L) in NS-46-B, 1,2-
dichloroethane (estimated below reporting limit at 0.30 µg/L) ... "
Table 4-2 Comparison of December 2007 Analytical Results for Plume
Periphery Wells to Performance Standards
11. In accordance with the laboratory analytical results submitted as Appendix C,
please correct Table 4-2 to indicate that the groundwater sample collected from
monitoring well NS-32-T contained an estimated 0.079 J µg/L chloroform.
Table 4-3 Comparison of Analytical Results for Trench Area Wells to
Performance Standards
12. In accordance with the laboratory analytical results submitted as Appendix C,
, please correct Table 4-3 to include the laboratory analytical results of trip blank
TB-121207, which was inadvertently omitted.
Table 4-4 Comparison of Analytical Results for OU3 Wells to Performance
Standards
13. In accordance with the laboratory analytical results submitted as Appendix C,
please correct Table 4-4 to indicate that the groundwater sample collected from
monitoring well NS-37-T contained an estimated 0.35 J µg/L 1,2-DCA.
14. In accordance with the laboratory analytical results submitted as Appendix C,
please correct Table 4-4 to indicate that the groundwater sample collected from
monitoring well NS-41-T contained an estimated 0.44 J µg/L 1, 1,2-
trichloroethane.
15. In accordance with the laboratory analytical results submitted as Appendix C,
please correct Table 4-4 to include the laboratory analytical results of equipment
blanks EB0 120507 and EB-121007 and trip blank TB-120507, which were
inadvertently omitted.
r
•
Mr. Ken Lucas
2007 Site Monitoring Report
National Starch and Chemical Company NPL Site
December 17, 2007
Page 3
16. In accordance with the laboratory analytical results submitted as Appendix C,
please correct Table 4-4 to indicate that the laboratory analytical results of trip
blank TB-121007 are actually the laboratory analytical results of trip blank TB-
121107.
Table 4-6 Comparison of RCRA Analytical Results to Class GA Groundwater
Standards -December 2007
17. In accordance with the laboratory analytical results submitted as Appendix C,
please correct Table 4-6 to indicate that the groundwater sample collected from
monitoring well NSA9-T contained 0.99 B µg/L copper.
-----_,,-,,Eo_sr,,l'::--_..---LiNITED STATES ENVIRONMENTAL PROTECTION AGENCY _____ ----------,,; ft . REGION 4 , ~ ~ ~l-~ -~f ,. ,~ 1 <: ~ ll 1r,;ic::. c i' ,, .... ·, ~ '0,_~/,7 ;j; SAM NUNN ATLANTA FEDERAL CENTER;("--· ____ .,c; __ .• :·: ~ ~ ~ 61 Forsyth Street, S.W. /i ·., , %-"" _,,_,o~ _Allanta,Georgia 30303-3104[, ,,1 OCT 22 2007 i '1 ,ql. PRO\iv I ' ..,
I October 18, 2007 SL; ~t ;:_i,-::-;::,· · -·--· ·,111 '-' 111 4WD-SRSEB
Ms. Angela J. Dohl _
National Starch & Chemical Company
IO 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 2006 Site Monitoring Report for National Starch & Chemical Compai)'.y Superfund Site, Salisbury, Rowan County, North Carolina
Dear Ms. Doh!, Mr. Fleischner, & Ms. Seebald:
The Agency received the above referenced document dated, September 13, 2007, on September 24, 2007. This report was prepared by Arcadis-BBL on behalf of National Starch & Chemical Company (NSCC). At the request of the Agency, a copy of this report-was also sent to North Carolina Department of Environment & Natural Resources (NCDENR) for the State's review and Site file. ·
Below are the Agency's comments and enclosed are comments from NCDENR. All comments need to be addressed. However, since this report does not draw any conclusions nor makes any recommendations, there is no need to revise this document based on these comments. The Agency will attach NSCCs response to these comments as an addendum to this report for the Site file.
I. A general comment, if permitted by NSCC and/or Arcadis protocols, it would be acceptable to the Agency if both sides ofa page were printed on. The Agency encourages are own contractors to use both sides of the page, when permissible.
2. Another general comment, it may be advisable to alter the nomenclature for the monitoring wells. It would be helpful to include something like an "S", "T"; and "B" after the number
of the well to indicate what zone the well is monitoring, "S" for saprolite, "T" for transition
zone, and "B" for bedrO(,;k. This is a frequent comment made during a process called
Remedial System Evaluation (RSE) conducted for the Agency by the contractors, GeoTrans,
Inc. and Dynamac Corporation.
