Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
NCD044447589_20170930_2017 Blue Ridge Plating FYR
Second Five-Year Review Report Blue Ridge Plating Site Arden, Buncombe County, North Carolina US EPA ID: NCD 044 447 589 Prepared for US Environmental Protection Agency Region 4 It PRO^l SEPTEMBER 2017 Prepared by North Carolina Department of Environmental Quality Raleigh, North Carolina din E. Hill, Director Superfund Division Dfte 11070115 TABLE OF CONTENTS LIST OF ABBREVIATIONS & ACRONYMS............................................................................iii I. INTRODUCTION......................................................................Error! Bookmark not defined.I Site Background.........................................................................................................................1 FIVE-YEAR REVIEW SUMMARY FORM.................................................................................2 II. RESPONSE ACTION SUMMARY...............................................................................................3 Basis for Taking Action............................................................................................................3 Response Actions........................................................................................................................4 Status of Implementation.........................................................................................................8 IC Summary Table......................................................................................................................9 Systems Operations/Operation & Maintenance...................................................................10 III. PROGRESS SINCE THE LAST REVIEW..................................................................................11 IV. FIVE-YEAR REVIEW PROCESS...............................................................................................13 Community Notification, Involvement & Site Interviews...................................................13 Data Review..............................................................................................................................13 Site Inspection...........................................................................................................................17 V. TECHNICAL ASSESSMENT.....................................................................................................18 QUESTION A: Is THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS?.........18 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, AND REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF THE REMEDY SELECTION STILL VALID?................................................................................... 18 QUESTION C: Has any other information come to light that could call INTO QUESTION THE PROTECTIVENESS OF THE REMEDY?...............................................20 VI. ISSUES.......................................... .20 Other Findings..........................................................................................................................21 VII. PROTECTIVNESS STATEMENT..............................................................................................22 VIII. NEXT REVIEW.........................................................................................................................22 APPENDICES APPENDIX A - APPENDIX B - APPENDIX C - APPENDIX D - APPENDIX E - APPENDIX F - APPENDIX G - APPENDIX H - APPENDIX I - REFERENCE LIST SITE CHRONOLOGY SITE INPSECTION CHECKLIST SITE MAPS/FIGURES ARAR REVIEW NEWSPAPER AD/INTERVIEWS 2016 ANNUAL DATA EVALUATION 2017 DECLARATION OF PERPETUAL LAND USE RESTRICTIONS 2017 EPA MEMORANDUM-HYDROGEOLOGY REVIEW Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County. NC TABLES TABLE 1 Soil Remediation Levels as Specified in the 2004 ROD...........................................7 TABLE 2 Groundwater Remediation Levels as Specified in the 2004 ROD.............................7 TABLE 3 IC Summary Table................................................................................................10 TABLE 4 O&M Costs and Events Conducted for 2012-2016.................................................11 TABLE 5 Protectiveness Determination/Statement from 2012 FYR.......................................12 TABLE 6 Explanation and Discussion of Recommendations and Issues from 2012 FYR......12 TABLE 7 COCs Detected Above Remediation Levels and/or NC2L (2013-2016).................15 TABLE 8 Trend Evaluation of the Groundwater data from 2007 to 2016...............................16 TABLE 9 ARAR Comparison of Remediation Levels and Current Standards........................19 TABLE 10 Groundwater Standards for Compounds Not-Specified in the ROD and Currently detected in Groundwater........................................................................20 TABLE 11 Issues and Recommendations.................. 21 FIGURES FIGURE 1 Site Location Map..............................................................................................D-1 FIGURE 2 General Site Plan................................................................................................D-2 FIGURE 3 Soil Sampling Grid Locations.............................................................................D-3 FIGURE 4 Groundwater Monitoring Well Locations............................................................D-4 FIGURES IC Overlay Map..................................................................................................D-5 Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County, SC LIST OF ACRONYMS ARAR Applicable or Relevant and Appropriate Requirements BHHRA Baseline Human Health Risk Assessment bis Below Land Surface BRP Blue Ridge Plating CERCLA Comprehensive Environmental Response, Compensation, and Liability Act cis-l,2-DCE cis-1,2-Dichloroethene COC Contaminant of Concern 1,1-DC A 1,1 -Dichloroethane 1,2-DCA 1,2-Dichloroethane 1,1-DCE 1,1 -Dichloroethene ESD Explanation of Significant Difference EPA Environmental Protection Agency FYR Five-Year Review 1C Institutional Controls MCL Maximum Contaminant Level Mg/kg milligrams per kilograms MNA Monitored Natural Attenuation MW Monitoring Well NC 2L North Carolina Groundwater Standard NCAC North Carolina Administration Code NC DENR North Carolina Department of Environment and Natural Resources NC DEQ North Carolina Department of Environment Quality NCP National Contingency Plan NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PCE Tetrachloroethene RAO Remedial Action Objective RAWP Remedial Action Work Plan RCRA Resource Conservation and Recovery Act RI Remedial Investigation ROD Record of Decision RPM Remedial Project Manager SARA Superfiind Amendments and Reauthorization Act SVOCs Semi Volatile Organic Compounds 1,1,1-TCA 1,1,1 -Trichloroethane 1,1,2-TCA 1,1,2-Trichloroethane TCE Trichloroethene l^g/L micrograms per Liter U.S.C.United States Code VOC Volatile Organic Compound yd^cubic yards I. INTRODUCTION The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in FYR reports. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them. The North Carolina Department of Environmental Quality (NC DEQ) prepared this FYR for the U.S. Environmental Protection Agency pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP) (40 CFR Section 300.430(f)(4)(ii)), and considering EPA policy. This is the second FYR for the Blue Ridge Plating Site (BRP Site or Site). The triggering action for this statutory review is the completion date of the previous FYR, September 26, 2012. A FYR has been prepared due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure. The Site consists of one operable unit (OU), which is addressed in this FYR. The OU addressed both contaminated soil and groundwater. The BRP Site FYR was led by NC DEQ. Participants included Stephanie Grubbs (NC DEQ Hydrogeologist), Beth Hartzell (NC DEQ Environmental Engineer), Jon Bornholm (EPA Remedial Project Manager [RPM]), and Angela Miller (EPA Community Involvement Coordinator). The review began on January 1, 2017. Site Background The BRP Site is located at 171 Glenn Bridge Road, Arden, Buncombe County, North Carolina and occupies 3.06 acres. No structures remain on the property due to an emergency response action initiated in December 2014 by the EPA and completed in May 2015. The Site is bounded to the north by Glenn Bridge Road, to the east by an uimamed dead-end road, and to the south and west by wooded wetland areas. This wetland area has been designated as a wetland by the U.S. Army Corps of Engineers. The following figures can be found in Appendix D: Figure 1 is a Site Location Map and Figure 2 is a General Site Layout Map. The BRP Company was a metal plating company, which operated business from 1974 to 2014 and used black oxide, cadmium, chromium, copper, cyanide, tin, and zinc in the electroplating processes. From 1974 to 1985, electroplating wastes were collected in drums located in the basement where plating sludges were filtered out and the wastewater was directed to a 70,000-gallon in-ground concrete lagoon located behind the shop. Plating sludges were shipped off Site for disposal and the wastewater was either sprayed on the ground or reused as process water. Between 1985 and 1990 the wastewater was discharged to the local municipal sewer system. In 1990, the municipality suspended access to the sewer system because BRP was not meeting pretreatment requirements. After that suspension, BRP employed a closed loop reclamation system, which was located in the basement. Second Five-Year Review- Blue Ridge Plating Site Arden. Buncombe County. NC Land use around the Site is primarily rural to light industrial. The nearest school is 1.5 miles north and the nearest residence is approximately 500 feet to the west. Site drainage enters an uimamed tributary south of the former concrete lagoon area. The unnamed tributary flows from the Site through an area of forested wetlands into another unnamed tributary. This tributary drains into Lake Julian which empties into the French Board River. Both Lake Julian and the French Board River are classified and protected by the State of North Carolina as water supplies suitable for aquatic life propagation and survival, fishing, wildlife, secondary recreation and agricultural. Lake Julian was created to store cooling water for a power plant located on the lake's northeastern shore. Currently, the entire immediate area around the Site is connected to a municipal water supply system. FIVE-YEAR REVIEW SUMMARY FORM SITE IDENTIFICATION Site Name: Blue Ridge Plating Site EPAID: NCD044447589 Region: 4 State: NC City/County: Arden, Buncombe County SITE STATUS NPL Status: Final Multiple OUs? No Has the site achieved construction completion? Yes REVIEW STATUS Lead agency: US EPA Author name (Federal or State Project Manager): Beth Hartzell (NC DEQ-Engineer)/Stephanie Grubbs (NC DEQ-Hydrogeologist)/Jon Bornholm (US EPA-RPM) Author affiliation: NC DEQ and US EPA Review period: 01/01/2017 - 09/26/2017 Date of site inspection: 02/09/2017 Type of review: Statutory Review number: 2 (second) Triggering action datej: 09/26/2012 Due date (five years after triggering action date): 09/26/2017 Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County, NC II. RESPONSE ACTION SUMMARY Basis for Taking Action Potential complete exposure pathways to human and ecological receptors were identified in the 2004 Record of Decision (ROD) based on data collected for the 2004 Baseline Human Health Risk Assessment (BHHRA). The exposure scenarios are discussed further in the following section, Response Action-Summary of Pre-ROD Activities, of this FYR. Contaminants found on the Site that warranted remedial action include: For Soil - Volatile Organic Compounds (VOCs): Tetrachloroethene (PCE) 1.1.1 -Trichloroethane (1,1,1 -TCA) Semi-Volatile Organic Compounds (SVOCsl: 2-Methylnaphthalene Naphthalene Inorganics: Cadmium Chromium Cyanide Iron Manganese. For Groundwater - Volatile Organic Compounds (VOCs): Chloroform 1.1 -Dichloroethane (1,1 -DCA) 1 j 1 -Dichloroethene (1,1 -DCE) Trichloroethene (TCE) PCE 1,1,1-TCA Semi-Volatile Organic Compounds (SVOCsl: 2-Methylnaphthalene Naphthalene Pentachlorophenol Inorganics: Arsenic Cadmium Cyanide Iron Manganese Nickel. Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC Based on historical records, the following areas of the Site were identified as sources of contamination: • Contaminated soil at the backdoor of the workshop, an alleged location of illicit dumping, • Contaminated soil behind the building near a broken pipe, • Contaminated soil in the abandoned vat area, and • Contaminated soil near the former concrete lagoon. Response Actions Summary of Pre-ROD Activities: BRP has been the subject of numerous investigations, warnings, violations, and court orders from the EPA and the North Carolina Department of Environment and Natural Resources (NCDENR, currently the NC Department of Environmental Quality, DEQ). In December 1980, NCDENR inspected the facility under Resource Conservation and Recovery Act (RCRA). Soil samples revealed the presence of 1,1,1-TCA, TCE, toluene, and cadmium. NCDENR sent BRP a compliance order in March 1987. In June 1989, NCDENR RCRA inspectors determined the facility had not address numerous aspects of the March 1987 compliance order. After 1990, BRP claimed the facility discontinued discharging wastewater to the sewer system. However, the Federal Bureau of Investigation ascertained the facility continued to discharge to the sewer system. In 1991, a federal court found BRP guilty of discharging heavy metals in excess of legal limits to the sewer system. In 1993, NCDENR served another injunction to BRP for not submitting a closure plan. In 1997, NCDENR received a complaint that BRP was disposing of plating wastes by dumping them outside the back door and through cracks in the floor. Consequently, NCDENR requested the EPA to collect environmental samples at the facility. The April 1998 sampling effort found elevated levels of cadmium, chromium, copper, cyanide, nickel, tin, and zinc in samples collected from inside and outside the BRP building. As a result of this sampling effort, the facility was placed in Comprehensive Environmental Response, Compensation, and Liability Information System in October 1998. NCDENR conducted the Preliminary Assessment/Site Inspection in July 1999 and an Expanded Site Investigation was conducted in September 2000. In an October 2002 correspondence, the NCDENR RCRA Program deferred the Site to the Superfund Program. From September 2002 through September 2004, a Remedial Investigation/Feasibility Study (RI/FS) was conducted. The RI characterized the nature and probable extent of the hazardous waste at the Site in soil, groundwater, and surface water/sediment. The major key points of the RI are summarized below: • Thirteen of the twenty surface soil sample locations indicate inorganic contamination higher than regulatory limits. • Groundwater at the BRP Site contains inorganic and organic constituents at concentrations greater than the lowest regulatory screening values. • The most important fate and transport processes acting on contaminants in the groundwater at the site are most likely: Adsorption and advection for inorganic contaminants; Biodegradation or other transformation reactions for volatile organic contaminants; and Adsorption and biodegradation for semi-volatile organic contaminants. Oxidizing conditions are likely to exist in the groundwater at the BRP Site as evidenced by the high redox and dissolved oxygen values Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC recorded during groundwater sampling; therefore, constituents such as chromium, nickel, and zinc may be the more susceptible inorganics to migrate in groundwater. • Overall, inorganic contamination associated with the electroplating process is widespread throughout the various environmental media at the BRP Site. Based on surface water and sediment samples collected offsite, the only constituents that have appeared to migrate considerably in these media are copper, cyanide, and zinc. A BHHRA was conducted as part of the RI. The BHHRA evaluated the contaminants associate with surface and subsurface soils; shallow and deep surficial groundwater, and surface water and sediment along exposure pathways and receptors. Risks were evaluated for the following four scenarios; future on-Site adult/child resident; on-Site industrial worker; construction worker; and adolescent trespasser. The results concluded there were no current unacceptable carcinogenic or non-carcinogenic risk for any of these four scenarios. None of these four scenarios resulted in an unacceptable future carcinogenic or non-carcinogenic risk for an adolescent trespasser. However, hypothetical exposure scenarios resulted in potential unacceptable risk for future construction worker and adult/child resident. The largest contributor for the construction worker was ingestion of and dermal contact with metals in the soil as well as metals ingestion in groundwater. The largest contributor to the future adult/child resident included ingestion of and dermal contact with polycyclic aromatic hydrocarbons and arsenic in the surface soil as well as ingestion and dermal contact of VOCs in the groundwater. An ecological risk assessment was also conducted and the area of concern for ecological risk coincides with the area of concern for human health. The conclusion reached in the "Toxicity and Bioaccumulation Potential of Sediment Samples from BRP Site ” (August 2006) was while it was unclear if sediments would be toxic or bioaccumulate, the concentrations are above the alternative toxicity values, indicating a possible issue on the south side of the unnamed tributary. On September 14, 2005, the Site was placed on the National Priorities List (NPL) established pursuant to 42 United States Code (U.S.C.) Section 9605(a)(8). Remedial Action Objectives (RAOs): The ROD for the Site was signed on September 29, 2004. As stated in the 2004 ROD Section VllI: RAOs, "CERCLA, as amended by Section 121(b) o/Superfund Amendments and Reauthorization Act (SARA), requires the selection of remedial actions that attain a degree of cleanup which ensures protection of human health and the environment, are cost effective, and use permanent solutions and alternative treatment technologies or resource technologies to the maximum extent practicable. To satisfy CERCLA requirements, RAOs were developed for the Blue Ridge Plating Site. RAOs will be used to develop general response actions for the Site that are protective of current and future construction worker, future Site residents, and the environment. The key contaminants of concern (COCs) are metals along with a number of volatile organic compounds (VOCs) and semi- volatile organic compounds (SVOCs). The soil/sediment cleanup goals were derived from predominantly leachate models for the metals in order to be protective of the underlying groundwater along a health based risk level for chromium. The groundwater cleanup goals were based on Applicable or Relevant and Appropriate Requirements (ARARs) (North Carolina Groundwater Classifications and Standards (ISA NCAC 2L) (NC 2L)) or background concentrations. The following are Site-specific RAOs for each environmental medium: Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC Surface Soil/Dry Sediment • Prevent ingestion, inhalation, or direct contact with soil containing contaminants at concentrations in excess of total hazard indices greater than I and/or a cumulative excess lifetime cancer risk greater than one out of one ten thousand (1 out of10,000) for a future construction worker use scenario. • Prevent migration of contaminants to prevent degradation of natural resources. The presence of the contaminants in the soil matrix presents a possible source for groundwater at the Site via leaching and surface water/sediment contamination at the Site via surface runoff. Groundwater • Prevent ingestion or direct contact with groundwater containing constituents at concentrations in excess of current NCAC 2L groundwater standards or federal regulatory drinking water standards (Maximum Contaminant Levels) MCLs and total Hazard Indices greater than 1. • Prevent migration of contaminants to prevent degradation of natural resources." Table 1 is the Soil Remediation Levels as specified in the 2004 ROD along with the rationale for the remediation goal. Table 2 is the Groundwater Remediation Levels as specified in the 2004 ROD as modified by the 2008 Explanation of Significant Difference (ESD) along with the rationale for the remediation level. Appendix E presents a discussion of Site ARARs. Remedy Components: 2004 ROD; The 2004 ROD required the following cleanup activities: • Excavation, treatment (if needed), and off-Site disposal for contaminated soils/sediments, which exceed cleanup levels. • Monitored Natural Attenuation (MNA) for contaminated groundwater. In the event MNA cannot be substantiated after the removal of the contaminated soils, a groundwater contingency remedy includes in-situ chemical oxidation/reduction/immobilization and long-term monitoring. The decision to implement a contingent remedy will be made after three years of collecting groundwater data following the completion of the soil cleanup. • Installation of additional groundwater monitoring wells and conducting groundwater modeling to assess MNA. • Implementation of institutional controls (ICs). • Conduct FYRs every five years until the levels of contaminants in the groundwater reach their specific cleanup level. 