SF_F_NCD986178226_20170316_FRB_PASI(2)

1)US EPA 40 CFR Part 300, Hazard Ranking System, Final Rule, Federal Register Volume 55, No.
241 Part II, December 14, 1990.
2)Superfund Chemical Data Matrix, Revised March 2012.
3)Zinn, Harry, NCDENR, Division of Waste Management: Texfi Latitude and Longitude
Calculations per CERCLA, October 20, 2001.
4)Cumberland County Geographic Information Service (GIS) Data Viewer 2:http://www.co.cumberland.nc.us/is_technology/gis.aspx
5)NC Public Water Supply Section Water Supply Plan, Fayetteville, NC
http://www.ncwater.org/Water_Supply_Planning/Local_Water_Supply_Plan/report.php?pwsid=
03-26-010&year=2016
6)Snavely, Keith; Parker, Stuart, NCDEQ Superfund Section, verbal communications, February 16-
March 14, 2017.
7)Duncklee & Dunham, P.C., Cary, NC: “Remedial-Design Data Collection Work Plan for a Solar-Powered Remedial Strategy, Former Tex-fi Facility, 601 Hoffer Drive, Fayetteville, North Carolina, Site ID: NCD986178226”, prepared for City of Fayetteville Engineering and
Infrastructure Department, Fayetteville, Cumberland County, North Carolina, October 27, 2016.
Available for review at: http://edocs.deq.nc.gov/WasteManagement/Search.aspx?cr=1
8)City of Fayetteville NC Public Works Commission: Progress monitoring (Laboratory analytical) reports on water quality monitoring at the Clear Well, Cape Fear River and Effluent (various dates,
ending December 27, 2016).
S&ME, Inc. Raleigh, NC: Progress monitoring (Laboratory analytical) reports on water quality
monitoring at Clear Well Toe Drain and at monitoring wells MW24C and MW-27C, August 10 and October 16, 2015.
Available for review at: http://edocs.deq.nc.gov/WasteManagement/Search.aspx?cr=1
9)Hart & Hickman, Charlotte, NC: Letter report to NC DENR Re: Asbestos Survey (Demolition
Area), Former Texfi Facility, Fayetteville, North Carolina, H&H Job No. TEX-001, December 28, 2007.
10)Duncklee & Dunham Environmental Geologists and Engineers: “Evaluation of Risk to the Public
Works Commission Clearwell, 601 Hoffer Drive, Fayetteville, North Carolina”, Texfi BF Project
# 13017-09-26, August 16, 2012.
TEXFI INDUSTRIES, INC.
NCD 986 178 226
Fayetteville, Cumberland County
Preliminary Assessment References
NCDEQ, Superfund Section
March 2017
11)Smith, Chris, Fayetteville PWC, e-communications to Keith Snavely, NCDEQ, December 27,
2016 and February 27, 2017.
Snavely, Keith, NC Superfund Section, e-communication to Stuart Parker, NC Superfund Section, March 14, 2017.
12)US EPA Region 4, Emergency Response and Removal Branch: “Initial Pollution Report/RAT Notification Recommendation for No Further Planned Removal Activity”, Removal Site Evaluation, Texfi Industries (NCD0001075), Fayetteville, North Carolina, April 17, 2003.
13)A: “Drainage Areas of Selected Sites on Streams in North Carolina” US Geological Survey Open
File Report 83-211, 1983.
B: “Map of Mean Annual Runoff for the Northeastern, Southeastern and Mid-Atlantic United States, Water Years 1951-1980” US Geological Survey Water Resources Investigations Report
88-4094, 1988.
C: Parker, Stuart F, Hydrogeologist, NCDEQ, Superfund Section, Memorandum to File: Cape Fear River Mean Annual Flow at Fayetteville, NC, March 18, 2017.
14)Solutions Industrial and Environmental Services, Inc., Raleigh, NC: “Environmental Site
Assessment for Texfi Industries, Fayetteville, North Carolina, NONCD0001075”, August 23,
2004.
15)North Carolina Source Water Assessment Program SWAPInfo2.0 GIS Mapping Tool:
nc.maps.arcgis.com
16)US Fish and Wildlife Service, National Wetlands Inventory On-line Mapper: http://wetlandsfws.er.usgs.gov/.
REFERENCE 1
REFERENCE 2
REFERENCE 3
SITE NAME:CERCLIS #:
AKA:SSID:
ADDRESS:
CITY:STATE:ZIP CODE:
SITE REFERENCE POINT:
USGS QUAD MAP NAME:TOWNSHIP:-N/S RANGE:-E/W
SCALE: 1 : 24,000 MAP DATE:SECTION:-1/4 -1/4 -1/4
MAP DATUM 1927 x 1983 MERIDIAN:
COORDINATES FROM LOWER RIGHT (SOUTHEAST) CORNER OF 7.5' MAP (attach photocopy)
LONGITUDE:78 o 45 '0.00 "LATITUDE:35 o 0 '0.00 "
COORDINATES FROM LOWER RIGHT (SOUTHEAST) CORNER OF 2.5' GRID CELL:
LONGITUDE:78 o 50 '0.00 "LATITUDE:35 o 5 '0.00 "
CALCULATIONS: LATITUDE (7.5' QUADRANGLE MAP)
A) NUMBER OF RULER GRADUATIONS FROM LATITUDE GRID LINE TO SITE REF POINT:
SITE LATITUDE:35 o 5 '2.97 "
CALCULATIONS: LONGITUDE (7.5' QUADRANGLE MAP)
A) NUMBER OF RULER GRADUATIONS FROM RIGHT LONGITUDE LINE TO SITE REF POINT:
SITE LONGITUDE:78 o 52 '2.58 "
INVESTIGATOR:DATE:
o
NONCD 000 1075
28301
10/10/2001Harry Zinn
LATITUDE AND LONGITUDE CALCULATION WORKSHEET #2
LI USING ENGINEER'S SCALE (1/60)
371
9
Texfi Industries Inc.
(CHECK ONE BOX WITH AN "X")
n.a.
NE corner of Texfi Building
Vander
n.a.
-
1983
601 Hoffer Road
Fayetteville NC
Site Name:
USGS 7.5" Quadrangle:
78 o 45 '0.00 "35 o 0 '0.00 "
78 o 50 '0.00 "35 o 5 '0.00 "
78 o 52 '2.58 "35 o 5 '2.97 "
78.8333
78.8674 o
Texfi Industries Inc.
Vander
Longitude Latitude
o78.7500
COORDINATES FROM LOWER
RIGHT (SOUTHEAST) CORNER
OF 7.5' MAP
COORDINATES FROM LOWER
RIGHT (SOUTHEAST) CORNER
OF 2.5' GRID CELL
35.0842 o
o
35.0000 o
35.0833 o
SITE COORDINATES
REFERENCE 4
REFERENCE 5
Technical Support Document
Technical and Analytical Support for EPAs NPL
Date of Call: January 24, 2002
Time: 10:00 a.m. (EST)
Subject: Texfi Industries, Inc., site, Fayetteville, NC
Evaluation of Possible HRS Scoring Strategies
Participants:
 EPA Headquarters: Barbara Vandermer, Region 6 NPL Coordinator
 EPA Region 4: Cindy Gurley, NPL Coordinator

 

 Marasco Newton Group: Alison Wolfe, Region 4 NPL Coordinator
Beth Leverich
Bill Michaud
Cindy Gurley, Region 4 NPL Coordinator, requested technical assistance support to evaluate
potential HRS scoring strategies for the Texfi Industries, Inc., site. Marasco Newton Group
conducted a preliminary review of the December 2001 Draft Pre-CERCLIS Site Screening
memorandum, three drawings showing construction of the clear well at the P.O. Hoffer Treatment
facility, and the CERCLIS Site Discovery Form for the Texfi Industries, Inc., site. A conference call
was convened between EPA Region 4, North Carolina Department of Environment and Natural
Resources (NCDENR), EPA HQ, and Marasco Newton Group on January 24, 2002 to discuss the
site. This document presents site background, a summary of the conference call, and Marasco
Newton Groups analysis of potential scoring strategies.
Background and General Site Features
The Texfi Industries Inc., (Texfi) site is located in Fayetteville, Cumberland County, North Carolina
and encompasses approximately 95.6 acres. Texfi operated a textile dyeing and finishing operation
from 1968 until 1999. The facility filed for bankruptcy in February 2000. In 1995, North Carolina
Division of Water Quality discovered a plume of contaminated ground water during the cleanup of a
fuel oil spill from an above ground storage tank on the Texfi property. In addition to contaminants
associated with fuel, chlorinated solvents were detected in ground water beneath the Texfi facility.
During subsequent investigations, it was determined that the chlorinated solvent plume was
migrating toward a clear well associated with the City of Fayettevilles main water treatment plant
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Texfi Industries Inc.
Page 2
(the P.O. Hoffer Water Treatment facility). A slurry wall and ground water extraction system were
constructed between the Texfi site and the clear well at the water treatment plant to prevent
migration of hazardous substances to the clear well. Contaminant levels in ground water around the
clear well have decreased dramatically since the installation of this system. Water from the clear
well is monitored weekly; no contamination associated with the ground water plume has been
detected. The ground water extraction system and monitoring program are considered components
of an interim action and funding for these activities is due to run out within 3 years. The site was
brought to the attention of EPA Region 4 due to concerns about the possibility that the ground water
contamination will reach the clear well after the system ceases to operate.
The clear well is an in-ground concrete tank used to store finished water from the treatment plant.
The clear well has a capacity of approximately 12 million gallons. The clear well was constructed in
two stages. The first part of the clear well (2 million gallons) was constructed in 1969. The second
part was constructed in 1976. The clear well is a covered, non-pressurized tank. The foundation,
walls, and roof are not monolithic but, rather, are constructed with expansion joints. Although
information regarding the original construction of the joints was not available for review, expansion
joints in clear wells are typically constructed using waterstops cast into the concrete below grade and
are usually sealed. Record drawings provided for review indicate that the expansion joints in the
floor, wall, and roof were repaired in 1996 using a polyurethane sealant and bituminous coating. The
record drawings also indicate that the exterior of the clear well walls was coated in 1996, presumably
for waterproofing. The material used to coat the walls was not described on the drawings.
The water level in the clear well is maintained at an elevation of 99.5 feet. The top of the floor of the
clear well is at an elevation of 84.5 feet. Ground water monitoring in the vicinity of the clear well
has documented ground water elevations as high as 86.7 feet. The clear well is occasionally drained,
at which time the ground water elevation outside the clear well could exceed the elevation of the
water within the clear well. The State has received verbal accounts that significant ground water
inflow into the clear well has occurred in the past when it was drained. According to record
drawings, a toe drain was installed around the clear well in 1996. The CERCLIS site screening
report indicates that the toe drain has lowered the ground water elevation around the clear well to
below the top of the floor.
A drainage ditch is located between the Texfi facility and the clear well. According to NCDENR,
the ditch is not perennial. Based on maps provided with the material for review, the ditch collects
runoff from the Texfi property and drains to the Cape Fear River. The intake for the P.O. Hoffer
water treatment plant is located in the Cape Fear River, approximately 400 feet downstream of the
point where the ditch enters the River. PCE (up to 11,400 g/l) and TCE (up to 2,800 g/l) have
been detected in surface water in the drainage ditch. No hazardous substances have been detected in
surface water or sediment samples collected from the Cape Fear River. The Cape Fear River at the
intake has an estimated flow of 5,000 cfs.

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Page 3
Based on information available at the Fayetteville Public Water Commission (FPWC) Web site
(www.faypwc.com), the current water system is supplied by two surface water treatment plants, the
P.O. Hoffer plant and the Glenville Lake plant, with total capacity of 50 million gallons per day
(MGD). FPWC estimates that the Glenville Lake plant treated an average of approximately 8.6
MGD in 1998. The average daily demand in 1998 was 25.2 MGD; therefore, it is estimated that the
P.O. Hoffer plant treated an average of 16.6 MGD in 1998. The P.O. Hoffer plant draws all of its
supply from the Cape Fear River. The Glenville Lake plant draws water from both Glenville Lake
and the Cape Fear River. According to NCDENR, the location of the Glenville Lake intake is next
to the P.O. Hoffer intake in the Cape Fear River. According to the FPWC Web site, the water
system serves a population of 159,000.

Summary of Conference Call Sources
No information regarding potential sources at the site was provided in the review materials. Marasco
Newton Group inquired as to the type, location, and size of these sources, if any had been identified.
The State replied that a former drum storage area and two main areas of contaminated soil had been
identified. However, no manifests or other records indicating the quantity of waste handled at the
facility were available. Marasco Newton Group asked about the lagoon identified on a site map.
The State replied that this lagoon mainly handled waste water containing petroleum-related products
and did not consider the lagoon to be a source of chlorinated solvents. The State said that the Texfi
facility used chlorinated solvents primarily for maintenance of facility equipment.

Targets
Marasco Newton Group inquired as to whether there were any private or public drinking water wells
located within 4 miles of the site. The State replied that no drinking water wells had been identified.

Marasco Newton Group questioned whether the drainage ditch was perennial, and if so, were there
any surface water migration pathway targets associated with it (sensitive environments, fisheries).
As noted above, the State replied that the ditch was not perennial.

Marasco Newton Group noted a discrepancy between the Pre-CERCLIS Site Screening
memorandum and the FPWC Web site regarding the number of people supplied by the drinking
water system. The State explained that the Fayetteville Public Water Commission had supplied an
array of numbers of residents served and had not yet confirmed the actual number of users. Marasco
Newton Group asked whether there were any other large metropolitan areas downstream of
Fayetteville that might use the Cape Fear River as a drinking water supply. The State indicated that
no other large metropolitan areas were present within the TDL. Marasco Newton Group asked about

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Texfi Industries Inc.
Page 4 the average annual flow rate for the P.O. Hoffer plant. The State answered that the flow rate is well
over 10 cfs.

Pathway Considerations
Marasco Newton Group summarized a preliminary evaluation of scoring the site using the ground
water to surface water component of the surface water pathway, concluding that a large hazardous
waste quantity (HWQ) factor value would be needed. The State explained that it had explored that
option and, based on the States familiarity with the sources at the site, did not think that a high
enough HWQ factor value could be documented to result is an HRS score of 28.5. Rather, the State
felt that the only way to score the site was by the ground water migration pathway using the clear
well as the source of withdrawal.

Marasco Newton Group asked whether there was any documentation to support the argument that
ground water could infiltrate into the clear well tank. As noted above, the State replied that it had
received verbal accounts of significant ground water infiltration to the clear well when the clear well
is drained for maintenance.

Potential Comments
The Region does not expect to receive comments in opposition to the listing of the Texfi site on the
NPL. The State suggested that if the potential threat to the water supply were communicated, there
would be great local political support for listing. It was noted, however, that proposed listing could
invite comments as a matter of national interest and could set a precedent regarding EPAs broad
interpretation of the HRS.

Evaluation of Possible HRS Scoring Strategies

Based on the information available for review, Marasco Newton Group evaluated HRS scoring
strategies for the ground water and surface water migration pathways. It appeared unlikely, based on
this information, that the soil exposure or air migration pathways would contribute significantly to an
HRS score for this site. The information provided did not describe an observed release to air, nor
any area of soil documented to be an area of observed contamination. In addition, there was no
mention of onsite workers, or the proximity of residences or schools.

A summary of the evaluation of the ground water and surface water migration pathways is presented
below.

Ground Water Migration Pathway: According to the Region and the State, there are no known
public or private drinking water wells within 4 miles of sources at the site. The public water system
is large enough to meet water demand, and it is unlikely that there is a significant number of private
wells in the area. If private wells do exist, there is no indication that they have been contaminated.

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Texfi Industries Inc.
Page 5 Given this, the Region requested that Marasco Newton Group explore the possibility suggested by
NCDENR of evaluating the clear well as a drinking water well or as an aquifer that serves as a
drinking water supply. Following is a discussion of how the site would score should this scenario be
acceptable to Headquarters.

Eligibility of clear well for scoring as an aquifer or drinking water well

There are two ways to view the ground water migration pathway scenario: that the clear well is (1)
analogous to an aquifer or (2) analogous to a drinking water well.

Evaluating the clear well as an aquifer
The term aquifer is not defined in HRS Section 1.1. However, the HRS Guidance Manual
defines an aquifer as: one or more strata of rock or sediment that is saturated and sufficiently
permeable to yield economically significant quantities of water to wells or springs. An
aquifer includes any geologic material that is currently used or could be used as a source of
water within the TDL. Because the clear well does not consist of geologic material, it
would be difficult to defend the analogy of the clear well as an aquifer based on existing
guidance.

Evaluating the clear well as a ground water drinking well
This scenario requires that the clear well be considered a point of withdrawal from the
aquifer. In this case, the clear well would be analogous to the inside of a drinking water well
casing. The walls and foundation of the clear well could either be considered analogous to
the well screen or they could be considered a separate aquifer. In this latter case, the clear
well would be analogous to an open-cased well in a low permeability aquifer that is
surrounded by a higher permeability aquifer.

Treating the walls and foundation of the clear well as analogous to a well screen could be defended
by drawing an analogy between slots in a well screen and the expansion joints in the walls and
foundation. The State has established preliminary documentation that ground water infiltrates the
clear well when the clear well is drained. When refilled, the ground water would commingle with
treated drinking water and would effectively be withdrawn from the aquifer and used as drinking
water. The primary argument against this analogy is that, unlike well screens, the walls and
foundation of the clear well are designed and maintained to keep ground water out and, during
normal operations, hydraulic head within the clear well will ensure that ground water is not
withdrawn from the surrounding aquifer.

Treating the walls and foundation of the clear well as an aquifer (and the interior of the clear well as
analogous to an open casing) could be defended by drawing an analogy between the concrete
structures with expansion joints and bedrock with fractures. Again, ground water would be

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Page 6
effectively withdrawn as a result of infiltration during maintenance. An argument against this
analogy is that whereas bedrock is a natural geologic feature, the concrete walls and foundation are
man-made. The concrete structure also differs from the HRSGM definition of an aquifer in that it
could not be considered capable of yielding economically significant quantities of water. The
argument that ground water would not be withdrawn under normal operating conditions would
also apply.

If the site were scored using either of these analogies, the development of a scoring strategy would
need to consider the long-term effectiveness of recent repairs to the clear well in preventing future
ground water infiltration. Documentation that the clear well walls and/or foundation could be
breached by ground water would need to be included in the HRS package.

Likelihood of Release
The information provided was insufficient for us to evaluate whether an observed release to ground
water can be established (i.e., primary analytical data and comparisons to background levels were not
included). However, for the purposes of this technical assistance, Marasco Newton Group has
assumed that an observed release can be established to ground water attributable to sources at the
Texfi facility. If this assumption is correct, a value of 550 would be assigned for Likelihood of
Release.

Waste Characteristics
According to HRS Section 3.2, to determine a Waste Characteristics factor value for the ground
water migration pathway, toxicity and mobility are evaluated for each hazardous substance available
to the pathway and then combined with the HWQ factor value for sources at the site. The following
hazardous substances have reportedly been documented in the ground water beneath the Texfi
facility.

Toxicity

Mobility

Toxicity x
Mobility
PCE 100 1 100 TCE 10 1 10 cis-1,2-DCE 100 1 100 1,1,1-TCA 1 1 1 vinyl chloride 10000 1 10000

No information was provided regarding hazardous waste quantity.

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Page 7
Targets
According to HRS Section 3.3.1, in evaluating the nearest well factor, include both the drinking
water wells drawing from the aquifer being evaluated and those drawing from overlying aquifers. It
appears that the clear well is located within the contaminated aquifer and, assuming that the
eligibility of the clear well for scoring could be established, it would, therefore, be eligible for
evaluation as a target. Since there are no drinking water wells within the TDL that are subject to
actual contamination, the HRS directs the package preparer to determine the shortest distance to any
drinking water well, as measured from any source at the site with a ground water containment value
greater than zero and assign a value from HRS Table 3-11 based on that distance. Based on the
information provided, it appears that the clear well is located within a few hundred feet of the Texfi
plant. Assuming that the sources are located near the plant and the distance to the clear well is 0 to 
mile (< 1320 feet), the value assigned for nearest well would be 20.

The clear well is not subject to actual contamination; therefore, the population served by the clear
well would be evaluated based on potential contamination. According to the Pre-CERCLIS Site
Screening memorandum, the clear well supplies drinking water to approximately 65,000 people,
although this number could be greater than 100,000 according to FPWC information. According to
HRS Section 3.3.2.4, since the clear well would be subject to potential contamination, the drinking
water population would be determined from HRS Table 3-12, then divided by 10. No information
has been provided regarding the underlying geology of the area; therefore, for the purposes of this
technical assistance, Marasco Newton Group has assumed that the aquifer is other than karst.
According to HRS Table 3-12, the distance weighted population value for a drinking water
population of 65,000, whose well is located within 0 to  miles, is 52,137. Therefore, the population
factor value would be 5,214.

No information was provided regarding resources within the TDL.

Overall pathway score for the ground water migration pathway
If the Likelihood of Release factor value equals 550, and the Targets factor value equals 5,234 (20 +
5,214), then to obtain an HRS site score of 28.5, the Waste Characteristics factor value from HRS
Table 2-7 would need to be at least 2. With a toxicity/mobility value of 10,000 for vinyl chloride,
the Waste Characteristics factor value would be at least 10, as long as Hazardous Waste Quantity is
greater than zero, resulting in a raw pathway score of:

(550 x 10 x 5,234) / 82,500 = 348.93

Should this scoring strategy be accepted by EPA HQ, the HRS site score would be 50.00, based on
the maximum pathway score of 100 for the ground water migration pathway.

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Page 8
Surface Water Migration Pathway, Overland Flow/Flood Component: Based on indications of
contamination in the drainage ditch located between the Texfi facility and the clear well, it is
possible that an observed release to surface water could be established. According to the State, the
drainage ditch is not a perennial surface water body. However, if the ditch water was entering the
Cape Fear River at the time that contamination was detected, depending on data quality, it is possible
that an observed release by direct observation could be established.

As suggested in the Pre-CERCLIS screening report, however, regardless of the ability to document
an observed release, it would be difficult to score this component of the surface water pathway due to
the lack of documentation of actual contamination at the surface water intake and the high dilution
weight that would apply to the Cape Fear River. According to HRS Table 4-13, the dilution weight
for the Cape Fear River (5,000 cfs) would be 0.001.

The population served by intakes within the Cape Fear River within the TDL was approximated as
65,000 in the information available for review. Based on information provided on the FPWC Web
site, the population associated with the Fayetteville system served by intakes from the Cape Fear
River could be as high as 159,000. Based on information provided by the State, no other significant
population centers exist along the River within the TDL.

A drinking water population of 159,000 would yield a potential contamination population factor
value of 16. Due to the lack of actual targets and the high dilution weight, the nearest intake factor
value would be 0. This would yield a targets factor value of at most 21, assuming that HRS eligible
resources could be documented. Depending on the HWQ factor value, the drinking water threat
would contribute less than 10 points to the overland flow/flood component score.

From the information provided and discussions with the Region and State, the drainage ditch is not
perennial and, therefore, could not be used to evaluate food chain or environmental targets. The
dilution weight and the lack of actual contamination in the Cape Fear River limit the possible
contribution of targets associated with the River to an HRS score. The human food chain and
environmental threats would make negligible contributions to an HRS score for this component of
the surface water pathway across any reasonable range of assumed targets along the River within the
TDL.

Therefore, it appears unlikely that the overland flow/flood component of the surface water pathway
would contribute significantly to an HRS score for this site.

Surface Water Migration Pathway, Ground Water to Surface Water Component: The ground
water to surface water migration component could be used to evaluate surface water threats from the
migration of hazardous substances from a source at the site to surface water via ground water.
Depending on whether the clear well could be considered an HRS-eligible surface water body, this

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Texfi Industries Inc.
Page 9 component could be scored by evaluating the Cape Fear River and the clear well as separate surface
water bodies.

This approach would be analogous to evaluating ground water breakthrough to a river that branched
downstream of the Texfi facility. If appropriate, the intake to the P.O. Hoffer plant could be
considered analogous to a branch off of the Cape Fear River. Hazardous substances could migrate
from the ground water to the drainage ditch and into the clear well via the Cape Fear River intake.
Alternatively, if the clear well were considered an eligible surface water body, hazardous substances
could migrate directly from the ground water to the clear well. The contribution of the former
migration path (via the River) to an HRS score would be subject to similar limitations discussed
above for the overland flow/flood component. The possible contribution of the latter (direct
migration to the clear well) is evaluated below.

Eligibility of clear well for scoring as a surface water body
HRS Section 4.0.2 indicates that eligible surface water bodies include ... natural and man-made
lakes (including impoundments) that lie along rivers... The clear well is a man-made impoundment
that lies alongside the Cape Fear River. The clear well receives water from the River, but unlike,
for example, a reservoir created by damming a river, the clear well is hydraulically disconnected
from the River by the water treatment plant.

An alternative definition of eligible surface water bodies us isolated, but perennial, lakes, ponds,
and wetlands. The clear well is isolated from the River and could be considered perennial in
that water must be present in the clear well at all times to maintain the Fayetteville water supply
(note that during maintenance, only part of the clear well is drained). Given these interpretations, it
seems that the definition of the clear well as an eligible surface water body could depend on whether
the qualifiers that attach to lakes that lie along rivers (i.e., they include man-made
impoundments) would also attach to isolated lakes.

Criteria for evaluating the ground water to surface water component
In addition to the criteria outlined in HRS section 4.0.2, the clear well would also need to meet the
requirements of HRS section 4.2.1.1, which further defines surface waters that are eligible for
scoring using the ground water to surface water component of the surface water migration pathway.
The criteria and an evaluation of the clear well relative to the criteria is presented below:

 A portion of the surface water is within 1 mile of one of the sources at the site having a
containment value greater than zero. Based on discussion with the Region and the State,
it appears that this criterion would be met.

 No aquifer discontinuity is established between the source and the portion of the
surface water within 1 mile of the source. HRS section 4.2.1.1 by reference to HRS

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Page 10
section 3.0.1.2.2 defines an aquifer discontinuity as a geologic, topographic, or other
structure or feature that creates a continuous boundary to ground water flow within 1
mile of the source. The walls and foundation of the clear well could possibly be viewed as
an aquifer discontinuity in that they create a continuous barrier between the aquifer and the
water contained in the clear well. However, they do not entirely transect the aquifer within 1
mile of the source; therefore, it could be argued that they be treated as part of the surface
water body rather than a structure within the aquifer. Precedence associated with scoring a
lined surface water reservoir could shed light on this interpretation. Regardless, it is
recommended that, if this component were scored, evidence that the walls and foundation do
not entirely prevent ground water infiltration be included in the HRS package.

 The top of the uppermost aquifer is at or above the bottom of the surface water.
Although it appears that this condition is met, a potential argument could be made that the
toe drain has lowered the water table level to below the elevation of the clear well floor. In
response, it could be argued that the toe drain is not a permanent structure and could fail
either over time (i.e., due to siltation) or periodically during storm events or from seasonal
variations in the ground water table.
Likelihood of Release
As discussed above, the information provided was insufficient for us to evaluate whether an
observed release to ground water can be established. For the purposes of this technical assistance,
Marasco Newton Group has assumed that an observed release can be established to ground water
within 1 mile of a source. Therefore, a value of 550 would be assigned for Likelihood of Release.
Waste Characteristics
According to HRS Section 4.2.2.2, to determine a Waste Characteristics factor value for the ground
water to surface water migration pathway, toxicity, mobility, and persistence are evaluated for each
hazardous substance available to migrate from the sources at the site to the uppermost aquifer. The
following hazardous substances have reportedly been documented in ground water in the uppermost
aquifer below the Texfi facility.

Toxicity

Mobility

Persistence (lake)

Tox. x Mob. x
Pers.
PCE 100 1 1 100 TCE 10 1 1 10 cis-1,2-DCE 100 1 1 100 1,1,1-TCA 1 1 1 1

Technical Support Document, 1/31/02
Texfi Industries Inc.
Page 11
vinyl chloride 10000 1 .07 700

No information was provided regarding hazardous waste quantity.

Targets
No Human Food Chain or Environmental threat targets can be associated with the clear well.
Therefore, only the drinking water threat could be scored for the ground water to surface water
migration component.

If the clear well were considered an HRS eligible surface water body, the effluent channel to the
distribution system lift pumps would be considered the drinking water intake.