3. Page I, Section I.I Purpose and Objectives, bullets: The first three (3) Record of Decisions
(RODs) are listed, however, the ROD for Operable Unit (OU) 4 was omitted.
4. Page 2, Section 1.1 Purpose and Objectives, second full paragraph: Can a timeline be
developed for completing the OU I remedy evaluation? This will assist the Agency in
insuring that the necessary resources are available when it comes time to prepare either a
ROD Amendment or Explanation of Significant Difference (ESD) to document changes to
the OU! remedy, if that is the decision the Agency makes.
5. Page 4, 1.1.1 Site Conceptual model, second paragraph: This paragraph needs to be
e_xpanded to explain how the natural hydraulic gradients were altered and/or influenced by
the extraction of groundwater via the plume periphery extraction system (PPES). This
explanation needs to include supporting rationale. This supporting explanation will be
needed to help support altering the OU! remedy either via a ROD Amendment or ESD, if the
Agency decides to make this modification permanent to the 1988 ROD.
6. Page 5, Section 1.2.1 Operable Units One and Two, third paragraph: This paragraph states
that approximately 1,800 trees were planted on top of the Trench Area, a form of
phytoremediation. How does this action affect the premise of the OU2 ROD? The OU2
ROD relies on natural precipitation percolating through the Trench Area soils (natural
flushing) and moving the contaminants in the soil to groundwater where they are anticipated
to be removed by the OU! groundwater extraction system(s)? Has any modeling been
performed to see how the reforesting of the Trench Area will affect the time-frame for
cleaning up the soils in the Trench Area? This also goes back to the question, how clean is
clean for the soils in the Trench Area?
7. Page 6, Section 1.2.1.2 Outstanding Issues, first two bullets: It would be helpful if a timeline
for completing the work highlighted in these two bullets can be developed.
8. Page 6, Section· 1.2.1.2 Outstanding Issues: Conducting a capture zone analysis for the
groundwater extraction system should be added to thi~ list of outstanding issues.
9. Page 8, Section 1.2.2.2 Outstanding Issues: Conducting a capture zone analysis for the OU3
groundwater ex fraction system in accordance to the steps highlighted in EPA 's July 22, 2004
correspondence.
I 0. Page 8, Section 1.2.3.1 Status of Operable Unit Four, last sentence: Have these soil
investigation activities already been compl'eted? If so, these activities need to be
incorporated into this section.
11. Page 9, Section 1.2.3.2 Issues Encountered and Resolved, last paragraph and last sentence:
Refer to comment # l O above.
12. Page 15, Section 2 Field procedures, first sentence: This states that the groundwater samples
were collected in November/December 2006. Why did it take so long to submit this report?
13. Page 18, Section 2.2. l Operable Units One and Two, paragraph at top of page, second
sentence: Was this the procedure for all the extraction wells or just for extraction wells EX-
05 through EX-10 as these are active wells. I am assuming the extraction wells EX-01
through EX-04 were treated as monitoring wells and purged first.
14. Page 20, Section 3.1.2 Operable Unit Three, first paragraph, third sentence: This sentence
should read, " ... remediation system indicate that capture to.soaj~ "degree is occurring in OU3 ... ". This comment applies here and elsewhere in this report were the text implies
capture of the plume is occurring. Refer to comment# 9 above.
15. Page 22, Section 3.2.1.2 Trench Area Wells: Some discussion needs to be added about the
annual rate of precipitation for 2006 as well as for previous years as this precipitation is the
driving force for removing the contamination for the Trench Area and transporting the
contaminants to the groundwater and to the OU I groundwater extraction system. This
discussion may fit better in another Section of the report. This comment also relates back to
comment# 6.
16. Page 29, Section 3.3. l. l Plume Periphery and Trench Area Wells, third paragraph: Has a
decrease in pumping rates from any of the Trench Area Extraction wells ( or the two OU3
extraction wells) been observed that are not weather related (i.e., do any of the wells need to
be re-developed, etc.)?
17. Page 29, Section 3.3.1.1 Plume Periphery and Trench Area Wells, third paragraph: Do the
pumps in these extraction wells cycle on and off? If so, how frequently?
18. Page 31, Section 3.3.1.1.1 Evaluation of Pumping in the Plume Periphery and Trench Area
Wells, second to the last bullet: This bullet mentions shutting down extraction wells EX-06
and EX-07. A case may be made for shutting down EX-06 but EX-07 still is showing
elevated levels of 1,2-dichloroethane. Proposing shutting down extraction well EX-06
should not made until after the capture zone analysis for the Trench Area is completed. The
capture zone analysis should look at the impact on the hydrology of turning offEX-06 and
show the anticipated effects, if any.