2008 Explanation of Significant Difference fESD): In June 2008, an ESD was issued for the Site to correct a transcription error in Table 18 of the 2004 ROD that listed the cleanup levels for COCs in the groundwater for 1,1-DCA. The cleanup goal for 1,1- DCA in the ROD was stated to be 0.38 micrograms per liter (pg/L) when the actual concentration should have been 700 pg/L, based on the 2004 NC 2L Groundwater Standard. This correction did not change, alter, or modify the groundwater remediation strategy or the anticipated cleanup time frame for the groundwater remedial action. Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County, NC Table 1: Soil Remediation Levels Contaminant Leachability of Soil Contamination to Groundwater (mg/kg) Remediation Level (mg/kg) Rationale for Remediation Level VOCs Tetrachloroethene (PCE)7.4 7.4 1 1,1,1-Trichloroethane (1,1,1-TCA)1,670 1,670 1 SVOCs 2-Methylnaphthalene 1,720 1,720 1 Naphthalene 585 585 1 Inorganics Cadmium 2.7 2.7 1 Chromium -882 2 Cyanide 31.1 31.1 1 Iron 151 49,000 3 Manganese 65.2 772 4 NOTES: 1. mg/kg = milligrams per kilogram 2. Concentration of constituent that remain in soil without leachate adversely impacting groundwater quality above the NC 2L Standard 3. Construction worker scenario from Baseline Human Health Risk Assessment 4. Regional soil concentration obtained from NCDENR (currently NCDEQ) 5. Site specific background concentration Table 2: Groundwater Remediation Levels Contaminant Remediation Level I Rationale for (pg/L) 1 Remediation Level vocChloroform 0.19 1 1,1 -Dichloroethane (1,1 -DCA)700*1 1,1 -Dichloroethene (1,1 -DCE)7 1 Tetrachloroethene (PCE)0.7 1 1,1,1 -Trichloroethane (1,1,1 -TCA) 200 1 Trichloroethene (TCE)2.8 1 SVOC 2-Methylnaphthalene 14 1 Naphthalene 21 1 Pentachlorophenol 0.3 1 Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC Table 2: Groundwater Remediation Levels Contaminant Remediation Level (Hg/L) Rationale for Remediation Level Inorganics Arsenic Cadmium Cyanide Iron Manganese Nickel 3,800 300 100 1 NOTES: 1. |ig/L = micrograms per liter 2. North Carolina Administrative Code 15 NCAC 02L 3. Site Specific background concentration * 2008 ESD changed Remediation Level from 0.38 micrograms per Liter to 700 micrograms per Liter Status of Implementation Soil Metals contamination appeared to be widespread in the surface soils and to a lesser extent in shallow subsurface soils, primarily 2 to 4 feet below land surface (bis). The following contaminants were identified as the BRP Site-specific COCs for soil media: PCE, 1,1,1-TCA, 2-methylnapthalene, naphthalene, cadmium, chromium, cyanide, iron, and manganese. The majority of the soil contamination was found within the top 1.5 feet. The remedial activities were conducted between December 2006 and June 2007 and included subdividing the 1.6 acres to be excavated into 50 feet by 50 feet grids (perimeter sampling expanded to approximately 2.1 acres). The remediated areas were backfilled, graded, and re seeded. A total of 13,105 tons (8,737 cubic yards [yd^]) of soil was removed and 6,105 tons (4,070 yd^) of soil was backfilled and graded. Upon completion of soil remediation activities, analytical data indicated that 39 grids and the perimeter grids had been remediated to below the action levels. However, five grids were still slightly above action levels. Refer to Appendix D, Figure 3 for a map of the grid locations. Excavation was terminated based on the fact that the results were near the remediation levels identified for the Site and the grids would be backfilled with a minimum of 2 feet of clean compacted soil. This 2 feet minimum compacted layer of clean backfill material would minimize human exposure and the threat to ecological receptors. On July 24, 2007, EPA personnel traveled to the Site to re-sample grid EG-8, which had soils notably above the remediation levels (cadmium at 21 mg/kg and manganese at 2,700 mg/kg). After marking out the boundary of the grid, two five-point composite soil samples were collected from this grid. To insure the soil cleanup effort was successful, this same sampling effort was duplicated for grids EG-16 and EG-17. The 2inalytical results for all of the COCs for these soil samples were below cleanup levels. EPA determined that grid EG-8 met the cleanup levels. The average concentration of cadmium left on Site in all grids is approximately 1.2 mg/kg (omitting all non-detects), 8 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County. NC which is below the cleanup level. In addition, the former pond, which had silted in over the years on the adjacent downgradient property, was excavated to remove the contaminated sediment that had accumulated in the pond basin. At the request of the property owner, this excavation was not backfilled with clean fill. The property owner planned on repairing the earthen dike/dam and reforming the pond. Groundwater Volatile and semi-volatile organic contaminants were detected in isolated areas of the aquifer beneath the BRP Site. COCs for groundwater include; chloroform; 1,1-DCA; 1,1-DCE; PCE; 1,1,1- TCA; TCE; 2-methylnapthalene; naphthalene; pentachlorophenol; arsenic; cadmium; cyanide; iron; manganese; and nickel. Cadmium and manganese contamination delineate the boundaries of the plume. For the groundwater cleanup phase, the ROD selected MNA as the Remedial Action. However, injecting a reagent(s) in the underlying aquifer to oxidize/reduce/immobilize the contaminants in place along with long-term monitoring was included as a contingent remedy for groundwater. Surface Water and Sediment The BHHRA concluded that surface water was not a media of concern for any scenario; therefore, no COCs were selected. Cadmium, chromium, and iron were determined to be COCs in dry sediment/surface soil. Institutional Controls (ICs) The ROD called for ICs in the form of land use restrictions or restrictive covenants. As part of the negotiated agreement between EPA and the BRP Company, the BRP Company would place ICs on the BRP property using the State’s Declaration of Perpetual Land Use Restrictions (DPLUR) process. ICs in the form of Land Use Restrictions were signed on March 13, 2017. Appendix H contains a copy of the DPLURs for the BRP property. Table 3 summarizes the ICs status and Figure 5 is an IC overlay map of the property boundary. Groundwater contamination has been detected in off-Site monitoring wells, southwest of the property, above safe drinking water standards (NC 2Ls and/or MCLs). As stated previously, groundwater in the vicinity is not being used as a drinking water source. However, there are no instruments in place to prevent the installation of a drinking water well on the properties that have been impacted. ICs are needed on the properties were groundwater contamination is detected above safe drinking water standards. Second Five-Year Re\ iew Blue Ridge Plating Site Arden. Buncombe County. NC Table 3: IC Summary Table Media Groundwater Soil Groundwater ICs Needed ICs Called for in the Decision Documents IC Objective ICs may include but not limited to deed restrictions or covenants. To limit the use of the property for exclusively commercial or industrial purposes ICs may include but not limited to deed restrictions or covenants or local ordinances to prevent installation of potable wells into contaminated groundwater. Parcel and Deed Book/ Page(s) 9644-91-4587-00000 Deed Book 5529 Deed Page 1745 Plat Book 0172 Plat Page 0150 9644-91-2501-00000 Deed Book 1395 Deed Page 0644 Plat Book 0000 Plat Page 0000 9644-91-0522-00000 Deed Book 1686 Deed Page 0571 Plat Book 0061 Plat Page 0184 9644-81-9812-00000 Deed Book 2092 Deed Page 0230 Plat Book 0047 Plat Page 0133 Instrument in Place Declaration of Perpetual Land Use Restrictions System Operation/Operation and Maintenance (O&M) The EPA tasked Versar (formerly J. M. Waller Associates) to collect aimual groundwater samples from the Site’s monitoring well network and prepare an Annual Data Evaluation Report based on the analytical data for each sampling event. The April 2017 Data Evaluation Report presents data and information obtained during the annual sampling event in June 2016 and compares it to groundwater data collected at the Site since 2007, the completion of the soil remediation action. The 2016 sampling event included collection of samples from 27 of the 28 on-Site monitoring wells. Monitoring well MW- 19D, which is an off-Site well downgradient of the BRP property, was not sampled as the well was destroyed by construction activities. Three additional monitoring wells owned and maintained by Duke Energy were also sampled during the 2016 sampling event. These three wells are also downgradient of the BRP property and close to Lake Julian. Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC As provided by Versar, Table 4 below describes the O&M costs and the events conducted each year, which clarifies the fluctuations in O&M costs. ni. PROGRESS SINCE LAST FIVE-YEAR REVIEW This is the second FYR Report. This section includes the protectiveness determinations and statements from the 2012 FYR and the current status of those recommendations. Table 5 provides the protectiveness statement included in the 2012 FYR and Table 6 summarizes the issues and recommendations stated in the 2012 FYR report. Table 6 also provides the implementation status and/or completion of these recommendations. Table 4: O&M Costs and Events Conducted from 2012-2016 Year Cost (rounded off to nearest $100) Activities 2016 $34,300 Annual groundwater sampling event including sampling of the three Duke Energy Wells. No MNA parameters collected. 2015 $49,200 Annual groundwater sampling event including sampling of the three Duke Energy Wells. Eliminated MNA parameter analyses. Costs for 2014 annual report were incurred in 2015. 2014 $63,400 Annual groundwater sampling event plus a second mobilization to sample three wells owned by Duke Energy. Costs for 2013 annual report were incurred in 2014. 2013 $52,400 Annual groundwater sampling event including new wells installed in 2012 plus disposal of 73 investigative derived waste drums from previous Site investigations. 2012 $88,100 Annual groundwater sampling event plus additional surface water and sediment sampling for 5-year review. Installed 5 new monitoring wells to further delineate downgradient groundwater contamination. Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC Table 5: Protectiveness Determination/Statement from 2012 FYR Sitewide Sitewide Protectiveness Determination Short-term Protective Protectiveness Statement The remedy at the Site currently protects human health and the environment in the short term because 1) the soil contamination was remediated through source removal and 2) currently, no human exposure pathways exist to contaminated groundwater as municipal water is supplied at and surrounding the Site. As this is the first FYR, MNA data is currently being gathered and the appropriateness of MNA needs to be determined. However, in order for the remedy to be protective in the long-term, the following actions need to be taken to ensure long-term protectiveness: implement institutional controls, complete delineation of the VOC plume, and issue an ESD to 1) allow the collection of additional groundwater data to complete the evaluation of monitored natural attenuation and 2) revise performance standards for 1,1 -DCA and cyanide. _____ Table 6: Explanation and Discussion of Recommendations and Issues Highlighted 2012 FYR Issues Recommendations Current Status Current Implementation Status Description Completion Date (if applicable) ICs have not been implemented (i.e., NCDENR Perpetual Land Use Restrictions) Implement Perpetual Land Use Restrictions Completed Declaration of Perpetual Land Use Restrictions March 13, 2017 Downgradient of the Site needs additional groundwater investigation Install additional monitoring wells downgradient to complete plume delineation Completed Wells MW 15S and MW15D installed December 12, 2010 Completed Wells MW 16S and MW16D installed January 10, 2012 Completed Wells MW 17, MW 18, MW 19, MW20 installed December 06, 2013 Additional data is necessary in order to determine if implementing contingent groundwater remedy is necessary Issue an ESD to allow the collection of additional groundwater data to complete the evaluation of monitored natural attenuation Ongoing Adjust the three-year MNA groundwater monitoring sampling schedule to begin after the completion of the 2015 Emergency Response Action NA Current performance standards for 1,1-DC A and cyanide are not protective of human health Issue an ESD to revise performance standards for 1,1-DCA and cyanide Ongoing ESD needed NA Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County. NC In December 2013, the City of Asheville determined that the building on the BRP property was unsafe and advised no entry into the building, which subsequently closed the facility. Because of the presence of hazardous substances that remained on Site, the EPA initiated an emergency response action at the property. Based on the EPA Action Memorandum dated November 18, 2014, the City of Asheville, the EPA and the NCDEQ RCRA program documented building disrepair; numerous containers or vats of highly corrosive materials in poor condition; and evidence of suspected plating waste solid residue on the floor along the base of the plating line. The response action began in December 2014 and was completed in May 2015. The response action included a pre-demolition asbestos inspection, demolition of the building, removal of the concrete floor, removal of 3,950 tons of contaminated soil from under the footprint of the building, and abandonment of an old supply well. IV. FIVE-YEAR REVIEW PROCESS Community Notification, Involvement, & Site Interviews The NC DEQ Superfund Section performed the second FYR process for the BRP Site. Beth Hartzell (Environmental Engineer) and Stephanie Grubbs (Hydrogeologist) from NC DEQ were responsible for gathering and reviewing data for this review and compiling all the information into the FYR Report for the EPA. Telephone and/or email discussions/interviews with Jon Bornholm (EPA RPM) were conducted. The community was notified via a public notice in the local newspaper. The Asheville Citizen Times, on March 24, 2017 regarding the FYR process at the Site. A copy of the public notice is included in Appendix F. Due to a low level of interest, no community interviews were conducted for this review. This low community interest assessment was made by EPA during the emergency response action. After the FYR has been approved and signed by the EPA, copies will be placed for the public to view at: the EPA Record Center, 11* Floor, 61 Forsyth Street, SW, Atlanta, GA 30303; the information repository for the Site located at the Buncombe Skyland Library, 260 Overlook Road, Asheville, North Carolina; and, on the EPA website (https://www.epa.gov/superfund/search-superfimd-five-vear- reviews). Data Review The annual Data Evaluation Reports by Versar were developed under an EPA task order for sampling and analytical support at the Site. As stated in the report, “The goal is to collect groundwater and MNA data to evaluate whether the ongoing MNA is a viable remedy for the groundwater at the Site. ” Groundwater Since the previous FYR, four annual sampling events have occurred, March 2013, August 2014, July 2015, and June 2016. During the most recent sampling event in June 2016, gromidwater samples were collected from 27 of 28 monitoring wells. Monitoring wells located on the BRP property include: MWOlS, MWOID, MW03S, MW04S, MW05S, MW06S, MW06D, MW07S, MW08S, MW09S, MW09D, MWlOS, MWl IS, MW12S, AND MW12D. Monitoring wells located off Site include: MW13S, MW13D, MW12S, MW14D, MW15S, MW15D, MW16S, MW16D, MW17S, Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County. NC MW17D, MW18D, MW19D, AND MW20D. The “S” indicates a monitoring well screened in the shallow region of the underlying aquifer and the “D” indicates a monitoring well screened in the deeper zone of the underlying aquifer. MW19D, an off-Site well, was not sampled as the well was destroyed during construction activities at the well location. In addition, three off-Site wells (AMW-3A, AMW- 3B, and MW-10), which are owned and maintained by Duke Energy, were sampled in the 2016 sampling event. See Appendi.\ D Figure 4 for a monitoring well location map. Appendix G, 2016 Data Evaluation Report, Table 3-1 is a table of all the Groundwater Analytical Data Summary from September 2007 through June 2016. The following contaminants were detected above ROD cleanup levels during the 2016 sampling event: • 1,1-DCE: MWOID, MW06S, MW08S, MWlOS, MWl IS, MW13D, MW15S, MW16D, MW20D • Chloroform: MW06S, MWl IS, MW12D, MW13D, MW16D, MW17S, MW20D • PCE: MWOID, MW06D, MW06S, MW08S, MW09D/MW09S (upgradient wells), MWlOS, MWl IS, MW12D, MW12S, MW13D, MW14D, MW15D, MW15S, MW16D, MW17D, MW17S,MW20D TCE: MW06S, MW08S, MWl IS, MW12D, MW12S, MW13D, MW16D, MW20D Cadmium: MW03S, MW05S, MW12S Iron: MWOID, MW04S Manganese: MWOlS, MW03S, MW04S, MW05S, MW12S, MW16D, MW16S The following contaminants were not detected above ROD cleanup goals but were detected above the 2013 amended North Carolina Groundwater Standards (NC 2L) during the 2016 sampling event: • 1,1-DCA: MW06S,MW08S, MWlOS, MWl IS, MW12S,MW16D • Cadmium: MWOlS, MW16S • Iron: MWOlS, MW03S, MW13D, MW16S, MW17D, MW18D • Manganese: MWOID, MWlOS, MWl IS, MW13S, MW15D, MW15S, MW17S, MW18D In addition, the contaminants listed below were not detected during the Remedial Investigation and therefore included in the ROD but have been detected in the groundwater during recent groundwater sampling events above either current EPA MCLs or NC 2L: • 1,4-Dioxane: MWOID, MW06D, MW06S, MW12D, MW13D, MW16D • 1,1,2-Trichloroethane (1,1,2-TCA): MW6S, MWllS • 1,2-DichIoroethane (1,2-DCA): MW6S • Carbazole: MWOlS • Chromium: MW06S, MWlOS • Cobalt: MWOlS, MW05S, MW06S, MWlOS, MW12S, MW16S Groundwater analytical results indicated that chlorinated VOCs were detected at concentrations above the ROD cleanup levels in 21 of the 30 wells sampled. In the 2016 data, the highest VOC concentrations were detected in MW06S. The metals cadmium, iron, and manganese were detected above ROD cleanup levels, with exceedances of cadmium in four wells (MW03S, MW05S, MW07S, and MW12S), iron in two wells (MWOID and MW04S), and manganese in eight wells (MWOlS, MW03S, MW04S, MW05S, MW07S, MW12S, MW16D, and MW16S). Appendix G (Table 3-1) is a table of all the Gixjundwater Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC The Site Inspection Checklist notes that no vandalism was evident. All monitoring wells were located and in good condition. However, MW-7S, MW-14S, and MW-14D were unlocked and new locks for these wells are needed. The EPA said they would supply the new locks. Monitoring data is routinely submitted and the MNA groundwater monitoring is conducted annually. Appendix C is the completed Site Inspection Checklist. V. TECHNICAL ASSESSMENT Question A: Is the remedy functioning as intended by the decision documents? Yes. As stated in the 2016 Data Evaluation Report, Versar recommends continuing annual groundwater monitoring in accordance with the recommendations of the First FYR. Groundwater concentrations, based on statistical testing, suggest chlorinated VOC concentrations generally appear to be decreasing in most shallow wells. However, in the deep wells, either an increasing trend, stable trend, or no trend is evident. For inorganics, data indicates most wells display decreasing trend, stable trend, or no trend. The only metals data set with an increasing trend was iron in MW04S. One of the unresolved, carry-over issues from the First FYR was the need for an ESD to allow for the collection of additional groundwater data to complete an evaluation of the MNA remedy. This issue as stated in the previous FYR was recommended due to the ROD requiring a decision to potentially implement a contingent remedy “w/7/ be made after three years of collecting groundwater data following the completion of the soil cleanup However, as stated in the “Data Review” section, EPA/NC DEQ concur it is appropriate to continue MNA groundwater monitoring and to start the three- year MNA monitoring schedule from the completion of the 2015 Emergency Reponses Action. This three-year monitoring period would run from May 2015 to May 2018. Following the collection of this data, a decision on appropriateness of MNA at this site, using EPA’s guidance on MNA, will be made. Currently, no human exposure pathways exist to contaminated soil or groundwater. The remedy remains protective in the short-term in that ICs are in place on the BRP property and MNA groundwater monitoring is occurring annually. However, the groundwater plume has migrated off Site; therefore, it is recommended to identify and evaluate potential ICs on properties within the vicinity of the site. Question B: Are THE EXPOSURE ASSUMPTIONS, toxicity data, clean-up levels and REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF THE REMEDYSTHL VALID? No. The NC Classifications and Water Quality Standards Applicable to the Groundwater of North Carolina, NCAC Title 15A Subchapter 2L, on which some of the remedial levels are based, were last amended on June 1, 2013. CERCLA requires that the remedy comply with any standard, requirement, criteria, or limitation under any Federal environmental law (such as Federal MCLs here), as well as any promulgated State standard that is more stringent than any federal standard. Currently, six compounds have NC 2L standards more stringent than the ROD designated cleanup level. These compounds are 1,1- DCA, naphthalene, cadmium, cyanide, iron, and manganese. It should be noted that naphthalene and cyanide are currently not detected above the ROD cleanup levels or the new NC 2L. Table 9 presents a comparison of the 2005 ROD, as modified, remediation levels to groundwater current standards. Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC Table 8: Trend Evaluation of the Groundwater Data from 2007 to 20 Contaminants Naphthalene Wells with Decreasing or Probably Decreasing Trend None Pentachlorophenol Inorganics Cadmium Wells with Increasing or Probably Increasing Trend [None Cyanide Iron Manganese None MWOlS, MW06S, MW07S, MW08S MW06S None MW07S MWOlS, MW03S, MW05S, MW06S, MW08S, MWlOS, MW12D,MW13D, MW14D, MW15S, MW16S, MW16D, MW17S, MW17D, MW20D None None Wells with No Trend or Stable Trend MWOlS None MW04S None MWOlS MW03S, MW05S, MW12S MW03S, MW05S, MW08S MW04S, MW07S, MW12S, MW13S,MW18D In June 2017, the US EPA reviewed the most recent groundwater data as part of the FYR. It was noted that the recent remedial action (the Emergency Response Action which occurred from December 2014 through May 2015 and included the demolition of the on-Site dilapidated building and removal of 3,950 tons of contaminated soil from under the footprint of the building) appears to have caused a brief increase in groundwater contaminant concentrations due to the increased groundwater recharge through the contaminated areas as the soils were being excavated or disturbed. This soil disturbance would only be reflected in the groundwater data from the most recent monitoring results, July 2015 and June 2016. Appendix I is a copy of the 2017 EPA Memorandum-Hydrogeology Review. As stated in the ROD, the decision to implement a potential contingent remedy "'will be made after three years of collecting groundwater data following the completion of the soil cleanup ”. Based on the 2014- 2015 Emergency Response Action, which is a component of the soil cleanup as well as the assessment of increased groundwater recharge and subsequent increase in groundwater contaminant concentration, it would be appropriate to continue MNA groundwater monitoring for the three years as called for in the ROD and to start the three-year monitoring MNA schedule from the completion of the 2015 Emergency Reponses Action. Site Inspection The inspection of the Site was conducted on February 02, 2017. In attendance were Jon Bornholm (EPA), and Beth Hartzell (NC DEQ). The purpose of the inspection was to assess the protectiveness of the remedy. 17 Second Five- Year Review Blue Ridge Plating Site Arden. Buncombe County, NC As stated within the 2016 Data Evaluation Report, 25 wells had enough data sets that qualified for statistical calculations. From these 25 wells, 100 data sets were analyzed to determine trends in concentrations of contaminants of concern over time. The data sets analyzed primarily were limited to those containing constituents exceeding the ROD cleanup levels. The Maim-Kendall statistical test was used to identify statistically significant trends in the groundwater contaminant concentrations generated from the sampling events that have occurred from September 2007 through June 2016. The Mann- Kendall test is a nonparametric test that can help identify changes in contaminant concentrations over time, for a minimum of four samples. This test cannot verify the rate at which concentrations are changing. Results of the trend evaluation are summarized in Table 8. In the Conclusions and Recommendations for the 2016 Data Evaluation Report, it was noted that, “Based on analysis of groundwater concentration trends at the Site using the Mann-Kendall statistical test, chlorinated VOC concentrations generally appear to be exhibiting a decreasing trend in most shallow wells but either an increasing trend, stable trend, or no trend in most deep wells. For metals, the Mann-Kendall test indicated that most wells display decreasing trend, stable trend, or no trend. The only metals data set with an increasing trend was iron in MW04S. Based on groundwater monitoring data collected from 2007 through 2016, Versar recommends continuing annual groundwater monitoring in accordance with the recommendations of the First Five Year Review. ” Table 8: Trend Evaluation of the Groundwater Data from 2007 to 2(116 Contaminants Wells with Decreasing or Probably Decreasing Trend 1 Wells with Increasing or Probably Increasing Trend Wells with No Trend or Stable Trend 1 VOCs 1,1,1 -Trichloroethane MW06S,MW10S,MW11S None None 1,1 -Dichloroethane MW06S, MW08S, MWlOS, MW18D MW12D,MW13D MWOID, MW06D, MWl IS, MW12D, MW16D, MW17S, MW20D 1,1-Dichloroethene MW06S, MW08S, MWlOS, MW18D MWOID, MW06D, MWl IS, MW16D, MW17S, MW20D Chloroform MWOlS, MW05S, MW06S, MW08S,MW12D MWllS MWOID, MW12S, MW13D, MW15D,MW16D T etrachloroethene MW08S, MWlOS MW12D, MW13D,MW15D MWOlD, MW06D, MW06S, MW09S, MWl IS, MW13S, MW14D, MW15S, MW16D, MW17S, MW17D, MW20D Trichloroethene MW08S, MWlOS MW13D MW06S, MWl IS, MW12S, MW12D, MW13S, MW15S, MW16D, MW17S, MW20D Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC Analytical Data Summary from September 2007 through June 2016. Table 7 lists the COCs detected above remedial levels and/or NC 2Ls between the following years: 2013-2016. Table 7: COCs Detected Above Bremedial 1.evels and/or NC 2Ls (2013-2016) COC ROD Remedial Level (pg/L) 2013 NC 2L (pg/L) Maximum Detected Concentration (pg/L) 2013 2014 2015 2016 Trichloroethene Cadmium 2,400 2,700Manganese 1,1-Dioxane Inorganics VOCs Contaminants not Specified in the ROD Cyanide 18,000 Chloroform T etrachloroethene 1,1-Dichloroethene Vanadium_________ NE 0.3 _____17_____| 16 | 12 r~~] Analytical results exceeding the ROD Cleanup Levels are shaded Bold Print - Analytical results exceeding the NC 2L Groundwater Standard are Bold Print pg/L - micrograms per Liter_________________________________________________ Vinyl Chloride Carbazole Barium Chromium Cobalt 1,1,2-Trichloroethane 1,2-Dichloroethane 0.68J 0.25J 0.57J Three nested wells located northwest of the BRP Site near the southern end of Lake Julian (AMW-3A, AMW-3B, and MW-10) are owned and maintained by Duke Energy. These wells have been sampled annually with the permission of Duke Energy since November 2014 to support monitoring of the Site. MW-10 is completed across the water table in the upper part of the saprolite aquifer, AMW-3A is completed to the top of bedrock at the base of the saprolite aquifer, and AMW-3B is completed in the bedrock aquifer. The only exceedances of ROD cleanup levels in these wells in June 2016 were the chloroform concentrations in AMW-3A (estimated 0.44 pg/L) and AMW-3B (estimated 0.32 pg/L). Additionally, chromium (59 pg/L) and vanadium (6.2 pg/L) exceeded NC 2L in AMW-3A, and manganese (190 pg/L) exceeded the standard in MW-10. Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County. NC In addition to the compounds with amended NC 2Ls, there are nine compounds, which were not specified in the ROD as COCs, which do not have cleanup levels. These nine compounds (1,4-dioxane, 1,1,2-trichloroethane, 1,2-dichloroethane, vinyl chloride, carbazole, barium, chromium, cobalt, and vanadium) have been detected above either the NC 2L or federal MCLs in one or more wells. Table 10 lists these nine contaminants along with their current MCL and/or NC 2L groundwater standard. Table 9: ARAR Comparison of Remed iation Levels and Current Standards Contaminant Cleanup Level (Pg/L) Current NC 2L (As of June 1,2013) (Jig/L) Current Federal MCL (Pg/L) Change in ARAR? Yes/No \OC Chloroform 0.19 70 -Yes 1,1 -Dichloroethane 700 6 -Yes 1,1 -Dichloroethene 7 350'7 Yes T etrachloroethene 0.7 0.7 5 No 1,1,1 -Trichloroethane 200 200 200 No Trichloroethene 2.8 3 5 Yes SVOC 2-Methylnaphthalene 14 30 -Yes Naphthalene 21 6 -Yes Pentachlorophenol 0.3 0.3 1 No Metals Arsenic 10 10 10 No Cadmium 5 2 5 Yes Cyanide 154 70 200 Yes Iron 3,800 300 300^Yes Manganese 300 50 50^Yes Nickel Too 100 -No ' This is the federal MCL. Where private drinking water well or public water supply system is impacted, the applicable standard is 7, 15ANCAC 02L .0202 - Secondary Drinking Water Regulation BOLD indicated the new standard is more stringent than the ROD Cleanup Goal (ug/L)- micrograms per Liter __________________________________________________ The EPA emergency response action left the BRP property as a vacant parcel. In March 2017, the BRP property was sold. Currently, there have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. The exposure assumptions, toxicity data, RAOs used at the time of the remedy are still protective of human health and the environment and land use restrictions have been implemented on the property. Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County. NC Question C: Has any other informa tion come to light tha t could call into QUESTION THE PROTECTIVENESS OF THE REMEDY? No additional information has come to light that could call into question the protectiveness of the remedy. Table 10: Groundwater Standards for Compounds Not-Specified in the ROD and Currently Detected in Groundwater Contaminant Current NC 2L (As of June 1,2013) (micrograms per Liter) Current Federal MCL (micrograms per Liter) VOC 1,2-Dichloroethane 0.4 5 1,4-Dioxane 3 - 1,1,2-Trichloroethane -5 Vinyl Chloride 0.03 2 svoc Carbazole -- Metals Barium 700 2,000 Chromium 10 100 Cobalt -- Vanadium -- VI. ISSUES Two issues have been identified during this review. These two issues are summarized below and are included in Table 11 which captures the issues and recommendations specified in this FYR. • The NC 2L groundwater standards, on which several of the cleanup levels are based, were amended on June 1, 2013. Several ROD designated COCs currently have standards more stringent than the ROD cleanup levels. In addition, nine compounds, which were not specified in the ROD as COCs, do not have cleanup levels. An ESD is needed to amend the cleanup levels for the Site. • Groundwater contamination has migrated off of the Site at concentrations that exceed either MCLs and/or NC 2Ls standards. It is recommended to identify and evaluate potential ICs on properties within the vicinity of the Site. Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC Table 11: 2017 Issues and Recommendations Issues and Recommendations Identified in the Five-Year Review: OU(s): Sitewide Groundwater Issue Category: Monitoring Issue: NC 2L Groundwater Standards were amended in 2013 and some of these new standards are more stringent than the cleanup levels specified in the 2005 ROD, as modified. As well, nine additional COCs have been detected in groundwater and cleanup standards for these COCs need to be specified. Recommendation: A decision document is needed to amend the cleanup levels for the Site. Affect Current Protectiveness Affect Future Protectiveness Implementing Party Oversight Party Milestone Date No Yes EP A/State EP A/State 09/26/2018 OU(s): Sitewide Groundwater Issue Category: Institutional Controls Issue: Groundwater contamination has migrated off of the Site at concentrations that exceed either MCLs and/or NC 2Ls standards. Recommendation: Identify and evaluate potential ICs on properties within the vicinity of the site. Affect Current Protectiveness Affect Future Protectiveness Implementing Party Oversight Party Milestone Date No Yes EP A/State EP A/State 09/26/2019 Other Findings An additional recommendation was identified during the FYR. This recommendation does not affect current and/or future protectiveness. • Determine if a Groundwater Remedy Completion Strategy evaluation is warranted. This evaluation will help ensure a good strategy is in place to address potential, future groundwater issues (i.e., if MNA is a viable alternative for groundwater at the site (refer to the following website for guidance: https://www.epa.gov/superfund/superfund-groundwater-groundwater- response-completion). Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC VII. PROTECTIVENESS STATEMENT Sitewide Proteetiveness Statement Protectiveness Determination: Short-Term Protective Addendum Due: NA Protectiveness Statement: The EPA and the State of North Carolina have determined that all of the remedial action construction activities were performed in accordance to specifications. The remedy at the Site currently protects human health and the environment in the short term as there are no human exposure pathways to contaminated soil or groundwater. ICs in the form of Land Use Restrictions have been implemented on the BRP property and the groundwater is being monitored on a regular basis. However, in order for the remedy to be protective in the long term, the following actions need to be taken; identify the appropriate ICs to be implemented for the properties within the vicinity of the Site where groundwater contamination has migrated to and modify the groundwater cleanup levels to reflect the revised NC 2L standards and the additional contaminants being detected in the groundwater. VIII. NEXT REVIEW The next FYR for the Blue Ridge Plating Site is required five years from completion date of this review. Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX A Reference List Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX A Reference List U.S. Environmental Protection Agency, Region IV. August 2004. Feasibility Study, Blue Ridge Plating Site, Arden, North Carolina. U.S. Environmental Protection Agency, Region IV. August 2004. Remedial Investigation Report, Blue Ridge Plating Site, Arden, North CaroUna. U.S. Environmental Protection Agency, Region IV. September 29, 2004. Record of Decision, Blue Ridge Plating Site, Arden, North Carolina. U.S. Environmental Protection Agency, Region IV. September 26, 2012. First Five-Year Review Report, Blue Ridge Plating Site, Arden, North Carolina. NC DEQ, April 1, 2013, NCAC Title 15A, Subchapter 2L section. Classifications and Water Quality Standards Applicable to the Groundwaters of North Carolina. JM Waller Associates, February 2014. Draft 2013 Data Evaluation Report. Blue Ridge Plating Site, Arden, North Carolina. U.S. Environmental Protection Agency, Region fV. November 18, 2014. Action Memorandum, Request for a Time-Critical Removal Action. Blue Ridge Plating Site, Arden, North Carolina. Crossroads Environmental, January 2, 2015. Comprehensive Asbestos Inspection Report. Blue Ridge Plating Site, Arden, North Carolina. JM Waller Associates, December 2015. Draft 2014 Data Evaluation Report. Blue Ridge Plating Site, Arden, North Carolina. Versar, July 2016. Draft 2015 Data Evaluation Report. Blue Ridge Plating Site, Arden, North Carolina. Versar, December 2016. Draft 2016 Data Evaluation Report. Blue Ridge Plating Site, Arden, North Carolina. U.S. Environmental Protection Agency, Region IV. June 19, 2017. Memorandum Hydrogeology Review, Blue Ridge Plating Site, Arden, North Carolina. A-1 Arden, Buncombe County, ^PENDIX B Site Chronology APPENDIX B Second Five-Year Rex’iew Blue Ridge Plating Site Arden, Buncombe County, NC Event Date Initial Site discovery December 17, 1998 Preliminary Assessment and Site Inspection completed January 25, 2000 Expanded Site Inspection completed March 15,2001 Approval of Remedial Investigation (RI)/Feasibility Study (FS) Work Plan (Final Sampling and Analysis Plan)April 2003 RI Report August 2004 RI and FS completed September 29, 2004 ROD signed September 29, 2004 Proposal to the National Priories List (NPL)April 27, 2005 Final Listing on NPL completed September 14, 2005 Remedial Design completed March 14, 2006 Remedial Action initiated November 2006 First Groundwater sampling event for MNA September 2007 PCOR signed September 27, 2007 Second Groundwater sampling event January 2008 Remedial Action Report completed March 31, 2008 Third Groundwater sampling event June 2008 ESD signed June 27, 2008 Fourth Groundwater sampling event January 2009 Annual Groundwater sampling event January 2010 Annual Groundwater sampling event January 2011 Annual Grormdwater sampling event January 2012 Annual Groundwater sampling event March 2013 City of Asheville determined the BRP building was unsafe and advised no entry into the building.December 2013 Annual Groimdwater sampling event August 2014 EPA Action Memorandum dated 11/8/2014 to document disrepair and evidence of improper storage.November 18, 2004 Response Action for pre-asbestos inspection, demolition, removal of concrete floor, removal of 3,950 tons of contaminated soil, abandonment of old supply well. December 2014- May 2015 Annual Groundwater sampling event July 2015 Aimual Groundwater sampling event June 2016 B-1 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX C Site Inspection Checklist C-1 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC SITE INSPECTION CHECKLIST FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST I. SITE INFORMATION Site Name: Blue Ridge Platying Site Location and Region: Concord NC, US EPA Region 4 Agency, Office or Company Leading the Five-Year Review: NC DEO Date of Inspection: February 09, 2017 EPA ID: NCD044447589 Weather/Temperature: Not recorded Remedy Includes: (Check all that apply) □ Landfill cover/containment □ Access controls ^ Institutional controls □ Ground water pump and treatment Q Surface water collection and treatment □ Other: ^ Monitored natural attenuation HU Ground water containment □ Vertical barrier walls Attachments: ^ Inspection team roster attached r~l Site map attached II. INTERVIEWS (check all that apply) 1. O&M Site Manager Name Title Interviewed Q at site □ at office □ by phone : ____ Problems, suggestions O Report attached: Date 2. O&M Staff Name Interviewed □ at site □ at office □ by phone Problems/suggestions □ Report attached: Title Date 4. Other Interviews (optional) [H Report attached:, III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply) 1.O&M Documents ^ O&M manual ^ Readily available ^ Up to date □ n/a □ As-built drawings □ Readily available Q Up to date ^N/A □ Maintenance logs □ Readily available □ Up to date Sn/a Remarks: In office/off-site C-2 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC 2.Site-Specific Health and Safety Plan □ Contingency plan/emergency response plan Remarks: In office/off-site Q Readily available □ Readily available □ Up to date □ Up to date E1n/a 3n/a 3.O&M and OSHA Training Records [3 Readily available □ Up to date.