According to HRS Section 4.2.2.3.1, to evaluate the nearest intake as a potential target, information
regarding the flow through a surface water body is needed. According to the information provided
and the FPWC Web site, average annual flow through the clear well would be on the order of 25
MGD or 39 cfs.

According to HRS Table 4-13, the flow through the clear well would be equivalent to that of a
small to moderate stream and would be assigned a value of 0.1 as a dilution weight. According to
HRS Section 4.2.2.3.1, this dilution weight would be multiplied by a value from HRS Table 4-27,
dependent upon Θ. In order to determine Θ, the distances from the sources on the Texfi property to
the clear well and the orientation of the clear well relative to the sources would need to be
determined. Based on information provided, it is reasonable to assume that Θ ranges somewhere
between 14 and 126, corresponding to a range of dilution weight adjustments from 0.05 to 0.3, or
adjusted dilution weights of 0.005 to 0.03. According to HRS section 4.2.2.3.1, this range of
adjusted dilution weights would result in a nearest intake factor value, based on potential
contamination, of 0 or 1.

According to HRS Section 4.2.2.3.2, since the intake would be subject to potential contamination,
the drinking water population would be calculated using Table 4-14, multiplied by the adjustments
value from Table 4-27, and divided by 10.

Using this approach (direct migration to the clear well), only that population served by the P.O.
Hoffer plant would be subject to potential contamination. The FPWC Web site indicates that the
P.O. Hoffer plant could account for as much as 66 percent of the average annual water supply. Using
the FPWC figure (total population = 159,000), this would result in a population of just over 100,000
apportioned to the intake from the clear well, or a population factor value as high as 490.

Technical Support Document, 1/31/02
Texfi Industries Inc.
Page 12 No information was provided regarding potential and non-drinking water uses associated with the
water supplied by the P.O. Hoffer plant; however, it is reasonable to assume that the water is used for
one of the purposes outlined in HRS section 4.1.2.3.3. Therefore, for this evaluation, we have
assumed a resources factor value of 5.

To obtain a score of 28.5, assuming an upper-bound drinking water targets score of 496, the Waste
Characteristics factor value would need to be greater than or equal to 18, according to Table 2-7.
Based upon the toxicity/mobility/persistence values assigned for vinyl chloride (700), the Hazardous
Waste Quantity value would need to be at least 10,000.

Based on the information available for the review, it appears that sources in addition to the areas if
contaminated soil would need to be identified for the site to score above 28.5 based on the ground
water to surface water component alone.

Conclusions

In summary, it appears that the possibility that an HRS score of 28.5 or greater could be obtained for
the Texfi site rests initially on the threshold policy decision regarding whether the clear well is either
an eligible ground water target well or an eligible surface water body. These threshold policy issues
and issues associated with scoring the ground water and surface water migration pathways are
summarized below.

Ground water migration pathway
With regard to the interpretation of the clear well as a ground water well, it appears that the most
promising approach would be to draw an analogy between the walls and foundation of the clear well
to the screen of a drinking water well. The main argument against this interpretation could be that
although the clear well may withdraw ground water from the surrounding aquifer and, as such,
function as a ground water well, it was not designed for this purpose and withdraws far less volume
than would a ground water well. It may be difficult to argue that the limited ground water
withdrawal that happens via the clear well was envisioned in the structure of the targets factor
category of the HRS.

If EPA determined that the clear well could be considered a ground water target well, the following
additional information would be required:

 Documentation that ground water can infiltrate the clear well under certain conditions;
 Information characterizing at least one source with a source HWQ value greater than zero;
 Documentation of an observed release to ground water;
 Location of source(s) relative to the clear well; and
 Documentation of the population that can be apportioned to the P.O. Hoffer plant.
Technical Support Document, 1/31/02
Texfi Industries Inc.
Page 13
Ground water to surface water component of surface water migration pathway
With regard to the interpretation of the clear well as a surface water body, it appears that the
eligibility of the clear well would hinge on interpretation of the first two bullets under the definition
of a lake in HRS section 4.0.2. The clear well has the hydraulic characteristics of a surface water
body (i.e., it is open to atmospheric pressure) and represents a more vulnerable resource than other
surface water bodies that would clearly be HRS-eligible (e.g., a lake used as a drinking water supply
subject to the treatment requirements of the Safe Drinking Water Act prior to distribution).
If EPA determined that the clear well could be considered a ground water target well, the following
additional information would be required:
 Interpretation and/or identification of precedence for evaluating the concrete walls and
foundation of the clear well relative to the aquifer discontinuity criterion;
 Documentation that ground water can infiltrate the clear well under certain conditions;
 Identification of sources in addition to the contaminated soil sources;
 Documentation of an observed release to ground water;
 Location of source(s) relative to the clear well (distance and orientation); and
 Documentation of the population that can be apportioned to the P.O. Hoffer plant.
Note that in addition to the policy issues, the critical factors and minimum values required to achieve
an HRS score of 28.5 would be as follows:
 The combined source HWQ value would need to be 10,000 or greater.
 Assuming that the clear well is skewed relative to the line defining the shortest distance
between it and the sources at the site, the sources would need to be within 640 feet of the
clear well to achieve a Θ of greater than 54.
 The population apportioned to the plant would need to be 100,000 or greater.
Technical Support Document
Technical and Analytical Support for EPA=s NPL
Date: March 1, 2002

To: Robert Myers, Task Order Manager, USEPA Headquarters
Barbara Vandermer, Region 4 NPL Coordinator, USEPA Headquarters
Cindy Gurley, NPL Coordinator, USEPA Region 4

From: Meg Keenan, Task Order Manager, Marasco Newton Group
Beth Leverich, Technical Assistance Reviewer, Marasco Newton Group
Bill Michaud, Senior Technical Reviewer, Marasco Newton Group

Subject: Texfi Industries, Inc., site, Fayetteville, NC
Evaluation of Possible HRS Scoring Strategies after Review of PWC video

Cindy Gurley, Region 4 NPL Coordinator, requested technical assistance support to evaluate
potential HRS scoring strategies for the Texfi Industries, Inc., site. Marasco Newton Group
conducted a preliminary review of the December 2001 Draft Pre-CERCLIS Site Screening
memorandum, three drawings showing construction of the clear well at the P.O. Hoffer Treatment
facility, and the CERCLIS Site Discovery Form for the Texfi Industries, Inc., site. The results of this
preliminary review were discussed with the Region on January 24, 2002, and summarized in the
technical support document dated January 31, 2002.

Subsequently, Mr. Ike Copeland from the Fayetteville PWC submitted a video and color photographs
showing the Texfi property and the clear well. When reviewing the tape, Marasco Newton Group
noticed a few site features that were not identified in the original files for review that could be
relevant to a potential scoring strategy for the site. These features and their implications for the
evaluation of the potential scoring strategies are described below.

∃ It appears that some large tanks and possibly drums are located on the Texfi property.
In the original files, we noted the presence of a lagoon on the property. These observations
have raised the following additional questions:

% How many drums and/or tanks are located on the Texfi property?
% What are the dimensions of the lagoon (area or volume)?
% Is any information available regarding the material contained in the tanks, drums, or
lagoon on the Texfi property?
% Given the operations that were conducted at Texfi, what hazardous substances may
reasonably be assumed to be present in the tanks, drums, and lagoon?

For the surface water migration pathway components, the evaluation of additional
sources at the site could potentially increase the value assigned for hazardous waste

Technical Support Document, 2/28/02
Texfi Industries Inc.
Page 2 quantity. According to HRS Table 2-5, the divisor for Tier C (Volume) of tanks and
containers, is only 2.5 in contrast to the Tier D (Area) divisor for contaminated soil
(34,000). Based on tanks and containers as a source, a volume of just greater than
25,000 cubic yards (5,049351 gallons) is required to assign a Hazardous Waste
Quantity of 10,000. Similarly, the Tier D divisor for area of a surface impoundment
(or lagoon) is 13. Therefore, to obtain a Hazardous Waste Quantity Factor Value of
10, 000, the area of the lagoon would need to be just greater than 13,000 ft2. Based
on the scale of the figure included with the site information, it appears that the lagoon
is approximately 100 ft wide, and would therefore need to be at least 130 ft long to be
assigned a Hazardous Waste Quantity of 10,000.

Similarly, the consideration of other hazardous substances, besides chlorinated solvents, if
appropriate, could result in higher values for the other factors in the waste characteristics
factor category and could increase the category value. Marasco Newton Group recommends
that all of the hazardous substances known or suspected to be in any of the sources at the
Texfi site (based on knowledge of Texfi operations) be evaluated to determine the scoring
potential.

∃ There appears to be a wetland area west of the clear well.

The video depicted a full fast-moving ditch. It was unclear from the video whether
the ditch and associated wetlands are perennial and whether they are hydraulically
connected to the Cape Fear River. Nonetheless, in an effort to provide a thorough
analysis, Marasco Newton Group assumed that this ditch/wetland would be HRS-
eligible and part of the Cape Fear River watershed and explored how establishing an
observed release to the ditch/wetland would affect the overland/flood component of
the surface water migration pathway.

If Level II wetlands can be established, the HWQ factor value will default to 100 (or higher if
other sources are identified at the site) and the assigned Waste Characteristics factor would
be 6 for the Drinking Water Threat and 18 for the other threats.
A drinking water population of 159,000 (based on a high estimate from the Fayetteville PWC
Web site) would yield a potential contamination population factor value of 16, based on a
Cape Fear River dilution weight of 0.001. If an observed release to surface water and the
presence of Level II targets can be established, then the drinking water threat could be scored
as follows:

(550 X 6 X 16)/82,500 = 0.64.

Technical Support Document, 2/28/02
Texfi Industries Inc.
Page 3 If an observed release (of a hazardous substance with a bioaccumulation potential factor
value of 500 or greater) to surface water could be established in the perennial drainage ditch
or wetlands and there is a fishery within the 15 mile target distance limit, then 20 would be
assigned for the Food Chain Individual and the Human Food Chain Threat would score:

(550 X 18 X 20)/82,500 = 2.4.
If the Region could document 0.1 mile of HRS-eligible wetland frontage within the area of
Level II concentrations, then the Sensitive Environments Targets value would be at least 25
for the Environmental Threat, yielding a score of:

(550 X 18 X 25)/ 82,500 = 3.

Therefore, the overland/flood component of the surface water pathway score would be less
than 10. Based on the potential targets above (16 for Drinking Water Threat, 20 for Human
Food Chain Threat, and 25 for the Environmental Threat), a Waste Characteristics factor
value of at least 100 for the Drinking Water Threat and at least 180 for the other threats
would be needed to score above 28.5 on the overland/flood component of the surface water
migration pathway. This could potentially be achieved by evaluating the characteristics of
other hazardous substances found in sources at the site and evaluating additional sources to
generate a greater HWQ (see above).

∃ There appears to be a second clear well at the PWC facility. This observation has raised
the following additional questions:

% Is the base of the second clear well below the ground water table, such that it
is a surface water body subject to evaluation under the ground water to
surface water component of the surface water migration pathway?
% Are the two clear wells hydraulically connected, such that, if they were
determined to be HRS-eligible, they would be part of the same Αwatershed?≅
% What is the proximity and orientation of the second clear well to the plume?
% What is the capacity and average daily flow of the second clear well?

The presence of another clear well could impact angle theta and the population used
to evaluate targets. Angle theta will depend upon the proximity and orientation of the
clear wells relative to the source(s) at the site.

Technical Support Document
Technical and Analytical Support for EPA=s NPL
Date of Call: April 12, 2002
Time: 9:30 a.m. (EST)
Subject: Texfi Industries, Inc., site, Fayetteville, NC
Evaluation of Possible HRS Scoring Strategies
Participants:
∃ EPA Headquarters: Barbara Vandermer, Region 4 NPL Coordinator
Bob Myers, Task Order Manager
∃EPA Region 4: Cindy Gurley, NPL Coordinator
Πηιλ ςορσατζ, Σεχτιον Χηιεφ
∃ΝΧ∆ΕΝΡ:
Ηαρρψ Ζινν, Συπερφυνδ Σεχτιον
∃ Marasco Newton Group: Alison Wolfe, Region 4 NPL Coordinator
Meg Keenan, Task Order Manager
Bill Michaud, Senior Technical Reviewer
A conference call was convened among EPA Headquarters, EPA Region 4, North Carolina
Department of Environment and Natural Resources (NCDENR), and Marasco Newton Group on
April 12, 2002 to discuss outstanding issues regarding a potential scoring strategy for the Texfi
Industries, Inc., site.
Marasco Newton Group, EPA Region 4, and NCDENR summarized the site background and
outstanding issues. The Texfi Industries Inc. (Texfi) facility is located in Fayetteville, NC. Texfi
operated a textile dyeing and finishing operation from 1968 until 1999. The facility filed for
bankruptcy in February 2000. In 1995, a chlorinated solvent plume attributed to the facility was
detected migrating toward a clear well associated with a City of Fayetteville water treatment plant.
A slurry wall and ground water extraction system were constructed to prevent migration of hazardous
substances to the clear well. To date, this action has been effective, but the ground water extraction
system is considered an Αinterim action≅ and funding is due to run out. The site was brought to the
attention of EPA Region 4 due to concerns about the possibility that the ground water contamination
will reach the clear well after the system ceases to operate.
Marasco Newton Group summarized the key outstanding issues. Based on the information available
for review, Marasco Newton Group evaluated HRS scoring strategies for the ground water and
surface water migration pathways. Key points highlighted during the call are as follows:
Technical Support Document, 4/17/02
Texfi Industries Inc.
Page 2
∃ Marasco Newton Group noted that for both of these pathways the outstanding policy issue,
critical to scoring the site, is whether the clear well is an eligible resource for HRS scoring.
∃ If it were determined that the clear well was eligible for scoring as a ground water resource
(i.e., aquifer or target well), preliminary information suggests that the HRS score would
exceed 28.5 based on the ground water migration pathway.
∃ Based on existing information, it appears unlikely that the overland flow/flood component of
the surface water pathway would contribute significantly to an HRS score for this site.
∃ If it were determined that the clear well was eligible for scoring as a surface water body, the
HRS score could possibly exceed 28.5 based on the drinking water threat of the ground water
to surface water component of the surface water migration pathway. This would require the
documentation of additional sources to establish a hazardous waste quantity factor value of
10,000. This does not seem viable given existing information.

At the conclusion of the call, EPA Headquarters requested that Marasco Newton Group summarize
the key outstanding issues and their implications on a possible site score. An analysis of the
eligibility of the clear well as a ground water or surface water resource and implications for HRS
scoring is attached. A more complete analysis is presented in the technical support document dated
January 31, 2002.

ATTACHMENT A
Summary of Analysis of HRS Eligibility of Clear Well and Scoring Implications
Texfi Industries Site, Fayetteville, NC
Please refer to technical support documents dated January 31, 2002 for a more detailed development of this analysis.
Eligibility of Clear Well as HRS-Eligible Resource Scoring Implications Issues to be Resolved
Ground Water Migration Pathway
Clear well as an aquifer - The HRSGM defines an aquifer as:
Αone or more strata of rock or sediment that is saturated and sufficiently permeable to yield economically significant
quantities of water to wells or springs. An aquifer includes any
geologic material that is currently used or could be used as a
source of water within the TDL.≅
Because the clear well does not consist of geologic material, it
would be difficult to defend the analogy of the clear well as an
aquifer.
If the clear well is
determined to be an
Αaquifer≅ or
Αdrinking water well≅ for HRS scoring
purposes, available
information suggests
the following:
∃ Documentation that
ground water can infiltrate the clear
well under certain
conditions;
∃ Information
characterizing at least
one source with a
source HWQ value
Eligibility of Clear Well as HRS-Eligible Resource Scoring Implications Issues to be Resolved
Clear well as a drinking water well - This scenario requires that
the clear well be considered a point of withdrawal from the aquifer. In this case, the clear well would be analogous to the
inside of a drinking water well casing. The walls and
foundation of the clear well could either be considered
analogous to the well screen or they could be considered a
separate Αaquifer.≅
Walls and foundation as a well screen Β This approach could
be defended by drawing an analogy between slots in a well
screen and the expansion joints in the walls and foundation.
Documentation suggests that ground water can infiltrate the clear well under certain conditions. An argument against this analogy is that, unlike a well screen, the walls and foundation
of the clear well are designed and maintained to keep ground
water out.
Walls and foundation as an aquifer - This approach could be defended by drawing an analogy between the concrete
structures with expansion joints and bedrock with fractures (the
interior of the clear well would be analogous to an open
casing). An argument against this analogy is that the concrete structure does not meet the HRSGM definition of an aquifer.
∃ LR = 550
∃ WC ∃ 10
∃ T ∃ 5,234
∃ HRS Score = 50.00
greater than zero;
∃ Documentation of an
observed release to
ground water;
∃ Location of source(s)
relative to the clear
well; and
∃ Documentation of the
population that can
be apportioned to the water treatment plant.
Surface Water Migration Pathway, Ground Water to Surface Water Component, Drinking Water Threat
Clear well as a surface water body Β HRS-eligible surface
water bodies include Α...natural and man-made lakes
(including impoundments) that lie along rivers...≅ and
Αisolated, but perennial, lakes, ponds, and wetlands.≅
The clear well is a man-made impoundment Αalongside≅ the
Cape Fear River; however, unlike a reservoir created by a river
dam, the clear well is disconnected from the River.
The clear well is isolated and could be considered Αperennial≅
in that water must be present in the clear well at all times to
maintain the water supply. The clear well could be considered
If the clear well is
determined to be a
Αsurface water body≅
for HRS scoring
purposes and LR =
500, the following would values would
need to be established:
∃ HWQ would need to be at least 10,000
∃ Interpretation/preced
ence for evaluating concrete-lined
reservoirs relative to
aquifer discontinuity
criterion.
∃ Documentation that
ground water can
infiltrate the clear well under certain
Eligibility of Clear Well as HRS-Eligible Resource Scoring Implications Issues to be Resolved
an eligible surface water body if the Αlakes≅ referred to in the
latter definition include man-made impoundments.
The clear well has the hydraulic characteristics of a surface
water body (i.e., open to atmospheric pressure) and represents
a more vulnerable resource than other surface water bodies that would clearly be HRS-eligible (i.e., unlike most surface water
supplies, water from the clear well is not treated prior to
distribution).
∃ The clear well
would need to be
within 640 feet of
the source
∃ Population
apportioned to the
treatment plant would need to be at
least 100,000
conditions.
∃ Documentation of
5,000,000 gallons of
tankage and drum capacity (or 4,000,000 gallons of
capacity if the
surface impoundment
is included as a source).
∃ Documentation of an
observed release to ground water;
∃ Location of source(s) relative to the clear
well (distance and
orientation); and
∃ Documentation of the
population that can
be apportioned to the
P.O. Hoffer plant.

REFERENCE 6
REFERENCE 7
Available
(read-only) on DEQ
Laserfiche Site
http://edocs.deq.nc.gov/
WasteManagement/
Search.aspx?cr=1
REFERENCE 8
Available
on DEQ Laserfiche Site
http://edocs.deq.nc.gov/WasteManagement/
Search.aspx?cr=1
REFERENCE 9
REFERENCE 10
DUNCKLEE & DUNHAM, P.C. DD
Evaluation of Risk to the Public Works Commission Clearwell
508 Hoffer Drive
Former Texfi Industries Site Brownfields Project #13017-09-26
601 Hoffer Drive Fayetteville, North Carolina
Prepared for:
Brownfields Program Division of Waste Management NC Department of Environment and Natural Resources
On behalf of:
City of Fayetteville Fayetteville, North Carolina
Prepared by
Duncklee & Dunham, P.C. Cary, North Carolina
August 16, 2012
DUNCKLEE
& DUNHAM
MAILING ADDRESS – POST OFFICE BOX 639 – CARY, NORTH CAROLINA 27512
NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261
NC DENR REGISTERED ENVIRONMENTAL CONSULTANT NUMBER 00061
DD ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE – SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858–9898
WWW.DUNCKLEEDUNHAM.COM
VIA EMAIL TO: [e-mail]
August 16, 2012
Ms. Sharon Eckard
North Carolina Brownfields Program
Division of Waste Management 217 West Jones Street
Raleigh, North Carolina 27603
Reference: Evaluation of Risk to the Public Works Commission Clearwell
Texfi BF Project # 13017-09-26 508 Hoffer Drive Fayetteville, North Carolina
Dear Ms. Eckard:
On behalf of the City of Fayetteville (City), Duncklee & Dunham P.C. (Duncklee & Dunham) is pleased
to submit this: (i) compilation and discussion of data collected and relevant corrective actions taken to date, and (ii) updated analysis of the risk to water quality in the 12-million gallon finished water supply
clearwell (Clearwell) that is part of the Hoffer Water Treatment Plant, from contamination migrating from
the adjacent, former Texfi Site, as requested by the North Carolina Brownfields Program in its draft brownfields agreement provided to the City.
In the early 2000s, the U.S. Environmental Protection Agency (EPA) conducted a risk analysis and scored the Texfi Site for possible inclusion on its national priorities list (NPL) under the federal Superfund law.
EPA’s analysis included an evaluation of the risk to water quality in the Clearwell posed by the contamination. EPA concluded that the risk to human health and the environment and to water quality in the Clearwell in particular, was not significant enough for the Texfi Site to be included on the NPL. We
understand this was due in large part to the outward pressure of water in the Clearwell.
The purpose of this report is to evaluate and document the risk to the water quality in the Clearwell from
the contaminant plume migrating from the Texfi Site using all lines of available evidence. Based upon a review of the significant sampling conducted since EPA did its analysis, including the most recent
assessment work conducted in early 2012 funded by a EPA Region 4 targeted brownfields assessment
grant, and our own additional analysis, all of which is described in this report, we conclude that (i) water quality in the Clearwell has not been impacted by the contaminant plume, and (ii) should not be impacted
by the plume going forward so long as voluntary guidelines for maintaining a minimum depth of water in
the Clearwell, which maintains the outward water pressure in the Clearwell, continue to be followed.

Duncklee & Dunham, the City and PWC look forward to our meeting on July 30, 2012 to discuss this
information with you and Bruce Nicholson. If you have any questions or comments, please contact Daphne Jones at [phone] or [e-mail].

Sincerely,

Duncklee & Dunham, P.C.
Daphne M. Jones, P.G., R.S.M.
Senior Geologist
Senior Peer Review:
David L. Duncklee, P.G., R.S.M.
Principal
Cc: Mr. Craig Hampton, City of Fayetteville
Mr. Mick Noland, PWC

P:\Fayetteville\Texfi - 200850\BFA\Public Health RA\Texfi Clearwell Summary - 12165.docx

iv DD
Table of Contents

1 Introduction and Scope of Work 1
2 The Texfi Site, the PWC Water Treatment Plant and Historical Summary 2
3 EPA’s Risk Analysis in Early 2000s 4
4 Compilation and Discussion of Data Available to Date 4
4.1 The Clearwell and its Physical Position Relative to the Slurry Wall 4
4.2 Data Obtained from the Targeted Brownfields Assessment 5
4.2.1 Stratigraphy 5
4.2.2 MIP-Generated Contaminant Plume Transects 6
4.2.3 MIP Logs on the South Side of the Slurry Wall 8
4.3 Historical Clearwell Water Sampling 9
4.4 May 2012 HRC-X Injections 10
5 Additional Analysis Conducted by Duncklee & Dunham 10
5.1 Pressure and Buoyancy Calculations 10
5.2 Diffusion of PCE through Concrete 11
5.3 Presence of Disinfection Byproducts in Monitoring Wells near the Clearwell 12

6 PWC Clearwell Rehabilitation Project 13
7 Summary and Conclusions 14
v DD
Figures
1 Site Location Map
2 Total Detected VOCs vs. Time GW-2 (2009 CDM Report)
3 Depth Slurry Wall Trench Cross Section (2001 CDM Report)
4 Elevation Slurry Wall Cross Section (2012 modifications by Duncklee & Dunham)
5 W-E Electrical Conductivity Transect (Columbia Technologies -2012 AES Report)
6 N-S Electrical Conductivity Transect (Columbia Technologies - 2012 AES Report)
7 Transect Location Map (2012 AES Report)
8 MIP Cross Section A-A’ (N-S)
9 MIP Cross Section B-B’ (N-S)
10 MIP Cross Section C-C’ (W-E)
11 Proposed HRC-X™ Injection Points
12 Trihalomethane Detections in PWC Monitoring Wells
Appendices
A Texfi Interim Remedial Measures Report (CDM June 2009)
B Annotated MIP Logs from South of the Slurry Wall with Location Map
C Buoyancy and Hydrostatic Pressure Calculations
D Sample Calculation for the Transport of PCE Liquid through Concrete via Diffusion and
Clearwell Information Provided by PWC and Hazen & Sawyer (email train)
E Clearwell Rehabilitation Drawings

vi DD
List of Acronyms
AES Advanced Environmental Solutions, Inc.
BDCM Bromodichloromethane (a THM)
bgs below ground surface
BFA Brownfields agreement
CDM Camp, Dresser & McKee
COC Constituent of concern
DENR Department of Environment and Natural Resources
DBCM Dibromochloromethane (a THM)
DBP Disinfection byproduct
DCE Dichloroethene (mainly cis- and trans-1,2-DCE isomers)
DNAPL Dense non-aqueous phase liquid
DWM Division of Waste Management
EC Electrical conductivity
ECD Electron capture detector
EPA Environmental Protection Agency
FID Flame ionizing detector
IHSB Inactive Hazardous Sites Branch
LNAPL Light non-aqueous phase liquid
MCL Maximum contaminant level (drinking water standards)
MDL Method detection limit
MG Million gallons
MGD Million gallons/day
MIP Membrane interface probe
NCBP North Carolina Brownfields Program
NFRAP No further remedial action planned
NPL National Priorities List
PCE Perchloroethylene, also known as tetrachloroethene
PID Photoionization detector
PWC Fayetteville Public Works Commission
PWS DENR’s Public Water Supply Section
TBA Targeted Brownfields Assessment
TCE Trichloroethene
THM Trihalomethane (a DBP)
VC Vinyl chloride
VOC Volatile organic compound
DUNCKLEE & DUNHAM, P.C. DD
Evaluation of Risk to the Public Works Commission Clearwell 508 Hoffer Drive
Fayetteville, North Carolina August 16, 2012
1 Introduction and Scope of Work
In July 2009, the City of Fayetteville submitted a brownfields application for the former Texfi Industries property (Texfi Site). In September 2009, the North Carolina Department of Environment and Natural Resources (DENR), North Carolina Brownfields Program (NCBP) issued a Letter of Eligibility for the
brownfields program to the City. The City subsequently obtained title to the Texfi Site via a tax foreclosure proceeding in January 2011.
The proposed brownfields agreement (BFA) the NCBP sent to the City included the following requirement in the “Work to be Performed” Section:
Within 90 days after the effective date of this Agreement, Prospective Developer shall submit to DENR a plan for a study that evaluates the risk to the PWC clearwell at the property adjacent to the
Brownfield property from the Property’s contamination […] and shall provide for evaluation of all relevant available data and the feasibility of various options for protecting the clearwell, including options relating to operation of the well.
Based on this paragraph and conversations between Ms. Sharon Eckard, the project manager for the NCBP and Ms. Daphne Jones of Duncklee & Dunham, P.C. (Duncklee & Dunham), this report
summarizes the available data and presents calculations to satisfy this requirement.
The City is voluntarily providing this report for NCBP’s review to facilitate the BFA negotiation process.
The City believes it is more appropriate to provide this report outside the scope of a BFA, particularly since the City’s proposed uses of the Texfi Site will not in any way alter whatever risk the contamination poses to the off-site Clearwell. Once NCBP has reviewed this draft report and it is finalized, it can be
added to the list of environmental reports in paragraph 5 of the BFA.
This document presents a compilation and discussion of data collected and relevant corrective actions
taken to date, and new calculations and analysis regarding the possible risk posed by the groundwater contaminant plume from the Texfi Site to water quality in the Fayetteville Public Works Commission’s
(PWC) 12-million gallon (MG) clearwell (Clearwell). The Clearwell, located on property immediately
adjacent and south of the former Texfi Site (Figure 1), is used to store the treated water supply for the City. The information and analysis in this report includes:
•Updates to cross section maps showing the slurry wall, groundwater table, and base of theclearwell. For example, the Camp Dresser & McKee (CDM) slurry wall cross section as-built
maps were converted to an elevation scale on the vertical axis.
•Significant additional soil and groundwater assessment data recently collected using membrane
interface probe (MIP) methods on both the Texfi Site and the PWC property funded by a U.S.
Environmental Protection Agency (EPA) Region 4 TBA grant. The TBA report was finalized inJune 2012.
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•Calculations by Duncklee & Dunham of buoyancy and hydrostatic pressure within the Clearwellfrom surrounding saturated and unsaturated soils. A groundwater elevation of 85 feet was used,
which is slightly above the highest elevations recorded from monitoring wells on the PWC
property located closest to the Clearwell. Monitoring wells were first installed on the PWCproperty in 2001 along with the slurry wall and recovery wells as part of the interim measures.
(Note: all elevations noted in this report are relative to average mean sea level.)
•Information on injections of remediation agents on the Texfi Site and near the Clearwell under
the direction of the IHSB to enhance the bioremediation of groundwater plume contaminants
near the slurry wall and upgradient Clearwell corner. These injections were performed in May2012.
•Data on the results of historical Clearwell sampling.
•Data on the diffusion rate of tetrachloroethene (PCE) through saturated concrete.
•The presence of disinfection byproducts (associated with chlorinated drinking water) in nearbymonitoring wells.
•Information related to the $4.6-million upgrade/rehabilitation being done on the Clearwell.
2 The Texfi Site, the PWC Water Treatment Plant and Historical Summary
The Texfi Site was undeveloped land until 1968, when a manufacturing facility was constructed. Cape Fear Industries, Inc. and Fayette Finishing Corporation conducted textile operations at the Site that
included yarn preparation, weaving, fabric dyeing and finishing. Texfi Industries purchased the property in 1975, and operated there until about 1999.
The Texfi Site is bound to the east by the Cape Fear River, to the south by the Hoffer Water Treatment Plant operated by PWC, and Clark Park to the north. To the west active railroad tracks bound the undeveloped portion of the Site, to the west of which are residential parcels.
Chlorinated solvent contamination was first discovered on the Texfi Site in 1995 during the investigation
of a fuel oil spill. During the investigations that led up to the 2001 interim measures work that included
the installation of the slurry wall and three recovery wells on the PWC property, it was discovered that the chlorinated solvent groundwater contamination had migrated off-site onto the adjacent PWC water
treatment plant property. More than thirty monitoring wells were installed on PWC property to assess the
extent of the groundwater contamination (Appendix A).
Texfi Industries filed for bankruptcy in 2000, and a trustee appointed to liquidate its assets. DENR’s Division of Waste Management, with legal support from the City, filed an action in state court and submitted a claim to the bankruptcy court to enforce an administrative order DENR had issued requiring
the bankruptcy trustee to expend funds necessary to assess and remediate the Site. This led to a multi-party settlement, which both DENR and the City were parties to, by which the bankruptcy trustee agreed
to contribute funds obtained from liquidating the company’s assets to a fund DENR would manage to be
used for assessment and remedial activities on the Site. The trustee ultimately contributed approximately $942,000 for corrective actions at the Site pursuant to this settlement. The trustee in turn, with DENR
and the City’s consent per the settlement, obtained permission from the bankruptcy court to abandon the
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DUNCKLEE & DUNHAM, P.C. DD
property, relieving the bankruptcy trustee and estate of any further obligations for the Site. DENR has contracted with environmental consultants using the funds from this settlement over the past several years; approximately $164,000 remains in this fund.
The PWC Hoffer water treatment plant averages about 20 million gallons per day (MGD) of treated
water. The raw water is pumped from the adjacent Cape Fear River and disinfected with a chloramination
process. This treated water is distributed to the City, Fort Bragg and surrounding communities with a total population of approximately 240,000. The intake on the Cape Fear River is located approximately
1,000 feet to the southeast of the former Texfi manufacturing building.
After treatment, water flows through the Clearwell, a partially sub-grade concrete reservoir, which is
located approximately 250 feet south-southeast from the former Texfi manufacturing building. After
residence time averaging about eight hours in the Clearwell, the treated water is pumped through the distribution system.