19. Page 33, Section 3.3.1.2.l Evaluation ofOU3 Collection Trench And Extraction Wells, last
sentence: This sentence refers to Figure 3-6, however, no Figure 3-6 was found. Nor was Figure 3-6 listed in the index.
----------,--------------4-------------------
20. Page 48, Section 5. l Groundwater Quality and Trends, the paragraph in between tables: The
text in this paragraph implies that if the concentration of 1,2-dichloroethane is over 86,900
µg/1 (micrograms per liter) a dense non-aqueous phase liquid (DNAPL) may be present.
Using this rationale, it appears that 1,2-dichloroethane may exist as a DNAPL in the Trench
Area. The most recent groundwater samples collected from Extraction Wells EX-05 and
EX-08 both contain concentrations of 1,2-dichloroethane above 86,900 µg/1. ·
21. Page 51, Section 5.2 Mann-_Kendall Trend Analysis Results, fourth paragraph: This
paragraph refers to Table 5-1 and states that trend analyses were conducted_on 38 different
wells. Table 5-1 only includes 9 wells, the four extraction wells and five monitoring wells.
22. Page 53, Section 5.3 Future Actions: So that there is no misunderstanding, any and all
requests to modify pumping and/or sampling schemes need to occur under in a separate letter
so that the process of each requested change/modification can be tracked individually.
23. Table 3-3: The MCL for ethylbenzene is 700 and not 70. The MCL for arsenic is 10 and not
50.
24. Table 3-4 through Table 3-15: These tables compare the analytical results to the performance
standards specified in the appropriate ROD. It may make more sense to start using the most
stringent cleanup goal, either the Federal MCL or the State's 2L groundwater standards, in
future tables. The rationale for this change is eventually the groundwater performance
standards specified in the RODs will be revised to reflect the most stringent cleanup goal at
the time the RODs are revised. By incorporating the current, most stringent cleanup goal in ·
these tables now will give a more realistic comparison of current groundwater conditions to
the final end point (goal) which is to allow for unlimited use and unrestricted exposure.
25. Table 5-2: Interpretation of Mann-Kendall (MK) tests results, when the MK statistic is less
then zero (0) then trend is deemed to be _decreasing and when the MK statistic is greater then
zero (0) then trend is deemed to be increasing. A footnote needs to be included in this table
explaining the range ofNST (No Significant Trend) and the rationale for this range.
26. Figure 1-2: The distance between EX-05 and EX-09 is approximately 400 feet. Without a
capture zone analysis, it is not feasible to either support or dismiss the installation of another
extraction between these two existing extraction wells .. Prior to the Agency concurring with
the permanent shutdown of PPES, this type of analysis is necessary. As expressed in
comment# 9, this information will be needed as support in any future ROD Amendment or
ESD.
As stated above, this report does not need to be revised: However, responses need to be
prepared to address the comments above and the enclosed comments from NCDENR. The final
response to these comments will be added to this report as an addendum,
If you have any questions, please feel to call me at 404-562-8820.
Enclosure (1 ):
Sincerely,
t/.6,v/'~
Jon K. Bomholm
Remedial Project Manager
I. Comments on 2006 Site Monitoring Report from NCDENR (October 17, 2007)
cc: David Mattison, NCDENR
October 17, 2007
Mr. Jon Bornholm
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
_U.S. Environmental Protection Agency, Region 4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA ·30303
RE: 2006 Site Monitoring Report
National Starch and Chemical Company NPL Site
Salisbury, Rowan County, North Carolina
Dear Mr. Bornholm:
The Superfund Section of the North Carolina Department of Environment and Natural
Resources (NC DENR) has received and reviewed the 2006 Site Monitoring Report for
the National Starch and Chemical Company National Priority List (NPL) Site. The
Superfund Section offers th~ following attached comments.
The NC DENR Superfund Section appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919)
508-8466. .
Attachment
Sincerely,
David B. Mattison
Environmental Engineer
NC Superfund Section
Mr. Jon Bomholm
2006.Site·MonitoringReport----------------
National Starch and Chemical Company NPL Site
October 17, 2007
Page I
2006 Site Monitoring Report
National Starch and Chemical Company NPL Site
Section 1.3.2.2 RCRA Sampling
I. Please revise Section 1.3.2.2 to include a brief synopsis of Resource Conservation
· and Recovery Act (RCRA) sampling of the Site and the contaminants of concern
(COC).