□ n/a Remarks; In office/off-site 4.Permits and Service Agreements Q Air discharge permit □ Readily available □ Up to date 3n/a □ Effluent discharge □ Readily available □ Up to date KIn/a □ Waste disposal, POTW □ Readily available □ Up to date 3 N/A n Other oermits:□ Readily available □ Up to date 3 n/a Remarks: 5.Gas Generation Records □ Readily available □ Up to date 3n/a Remarks: 6.Settlement Monument Records □ Readily available □ Up to date 3n/a Remarks: 7.Ground Water Monitoring Records 13 Readily available 3 Up to date □ n/a Remarks: In office/off-site 8.Leachate Extraction Records □ Readily available □ Up to date 3 n/a Remarks; 9.Discharge Compliance Records Q Air □ Readily available □ Up to date 3n/a □ Water (effluent) □ Readily available □ Up to date 3In/a Remarks: 10.Daily Access/Security Logs □ Readily available n Up to date □ n/a Remarks: C-3 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC TV. O&M COSTS 1. O&M Organization □ State in-house O PRP in-house l~l Federal facility in-house □ __ n Contractor for state □ Contractor for PRP 13 Contractor for Federal facility 2.O&M Cost Records 3 Readily available 3 Up to date r~| Funding mechanism/agreement in place [H Unavailable Original O&M cost estimate: O Breakdown attached Total annual cost by year for review period if available From: 2012 To:$88,147 nH Breakdown attached Date Date Total cost From: 2013 To:$52,357 CH Breakdown attached Date Date Total cost From: 2014 To:$63,409 O Breakdown attached Date Date Total cost From: 2015 To:$49,172 nH Breakdown attached Date Date Total cost From: 2016 To:$34,348 □ Breakdown attached Date Date Total cost 3.Unanticipated or Unusually High O&M Costs during Review Period Describe costs and reasons: NA V. ACCESS AND INSTITUTIONAL CONTROLS 3 Applicable □ n/a A. Fencing 1.Fencing Damaged □ Location shown on site map □ Gates secured Remarks: 13 N/A B. Other Access Restrictions 1.Signs and Other Security Measures □ Location shown on site map ^ N/A Remarks: Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC C. Institutional Controls (ICs) 1.Implementation and Enforcement* Site conditions imply ICs not properly implemented Site conditions imply ICs not being flilly enforced Type of monitoring (e.g., self-reporting, drive by: annual certification Frequency: Annual Responsible party/agency: Havwood Vocational opportunities Contact George Marchall □ Yes Kl No □ N/A □ Yes ^ No □ N/A Name Title Date Phone no. Reporting is up to date Kl Yes □ No □n/a Reports are verified by the lead agency Kl Yes □ No □ n/a Specific requirements in deed or decision documents have been met lEl Yes □ No □ n/a Violations have been reported □ Yes □ No □ n/a Other problems or suggestions: □ Report attached 2.Adequacy □ ICs are adequate □ ICs are inadequate Remarks: Institutional controls signed and recorded Marchl3, 2017 □ n/a D. General 1.V andalism/T respassing □ Location shown on site map □ No vandalism evident Remarks: 2.Land Use Changes On Site □ N/A Remarks: None 3.Land Use Changes Off Site □ N/A Remarks: None VI. GENERAL SITE CONDITIONS A. Roads □ Applicable □ N/A 1.Roads Damaged □ Location shown on site map □ Roads adequate □ n/a Remarks: B. Other Site Conditions Remarks: NA C-5 Second Five-Year Re\>iew Blue Ridge Plating Site Arden, Buncombe County, NC VII. LANDFILL COVERS □ Applicable ^ N/A A. LandflU Surface 1.Settlement (low spots) Arial extent: Remarks: P Location shown on site map P Settlement not evident Deoth: 2.Cracks Lengths: Remarks: P Location shown on site map Widths: P Cracking not evident Depths: 3.Erosion Arial extent: Remarks: P Location shown on site map P Erosion not evident Depth: 4.Holes Arial extent: Remarks: P Location shown on site map P Holes not evident Deoth: 5.Vegetative Cover P No signs of stress Remarks: P Grass P Cover properly established P Trees/shrubs (indicate size and locations on a diagram) 6.Alternative Cover (e.g., armored rock, concrete) Remarks: Pn/a 7.Bulges Arial extent: Remarks: P Location shown on site map P Bulges not evident Height: Wet AreasAVater Damage □ Wet areas/water damage not evident Q Wet areas P Ponding P Seeps P Soft subgrade Remarks: P Location shown on site map Arial extent:. P Location shown on site map Arial extent:. P Location shown on site map Arial extent:. P Location shown on site map Arial extent:. Slope Instability P Slides P No evidence of slope instability P Location shown on site map C-6 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC Anal extent:. Remarks; B. Benches □ Applicable □ N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.) 1.Flows Bypass Bench Q Location shown on site map n N/A or okay Remarks; 2.Bench Breached O Location shown on site map □ N/A or okay Remarks: 3.Bench Overtopped Q Location shown on site map O N/A or okay Remarks: C. Letdown Channels □ Applicable ^ N/A (Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.) 1.Settlement (Low spots)□ Location shown on site map □ No evidence of settlement Arial extent:Denth; Remarks; 2.Material Degradation □ Location shown on site map □ No evidence of degradation Material tvne:Arial extent; Remarks: 3.Erosion □ Location shown on site map Q No evidence of erosion Arial extent:Denth: Remarks; 4.Undercutting □ Location shown on site map □ No evidence of undercutting Arial extent:Denth; Remarks: 5.Obstructions Type:□ No obstructions □ Location shown on site map Arial extent: Size: Remarks: Excessive Vegetative Growth Type:. C-7 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC □ No evidence of excessive growth □ Vegetation in channels does not obstruct flow |~) I,ocation shown on site map Arial extent; Remarks: D.Cover Penetrations □ Applicable ^ N/A 1.Gas Vents □ Active im Passive l~l Properly secured/locked O Functioning n Routinely sampled n Good condition r~l Evidence of leakage at penetration D Needs maintenance □ n/a Remarks: 2.Gas Monitoring Probes n Properly secured/locked Q Functioning n Routinely sampled n Good condition n Evidence of leakage at penetration n Needs maintenance □ n/a Remarks: 3.Monitoring Wells (within surface area of landfill) □ Properly secured/locked Q Functioning n Routinely sampled □ Good condition O Evidence of leakage at penetration n Needs maintenance □ n/a Remarks: 4.Extraction Wells Leachate n Properly secured/locked Q Functioning n Routinely sampled □ Good condition n Evidence of leakage at penetration □ Needs maintenance □ n/a Remarks: 5.Settlement Monuments O Located l~l Routinely surveyed □ n/a Remarks: E.Gas Collection and Treatment □ Applicable lElN/A 1.Gas Treatment Facilities □ Flaring □ Thermal destruction □ Collection for reuse n Good condition Q Needs maintenance Remarks: 2.Gas Collection Wells, Manifolds and Piping O Good condition O Needs maintenance Remarks: C-8 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) n Good condition CH Needs maintenance Q N/A Remarks; F. Cover Drainage Layer □ Applicable □ N/A 1. Outlet Pipes Inspected O Functioning d N/A Remarks; 2. Outlet Rock Inspected Q Functioning Q N/A Remarks; G. Detention/Sedimentation Ponds □ Applicable d N/A 1. Siltadon Area extent; Depth; FI N/A D Siltation not evident Remarks; 2. Erosion Area extent; Depth; □ Erosion not evident Remarks; 3. Outlet Works O Functioning □ N/A Remarks; 4. Dam d Functioning d N/A Remarks; H. Retaining Walls d Applicable ^ N/A 1. Deformations d Location shown on site map d Deformation not evident Horizontal displacement; Vertical displacement; Rotational disolacement; Remarks; 2. Degradation d Location shown on site map d Degradation not evident Remarks; I. Perimeter Ditches/Off-Site Discharge d Applicable d N/A 1. Siltation d Location shown on site map d Siltation not evident Area extent; Depth; Remarks; C-9 Second Five-Year Review Blue Ridge Plating Site Arden. Buncombe County, NC 3.Erosion Area extent: Remarks: n Location shown on site map □ Erosion not evident Depth: 4.Discharge Structure Remarks: |~| Functioning □ n/a VIII. VERTICAL BARRIER WALLS □ Applicable ^N/A 1.Settlement Area extent: Remarks: [I Location shown on site map Q Settlement not evident Depth: 2.Performance Monitoring Type of monitoring: 2. Vegetative Growth H] Location shown on site map C] N/A □ Vegetation does not impede flow Area extent:____ Type: Remarks: n Performance not monitored Frequency: Head differential: Remarks: □ Evidence of breaching IX. GROUND WATER/SURFACE WATER REMEDIES □ Applicable ^ N/A A. Ground Water Extraction Wells, Pumps and Pipelines □ Applicable ^ N/A 1. Pumps, Wellhead Plumbing and Electrical □ Good condition □ All required wells properly operating [II Needs maintenance □ N/A Remarks: 2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances □ Good condition D Needs maintenance Remarks: 3. Spare Parts and Eqiupment n Readily available [I Good condition Remarks: r~l Requires upgrade [I Needs to be provided B. Surface Water Collection Structures, Pumps and Pipelines □ Applicable ^ N/A C-10 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC 1. Collection Structures, Pumps and Electrical □ Good condition CH Needs maintenance Remarks: 2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances n Good condition O Needs maintenance Remarks: 3. Spare Parts and Equipment O Readily available □ Good condition Remarks: |~| Requires upgrade Q Needs to be provided C. Treatment System □ Applicable N/A 1. Treatment Train (check components that apply) n Metals removal O Oil/water separation r~| Air stripping CH Carbon adsorbers □ Filters: l~l Additive (e.g., chelation agent, flocculent): □ Others: l~l Good condition CH Needs maintenance l~| Sampling ports properly marked and functional n Sampling/maintenance log displayed and up to date □ Equipment properly identified □ Quantity of ground water treated annually: n Quantity of surface water treated annually: Remarks: r~l Bioremediation* I~1 In-situ chemical oxidation* |~l Monitored natural attenuation* 2. Electrical Enclosures and Panels (properly rated and functional) n N/A Q Good condition Q Needs maintenance Remarks: 3. Tanks, Vaults, Storage Vessels l~l N/A n Good condition O Proper secondary containment Remarks: l~] Needs maintenance 4. Discharge Structure and Appurtenances □ N/A Q Good condition Q Needs maintenance C-11 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC Remarks: 5. Treatment Building(s) □ N/A □ Good condition (esp. roof and doorways) CH Needs repair l~l Chemicals and equipment properly stored Remarks: 6. Monitoring Wells (pump and treatment remedy) Q Properly secured/locked □ Functioning □ Routinely sampled □ Good condition r~l All required wells located O Needs maintenance [U N/A Remarks: D. Monitoring Data 1. Monitoring Data K Is routinely submitted on time ^ Is of acceptable quality 2. Monitoring Data Suggests: l~l Ground water plume is effectively contained ^ Contaminant concentrations are declining E. Monitored Natural Attenuation* 1. Monitoring Wells (natural attenuation remedy) (~~| Properly secured/locked ^ Functioning ^ Routinely sampled ^ Good condition □ All required wells located □ Needs maintenance □ N/A Remarks: MW-7S. MW-14S. and MW-14D need new locks-thev were not locked durine the Site Insoection. EPA has said thev will orovide new locks. X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. XL OVERALL OBSERVATIONS A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. O&M orocedures are adeauate for current and lone-term nrotectiveness of the remedv. C-12 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. Site Inspection Participants Jon Bornholm, US EPA Remedial Project Manager Nile Testerman, NC DEQ Superfund Section Environmental Engineer (Retired 2/28/2017) Beth Hartzell, NC DEQ Superfund Section Environmental Engineer C-13 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX D Figures .......................................... . , .»^i,4^.-....k-.,^^v.., ■ ;4:. :■>:.. ..' - 4;* ..............-1,^ ^ i, - *.«s • v, '■ = ■ ■■•^4 ' ' .a- -a- ' • -■ :. ' ‘■' 4. ''i;'?'a^aaF a-a'-4"''a t «.', .: :;a a..- . - ^ ‘m -a; ■ r- i Featuring MspFttint'’ ITecSnolcigy a. a;;; S' . **■ ¥■ ■,4';:-’ a ■ -''Slf a,. .' 5Ss;;¥% ■> %■ r '¥r ■ :-H' tfeywood 11 ■^7;Ro)w^Pine*^-, ___ '' ^ II I "a '^162.'7 rC315^ ' ■ ' a? a . a.s 3524; 4- -■ 7 aa' a •i .'.;h Blue Ridge Plating Company Site i;J621 ,.-¥ ■t m , V'3553':' \ 171 Glenn Bricicje Rtl, Arden, NC, 28704 iS) ' »r ^(r y/' Arderts^ / j/'-----Vt)ls <3:Ji:‘: "%. '3541) H;U!_ -S-S/a)) ,-:“^t(Ka .. at \' h. ' ' - ““1:=^7;^ pS 7% ^^!!»■ '• .r 3^- • -,>■ Q2002 Mcrcsoft Coip ©^909 MauTech. GOT. Inc. and/or Compusearch Blue Ridge Plating Company Atlen, Buncombe County, NC SaeeningLevel Ecological Risk Assessment Figure 1 Site Looatioit D-1 ;-: :',^.4a,-.:- i^-' r. '.V‘..' - • K WiiOM ' •¥;^ ■ 4-‘. h-v\ X •’■- 5?, .■ my'1 - ^ •W»i; ^ ^ % : JII?[Blu?Rid^Rlatingi IV' -s. iii? tf' % ■J/'t'.; .1f ir-sy«“' S» &i|5 w ^ s/^ m mmm VEUimron 0^ 1=13 Legend ' Property Line Streams Former Building (Demolished) Lake/Pond Feet 0 62.5 125 250 NAD83 US State Plane North Carolina, Feet OH WV MD Yadkin County North Carolina Blue Ridge Plating USEPA ID#: NCD044447589 Arden, Buncombe County North Carolina Figure 2 Site Location Map VE RS AR r \ ’ >:•" r' ■ • ".' V' .:•- ,V«'.'" xf|l ■■'#:: •UNMMBe OCXJKTt. MOtr>» CiWOUMA aurae kak fiONTOtmiHnRMli; 4* lom Ai«e naxnvK 10 MMi wkiMu fr-iQot=J»f-----1- f-^M; Jj'Jl,;/';-''; ■-•i' ■ V*' sfer' V > • V- V'Ir.-4* y'. C=3' „r_-' ^ ^ %; * Jf **■ >1 *JV> V ' S - k' ^1 ! 5 -- -'/y a*;,;'^''.. ,,;'■ y.v'. ,:' 'rv;^'-■ ^ "'^4' .■:: r-'= -. .. «- V;1 ‘ . -V- ■y-y " ...-y s- -■■«■ ; il g:>- 4 ;t:'. ';., .’A -Ayr. V ■ . ¥i*t|;Cii' V -1 ;■ y*- .y-' p-‘ fr|^:i i. "msiAm EPG-l i: .^'4 " J'-: '"I . K .*»4;V ,V"- . 'f P r3* ■;;v ■ /' , ' .......'M4' -'Ar:1' 'r.»^i;J"''Va.;n^‘,' "'jy.'. , V , ---------------- .JJORNERNOTSei . SMH' . KWER MANHOUE MW WONnORINGWEU. ■ ' ;'K AS&e,... Figure 3 Aerial Extent of Soil Excavation D-3 '-0 rF X-s :' ■■■■■ '-'P. -^'■, -y«r''"!V--'*' 3.:-^ %■'. '«r:':yy. :Sy, W-." " '"' ^ rp ■/yy ,, .':';^'T.i/--: *■ ^ N ^,: \ ^-»*>. .1 i^: i . 7^ Legend ■«► Deep Shallow Nested Well Bedrock «r ♦ Former Building (Demolished) Lake/Pond Property Line Streams Nested WeH includes deep and shallow wells in the same casing. Feet 0 SO 100 200 NA083 US State Plane North CaroBna, Feet Yadkin County North Carolina Blue Ridge Plating USEPAID#: NCD044447589 Arden, Buncombe County North Carolina Figure 4 Monitoring Well Locations ^ VERSAR i\- '■ r-^WK v-;’E»|SK,^' ^sT^JfeP^;^ Im LEGEND ffec 0tlM mmvV\«# Sis* «e:™MMV » 4- SHALLOW MONITORING WELL DEEP MONDORING WELL NESTED MONITORING WELL Boundary o Blue Ridge Property Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informotionol purposes only regarding the EPA’s response octions at the Site end is not intended for any other purpose. GRAPHIC SCALE !00‘ 200' r = 200' r>. tn 0 ui 2 § £ 0 LO &s a z g g 0 5 cs 0 s ili33 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX E ARAR List Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX E ARAR Review Section 121 (d)(2)(A) of CERCLA specifies that Superfund remedial actions must meet any federal standards, requirements, criteria, or limitations that are determined to be legally ARARs. Applicable or Relevant and Appropriate Requirements are those standards, criteria, or limitations promulgated under federal or state law that specifically address a hazardous substance, pollutant, contaminant, action, location, or other circumstance at a CERCLA site. To-Be-Considered criteria (TBCs) are non- promulgated advisories and guidance that are not legally binding, but should be considered in determining the necessary level of cleanup for protection of human health or the environment. While TBCs do not have the status of ARARs, EPA's approach to determining if a remedial action is protective of human health and the environment involves consideration of TBCs along with ARARs. Chemical- specific ARARs are specific numerical quantity restrictions on individually listed contaminants in specific media. Examples of chemical-specific ARARs include the MCLs specified under the Safe Drinking Water Act (SDWA) as well as the ambient water quality criteria that are enumerated under the Clean Water Act. Because there are usually numerous contaminants of potential concern for any site, various numerical quantity requirements can be ARARs. In performing the FYR for compliance with ARARs, only those ARARs that address the protectiveness of the remedy are reviewed. Because the remedy at the Site currently addresses only groimdwater contamination, this FYR will discuss compliance with chemical-specific groundwater ARARs only. The 2004 ROD identified the following Federal and State chemical-specific ARARs: Federal ARARs • 40 CFR Parts 262 promulgated under the authority of RCRA, Standards Applicable to Generators and Transporters of Hazardous Waste • Hazardous Materials Transportation Regulations (49 CFR USC Sect 1801 -1813; 49 CFR 107, 171-177) • Clean Air Act (42 USC Section 7401 -7642) • National Ambient Air Quality Standards (40 CFR Part 50; 40 CFR Part 53; 40 CFR Part 61) • Endangered Species Act (16 USC 1531; 50 CFR 200 and 402) • Fish and Wildlife Coordination Act (16 USC 2901 et seq) • Noise Control Act of 1972 (42 USC Sect. 4901 et seq) • National Historic Preservation Act (16 USC 470; 40 CFR 6.301(b); 36 CFR 800) • Archeological and Historic Preservation (16 USC 469; 40 CFR 6 301(c)) • Migratory Bird Treaty Act (16 USC 703) • Executive Order No. 11,990 40 CFR 6.302(a) and Appendix A • Clean Water Act (Part 301 (b)) • National Primary Drinking Water Standards (40 CFR Part 141) • National Pollutant Discharge Elimination System Requirements (CWA Part 402, 40 CFR Part 122) E-1 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC State ARARs • Regulations for the Management of Hazardous Waste promulgated imder the authority of the NC Waste Management Act (North Carolina Administrative Code (NCAC) Title 15 A, Chapter 13 A) • NC Drinking Water and Groundwater Standards; Groundwater Classifications and Standards (NCAC Title 15 Chapter 2L) • NC Surface Water Quality Standards Classification and Water Quality Standards (NCAC Title 15A Chapter 2B) • Well Construction Standards (NCAC Title 15A Subchapter 2C 0100) • NC Air Pollution Control Regulations (NCAC Title 15A Chapter 2D, 2H, and 2Q) • Inactive Hazardous Program Guidelines for Assessment and Cleanup, NC, Superfund Section, Jan 2003 • NC Solid Waste Management Regulations (15A NCAC 4B) • NC Erosion and Sedimentation Control Rules (NCAC Title 15A Subchapter 4B) It is the EPA's policy that ARARs are generally "frozen" at the time of the ROD signature unless a "new or modified requirement calls into question the protectiveness of the selected remedy", 55 Fed. Reg. 8757 (March 8, 1990). The NC Classifications and Water Quality Standards Applicable to the Groundwater of North Carolina, NCAC Title 15A Subchapter 2L, (NC 2L) on which several of the remedial levels are based were last amended on June 2013. coc ROD Remedial Goal 2013 NC 2L Maximum Detectet (pg/1 d Concentration L) 2013 2014 2015 2016 VOCs 1,1 -Dichloroethene 7 7 160 120 190J 120 Chloroform 0.19 70 1.8 1.9 1.8 1.7 T etrachloroethene 0.7 0.7 100 130 140J 150 Trichloroethene 2.8 3 35 38 33 26 Metals Cadmium 5 2 37 14 12 19 Cyanide 154 70 110 no 36 41 Iron 3,800 300 6,200 18,000 10,000 10,000 Manganese 300 50 2,400 2 700 2,400 2.900 Contaminants not Specified in the ROD 1,1-Dioxane NE 3 -iO 26 42 1,1,2-T richloroethane NE 0.6 2.3 0.94 6.7 2.7 1,2-Dichloroethane NE 0.4 0.68J 0.54 2.3 0.57J Vinyl Chloride NE 0.03 0.5 0.25J --Carbazole NE 2 -11 6.9 3.5 Barium NE 700 860 940 690 560 E-2 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC coc ROD Remedial Goal 2013 NC 2L Maximum Detected Concentration (4g/L) 2013 2014 2015 2016 Chromium NE 230 Cobalt NE 1 Vanadium NE IBT I Analytical results exceeding the ROD Cleanup Goals are shaded Red Analytical results exceeding the NCAC Groundwater Standard are red As stated previously the performance standards for the soil remediation has been completed based upon the cleanup levels established within the ROD. The 2004 ROD stated, "CERCLA, as amended by Section 121(b) of SARA, requires the selection of remedial actions that attain a degree of cleanup which ensures protection of human health and the environment, are cost effective, and use permanent solutions and alternative treatment technologies or resource technologies to the maximum extent practicable. To satisfy CERCLA requirements, RAOs were developed for the Blue Ridge Plating site. RAOs will be used to develop general response actions for the Site that are protective of current and future construction worker, future Site residents, and the environment. The key contaminants of concern (COCs) are metals along with a number of volatile organic compounds (VOCs) and semi- volatile organic compounds (SVOCs). The soil/sediment cleanup goals were derived from predominantly leachate models for the metals in order to be protective of the underlying groundwater along a health based risk level for chromium. The groundwater cleanup goals were based on ARARs (North Carolina Groundwater Classifications and Standards (ISA NCAC 2L) (NC2L)) or background concentrations. E-3 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX F Newspaper Ad and Interviews Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX F Newspapers Ad and Interviews The U.S. Environmental Protection Agency, Region 4 Announces a Five-Year Review for the Blue Ridge Plating Site in Arden, Buncombe County, North Carolina The U.S. Environmental Protection Agency is conducting its second Five-Year Review of the remedy for the Blue Ridge Plating Site located in Arden, Buncombe County, North Carolina. The purpose of the Five-Year Review is to ensure that the selected cleanup actions effectively protect human health and the environment. The soil cleanup phase occurred between December 2006 and June 2007. Approximately 8,737 cubic yards of contaminated soil were excavated and transported to an off-site facility for disposal. Four additional groundwater monitoring wells were installed in August-September 2007. EPA issued the Preliminary Closeout Report in September 2007. Groundwater was last sampled in March 2012 and the next aimual ground water sampling event will occur in 2013. Due to Site related contaminants being detected in the furthest downgradient monitoring wells, two additional monitoring wells (one shallow and one deep) were installed in April 2011 and were initially sampled in June 2011. These wells were last sampled in July 2016. In December 2013, the City of Asheville determined that the building on the Blue Ridge property was unsafe and advised occupants to stay out which basically closed the business. Because of the presence of hazardous substances remained onsite, EPA initiated an emergency response action at the property. The response action began in December 2014 and was completed in May 2015. The response action included talking down the building, removing the concrete floor, removing 3,950 tons of contaminated soil from under the footprint of the building, and abandoning an old supply well. The National Contingency Plan (NCP) requires remedial actions that result in any hazardous substances, pollutants or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure be reviewed every five years to ensure the protection of human health and the environment. The Five-Year Reviews for the site will be completed by September 2017. A copy of the final report will be placed in the information repository located at the Skyland South Buncombe Branch Library, 260 Overlook Road in Asheville, for the public to review. For further information, please contact Jon Bornholm, EPA Remedial Project Manager via email at bornholm.ion@epa.gov or Angela Miller, EPA Community Involvement Coordinator via email miller.angela@epa.gov or directly at (678) 575-8132. F-1 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC Blue Ridge Plating Site Arden, Buncombe County, NC EPA ID; NCD044447589 Second Five-Year Review Report Interview Questionnaire Completed by Jon Bornholm, EPA RPM 1. What is your overall impression of the project? (general sentiment) The cleanup has been slow but positive progress is being made. The structure was recently removed as part of the emergency response EPA conducted at the Site in 2015. 