In 2001, DENR’s Inactive Hazardous Sites Branch (IHSB) constructed a 450-foot bentonite slurry wall between the Texfi Site and PWC water treatment plant property to impede the migration of contamination
via groundwater. Three groundwater recovery wells were also active near the east end of the slurry wall from 2001 to 2009.
In 2006-2008, using funds from the bankruptcy settlement, IHSB directed the injection of a bioremediation substrate into the shallow aquifer. Results of a pilot study injection of HRC™ at the
northern end of the Texfi plant in November 2006 confirmed anaerobic conditions favorable for reductive
dechlorination had been created. The full-scale injection of HRC-A™ occurred between May and July 2008 with a minor follow-up injection of HRC-A™ in October 2008. Approximately 50,640 pounds of
HRC-A™, diluted at a 1:10 ratio with water, was injected into 417 injection points at depths between
about 5 and 12 feet below surface, from the top of the water table to the top of the Cape Fear clay unit beneath the surficial aquifer. Subsequent to the injection activities, IHSB concluded that interim actions
since 2001 had reduced contaminant concentrations in the monitoring wells on the adjacent, PWC water
treatment plant property.
IHSB then turned off the pumps in the recovery wells in March 2009, because of concern that higher contaminant concentrations could be pulled toward the Clearwell by those wells. There is indication from water level maps presented in the 2011 Clay Assessment Report, after the recovery wells had been turned
off, that a toe-drain system surrounding the Clearwell may be influencing the groundwater flow approximately 250 feet to the east and 200 feet to the north, which is beyond the end of the slurry wall. The toe-drain system is a gravity-flow french-drain system installed in 1997 during a Clearwell reservoir
repairs project, with a base elevation of 82 feet. The toe drain is designed to keep groundwater levels low around the structure. The report indicates that the influence of the toe drain has a similar but less
pronounced effect on groundwater flow within the upper clay unit.
Significant levels of chlorinated solvent contamination in groundwater were discovered in the area near
the northeast corner of the Clearwell in 2009. After a period of decline from 2001 to 2008, groundwater
concentrations of PCE in the former GW-2 monitoring well (since replaced by the MW-24 cluster) increased from 1,900 µg/L in March 2009 to 36,000 µg/L in June 2009. GW-2 was abandoned in order to
prepare for the proposed excavation of soil in this area to remove the contaminants. Due to PWC’s concerns to possible damage to the Clearwell by vibrations caused by driving sheet pilings needed to contain flowing sands during the excavation, the plans for the excavation were discontinued.
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Figure 2 shows a histogram from a report prepared by CDM for DENR, Texfi Interim Remedial Measures. After the HRC-A™ injection event in 2008, there was a change in the magnitude of
contamination in GW-2, and also a change in the ratio of the contaminants of concern (COCs). The histogram in Figure 2 has been annotated to show the timeframe of the injection event. Approximately a
year after the injection, a 20-fold increase in contamination was found in GW-2. Further, the ratio of cis-
and trans-1,2-dichloroethene isomers (DCE) and vinyl chloride (VC), or end products of the PCE degradation pathway, decreased relative to the PCE/trichloroethene (TCE) in the sample. Well GW-2 had
been installed a few feet into the clay unit and was the deepest of the GW wells around the Clearwell.
Additional assessment work focused in the deeper upper clay unit was performed for IHSB from February
2010 through January 2011. These tasks were performed on both the Texfi Site and the PWC water
treatment plant property where the upper clay unit was found to be water bearing and impacted with chlorinated solvents. PCE impacts were found to extend to a significant extent vertically in what was
formerly believed to be a clay confining unit.
The City obtained title to the Texfi Site via a tax foreclosure in January 2011. The City has not yet used
the Texfi Site for any significant purpose. The City later applied for a TBA grant in April 2011, and provided EPA Region 4 with a work scope of assessment activities in June 2011. The primary task was using MIP methods to provide high density assessment data in source areas, around the slurry wall, in a
ditch on the Texfi Site, around the Clearwell, and other areas. The MIP tools would be effective in the saturated zone to a depth of approximately 30 feet. Field work was conducted during between January 30
and February 10, 2012. The TBA report was finalized in early June, 2012.
3 EPA’s Risk Analysis in Early 2000s
As indicated in our cover letter, EPA evaluated the Texfi Site in the early 2000s for possible inclusion on
its NPL under the federal Superfund law. In January 2012, Ms. Daphne Jones of Duncklee & Dunham
had a telephone conversation with Mr. Phil Vorsatz, the current head of EPA Region 4’s brownfields program. Mr. Vorsatz worked in the Superfund branch of EPA when EPA was evaluating the Texfi Site
for possible inclusion on the NPL. Mr. Vorsatz indicated the outward pressure of the Clearwell is the primary reason the Texfi Site was issued a no further remedial action planned (NFRAP) status by EPA, thereby establishing DENR’s IHSB as the regulatory authority for oversight.
4 Compilation and Discussion of Data Available to Date
In this Section, we compile and discuss the sampling and other data collected, and corrective actions to
date relevant to the risk to water quality in the Clearwell from the contamination migrating from the Texfi
Site.
4.1 The Clearwell and its Physical Position Relative to the Slurry Wall
The base of the slurry wall has been placed at an elevation four to nine feet below the base of the
Clearwell. Duncklee & Dunham has used the information from a previously drawn cross section along
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with newly collected elevation information to redraw the cross section (Figure 3) and show the finished bottom elevations of each of these structures.
In an appendix in the Texfi Interim Remedial Measures Project Completion Report (CDM, June 2001), there is a cross section illustrating the depth of the slurry wall along its 450-foot length, which was
installed with a minimum 3-foot penetration into the clay layer (Figure 4). However, the cross section is
based on depth, not elevation. Note the variability of the depth of the top of the clay layer (between 9 and 13.5 feet) in this figure along its 450-foot length.

During the TBA field work, a City survey team collected elevation and location information for all the MIP boring locations, as well as elevations at seven locations along the slurry wall. Three elevations
were collected perpendicular to the 3-foot thick wall at each location and averaged. While the current
elevation along the slurry wall may be somewhat different than the original elevation, this at least gives us the ability to approximately determine the elevation of the base of slurry wall for comparison to the base
of the Clearwell.
The elevation of the top and bottom of the Clearwell floor has been translated onto Figure 3. The bottom
of the base slab of the Clearwell is between 4 and 9 feet above the bottom of the slurry wall. Based on water table information collected by CDM over a nine-year period (summary tables provided in June 29, 2009 report Texfi Interim Remedial Measures, attached as Appendix A), groundwater table elevations in
wells nearest the Clearwell generally fall between 83 and 85 feet elevation over that time period between 2001 and 2009. The top of the concrete floor is 84.5 feet elevation, and on the northern end of the
Clearwell the thickness of the mat slab is about 1.5 feet at the northern end of the Clearwell (near the
slurry wall), although it is typically closer to 1-foot thick elsewhere. We assumed the 1.5-foot thickness of the mat slab to draw the elevation of the base of the Clearwell at approximately 83 feet elevation on
Figure 3. The thickness of the Clearwell walls is also one foot.
Due to the presence of the toe drain, the most recent groundwater measurements show that the
groundwater elevation is 82.38 feet near the northeast corner of the Clearwell in the TBA sampling of
MW-24C in January 2012. The Clearwell has an operating depth of up to 14 feet. Ultrasonic detectors are used to determine water levels in the Clearwell. The self-imposed minimum level is seven feet of
water or 91.5 feet of elevation, with the operating level between 91.5 and 98.5 feet and overflow at 99.5 feet.
4.2 Data Obtained from 2012 Targeted Brownfields Assessment 4.2.1 Stratigraphy
The City applied for a TBA grant from EPA Region 4 in the spring 2011. The scope of work, which was
predominantly MIP/HPT borings with associated groundwater, soil and surface water sampling, was
approved in fall 2011. Field work was conducted over a two-week timeframe in late January/early February 2012. The final report was received from Advanced Environmental Solutions (AES) on June 7,
2012. This sub-section presents a summary of the AES findings as presented in their report.
Prior to the TBA, no cross-sections had been constructed for the Texfi Site or PWC property, and with the
exception of the Clay Assessment Report (2011), there were relatively few lithologic descriptions available. The stratigraphy was considered to have an upper predominantly sand interval to
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approximately 10-12 feet below ground surface (bgs) with the lower predominantly clay confining interval known as the Cape Fear confining unit.
However, based on the clay unit assessment work by IHSB and MIP results from AES, the upper Cape Fear does not become a true confining layer at depths until about 35 feet bgs, with its shallower lithology
being a heterogeneous intermingling of clay, silt and sand. Numerous monitoring wells constructed in the
uppermost heterogeneous portion of the Cape Fear unit and sampled demonstrate that the upper Cape Fear has enough permeability for significant groundwater and contaminant transport.
The TBA included 45 direct-push MIP borings mostly advanced to depths between 2 to 30 feet bgs, with the deepest boring advanced to 38 feet bgs. The MIP data produced includes lithology information as
well as relative concentrations of volatile organic compounds (VOCs). The MIP tools include an
electrical conductivity (EC) detector used to interpret lithology, with higher conductivity values indicative of finer grained materials (silty clays and clays), and lower conductivity values indicative of coarser
grained materials (sands and silty sands).
Based on the information collected during the TBA, the upper clay unit below the upper sandy surficial
aquifer appears to be more heterogeneous than previously thought. This is a non-confining clay unit with interbedded layers of sand or silt encountered between about 9 and 35 feet bgs. Figures 20 and 21 from the Columbia Technologies MIP Report (an appendix to the 2012 TBA report) are attached here as
Figures 5 and 6. The lightest color near the surface represents the sand layer. At about 12 feet bgs, one can see the intermingling of more clay and silt layers in the upper Cape Fear. The conductivity diagrams
become noticeably darker, indicating more clay at about 16 feet bgs, but still containing zones of higher
permeability. These two figures demonstrate how heterogeneous this interval actually is.
The lithologic unit referred to as the non-confining clay unit in the TBA report is where dense non-
aqueous phase liquid (DNAPL) is likely to be currently concentrated, between the base of the sand (8-10 feet bgs) extending down to around 37 feet bgs on the PWC Property. It is likely the DNAPL first settled
on the top of the predominantly clay unit on the Texfi property, but then continued downward as it
followed the more permeable silt and sand stringers located in the upper 20 feet or so of the clay unit.
4.2.2 MIP Generated Contaminant Plume Transects
The transect location map (Figure 7) and three MIP transects (Figures 8-10 from the TBA report) are
included in this summary. While the electron capture detector (ECD) is typically best for detection of halogenated molecules, during the TBA study, the concentration of chlorinated compounds was so high that the ECD was often saturated. Therefore, the photoionization detector (PID) data was the detector of
choice for the three transects that were made into cross-sections for the TBA Report.
The two north-south transects, A-A’ and B-B’ (Figures 8 and 9) show groundwater contamination being
located primarily on the former Texfi Site and originating in the shallow zone on the northern or plant building end. Historically, the northern area of the transects is where 2- and 4-chlorotoluene are
concentrated. These isomers have densities only slightly heavier than water (1.073 gm/ml and 1.059
g/ml, respectively) and are insoluble. So, while they cannot be considered light non aqueous phase liquids (LNAPLs) as their densities are not less than water, they are likely to be more concentrated in the
shallower portions of the surficial aquifer as opposed to sinking to deeper zones.
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The chlorinated solvents that are the predominant COCs throughout the Site include PCE and its degradation products TCE and DCE. PCE has a density of 1.622 mg/ml, TCE’s density is 1.46 mg/L and cis-and trans-DCE are 1.28 and 1.26 mg/ml respectively. These COCs also have low solubility. After the
HRC-A™ injections in 2008 on the Texfi Site, where the chlorinated solvent concentrations were greatly reduced in the surficial aquifer while the chlorotoluene isomers were relatively unaffected.
Looking again at transects A-A’ and B-B’, the MIP probe data shows COCs in the upgradient shallow zones to the north have moved downward into the heterogeneous upper clay unit and to the south. On the
left portion of transect A-A’ and B-B’ (north end) the contamination is first noted in the unsaturated zone,
at less than five feet depth. The MIP data shows contamination on the northern end of A-A’ originates deeper than along B-B’. This feature may be because of origination in former plant underground waste
lines and sumps rather than surface spills of 2- and 4-chlorotoluene near the former AST area. The use of
HRC-A™ may also have reduced contaminant levels in the uppermost portion of the shallow sandy aquifer unit along the A-A’ axis transect.
Between MW-10 and MIP/HPT-3 on A-A’, the MIP data shows contamination extending to the base of the surficial aquifer in the non-confining clay unit. The magnitude of contamination increases in the
known source areas just east of the Boiler Area and former Dye Room on the Texfi Site. The MIP data shows this area, from about 11 to 22 feet below grade, has the greatest contaminant mass in the entire study area. There is another increased area of contamination shown on A-A’ under the east-west drainage
ditch just north of HPT-14; the B-B’ cross section also shows a high magnitude area of contaminant mass under this ditch. MIP-38 and MIP-39 (are located on the south side of the bentonite slurry wall in cross-
section A-A’, and relatively contaminant free except at depths below the slurry wall’s base that is
approximately 12 to 16.5 feet bgs. The top of the water table near the Clearwell averages 7 to 9 feet bgs.
Transect B-B’ depicts both shallow and deep contamination from MIP-21 to a point in between MIP-18
and MIP-13. The MIP data then shows COC mass becoming more concentrated between MIP-13 and MIP-16; these locations were near/in a former shallow (dry) drainage ditch that flows into the deeper east-
west drainage ditch. The deepest and highest concentrations of contamination are again located near the
east-west drainage ditch, where the data show contamination in the unconfined unit of the top of the Cape Fear clay. On this transect, the slurry wall is between MIP-107 and MIP/HPT-12. On the south side of
the slurry wall, the contamination greatly decreases, although there is a peak at about 25 feet bgs in MIP-102 located adjacent to the east side of the Clearwell.
Note that south of the slurry wall in both transects, the contamination depicted is in the non-confining portion of the Cape Fear clay, and is at elevations that are lower than the base of the Clearwell structure. In both transects, the bulk of the mass of the contamination is located north of the slurry wall. While the
contamination north of the slurry wall is at higher elevations than the contamination located south of the slurry wall, the contamination north of the slurry wall is still mainly within in the non-confining clays
beneath the surficial aquifer.
For Transect C-C’ (Figure 10) only MIP/HPT-15 and MIP-107 are from upgradient of the slurry wall.
The majority of the contamination is in the upper clay interval in this area, which again is at elevations
that are lower than the base of the Clearwell.
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4.2.3 MIP Logs on the South Side of the Slurry Wall
Attached are the individual MIP logs, as annotated by Duncklee & Dunham (Appendix B), located on the
downgradient side of the slurry wall. The ground elevation has been noted at the top of the EC log for each location. A low EC reading (to the left) corresponds to coarser grained material, a moderate EC
reading with silt and an EC reading to the right with clay. The red line on the EC logs marks the
approximate base of the surficial sand aquifer on these logs, the green line marks the approximate base of the slurry wall and the purple line marks the elevation at the top of the Clearwell floor slab.
The ECD log is best for detection of the chlorinated solvents such as PCE/TCE/DCE. When the ECD log moves to the right, it is indicative of the presence of these chlorinated VOCs. The elevation of the top of
the Clearwell floor slab is marked on the ECD log; the slab is between 1 and 1.5 feet thick beneath the top
of the floor, excluding footer areas.
By referencing the elevations of the base of the clearwell to the bottom of the slurry wall the COC data
from the MIP probe, Duncklee & Dunham makes the following observations:
1.In a number of borings (e.g. MIP-31, MIP-38, MIP-101, MIP-104, MIP-105 and MIP/HPT-13),the MIP ECD data indicates contamination is five to ten feet beneath the base of the surficialaquifer and below the base of the slurry wall within this heterogeneous upper clay unit. The MIP
data supports a finding that this contamination is moving under the slurry wall within the clayunit.
2.The following observations are indicative of the heterogeneous complexity of the upper Cape
Fear clay interval south of the slurry wall as evidenced by the movement of contaminationthorough it:
a.MIP-102 has a fairly well-developed sandy interval at about 22 feet. In addition to the ECD
reading there is also a deflection at this elevation in both the flame ionization detector (FID)and PID curves.
b.MIP-103, MIP-108, MIP/HPT-12 have ECD deflections near the top of the clay layer as well
as the maximum ECD readings lower in the clay layer.
c.In MIP-31 and MIP-102, the ECD deflections start a couple of feet down in the clay layer, as
well as having the maximum ECD readings lower in the clay.
d.The contamination in MIP-38, MIP-104 and MIP/HPT-13 starts deeper in the clay interval,seven feet or more below the base of the surficial sand.
e.MIP-104 and MIP/HPT-13 have ECD deflections three or more feet lower than theapproximate elevation of the base of the slurry wall.
3.MIP-31, MIP-38, MIP-39, MIP-101 and MIP-106 all show increases in the ECD logs near the
approximate elevation of the base of the slurry wall. The MIP data indicates the slurry wall haslimited the flow of COCs in the shallow sandy soil along the axis of plume unit from migrating
directly onto the PWC property.
4.The highest concentrations of contaminants in the aquifer based on the MIP locations near thenortheastern corner of the Clearwell are all at elevations beneath the base of the Clearwell slab.
5. The least separation between the contamination and the top of the Clearwell slab is approximately
three feet in MIP-103 and MIP/HPT-12. MIP-102 and MIP-108 have more separation between
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the contamination and the top of the clearwell slab (4-5 feet). All four of these borings located near the northeast corner of the Clearwell show significant chlorinated solvent contamination in the upper clay zone just beneath the surficial sand, several feet above the base of the slurry wall.
Additionally, MW-24S, screened between 4 and 9 feet depth had PCE at 1,760 µg/L in October 2010 (2009 Clay Assessment Report), indicating presence of shallower contamination in this
same area, although not the same lithology. This shallower contamination near the corner of the
Clearwell is adjacent to the toe-drain system. The 2011 Clay Assessment Report indicates that an upward hydraulic gradient in this area may be caused by the influence of the toe drain acting as a
groundwater sink that causes shallow and confining unit groundwater to discharge to the drain.
4.3 Historical Clearwell Water Sampling
Samples have been collected at least monthly since 2001 from the Clearwell treated water, and more recently influent water from the Cape Fear River. In the 11 years of historical data, samples collected
from the Clearwell water have had three incidents of detections of COCs, other than disinfection
byproducts (DBPs) that are associated with chlorinated drinking water.
The first was from a sample collected by DENR on May 31,2001, when traces of PCE, cis-1,2-DCE and tetrahydrofuran were detected below method detection limits (MDLs), which are considered to be estimated “J” values; i.e. not quantitative data. These results were reported to and discussed with
DENR’s Public Water Supply Section (PWS) and IHSB, and the Clearwell water was promptly re-sampled on June 7, 2001. Based on follow-up sampling, which had no detectable levels, it was concluded
that the initial results were not representative and no further action was taken. At this point in time the
IHSB contractor, CDM, was sampling the Clearwell water on a weekly basis.
There were no detections of any COC in the Clearwell water sampling from May 2001 until June 2009.
During the last CDM sampling event in June 2009, two constituents were detected in the Clearwell water
for the first time above detection limits, but below applicable maximum contaminant levels (MCLs) used
for treated drinking water. Ethylbenzene was detected at 2.2 µg/L (MCL = 700µg/L), and xylene at 12.6 µg/L (MCL =10,000 µg/L). MCLs are legally enforceable drinking water standards that apply to public
water systems. These results were again reported to and discussed with the PWS Section and IHSB.
Based on follow-up sampling, it was concluded that the initial results were not representative and no further action was taken.
The CDM contract ended with this sampling event, and PWC has continued monthly sampling of the Clearwell water since July 2009. Neither ethylbenzene nor xylene has been detected in the samples again
since then.
There has been only one instance since June 2009 when any COC (other than a DBP) was detected above
detection limits in the Clearwell water. During PWC’s sampling on March 7, 2012, PCE was detected in the Clearwell water at 0.7 µg/L, and at 1.90 µg/L in the Cape Fear raw water sample (MCL = 5 µg/L).
After obtaining the lab results, PWC re-sampled on March 15, 2012, and PCE was below the detection limit in both the Clearwell water and the Cape Fear sample. PWC also instituted collection of a Cape
Fear River sample upgradient of Texfi near Clark Park on a monthly basis, starting with the March 15,
2012 sampling event. The March sampling results were reported to and discussed with the PWS Section
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and IHSB. Based on follow-up sampling having no detections except for DBPs, it was concluded that the initial results were not representative and no further action was taken.
On March 8, 2012, when the initial sampling was conducted, the flow in the Cape Fear River was in excess of 2.8 billion gallons per day. A 7Q10 value is a seven-day, consecutive low flow with a ten year
return frequency, which is the lowest stream flow for seven consecutive days that would be expected to
occur once in ten years. For the Cape Fear River near the PWC water treatment plant property in Fayetteville, the 7Q10 is approximately 390 million gallons per day. Since the last detection of a
constituent other than DBPs in the Clearwell in March 2012, there have been no VOC detections in the
raw water influent from the Cape Fear River, the Clearwell or the upstream Cape Fear River sample.
4.4 May 2012 IHSB HRC-X™ Injections
Based on conversations with the IHSB, a Regenesis-brand extended-release substrate (HRC-X™), chosen
for its longevity, was injected into the surficial aquifer at the Texfi Site and PWC property in a limited
area northeast of the Clearwell up to the vicinity of MW-27C in late May 2012. The intent of this injection event by IHSB’s contractor is to decrease the surficial aquifer contaminant concentrations near
the Clearwell and in the area around the edge of the slurry wall.
Approximately 77 injection points were planned in nine rows northeast of the Clearwell. A hand sketch
of the location of these lines is attached as Figure 11. Each injection location was to be approximately 6 to 11 feet deep injecting at a rate of 6 lbs/ft for a total of approximately 2,790 pounds.
5 Additional Analysis Conducted by Duncklee & Dunham
5.1 Pressure and Buoyancy Calculations
Hydrostatic and buoyancy calculations were conducted by Duncklee & Dunham (see Appendix C) and
checked by Hazen & Sawyer, the prime contractor for the Hoffer treatment plant upgrades. The hydrostatic calculations determine the height in the Clearwell walls where the pressure is the greatest.
Buoyancy calculations are provided for three different Clearwell operational scenarios, with no water (0 feet) inside, with water at 7 feet (the PWC self-imposed minimum operational level), and water at 15 feet
(overflow level). The maximum operational level is a water depth of 14 feet in the Clearwell. The calculations show the weight of the Clearwell in all three scenarios is more than enough to compensate against the buoyancy (uplift) forces created by the saturated soil beneath it.
The saturated and unsaturated soil around the Clearwell exerts a total pore pressure against the structure,
but instead of trying to identify ever changing water table elevations, for our calculations we
conservatively assumed a water table elevation of 85 feet, which is the highest level recorded in monitoring wells located closest to the Clearwell during the 2001-2009 Interim Measures sampling
conducted by CDM1. Groundwater elevations documented in the more recent 2011 Clay Assessment
1 GW-2 had groundwater elevations listed around 87 feet in May/June 2001 (see Table 2, Texfi Interim Remedial Measures Report, Appendix A). However, GW-2 was reported damaged the rest of 2001 and early 2002 and finally replaced in May 2002. After replacement, GW-2 groundwater elevations ranged from 82.13 feet to 84.74 feet. The
higher elevations are attributed to the damaged well and were not used in the calculations.
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DUNCKLEE & DUNHAM, P.C. DD
Report and the water table measurement of MW-24-C in the 2012 TBA Report are also below 85 feet. This assumption provides a greater than normal hydrostatic pore pressure on the walls of the Clearwell, as the toe drain at 82 feet elevation acts as a sink, drawing water table elevations down towards and beneath
the base of the Clearwell.
With this conservative assumption, Duncklee & Dunham calculated the location of the maximum
hydrostatic pore pressure on the Clearwell structure at approximately 0.5 feet above the base (floor) elevation. At this elevation of 85 feet, the hydrostatic pore pressure exerted by saturated soil has the
potential to exceed the internal hydrostatic pressure exerted by the water within the Clearwell, and
positive pressure exerted by the surrounding saturated soil may direct groundwater into the Clearwell if defects in the concrete (i.e. cracks, fissures) are present. (see Hydrostatic Calculations in Appendix C).
This clearly shows that as long as more than 0.5 feet of water is in the Clearwell, outward pressure keeps contaminated groundwater from entering the Clearwell. PWC’s self-imposed 7-foot minimum
operational depth in the Clearwell provides significant protection over and above the calculated 0.5-foot
depth.
As described in Section 6 below, the Clearwell rehabilitation project will be the first time the Clearwell has been dry in years. When maintenance of the Clearwell completely empties the structure, PWC will take precautionary steps to bring it back online. The steps will be coordinated with DENR’s PWS to
ensure adequate disinfection and protection of the public.
5.2 Diffusion of PCE through Concrete
The NCBP specifically asked that the requested study include a discussion about diffusion of chlorinated
solvents/PCE through concrete. This sub-section addresses this topic.
A “Sample Calculation for the Transport of PCE Liquid through Concrete via Diffusion” is provided in
an appendix of the book Environmental Forensics, Principles & Applications (Robert D. Morrison,
2000), and is included as Appendix D to this report. In his calculation, Morrison assumes a spill of pure PCE product on top of a concrete slab at ground surface. Morrison assumes the concrete is saturated and
effective porosity provides a continuous pathway for the solvent dissolution. Morrison also assumes the
absence of cracks and expansion joints in the concrete pavement that would provide a preferential pathway for liquid migration into the underlying soil.
Based on Morrison’s calculations, it would take in excess of 2,000 days (5.5 years) for an appreciable amount (1.5 x 10-5 gm/cm) of PCE to diffuse through the concrete (see page 305 of Morrison’s
calculations in Appendix D).
Based on that calculation, even though the Clearwell is twice as thick as the concrete in Morrison’s
scenario (1.0 ft v. 0.5 ft.), it is possible that the portion of the Clearwell that is below the water table and that has come into contact with contaminated groundwater has by now become saturated with an
groundwater containing PCE and other chlorinated solvents, given how much time has elapsed since the
contamination was detected on the Texfi Site in 1995. As noted in Section 4.1, the highest measurement of the water table is 85 feet, and the top of the Clearwell slab is 84.5 feet. So the slab and the first 0.5
foot of Clearwell wall are in the area of this potential saturation. This is another conservative assumption
since it has been demonstrated that outward pressure is greater and treated water is being forced out of the Clearwell into the surrounding unsaturated soil and surficial aquifer, effectively diluting contaminated
Evaluation of Risk to the Public Works Commission Clearwell 601 Hoffer Drive Fayetteville, North Carolina
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DUNCKLEE & DUNHAM, P.C. DD
groundwater on a localized basis and thereby working against the separate diffusion mechanism. Thus, saturation of the lower portion of the Clearwell structure would be from a combination of treated drinking water and diluted groundwater.
Even if any such saturation at the bottom of the Clearwell has occurred, however, the risk for PCE-
contaminated groundwater to diffuse through the Clearwell to detectable levels is not significant, for
several reasons.
The first is the volume (19 MDG) of average daily flow through the Clearwell discussed below in this
subsection, which causes the outward pressure discussed in sections 5.1 of this report. Even if there were preferential pathways in the Clearwell, as long as outward pressure is maintained which is the case when
the depth of water in the Clearwell is above 0.5 feet, the circumstances would not provide a pathway for
infiltration of contaminated groundwater in detectible levels into the Clearwell.
The second is the relatively short time water is stored in the Clearwell. As part of completion of our
diffusion analysis, Duncklee & Dunham asked Hazen & Sawyer to provide the minimum theoretical detention times for treated water under various conditions in the Clearwell (Appendix D). With a water
elevation of 93 ft. in the Clearwell, which corresponds to an 8.5-foot water level in the structure, the minimum theoretical detention time would be 306 minutes (approximately 5 hours) assuming an average 32-MGD throughput, or 245 minutes (approximately 4 hours) assuming a 40 MGD throughput (Appendix
D). For a Clearwell maximum level of 99.5 feet elevation, the maximum theoretical retention time corresponds to minimum flow condition of 12 MGD or approximately 1,440 minutes (or one day). The
average flow through the Clearwell from September 2012 through August 2011 was approximately 19
MGD. Accordingly, eight hours would be a conservative average time that a gallon of water is stored in the Clearwell.
The third is the maximum PCE concentrations found outside the Clearwell (100 mg/l detected in MW-24C in October 2010) is equivalent to 0.01% of the concentration (pure product) Morrison used in his
calculation.
Finally, the gravity-flow toe-drain system around the perimeter of the Clearwell now diverts flow away
from the outer concrete wall, and the groundwater level adjacent to the clearwell is likely closer to the 82 foot elevation of the base of the toe drain instead of the 85 foot maximum groundwater elevation of wells that are approximately 10 to 30 feet away from the Clearwell structure.
5.3 Presence of Disinfection Byproducts in Monitoring Wells near Clearwell
As suggested by the NCBP, Duncklee & Dunham reviewed groundwater data for the presence of DBPs collected from near the Clearwell to support the results of calculations indicating the hydrostatic pressure
in the Clearwell when water is at operational depths is outward. The presence of DBPs in a toe-drain
sample show that treated water from inside the Clearwell is being forced outward into the surrounding soils.
During the disinfection process in water treatment systems, DBPs are created, some of which are known as trihalomethanes (THMs). THMs tested for using SW-846 analytical Method 8260B and Drinking
Water Method 524.2 include chloroform, dibromochloromethane (DBCM), bromodichloromethane (BDCM) and bromoform. These four THMs are usually detected during the monthly Clearwell water sampling conducted by PWC. Chloromethane is a less common DBP, but was detected four times
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DUNCKLEE & DUNHAM, P.C. DD
between 0.6 and 1.5 µg/L during the last 21 Clearwell water sampling events conducted by CDM (Appendix A). There is no MCL for chloromethane; the North Carolina groundwater quality standard is 3µg/L.
The Texfi Interim Remedial Measures included the installation of the slurry wall, pumping of recovery
wells RW-1, RW-2 and RW-3 located near the northeast corner of the Clearwell (Figure 12), as well as
periodic sampling of the “GW” series of monitoring wells located on the PWC property occurred from 2001 until 2009. When the interim measures funding was almost depleted, the IHSB conducted one last
snapshot of VOCs in 10 selected monitoring wells, the recovery wells and the Clearwell in June 2009.
The CDM June 2009 report (Appendix A), also included tables summarizing the detections in the PWC monitoring wells over the nine years of sampling.
Chloroform was only found to be present in four monitoring wells, GW-2, GW-4, GW-22 and GW-24, with six detections in these four wells in 2001 and 2002 (circled in Figure 12 with summary of detections
noted in text box at the bottom of that figure). These wells are not directly adjacent to the Clearwell.
Monitoring wells closer to the Clearwell have not had THM detections over time. Duncklee & Dunham asked PWC if there was any type of treated-water line in the area of these four monitoring wells; often
THMs are detected in monitoring wells due to leakage from such lines. However, there is no treated-water line near these four wells. The groundwater data is therefore inconclusive with regards to DBP migration from the Clearwell.
A sample from MH-2 (Manhole #2 which accesses the toe-drain sump around the Clearwell) collected in
February 2009 detected BDCM at 7.51 µg/L. The BDCM concentrations in samples from the Clearwell
water generally range from around 5 to 15µg/L. The detection of BCDM in the toe drain is evidence water is being forced out of the Clearwell into the drainage system.
Also, the toe-drain collection system is tied into the stormwater collection system that drains the entire PWC water treatment plant property. Even in dry conditions, when there is no stormwater being collected
from precipitation events, there is a base flow of water estimated at up to a couple of gallons per minute
from the stormwater discharge pipe that outfalls into the Cape Fear River south (downstream) of the surface water intake. This is an additional indication that the pressure of the water inside the Clearwell is
such that treated water is being forced out to the gravity-fed toe-drain collection system. This storm drainage system also drains a large area of the PWC water treatment plant property along the road leading into the PWC property. The drainage ditches alongside the entry road generally hold water.
6 Clearwell Rehabilitation Project
PWC’s strategy for rehabilitation of the 12-million gallon MG Clearwell at the water treatment facility is
described below. Further details of the $4.6 million rehabilitation work are provided in the Hazen and
Sawyer October 2011 Clearwell Rehabilitation and Chemical Feed Systems Improvements summary drawings provided in Appendix E.
The rehabilitation work planned for inside the 12 MG Clearwell will require that it be completely dewatered and made as dry as reasonably possible. Up until this point, inspections and other work inside
the Clearwell have been performed with some compartments flooded and in service since presently the Clearwell cannot be totally bypassed given the current yard piping configuration. Many of the gates that
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DUNCKLEE & DUNHAM, P.C. DD
isolate the various tank compartments are no longer 100% watertight; hence the interior has not been completely dry in years.
Therefore, the first step for this project will be construction of a 54-inch filtered water by-pass main from the upstream side of the structure through to the finished water main on the downstream side. The sealed
steel bypass pipe is enclosed in an outer steel casing with grout filling the annular space. Fortunately,
adequate detention time necessary to achieve the primary disinfection contact time at the present water treatment facility average flow rate is available in the neighboring two clearwells (4 MG each). The 4MG
clearwells are upgradient from the 12 MG clearwell and are not affected by the groundwater
contamination from the Texfi Site. Hence the 12 MG Clearwell will be temporarily taken out of service to make repairs. Once the by-pass main is in place, the Clearwell can be completely dewatered allowing a
more thorough investigation of conditions, particularly of the bottom slab.
For contracting purposes, PWC estimated unit price quantities for a potential scope of rehabilitation work
that includes minor spall repair, extension of water stops along vertical expansion joints in the exterior
walls and crack injection for the bottom slab (if needed). This will keep water from being pushed out of the Clearwell so less treated water will be lost from the water-treatment process.
On the mechanical side, PWC assumes that all of the existing gate structures and associated equipment will be replaced. Again, the ability to dewater the structure will help determine if some of these gates
may be repaired in place or if some of this equipment such as the existing wall thimbles may be reused. This project has been reviewed and approved by the PWS and coordinated with the ISHB.
Additionally, new membrane curtain-baffle walls will be installed in all tank compartments (except 3B) while the tank is offline. The Clearwell baffle walls are similar to a maze structure forcing the water to
travel a specific path prior to leaving the plant, and serve to prevent short-circuiting of flow and thereby
enhance finished water quality.
7 Summary and Conclusions
In summary, regarding the risk posed to water quality in the clearwell from the contaminant plume, the
available lines of evidence show that:
1.Calculations and data show outward pressure of water from the Clearwell into the surroundingvadose and saturated zones. The outward pressure of the Clearwell is the primary reason the TexfiSite was issued NFRAP status by EPA in 2000; and these outward pressure conditions have not
changed. Based on the amount of water in the toe drain that surrounds the Clearwell under dryweather conditions, plus the presence of a DBP in the single toe-drain sample collected in 2009,
treated water from the Clearwell is entering the toe drain. During normal operating conditions,
and down to a Clearwell water depth of approximately 0.5 feet, outward pressure from the watercontained in the Clearwell prevents groundwater from entering the structure. Just the opposite is
occurring – some treated water is being forced from the Clearwell into the surrounding soil.
2.Notwithstanding the outward pressure, the short residence time of water within the Clearwell(less than 12 hours and the large volume of water that is treated each day, does not allow for the
small amount of diffusion of PCE that might occur through the lowermost portion of the
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DUNCKLEE & DUNHAM, P.C. DD
Clearwell concrete walls/slab, if it is indeed saturated, to degrade the large volume of treated water.
3.PWC has set forth voluntary guidelines to operate the water treatment plant so that there is at
least a minimum depth of seven feet in the Clearwell. This is 6.5 feet above the conservatively-calculated minimum depth of 0.5 feet that is associated with the highest inward pressure from the
saturated and unsaturated soil surrounding the bottom half of the Clearwell structure. Any
changes to these guidelines will be coordinated with the PWS Section.
4.The TBA MIP data shows that in most aspects the slurry wall has worked as designed – to stop
the flow of contaminated groundwater in the surficial sand aquifer to protect the Clearwell. There
may have been some groundwater flow around the eastern end of the slurry wall, which wouldhave been exacerbated by recovery well pumping. Now that the recovery wells are no longer
pumping, however, it appears the toe-drain system surrounding the Clearwell also influences the
flow of groundwater around the eastern end of the slurry wall.
5.The MIP data shows the majority of COC contaminant mass remains on the former Texfi Site,
mostly within the upper non-confining clay layer underneath the surficial sandy aquifer unit. The
MIP cross sections and physical properties of the COCs indicate the potential for contaminants tocontinue to migrate downgradient and under the base of the slurry wall. However, the base of the
Clearwell is between four and nine feet higher in elevation than the base of the slurry wall.
6.Similarly, the MIP data around the Clearwell indicates most of the COC mass is in the upper non-confining clay layer, beneath the surficial aquifer and below the elevation of the base of the
Clearwell slab. The COCs have a higher density than water and will migrate vertically as long assufficient permeability and coarser-grained heterogeneity continue in the clay layer.
7.The least separation between the contamination noted in the MIP borings and the top of the
Clearwell slab is approximately three feet. MW-24S, screened 4-9 feet bgs provides evidencethat there is shallower contamination near the northeast corner of the Clearwell. However, there
is evidence that both the shallow sand and the non-confining clay aquifers are discharging to the
toe drain, which lies between this area of shallower contamination and the Clearwell.
8.Water in the Clearwell has been routinely sampled since 2001; it was sampled on a weekly basis
from May 31, 2001 through 2005, and monthly since that time. In over 200 water samples taken
in the Clearwell taken since mid-2001, there have only been three occasions where any COCother than disinfection byproducts have been detected, all at concentrations below drinking water
standards. Based on the sporadic low levels of different contaminants, which, when re-sampled
were below detection limits, the PWS Section and the IHSB indicated that these detections ofnon-DBP constituents were not representative and no further action was required.
9.A Regenesis extended-release substrate (HRC-X™) chosen for its longevity was injected into thesurficial aquifer at the Texfi Site and PWC property in late May 2012 in a limited area northeastof the Clearwell. The intent of this measure is to decrease the surficial aquifer contaminant
concentrations near the Clearwell and in the area around the edge of the slurry wall.
For these reasons, we concluded that (i) water quality in the Clearwell has not been impacted by the
contaminant plume, and (ii) should not be impacted by the plume going forward so long as voluntary
guidelines for maintaining a minimum depth of water in the Clearwell, which maintains the outward water pressure in the Clearwell, continue to be followed.
Evaluation of Risk to the Public Works Commission Clearwell 601 Hoffer Drive Fayetteville, North Carolina
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DUNCKLEE & DUNHAM, P.C. DD
Further, the risk posed by the contaminant plume to water quality in the Clearwell has been sufficiently evaluated and no further assessment or action to further mitigate that risk is warranted at this time. Furthermore, the City’s planned uses of the Texfi Site will not increase that risk.
Additionally, the following operational strategies that will be used to further protect the treated-water
while stored in the Clearwell:
1.When the Clearwell is being emptied for construction or inspection, PWC will stop pumping into
the distribution system once the self-imposed seven-foot depth in the Clearwell is reached. Any
water pumped into the distribution below the seven foot level will be coordinated with the PWSSection to ensure safety of the public.
2.PWC will start rehabilitation of the Clearwell as soon as the bypass pipe can be installed.
Funding is in place, the design work is finalized, and contractors plan to begin work on thebypass pipe later this summer with completion anticipated in late spring 2013
Also, although the draft BFA does not call for any active remediation at the Site, the City plans to conduct a proton reduction (hydrolysis) pilot study near the MW-12 monitoring well cluster east of the former
Texfi manufacturing plant this summer to try to obtain a proof of principle that this remediation strategy will be effective at the Site. This technology is particularly suitable for use in low permeability aquifers and is very inexpensive to operate.
The City also plans to apply for EPA Brownfields cleanup grant(s) this fall to seek funding implement the
hydrolysis remedy if the pilot study results are favorable. The grant funding will also be used to remove
asbestos-containing materials in the former Texfi manufacturing building so demolition of the building can be performed.
Figures