Section 3.2.1.1 Plume Pcriphery"Wells
2. Please correct the table in Section 3.2. I. I that depicts the metals exceedances to
only include those detected concentrations of metals greater than the Performance
Standards (i.e., barium in extraction well EX-03 does not exceed the Performance
Standards). Please correct this oversight.
Section 3.2.1.2 Trench Area Wells
3. Please correct the table in Section 3.2.1.2 that depicts the volatile organic
compounds (VO<;:s) exceedances to only include those detected concentrations of
VOCs greater than the Performance Standards (i.e., xylene in extraction well EX-
05, 1,2-dichloropropane (1,2-DCP) in extraction well EX-07, acet_one in
extraction well EX-08, toluene in extraction well EX-I 0, toluene in monitoring
well NS-09, xylene in monitoring well NS-09, and vinyl chloride in monitoring
well NS~56 do not exceed the Performance Standards). Please correct these
oversights.
4. Please correct the table_ in Section 3.2. l .2 that depicts the VOCs exceedances to
indicate that xylene was detected in extraction well EX-09 at a concentration of
3,200 J micrograms per Liter (µg/L). Please co~ect this oversight. ·
5. Please correct the table in Section 3.2, l .2 that depicts the metals exceedances to
only include those detected concentrations of metals greater than the Performance
Standards (i.e., chromium in extraction well EX-05, manganese in extraction well
EX-06, nickel in extraction well EX-06, chromium in extraction well EX-07,
nickel iri extraction well EX-07, cadmium in extraction well EX-08, chromium in
extraction well EX-08, chromium in extraction well EX-09, chromium in
extraction well EX-I 0, nickel in extraction well EX-I 0, chromium in monitoring
well NS-09, nickel in monitoring well NS-09, cadmium in monitoring well NS-
56, and chromium in monitoring well NS-56 do not exceed the Performance
Standards). Please correct these oversights.
Mr. Jon Bomholm
__ 2006_Site Monitoring Report _____ _
. National Starch and Chemical Company NPL Site
October 17, 2007
Page 2
Section 3.2.2.1 OU3 Wells
6. Please correct the table in Section 3.2.2. I that depicts the VOCs exceedances to
only include those detected concentrations of VOCs greater than the Performance
Standards (i.e., chloroform in monitoring well NS-35, 1,2-DCP in monitoring
well NS-4 I, trichloroethene (TCE) in monitoring well NS-45, I ,2-DCP in
monitoring well NS-47, chloroform in monitoring well NS-47, tetrachloroethene
(PCE) in monitoring well NS-47, TCE in monitoring well NS-47, vinyl chloride
in monitoring well NS-47, chloroform in monitoring well NS-50, TCE in
monitoring well NS-52, PCE in monitoring well NS-53, and PCE in collection
trench CT-I do not exceed the Performance Standards. Please correct these
oversights.
Section 3.2.3.1 July 2006
7. Please correct the first sentence of Section 3.2.3.1 to reference Table 3-16.
Section 3.2.3.2 November 2006
8. ·Please correct the first sentence of Section 3.2.3.2 to reference Table 3-17.
· 9. Please correct the third sentence of the first bullet item of Section 3.2.3.2 to
indicate that bis (2-ethylhexyl) phthalate was detected in monitoring well NS-39.
10. · Please strike that last sentence of the first bullet item of Section 3.2.3.2.
Section 3.3.1.2.1 Evaluation of OU3 Collection Trench and Extraction \Veils
11. Section 3 .3 .1.2.1 reference Figure 3-6 .. However Figure 3.6 was inadvertently
omitted. Please correct this oversight. .
Section 4 Data Validation
12. Please revise Section 4 to include an evaluation of the significance of the general
laboratory conformance with particular emphasis on the significance of the
numerous instances of method detection limits exceeding regulatory thresholds
due to sample dilution.
Section 4.1.5.1 Plume Periphery Wells
13. Please correct the fourth bullet item of the first paragraph of Section 4.1.5.1 to
state "4 nitroiihenol, bis (2-chlorethyl) ether in EX-01, EX-04, and NS-32."
Mr. Jon Bomholm
------2006-SiteMonitoring·Report------------------------______ _
National Starch and Chemical Company NPL Site
October 17, 2007
Page 3
Section 4.1.5.2 Trench Area Wells
14. Please correct the eighth bullet item of the first paragraph of Section 4.1.5.2 to
state "4-nitrophenol in EX-05, EX-07, EXc0S, EX-09, EX-I 0, N£ 09, and NS-
56;"
15. Please correct the ninth bullet item of the first paragraph of Section_ 4.1.5.2 to
state "bis (2-chlorethyl) ether in EX-06, EX-07, EX-08, EX-09, NS-09, NS-10,
NS-11, and NS-15, aHd N£ 5€i; and"
Section 4.1.6 Operable Unit Three
16. Please review Section 4.1.6 for accuracy. A tabular format may present this
information in an easier form to understand.