2. What effects have site operations had on the surrounding community? To the best of my knowledge, recent Site related activities have not had any effect of the surrounding community. 3. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details. No 4. Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? No 5. Do you feel well informed about the site’s activities and progress? Yes 6. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation? No 7. What is the current status of construction (e.g., budget and schedule? All planned remedial activities have been completed at the site. The only activity occurring is the annual groundwater monitoring event. 8. Have any problems been encountered which required, or will require, changes to this remedial design or this ROD? No F-2 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC 9. Have any problems or difficulties been encountered which have impacted construction progress or implementability? No. Remedial action activities were reported in the July 2007 Remedial Action Report and the September 2007 Preliminary Close-Out Report. 10. Do you have any comments, suggestions, or recommendations regarding the project (i.e., design, construction documents, constructability, management, regulatory agencies, etc.)? No 11. Is the remedy functioning as expected? How well is the remedy performing? Yes, groundwater quality in the vicinity of where the building use to stand may be adversely impacted due to the recent soil disturbance that occurred during the 2015 Emergency response Action. 12. What does the monitoring data show? Are there any trends that show contaminant levels are decreasing? The following text comes from the July 2016 2015 Data Evaluation Report, Groundwater analytical results from July 2015 indicated that chlorinated VOCs were detected at concentrations above the ROD cleanup goals in 24 of the 30 wells sampled. The highest VOC concentrations were detected in MWl 1S. No SVOCs were detected in excess of the cleanup goals. The metals cadmium, iron, and manganese were detected above ROD cleanup goals, with exceedances of cadmium in four wells (MW03S, MW05S, MW07S, and MW12S), iron in one well (MW04S), and manganese in eight wells (MWOlS, MW03S, MW04S, MW05S, MW07S, MW12S, MW16D, and MW16S). In addition to the site contaminants with cleanup goals established by the 2004 ROD and 2008 Explanation of Significant Difference, there were several other constituents detected in site groundwater in July 2015 at concentrations exceeding current EPA MCLs or North Carolina groundwater standards. These constituents are: 1,1,2-trichloroethane, 1,2-dichloroethane, 1,4- dioxane, carbazole, chromium, cobalt, and vanadium. Based on analysis of groundwater concentration trends at the site using the Mann-Kendall statistical test, chlorinated VOC concentrations generally appear to be exhibiting a decreasing trend in most shallow wells but either an increasing trend, stable trend, or no trend in most deep wells. For metals, the Marm-Kendall test indicated that most wells display decreasing trend, stable trend, or no trend. The only metals data set with an increasing trend was iron in MW04S. The Mann-Kendall test indicated no trend for the SVOCs pentachlorophenol and naphthalene in MWOlS, although concentrations of these constituents did not exceed ROD cleanup levels in MWOlS during the July 2015 sampling event. F-3 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC 13. Is there a continuous on-site O&M presence? If so, please describe staff and activities. If there is not a continuous on-site presence, describe staff and frequency of site inspections and activities. No, groundwater samples are collected from the groundwater monitoring network on an annual basis. Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC Blue Ridge Plating Site Arden, Buncombe County, NC EPA ID; NCD 044 447 589 Second Superfund Five-Year Review Report Interview Questionnaire Completed by Nile Testerman, (Former/Retired) NC DEQ RPM 1. What is your overall impression of the project? (general sentiment) The site is in good condition. 2. What effects have site operations had on the surrounding community? No impact with the current remedy of MNA. 3. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details. None. 4. Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? No. 5. Do you feel well informed about the site’s activities and progress? Yes. 6. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation? None. 7. What is the current status of construction {e.g., budget and schedule? Construction is complete. 8. Have any problems been encountered which required, or will require, changes to this remedial design or this ROD? No. 9. Have any problems or difficulties been encountered which have impacted construction progress or implementability? No problems after building was demolished. 10. Do you have any comments, suggestions, or recommendations regarding the project (i.e., design, construction documents, constructability, management, regulatory agencies, etc.)? None. 11. Is the remedy functioning as expected? How well is the remedy performing? The gw remedy of MNA is functioning, 12. What does the monitoring data show? Are there any trends that show contaminant levels are decreasing? Most contaminant levels are decreasing or not increasing. F-5 13. Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC Is there a continuous on-site O&M presence? If so, please describe staff and activities. If there is not a continuous on-site presence, describe staff and frequency of site inspections and activities. GW is being monitored on an annual basis. F-6 Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX G 2016 Annual Data Evaluation Report G-1 DRAFT 2016 DATA EVALUATION REPORT BLUE RIDGE PLATING SITE ARDEN, BUNCOMBE COUNTY, NORTH CAROLINA NCD044447589 PREPARED FOR: U.S. ENVIRONMENTAL PROTECTION AGENCY REMEDIAL ACTION CONTRACT II LITE REGION 4 EPA CONTRACT NO. EP-S4-08-03 TASK ORDER 008 DCN 008DER122316-DRAFT PREPARED BY: VERSAR December 2016 DRAFT 2016 DATA EVALUATION REPORT BLUE RIDGE PLATING SITE ARDEN, BUNCOMBE COUNTY, NORTH CAROLINA NCD044447589 Prepared for: U.S. Environmental Protection Agency Remedial Action Contract II Lite Region 4 Contract No. EP-S4-08-03 Task Order 008 Prepared by: Versar, Inc. December 2016 \y Jane Traylor Versar Project Manager 12/23/16 Date Arnold Ostrofsky, P.E. Versar Program Manager 12/23/16 Date Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT TABLE OF CONTENTS SECTION PAGE ACRONYMS AND ABBREVIATIONS......................................................................................ii 1.0 INTRODUCTION............................................................. 1-1 1.1 Purpose and Scope..................................................................................................1-1 1.2 Site Background................. 1-1 1.3 Previous Investigations............................................................................................1-2 2.0 FIELD ACTIVITIES.....................................................................................................2-1 2.1 Water Level Measurements.....................................................................................2-1 2.2 Groundwater Sampling............................................................................................2-1 2.3 Sampling Quality Control.........................................................................................2-2 3.0 RESULTS..................................................................................................................3-1 3.1 Groundwater Elevations and Gradient.....................................................................3-1 3.2 Groundwater Analytical Results...............................................................................3-1 3.3 Statistical Analysis of Trends...................................................................................3-7 3.4 Quality Assurance Summary..................................................................................3-10 4.0 CONCLUSIONS AND RECOMMENDATIONS...........................................................4-1 5.0 REFERENCES............................................................. 5-1 TABLES Table 2-1 Table 3-1 Table 3-2 Table 3-3 Table 3-4 FIGURES Figure 1-1: Figure 2-1: Figure 3-1: Figure 3-2: Groundwater Elevation Summary: June 21, 2016 Groundwater Analytical Data Summary: September 2007 - June 2016 Field Parameters: January 2010 - June 2016 Summary of Mann-Kendall Statistical Calculations: September 2007 - June 2016 Groundwater Duplicates Relative Percent Difference (RPD): June 2016 Site Location Map Monitoring Well Locations Groundwater Elevation Contour Map - Shallow Groundwater Elevation Contour Map - Deep APPENDICES Appendix A: Mann-Kendall Statistics Appendix B: Analytical Data Reports Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT ACRONYMS AND ABBREVIATIONS AFCEC Air Force Civil Engineering Center CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System CF Confidence Factor CLP Contract Laboratory Program COV Coefficient of Variation °C Degrees Celsius DER Data Evaluation Report EPA U.S. Environmental Protection Agency ESD Expianation of Significant Difference ESI Expanded Site Investigation FBI Federal Bureau of Investigation IDW Investigation Derived Waste J. M. Waller J. M. Waller Associates, Inc. MAROS Monitoring and Remediation Optimization System MCL Maximum Contaminant Limit Mg/L Micrograms per Liter mg/L Milligrams per Liter MNA Monitored Natural Attenuation mV Millivolt n Number of Sampling Events NCDENR North Carolina Department of Environment and Natural Resources NPL National Priorities List ORP Oxidation Reduction Potential P Probability Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT ACRONYMS AND ABBREVIATIONS (continued) PARCC Precision, Accuracy, Representativeness, Comparability, and Completeness PA/SI Preliminary Assessment/Site Inspection PVC Polyvinyl Chloride QA/QC Quality Assurance/Quality Control RCRA Resource Conservation and Recovery Act RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPD Relative Percent Difference RPM Remedial Project Manager S Mann-Kendall Statistic SAP Sampling and Analysis Plan SVOCs Semivolatile Organic Compounds TAL Target Analyte List TCL Target Compound List TOC Total Organic Carbon VOCs Volatile Organic Compounds Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT 1.0 INTRODUCTION This Data Evaluation Report (DER) has been developed by Versar, Inc. (Versar) for the United States Environmental Protection Agency (EPA) under Contract Number EP-S4-08-03, Task Order 08, for sampling and analytical support at the Blue Ridge Plating Site in Arden, Buncombe County, North Carolina. The purpose of this task order is to provide support for overall planning, coordination, and the collection of groundwater samples for analysis of volatile and semivolatile organic compounds, metals, cyanide, and monitored natural attenuation (MNA) parameters. The goal is to collect groundwater data to evaluate whether MNA is a viable remedy for the groundwater at the site. 1.1 Purpose and Scope This DER presents data and information obtained during the annual sampling event conducted by Versar in June 2016 and compares it to groundwater data collected at the site since September 2007. The collected information is presented in summary form and includes the following: • Field measurements including groundwater water quality parameters and water levels; • Analytical results summary tables and full data validation laboratory reports; • Trend analysis using Mann-Kendall statistics. 1.2 Site Background The Blue Ridge Plating Site occupies 3.06 acres located at 171 Glenn Bridge Road in Arden, Buncombe County, North Carolina. EPA is the lead agency for this site and the Site Identification Number is NCD 044 447 589. The southern portion of the site lies within the boundary of a U.S. Army Corps of Engineers designated wetland. A site location map is shown as Figure 1-1. Blue Ridge Plating started business in 1974 and has used raw materials such as cadmium, chromium, copper, cyanide, tin, and zinc. There is one building on the site and part of this building is in a state of disrepair. To the west of the building were formerly a number of old plating vats and several 55-gallon drums associated with Blue Ridge Plating operations, and other miscellaneous debris that were removed and disposed of as part of the soil cleanup completed in 2006 and 2007. 1-1 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT From 1974 to 1985, electroplating wastes were collected in drums stored in the basement of the building. Plating sludges were filtered out of the wastes and the resulting wastewater was directed to a 70,000 gallon in-ground concrete lagoon formerly located immediately south of the building. Plating sludges were shipped offsite for disposal, and the wastewater was either sprayed on the ground or reused as process water. Between 1985 and 1990, the wastewater was discharged to the local municipal sewer system. In 1990, the municipality suspended access to the sewer system because Blue Ridge Plating was not meeting pretreatment requirements. Blue Ridge Plating claimed the facility discontinued discharging wastewater to the sewer system and was using a “closed loop” treatment system; however, the Federal Bureau of Investigation (FBI) discovered that the facility continued to discharge to the sewer system. In 1991, a federal court found Blue Ridge Plating guilty of discharging heavy metals in excess of legal limits to the sewer system, discharging to a sewer without a permit, and lying to federal investigators. In 1993, the North Carolina Department of Environment and Natural Resources (NCDENR) served an injunction to Blue Ridge Plating to produce site information and implement a closure plan or further site investigation. As a result. Blue Ridge Plating proposed a groundwater monitoring schedule in 1994, and submitted a closure plan in 1996. In 1997, NCDENR received a complaint that Blue Ridge Plating was disposing of plating wastes by dumping them outside the back door and through the cracks in the floor. Consequently, NCDENR requested that EPA collect environmental samples at the facility. The EPA sampling effort, conducted in April 1998, found elevated levels of cadmium, chromium, copper, cyanide, nickel, tin, and zinc in samples collected from inside and outside the Blue Ridge Plating building. Because of these sampling results, the facility was placed in the Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) in October 1998. The 70,000-gallon lagoon was closed under EPA’s Resource Conservation and Recovery Act (RCRA) in 2000. 1.3 Previous Investigations NCDENR conducted a Preliminary Assessment / Site Inspection (PA/SI) in July 1999, which documented a release of cadmium, chromium, copper, and nickel to soils at the site. An Expanded Site Investigation (ESI) was conducted in September 2000. This investigation confirmed the presence of elevated levels of arsenic, cadmium, chromium, copper, cyanide, lead, manganese, mercury, nickel, selenium, silver, and zinc in the site soils. A Remedial Investigation / Feasibility Study (RI/FS) was conducted between 2002 and 2004, and the site 1-2 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT was placed on the National Priority List (NPL) in September 2004. A Record of Decision (ROD) for the site was issued in October 2004. The 2004 ROD called for excavation of contaminated soil/sediment and off-site disposal at a RCRA Subtitle D landfill, along with backfilling, re-grading, and re-seeding the disturbed areas. The soil cleanup phase was conducted between December 2006 and June 2007. A total of 13,105 tons (8,737 cubic yards) of soil was removed and 6,105 tons (4,070 cubic yards) of soil was backfilled and graded. A former pond, which had silted in over the years on the adjacent downgradient property, was excavated to remove the contaminated sediment that had accumulated in the pond basin. At the request of the property owner, this excavation was not backfilled with clean fill since the property owner planned on repairing the earthen dike/dam and reforming the pond. In February 2008, the breach in the earthen dike/dam was repaired, an overflow pipe was installed, and the pond has since refilled. For the groundwater cleanup phase, the ROD selected MNA as the remedy. However, injecting a reagent(s) in the underlying aquifer to oxidize, reduce, or immobilize the contaminants in place along with long-term monitoring was included as a contingent remedy for groundwater. The decision to implement the contingency was to be made after monitoring the changes in contaminant concentrations in the groundwater for five years after the soil remediation phase was completed. The groundwater monitoring program was implemented at the site in September 2007, and is currently conducted on an annual schedule. To date, there has not been a consistent trend indicating that the groundwater contamination is attenuating to below ROD cleanup levels. ERA and NCDENR completed a Five Year Review for the site in September 2012. The Five Year Review concluded that the current remedy at Blue Ridge Plating is protective of human health and the environment, and that collection of additional groundwater data is needed to determine if MNA is an effective groundwater remedy. The review recommended issuing an Explanation of Significant Difference (ESD) to allow more time for collection of groundwater data for evaluation of MNA. Other recommendations of the Five Year Review were to implement perpetual land use restrictions, to install additional downgradient monitoring wells to complete the groundwater plume delineation, and to issue an ESD revising groundwater cleanup goals for 1,1-dichloroethane and cyanide to meet current North Carolina groundwater standards. Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT EPA completed a removal action at the site in December 2014 and January 2015 to remove and properly dispose of hazardous substances, including acids, cyanide, and heavy metals such as hexavalent chromium, that were stored in deteriorating containers inside the former process building. The removal action was the result of a joint EPA and NCDENR inspection conducted in April 2013, and a follow-up inspection by the City of Asheville in October 2013, which identified leaking and unlabeled containers of hazardous waste. The removal action also included demolition of the former process building, which was deemed unsafe and condemned by the City of Asheville in December 2013. Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT 2.0 FIELD ACTIVITIES Field activities summarized in this DER include completing an annual groundwater sampling event in June 2016. The following subsections describe the field tasks completed. 2.1 Water Level Measurements On June 21, 2016, water level elevation measurements were collected from 27 of the 28 monitoring wells at the Blue Ridge Plating Site and from three offsite wells owned and maintained by Duke Energy. Well MW19D was destroyed between the August 2014 and July 2015 sampling events by construction activities and data can no longer be collected from this well. Water levels were measured from the top of casing of each monitoring well to the nearest 0.01-foot using an electronic water level indicator. Locations of the monitoring wells at the site are shown on Figure 2-1. The measured groundwater elevations, in addition to weil construction information for each of the monitoring wells, are presented in Table 2-1. 2.2 Groundwater Sampling Groundwater samples were collected from 27 of the 28 monitoring wells at the site. Monitoring well MW19D was not sampled since the well has apparently been destroyed by construction activities. Figure 2-1 shows the locations of the monitoring wells. Prior to sampling, each well was purged by pumping a minimum of three weil volumes or until field parameters (pH, turbidity, specific conductance, oxidation reduction potential [ORP], dissolved oxygen, and temperature) stabilized to within 10% of the prior reading, in accordance with EPA Region 4 field sampling protocols. The groundwater samples were collected using either peristaltic pumps or submersible pumps with Teflon tubing. The approved Sampling and Analysis Plan (SAP) for the Blue Ridge Plating Sampiing and Analytical Support provides details of sampling protocols used, field quality assurance/quality control (CWQC), and data validation/evaluation. All groundwater samples were submitted for laboratory analysis of Target Compound List (TCL) volatile organic compounds (VOCs), TCL semivolatile organic compounds (SVOCs), target analyte list (TAL) metals, and cyanide. All analyses were performed by the EPA Region 4 laboratory except cyanide which was submitted to and analyzed by Chemtech Consulting Group laboratory in Mountainside, NJ. Sampling events prior to 2015 also included the MNA parameters of ferrous iron, sulfate, sulfide, chloride, alkalinity, total organic carbon, nitrate, methane, ethane, ethene, and Dehalococcoides bacteria; however, these parameters were 2-1 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT discontinued after the 2014 sampling event based on the recommendations of the EPA Region 4 Technical Services Section. 2.3 Sampling Quality Control In accordance with the approved SAP, field quality control samples, such as field duplicates, trip blanks, rinsate blanks and temperature blanks, were collected and evaluated as a method to assess the sample handling procedures. During sampling activities, instruments used for field measurements were routinely calibrated and recorded to ensure the accuracy of readings. 2-2 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT 3.0 RESULTS The following subsections present the results of the June 2016 sampling event. 3.1 Groundwater Elevations and Gradient Groundwater elevations measured on June 21, 2016 (listed in Table 2-1) were used to create groundwater elevation contour maps for the shallow and deep zones of the saprolite aquifer. Figures 3-1 and 3-2 show the groundwater elevation contours for the shallow and deep zones, respectively. Groundwater flow direction in June 2016 was to the west-southwest in both zones. Horizontal groundwater gradients in the shallow and deep zones were approximately 0.033 and 0.029, respectively. Vertical gradients, as evaluated by comparing groundwater elevations at paired shallow and deep well locations, were downward from the shallow zone to the deep zone at seven of the ten nested well pairs (at all except the MW01, MW09, and MW12 pairs). Groundwater flow directions, horizontal gradients, and vertical gradients observed in June 2016 were consistent with those observed during previous sampling events. 3.2 Groundwater Analytical Results The following summary of analytical results is organized by monitoring well and discusses results of the 2016 annual sampling event for each monitoring well. Table 3-1 summarizes results for constituents that have been detected at concentrations above the 2004 ROD and the 2008 ESD groundwater cleanup levels, plus current ERA Maximum Contaminant Levels (MCLs) and North Carolina’s groundwater standards, between 2007 and 2016. Groundwater results are presented in Table 3-1 from all sampling events conducted since the soil remediation activities were completed, and include samples collected in September 2007, January 2008, June 2008, January 2009, January 2010, January/February 2011, February 2012, March 2013, August 2014, July 2015, and June 2016. Table 3-2 provides the final readings of field water quality parameters measured during the January 2010, January/February 2011, February 2012, March 2013, August 2014, July 2015, and June 2016 sampling events. A complete set of the analytical data reports from the June 2016 sampling event is presented in Appendix A. The following contaminants were detected above ROD cleanup goals in the June 2016 sampling event: 1,1-dichloroethene, chloroform, tetrachloroethene, trichloroethene, cadmium, iron, and manganese. In addition, other contaminants that were detected in June 2016 above either current ERA MCLs or North Carolina groundwater standards were: 1,4-dioxane, 1,1,2- 3-1 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT trichloroethane, 1,1-dichloroethane, 1,2-dichloroethane, carbazole, chromium, cobalt, and vanadium (in offsite well AMA-3A only). MW01D had three ROD cleanup goal exceedances, which were 1,1-dichIoroethene (9.1 ng/L), tetrachloroethene (18 pg/L), and iron (5,900 pg/L). Additionally, 1,4-dioxane (5.4 pg/L) and manganese (140 pg/L) exceeded North Carolina groundwater standards. Most concentrations in MW01D increased slightly in June 2016 as compared to July 2015, with 1,1-dichloroethene and iron increasing above cleanup goals. However, VOC concentrations in this well have remained relatively stable since 2007. MW01S had only one ROD cleanup goal exceedance, which was manganese at a concentration of 440 pg/L. Carbazole (3.5 pg/L), cadmium (2.8 pg/L), cobalt (6.2 pg/L), and iron (2,800 pg/L) also exceeded North Carolina groundwater standards. Contaminant concentrations in this well have generally shown a decreasing trend over the last seven sampling events, with concentrations of chloroform, naphthalene, pentachlorophenol, and cadmium dropping to below ROD cleanup goals. MW03S had two exceedances of ROD cleanup goals, which were cadmium at 6.3 pg/L and manganese at 730 pg/L. Additionally, the concentration of iron (1,400 pg/L) exceeded North Carolina groundwater standards. Metals concentrations have historically fluctuated in this well, but VOCs and SVOCs have not been detected above ROD cleanup goals. MW04S had ROD cleanup goal exceedances for iron (10,000 pg/L) and manganese (2,900 pg/L), consistent with previous sampling events. VOCs and SVOCs have not historically been detected in this well above ROD cleanup goals. MW05S had exceedances of ROD cleanup goals for cadmium (6.3 pg/L) and manganese (1,500 pg/L). Additionally, cobalt (18 pg/L) exceeded North Carolina groundwater standards. Metals concentrations remained stable as compared to the July 2015 sampling event as has been the case historically. MW06D had one ROD cleanup goal exceedance, which was tetrachloroethene at 11 pg/L. Additionally, 1,4-dioxane (4.4 pg/L) exceeded the North Carolina groundwater standard. Contaminant concentrations in MW06D have historically remained relatively stable. 3-2 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT MW06S had ROD cleanup goal exceedances for 1,1-dichloroethene (120 pg/L), chloroform (0.63 pg/L), tetrachloroethene (150 pg/L), and trichloroethene (26 pg/L). In addition, the following constituents also exceeded North Carolina groundwater standards: 1,1,2- trichloroethane (2.7 pg/L), 1,1-dichloroethane (61 pg/L), 1,2-dichloroethane (0.56 pg/L), 1,4- dioxane (41 pg/L), chromium (45 pg/L), and cobalt (10 pg/L). The VOCs 1,1-dichloroethene, chloroform, tetrachloroethene, and trichloroethene have historically fluctuated in this well, while other constituents have displayed a general decreasing trend. Concentrations of 1,1,1- trichloroethane, arsenic, cadmium, cyanide, iron, and manganese formerly exceeded ROD cleanup goals in MW06S, but have decreased to below the cleanup goals. MW07S equaled or exceeded ROD cleanup goal for chloroform (estimated at 0.19 pg/L), tetrachloroethene (1 pg/L), trichloroethene (13 pg/L), cadmium (19 pg/L) and manganese (2,200 pg/L). Cobalt (28 pg/L) was also detected at a concentration exceeding the North Carolina groundwater standard. June 2016 was the first sampling event since 2009 in which VOCs were detected in MW07S above ROD cleanup goals. Cadmium concentrations have historically fluctuated with a general decreasing trend. MW08S had ROD cleanup goal exceedances for 1,1-dichloroethene (23 pg/L), tetrachloroethene (21 pg/L), and trichloroethene (4.8 pg/L). The concentration of 1,1- dichloroethane (9.7 pg/L) also exceeded the North Carolina groundwater standard. Most contaminants in this well remained stable or decreased marginally as compared to the July 2015 sampling event but have historically displayed a general trend of decreasing concentrations since 2007. MW09D had one exceedance of ROD cleanup goals, which was tetrachloroethene at a concentration of 1.5 pg/L. June 2016 was the second consecutive sampling event in which tetrachloroethene was detected above the ROD cleanup goal in this upgradient well, although very low concentrations of several VOCs have historically been detected. No other detections exceeded the ROD cleanup goals, ERA MCLs, or North Carolina groundwater standards. MW09S, which is also an upgradient well, also had a detection of tetrachloroethene at a concentration of 1.0 pg/L, exceeding the ROD cleanup goal. Tetrachloroethene has occasionally exceeded the ROD cleanup goal in this well during some previous sampling events, with concentrations of up to 1.6 pg/L. No other detections exceeded the ROD cleanup goals, ERA MCLs, or North Carolina groundwater standards. 3-3 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT MW10S had ROD cleanup goal exceedances for 1,1-dichloroethene (29 pg/L) and tetrachloroethene (69 pg/L). In addition, the concentrations of 1,1-dichloroethane (6.7 pg/L), chromium (19 pg/L), cobalt (9.8 pg/L), and manganese (190 pg/L) exceeded North Carolina groundwater standards. Despite the increases in VOC concentrations in this well as compared to the 2015 sampling event, historical concentrations in this well have displayed a strong decreasing trend, with 1,1,-trichloroethane, chloroform, trichloroethene, and manganese decreasing to below ROD cleanup goals. MW11S had ROD cleanup goal exceedances for 1,1-dichloroethene (79 pg/L), chloroform (1.7 pg/L), tetrachloroethene (83 pg/L), and trichloroethene (21 pg/L). Constituents that also exceeded North Carolina groundwater standards were 1,1,2-trichloroethane (0.8 pg/L) 1,1- dichloroethane (46 pg/L), and manganese (120 pg/L). No clear overall trend can be determined in the contaminant levels. Some contaminants have a decreasing trend (1,1,1-trichloroethane), some have an increasing trend (chloroform), while others have been relatively stable (1,1- dichloroethane, 1,1-dichloroethene, tetrachloroethene, and trichloroethene). MW12D had ROD cleanup goal exceedances for chloroform (estimated at 0.21 pg/L), tetrachloroethene (15 pg/L) and trichloroethene (4 pg/L). Additionally, 1,4-dioxane (4 pg/L) exceeded the North Carolina groundwater standard. Most metals in this well have shown a decreasing trend in concentrations; however, concentrations of VOCs have remained relatively stable or increased slightly. MW12S had ROD cleanup goal exceedances for tetrachloroethene (4.9 pg/L), trichloroethene (25 pg/L), cadmium (26 pg/L) and manganese (1,800 pg/L). Additionally, 1,1-dichloroethane (9.8 pg/L) and cobalt (47 pg/L) exceeded North Carolina groundwater standards. June 2016 was the first time since 2011 that trichloroethene, and the first time since 2010 that tetrachloroethene, has been detected above its ROD cleanup goal. The concentrations of tetrachloroethene and trichloroethene detected in June 2016 were historical highs for this well. Chloroform previously exceeded the ROD cleanup goal, but concentrations have decreased to below the cleanup goal. Concentrations of metals have historically fluctuated with no discernable trend. MW13D had four ROD cleanup goal exceedances, which were 1,1-dichloroethene (13 pg/L), chloroform (estimated 0.29 pg/L), tetrachloroethene (19 pg/L), and trichloroethene (6.9 pg/L). Additionally, 1,4-dioxane (5.1 pg/L) and iron (370 pg/L) exceeded North Carolina groundwater Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT standards. Concentrations of 1,1-dichloroethene, tetrachloroethene, and trichloroethene have generally increased over time while chloroform has remained relatively stable. MW13S had no ROD cleanup goal exceedances: however, the concentration of manganese (150 pg/L) exceeded the North Carolina groundwater standard. MW14D had one ROD cleanup goal exceedance, which was tetrachloroethene at 1.2 pg/L. Tetrachloroethene has been consistently detected in this well since September 2007 at relatively low concentrations ranging from 0.99 to 7.1 pg/L. Concentrations in MW14D have remained relatively stable over time. MW14S had no constituents exceeding the ROD cleanup goals, ERA MCLs or North Carolina groundwater standards. There have been no exceedances of cleanup goals in this well since September 2007. MW15D had one ROD cleanup goal exceedance, which was tetrachloroethene at 6.7 pg/L. This concentration was the highest level of tetrachloroethene detected in MW15D since sampling began in January 2010. Additionally, manganese (110 pg/L) exceeded the North Carolina groundwater standards. Concentrations of tetrachloroethene in MW15D have shown an increasing trend over time. MW15S had ROD cleanup goal exceedances of 1,1-dichloroethene (12 pg/L) and tetrachloroethene (2.7 pg/L). Additionally, the concentration of manganese (110 pg/L) exceeded the North Carolina groundwater standard. After observing historically high VOC concentrations in this well during the July 2015 sampling event, VOCs decreased in June 2016, returning to levels more consistent with historical data. MW16D had ROD cleanup goal exceedances of 1,1-dichloroethene (40 pg/L), chloroform (3.2 pg/L), tetrachloroethene (7.4 pg/L), trichloroethene (64 pg/L), and manganese (790 pg/L). Concentrations of 1,1-dichloroethane (12 pg/L) and 1,4-dioxane (4.4 pg/L) also exceeded North Carolina groundwater standards. Most concentrations in this well have remained generally stable since sampling began in February 2012. MW16S had one ROD cleanup goal exceedance, which was manganese at 440 pg/L. Cadmium (3.6 pg/L), cobalt (29 pg/L), and iron (1,100 pg/L) also exceeded North Carolina groundwater standards. Historically, no VOCs have been detected above ROD cleanup goals in this well. 3-5 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT MW17D had only one ROD cleanup goal exceedance, which was tetrachloroethene at 3.4 pg/L. Additionally, iron (320 pg/L) exceeded the North Carolina groundwater standard. The June 2016 concentration of tetrachloroethene was slightly higher than during the 2014 and 2015 sampling events, and was the highest detected since sampling of this well began in March 2013. MW17S had two ROD cleanup goal exceedances, chloroform at an estimated 0.19 pg/L and tetrachloroethene at 1.8 pg/L. Manganese (85 pg/L) also exceeded the North Carolina groundwater standard. Most constituents in this well have decreased since its initial sampling in March 2013, with 1,1-dichloroethene and trichloroethene decreasing to below ROD cleanup- goals. MW18D had no exceedances of ROD cleanup goals. Iron (2,700 pg/L) and manganese (74 pg/L) exceeded North Carolina groundwater standards. MW19D was destroyed sometime between the August 2014 and the July 2015 sampling events, and therefore no current data is available from this well. MW20D had ROD cleanup goal exceedances of 1,1-dichloroethene (9.7 pg/L), chloroform (0.92 pg/L), tetrachloroethene (4 pg/L), and trichloroethene (11 pg/L). Most VOC concentrations in this well have displayed an increasing trend, while manganese concentrations have decreased to below the ROD cleanup goal. AMW-3A, AMW-3B, and MW-10 are three clustered wells located northwest of the Blue Ridge Plating site near the southern end of Lake Julian (see Figure 2-1), that are owned and maintained by Duke Energy. These wells have been sampled annually with the permission of Duke Energy since November 2014 to support characterization of the Blue Ridge Plating site. MW-10 is completed across the water table in the upper part of the saprolite aquifer, AMW-3A is completed to the top of bedrock at the base of the saprolite aquifer, and AMW-3B is completed in the bedrock aquifer. The only exceedances of ROD cleanup goals in these wells in June 2016 were the chloroform concentrations in AMW-3A (estimated 0.44 pg/L) and AMW-3B (estimated 0.32 pg/L). Additionally, chromium (59 pg/L) and vanadium (6.2 pg/L) exceeded North Carolina groundwater standards in AMW-3A, and manganese (190 pg/L) exceeded the North Carolina groundwater standard in MW-10. 