Source Map: U.S.G.S. Vander 7.5-Minute Quadrangle
Approximate Scale:
1” = 2000’
Title: Site Location Map DD DUNCKLEE & DUNHAM, P.C.
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE – SUITE 102
CARY, NORTH CAROLINA 27518
Figure:
1
Project: Former Tex-Fi Facility
Fayetteville, North Carolina

Figure 3Total Detected VOC vs. TimeGW-22000025000300003500040000ed VOC (ug/l)AFigure 3050001000015000200001/30/2001 2/7/2001 5/8/2002 7/16/2002 6/24/2003 7/10/2006 2/4/2008 3/24/2009 6/2/2009GW-2Total DetecteDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
Figure 20 Transect View Looking North, Soil Conductivity Response January 30th, 2012 – February 8th, 2012 Copyright © 2012, Columbia Technologies, LLC. All Rights Reserved
Figure 21 Transect View Looking East, Soil Conductivity Response January 30th, 2012 – February 8th, 2012Copyright © 2012, Columbia Technologies, LLC. All Rights Reserved
PIDPHOTOIONIZATION DETECTOR (PID) RESPONSES 6.0E+8 uV5.0E+7 uV1.0E+7 uV7.5E+6 uV5.0E+6 uV4.0E+6 uV3.0E+6 uV2.0E+6 uV1.0E+6 uV7.5E+5 uV5.0E+5 uV2.5E+5 uV0485,400.0485,200.0485,000.0484,800.0484,600.0-40.0-30.0-20.0-10.00.0MIP-1HPT-3
MIP-10
MIP-6
HPT-14
MIP-38
MIP-39
MIP-34
HPT-1MIP-2
DEPTH (FEET BGS)ANORTHA'SOUTHNOTES:1. PID DATA IMAGE PROVIDED BY COLUMBIA TECHNOLOGIES, INC.2. GROUND SURFACE THROUGHOUT THE STUDY AREA HAS AN ASSUMEDREFERENCE ELEVATION OF 0 FEET.MW-10
MW-6R53450LEGEND:MONITORING WELLSCREENED INTERVALTOTAL VOC CONCENTRATION (µg/L)(FEBRUARY 2012)MIPPIDVOCMEMBRANE INTERFACE PROBEPHOTOIONIZATION DETECTORVOLATILE ORGANIC COMPOUNDDEPTH TO WATER (FEBRUARY 2011)5345020592(µg/L) MICROGRAMS PER LITER
SCALE:DATE:PROJECT NUMBER:SHEET NUMBER:FIGURE NUMBER:DESIGNED BY:
DRAWN BY:
APPROVED BY:
CHECKED BY:
REVISIONS
NO.:DATE: BY:DESCRIPTION:
FAX: [phone]
PHONE: [phone]
WEB: HTTP://WWW.AECOM.COM
RALEIGH, NORTH CAROLINA 27615
AECOM North Carolina, Inc.
8540 COLONNADE CENTER DRIVE, SUITE 306
-40.0-30.0-20.0-10.00.0DEPTH (FEET BGS)B'SOUTHNOTES:1. PID DATA IMAGE PROVIDED BY COLUMBIA TECHNOLOGIES, INC.2. GROUND SURFACE THROUGHOUT THE STUDY AREA HAS AN ASSUMEDREFERENCE ELEVATION OF 0 FEET.485,400.0485,200.0485,000.0484,800.0PIDPHOTOIONIZATION DETECTOR (PID) RESPONSES 6.0E+8 uV5.0E+7 uV1.0E+7 uV7.5E+6 uV5.0E+6 uV4.0E+6 uV3.0E+6 uV2.0E+6 uV1.0E+6 uV7.5E+5 uV5.0E+5 uV2.5E+5 uV0BNORTHMIP-21HPT-2MIP-18MIP-13
MIP-17
MIP-16
MIP-14
HPT-6
MIP-15
MW-24C
HPT-12
MIP-107
MIP-102
MIP-105
IP-106
MIP-33
MW-23
MIP-101
MW-31C415.5LEGEND:MONITORING WELLSCREENED INTERVALMIPPIDVOCMEMBRANE INTERFACE PROBEPHOTOIONIZATION DETECTOR(µg/L) MICROGRAMS PER LITERTOTAL VOC CONCENTRATION (µg/L)(FEBRUARY 2012)VOLATILE ORGANIC COMPOUNDDEPTH TO WATER (FEBRUARY 2011)58250.6415.59.5SCALE:DATE:PROJECT NUMBER:SHEET NUMBER:FIGURE NUMBER:DESIGNED BY:
DRAWN BY:
APPROVED BY:
CHECKED BY:
REVISIONS
NO.:DATE: BY:DESCRIPTION:
FAX: [phone]
PHONE: [phone]
WEB: HTTP://WWW.AECOM.COM
RALEIGH, NORTH CAROLINA 27615
AECOM North Carolina, Inc.
8540 COLONNADE CENTER DRIVE, SUITE 306
2,039,800.02,039,400.02,039,600.0NOTES:1. PID DATA IMAGE PROVIDED BY COLUMBIA TECHNOLOGIES, INC.2. GROUND SURFACE THROUGHOUT THE STUDY AREA HAS AN ASSUMEDREFERENCE ELEVATION OF 0 FEET.PIDPHOTOIONIZATION DETECTOR (PID) RESPONSES 6.0E+8 uV5.0E+7 uV1.0E+7 uV7.5E+6 uV5.0E+6 uV4.0E+6 uV3.0E+6 uV2.0E+6 uV1.0E+6 uV7.5E+5 uV5.0E+5 uV2.5E+5 uV0CWESTMIP-38
HPT-15
MIP-39
MIP-101
HPT-12
HPT-13
MIP-107
HPT-10
MIP-29
-40.0-30.0-20.0DEPTH (FEET BGS)2,040,000.0-10.00.0C'EASTMW-25C
MW-23
MW-24C2691.6LEGEND: MONITORING WELLSCREENED INTERVALMIPPIDVOCMEMBRANE INTERFACE PROBEPHOTOIONIZATION DETECTOR(µg/L) MICROGRAMS PER LITERTOTAL VOC CONCENTRATION (µg/L)(FEBRUARY 2012)VOLATILE ORGANIC COMPOUNDDEPTH TO WATER (FEBRUARY 2011)2691.658250.6415.5SCALE:DATE:PROJECT NUMBER:SHEET NUMBER:FIGURE NUMBER:DESIGNED BY:
DRAWN BY:
APPROVED BY:
CHECKED BY:
REVISIONS
NO.:DATE: BY:DESCRIPTION:
FAX: [phone]
PHONE: [phone]
WEB: HTTP://WWW.AECOM.COM
RALEIGH, NORTH CAROLINA 27615
AECOM North Carolina, Inc.
8540 COLONNADE CENTER DRIVE, SUITE 306
TEXFIAbandoned Heating Oil UST'sDrainage DitchMH-1MW-2786.83GW-786.41GW-885.94GW-1NMGW-985.73GW-1084.35GW-1183.84GW-3386.95GW-3187.06Slurry WallGW-2884.54GW-2984.38GW-3086.76GW-1285.54GW-284.30MH-2GW-1682.69GW-1584.93GW-1485.36GW-1782.84GW-1884.97GW-2585.20MH-3RW-385.33FormerGasolineUSTsGW-19NMGW-2485.45GW-2385.46GW-2185.21GW-2285.32GW-4NMGW-2684.35GW-2081.99GW-385.51GW-683.72GW-5ANMGW-5NMGW-1385.67MW-2NMRW-185.81RW-285.03GW-32NMApproximateSurface WaterIntake LocationNote: Groundwater Elevations Measured on 6/2/09ClearwellLEGENDMonitoring WellRecovery WellSewer ManholePiezometerRiverSlurry WallClearwell BoundaryDrainage DitchFencePotentiometric Contour LineInferred Pontentiometric Contour LineBuilding FootprintFigure 2Groundwater Contour Map86868484848483831 inch = Approximately 100 feet8582828583838787
Appendix A
Table 1Summary of Groundwater Field Parameters - Select PiezometersTexfi Interim Remedial MeasuresAdditional Groundwater Sampling - June 2009Sampling Date: January 30, 2001February 7, 2001 September 13, 2001May 8, 2002July 16, 2002June 24, 2003Temporary Well pH Conductivity Temp. pH Conductivity Temp. pH Conductivity Temp. pH Conductivity Temp. pH Conductivity Temp. pH Conductivity Temp.Designation (SU) (mS) (deg. C) (SU) (mS) (deg. C) (SU) (mS) (deg. C) (SU) (mS) (deg. C) (SU) (mS) (deg. C) (SU) (mS) (deg. C)PWC-GW-1 6.28 456 15.2 5.65 441 14.0 5.93 451 25.6 6.26 405 23.8 NS NS NS NS NS NSPWC-GW-2 (5)5.10 7,540 14.0 5.63 7,700 13.1 NS NS NS 5.66 459 19.8 5.66 1,410 23.8 5.43 2,450 20.9PWC-GW-3 4.37 92 15.6 6.04 106 15.3 6.04 106 15.3 NS NS NS NS NS NS NS NS NSPWC-GW-4 3.98 337 15.4 5.32 316 15.2 NS NS NS NS NS NS NS NS NS NS NS NSPWC-GW-5 -- -- -- -- -- -- NS NS NS NS NS NS NS NS NS NS NS NSPWC-GW-5a NS NS NS NS NS NS 4.90 79 19.8 NS NS NS NS NS NSPWC-GW-6 NS NS NS 5.45 253 16.0 NS NS NS 6.20 94 19.4 NS NS NS NS NS NSPWC-GW-7 5.28 63 13.4 NS NS NS NS NS NS NS NS NS NS NS NSPWC-GW-8 5.68 107 13.7 5.18 50 25.2 -- -- -- NS NS NS NS NS NSPWC-GW-9 5.35 55 13.4 5.10 46 24.8 6.11 54 22.0 NS NS NS NS NS NSPWC-GW-10 -- -- -- NS NS NS NS NS NS NS NS NS NS NS NSPWC-GW-11 5.40 60 11.2 NS NS NS NS NS NS NS NS NS 3.67 54 24.3PWC-GW-12 5.25 37 11.8 5.10 52 24.8 5.52 90 21.6 5.85 102 27.0 NS NS NSPWC-GW-13 5.15 72 12.9 5.23 67 23.9 5.46 65 18.9 NS NS NS NS NS NSPWC-GW-14 5.48 131 12.9 5.28 116 21.9 5.80 125 19.0 NS NS NS NS NS NSPWC-GW-15 5.02 89 12.8 5.46 130 24.5 5.58 181 21.2 NS NS NS NS NS NSPWC-GW-16 5.41 4,510 12.2 5.29 404 24.5 5.55 269 21.6 5.95 292 26.2 5.24 341 23.6PWC-GW-17 5.50 384 12.2 5.10 206 24.2 5.97 202 20.6 NS NS NS 5.01 159 24.4PWC-GW-18 5.25 60 12.9 5.25 60 12.9 5.42 98 19.4 NS NS NS NS NS NSPWC-GW-19 6.60 129 14.5 5.06 82 24.2 NS NS NS NS NS NS NS NS NSPWC-GW-20 -- -- -- NS NS NS NS NS NS NS NS NS NS NS NSPWC-GW-21 -- -- -- NS NS NS NS NS NS NS NS NS NS NS NSPWC-GW-22 6.32 212 14.5 NS NS NS NS NS NS NS NS NS NS NS NSPWC-GW-23 5.18 173 14.7 NS NS NS NS NS NS NS NS NS NS NS NSPWC-GW-24 -- -- -- NS NS NS 5.84 110 20.5 NS NS NS NS NS NSPWC-GW-25 5.25 269 14.5 4.90 141 21.5 5.53 112 18.4 NS NS NS NS NS NSPWC-GW-26 6.1* 250* 14.2* NS NS NS 6.08 78 19.7 NS NS NS NS NS NSPWC-MW-27NS NS NS 4.32 52 23.8PWC-GW-286.04 277 28.6 4.51 105 22.6PWC-GW-29-- -- -- NS NS NSPWC-GW-30NS NS NS NS NS NSPWC-GW-316.36 1,690 27.6 NS NS NSPWC-GW-326.74 642 29.8 NS NS NSPWC-GW-334.49 214 22.6RW-16.53 861 24.5 NS NS NSRW-2NS NS NS NS NS NSRW-3NS NS NS NS NS NSEffluentNotes:1. -- Well sampled, measurement was not recorded2. NS denotes Not Sampled3. Blank fields denote well not yet installed4. * Sample collected on February 13, 20015. PWC-GW-2 replaced with 2-inch monitoring well on May 7, 2002.6. A piezometer with the number 6 painted adjacent to it was used as GW-31 during the February 2008 sampling event. Broken PVC was found adjacent to the original location of GW-31. The piezometer used as GW-31 during the February 2008 event is approximately 8 feet west of the original location.Page 1 of 2Table 1.xls
Table 1Summary of Groundwater Field Parameters - Select PiezometersTexfi Interim Remedial MeasuresAdditional Groundwater Sampling - June 2009Sampling Date:Temporary WellDesignationPWC-GW-1PWC-GW-2 (5)PWC-GW-3PWC-GW-4PWC-GW-5PWC-GW-5aPWC-GW-6PWC-GW-7PWC-GW-8PWC-GW-9PWC-GW-10PWC-GW-11PWC-GW-12PWC-GW-13PWC-GW-14PWC-GW-15PWC-GW-16PWC-GW-17PWC-GW-18PWC-GW-19PWC-GW-20PWC-GW-21PWC-GW-22PWC-GW-23PWC-GW-24PWC-GW-25PWC-GW-26PWC-MW-27PWC-GW-28PWC-GW-29PWC-GW-30PWC-GW-31PWC-GW-32PWC-GW-33RW-1RW-2RW-3EffluentJuly 10, 2006February 4, 2008March 25, 2009June 2, 2009pH Conductivity Dissolved Oxygen ORP Temp. pH Conductivity Dissolved Oxygen ORP Temp. pH Conductivity Dissolved Oxygen Turb ORP Temp. pH Conductivity Dissolved Oxygen Turb ORP Temp.(SU) (mS) (mg/L) (mv) (deg. C) (SU) (mS) (mg/L) (mv) (deg. C) (SU) (mS) (mg/L) (NTU) (mv) (deg. C) (SU) (mS) (mg/L) (NTU) (mv) (deg. C)NS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NS5.62 1810.64 193 20.8 4.87 2080.75 45.6 16.6 4.95 1640.99 6 217.9 14.3 4.45 4850.37 6 106.8 17.7NS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS 4.73 553.87 56.9 14.6 NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NS3.67 5424.3 NS NSNS NS NS 5.34 504.90 327 75.3 14.2 8.73 484.55 27 60.1 22.05.94 708.17 -2 21.2 NS NSNS NS NS 4.60 626.64 550 80.2 12.6 4.58 551.83 764 66.7 19.55.39 895.15 271 21.4 4.52 1263.19 53.2 13.8 4.86 1081.50 11 206.5 13.0 4.89 931.37 14 100.7 17.8NS NSNS NS NSNS NS NS 4.90 545.19 9 263.8 11.7 NS NSNS NS NS NSNS NSNS NS NSNS NS NS 4.95 853.51 321 160.6 12.1 3.92 1041.03 407 121.5 19.45.24 34123.6 NS NSNS NS NS 6.16 2233.01 192 21.9 13.5 6.07 2531.10 150 43.4 21.25.01 15924.4 NS NSNS NS NS 5.87 1821.61 864 56.1 11.4 6.74 1771.60 350 75.6 21.4NS NSNS NS NSNS NS NS 4.85 871.33 143 113.8 12.1 NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NSNS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NS4.32 5223.8 3.86 480.67 50.7 16.3 NS NSNS NS NS NS NS NSNS NS NS NS4.51 10522.6 NS NSNS NS 22.6 5.43 873.54 90 191.8 13.5 4.9 1181.45 45 120.7 19.6NS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NS6.93 4022.84 -65 22.5 5.12 1362.91 49.0 14.6 6.04 2652.41 923 252.2 14.6 5.91 1632.53 195 1.2 20.2NS NSNS 5.32 2230.41 31.0 15.8 5.45 1271.69 14 200.9 15.1 5.44 1430.80 2 91.8 21.7NS NSNS NS NSNS NS NS NS NSNS NS NS NS NS NSNS NS NS NS4.49 21422.6 5.26 2650.79 44.7 14.9 5.5 1882.47 11 221.8 14.1 NS NSNS NS NS NSNS NSNS NS NS 5.97 2881.48 47.1 20.7 6.6 4151.24 8 159.2 13.2 6.65 5360.22 11 -74.6 17.3NS NSNS NS NS 5.30 2751.57 52.9 17.1 5.26 982.41 51 218.4 10.9 5.47 1050.25 17 74 15.6NS NSNS NS NS 5.39 1683.28 55.7 16.9 5.78 3761.54 12 216.3 12.6 NS NSNS NS NS NS5.19 2691.52 54.2 19.5 6.42 2199.64 80 274.8 12.8 NS NSNS NS NS NSNotes:1. -- Well sampled, measurement was not recorded2. NS denotes Not Sampled3. Blank fields denote well not yet installed4. * Sample collected on February 13, 20015. PWC-GW-2 replaced with 2-inch monitoring well on May 7, 2002.6. A piezometer with the number 6 painted adjacent to it was used as GW-31 during the February 2008 sampling event. Broken PVC was found adjacent to the original location of GW-31. The piezometer used as GW-31 during the February 2008 event is approximately 8 feet west of the original location.Page 2 of 2Table 1.xls
Table 2Summary of Groundwater Analytical Results - Select PiezometersTexfi Interim Remedial MeasuresAdditional Groundwater Sampling - June 2009Sample Location Sample DateAcetoneBromodichlormethaneChloroformChloromethaneBenzenen-PropylbenzeneChlorobenzene1,2-Dichlorobenzene1,3-Dichlorobenzene1,4-Dichlorobenzene1,2,4-TrichlorobenzeneToluene2-Chlorotoluene4-Chlorotoluene1,1-Dichloroethene1,1-Dichloroethane1,1,2-Trichloroethanecis-1,2-Dichloroethenetrans-1,2-DichloroetheneTetrachloroetheneTrichloroetheneVinyl ChlorideTotal Xylenes700 0.56 70 2.6 1 70 50 24 170 1.47011,000 140 NA 7 700.6170 100 0.7 2.8 0.015 530PWC-GW-1 30-Jan-01667-Feb-010.5260.827.313-Sep-01227-May-0211PWC-GW-2 30-Jan-0117,00013333,70020,7007-Feb-0120,0003,90023,9008-May-022,3007,900 710190310,91016-Jul-029,8003,200 830 1,10014,93024-Jun-032914065286795,60063410 260 6807,30610-Jul-0641.5 2.663.25 11.73.235.81,3609.9380 60 661,6444-Feb-081.14J4.281.4J1.06J1,52012.41,010 267 322,846duplicate4-Feb-081.3251.81.321,46017.81,020 250 372,79424-Mar-092.39298.06779 191 131,9222-Jun-0935.75,6804226,400 3,670 18336,011PWC-GW-3 30-Jan-0107-Feb-01 6610.5267.513-Sep-011.5PWC-GW-4 30-Jan-0111510 6327-Feb-0111612 736PWC-GW-5 30-Jan-0107-Feb-01 87188PWC-GW-5a 7-May-020PWC-GW-6 7-Feb-017407407-May-0238680718PWC-GW-7 6-Feb-010PWC-GW-8 6-Feb-01013-Sep-0107-May-020NC2L StandardTotal Volatiles (ppb)Volatiles - EPA Method 8260BAPage 1 of 5Table 2.xls
Table 2Summary of Groundwater Analytical Results - Select PiezometersTexfi Interim Remedial MeasuresAdditional Groundwater Sampling - June 2009Sample Location Sample DateAcetoneBromodichlormethaneChloroformChloromethaneBenzenen-PropylbenzeneChlorobenzene1,2-Dichlorobenzene1,3-Dichlorobenzene1,4-Dichlorobenzene1,2,4-TrichlorobenzeneToluene2-Chlorotoluene4-Chlorotoluene1,1-Dichloroethene1,1-Dichloroethane1,1,2-Trichloroethanecis-1,2-Dichloroethenetrans-1,2-DichloroetheneTetrachloroetheneTrichloroetheneVinyl ChlorideTotal Xylenes700 0.56 70 2.6 1 70 50 24 170 1.47011,000 140 NA 7 700.6170 100 0.7 2.8 0.015 530NC2L StandardTotal Volatiles (ppb)Volatiles - EPA Method 8260BPWC-GW-9 6-Feb-0133613-Sep-0107-May-0204-Feb-080PWC-GW-10 7-Feb-01330.526.5PWC-GW-11 6-Feb-010.82121.824-Jun-0324-Mar-09112-Jun-090PWC-GW-12 6-Feb-010.720.713-Sep-0108-May-02815 42716-Jul-02821010-Jul-0612.255 1.186 21.5175.824-Mar-092.12.11.095.293-Jun-092.481.273.75PWC-GW-13 6-Feb-016613-Sep-01118-May-021110-Jul-0648.42.150.54-Feb-08024-Mar-0903-Jun-090PWC-GW-14 6-Feb-01959513-Sep-01314358-May-0213313525-Mar-090PWC-GW-15 6-Feb-011011113-Sep-012552597-May-026136425-Mar-091791.112.6 11.6204.32-Jun-091321.386.92 11.3151.6APage 2 of 5Table 2.xls
Table 2Summary of Groundwater Analytical Results - Select PiezometersTexfi Interim Remedial MeasuresAdditional Groundwater Sampling - June 2009Sample Location Sample DateAcetoneBromodichlormethaneChloroformChloromethaneBenzenen-PropylbenzeneChlorobenzene1,2-Dichlorobenzene1,3-Dichlorobenzene1,4-Dichlorobenzene1,2,4-TrichlorobenzeneToluene2-Chlorotoluene4-Chlorotoluene1,1-Dichloroethene1,1-Dichloroethane1,1,2-Trichloroethanecis-1,2-Dichloroethenetrans-1,2-DichloroetheneTetrachloroetheneTrichloroetheneVinyl ChlorideTotal Xylenes700 0.56 70 2.6 1 70 50 24 170 1.47011,000 140 NA 7 700.6170 100 0.7 2.8 0.015 530NC2L StandardTotal Volatiles (ppb)Volatiles - EPA Method 8260BPWC-GW-16 6-Feb-0123,0009,000 3,000 1,60036,60013-Sep-013,20063632303,4307-May-026902312081016-Jul-021,30053431301,43924-Jun-0331 4311,300102701,59224-Mar-091.411.132.21,4103.171.081491,5682-Jun-0929968.5368PWC-GW-17 6-Feb-011701318313-Sep-01210102207-May-02110511524-Jun-0311702 3 38025-Mar-0978.618.2 4.29 2.52103.612-Jun-0998.226 6.83 2.78133.81PWC-GW-18 6-Feb-01013-Sep-0108-May-02025-Mar-092.562.56PWC-GW-19 7-Feb-010PWC-GW-20 13-Feb-01121PWC-GW-21 7-Feb-010.520.5PWC-GW-22 7-Feb-0172311 748PWC-GW-23 7-Feb-010PWC-GW-24 7-Feb-0120.8223310.88-May-02145414PWC-GW-25 7-Feb-011,3001,30013-Sep-011431188-May-0292112PWC-GW-26 13-Feb-010.72462 12.78-May-022015 1247APage 3 of 5Table 2.xls
Table 2Summary of Groundwater Analytical Results - Select PiezometersTexfi Interim Remedial MeasuresAdditional Groundwater Sampling - June 2009Sample Location Sample DateAcetoneBromodichlormethaneChloroformChloromethaneBenzenen-PropylbenzeneChlorobenzene1,2-Dichlorobenzene1,3-Dichlorobenzene1,4-Dichlorobenzene1,2,4-TrichlorobenzeneToluene2-Chlorotoluene4-Chlorotoluene1,1-Dichloroethene1,1-Dichloroethane1,1,2-Trichloroethanecis-1,2-Dichloroethenetrans-1,2-DichloroetheneTetrachloroetheneTrichloroetheneVinyl ChlorideTotal Xylenes700 0.56 70 2.6 1 70 50 24 170 1.47011,000 140 NA 7 700.6170 100 0.7 2.8 0.015 530NC2L StandardTotal Volatiles (ppb)Volatiles - EPA Method 8260BPWC-MW-27 7-Jun-01019-Sep-01014-Jan-02020-May-0205-Sep-021124-Jun-0304-Feb-080PWC-GW-28 16-Jul-024805515355024-Jun-0371812624-Mar-096.54.4910.992-Jun-094.624.62PWC-GW-29 17-Jul-026,7008,100 450 23015,480PWC-GW-30 5-Sep-026 26344729 6,000275,900 2,400 28014,66810-Jul-0617.91.481.41.339364.55370 93 86.81,5134-Feb-081.097994.22169 54 1051,13224-Mar-097572.28239 67 45.11,1103-Jun-091.031.527816.1630 27 23.4870PWC-GW-31 16-Jul-0214,000900 430 1,30016,6304-Feb-085.643,8909.96141 70.1 36.74,153duplicate4-Feb-086.364,62013.1232 91.7 40.85,00425-Mar-091,740446 148 5.22,3392-Jun-091,7504.92724 370 13.02,862PWC-GW-32 16-Jul-0228,0007031832,40030,488PWC-GW-33 24-Jun-0312704110 14 94084-Feb-082,7808.24784 235 18.83,82625-Mar-091,8206.08523 1212,470RW-1 4-Jun-01350140 43 5159416-Jul-0215,0007,500 1,80061324,3614-Feb-083,080115,340 1,040 69.69,54125-Mar-092,4602,470 744 85,682(filtered) 25-Mar-092,6804.642,710 770 5.286,1702-Jun-094,9909.361,270 672 50.66,992APage 4 of 5Table 2.xls
Table 2Summary of Groundwater Analytical Results - Select PiezometersTexfi Interim Remedial MeasuresAdditional Groundwater Sampling - June 2009Sample Location Sample DateAcetoneBromodichlormethaneChloroformChloromethaneBenzenen-PropylbenzeneChlorobenzene1,2-Dichlorobenzene1,3-Dichlorobenzene1,4-Dichlorobenzene1,2,4-TrichlorobenzeneToluene2-Chlorotoluene4-Chlorotoluene1,1-Dichloroethene1,1-Dichloroethane1,1,2-Trichloroethanecis-1,2-Dichloroethenetrans-1,2-DichloroetheneTetrachloroetheneTrichloroetheneVinyl ChlorideTotal Xylenes700 0.56 70 2.6 1 70 50 24 170 1.47011,000 140 NA 7 700.6170 100 0.7 2.8 0.015 530NC2L StandardTotal Volatiles (ppb)Volatiles - EPA Method 8260BRW-2 4-Jun-01810 9,400 69010,9004-Feb-082,40025.618,200 1,750 18622,56225-Mar-093264.121,660 79.22,069(filtered) 25-Mar-093231.98839 71.02.19 1,237**4-Apr-0993350 16.2459**29-May-093223.35773 48.61,1473-Jun-093901,650 1142,154RW-3 4-Jun-015405404-Feb-0810.215.76.121.393325-Mar-093.672.539.31.1447(filtered) 25-Mar-093.531.817.423Manhole #2 24-Mar-097.511915.153.60 7.72103Notes:All results in ug/l (ppb)NA - Not EstablishedBlanks - Not Detected (below detection limits)NS - No Sample Collected1 - Interim Standard2 - Estimated (J) value3 - Data generated from a GC/MS screening run, not by 8260. The data, while qualitatively correct, provides only estimated concentrations.** - Samples collected by PWC personnelShading indicates exceedence of NC2L or Groundwater Protection Standard.Samples analyzed by SGS Environmental Inc.A piezometer with the number 6 painted adjacent to it was used as GW-31 during the February 2008 sampling event.Broken PVC was found adjacent to the original location of GW-31.The piezometer used as GW-31 during the February 2008 event is approximately 8 feet west of the original location.APage 5 of 5Table 2.xls
Table 3Groundwater ElevationsTexfi Interim Remedial MeasuresLocation TOC Elevation Ground ElevationGW Elevation 5/8/2001GW Elevation 5/31/2001GW Elevation 6/28/2001GW Elevation 7/26/2001GW Elevation 8/16/2001GW Elevation 9/13/2001GW Elevation 10/25/2001GW Elevation 11/15/2001GW Elevation 12/13/2001GW Elevation 1/28/2002GW Elevation 2/25/2002PWC-GW-192.3792.3385.27 84.82 85.43 NM 83.76 84.67 83.93 83.72 83.92 85.88 84.72PWC-GW-2*94.5292.1787.17 Damaged 86.67 Damaged Damaged Damaged Damaged Damaged Damaged Damaged DamagedPWC-GW-394.0693.8385.57 85.22 85.99 85.45 85.33 85.28 84.64 84.32 84.24 85.79 85.66PWC-GW-492.5292.4285.23 84.72 85.69 NM 84.74 84.72 84.17 83.92 83.82 85.60 85.10PWC-GW-589.5988.9575.85 75.97 76.80 76.85 76.71 76.81 76.27 75.74 75.64 75.92 75.83PWC-GW-5a89.4588.9076.51 76.7 79.30 79.27 77.85 79.81 77.66 76.45 77.15 82.05 79.87PWC-GW-692.8192.53NM 83.51 83.88 83.59 83.45 83.54 83.26 83.15 83.16 84.01 83.90PWC-GW-793.4492.5586.54 86.49 87.12 87.1 86.87 86.80 86.09 85.78 85.83 86.16 85.87PWC-GW-893.6192.6186.11 85.25 86.00 86.00 85.59 85.51 84.84 84.58 84.66 85.25 85.76PWC-GW-992.5791.8385.02 85.49 85.54 86.11 85.08 84.85 84.02 83.87 83.52 85.32 83.86PWC-GW-1093.4692.5784.26 84.31 84.58 84.78 84.25 84.14 83.72 83.61 83.78 84.76 83.29PWC-GW-1194.1593.3183.15 83.23 83.28 83.33 83.24 83.20 83.13 83.13 82.4 83.30 82.50PWC-GW-1291.0790.3585.07 84.75 84.87 84.96 84.56 84.25 83.94 83.89 83.97 84.90 84.61PWC-GW-1391.8891.50NMNM 85.88 84.61 85.26 85.17 84.76 84.57 84.43 85.68 85.49PWC-GW-1490.7590.44NM 84.82 85.47 NM 84.77 84.72 84.33 84.13 84.05 84.90 85.04PWC-GW-1590.4990.0084.19 83.21 83.51 84.37 83.54 82.84 82.75 82.69 82.69 83.07 83.15PWC-GW-1694.9693.1882.86 82.76 82.84 83.16 83.11 83.00 82.70 82.75 82.76 82.92 83.04PWC-GW-1794.9793.4782.87 82.72 82.84 82.80 82.72 82.65 82.51 82.63 82.57 82.85 82.86PWC-GW-1890.2589.7984.95 84.41 85.05 84.86 84.47 84.40 83.94 83.76 83.75 84.53 84.74PWC-GW-1992.6890.8583.88 83.88 84.37 84.34 83.91 83.98 83.68 83.43 83.82 84.47 84.04PWC-GW-2090.8489.5580.74 80.74 81.00 81.10 81.09 81.16 81.06 80.84 80.75 81.29 81.32PWC-GW-2191.4489.6985.53 85.13 86.16 86.03 85.41 85.35 84.77 84.39 84.51 86.55 85.55PWC-GW-2293.6392.3785.42 84.94 85.65 85.28 84.91 84.85 84.36 84.15 84.03 85.03 85.18PWC-GW-2393.0891.3485.53 85.34 85.74 85.73 85.51 85.46 84.97 84.61 84.73 85.82 85.61PWC-GW-2493.5391.6285.44 85.00 84.80 84.38 84.09 84.11 83.51 83.17 83.05 83.44 84.01PWC-GW-2592.5690.8585.36 84.52 84.98 84.89 84.45 84.41 83.96 83.78 83.71 84.14 84.68PWC-GW-2692.8991.2384.41 83.30 84.68 84.58 84.29 84.37 84.13 83.87 83.76 84.80 84.50PWC-MW-2794.9692.20PWC-GW-2894.1592.32PWC-GW-2993.4291.41PWC-GW-3092.5490.44PWC-GW-3193.6891.86PWC-GW-31 (6) 93.3691.86PWC-GW-3294.8292.76PWC-GW-3393.8691.86MW-296.5793.87NMNM 86.02 85.71 85.50 85.45 84.88 84.55 84.71 85.99 85.68RW-193.08----84.08 82.68 79.87 80.08 79.58 80.53 79.17 79.08 79.38 79.28RW-292.44----83.39 83.59 84.35 83.54 79.24 79.24 79.06 78.84 79.49 80.74RW-394.14----83.64 82.39 84.64 83.46 78.84 78.63 78.64 79.04 79.29 79.64Notes:- All elevations are in feet.-- Indicates wells not yet installed.- Slurry wall installation completed 5-10-01.- Initiation of Recovery Well Pumps on 5-24-01.- GW-1, 4, 19, 31, and 32 were not located during the February 2008 sampling event.- A piezometer with the number 6 painted adjacent to it was used as GW-31 during the February 2008 sampling event. A TOC elevation of 2-feet above ground surface was assumed to calculate the groundwater elevation.*-PWC-GW-2 replaced with 2" monitoring well on May 7, 2002. **Groundwater elevation was calculated using the ground elevation.***Piezometer GW-30 was broken 4.13-inches below ground elevation. APage 1 of 3Table 3.xls
Table 3Groundwater ElevationsTexfi Interim Remedial MeasuresLocation TOC Elevation Ground ElevationPWC-GW-192.3792.33PWC-GW-2*94.5292.17PWC-GW-394.0693.83PWC-GW-492.5292.42PWC-GW-589.5988.95PWC-GW-5a89.4588.90PWC-GW-692.8192.53PWC-GW-793.4492.55PWC-GW-893.6192.61PWC-GW-992.5791.83PWC-GW-1093.4692.57PWC-GW-1194.1593.31PWC-GW-1291.0790.35PWC-GW-1391.8891.50PWC-GW-1490.7590.44PWC-GW-1590.4990.00PWC-GW-1694.9693.18PWC-GW-1794.9793.47PWC-GW-1890.2589.79PWC-GW-1992.6890.85PWC-GW-2090.8489.55PWC-GW-2191.4489.69PWC-GW-2293.6392.37PWC-GW-2393.0891.34PWC-GW-2493.5391.62PWC-GW-2592.5690.85PWC-GW-2692.8991.23PWC-MW-2794.9692.20PWC-GW-2894.1592.32PWC-GW-2993.4291.41PWC-GW-3092.5490.44PWC-GW-3193.6891.86PWC-GW-31 (6) 93.3691.86PWC-GW-3294.8292.76PWC-GW-3393.8691.86MW-296.5793.87RW-193.08--RW-292.44--RW-394.14--Notes:- All elevations are in feet.-- Indicates wells not yet installed.- Slurry wall installation completed 5-10-01.- Initiation of Recovery Well Pumps on 5-24-01.- GW-1, 4, 19, 31, and 32 were not located during the February 2008 sampling event.- A piezometer with the number 6 painted adjacent to it was used as GW-31 during the February 2008 sampling event. A TOC elevation of 2-feet above ground surface was assumed to calculate the groundwater elevation.*-PWC-GW-2 replaced with 2" monitoring well on May 7, 2002. **Groundwater elevation was calculated using the ground elevation.***Piezometer GW-30 was broken 4.13-inches below ground elevation. GW Elevation 3/18/2002GW Elevation 4/22/2002GW Elevation 5/8/2002GW Elevation 6/17/2002GW Elevation 7/17/2002GW Elevation 8/19/2002GW Elevation 9/23/2002GW Elevation 10/28/2002GW Elevation 11/26/2002GW Elevation 12/30/2002GW Elevation 2/04/200384.42 84.24 84.27 83.82 84.16 83.93 85.00 84.89 86.71 86.45 87.16Damaged Damaged 82.13 82.53 82.50 82.16 82.51 82.63 83.10 83.63 84.1785.44 85.56 85.21 84.41 84.03 83.86 83.83 84.15 85.21 85.7 85.3784.87 84.94 84.52 83.97 83.66 83.52 83.48 83.40 84.46 85.09 84.6375.80 75.96 75.74 75.67 75.79 75.90 76.54 76.17 76.64 76.27 75.7779.42 79.19 82.00 78.19 81.17 83.35 82.47 83.20 83.69 83.64 83.5383.80 83.86 83.56 83.03 82.91 83.11 83.19 83.11 83.63 83.91 83.7086.57 86.46 86.44 85.93 86.19 86.13 86.19 88.42 90.69 87.92 89.0985.45 85.31 85.09 84.72 84.91 84.79 85.56 86.53 88.81 87.78 89.0384.57 84.31 84.12 84.07 84.58 84.47 84.22 83.77 86.22 86.12 86.5484.03 83.89 84.01 83.7 83.91 83.74 84.26 83.91 85.00 84.95 85.0483.15 83.14 83.20 83.12 83.20 83.13 83.25 82.52 83.37 83.26 83.2584.52 84.30 84.05 83.77 83.92 83.89 84.35 84.15 84.82 85.32 85.2585.35 85.42 85.12 84.58 84.37 84.33 83.92 84.42 85.18 85.64 85.4184.95 85.11 84.57 84.05 83.77 83.70 84.03 83.77 84.51 85.01 85.0183.01 82.95 82.84 82.69 82.64 82.54 82.04 82.60 82.94 83.26 82.6182.96 82.94 82.71 82.68 82.61 82.64 82.85 82.75 82.96 83.05 83.0782.75 82.60 82.52 82.4 82.32 82.31 82.36 82.36 82.58 82.91 82.9184.70 83.61 84.20 83.65 83.45 83.35 83.65 83.35 84.25 84.9 84.7984.05 84.41 83.78 83.68 83.52 83.60 84.40 84.72 84.76 85.26 85.1781.36 81.42 81.29 80.97 80.73 80.64 80.66 80.59 81.06 81.43 82.0285.57 85.61 85.04 84.32 83.90 83.56 83.58 83.40 85.02 86.02 84.6185.05 85.13 84.78 84.18 83.93 83.83 83.71 83.61 84.13 84.71 84.6985.56 84.55 85.26 84.52 84.19 84.03 83.88 83.80 85.03 85.72 85.5684.33 84.67 84.32 83.5 83.04 82.64 82.65 82.55 82.73 83.31 83.8384.66 84.62 84.31 83.74 83.31 83.04 82.91 82.81 82.78 83.74 84.3284.40 84.44 84.29 83.97 83.61 83.42 82.89 83.25 84.43 84.59 84.4486.40 86.26 86.18 87.91 88.85 88.18 89.2484.09 84.04 84.35 84.15 84.91 84.94 84.9982.81 83.77 84.11 83.91 84.56 84.62 84.5281.27 83.66 83.96 83.78 84.52 85.72 86.5186.30 86.23 86.62 86.40 **87.06 **86.21 DAMAGED86.63 86.57 86.84 86.58 87.21 87.43 88.2285.59 85.76 85.32 84.46 84.31 84.25 84.99 84.55 85.70 85.88 85.5979.48 79.87 79.76 79.68 79.23 79.13 79.43 79.08 78.76 79.18 80.2879.39 79.98 79.35 80.54 80.04 78.69 79.24 80.59 78.94 81.24 83.4979.24 78.76 78.89 79.19 79.09 79.34 78.60 78.64 79.29 79.29 83.59APage 2 of 3Table 3.xls