Section 4.1.7 R_CRA Samples
17.. Please review Section 4.1.7 for accuracy. A tabular format may present this
information in an easier form to understand.
Section 5 Summary
18. Please revise Section 5 to include a writteri synopsis of the groundwater quality
• and trends observed at the Site. This synopsis should also evaluate the current
extraction and monitoring systems including their effectiveness, overall trends
noted, significance of trends, significance of dilution factors and method detection
-limits, improvements or system enhancements, etc.
Section 5.2 Mann-Kendall Trend Analysis Results
19. Please correct the sixth paragraph of Section 5.2 to include the upward trend for
1,2-DCP observed at Trench Area extraction well EX-08.
20. Please correct the seventh paragraph of Section 5.2 to include the upward trend
for PCE observed at Operable Unit 3 (OU3) monitoring well NS-36.
21. Please correct the seventh paragraph of Section 5.2 to include the upward trend
for 1, 1-dichloroethene (1,2-DCE) observed at OU3 monitoring well NS-54.
22. Please correct tl-ie sevent\1 paragraph of Section 5.2 to include the upward trend
for l',2-dichloroethane (1,2-DCA) observed at OU3 monitoring well NS-36.
Mr. Jon Bomholm
2006 Site Monit~ri11g_~ep"'ort'--'--------------"~N;--at7io-n~a.cl S;;-:"tarch and Chemical Company NPL Site
October 17, 2007
Page 4
23. Please correct the seventh paragraph of Section 5.2 to include the upward trend
for TCE observed at OU3 monitoring well NS-36.
24. Please correct the seventh paragraph of Section 5.2 to include the upward trend
for manganese observed at OU3 monitoring well NS-37.
Figure 3-1 Groundwater Elevation Contour Map, OU1/0U2 Saprolite Wells,
November 2006
25. Please revise Figure 3-1 such that the groundwater elevation for monitoring well
NS-8 and the groundwater elevation contour for 745 feet above mean sea level
(ft-ams!) are clearly visible.
Figure 3-2 Groundwater Elevation Contour Map, OU1/0U2 Transition Zone
Wells, November 2006
26. The groundwater elevations for extraction wells EX-05, EX-07, EX-08, and EX-
l O were i_nadvertently omitted from Figure' 3-2. Please correct this oversight.
27. Figure 3-2 indicates that the groundwater elevation at monitoring well NS-16 is
693.61 ft-ams!. However, Table 3-1 indicates that the groundwater elevation at
monitoring well NS-16 is 743.01 ft-ams!. Please clarify this discrepancy.
Figure 3-5 Groundwater Elevation Contour Map, OU3 Bedrock Wells,
November 2006
28. Figure 3-1 indicates that t_he groundwater elevation at monitoring well NS-54 is
745.89 ft-ams!. However, Table 3-1 indicates that the groundwater elevation at
monitoring well NS-5_4 is 754.89 ft-ams!. Please clarify this discrepancy.
4WD-SRSEB
Mr. David Mattison
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
SAM NUNN ATLANTA FEDERAL CENTER
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
September 25, 2007
North Carolina Department of Environment &
Natural Resources/Superfund Section
Suite 150
401 Oberlin Road
Raleigh, North Carolina 27605
SUBJ: Request to Review 2006 Site Moniioring Report for the National Starch & Chemical
Company Superfund Site, Salisbury, Rowan County, North Carolina
Dear Mr. Mattison:
The Agency received four copies of the above referenced document from, ARCADIS BBL,
National Starch & Chemical Company's consultant for the above referenced Site, on September
24, 2007. Enclosed for North Carolina Department of Environment and Natural Resources
(NCDENR) is a copy of this report for the State's review and Site file. The date of"2006 Site
Monitoring Report" is September 2007.
Please review this document. The Agency would appreciate receiving comments by
Thursday, October 18, 2007. If the State is unable to submit comments on this document by this
date, please advise the Agency as to when the State will be able to submit its comments.
If you have any questions, I can be reached at 404-562-8820.
Enclosure (I):
Sincerely,
Jon K. Bomholm
Remedial Project Manager
I. 2006 Site Monitoring Report (September 2007)