3-6 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT 3.3 Statistical Analysis of Trends The Mann-Kendall statistical test was used to identify statistically significant trends in the groundwater contaminant concentrations generated from the sampling events that have occurred from September 2007 through June 2016. The Mann-Kendall test is a nonparametric test that can help identify changes in contaminant concentrations over time, for a minimum of four samples. This test cannot verify the rate at which concentrations are changing. The Mann-Kendall statistical calculations were performed using the GSI Mann-Kendall Toolkit (GSI Environmental, 2012). This spreadsheet-based software follows the Mann-Kendall methodology developed by GSI Environmental, Inc. for the Air Force Civil Engineering Center (AFCEC) in its Monitoring and Remediation Optimization System (MAROS) software. This software relies on three statistical metrics, as follows: • The Mann-Kendall Statistic, or S Statistic, indicates whether the concentration trend versus time is generally decreasing (negative S value) or increasing (positive S value). • The Confidence Factor, or CF, which modifies the S Statistic calculation to indicate the degree of confidence in the trend result. Also, if the CF is low, it is used to apply a preliminary “No Trend” classification pending consideration of the Coefficient of Variation. • The Coefficient of Variation, or COV, is used to distinguish between a “No Trend” result and a “Stable” result for datasets with no significant increasing or decreasing trend (e.g., a low CF). The S Statistic is calculated by comparing the data sequentially. For a given number of sampling events (n), the contaminant concentration from Event 1 is compared to the concentration from Events 2 through n, the concentration from Event 2 is compared to the concentrations from Events 3 through n, and the concentration from Event 3 is compared to the concentrations from Events 4 through n, and so on. If the contaminant concentration increases between two events, then a value of +1 is given. A value of -1 is given if the contaminant concentration decreases between two events and a value of 0 is given if the concentration does not change. The values representing the changes between the concentration from Event 1 and the other events are summed, then the changes between Event 2 and other events, and so on. The sums are added together to get one value, which is the S Statistic. A value of S greater than zero indicates an increasing trend, while a value of S less than zero indicates a decreasing 3-7 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT trend, subject to further modification based on the CF and the COV. The S statistic indicates the direction of the trend (increasing or decreasing), while the strength of the trend is characterized by the CF, as described below. Furthermore, if the degree of confidence regarding an increasing or decreasing trend is insufficient (due to either variability in concentrations versus time or little change in concentrations versus time), the S Statistic result is re-classified as “No Trend.” The CF is the measure of confidence for rejecting the null hypothesis of “no trend” versus time. The null hypothesis states that the dataset shows no distinct linear trend over time. The Mann- Kendall method tests the null hypothesis against the alternative hypothesis, which is that the data do show a trend over the specified time period. The probability (p) of accepting the null hypothesis is determined from the Mann-Kendall table of probabilities, which are based on the number of sample events (n, for 4 < n < 40) and the absolute value of S. Specifically, p is the probability of obtaining a value of S equal to or greater than the calculated value for n events when no trend is present. The null hypothesis is rejected when p < 0.1. The CF is defined as (1 - p)%. When CF > 95% (p < 0.05), the data demonstrate a strong trend, either “Increasing” or “Decreasing” trends. When the CF falls between 90 and 95% (0.1 > p > 0.05), the null hypothesis is rejected and a trend is indicated; however, due to the lower confidence in the trend, the qualifier “Probably” is applied, as in “Probably Increasing" or “Probably Decreasing.” If the CF is less than 90% (p > 0.1), the null hypothesis is accepted and either a “No Trend” condition or a “Stable” condition is indicated, depending on the COV. The COV for the dataset is the standard deviation divided by the mean. The COV provides a general indicator of the degree of variability in the concentrations at a particular monitoring location over time. The COV is used to distinguish between a “Stable" plume condition (relatively constant concentration in the well versus time) and a “No Trend” condition (highly variable concentrations versus time) for datasets with no significant increasing or decreasing trend. Depending on the values of the S Statistic and the COV, sampling locations that exhibit a low CF (CF < 90%) are designated as either “Stable” (S < 0 and COV < 1) or “No Trend” (COVai). The following table summarizes the statistical metrics used by the GSI Mann-Kendall Toolkit to evaluate trend; Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT S Statistic Confidence in Trend Trend S>0 CF > 95%Increasing S>0 95% > CF > 90%Probably Increasing S>0 CF < 90%No Trend S<0 CF < 90% and COV > 1 No Trend S<0 CF < 90% and COV < 1 Stable S<0 95% > CF > 90%Probably Decreasing S<0 CF > 95%Decreasing Of the 30 wells sampled in June 2016, 25 wells had enough data sets that qualified for statistical calculations. From these 25 wells, 100 data sets were analyzed to determine trends in concentrations of contaminants of concern over time. The data sets analyzed primarily were limited to those containing constituents exceeding the ROD cleanup goals. The results of the Mann-Kendall statistical analysis are listed in Table 3-3, and the outputs from the GSI Mann- Kendall Toolkit are included in Appendix B. Results of the trend evaluation are summarized in the table below: Contaminant of Concern Wells with Decreasing or Probably Decreasing Trend Wells with Increasing or Probably Increasing Trend Wells with No Trend or Stable Trend VOCs 1,1,1-Trichloroethane MW06S, MW10S, MW11S None None 1,1-Dichloroethane MW06S, MW08S, M\A/10S, MW18D MW12D, MW13D MW01D, MW06D, MW11S, MW12D, MW16D, MW17S, MW20D 1,1-Dichloroethene MW06S, MW08S, MVyiOS, MW18D MW01D, MW06D, MW11S, MW16D, MW17S, MW20D Chloroform MW01S, MW05S, MW06S, MW08S, MW12D MW11S MW01D, MW12S, MW13D, MW15D, MW16D Tetrachloroethene MW08S, MW10S MW12D, MW13D, MW15D MW01D, MW06D, MW06S, MW09S, MW11S, MW13S, MW14D, MW15S, MW16D, MW17S, MW17D, MW20D Trichloroethene MW08S, MW10S MW13D MW06S, MW11S, MW12S, MW12D, MW13S, MW15S, MW16D, MW17S, MW20D SVOCs Naphthalene None None MW01S Pentachlorophenol None None MW01S Metals Cadmium MW01S, MW06S, MW07S, MW08S None MW03S, MW05S, MW12S 3-9 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT Contaminant of Concern Cyanide Iron Manganese Wells with Decreasing or Probably Decreasing Trend MW06S MW07S MW01S, MW05S, MW08S, MW12D, MW14D, MW16S, MW17S, MW20D MW03S, MW06S. MW10S. MW13D, MW15S. MW16D, MW17D, Wells with Increasing or Probably Increasing Trend None MW04S None Wells with No Trend or Stable Trend None MW03S, MW05S, MW08S MW04S, MW07S, MW12S, MW13S, MW18D 3.4 Quality Assurance Summary Data quality objectives for the Blue Ridge Plating Site were developed during the preparation of the SAP. Data quality indicators (DQIs) are used to interpret the degree of acceptability or usability of data collected. The principal DQIs are precision, accuracy (or bias), representativeness, comparability, and completeness (PARCC). As discussed in the SAP, an EPA Region 4 contractor provides data validation of analytical results. The data validators review all method procedures, internal spikes, calibrations, matrix spike, matrix spike duplicate, performance evaluation samples among other tasks performed by the laboratories for the sample set. The case narratives included in the data deliverables and the qualifiers placed on the data are reflective of the data validation review. Other data quality review is performed by the sampling contractor including evaluation of precision and completeness, and discussion of the analytical results of field prepared blanks or equipment rinsate blanks. Field and laboratory completeness goals for this project are greater than 90 percent, as established in the SAP. To determine completeness, the number of usable, valid results for each sample type and analyte were counted and compared to the completeness objectives. The percent completeness was calculated using the following equation: % Completeness = (DO/DP) * 100 Where: DO = Data Obtained and usable. DP = Data Planned to be obtained 3-10 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT The VOC, SVOC, and metals data for the June 2016 sampling event were qualified without any rejected, not analyzed, or not reported data. However, three SVOC samples (MW06D, MW13D, and MW13D duplicate) did arrive at the laboratory in excess of 6 °C and were flagged in the data set for temperature exceedances. The only constituent detected in these three samples was 1,4-dioxane at levels anticipated from trends from previous sampling events. Therefore, the percent completeness is 100% for these data packages and the overall completeness of this field event exceeded the DQI of 90%. For precision of duplicate samples, the Relative Percent Difference (RPD) goal established in the SAP is less than 35 percent for water sample results and less than 50 percent for sediment or soil sample results. The RPD between a sample (Sample 1) and its duplicate (Sample 2) was calculated using the following formula. Relative Percent Difference = ((S-D) / [(S+D)/2J) * 100 Where: S = First sample value (original value), and D = Second sample value (duplicate value). A summary of the RPD calculations is presented in Table 3-4. Three duplicate groundwater samples were collected during this field event. Each sample and its duplicate had enough detection of contaminants to perform the RPD calculations. The average RPDs calculated for the groundwater duplicate pairs on detected constituents were 3.7% for MW06S, 3.3% for MW13D, and 5.4% for MW16D. The precision criterion for the groundwater samples was met as less than 35%. In addition to the duplicates, other field quality control samples, including trip blanks, rinsate blanks and temperature blanks, were collected and evaluated to assess the data quality. Aqueous trip blanks were collected for monitoring of the ambient conditions during collection of VOCs. For this sampling field event, two aqueous trip blanks was prepared, handled, and analyzed along with the field samples. The trip blanks were ordered and received along with the other bottle ware purchased for this sampling project. No VOCs were detected in the trip blanks. A rinsate blank was collected and analyzed for VOCs, SVOCs, and metals to check procedural decontamination and/or sample container contamination at the site that may cause sample contamination. Chloroform was detected in the rinsate blank at estimated concentrations 0.12 3-11 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT jjg/L. Chloroform is a contaminant of concern at the site; however, chloroform regularly appears as a laboratory contaminant as well. Additionally, the estimated value was below the reporting limit but above the minimum detection limit therefore the accuracy of the value is in doubt. Since no other site COCs were detected in the rinse blank sample it is possible that the chloroform is a laboratory artifact. This result should not affect the overall quality of the data of field samples from monitoring wells. Samples were packed into coolers with ice and a two-ounce bottle of water was included in each cooler as a temperature indicator. Upon receipt of samples at the laboratory, the sample custodian measured the temperature of the temperature indicators. If the temperature was outside the range of 4 degrees Centigrade plus or minus 2 degrees Centigrade, the sample custodian informed EPA sample management. Data qualifiers may be placed on the data for temperature exceedances. Notifications and qualifiers were placed on three of the June 2016 results (1,4-dioxane results for MW06D, MW13D, and MW13D duplicate) to reflect sample temperature exceedances. Historical data confirmed that the 1,4-dioxane levels were within expected ranges; therefore, the confidence in the data quality for these three samples is high. In summary, the sample results received for this sampling event are useable and met quality assurance and quality control criteria and objectives. Minor data qualifiers were applied to the data which should be reviewed and may require consideration depending on intended use and decisions to be made. 3-12 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT 4.0 CONCLUSIONS AND RECOMMENDATIONS Versar completed an annual groundwater monitoring event at the Blue Ridge Plating site in June 2016. This was the seventh annual sampling event completed under this task order. The 2016 sampling also included collection of samples from three monitoring wells that are owned and maintained by Duke Energy. Groundwater analytical results from June 2016 indicated that VOCs (1,1-dichloroethene, chloroform, tetrachloroethene, or trichloroethene) were detected at concentrations above the ROD cleanup goals in 21 of the 30 wells sampled. The highest VOC concentrations were detected in MW06S. No SVOCs were detected in excess of the cleanup goals. The metals cadmium, iron, and manganese were detected above ROD cleanup goals, with exceedances of cadmium in four wells (MW03S, MW05S, MW07S, and MW12S), iron in two wells (MW01D and MW04S), and manganese in eight wells (MW01S, MW03S, MW04S, MW05S, MW07S, MW12S, MW16D, and MW16S). In addition to the site contaminants with cleanup goals established by the 2004 ROD and 2008 ESD, there were several other constituents detected in site groundwater in June 2016 at concentrations exceeding current EPA MCLs or North Carolina groundwater standards. These constituents are; 1,1,2-trichloroethane, 1,1-dichloroethane, 1,2-dichloroethane, 1,4-dioxane, carbazole, chromium, cobalt, and vanadium. Based on analysis of groundwater concentration trends at the site using the Mann-Kendall statistical test, chlorinated VOC concentrations generally appear to be exhibiting a decreasing trend in most shallow wells but either an increasing trend, stable trend, or no trend in most deep wells. For metals, the Mann-Kendall test indicated that most wells display decreasing trend, stable trend, or no trend. The only metals data set with an increasing trend was iron in MW04S. Based on groundwater monitoring data collected from 2007 through 2016, Versar recommends continuing annual groundwater monitoring in accordance with the recommendations of the First Five Year Review. 4-1 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT 5.0 REFERENCES Black & Veatch Special Projects Corporation (Black & Veatch) 2004, Remedial Investigation Report, Blue Ridge Plating Company Site, Arden, Buncombe County, North Carolina, August 19, 2004. Black & Veatch 2009, Revised Data Evaluation/Cleanup Status Report Based on Groundwater Data Collected between September 2007 and January 2009, Blue Ridge Plating Site, Arden, Buncombe County, North Carolina, May 2009. GSI Environmental Inc., 2012, Software User’s Manual GSI Mann-Kendall Toolkit for Constituent Trend Analysis Version 1, November 2012. J. M. Waller, 2010, Sampling and Analysis Plan for Sampling and Analytical Support, Blue Ridge Plating Superfund Site, Arden, Buncombe County, North Carolina, January 2010. U.S. Environmental Protection Agency (EPA) 2004. Record of Decision Summary of Remedial Alternative Selection, Blue Ridge Plating Site, Arden, Buncombe County, North Carolina, September 29, 2004. EPA 2008, Explanation of Significant Difference to the Remedial Action; Blue Ridge Plating Superfund Site, Arden, Buncombe County, North Carolina, June 27, 2008. EPA 2009, Review of Revised Data Evaluation/Cleanup Status Report on Groundwater Data Collected between September 2007 and January 2009 (Black & Veatch), Blue Ridge Plating Site, Arden, Buncombe County, North Carolina. July 16, 2009. EPA 2012, First Five-Year Review Report, Blue Ridge Plating Site, Arden, Buncombe County, North Carolina, September 26, 2012. 5-1 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT TABLES Table 2-1 Groundwater Elevation Summary June 21,2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Screened Water Level Total Depth interval TOC Elevation Depth to Water Elevation Well Number (feet bgs)(feet bgs)(feet) (ft below TOC) (feet) MW01D 73 63-73 2213.70 11.13 2202.57 MW01S 22 *2212.87 11.46 2201.41 MW03S 13 2.5-12.5 2204.13 2.98 2201.15 MW04S 15 5.0-15.0 2205.60 3.49 2202.11 MW05S 15 5.0-15.0 2206.11 4.87 2201.24 MW06D 78 68-78 2217.65 19.37 2198.28 MW06S 36 16-26 2216.23 17.77 2198.46 MW07S 15.5 5.5-15.5 2204.34 5.73 2198.61 MW08S 26.5 16.5-26.5 2214.42 18.11 2196.31 MW09D 78 68-78 2222.57 13.74 2208.83 MW09S 27.5 17.5-27.5 2223.09 15.69 2207.40 MW10S 30 20-30 2215.98 17.15 2198.83 MW11S 32.5 22.5-32.5 2218.80 18.40 2200.40 MW12D 60 50-60 2206.19 8.30 2197.89 MW12S 19 *2207.25 9.43 2197.82 MW13D 89 79-89 2211.58 18.56 2193.02 MW13S 30 20-30 2211.74 18.21 2193.53 MW14D 90 80-90 2220.17 21.32 2198.85 MW14S 40 30-40 2220.09 20.14 2199.95 MW15D 80 70-80 2212.06 21.95 2190.11 MW15S 26 16-26 2212.26 21.64 2190.62 MW16D 63.5 53.5-63.5 2185.99 6.08 2179.91 MW16S 15 5-15 2185.96 4.59 2181.37 MW17D 109.5 99.5-109.5 2212.95 24.82 2188.13 MW17S 34.5 24.5-34.5 2213.01 22.34 2190.67 MW18D 25.5 15.5-25.5 2181.28 4.66 2176.62 MW19D 62.5 52.2-62.5 2189.75 destroyed -MW20D 52.75 42.75-52.75 2178.01 4.91 2173.10 MW-10 8 3-8 2171.20 6.26 2164.94 AMW-3A 72 62-72 2173.37 8.46 2164.91 AMW-3B 98 88-98 2173.00 8.56 2164.44 Notes bgs = below ground surface TOC = top of casing * = Data not available Table 3-1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Andyte ROD Cleanup EPA NCAC 2L u„«. I I I }unds 1,1,1-Trichloro6thane 200 200 200 pgA 42 4.4 3.5 3.9 3.2 3.4 1.3 2.4 1.9 1.6 3.4 1,1,2-TrichlorDelhane NE S 0.6 na/L 0.13 J 0.13 J 0.064 J1.1'Dichloroethane 700 NE 6 2.9 3.0 3.0 3.6 3.4 4.2 1,7 3.2 2.9 2 5 2.7 0.0080 J1,1-Dichioroethene 7 7 7 ug/L 3.2 12 ».8 _14 12 15 5.9 J 9.8 6.1 J 9.1 8.2 t,2-0ichloroethane NE 5 0.4 0.31 J 0.28 J 0.33 J 0.19 J 0.30 J 0.17 J Carbon Tetrachloride NE 5 0.3 pgA. Chloroform 0.19 80 70 Mg/L 0.2 J 0.46 J 0.19 J 0.25 J 0.24 J 0.29 J 0.22 J 0.17 J 0.45 J 0.52 0.17 J 0.49 J 0.18 J 0.25 J T:25J 0.13 0.17 J 0.09 JChloromethaneNE NE 3 mil T etrad>k>roether>e 0.7 S 0.7 23 25 14 I 25 26 32 11 24 16J 18 19 Trichioroethene 2.8 5 3 pg/L 062 0.75 062 0.88 0.96 1.1 0.44 J 11 0.99 0.77 0.56 NE 2 0.03 A ■Hj1,4-Oioxane NE NE 3 pg/L 6.7 J 13 7.4 J 7.4 5.4 14 NE 30 pg/L 0.03 J 6 10 7.9 26 1.1J NE 6 3 pg/L 15 Carbazoie NE NE 2 pg/L 8.8 ,9,6 9.1 6.0 11 6.9 3.5 Naphthalene 21 NE 6 pg/L 0.09 J 61 70 51 14 1.3 JPentachlofophenol0.3 1 0.3 pg«-1 J 1.4 J 0.54 N 2.1 1.9 2.0 Metals 1AntimonyNE6 '1 pg/L Arsenic 10 10 10 pgfl-5.9 JBariumNE2000700M9/L 25 45 16 24 19 17 53 16 11 11 13 14 15 11 22 Cadmium '5 5 2 pg/u 3.0 J 20 9.0 17 19 12 :8.0 7.9 3.9 3.8 3 6 3.3 28 Chromium !NE 100 10 pg/L 6.8 7.7 I 6.7 Cobalt NE NE 1 pg/L 23 14 14 9 1 7.1 5,5 6.2 Cyanide 154 200 70 pg/L 1.3 J 72 45 20 6.6 JIron3800NE300pg/L 1600 1100 190 340 2200 4800 540 1900 730 440 5900 37 J 2800 Manganese 300 NE 50 pg/L 51 34 7.6 45 56 110 16 46 19 14 140 1600 820 1400 j 1800 1400 510 910 490 510 STO 400 440 Nickel 100 NE 100 pg/L 1 5 J 6.5 J 12 15J Selenium NE 50 20 pg/L Vanadium NE NE 0.3 _P3rt^5.5 Bold Notes Table presents results for constituents that currently or historically exceed ROD cleanup goals, EPA MCLs, or NCAC 2L standards. ' Record of Decision Summary of Remedial Alternative Selection, Blue Ridge Plating Site, Arden, Buncombe County, North Carolina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. ^ North Carolina Administrative Code Title 1SA, North Carolina Department of Environment and Natural Resources Division of Water Quality, Subchapter 2L, Groundwater Quality Standards, ISA NCAC 2L .0202 (Effective April 1,2013) Analytical results exceeding the ROD Cleanup Goals are shaded. Analytical results exceeding the EPA MCL are bold. Analytical results exceeding the NCAC Groundwater Standard are red. ROD - Record of Decision EPA - United Stales Environmental ProtecBon Agency MCL - Maximum Contaminant Level NCAC - North Carolina Administrative Code pgA. - micfograms per liter Blank' no data available: or results are non-detect NE - not established * - denc^es duplicate sample Qualifier Definitions J • The identificatjon of the analyte is acceptaMe; the reported value is an estimate. N * There Is presumptive evidence that the analyte Is present: the analyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in ax)lerwith temperature blank > 6 degrees C Page 1 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte ROD Cleanup Goal' ' EPA MCL^NCAC 2L Standard^Units MW03S 1 MW04S | Vnlatilu Onjami; Com|i lliuts 1.1,1 -Trichtofoethane 200 200 200 pg/L 1,1,2-Trichlofoethane NE 5 06 tig/L 1.1-Dichlorc}emane 700 NE 6 iig/L 0.08 J 0.025 0.16 J 0.091 1 1,1-Dichioroethene 7 7 '7 tia/L 0.25 J 0.10 J1.2-Dichloroethane NE ,5 0.4 (ig/L Carbon Tetrachloride NE 5 0.3 Mg/L Chloroform 0.19 80 70 ligrt.0.047 Chloromethane NE NE 1 3 gg/L Tetrachloroethene 0.7 5 0.7 ggrt.0,15 J 0.19 JTrichloroethene2.8 1 5 3 M9/L 050 0.60 0.75 0.53 0.16 J 0.14 J Vinvl chloride NE '2 0.03 Pfi/L 1,4-Dioxane NE NE 3 pgA.1.2 J2-Methyinaphthalene 14 NE 30 0,10 6is<2-ethy4he](yt) phihatate NE 6 3 Ud/L Carbazole NE NE 2 pgrt. Naphthalene 21 NE 6 pgrt.0,09 J 0.08 JPentachlorophenol0.3 1 0.3 pg/L 0.042 J Antimony NE 6 1 pg^ Arsenic 10 10 10 pgA.24 JBariumNE2000700uo/L 49 50 31 55 50 78 62 58 54 43 39 43 36 32 34 Cadmium 5 5 2 pg/L 7,8 48 7.8 8.2 2,7 30 1.1 6.1 8.3 Chromium NE 100 10 pg/L 16 17 18 35 15 12 9.5 6.3 Cobalt NE NE 1 pgA. Cyanide 154 200 70 pg/L 59 42 16 55 40 Iron 3800 NE 300 pg/L 12000 190 3000 2600 580 570 330 140 570 1400 400 1400 2300 570 2800 110 8800 11000 7800 6200 16000 10000 10000 300 NE 50 pg/L 7800 870 1400 2000 840 840 390 31 84 820 320 730 3400 1^0 34(K}3400 2400 2(XH)2000 24m 2700 2400 2900 Nickel 100 NE 100 pg/L 19J 10 11 Seienium NE 50 20 pg/L Vanadium NE NE 0.3 pg/L Red Table presents results for constituents that currently or hisloncatly exceed ROD cleanup goals, EPA MCLs. or NCAC 2L standards. ' Record of Dedsic^ Summary of R^edial Alternative Selection. Blue Ridge Piating SKe, Arden, Bunccmibe County, North Carolina. ^ Regional Screening Levels for Chemical Contaminants at SuperfufKl Sites. ^ North Carolina Administrative Code Title 15A, North Carolina Department of Environment and Natural Resources Division of Water Quality. Subchapter 2L. Groundwater Quality Standards. ISA NCAC 2L .0202 (Effective April 1, 2013) Analytkal results exceeding the ROD Cleanup Goals are ^aded. Analytical results exceeding the EPA MCL are bold. Analytical results exceeding the NCAC Groundwater Standard are red. ROD - Record of Decision EPA - United States Environmental Protection Agency MCL - Maximum Contaminant Level NCAC - North Carolina Administrative Code pg^ • micrograms per liter Blank - no data available; or results are nomdetect NE • not established * - denotes duplicate sample Qualifier Definitions J - The identification of the analyte is acceptable; the reported value is an estimate. N • There is presumptive evidence that the analyte is present; the analyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in cooler with temperature blank > 6 degrees C Page 2 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 • June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Anaivts ROD Cleanup EPA NCAC 2L UnHs MW05S MW06D Volatile Organic Compounds1.1,1-TrichlorDethan®200 200 200 Mg/L 0.27 J 1.9 J 2.2 2.0 2.8 2.8 2.1 2.1 1.8 1.8 1.2 1.1 1.1.2-Trichk>roethane NE 5 0.6 Mg/L 0.16 J1,1-Dichloroe^ane 700 NE 6 (ig/L 0.042 1.4 1.4 1.6 2.1 2.3 2.2 2.4 2.2 2 1 1.6 1.6 1.1-Dichloroethene 7 7 7 Pfl/L 0.08 J 0.25 J 0.39 J 5.1 5.2 f.S 7.6 7.6 8.5 8.1J 6.3 5.1 J 6.0 NE 5 0.4 Pfl/L 0,21 J 0.18 J 0.17 J 0.11 J Carbon Tetrachloride NE 5 0.3 Mg/L 0.34 JChloroform0.19 80 70 gg/L 0.71 0.52 0.40 J 0.27 J 0.17 J 0.18 J 0.19 0.08 J 0.10 J 0.11J 0.16 J 0,16 J 0.15J 0.21 0.14 J 0.22 J 0.15 JChloromethane NE NE 3 pg/L 0.96 T etrachkrroe^ene 0.7 5 0,7 pg/L 0.07 J 0.21 J 0.22 J 12 13 11 16 18 18 19 14 14 9.1J 11 Trichloroethene 28 5 3 mq/l 0.10 J 0.13 J 0.36 J 0.38 J 0 30 J 0,60 0.60 0.63 0.72 0.54 0.82 0.58 0.50 NE 2 0 03 ua/L II■|H1.4-Dioxane NE pg/L 4.8 J 8.2 J 5.6 J 4.0 4.4 T-12'Methvtnaphthalene 14 NE 30 pg/L 0.45 0.15 0.17 Bls(2-ethylhexv4} phthalaie NE 6 3 pg/L 11 Carbazoie NE NE 2 gg/L Naphthalene 21 NE 6 gg/L 1.8 1.8 0.76 0.08 JPanlachlorophenol0310,3 gg/L 0.15J Metals 161 Arsenic 10 10 10 pg/L 4.5 J 2.8 Barium NE 2000 700 36 33 34 33 23 28 15 19 16 14 16 16 15 Cadmium 5 5 2 gg/L 14 9.S 12 24 8.6 8.4 9.3 5.1 6.3 Chrmnlum NE 100 10 gq/L 5,1 5 1CobaltNENE1gg/L 28 25 19 23 14 18 154 200 70 pg/L 77 59 24 24 22 18 19 13 1.6 JIron3800NE300pg/L 450 26 J 230 100 460 350 260 180 210 92 J 300 700 460 200 320 130 Manganese 300 NE 50 gg/L 4100 1800 3^2800 4000 3100 2500 3200 1500 1500 8.4 J 21 8.4 J 9.9 15 14 9.6 9.0 Nickel 100 NE 100 5.3 J 12 Selenium NE 50 20 gg/L 6.2 Vanadium NE NE 0,3 li3^ Not0« Table presents results for constituents that cumntty or historically exceed ROD cleanup goals. EPA MCLs, or NCAC 2L star>dards. ’ Record of Decision Summary of Remedial Alternative Sdection. Blue Ridge Plating Site, Arden, Buncombe County. North Carolina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. ^ North CaroRna Administrative Code Title ISA. North Carrriina Department of Environment and Natural Resources Division Water Quality, Subchapter 2L, Groundwater Quality Standards. 