Table 3Groundwater ElevationsTexfi Interim Remedial MeasuresLocation TOC Elevation Ground ElevationPWC-GW-192.3792.33PWC-GW-2*94.5292.17PWC-GW-394.0693.83PWC-GW-492.5292.42PWC-GW-589.5988.95PWC-GW-5a89.4588.90PWC-GW-692.8192.53PWC-GW-793.4492.55PWC-GW-893.6192.61PWC-GW-992.5791.83PWC-GW-1093.4692.57PWC-GW-1194.1593.31PWC-GW-1291.0790.35PWC-GW-1391.8891.50PWC-GW-1490.7590.44PWC-GW-1590.4990.00PWC-GW-1694.9693.18PWC-GW-1794.9793.47PWC-GW-1890.2589.79PWC-GW-1992.6890.85PWC-GW-2090.8489.55PWC-GW-2191.4489.69PWC-GW-2293.6392.37PWC-GW-2393.0891.34PWC-GW-2493.5391.62PWC-GW-2592.5690.85PWC-GW-2692.8991.23PWC-MW-2794.9692.20PWC-GW-2894.1592.32PWC-GW-2993.4291.41PWC-GW-3092.5490.44PWC-GW-3193.6891.86PWC-GW-31 (6) 93.3691.86PWC-GW-3294.8292.76PWC-GW-3393.8691.86MW-296.5793.87RW-193.08--RW-292.44--RW-394.14--Notes:- All elevations are in feet.-- Indicates wells not yet installed.- Slurry wall installation completed 5-10-01.- Initiation of Recovery Well Pumps on 5-24-01.- GW-1, 4, 19, 31, and 32 were not located during the February 2008 sampling event.- A piezometer with the number 6 painted adjacent to it was used as GW-31 during the February 2008 sampling event. A TOC elevation of 2-feet above ground surface was assumed to calculate the groundwater elevation.*-PWC-GW-2 replaced with 2" monitoring well on May 7, 2002. **Groundwater elevation was calculated using the ground elevation.***Piezometer GW-30 was broken 4.13-inches below ground elevation. GW Elevation 2/25/2003GW Elevation 3/26/2003GW Elevation 4/21/2003GW Elevation 5/28/2003GW Elevation 6/24/2003GW Elevation 7/10/2006GW Elevation 2/4/2008GW Elevation 3/24/2009GW Elevation 6/2/0987.19 87.29 86.80 88.23 86.89 86.16 NMNMNM83.84 84.37 84.10 84.74 84.42 84.44 84.11 84.71 84.3085.90 86.06 86.70 87.18 86.06 85.12 85.35 86.03 85.5185.59 85.71 86.49 88.00 85.84 NMNMNMNM76.02 76.34 76.23 76.76 76.72 76.31 **75.46 NMNM83.82 84.12 83.73 84.23 83.74 83.59 **83.99 NMNM84.26 84.63 84.49 84.65 84.15 83.32 83.66 84.25 83.7288.31 88.13 87.84 88.11 87.69 87.02 86.69 86.97 86.4188.20 88.00 87.61 87.56 87.40 86.72 86.53 86.68 85.9487.00 87.09 86.63 88.35 86.74 86.69 **85.93 86.48 85.7385.26 85.46 85.24 86.03 85.34 85.01 84.75 84.78 84.3583.30 83.34 83.35 83.54 83.47 83.77 DRY 83.72 83.8486.09 86.12 85.87 86.82 85.57 84.86 85.09 86.43 85.5485.98 86.04 86.66 85.15 86.12 85.35 85.45 86.27 85.6785.61 86.43 86.25 87.73 85.73 84.81 84.73 86.21 85.3682.93 84.14 83.04 85.58 84.08 84.06 85.15 85.64 84.9383.17 83.24 83.28 83.22 82.95 82.79 82.74 82.75 82.6982.95 83.07 82.99 83.02 82.83 82.76 83.13 83.20 82.8485.41 86.05 85.85 86.79 85.37 84.53 85.84 86.39 84.9785.50 85.76 85.59 85.91 85.73 85.09 NMNMNM83.43 83.52 82.20 82.34 81.76 81.93 82.06 82.45 81.9986.31 86.32 87.20 88.90 86.37 84.31 84.99 86.06 85.2185.56 86.83 86.68 87.66 85.91 85.12 84.13 86.05 85.3285.78 86.88 86.83 87.57 86.00 85.07 84.47 86.12 85.4684.37 84.57 87.01 86.64 86.02 DRY DRY 86.03 85.4584.88 86.08 85.61 86.38 85.05 83.70 83.05 86.06 85.2084.65 85.01 85.39 85.90 84.89 84.29 84.49 84.67 84.3588.64 88.74 88.25 88.94 88.05 87.36 87.10 87.46 86.8385.25 85.43 85.22 85.90 85.24 84.96 84.89 84.92 84.5484.90 85.12 84.92 85.41 84.85 84.64 84.63 84.82 84.3885.71 85.78 86.03 87.07 85.72 84.59 ***84.44 87.38 86.76DAMAGED DAMAGED DAMAGED DAMAGED **87.83 **85.99 NMNMNM86.90 87.52 87.0688.22 88.27 88.21 88.54 88.22 NMNMNMNM87.48 87.12 86.29 87.44 86.9586.05 86.59 87.53 86.88 86.18 DRY DRY 86.16 NM79.53 82.96 79.50 79.06 78.72 82.85 79.09 86.57 85.8179.35 84.34 81.96 85.87 83.82 84.12 80.68 85.66 85.0378.93 85.49 79.48 83.31 80.12 78.99 79.20 86.28 85.33APage 3 of 3Table 3.xls
Table 4
Laboratory Analytical Results Summary - Clearwell Samples
Texfi Interim Remedial Measures
Location Date BromodichloromethaneBromoformChloroformDibromochloromethaneChloromethanecis-1,2-dichloroetheneEthylbenzeneTetrahydrofuranTotal XyleneTetrachloroethene (PCE)Clearwell (by DENR from labroom tap) 31-May-01 18.8 trace 24.1 8.1 trace trace trace
Clearwell (inside well) 7-Jun-01 21 <0.5 28 8.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 14-Jun-01 24 0.5 63 5.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 20-Jun-01 12 <0.5 76 0.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 28-Jun-01 17 <0.5 67 3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 5-Jul-01 25 <0.5 50 7.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 12-Jul-01 24 <0.5 65 7.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 19-Jul-01 21 <0.5 36 7.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 26-Jul-01 29 0.5 53 9.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 2-Aug-01 23 <0.5 72 3.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 9-Aug-01 38 1.3 49 16 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 16-Aug-01 27 <0.5 96 3.1 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 23-Aug-01 24 <0.5 89 4.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 30-Aug-01 24 0.5 49 7.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 6-Sep-01 24 <0.5 60 4.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 13-Sep-01 31 <0.5 54 8.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 19-Sep-01 45 <0.5 82 11 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 27-Sep-01 18 0.8 23 8.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 4-Oct-01 19 <0.5 32 5.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 11-Oct-01 19 0.6 26 7.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 18-Oct-01 25 1 27 13 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 25-Oct-01 37 0.7 31 12 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 1-Nov-01 20 1 17 10 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 8-Nov-01 24 1.3 25 12 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap) 15-Nov-01 27 1.5 25 14 <0.5 <0.5 <0.5 <0.5
C( )29 01 22 06 30 83 0 0 0 0
Volatiles by Method 524.2
Clearwell (labroom tap)29-Nov-01 22 0.6 30 8.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)6-Dec-01 21 0.8 35 9.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)13-Dec-01 18 <0.5 32 6.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)20-Dec-01 17 0.8 16 8.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)7-Jan-02 10 0.7 8.9 6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)14-Jan-02 13.4 0.6 14.6 6.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)21-Jan-02 11 <0.5 10 3.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)28-Jan-02 6.2 <0.5 35 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)4-Feb-02 13.4 <0.5 29.4 2.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)11-Feb-02 8.8 <0.5 26.9 1.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)18-Feb-02 9.5 <0.5 18 2.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)25-Feb-02 8.1 <0.5 21.2 1.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)4-Mar-02 9 <0.5 26.6 1.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)12-Mar-02 20.3 2.3 14.9 13.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)18-Mar-02 15.6 <0.5 22.9 5.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)25-Mar-02 18.1 <0.5 30.4 5.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)1-Apr-02 14.1 <0.5 18.8 5.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)8-Apr-02 16.5 <0.5 27.4 5.1 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)15-Apr-02 18.7 <0.5 40.3 5.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)22-Apr-02 24.6 <0.5 75.1 5.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)29-Apr-02 21.8 <0.5 34.2 8.1 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)6-May-02 27.3 2.3 31.2 15.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)13-May-02 23 3.3 22 16 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)20-May-02 25.5 3.3 23 17.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)5-Jun-02 30.8 4.7 24 22 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)10-Jun-02 31.7 4.5 25.2 23.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)17-Jun-02 40.4 9 30 38.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)24-Jun-02 28.5 10 16.6 34.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)1-Jul-02 27.2 4.8 22.7 22.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)8-Jul-02 33.5 4.4 37.7 23.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)15-Jul-02 30.6 5.3 30.4 25.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)29-Jul-02 26.9 6.2 22.8 29.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)5-Aug-02 44.8 16.2 30.1 53.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)12-Aug-02 47.4 2.2 56.1 21.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)19-Aug-02 33.8 28 11.4 63.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)26-Aug-02 36.3 26.6 12.4 52.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)5-Sep-02 26.1 <0.5 93.8 5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)9-Sep-02 38.2 <0.5 97.5 7.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)16-Sep-02 29.9 0.5 53.8 9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)23-Sep-02 39.1 1.8 50.2 18 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)1-Oct-02 36.8 1.1 51.2 14.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)8-Oct-02 29 1.5 32.5 15.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)14-Oct-02 18 0.5 50.3 5.8 <0.5 <0.5 <0.5 <0.5
A Page 1 of 3 Table 4.xlsx
Table 4
Laboratory Analytical Results Summary - Clearwell Samples
Texfi Interim Remedial Measures
Location Date BromodichloromethaneBromoformChloroformDibromochloromethaneChloromethanecis-1,2-dichloroetheneEthylbenzeneTetrahydrofuranTotal XyleneTetrachloroethene (PCE)Volatiles by Method 524.2
Clearwell (labroom tap)21-Oct-02 20.8 0.5 26.8 9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)28-Oct-02 19.6 0.9 27.4 8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)4-Nov-02 24.2 1.1 29.2 9.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)11-Nov-02 12.9 <0.5 35.9 2.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)19-Nov-02 12.1 <0.5 29.3 2.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)26-Nov-02 17.5 0.5 19.9 7.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)2-Dec-02 11.3 <0.5 19.4 3.0 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)16-Dec-02 12.9 <0.5 20.7 3.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)30-Dec-02 8.36 <0.5 23.8 1.71 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)6-Jan-03 9.6 <0.5 22.8 2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)13-Jan-03 9.9 <0.5 20.9 2.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)28-Jan-03 7.40 <0.5 11.7 2.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)4-Feb-03 9.6 0.6 9.3 5.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)11-Feb-03 8.3 <0.5 17.8 2.1 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)20-Feb-03 9.2 <0.5 12.8 3.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)25-Feb-03 5.4 <0.5 16 0.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)4-Mar-03 6.1 <0.5 10.4 1.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)10-Mar-03 4.5 <0.5 16.7 0.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)17-Mar-03 8.1 <0.5 15.0 2.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)26-Mar-03 5.8 <0.5 20.8 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)8-Apr-03 13.6 <0.5 21.2 4.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)16-Apr-03 4.0 <0.5 22.0 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)21-Apr-03 9.2 <0.5 21.4 1.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)28-Apr-03 11.7 <0.5 23.8 2.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)5-May-03 10.5 <0.5 34.1 1.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)12-May-03 10.0 <0.5 26.5 2.1 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)21-May-03 12.4 <0.5 22.3 3.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)28-May-03 9.9 <0.5 23.7 1.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)9-Jun-03 16.5 <0.5 25.5 5.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)16-Jun-03 14.4 <0.5 24.4 4.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)24-Jun-03 12.8 <0.5 30.3 2.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)30-Jun-03 12.6 <0.5 33.7 2.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)7-Jul-03 8.6 <0.5 21.4 1.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)14-Jul-03 11.9 <0.5 38.4 1.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)21-Jul-03 11.0 <0.5 28.8 2.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)30-Jul-03 14.3 <0.5 26.9 4.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)4-Aug-03 9.4 <0.5 26.2 1.84 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)11-Aug-03 7.1 <0.5 24.1 1 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)20-Aug-03 15.7 <0.5 25.8 5.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)25-Aug-03 17.4 0.6 22.4 7.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)8-Sep-03 15.1 <0.5 18.8 7.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)22-Sep-03 16.6 <0.5 24.4 6.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)29-Sep-03 15.2 <0.5 24.5 4.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)6-Oct-03 15.1 <0.5 24.6 5.1 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)14-Oct-03 9.6 <0.5 18.4 2.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)20-Oct-03 9.0 <0.5 17.2 2.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)27-Oct-03 14.2 9 5.5 22 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)17-Nov-03 <0.5 3.2 17.3 18.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)25-Nov-03 22.4 3.7 16.4 20.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)2-Dec-03 16.4 3.3 12.1 15.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)6-Jan-04 10.4 <0.5 13.2 3.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)2-Feb-04 11.0 <0.5 8.9 4.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)1-Mar-04 6.4 <0.5 9.8 2.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)29-Apr-04 24.8 2 18.1 16.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)27-May-04 12.1 <0.5 27.3 3.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)1-Jul-04 19.0 2.5 15.0 14.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)26-Jul-04 21.4 3.2 15.5 16.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)26-Aug-04 15.6 <0.5 29.9 4.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)14-Sep-04 16.7 <0.5 22.6 5.9 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)22-Oct-04 13.2 <0.5 22.6 3.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)11-Nov-04 13.3 1 10.6 8.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)29-Dec-04 7.5 <0.5 5.3 3.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)25-Jan-05 12.0 <0.5 9.5 5.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)25-Feb-05 10.1 <0.5 12.6 3.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)22-Mar-05 7.8 <0.5 17.5 1.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)27-Apr-05 12.8 <0.5 17.8 4.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)25-May-05 17.9 <0.5 20.7 7.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)22-Jun-05 23.8 5.51 13.0 24.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)19-Jul-05 31.5 2.6 23.9 20.3 <0.5 <0.5 <0.5 <0.5
A Page 2 of 3 Table 4.xlsx
Table 4
Laboratory Analytical Results Summary - Clearwell Samples
Texfi Interim Remedial Measures
Location Date BromodichloromethaneBromoformChloroformDibromochloromethaneChloromethanecis-1,2-dichloroetheneEthylbenzeneTetrahydrofuranTotal XyleneTetrachloroethene (PCE)Volatiles by Method 524.2
Clearwell (labroom tap)15-Aug-05 14.0 <0.5 17.6 6.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)15-Sep-05 23.9 12.6 10.3 30.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)31-Oct-05 17.9 0.8 19.7 8.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)17-Nov-05 25.1 2.9 16.4 18.3 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)12-Dec-05 11.5 <0.5 43.8 1.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)17-Jan-06 17.1 <0.5 16.8 5.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)9-Feb-06 14.2 <0.5 18.4 3.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)9-Mar-06 15.4 <0.5 9.1 13.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)17-Apr-06 22.0 <0.5 27.1 9.93 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)11-May-06 9.7 <0.5 35.0 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)8-Jun-06 16.6 1.2 11.2 10.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)10-Jul-06 25.3 1.8 21.1 14.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)7-Aug-06 31.4 2.6 27.7 19.2 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)13-Sep-06 15.2 <0.5 23.4 6.51 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)9-Oct-06 28.9 1.9 22.9 18.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)9-Nov-06 23.0 5.3 10.0 23.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)12-Dec-06 7.1 <0.5 11.6 1.85 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)17-Jan-07 11.1 <0.5 20.1 2.86 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)15-Feb-07 11.9 <0.5 20.6 3.46 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)12-Mar-07 15.2 <0.5 32.7 4.52 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)30-Apr-07 15.8 <0.5 46.9 3.07 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)31-May-07 26.8 0.92 38.6 12.4 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)27-Jun-07 27.3 2.24 35.6 16.0 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)31-Jul-07 30 2.72 25 19.8 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)16-Aug-07 33.9 3.87 25.4 24.1 0.74 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)10-Sep-07 30.7 3.1 23.2 21.6 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)30-Oct-07 18.6 <0.5 46.1 5.9 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)29-Nov-07 27.3 3.6 17.6 22.2 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)26-Dec-07 21.9 2.4 14.9 16.2 0.7 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)21-Jan-08 18.5 1.2 19.4 11.0 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)5-Feb-08 16.8 1.5 11.5 11.7 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)19-Mar-08 17.1 <0.5 29.4 6.6 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)27-Apr-08 19.8 <0.5 40.2 6.9 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)28-May-08 36.9 <0.5 64.2 12.8 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)10-Jun-08 30.2 0.6 55.1 11.2 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)14-Jul-08 29.0 <0.5 60.0 8.5 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)14-Aug-08 27.6 11.5 11.6 38.2 1.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)9-Sep-08 5.9 <0.5 61.4 0.5 0.6 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)9-Oct-08 27.5 2.8 29.6 19.8 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)24-Nov-08 15.4 <0.5 27.0 6.0 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)16-Dec-08 6.9 <0.5 28.2 1.2 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)12-Jan-09 5.3 <0.5 18.4 0.8 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap collected by PWC) 28-Apr-09 11.3 <0.5 30.7 2.4 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap collected by PWC) 29-May-09 14.2 <0.5 31.0 5.0 <0.5 <0.5 <0.5 <0.5 <0.5
Clearwell (labroom tap)3-Jun-09 15.6 <0.5 34.2 4.9 <0.5 <0.5 2.2 12.6 <0.5
Field Blank 31-May-01 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5
Field Blank (by DENR)31-May-01 <0.5 <0.5 <0.5 <0.5 <2.0 <0.5
Notes:
All units are in micrograms per liter (parts per billion)
* - Estimated Value
**- Trihalomethane MCL lowered from 100 ug/l to 80 ug/l.
-Table presents only data analyzed by EPA Method 524.1. Method 8260 was used from 3/21/01 to 5/31/01.
Trace - present, at concentration below MDL (<0.5 ug/l)
A Page 3 of 3 Table 4.xlsx
TEXFIAbandoned Heating Oil UST'sDrainage DitchMH-1MW-27GW-7GW-8GW-1GW-9GW-10GW-11BDLGW-33GW-312,862Slurry WallGW-285GW-29GW-30870GW-123.75MH-2GW-16368GW-15152GW-14GW-17134GW-18GW-25MH-3RW-3FormerGasolineUSTsGW-19GW-24GW-23GW-21GW-22GW-4GW-26GW-20GW-3GW-6GW-5AGW-5GW-13BDLMW-2DRYRW-16,992RW-22,154GW-32ApproximateSurface WaterIntake LocationNote: Groundwater Samples Collected on 6/2-3/09ClearwellLEGENDFigure 1Total Volatile Organic Compound Isoconcentration MapMonitoring WellRecovery WellSewer ManholePiezometerRiverSlurry WallClearwell BoundaryDrainage DitchFenceIsoconcentration Contour Line (ppb)Inferred Isoconcentration Contour Line (ppb)Building FootprintNote: Piezometers shown in red were sampled for this event.1001001,0001,0005,0005,0001 inch = Approximately 100 feetGW-236,01110,000
TEXFIAbandoned Heating Oil UST'sDrainage DitchMH-1MW-2786.83GW-786.41GW-885.94GW-1NMGW-985.73GW-1084.35GW-1183.84GW-3386.95GW-3187.06Slurry WallGW-2884.54GW-2984.38GW-3086.76GW-1285.54GW-284.30MH-2GW-1682.69GW-1584.93GW-1485.36GW-1782.84GW-1884.97GW-2585.20MH-3RW-385.33FormerGasolineUSTsGW-19NMGW-2485.45GW-2385.46GW-2185.21GW-2285.32GW-4NMGW-2684.35GW-2081.99GW-385.51GW-683.72GW-5ANMGW-5NMGW-1385.67MW-2NMRW-185.81RW-285.03GW-32NMApproximateSurface WaterIntake LocationNote: Groundwater Elevations Measured on 6/2/09ClearwellLEGENDMonitoring WellRecovery WellSewer ManholePiezometerRiverSlurry WallClearwell BoundaryDrainage DitchFencePotentiometric Contour LineInferred Pontentiometric Contour LineBuilding FootprintFigure 2Groundwater Contour Map86868484848483831 inch = Approximately 100 feet8582828583838787
Figure 3Total Detected VOC vs. TimeGW-22000025000300003500040000ed VOC (ug/l)AFigure 3050001000015000200001/30/2001 2/7/2001 5/8/2002 7/16/2002 6/24/2003 7/10/2006 2/4/2008 3/24/2009 6/2/2009GW-2Total DetecteDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
Figure 4Total Detected VOC Vs. TimeGW-12100150200l VOC (ug/l)AFigure 40502/6/2001 9/13/2001 5/8/2002 7/16/2002 7/10/2006 3/24/2009 6/3/2009GW-12TotalDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
Figure 5Total Detected VOC Vs. TimeGW-1330405060ected VOC (ug/l)AFigure 5010202/6/2001 9/13/2001 5/8/2002 7/10/2006 2/4/2008 3/24/2009 6/3/2009GW-13Total DeteDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
Figure 6Total Detected VOC Vs. TimeGW-15150200250ected VOC (ug/l)AFigure 60501002/6/2001 9/13/2001 5/8/2002 3/25/2009 6/2/2009GW-15Total DeteDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
Figure 7Total Detected VOC Vs. TimeGW-162000025000300003500040000ected VOC (ug/l)AFigure 70500010000150002/6/20019/13/20015/7/20026/24/20033/24/20096/2/2009GW-16Total DeteDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
Figure 8Total Detected VOC Vs. TimeGW-17150200250ected VOC (ug/l)AFigure 80501002/6/2001 9/13/2001 5/7/2002 6/24/2003 3/24/2009 6/2/2009GW-17Total DeteDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
Figure 9Total Detected VOC vs. TimeGW-3080001200016000ected VOC (ug/l)AFigure 9040009/5/2002 7/10/2006 2/4/2008 3/24/2009 6/3/2009GW-30Total DeteDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
Figure 10Total Detected VOC vs. TimeRecovery Wells100010000100000ected VOC (ug/l)AFigure 101101002/4/2008 3/25/2009 6/2/2009 2/4/2008 3/25/2009 6/2/2009 2/4/2008 3/25/2009RW-1 RW-2 RW-3Total DeteDateotherchloromethanevinyl chloridetrichloroethenetetrachloroethenetrans-1,2-dichloroethenecis-1,2-dichloroethene
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SGS North America, Inc.
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SGS North America, Inc.
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SGS North America, Inc.
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SGS North America, Inc.
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SGS North America, Inc.
N.C. Certification #481
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SGS North America, Inc.
N.C. Certification #481
Page 26 of 30
SGS North America, Inc.
N.C. Certification #481
Page 27 of 30
SGS North America, Inc.
N.C. Certification #481
Page 28 of 30
SGS North America, Inc.
N.C. Certification #481
Page 29 of 30
SGS North America, Inc.
N.C. Certification #481
Page 30 of 30
SGS North America, Inc.
N.C. Certification #481
Appendix B
Appendix C
1) Upward (buoyant) force from the saturated soil beneath the floor of the clearwell
The following factors/conditions were used in the calculation of these forces/pressures:
1) The normal operating water level in the clear well: 7 ft (2.14 m)
2) Top of surface grade elevation: 92 ft msl
3) Clear well floor elevation: 84.5 ft msl
5) Groundwater table at elevation 85 ft asl (7 ft (2.13 m) bls)
6) Densities of subsurface soil: dry (18 kN/m3), saturated (20 kN/m3)
7) Weight of water: 9.807 kN/m3
8) Angle of friction (∅) (saturated soil) : 30°
9) Angle of friction (∅) (unsaturated soil): 30°
10) Does not take into account superimposed loading of aboveground sturctures (i.e. 4 MG clearwell), as did not know proximity of
AST to underground clearwell and if it had any influence on pore pressures
12) Treats entire clearwell as one contiguous footprint for loading purposes (per approval from Mick Noland, PWS)
Conclusions:
3) Lateral pore pressure extered on wall exterior exceeds interior hydraulic wall pressure when water depth in
the clear well is < 0.5 feet (below 85 ft asl)
Summary of Vertical and Lateral Force and Pore Pressure Calculations
PWC Hoffer Clearwell
Fayetteville, NC
1) Upward buoyant force (pressure) extered by saturated soil beneath floor of clearwell is not greater than downward force
exerted by weight of concrete and water (at overflow, normal, and empty conditions).
2) Lateral pore pressure extered on walls of clear well from surrounding soils not greater than internal hydraulic force exerted
on walls when water depth in tank is > 0.5 ft (above elevation 85 ft asl)
Two types of forces/pressures were evaluated on the walls and floor of the clear well from the surrounding subsurface
environment:
2) Hydrostatic pore pressure and force exerted on the walls of the clearwell for the portion of the clearwell that is
4) Clear well surface areas and weights derived from Hazen and Sawyer drawing M121, Hoffer WTF Clearwell
11) Does not take into account cracks in foundation of well or other conduits for groundwater intrusion. However, clearwell water levels > 0.5 feet still
result in internal positive pressure exerted on the walls of the clearwell, even if cracks are present.
Clear well Outside Dimensions (l)386.08 Feet
Clear well Outside Dimensions (w)297.67 Feet
Clear well Top Floor Slab Elevation 84.50 Feet (highest elevation=shallowest water depth)
Clear well Overflow Elevation 99.50 Feet
Extended Base Slab 2.50 Feet
Extended Base Slab Thickness 1.50 Feet
Base Slab Thickness 1.25 Feet (at thinnest point)
Top Slab Thickness 0.54 Feet
Calculate Total Volume of Clear well Structure
Volume of Clear well (15 ft - full)=1,723,880 cf
Calculate Total Volume of Water Displaced
(94+62.4) lb//ft3/133 lb/ft3 =28,371,092/(28,371,092-wt of displaced water)
Wt of displaced water = 4,122,296 lbs
Calculate Submerged Weight of Clear well Components
Section Total Ht Weight
Roof Slab Thickness (ft.)0.54 5,436,427.65
End & Divider Walls, Total Square ft.15.50 5,799,842.70
Support Columns, Total Square ft.17.00 309,753.60
Base Slab Thickness (ft.)1.25 12,584,323.26
Totals=24,130,347
Total Weight of Concrete in Clear well=24,130,347 lbs.
Calculate Weight of Soil Above Extended Base/Footing
Total Area ( Extended Base)3,419 3,419 sf
Height of Soil Above Extended Base 0.5 7 ft
Volume of Soil Above Extended Base 1,709 23,933 cf
Weight of Soil Above Extended Base (estimated)133 (sat)114 (dry)lbs/cf
Total Weight of Soil Above Extended Base 227,348 (wet)2,728,362 lbs
(assumes saturated soil at height of 0.5 ft above base, unsaturated soil at a height of 7 ft above that)
Using ground elevation of 92' MSL and top of base elevation of 84.5' MSL
Assuming water table at elev 89', gsat = (Gsgw+ egw)/1 +e
Flotation Protection Required?
Weight of Concrete and Weight of Soil Above Extended Base:26,858,709 lbs
Weight of Saturated Soil above Extended Base:227,348
Weight of Water Displaced By Clear Well:4,122,296 lbs
Hydraulic Uplift?NO
Texfi-Hoffer Clearwell

Buoyancy Calculations - Clearwell
Capacity (15-ft depth)
Interior divider walls at 18" thick; Support columns at 18" square
Clear well Outside Dimensions (l)386.08 Feet
Clear well Outside Dimensions (w)297.67 Feet
Clear well Top Floor Slab Elevation 84.50 Feet (highest elevation=shallowest water depth)
Clear well Operating Elevation 91.50 Feet
Extended Base Slab Diameter 2.50 Feet
Extended Base Slab Thickness 1.50 Feet
Base Slab Thickness 1.25 Feet (at thinnest point)
Top Slab Thickness 0.54 Feet
Calculate Total Volume of Clear well Structure
Volume of Clear well (7 ft) =804,477 cf
Weight of Water Displaced (Proportional to Groundwater Elevation)
(94+62.4) lb//ft3/133 lb/ft3 =27,451,689/(27,451,689-wt of displaced water)
Wt of displaced water = 3,988,707 lbs
Calculate Submerged Weight of Clear well Components
Section Total Ht Weight
Roof Slab Thickness (ft.)0.54 5,436,427.65
End & Divider Walls, Total Square Ft.15.50 5,799,842.70
Support Columns, Total Square Ft.17.00 309,753.60
Base Slab Thickness (ft.)1.25 12,584,323.26
Totals=24,130,347
Total Weight of Concrete in Clear well=24,130,347 lbs.
Calculate Weight of Soil Above Extended Base/Footing
Total Area ( Extended Base)3,419 3,419 sf
Height of Soil Above Extended Base 0.5 7 ft
Volume of Soil Above Extended Base 1,709 23,933 cf
Weight of Soil Above Extended Base (estimated)133 (sat)114 (dry)lbs/cf
Total Weight of Soil Above Extended Base 227,348 (wet)2,728,362 lbs
(assumes saturated soil at height of 4.5 ft above base, unsaturated soil at a height of 7 ft above that)
Using ground elevation of 93' MSL and top of base elevation of 84.5' MSL
Flotation Protection Required?
Weight of Concrete and Weight of Soil Above Extended Base:26,858,709 lbs
Weight of Saturated Soil above Extended Base:227,348
Weight of Water Displaced By Clear Well:3,988,707 lbs
Hydraulic Uplift?NO

Operating Level (7-foot water depth)
Texfi-Hoffer Clearwell
Buoyancy Calculations - Clearwell
Clear well Outside Dimensions (l)386.08 Feet
Clear well Outside Dimensions (w)297.67 Feet
Clear well Top Floor Slab Elevation 84.50 Feet at highest elevation
Clear well Operating Elevation 84.50 Feet
Extended Base Slab Diameter 2.50 Feet
Extended Base Slab Thickness 1.50 Feet
Base Slab Thickness 1.25 Feet at thinnest location
Top Slab Thickness 0.54 Feet
Calculate Total Volume of Clear well Structure
Volume of Clear well (empty)=0 cf
Calculate Total Volume of Water Displaced
H20 Displaced = (Volume of Clear well Structure) * (62.4 lbs/cf)
H20 Displaced=0.00 lbs
Calculate Submerged Weight of Clear well Components
Section Total Ht Weight
Roof Slab Thickness (ft.)0.54 5,436,427.65
End & Divider Walls, Total Square Ft.15.50 5,799,842.70
Support Columns, Total Square Ft.17.00 309,753.60
Base Slab Thickness (ft.)1.25 10,067,458.61
Totals=21,613,483
Total Weight of Concrete in Clear well=21,613,483 lbs.
Calculate Weight of Soil Above Extended Base/Footing
Total Area ( Extended Base)3,419 3,419 sf
Height of Soil Above Extended Base 0.5 7 ft
Volume of Soil Above Extended Base 1,709 23,933 cf
Weight of Soil Above Extended Base (estimated)133 (sat)114 (dry)lbs/cf
Total Weight of Soil Above Extended Base 227,348 (wet)2,728,362 lbs
(assumes saturated soil at height of 4.5 ft above base, unsaturated soil at a height of 7 ft above that)
Using ground elevation of 92' MSL and top of base elevation of 84.5' MSL
Assuming water table at elev 89' MSL
Flotation Protection Required?
Weight of Concrete and Weight of Soil Above Extended Base:24,341,845 lbs
Weight of Saturated Soil above Extended Base:227,348
Weight of Water Displaced By Clear Well:0 lbs
Hydraulic Uplift?NO
Empty Well
Texfi-Hoffer Clearwell
Buoyancy Calculations - Clearwell
Determine lateral pressure on walls of well from surrounding soil
Assume gwt at elevation 85' asl (approx. 7 ft bls)
Total depth to bottom of clear well wall from gwt: 0.5 ft (0.15 m)
ph =pw + ps
ph =lateral pressure
pw =water pressure = 9.807 * z
ps =soil pressure =q + (gsat -9.807) x Ko
z = height below surface 2.13 m (unsat), 2.28 m (sat)
gsat = saturated soil unit weight (20 kN/m3)
gd = unsaturated zone soil unit weight (18 kN/m3)
Ko =
Ko =1 (water)
Unsaturated zone:
Ko (soil)=1-sin (PHI)PHI =30° (sand, assumed)
Ko (soil)=1-sin (30)
Ko (soil)=0.5
Saturated Zone:
Ko (soil)=1-sin (PHI)PHI = 30°(saturated sand)
Ko (soil)=1-sin (30)
Ko (soil)=0.5
Unsaturated zone:
ps =(18 kN/m3) x (2.13 m)* 0.5
ps =19.17 kN/m2
Saturated Zone:
pw =9.807 * (0.15)
pw =1.47 kN/m2
psat = (20 -9.807)*0.5* 0.15
psat =0.76 kN/m2
See attached calculations for breakdown of soil pressure at depth
coefficient of at-rest earth pressure (assume wall not allowed to move either
way (zero horizontal strain))
Total Pressure exerted on walls from water, well interior (see calculation sheets): 20.92
kN/m2 (436.8 lb/ft2)
Hydrostatic Calculations - Walls of Clearwell
PWC Hoffer Site
Therefore, external pore pressure exceeds internal pressure on wall when water level in well is below normal elevation of
water table (0.5 feet above base), elevation 85 ft asl
Total pressure exerted on wall from surrounding soil in vadose and saturated zone: 21.40kN/m2 (446.9 lb/ft2) (at base of
clearwell)
Appendix D

Divider
Page
1
Daphne Jones
From:Hopkins, Cory [[e-mail]]
Sent:Thursday, May 31, 2012 5:15 PM
To:Daphne Jones
Cc:'Chris Smith'; 'Mick Noland'; 'Vance McGougan'; Wang, Michael
Subject:RE: Texfi-Hoffer Clearwell Levels
Follow Up Flag:Follow up
Flag Status:Completed
Daphne-
The following are approximate numbers…

Minimum clearwell level = EL 93.00 (corresponds to a 8.5 ft liquid level in the structure) Maximum clearwell level = EL 99.50 (corresponds to overflow elevation)
Clearwell invert = EL 84.50
At minimum clearwell level, usable volume is approximately 6.8 million gallons (MG).
At maximum clearwell level, usable volume is approximately 12 MG (no big surprise here).
Minimum theoretical detention time corresponds to a minimum clearwell level at a maximum flow condition (32-MGD,
or 40-MGD at high-rate capacity), or 306 minutes (245 minutes at 40-MGD). Maximum theoretical detention time corresponds to a maximum clearwell level at a minimum flow condition (most recently, near 12-MGD), or 1,440 minutes (i.e. 1 day).
As for the average flow you have requested, I can provide you with the average filtered water flow (to the clearwell) and the finished water flow (from the clearwell) for the latest year’s worth of flow data I have (September 2010 to August
2011). These numbers are 19.1-MGD and 18.7-MGD, respectively (the difference due to storage in the clearwell). 19-MGD would be a good ballpark number to use for average flow conditions.

Hope this helps.
-Cory

From: Daphne Jones [mailto:[e-mail]]
Sent: Thursday, May 31, 2012 12:51 PM
To: Hopkins, Cory
Cc: 'Chris Smith'; 'Mick Noland'; 'Vance McGougan'; Wang, Michael
Subject: RE: Texfi-Hoffer Clearwell Levels

Hi Cory – Could you provide me with minimum/maximum residence times in the clearwell for the treated water?  Also 
what is the average flow of water through the 12‐million gallon clearwell per day?  Thanks,  Daphne 

From: Hopkins, Cory [mailto:[e-mail]]
Sent: Thursday, May 10, 2012 3:39 PM
To: Daphne Jones-Dunklee & Dunham
Cc: Chris Smith; Mick Noland; Vance McGougan; Wang, Michael
Subject: RE: Texfi-Hoffer Clearwell Levels

Daphne-
Please find below the requested information regarding the design of the compartmentalized 12-MG clearwell:
2
Length (east/west direction): 386’-1” (includes wall thicknesses and expansion joints)
Width (north/south direction): 297’-8” (includes wall thicknesses and expansion joints)
Depth (varies – sloped bottom):
 Top of floor slab – EL 84.50 (high point), EL 84.25 (low point – at drain valves)
 Overflow – EL 99.50
 Roof (top) – EL 103.20 (high point), EL 101.04 (low point)
Mat slab thickness: typically 1’-0”
 @ North end – 1’-6”
 @ South end – 1’-3”
 @ East end – 1’-6” (3’-0” with footer)
 @ West end – 1’-6” (3’-0” with footer)
 @ Dividing wall 1B/2B and 1A/2A – 1’-6” (3’-0” with footer overlap)
 @ Dividing wall 1A/1B, 2A/2B, and 3A/3B – 1’-6”
 @ Dividing wall 1A/3B and 1B/3B – 1’-6” (3’-0” with footer overlap)
 Other intermediate locations – 2’-0”
I’ve have provided photocopies of existing drawings to further support the information provided above. The attachments
include the following information:

 37 of 44 – original clearwell construction from the 1967 drawing set.
 30402-010-M121-03-27-2012 – identifies clearwell compartments (i.e. 1A, 1B, 2A, etc.); mat slab thickness at
the various dividing walls within the clearwell are noted above.
 1974 Drawing Set – 12-MG Clearwell – expansion construction of clearwell from the 1974 drawing set.
I have the following information regarding Manhole #2 located at the northeast corner of the clearwell:
 Rim EL = 93.14
 Invert EL = 81.14

I hope all of this helps. If you have any questions regarding any of the information provided above, then please don’t hesitate to ask. Thank you.

-Cory
D. Cory Hopkins, P.E. Associate Hazen and Sawyer, P.C.
Environmental Engineers and Scientists 4011 WestChase Boulevard, Suite 500 Raleigh, NC 27607
P: 919.833.7152 F: 919.833.1828
E: [e-mail]

From: Mick Noland [mailto:[e-mail]]
Sent: Tuesday, May 08, 2012 5:40 PM
To: Hopkins, Cory
Cc: Chris Smith; Vance McGougan; Wang, Michael
Subject: FW: Texfi-Hoffer Clearwell Levels

3
Since H &S is actively working on this project, please respond to Daphne’s request. 

Thanks,  Mick 

From: Daphne Jones [mailto:[e-mail]]
Sent: Wednesday, May 02, 2012 4:53 PM
To: Chris Smith
Cc: Mick Noland
Subject: RE: Texfi-Hoffer Clearwell Levels

Hi Chris – I am trying to get the information our engineer needs for simple outward/downward pressure calculations 
that the NCBP wants related to the clearwell (even though it’s pretty obvious there is outward pressure).    What I need 
is the approximate width, length and height of the clearwell.  I don’t think I actually have this information in any of my 
files except if I measured the length/width from scaled drawings. 

I have the email below that has most of the elevation info I need. From the survey work of the MIP data I have a pretty 
good idea of the ground elevation from points close to the clearwell, and I can get the groundwater elevation from 
recent monitoring well data.  Has there ever been any elevation data associated with the toe drain in Manhole Number 
2? 

Finally, you know how the approximate thickness of the concrete floor of the structure?   No big hurry, just when you 
have time.   Thanks, Daphne 

From: Mick Noland [mailto:[e-mail]]
Sent: Monday, February 06, 2012 3:24 PM
To: 'Daphne Jones'
Subject: FW: Texfi-Hoffer Clearwell Levels

fyi 

From: Chris Smith
Sent: Friday, March 18, 2011 10:03 AM
To: Mick Noland
Subject: Re: Texfi-Hoffer Clearwell Levels

There’s roughly 7’ above ground, and 7’ in the ground. 

Top of the floor slab is @ 84.5‘ 

Our operating range is 91.5’ to 98.5’.  91.5’ keeps “our water” above the outside water‐table(for positive pressure).   

Let me know if you need more exact figures. 

Chris 

From: Chris Smith
Sent: Wednesday, July 01, 2009 10:02 AM
To: Mick Noland
Cc: Jeff Carlisle
Subject: Texfi-Hoffer Clearwell Levels
Appendix E
NOTES:
MECHANICAL
HOFFER WTF - CHEMICAL DUCTBANK
SITE PLAN M101
NOTES:
MECHANICAL
HOFFER WTF - CHEMICAL DUCTBANK
ENLARGED SITE PLAN - CHEM. DUCT BANKS M102
NOTES:
MECHANICAL
HOFFER WTF - CHEMICAL DUCTBANK
CHEMICAL DUCT BANK PROFILES M103
NOTES:
MECHANICAL
HOFFER WTF YARD PIPING
LARGE DIAMETER PIPING - PLAN M124
NOTES:
MECHANICAL
HOFFER WTF YARD PIPING
LARGE DIAMETER PIPING - SECTIONS M125
MECHANICAL
HOFFER WTF YARD PIPING
LARGE DIAMETER PIPING - SECTIONS M126

Divider
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4

Mick, 
I have confirmed (from drawings) that the elevation of the 12 MG clearwell’s floor slab is 84.50’.  Our normal operating 
level for water in the clearwell is 91.5’‐98.5’.   We use ultrasonic level indicators to determine water levels in the 
clearwell.  The levels are relayed to the Operators Room in "feet of water", not “elevation”.  Since the Texfi 
contamination was discovered, our self‐imposed minimum level in the clearwell has been 7’ of water or,... 91.5’ of 
elevation. 

As you know, the groundwater elevations nearest the clearwell on 6/2/09 ranged between 82.69’ (GW‐16) and 84.3’ 
(GW‐2), slightly below the top of the floor slab.   

Chris  The information contained in this communication (including any attachment) is privileged and confidential information that is intended for the sole use of the addressee. Access to this communication by anyone else is unauthorized. If the reader is not the intended recipient, or an employee or agent responsible for delivering this communication to the intended recipient, you are hereby notified that any distribution or copying of this communication is strictly prohibited and may be unlawful. If you have received this transmission in error, please reply and notify us of this error and delete this message. Finally, the recipient should check this communication and any attachments for the presence of viruses. The Public Works Commission of the City of Fayetteville, NC, accepts no liability for any damage caused by any virus transmitted by this communication. The information contained in this communication (including any attachment) is privileged and confidential information that is intended for the sole use of the addressee. Access to this communication by anyone else is unauthorized. If the reader is not the intended recipient, or an employee or agent responsible for delivering this communication to the intended recipient, you are hereby notified that any distribution or copying of this communication is strictly prohibited and may be unlawful. If you have received this transmission in error, please reply and notify us of this error and delete this message. Finally, the recipient should check this communication and any attachments for the presence of viruses. The Public Works Commission of the City of Fayetteville, NC, accepts no liability for any damage caused by any virus transmitted by this communication.
REFERENCE 11
REFERENCE 12
,1^1 li? M.
Yl .1
;ua&
U.S. ENVIRONMENTAL PROTECTION AGENCY -
REGION 4
INITIAL POLLUTION REPORT / RAT NOTIFICATION
RECOMMENDATION FOR NO FURTHER PLANNED REMOVAL ACTFVITY
DATE: Aprill?, 2003
FROM: James Webster, On-Scene Coordinator
Emergency Response and Removal Branch
TO: Don Rigger, Chief
Removal Operations Section
Emergency Response and Removal Branch
Charlie Fitzsimmons, On-Scene Coordinator
Removal Assessment Team, North Carolina
Emergency Response and Removal Branch
SUBJECT: Removal Site Evaluation
Texfi Industries, Inc.
Fayetteville, Cumberland County, Tennessee
CERCLIS No. NCD0001075
Site ID No. A48M
L BACKGROUND
LA. Location and Area Landuse
The Texfi Industries, Inc. Site ("Texfi" or "Site") is located at 601 Hoflfer Road in Fayetteville,
Cumberland County, North Carolina at approximately 35O05'03" N Latitude and 78O52'03" W
Longitude (Ref. 1). The subject property is approximately 96 acres in size (Figure 1). The Cape
Fear River bounds the site to the east. Hoffer Road and the Public Works Commission (PWC)
Hoffer Water Treatment Facility lie immediately to the south ofthe site. The Northem &
Southem Railway extends along the westem boundary ofthe property. A city park borders the
property to the north.
LB. Physical Setting
Texfi is located on the Vander, North Carolina USGS 7.5 minute series topographic quadrangle
(Ref 2). Surface elevations on the site range fi'om about 50 feet above mean sea level (msl)
along the Cape Fear River to approximately 90 feet MSL on the eastem portion ofthe property.
10706497
Texfi Industries
Fayetteville, Norih Carolina
Toe Drain
\ >400
Approximate
locolion of tos-drdn
oulfall.
Figure 1. Eastern portion ofthe Texfi Site, Fayetteville, North Carolina showing approximate locations of
known areas of concem (AOCs) and highest observed concentrations (ug/l) of total volatile
organic compounds in on-site monitoring wells recorded during previous, non-EPA, sampiing
events.. 1. Approximate location of 1,000 gallon gasoline UST, reportedly removed in 1993. 2.
Former empty drum storage area. 3. Oil storage AST. Backup storage of #6 fuel oil, renovated in
1994. Renovation reportedly consisted of solidification and removal of sludge in diked area
around the tank followed by construction ofa concrete bottom in containment area. 4.
Approximate location of two, 10,000 gallon capacity, heating oil USTs, reportedly closed in place
in 1993. 5. Wastewater basin. 6. Reported location of PCE tank. Tank is not longer present. 7.
Drum disposal area remediated under State oversight. 8. Reported location of PCE distillation
unit. Unit is no longer present. (Source: Modified from a diagram contained in Ref. 3).
The site lies within the Coastal Plain Physiographic Province ofthe southeastem United States.
The uppermost geologic formation underlying Texfi is the Cape Fear Formation (Ref 3).
Surficial soils consist of fine to coarse-grained sands and discontinuous clay lenses.(Ref 4).
The upper portion ofthe Cape Fear Formation, referred to as the Upper Cape Fear Confining
Unit, reportedly consists of an average of 48 feet of consolidated clay, sandy clay, and silty clay.
Available data suggest that this unit lies from 9 to about 14 feet below ground surface onsite
(Ref 3). Groundwater flow is generally to the southeast, toward the Cape Fear River.
IL OPERATIONAL HISTORY
Texfi's manufacturing process included yam preparation and weaving and fabric dyeing and
finishing. Operations at the Fayetteville facility began circa 1969 and ceased in October 1999
(Ref 1). The company is currently in bankruptcy.
HI. REMOVAL SITE EVALUATION
A Removal Site Evaluation was performed pursuant to 40 CFR §300.410 (Ref 5) in response to
a request submitted by the NCDENR (Ref 1).
HLA. Site Investigation and Sampling
Sampling was conducted at Texfi during the week of July 15, 2002 (Ref 6) and again on
January 23, 2003 (Ref 7). Sampling was conducted by START-2. EPA and NCDENR
personnel were on-site to observe sampling activities during the July 2002 event.
IILB. Analytical Results
IILB.l. Soil
IILB. La. July 2002 Event
A total of forty-four (44) soil samples, including two background samples and three duplicate
samples were collected during the July sampling event (Ref 6). The samples consisted of
twenty-two (22) shallow, subsurface soil samples collected from the 1.5 - 2.0 feet below ground
surface (bgs) and twenty-two deeper, subsurface samples coUected from 3.5-4.0 feet bgs'.
Surface samples were not collected because the contaminants of concem are volatile compounds
that quickly evaporate from surface or near surface soils. Soil sampling locations are shown in
Figure 2.
Analysis ofthe soil samples yielded a range of volatile organic compounds (VOCs). Volatile
organic compounds (VOCs) were detected in 42 ofthe 43 samples collected onsite (i.e.
excluding background samples). Total VOC concentrations in the onsite samples yielding
detections ranged from 1 ug/kg (ppb) to 21,880 ug/kg (Table 1). The principal contaminant of
concem, tetrachloroethene, was detected in 22 of 43 samples collected onsite at concentrations
ranging from 1 ug/kg to 2,600 ug/kg (Table 1).
The two highest total VOCs levels were found in sample TI-03-SBA (21,880 ug/kg) and TI-03-
SBB (21,660 ug/kg). Both samples were collected from a boring beneath the floor ofthe
southeast comer ofthe plant building (Figure 2). Tetrachloroethene was not detected in either of
these samples.
The two highest concentrations of tetrachloroethene were detected in samples TI-06-SBB (2600
ug/kg) and TI-06-SBA (1,100 ug/kg), which were collected just southwest ofthe above-ground.
i
an OF FAYETTCVUIE PWC
HOTFER WATER TFEATMENT FACBJTY
atr-aiE BMWROUMC) 11-a-jr •
A£S£m
DRAINAGE DTTCH
— PROPERTY UNE
•— FENCE
UTIUTY EASEMENT
— PtWIER EASEMENT
UOraTORING \fllELL
SAMPLE LOCATION
SCALE: r - 290*
SCO SEDIMENT SAMPLE
SSA SUBSURFACE SCO. SAMPLE
(1' TO 20
SBB SUBSURFACE SOO. SAMPLE
(3" TOO
SW SURFACE WATER SAMPIE
ew GROUNDWATER SAMPLE
Figure 2. Sampling locations, Texfi Site, Fayetteville, North Carolina. (Source:
Ref 6)
Table 1
Generalized Summary of Soil Analytical Results
Texfi Site, Fayetteville, Nortii Carolina
Sample and depth to top of SBB
sample if known
TI-0 ISB A (background)
TI-OI-SBB (background)
TI-02-SBA
TI-02-SBB (2.75 ft.)
TI-03 (2.5)
TI-03-SBA
T1-03-SBB (3.75 ft.)
TI-04-SBA
TI-04-SBB (3.0 ft.)
TI-05-SBA
TI-05-SBB (2.75 ft.)
TI-06-SBA
TI-06-SBB (3.5 ft.)
TI-07-SBA
TI-07-SBB (3.5 ft.)
TI-08-SBA
TI-08-SBB (3.5 ft.)
TI-10-SBA
TI-10-SBB(3.5ft.)
TI-11-SBA
TI-ll-SBB(3.5ft.)
TI-12D-SBA
TI-12-SBA
TI-12-SBB(3.5ft.)
TI-13D-SBA
Total VOCs (ppb)
28
ND
1
5
17870
21880
21660
II
34
48
242
1487
3022
41
76
666
50
37
15
.648
.736
.736
73
89
31
Tetrachloroethene (ppb)
>TO
ND
ND
ND
ND
ND
ND
2
16
24
120
1100
2600
ND
ND
ND
ND
6
3
ND
ND
II
17
41
7
Table 1
continued
Sample and depth to top of SBB
sample if known
TI-13D-SBB
TI-13-SBA
Tl-13-SBB(3.5ft.)
TI-14-SBA
TI-14-SBB(2.5ft.)
Total VOCs (ppb)
39
91
39
6
10
Tetrachloroethene (ppb)
ND
II
ND
6
7
TI-16-SBA
TI-16-SBB(2.0ft.)
TI-17-SBA
TI-17-SBB(2.5ft.)
TI-18-SBA
TI-18-SBB(3.0fl.)
TI-19-SBA
Tl-19-SBB(2.5ft.)
TI-20-SBA
T1-20D-SBB
TI-20-SBB (3.5 fl.)
T1-27-SBA
TI-27-SBB (3.5 fl.)
TI-31-SBA
TI-31-SBB(3.5fl.)
Number qf samples yielding delect ions. *
Mean among samples witii detections. *
Median among samples with detections. *
Range among samples with detections*
Maximum among samples with detections. *
Minimum among samples wilh detections. *
208
254
ND
9
27
2
3
1
428
2642
2127
23
14
5
27
43
2320
45
21880
21880
1
ND
ND
ND
ND
ND
ND
1
ND
11
6
8
6
3
3
ND
22
180
8
2560
2600
1
ND-Not detected.
SBA
SBB
Sliallow subsurface sample (1.5 - 2.0 feet bis).
Deeper subsurface sample (2.5 - 3.0 feet bis).
Excluding baclcground samples
fuel-oil, storage tank (Figure 2), in the vicimty ofthe reported location ofa tetrachloroethene
distillation unit (Ref. 3).
IILBA.b. January 2003 Event
START-2 personnel collected a total of 10 surface and 27 subsurface samples during the
January 2003 event (Figure 3) All samples were analyzed for volatile and semivolatile orgamc
compounds (SVOCs).
VOCs were detected in the ppb to low ppm range in nine out of 10 ofthe surface soil samples
(Table 2). Tetrachloroethene concentrations ranged from 2 to 1,100 ug/kg. SVOCs were
detected in four samples in the ppb to low ppm range (Table 2).
VOCs were detected in all 27 subsurface samples (Table 2). Tetrachloroethene concentrations
ranged from BDL to 970,000 ug/kg. The highest concentrations were generally observed in the
lowermost (6.0 - 6.5 foot interval) sampling interval. SVOCs were detected in Ihe majority ofthe
soil samples in the ppb to low ppm range (Table 2). Ofthe SVOCs, the compound 1,1- biphenyl
was consistently present at the highest concentration, ranging up to 430,000 at 4 - 4.5 feet
below land surface at location TI-35.
III.B.2. Groundwater
During the July 2002 sample event groundwater samples were collected from five monitoring
wells located on-site and from a manhole accessing the toe drain around a clear well on the
adjacent PWC Hoffer Treatment Plan (Figure 2). A seventh sample was collected from the
outfall ofthe toe-drain to the Cape Fear River (Figure 2). This sample was classified as surface
water in the sampling report; however, it is probably more appropriately evaluated as a
groundwater sample. No volatile organic compounds were reported in the background sample.
All other samples possessed detectable concentrations of VOCs (Table 3).
The highest observed total VOCs level was detected at momtoring well MW-1 (86,940 ug/l)
which is located northeast of the fuel-oil, above-ground, storage tank (Figures 1, 2).
Tetrachloroethene was not detected in this sample although its degradation products cis-1,2-
dichloroethene (50,000 ug/l) and vinyl chloride (5,000 ug/l) were present at concentrations far
exceeding their respective MCLs. The highest concentration of tetrachloroethene in an EPA
sample was in a sample collected from monitoring well MW-4 (1,200 ug/l) located north ofthe
reported location of a former empty drum storage area (Figures 1,2).
i OHM DISPOSAL EXCAVATIONS
AREA 1
FORMER
GASOUNE.,
UST
QTY OF FAYETTEVILLE PWC
HOFFER WATER TREATMENT FAOUTY ^
LEGEND
DRAINAGE DITCH
PROPERTY UNE
— — — •—'— FENCE
UTIUTY EASEMENT
POWER EASEMENT
9 MONITORING WELL
4- SAMPIX LOCATION
bgs Below ground surface
0 _ 125 250
SCALE
SS SURFACE SOIL SAMPLE
(0.0' TO 0.5' bgs)
SBB SUBSURFACE SOIL SAMPLE
(2.0' TO 2.5' bga)
SBC SUBSURFACE SOIL SAMPLE
(4.0' TO 4.5' bgs)
SBD SUBSURFACE SOIL SAMPLE
(6.0' TO $.5' bgs)
Figure 3. Soil sampling locations for January 2003 event
Table 2
Detected Compounds in Soil
January 2003 Sampling Event
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Trichlorofluoromethane (Freon 11)
TI-01-T
B2
Trip blank
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
TI-32-SB
B
Drum
Storage
BDL
BDL
BDL
BDL
BDL
BDL
BDL
100
BDL
BDL
27
BDL
BDL
4
BDL
J
J
TI-32-SBC
Drum Storage
52
BDL
BDL
BDL
BDL
BDL
BDL
23
BDL
BDL
10
BDL
BDL
1
BDL
J
J
J
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
TI-32-S
S
Drum
Storage
BDL
BDL
BDL
BDL
BDL
BDL
38
1
BDL
BDL
6
BDL
BDL
BDL
J
J
J
TI-33-SB
B
Drum
Storage
BDL
BDL
BDL
BDL
BDL
BDL
BDL
61
BDL
BDL
54
BDL
BDL
10
J
J
TI-33-SBC 1
Drum Storage
BDL
BDL
BDL
BDL
BDL
BDL
BDL
94
BDL
BDL
31
BDL
1
8
J
J
J
1 Trichlorofluoromethane (Freon 11) BDL BDL BDL
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Voiatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Trichlorofluoromethane (Freon 11)
TI-33-S
S
Drum
Storage
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
5
BDL
BDL
BDL
BDL
J
TI-34-SB
B
PCE
Distillation
62
BDL
BDL
BDL
BDL
BDL
BDL
BDL
180
2300
580
BDL
BDL
BDL
BDL
J
J
J
TI-34-SBC
PCE Distillation
4600
BDL
BDL
74
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
J
-
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Trichlorofluoromethane (Freon 11)
TI-34-
SBD
PCE
Distillation
200000
BDL
BDL
3100
BDL
1200
BDL
740
BDL
BDL
67000
BDL
BDL
2000
BDL
J
J
J
TI-34-SS
PCE
Distillation
BDL
BDL
140
BDL
BDL
BDL
BDL
BDL
BDL
BDL
1
BDL
BDL
BDL
1
J
J
J
TI-35-SBB
PCE Distillation
1100
1300
BDL
BDL
BDL
BDL
BDL
BDL
130
2000
2400
BDL
BDL
140
BDL
J
J
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichioroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Thchlorofluoromethane (Freon 11)
TI-35-
SBC
PCE
Distillation
150000
1200
BDL
2700
BDL
130
BDL
BDL
150
2100
5000
130
BDL
130
BDL
J
J
J
J
TI-35D-
SBCdupl
icate
PCE
Distillation
430000
BDL
BDL
6600
41
BDL
BDL
BDL
130
1900
1400
BDL
BDL
BDL
BDL
J
J
J
TI-35-SBD
PCE Distillation
100000
BDL
BDL
24000
BDL
BDL
BDL
BDL
BDL
BDL
970000
BDL
BDL
46000
BDL
J
J
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
TI-35-S
S
PCE
Distillation
68
1700
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
J
TI-36-SB
B
PCE
Distillation
190
BDL
BDL
BDL
BDL
BDL
BDL
160
160
2400
2200
BDL
BDL
J
J
J
TI-36D-
SBBduplicatc
PCE Distillation
400
BDL
BDL
BDL
BDL
400
BDL
150
160
2100
4000
130
BDL
J
J
J
J
J
Trichloroethene
Trichlorofluoromethane (Freon 11)
BDL
BDL
180
BDL
J 240
BDL
J
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthaiate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Trichlorofluoromethane (Freon 11)
TI-36-
SBC
PCE
Distillation
150
540
BDL
BDL
BDL
BDL
BDL
210
BDL
2100
2700
BDL
BDL
200
BDL
J
J
J
TI-36-SS
PCE
Distillation
BDL
1200
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
2
BDL
BDL
BDL
BDL
J
TI-37-SBB
PCE Distillation
180
BDL
BDL
BDL
BDL
BDL
BDL
BDL
150
2100
7600
BDL
BDL
270
BDL
J
J
J
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
TI-37-
SBC
PCE
Distillation
74
BDL
BDL
BDL
BDL
BDL
BDL
BDL
130
1700
410
BDL
BDL
BDL
J
J
J
TI-37-SB
D
PCE
Distillation
780
3400
BDL
BDL
BDL
BDL
BDL
BDL
180
2100
3700
BDL
BDL
150
J
J
TI-37-SS
PCE Distillation
BDL
BDL
BDL
BDL
BDL
BDL
BDL
2
2
BDL
87
BDL
BDL
8
J
J
J
I Trichlorofluoromethane (Freon 11) BDL BDL BDL
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichloroben2ene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Trichlorofluoromethane (Freon 11)
TI-38-
SBB
PCE
Distillation
260
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
300
BDL
BDL
BDL
BDL
J
J
TI-38D-
SBBdupl
icate
PCE
Distillation
54
4000
BDL
BDL
BDL
BDL
BDL
BDL
170
2200
530
BDL
BDL
BDL
BDL
J
J
J
TI-38-SBC
PCE Distillation
160
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
16
BDL
BDL
BDL
BDL
J
Bold values exceed PRG.
1 Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichloroben2ene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
TI-38-S
S
PCE
Distillation
600
1400
BDL
BDL
BDL
BDL
BDL
3
BDL
BDL
110
BDL
BDL
9
J
J
TI-39-SB
B
PCE
Distillation
BDL
1600
BDL
BDL
BDL
BDL
BDL
BDL
140
1300
460
BDL
BDL
BDL
J
J
J
TI-39-SBC
PCE Distillation
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
1500
380
BDL
BDL
BDL
J
J
I Trichlorofluoromethane (Freon 11) | BDL BDL BDL
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Trichlorofluoromethane (Freon 11)
TI-39-
SBD
PCE
Distillation
47000
950
BDL
1200
BDL
BDL
BDL
150
180
1800
1500
BDL
BDL
BDL
BDL
J
J
J
TI-39-SS
PCE
Distillation
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
2100
1100
BDL
BDL
BDL
BDL
TI-40-SBB
PCE AST
60
BDL
BDL
BDL
BDL
BDL
BDL
3
BDL
BDL
37
BDL
BDL
1
BDL
J
J
J
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichlorobenzene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Thchlorofluoromethane (Freon 11)
TI-40-
SBC
PCE AST
48
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
J
TI-40-SS
PCE AST
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
170
1900
170
BDL
BDL
BDL
BDL
J
J
TI-41-SBB
PCE AST
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
Bold values exceed PRG.
Compound
Extractables (ug/kg)
1,1-Biphenyl
bis(2-Ethylhexyl) Phthalate
Di-n-Butylphthalate
Naphthalene
Phenanthrene
Volatiles (ug/kg)
1,2,4-Trichloroben2ene
Acetone
cis-1,2-Dichloroethene
Methyl Acetate
Methyl Ethyl Ketone
Tetrachloroethene
Total Xylenes
trans-1,2-Dichloroethene
Trichloroethene
Trichlorofluoromethane (Freon 11)
TI-41-
SBC
PCE AST
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
8
BDL
BDL
BDL
BDL
J
TI-41-SS
PCE AST
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
62
BDL
BDL
BDL
BDL
Bold values exceed PRG.
Table 3
Generalized Results of Groundwater Analysis
Texfi Site, Fayetteville, North Carolina
Sample & (Monitoring Well)
TI-Ol-GW (Background)
TI-09-GW(MW-l)
TI-15-GW(MW-4)
TI-21-GW(MW-3)
TI-26-GW (TOE DRAFN)
TI-29-SW (TOE DRAIN OUTFALL)
Total VOCs (ppb)
ND
86940
7430
2.5
54.5
36.2
Tetrachloroethene (ppb)
ND
ND
1200
ND
10
18
III.B.3. Surface Water
A total of five surface water samples were collected as part ofthe July 2002 sampling event
(Figure 2). Of these, sample TI-24-SW displayed the highest concentration of total VOCs and
tetrachloroethene at 2,324 ppb and 36 ppb, respectively. The sample was collected from a
ephemeral drainage ditch located on the southeast portion ofthe site (Table 4). At the time of
sampling, there was no flow (i.e. zero discharge) in the ditch, and the only surface water was
confined to a shallow pool at its westem (upstream) end.
No VOCs were detected in any sample collected directly from the Cape Fear River. Notably, the
sampales were collected during what is estimated to have been "worst cast" conditions as the
river was at a base flow during the sampling event (Figure 4). Thus, dilution of any
contaminated groundwater discharging to the river would be expected to have been at a
minimum relative of higher stage conditions.
Table 4
Generalized Results of Surface Water Analysis
Texfi Site, Fayetteville, North Carolina
Sample & (Location)
Tl-OI-SW (background Cape Fear)
T1-24-SW (Ephemeral drainage ditch,
southeast portion of plant site)
TI-28-SW (Downstream from Texfi and
just upstream from water intake located
midstream of Cape Fear River)
TI-30-SW (Storm water sump between
plant building and waste water lagoon)
TI-30D-SW (Storm water sump
between plant building and waste water
lagoon)
Total VOCs (ppb)
ND
2324
ND
2.03
0.72
Tetrachloroethene (ppb)
ND
36
ND
ND
ND
SUSGS
USGS 02104000 CRPE FERR RIVER m* FRyETTEVILLE, NC
Jul
2001
Sep
2001
Nov
2001
Jan
2002
Har
2002
Hay
2002
Jul
2002
Sep
2002
Hov
2002
DRIES: 06/02/2001 to 12/01/2002
Provisional Data Bubjsct to Ravlslon
Figure 4. Hydrograph for Cape Fear River at Fayetteville, North Carolina for the period June 6, 2001
through December 1, 2002. Source: U.S. Geological Survey. Water Data.
http://vraterdata.usgs.gov. Note base level conditions during July and August 2002.
III.B.4. Sediment
Sediment was collected from two onsite and one background locations during the investigation
(Figure 2). Both onsite samples were collected from the drainage ditch on the southeast portion
ofthe site. Total VOCs and tetrachloroethene were detected at 308 ug/kg and 13 ug/kg,
respectively, in one ofthe two onsite samples. There were no reported detections of VOCs in the
background sample (Table 5).
IV. REMOVAL ELIGIBILITY (40 CFR §300.415)
Pursuant to 40 CFR §300.415(b), removal actions may be initiated to mitigate any release that
meets one or more ofthe criteria specified under §300.415(b)(2). Those criteria relative to
currently known site conditions follow:
§300.41 S(b)(2)(i) - Actual or potential exposure to nearby populations, animals, or the food
chain from hazardous substances.
Surface VOC concentrations in all soil samples imder the directionof EPA were below Region 9
Preliminary Remedial Goals (PRGs) for soils in industrial landuse setting for compounds with
established PRGs (Ref 8). One soil sample, GP-1 (near EPA TI-06), collected in November
2000 by Mid-Atlantic Associates, P.A. was reported 280,000 ug/kg of tetrachloroethene in the 6
- 8 foot bis. Samples collected under the direction of EPA within in the same general area
displayed tetrachloroethene concentrations up to 970,000 ug/kg. However the higher
contaminant concentrations were observed from 4 - 6.5 feet below ground surface. Groundwater
measurements (Refs. 6, 8) in the vicinity ofthe plant building and shallow saturated zone
conditions encountered during the EPA assessment (Ref 6) suggest that these more highly
contaminated soUs lay near or within the saturated zone. (Table 6).
Table 5
Generalized Results of Sediment Analysis
Texfi Site, Fayetteville, North Carolina
Sample & (Location
TI-01-SED (Offsite background)
TI-22-SED (Westem end of onsite
drainage ditch)
TI-23-SED (Eastem end of drainage ditch
onsite)
Total VOCs (ppb)
ND
308
ND
Tetrachloroethene (ppb)
ND
13
ND
No hazardous substances were detected in surface water samples collected from the Cape Fear
River. Surface water collected from the onsite drainage ditch did display MCL exceedances for
cis-1,2-dichloroethene, tetrachloroethene, trichloroethene, and vinyl chloride. However, this
ditch is an ephemeral stream of limited areal extent. At the time of sampling, it was not flowing,
and the only water present was confined to a small pool near the main plant building.
Sediment from one sample location displayed sub-ppm concentrations of VOCs including
tetrachloroethene, trichloroethene, and vinyl chloride. There are no established sediment
screening values for these compounds. Furthermore, the sample was collected from an onsite
drainage ditch with ephemeral discharge. A sediment sample collected approximately 100 feet
downstream within the same drainage ditch displayed no detections of VOCs.
Table 6
Estimated Depth to the Top ofthe
Saturated Zone Near the Texfi Plant Building
Location
Southeast comer of plant building.
North side of plant building
West side of plant building
Approximate Depth to
Watertable (ft.) from
ground surface
6.1
5.9
6.1
Remarks
Based upon measured water levels by
NCDENR contractors July 17, 2002.
Based upon measured depth to water in
MW-4on July 16,2002.
Based upon measured depth to water in
MW-1 on July 16,2002.
Existing analytical data (Refs. 3, 6, 9) indicate that groundwater is widely contaminated beneath
the site and that the plume of containination has moved offsite to the south and impacted
property owned by the Fayetteville Public Works Commission (PWC). There are no known
groundwater users within the vicinity ofthe site. Consequently, the primary concem with
respect to groundwater contamination at the site is the possibility that the contaminated water
will make its way into the public water supply via seepage into a clear weU owned and
maintained by the Fayetteville PWC. This potential threat is discussed under §300.415(b)(2)(ii),
below.
§300.415(b)(2)(ii) - Actual or potential contamination of drinking water supplies or
sensitive environments.
Although there is significant groundwater containination at Texfi, there are no knowTi
groundwater users in the vicinity ofthe site.
The site is located less than 1,000 feet from the Cape Fear River and is upstream ofa midstream
intake that draws water for the Fayetteville PWC Hoffer water treatment plant. It is possible that
contaminated groundwater discharges to the river upstream ofthis intake. However, the intake is
located at midstream and, to date, tetrachloroethene has not been detected in samples coUected
from the River.
A twelve-miUion gaUon capacity, concrete clearweU operated by the FayetteviUe PWC is located
approximately 300 feet south ofthe Texfi Plant (Ref 1). The bottom ofthe tank Ues at 84.5 feet
above msl approximately two (2) feet below the watertable (Ref 10). The clearweU Ues within
the path ofthe contaminated groimdwater plume emanating form Texf, and site-related
hazardous constituents have been detected in groundwater samples coUected from a perimeter
toe drain instaUed below the bottom ofthe tank (Ref 10)^. Given these conditions, there exists
the potential, in theory, that contaminated groundwater could seep into the tank and thus impact
a significant portion ofthe city's water supply (Figure 5).
The potential for contaminated groundwater to enter the clearweU is Ukely greater when the
water level within the tank is such that there is a net inward hydrauUc head (i.e. groundwater
may leak into the tank when the static groundwater level is higher than the water level in the
tank). Conversely, when the water level in the tank is higher than the surrounding watertable, it
creates an outward hydraulic head (i.e. water is more likely to leak out ofthe tank). In this case
the potential for contaminants entering the tank from groundwater is greatly reduced.
Although it diminishes the usable capacity ofthe clearwell, the Fayetteville PWC currently
maintains the water level in the tank high enough to maintain an outward hydrauUc gradient.
Water samples are collected from the tank on a frequent basis, and, to date, no detections of site
related contaminants have occurred^. AdditionaUy, based upon data coUected by NCDENR
(Ref 9), it appears that the static groundwater level in the more contaminated portion ofthe
plume proximate to the clear-weU is lower than the elevation ofthe bottom ofthe tank (Figure
6). This situation may be due to a combination of factors including the slurry waU, toe drain,
operation ofthe groundwater recovery wells, and natural groundwater flow conditions.
11*11
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K 1 • • •
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\Mciter level in tank
:> a>n^i ^n ^n -• - N - N -i
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riirprii'-V-*!-"!!-"!!-"!!-' nn Water (evel in tank
ssUsi
lilM!SffSS^K*$fii! 1JMJI
^••••^H ^^^^^^^^^^^^^1 ^^^^^^^^^^H ^^^^^^^^^^H
Figure 5. Two potential scenarios with respect to the clearwell at the Fayetteville Hoffer
clearwell. Scenario A: When the water level in the tank is maintained at a level higher than the
static watertable, an outward hydraulic gradient is created. Scenario B: Ifthe water level in the
tank drops below the level ofthe static water level an inward hydraulic gradient is created and the
probability that contaminated water might seep into the tank increases. Note: Extent of watertable
depression due to toe drain is unknown.
§300.415(b)(2)(iii) - Hazardous substances or pollutants or contaminants in drums, barrels,
tanks, or other bulk storage containers, that may pose a threat of release.
The dye room ofthe plant contained a number of 55-gaUon drums and other containers. All
appeared to be empty at the time ofthe inspection. The 45,000 gaUon fuel-oil tank located east
ofthe plant building was used to store fuel oU (Ref. 4, 11) and appeared at the time ofthe
removal assessment to be in good condition and to have satisfactory secondary containment.
Other above-ground storage tanks east ofthe plant were reportedly used to store acetic acid,
fabric softener, and brine solution (Ref 4). These tanks appeared to be in good condition and to
have adequate secondary containment. Both the above groimd PCE tank and the PCE distUlation
unit have been removed from the site. Underground tanks at the site were reportedly removed or
closed in place in 1993 (Ref 11).
o7/2aoi oanaoi osnsAJi IOQSAJI II/I5«I 12/13/01 01/28/02 02/2SA)2 03naA)2 0^22x12 0510S102 oemiai 07/17/02 07/17/02
GV\M7 GW-19
Figure 6. Measured water levels in monitoring wells proximate to the Hoffer clear-well. The heavy black
line is the reported elevation ofthe bottom ofthe clear-well. Light dashed lines are monitoring
wells that have not displayed detections of site-related hazardous substances above MCLs.
Heavy, solid, grey lines are monitoring wells that have displayed concentrations of site- related
hazardous substances above MCLs. All the wells displaying MCL exceedances are located
proximate to the westem portion ofthe clear well. Source: Ref 9.
§300.415(b)(2)(iv) - High levels of hazardous substances or poUutants or contaminants in soils
largely at or near the surface, that may migrate.
AvaUable analytical data suggest that high levels of hazardous substances do not exist within
surface so Us at the site. The data are consistent with expectations as the contaminants of concem
are volatile organic compounds that evaporate quickly and would thus not be persistent in
surface soUs.
§300.415(b)(2)(v) - Weather conditions that may cause hazardous substances or pollutants
or contaminants to migrate or be released.
Weather conditions are not thought to be a significant factor in the case ofthis site.
§300.415(b)(2)(vi) - Threat of fire or explosion.
Threat of fire or explosion is not thought to be a significant factor in the case ofthis site.
§300.415(b)(2)(vii) - The availability of other appropriate federal or state response
mechanisms to respond to the release.
NCDENR fimded constmction ofa slurry waU upgradient of clear weU and instaUation of
groundwater extraction wells to provide for hydraulic control ofthe down gradient edge ofthe
plume. The system has been in operation since 2001. NCDENR has indicated to EPA that it has
sufficient funds to maintain the system untU some time in 2004 (Ref 1). Texfi is not a National
Priorities List site.
§300.415(b)(2)(viii) - Other situations or factors that may pose threats to public health or
welfare ofthe United States or the environment.
No other appUcable situations or factors have been identified in the case ofthis site.
V. RECOMMENDATION
Based upon current information, it appears that contamination at the Texfi site faUs outside the
scope ofthe removal program. Site related contaminants have not been detected in the Cape
Fear River or in the clear weU at the FayettevUle Hoffer Treatment Plant. AvaUable data
indicate that surface soUs do not present a significant threat to nearby human populations or
sensitive ecosystems. AvaUable data suggest that significant, subsurface soU contamination
exists in the vicinity ofthe former PCE distillation unit. However, these soUs do not present a
significant direct contact threat, and there are no known groundwater receptors in the vicinity of
the site. HistoricaUy, Region 4 has refrained from conducting removals at groundwater
contamination sites where there are no potential receptors and which do not otherwise meet the
criteria set fourth under 40 CFR §300.415(b).
VL REFERENCES
1. Immediate Removal Evaluation Request. Harry Zinn, Superfund Section, North Carolina
Department of Environment and Natural Resources to Myron Lair, Chief, Emergency
Response and Removal Branch, U.S. EPA, Region 4. March 11, 2002.
2. U.S. Geological Survey. Vander Quadrangle. U.S.G.S. 7.5 minute topographic
quadrangle. 1:24,000. 1983.
3. Limited Site Assessment Report: Texfi FacUity, Fayetteville, North Carolina. Prepared
by Mid-Atlantic Associates, P.A. for Cherokee Environmental Risk Management.
Incident No 13601. January 23, 2001.
4. Phase I Environmental Site Assessment Texfi Property (Draft Report). Prepared by
Camp Dresser & McKee for the PubUc Works Commission ofthe Cit of Fayetteville,
North Carolina. May 2000.
5. Code of Federal Regulations. Title 40. Part 300. July 1,2000.
6. Site Sampling Letter Report: Texfi Industries Site, Fayetteville, Cumberland County,
North Carolina (Revision 0). TDD No. 4W-02-05-A-005. Prepared by Weston
Solutions, Inc., START-2. Lori Skidmore (Project Manager) for U.S. Environmental
Protection Agency, Region 4 Emergency Response and Removal Branch. October 7,
2002.
7. Site SampUng Phase 2 Letter Report. Texfi Industries Site Fayetteville, Cumberland
County, North CaroUna (Revision 0). TDD No. 4W-02-05-A-005. Prepared by Weston
Solutions, Inc., START-2. Lori Skidmore (Project Manager) for U.S. Environmental
Protection Agency, Region 4 Emergency Response and Removal Branch. March 28,
2003.
8. PreUminary Remediation Goals (PRGs). EPA Region 9: Superfimd.
http;//www.epa.gov/region09/waste/sflind/prg/index.htm. 2002.
9. Texfi Interim Remedial Measures Project: Additional Piezometer InstaUation and
Sampling. Prepared by Camp, Dresser, & McKee for North Carolina Department of
Environment and Natural Resources. Revised September 2002.
10. Clearwater Reservoir Piping Modifications. Engineering Drawing. Prepared by
Environmental Engineering & Technology, Inc. for PubUc Works Commission, City of
FayettevUle, North CaroUna. Sheet 2 of 15. June 1997.
11. Phase I Environmental Site Assessment, Texfi Industries, Inc., FayettevUle, North
CaroUna. Aquaterra. Febmary 13, 1996.
Vn. CONCURRENCE/NONCONCURRENCE
( ) 1 concur with the conclusions and recommendations made by the On-Scene Coordinator.
( ) I do not concur with the conclusions and recommendations made by the On-Scene
Coordinator.
Don Rigger, Chief Date
Emergency Response Section
(l/f 1 concur with the conclusions and recommendations made by the On-Scene Coordinator.
( ) I do not concur with the conclusions and recommendations made by the On-Scene
Coordinator.
'^^Plrt/^ ^ f-7lP •d'^
CharUe Fitzsimmons, OSC Date
Removal Assessment Team
c/webster/removal sites/texfi/texfi.polrepl .finaLwpd
^ In some cases, saturated soil conditions prevented collection ofa sample from the 2.5 - 3.0 foot interval. In
these cases, the lowermost sample was collected as far below the 1.5-2.0 foot interval as possible.
^ Ref 10 (Engineering Drawings), indicate that the elevation ofthe invert ofthe toe drain is at 83.03' and
81.14' (amsl) at the northwest and northeast comers ofthe toe drain, respectively.
•' Available data indicate that trichloromethanes are routinely detected in the clearwell. These are likely
produced during the water treatment process.
r
11. Phase I Environmental Site Assessment, Texfi Industries, Inc., Fayetteville, North
Carolina. Aquaterra. February 13, 1996.
VIL CONCURRENCE/NONCONCURRENCE
( ) 1 concur with the conclusions and recommendations made by the On-Scene Coordinator.
( ) I do not concur with the conclusions and recommendations made by the On-Scene
Coordinator.
2^/h/^f-03
Don Rigger, Chief / *-' Date
Emergency Response Section
(X) , 1 concur with the conclusions and recommendations made by the On-Scene Coordinator.
( ) 1 do not concur with the conclusions and recommendations made by the On-Scene
Coordinator.
Charlie Fitzsimmons, OSC Date
Removal Assessment Team
c/webster/removal sites/texfi/le,\fi.polrepl .final.wpd
Texfi Polrep 1: Page 24 of 24
REFERENCE 13
i·
North Carolina A
Department of Environment and Natural RJI!I!!!'urces
Division of Waste Management
Mic~ael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Mr. Myron Lair, Chief
March 11, 2002
Emergency Response and Removal Branch
US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
Subject: Immediate Rel_Iloval Evaluation Request
Texfi Industries, Inc.
601 Hoffer Road
Fayetteville, Cumberland County, North Carolina
NONCD 000 1075
Dear Mr. Lair,
As per our discussions with Don Rigger in Raleigh on March 5, we are forwarding
information about the Texfi Industries, Fayetteville site. The NC Superfund Section requests
that the US EPA evaluate the site for a possible removal action. The site involves chlorinated
solvents in groundwater immediately adjacent to a clear well at a municipal water treatment
plant serving approximately 145,000 people. Contaminant source areas are numerous, poorly
characterized and located within 400 feet of the clear well. Phil Vorsatz has reviewed a draft
version of our Pre-CERCLIS Site Screening, and will be able to answer questions you may
have about the site.
The Texfi site is a 95.6 acre property located at 601 Hoffer Road in Fayetteville, North
Carolina. The geographic coordinates for the site based on the northeast corner of the Texfi
building are 35° OS' 02.97" north latitude and 78° 52' 02.5~" west longitude (Attachment 1).
In 1968/69 the first permanent structure known as Fayetteville Finishing Corporation
was located on the site. From that time until October 1999 when on-site operations ceased,
the site has been utilized as a textile manufacturing facility. This consisted of yarn
preparation, weaving, dyeing, and finishing. The dyeing and finishing processes were
suspended from 1980 until1988. Since 1999, the site has been inactive. Texfi Industries is
currently in bankruptcy.
Numerous Enviroiunental Site Assessments and sampling events have been conducted
at this site. The first report is "Above Ground Tank Dike Remediation Report, Tex:fi Blends,
601 Hoffer Drive Fayetteville, North Carolina" dated March 6, 1995 by Legacy
Environmental Services. This report addressed the remediation of contaminated water and
soils within a diked area around a 45 foot diameter above ground storage tank (AST) used to
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNilY \AFFIRMATIVE ACTION EMPLOYER-SO% RECYCLED /10% POST CONSUMER PAPER
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Partners have made no further inquiries concerning redevelopment of the property.
Camp Dresser & McKee (CDM), on behalf of PWC, sent a letter dated February 19,
2001 to Charlotte Jesneck, Head of State Inactive Hazardous Sites Branch (SIHS) with the
subject, " Recommendations for Remedial Investigation at the Texfi Facility, Fayetteville,-
North Carolina". This report recommended an interceptor trench, recovery wells and further
assessment be performed. A bid package was prepared based on some of these
recommendations and on March 13, 2001 a contract was let between SIHS and CDM. Since
that time the following areas have been addressed.
Numerous piezometers previously installed both on the Texfi site and the Hoffer
property have been sampled.-Analysis of samples collected from these have documented
contaminated groundwater migration from the Texfi site to the Hoffer site at levels
significantly higher than Drinking Water Standards (Reference 2). Wells within 20 feet of the
clear well have tetrachloroethene (PCE) concentrations up to 9,000 ug/1 and cis 1,2-
Dichloroethene (1,2-DCE) up to 23,000 ug/1.
Samples collected from a drainage ditch running between the Texfi site and the clear
well indicate tetrachloroethene (PCE)(11400 ug/1), trichloroethene (TCE)(2800 ug/1), and
other degradation products as well. This ditch would be consider to be the Probable Point of
Entry for the surface water pathway from the Texfi site. It is approximately 400 feet upstream
of the surface water intake for the P.O. Hoffer treatment facility. Surface water and sediment
samples collected from the Cape Fear River have not documented any release of any
contaminants to the river.
A soil-bentonite slurry wall approximately 450 foot long was constrUcted between the
Texfi site and the clear well. This wall was installed to prevent the migration of contaminants
to the clear well area. Three recovery wells were installed in conjunction with the wall to
reduce contaminant levels around the clear well and to prevent further migration of
contaminants to the clear well toe drain area. Initial sampling of these wells showed levels of
PCE as high as 9400 ug/1 on 5/23/01. More current analysis of the discharge.from these
wells indicate PCE as high as 21000 ug/1 and TCE as high as 2000 ug/1.
The clear well located on the Hoffer site is an in-ground concrete tank, approximately
300 ft. By 500 ft., with a floor elevation of 84.5 ft above sea level. The first portion of the
clear well was constructed in 1969, was located on the north side, closest to Texfi and had a
capacity of 2 million gallons~ The second phase in 1974 added 10 million gallons capacity and
a french drain on the south side of the clear well. The remainder of the toe drain system,
which now surrounds the clear well, was installed in 1996. Based on two piezometric surveys
in February 2001 by CDM, the water table is as high as 86.7 in the vicinity of the clear well.
The clear well is a segmented tank with segments being flushed on a routine basis. While
being flushed, the segment is totally drained, potentially allowing a negative head to develop
with respect to the groundwater. The clear well is not a monolithic structure, but has joints
that may allow seepage into or out of the tank. No further treatment occurs after the treated
water enters the clear well.
Since March 21, 2001 CDM has taken weekly samples of the water dischBJging from
the clear well at a tap located inside a laboratory on the P.O. Hoffer site. None of these
samples has indicated any contaminants associated with the chlorinated solvents or their
degradation products. On two occasions samples were collected directly from the
northeastern most segment of the clear well via a peristaltic pump. Neither of these samples
indicated contaminants other than the trihalomethanes associated with the chlorination process.
The State Inactive Hazardous Sites Branch currently has a contract with CDM to
operate the recovery wells and continue monitoring the groundwater around the clear well for
two more years. After that time, no monies will be available to continue the monitoring of
this site. No further investigation of the on-site sources on the Texfi property is currently
funded. The owners/operators of the Texfi site are in bankruptcy and no monies are expected
to be recovered. Based on these facts and a discUssion concerning this site with Don Rigger,
Chief Removal Operations Section, we request that this site be evaluated for an emergency
removal. This is based on the potential of the clear well being impacted by contaminated
ground water emanating from the site and the potential of the surface water intake currently
supplying P.O. Hoffer Treatment facility being impacted if the contaminated ground water is
allowed to continue to migrate toward the Cape Fear River.
Attached are the latitude and longitude worksheets, Table 4 and Figure 3 from Texfi
Interim Remedial Measures Report, September 2001 Monthly Progress Report by CDM, and ·
three drawings showing construction of the clear well. Additional State funds, other than
. those committed for the continued monitoring of the site, are not available at this time. Please
let us know if and when a field evaluation can be conducted so we may coordinate your site
visit with our staff. Please feel free to contact me at [phone] ext. 313 or by e-mail at
han:[e-mail] if you have any questions or comments.
Sincerely,
~<._. HarryZ~
Environmental Engineer
NC Superfund Section
Attachments
CC: Scott Ross-File
Don Rigger, US EPA
CC: (Letter Only)
Jack Butler DWM
Charlotte Jesneck DWM
Jennifer Wendel, USEPA
Phil Vorsatz, USEPA
Chrystal Bartlett, DWM
-··~·
I im Bateson, Head
Site Evaluation and Removal Branch
NC Superfund Section
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REFERENCE 14
REFERENCE 15
REFERENCE 16