15A NCAC 2L .0202 (Effective April 1. 2013) [Analytical results exceeding the ROD Cleanup Goals are shaded. Bold lAnatytical results exceeding the EPA MCL are bold. Red lAnalytical results exceeding the NCAC Groundwater Standard are red. ROD • Record of Decision EPA - United States Environmental Protection Agency MCL - Mawmum Contaminant Level NCAC - North Carolina Administrative Code pg/L - micrograms per liter Blank • no data available: or results are non-detect NE • not established * • denotes duplicate sample Qualifier DefInHIons J • The identification of the analyte is acceptable; the reported value is an estimate. N - There is presumptive evidence that the analyte is present; the analyte is reported as a tentative kjentification. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in cooler with temperature blank > 6 degrees C Page 3 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyt* ROD Cleanup Goal' EPA MCL^NCAC 2L Slanclard' 9/26/07 [ V30/08 I 6/11/08 I 1/28/09 T 1^/10 T 2/2/11 I' 2/9/12 I 2/9/12’ I 3/28/13 I 3/28/13’I 8/13/14 I 8/13/14'I 7/13/15 1 7/13/15‘f 6/19/16 I 6/19/16* 1,1,1-Trichloroelhane 200 I 200 200 Mfl/U 370 310 400 240 160 120 120 no 140 140 65 75 140 !110 92 87 1.1,2*T richkKoethane NE 5 0.6 MflA-1.3 0 82 J 1 2 J 1.0 J 1 5 2.3 0.77 094 2.6 22 27 2.6 1.1-Dichloroethane 700 NE 6 pg/L 95 92 100 76 40 27 24 21 '39 45 15 19 56 36 61 60 1,1-Dichloroethene 7 7 7 pg/L 300 J 220 320 180 1 140 110 110 98 1 150 J 160 67 79 ISO J no J 120 110 1.2-Dichloroethane NE 5 0.4 pg/L 0.28 J 0 74 054 0.56 0 57 Cartion Tetrachloride NE 5 0.3 pg/L Chioroform 0.19 60 70 pg/L 1.1 0.86 1.1 0.76 J 1 0.32 J 0 26 J 0.33 0.35 i 0.16 J 0.23 J 0.54 0.47 J 063 0.59 Chloromettiane NE NE 3 pg/L 9 3 1 Tetrachloroetirane 0.7 5 07 pg/L 87 84 J 92 54 37 35 52 45 :64 78 j 54 :65 140 J ;100 J 150 140 Trichtoroethene 2.8 5 3 pg/L 21 19 J 31 31 8.8 9.0 4.5 4 3 ;6,9 10 6.3 7.6 30 16 26 26 Vinyt chloride NE 2 0.03 pg/L 1,4-Dioxane NE NE 3 pg/L H 4 29 37 74 ■ 13 24 ?e 41 42 2-Methvlnai:^thalene 14 NP NE 30 -Ha/L, Carbazole iVt NE NE 2 gg/L ng/LNaphthalene21NE6h?/l 0.19 Pentachlorophenol 0.3 1 0.3 pg/L 0.27 JMetals Antimony NE 6 1 ng/LArsenic101010pg/L 56 14 14 Barium NE 2000 700 |/fl/L 9.8 18 28 28 33 33 20 20 25 27 23 23 Cadmium 5 5 2 pg/L 46 21 46 45 17 7.0 4.3 3.3 1,6 1,5 Chromium NE 100 10 ggn-110 130 190 180 220 230 60 59 55 56 45 42 Cobalt NE NE 1 pg/L 76 40 28 28 30 30 9.2 9.2 11 11 10 9.9 Cyanide 154 200 70 260 250 280 J 250 230 120 NA-4 NA-4 110 110 36 28 41 37 31 36 Iron 3800 NE 300 Mfl/L 160 160 140 61 J 160 110 120 Marrganese 300 NE SO pg/L 1200 670 2000 2300 1000 570 200 170 180 190 13 14 39 42 40 40 Nickel 100 NE 100 pgfl-9.5 J 25 26 J 12 Selenium NE 50 20 pg/L 24 18 IS 15 40 38 6.2 6.4 B.O 8.0 8.2 J 8.0 JVanadiumNENE03,1^. TsMe presents results for constituente that currently or histork»tly exceed ROD deanup goals. EPA MCLs. or NCAC 21. dandaRis. ' Record of Decision Summary of Remedial Alternative Selection, Blue Ridge Plating Site. Arden, Buncombe County, North Carolina. ^ Regional Screening Levels for Chemical Contaminante at Superfund Sites. ^ North Carolina Administrative Code Title 15A, North Carolina Department of Environment and Natural Resources Division of Watw Qua%. Subchapter 2L, Groundwater Quality Standards. 15A NCAC 2L .0202 (Effective April 1.2013) Analytical results exceeding the ROD Cleanup Goals are shaded. Analytical results exceeding the EPA MCL are bold. Analytical results exceedirtg the NCAC Groundwater Stendard we red. ROD • Record of Decision EPA • United States Environmental Protection Agency MCL - Maximum Contaminant Level NCAC - North Carolina Administrative Code pg/L - microhms per liter Blank > no data availaUe; or results are non-datect NE • not established * - denotes duplicate sample Qualifier Definftiona J • The identification of the analyte is acceptable; the reported value is an estimate. N > There is presumptive evidence that the analyte is present; the anatyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to interferences. T*1 • Sample re<»ived In cooler vrith temperature blank > 6 degrees C Page4of 13 Table 3>1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte ROD MW07S I mSmm [gij jujj wBEroa wrmm mn^nm mmtu minm wmm wmmt wismm w^imi mmmui mn^^kim mhul^alm em3 Kana 1,1,1-Trichloroelhane 200 200 200 lig/L 0.14 J 0.30 J 170 ISO 63 100 12 87 30 19 16 27 16 1,1,2-Trichloroethane NE 5 0.6 pg/L 0.14 J 1.3 0.29 J 0.27 J 0.24 J 0.42 J1,1-Dichioroethane 700 NE 6 pg/L 0.48 J 0.16 J 0,12 J 0.063 0.60 62 55 23 48 7.4 23 10 7.4 4.9 10 9.7 1,1-Dichloroethene 7 7 7 pg/L 0.82 J 0.05 J 0 36J 0.060 J 0.22 J 0.64 190 J 140 73 110 17 80 14 27 J 19 27 J 23 1,2-Oic^loroethane NE 5 0.4 pg/L 0.36 J 0.13 J Carbon Tetrachloride NE 5 0.3 pg/L Chloroform 0.19 60 70 pg/L 1.6 0.23 J 0.4 J 1.4 0 13 J 0.095 0.090 J 0.19J 0.79 0.63 0.24 J 0.64 0.32 J 0,17 0.10 JChloromethaneNE NE 3 pg/L 0.93 T etrachloroethene 0.7 5 0.7 pg/L 0.24 J 0.09 J 0.31 J 0.12 J 0,23 J 0.29 J 1 0 65 61 20 41 4 6 26 13 9.2 12 22 J 21 Trichloroethene 2.8 5 3 pg/L 19 1.9 0.95 11 J 0,29 J 0.14 J 0.45 J 0.21 J 1.7 1.6 !13 34 33 18 50 11 15 7.8 5.8 2.6 5.2 4 8 Vinyl chloride NE 2 0.03 Semivolatile Otg3mIc Compound3 1,4-Dioxane NE NE 3 pg/L 22 5.5 J !2.6 J 33 1.9 J14NE30pg/L 0.05 J 0.12 8is(2-e1hy^xyl) phthalate NE 6 3 pg/L Carbazole NE NE 2 :pg/L 21 NE 6 pg/L 0.17 1.4 0.64 4.4 0.11 Penlachlorophenol 0.3 1 0.3 pg/L 0.16 J Metals 1/Vntimonv 6 1 pg/L Arsenic 10 10 10 pg/L 1.3 Barium NE 2000 700 pg/L 63 28 36 65 31 27 54 25 76 37 34 14 17 12 Cadmium 5 5 2 pgA-53 37 42 !44 38 15 18 37 14 12 19 65 26 11 51 4,5 18 2 6.8 2.1 34 0.78 Chromium NE 100 10 pg/L 10 5.9 6.7 6.5 CobaH NE NE 1 pg/L 23 14 28 56 22 80 9.3 Cyanide 154 200 70 pg/L 35 55 25 J 16 28 28 17 20 31 33 64 48 37 '19 51 NA-4 25 15 26 Iron 3800 NE 300 pgrt.4200 650 '1500 1600 340 700 510 410 490 110 170 5100 95 J 220 430 450 450 130 Manganese 300 NE 50 pgg.9600 2700 :2100 930 420 140 230 .380 1800 1400 2200 1000 430 400 900 99 330 59 180 51 95 21 Nickel 100 NE 100 pg/L 73 29 J 46 47 47 23 26 42 18 14 20 40 15J 14 31J Selenium NE 50 20 pg/L 2.6 2-6 5.8 3.7 5.6 2.9 5.4 2.0 Vanadium NE NE 0.3 Bold Red Notes TaUe ixesents results for constituents that currently or histork»IIy exceed ROD cleanup goals, EPA MCU. w NCAC 2L standards. ' Record of Decision Summary of Remedial Alternative Selection. Blue Ridge Plating Site, Arden, Buncx>mbe County. North Carolina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. ’ Norfo Carolina Administrative Code Title 15A, Nordi Carolina Department of Environment and Natural Resources Division of Water Quality. Subchapter 2L, Groundvrater Quality Standards. ISA NCAC 2L .0202 (Effective April 1. 2013) Analytical results exceeding the ROD Cleanup Goals are shaded. Analytical results exceeding the EPA MCL are bold. Analytical results exceeding the NCAC Groundwater Standard are red. ROD • Record of Decision EPA - United Stat^ Environmental Protection Agency MCL - Maximum Contaminant Level NCAC - North Cartriina Administrative Code pg/L - mioograms per liter Blank - no data available; or results are non-d^ect NE • r>ot established * - denotes duplicate sample Qualifier Definitions J - The idenhfication of the analyte is acceptable: the reported value is an estimate. N - There is presumptive evidence that the analyte is present; the analyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in cooler with temperature blank > 6 degrees C Page 5 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 • June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte j ROD Cleartup Goal' ERA MCL*NCAC 2L Standard^Units MW09D 1 MW09S 1.1.1-Trichloroelhane 200 200 200 pg/L 0.08 J 0.10 J 0.23 J 0 29 J 0.28 J 0.10 J1,1,2-TricNoroelhane NE 5 0.6 M?/L 1,1-Dichtoroethane 700 NE 6 li?/u 0.09 J 0.11 J 0.12 J 0.14 0.0054 J1,1-Dichioroethene 7 7 7 mqa.0.12 J 0.28 J 0 21 J 0.24 J 0.27 J 0.39 J 0.30 J 0.42 J 0.31 J 0.61 0.22 J 0.64 0.29 J 0.55 J 0.45 J1,2-Dichloroethane NE 5 0.4 Carbon Tetrachloride NE 5 0.3 M9/L Chloroform 0.19 80 70 pgA 0.047 0.07 J 0.15J 0.010 J 0.10 JChloromethaneNENE3pg/L 0.82 T etrachloroethene 0.7 5 0.7 pgA-0.1BJ 0.37 J 0.37 J 0.36 J 0.23 J 0.45 J 0.64 1.0 J 1.5 0.64 !1.4 1.1 1.5 0.55 1.6 0.90 0.99 1.0J 1.0Trichloroethene2.8 5 3 Mgrt.0.31 JNE2003 1,4-Dioxane NE NE 3 pg/L 2-Methylnaphlhalene 14 NE 30 .jig'i-0.03 J :0.12 Bis(2-e4h)eiexyl) phth^te NE 6 3 pgA. Carbazole NE NE 2 MS'!- Naphthalene 21 NE 6 M?/L 0.20 0.21 0.08 JPentachlorophenol0.3 1 0.3 pg/L 0.089 J■■■■I■■■■■■■■BB|Antimony NE 6 1 Arsenic 10 10 10 ggA. Barium NE 2000 700 Mg'!-17 28 IS 15 16 18 14 20 16 14 15 14 16 16Cadmium55 2 gg'i- Chromium NE 100 10 Mg'!-50 60 Cobalt NE NE 1 M9/L Cyanide 154 200 70 ..HirE,36 10 Iron 3600 NE 300 1200 340 230 39 J 660 2300 100 360 600 1300 220 200 300 270 220 300 NE 50 300 98 160 70 82 120 12 10 13 11 12 J 7 J 14 19 28 11 9.6 11 7 3 13 9.4Nickel100NE100..gg/E 92 17 J 15 25 33 Selenium NE SO 20 pgA. Vanadium NE NE 0.3 W'E Table presents results for constituents that currently or historically exceed ROD cleanup goals, ERA MCLs, or NCAC 2L standards. ’ Record of Dedsion Summary of Remedial Alternative Seledion, Blue Ridge Plating Site. Arden. Buncombe County, Nwlh Carolina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. ^ Norttt Carolina Administrative Code Title ISA. North Carolina Department of Enwronment and Natural Resources Division of Water Quality. Subchapter 2L. Groundwater Quality Standards. ISA NCAC 2L .0202 (Effective April 1,2013) [Analytical results exceeding the ROD Cleanup Goats are shaded. Bold [Analytical results exceeding the ERA MCL are bold. Red [Analytical results exceeding the NCAC Groundwater Standard are rad. ROD - Record of Decision ERA - United States Enviror il Protection Agency MCL • ^teximum Contaminant Level NCAC - North Carolina Administrative Code pg/L - micrograms per liter Blank - r>o data available; or results are non-detect NE - not established * - denotes duplicate sample Qualifier Definitiona J - The identification of the analyte is acceptable: the reported value is an estimate. N - There is presumptive evidence that the analyte Is present: the analyte is reported as a t« NA-4 - Not analyzed or reported due to interferences. T-1 - Sample recced in cooler wibi temperature blank > 6 degrees C Page 6 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Anaivta ROD ! Cleanup EPA NCAC 2L Unito MW1QS MW11S Volatile Organic Compounds1,1,1-TnchloroBthane 200 200 200 2800 3000 2100 1700 270 91 70 42 16 15 39 260 J 440 370 400 240 130 no 96 46 1,1,2-Trichloroelhane NE 5 0.6 Mg/L 2 0.40 J 0.27 J 2.0 J 1 6 J 1.8 1.2 1,4 0.80 1,1-Dichi(m}ethane 700 NE 6 mo/l 110 120 94 82 13 3.3 3,5 3.2 0.91 1,2 67 45 75 J 59 74 58 68 52 71 63 46 1.1-Dichloroethene 7 7 7 pg/L 1400 J ■isoo 1300 910 190 56 47 31 J 12 12 J 29 190 J 310 210 2S0 180 190 110 120 110 J 79 1.2'Oichloroethane NE 5 0.4 uo/u 0,68 J 0 80 J 0 68 J 0.54 0 57 0.32 J Carbon Tetradilohde NE 5 0.3 pg/L Chloroform 0.19 80 70 pg/L 2.5 J 1.8 2.4 0.12 0,11 J 0.80 J 1.4 1.2 J 1.4 J 0 95 J 1.7 1-8 1.9 18 1.7 Chloromethane NE NE 3 pg/L 77 3 8Tetrachloroethena0.7 5 0.7 gg/L 570 660 430 320 55 30 28 20 14 15 J 69 95 160 120 160 140 160 100 130 100 J 83 Tnchloroethene 2.8 5 3 pg/L 57 66 60 43 7.1 1.8 1.6 1.3 0.46 J 0.56 27 25 37 J 31 33 28 32 35 38 33 21 V/mi/1 rtht/viflA NE 2 0.03 II II yiHyi _______________pfadBHi HH ■■■■■■1,4-Oioxane NE 3 pg/L 2.5 J 3.4 J ,1.3 J 1.5 J 1.2 J2-Methvlnaphthalene 14 NE 30 pg/L 0.05 J Bls(2-ett)yeiexyl} pMhalate NE 6 3 pgA. Carbazole NE NE 2 pgrt. Naphthalene 21 NE 6 pg/L 0.12 0.47 0.18 0.12 1Pentachlorophenol0.3 1 0.3 ggfl-0.24 1 Metals 1Antimony61pgA. Arsenic 10 10 10 pg/L 1.5 NE 2000 700 pgrt.12 11 11 12 9.0 8.4 9.7 0.28 J 120 110 130 120 110 85 77 Cadmium 5 1 5 2 pg/L 4.2 5.6 3.5 1.6 1.6 1.3 1.0 0,78 0.62 0.66 0.61 0.69 0.58 NE i 100 10 pgfl.5,0 17 22 19 Cobalt NE NE 1 pgrt-62 28 20 15 12 10 98 5.0 154 200 70 van-37 82 57 53 68 7.2 J3800NE 300 gg/L 290 84 J 110 110 130 110 1100 Manganese 300 NE 50 pg/L 1200 720 1400 1800 1200 520 370 320 280 220 190 180 190 150 190 190 190 180 190 140 120 Nickel 100 NE 100 gg/L 12 J 21 24 J 17 23 15 J 19 22 19 21 17 14 11 Selenium NE 50 20 pg/L 12 4.9 3.5 4.1 3.6 Vanadium NE NE 0.3 _12tJ T^e presents results for constituents foal currently or historically exceed ROD cleanup goals. EPA MCLs, or NCAC 2L stondards. ’ Record of D«xsion Summary of Remedial Alternative Selection, Blue Ridge Plating Site, Arden, Buncombe County. North Carolina. ^ Regional Screening Lev^s for Chemical Contaminants at Superfurnl Sites. ^ North Carolina Administrative Code Title 1^, North Carolina Department of Environment and Natural Resources Division of Water Quality, Subchapter 2L, Groundwater Quality Standards. 15A NCAC 2L .0202 (Effective April 1. 2013) Analytical results exceeding the ROD Cleanup Goals are shaded. Analytical results exceeding the EPA MCL are bold. Analytical faults exceeding the NCAC Groundwater Standard are red. Bold ROD - Record of Decision EPA - United Stales Environmental Protection Ag^tcy MCL - Majdmum Contaminant Level NCAC - North Carolina Administrative Code pg/L - micrograms per liter Blank - no data available: or restAs are non<deteet NE - not established * • dentrfes duplicate sample Qualifier DefinKione J • The identification of the analyte Is acceptable: the reported value is an estimate. N • There is presumptive evidence that the analyte is present: the analyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in cooler with temperature blank > 6 degrees CPage7of13 Table 3-1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte ROD Cleanup Goal' EPA MCL^NCAC 2L Standard^Units MW12D MW12S 1/5/10 I 2/1/11 I 2/10/12 I 3/28/13 I 8/14/14 1 7/16/15 I 6/19/16 9/27/07 [ 1729/08] 6/127081 1/28/09 1 1/5/10 I 1/31/11 I 2/10/12 I 3/28/13 I 8/13/14 1 7/16/15 1 6/19/16r/OEiiiiseizrEniraifQnit]>unds 1,1,1 -T richloroethane 200 200 200 1.3 1.5 J 0.89 0.99 069 1.2 1.2 0.21 J 0.67 0.60 0.23 J 0.18 J 0.14 J 1.1 1,1,2-Trichloroethane NE 5 0.8 MSn- 1,1-Oichloroethane 700 NE 6 pgfl. 1.7 1.6 2.0 22 2.0 2.6 2.9 0 34 J 0.17 J 1.2 1.1 0.51 0.30 J 0.42 0.35 J 0.30 J 98 1,1-Dichloroethene 7 7 7 mq/l 4.9 5.1 5.2 4.4 2.6 5.9 J 6.6 0.69 J 0.22 J 1.8 1.7 0.69 0.30 J 0.32 J 4.2 1,2-Oichloroethane NE 5 0.4 Mgn-0.19 J Carbon Tetrachloride NE 6 0.3 ra/L Chloroform 0.19 80 70 |K»/L 0.60 0.25 J 0.30 0.16 J 0.21 J 0.16 J 0.67 1.0 0.67 0.27 J 0.19 0.18 J Chlorom ethane NE NE 3 pg/L Tetrachloroethene 0.7 5 0.7 Mg/i-6.7 9.0 8.2 8.2 7.0 i 10J 15 0.21 J 0,84 '0.38 J 0.22 J 0.19 J 0.27 J 0.35 J 4.9 Trichloroethene 2.8 5 3 W'L 5.9 2,7 3.7 4 8 3.0 3.7 40 3.2 2.0 13 16 7.2 2.8 0.85 1.7 0.14 J 0.92 25 Vinyl chloride NE 2 0.03 pg/L ■■1pbbiNE NE 3 pg'L 2.1 J ’ 6 J 4 4 ,J 4 14 NE 30 pg/L 8.1 J 1.6 Bis(2-ethyttiexyl) pMhaiate NE 6 3 pg/L Carba^NE NE 2 wn.Naphthalene 21 NE 6 M9^020 0.57 15 1.4 J 2.7 JPentachforOTheno^^0.3 1 0.3 Mfl/L 0,077 J '0.16 JHHMPHl■■IIIIAntimonyNE61MS'!-4.5 Arsenic 10 10 10 M9'L 8.1 J 1.6 Sarium NE 2000 700 73 210 460 290 340 430 580 68 45 29 26 13 27 52 Cadmium 5 5 2 pg/L 34 32 5.9 40 82 63 21 .8.1 10 4.7 IS 26 Chromium NE 100 10 M!1/L 170 24 13 11 14 8.2 Cobalt NE NE 1 14 5.8 55 31 19 16 10 22 47 Cyanide 154 200 70 m/l 21 70 65 52 J 60 63 110 NA-4 71 23 25 29 Iron 3800 NE 300 M9/L 1100 840 270 52 J 260 Manganese 300 NE 50 (I9/L 1300 300 7.8 81 1100 170 1100 2300 1800 760 400 430 270 830 1800 Nickel 100 NE 100 pg/L 93 12 18 33 J 32 11 16 26 Selenium NE 50 20 pg/L 4.8 4.2 5.8 JVanadiumNE NE 0.3 55 27 17 16 12 Table presents results fix con^luerMs that currently or historically exceed ROD cleanup goals. EPA MCLs. or NCAC 2L stendards. ' Record of Decision Sunnmary of Remedial AKemative Selection, Blue Ridge Plating Site, Arden, Buncombe County. North Ovcriina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. ’ North Carolina Adminisfrative Code Trtie 15A. North Carolina Department of Environment and Natural Resources Division of Water Quality. Subchapter 2L. Groundwater Quality Standards, 15A NCAC 2L .0202 (Effective April 1. 2013) Bold Red Analytical results exceeding the ROD Cleanup Goals are shaded. Analytical results exceeding the EPA MCL are bold. Analytical results exceeding the NCAC Groundwater Standard are red. ROD - Record of Decision EPA • United States Environmental Protection Ager>cy MCL - Mawmum Contaminanl Level NCAC - North Carolina Administrative Code pg/L - miCFograms per liter Blank • no data available; or results are non-deteel NE - not esfoblished * - denotes duplicate sample Qualifier Definitions J - The Identification of the anatyte is acceptable: the reported value is an estimate. N - There is presumptive evidence that the analyte e present; the analyte is reported as a tentative identtficatjon. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in cooler vrith temperature blank > 6 degrees C Page 8 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina 1 1 ERA Anaivto Cleanup NCAC 2L 1 1 Voiatile Organic Compounds1.1,1-TrichlorDrthane 0.22 J IBFH 0.33 J ^BVSI ■ms 1.4 2.9 3.0 2.0 1.2 1.6 0.19 J 0.61 0.94 ■IWfi ■lEW Q3I 1,1,2-Trichloroethane NE 5 0.6 UQ/l 0.17 J 0.15 J1,1-Dichloroethane 700 NE 6 pg/L 0.15 J 0.98 1.2 1.2 0.23 J 1.7 1.8 2.0 2.5 2.5 2.1 2.3 4.7 4.7 1.4 0.6 0,32 J 0.77 0.39 2.8 0.31 J 0.65 0.28 J1.1-Dichloroethene 7 7 7 0.56 J 3.8 4.7 3.5 0.62 5.2 4.8 4.3 8.4 8.6 6.2 J 7.3 J 13 13 3.7 1.6 1.0 0.20 J 1.4 3.8 0.49 J 1.1 J 0,46 J1.2-Dichlofoethane NE 5 0.4 pg/L 0.22 J 0.23 J Carbon Tetrachloride NE 5 0.3 pg/L 0.30 JChlaxjform0.19 80 70 pg^0.51 0.21 J 0.19 J 0.18 J 0.25 0.24 J 0.25 J 0.25 J 0.22 J 0.29 J 0.28 J 0.22 J 0.10 J 0.062 Chloromethane NE NE 3 pg/L 0.30 J 0.51 1 Tetrachlofoethene 0.7 5 0.7 pg/L 1.2 4.2 3.9 4-5 20 8.4 11 10 15 15 13J 12J 19 20 0.87 0.65 0,14 J 0.47 J 1.3 0.16 J 0,50 J 0.19 JThchloroethene2.8 5 3 pg/L 0.09 J 2.4 34 2.6 3,6 2.7 2.3 4.3 4.3 3.5 3.6 6.9 6.8 4,9 18 0.69 2.4 0.26 J 11 0.69 1.7 0.42 JNE20.03 II IIA■|H m/M HI ^H^H ^HPHiHHHH 1.4-Dloxane NE pq/L 2.8 J 3.5 J 4.5 J 3.5J 5.1 4,6 5.1 T-1 4.8 T-114NE30pg/L 0.19 Bis(2-ethylhexyl) phthalate NE 6 3 pgA. Carbazole NE NE 2 pgrt- Naphthalene 21 NE 6 pg/L 0.13 0.31 0.11 Pentachlorophenol 03 1 0.3 _P9i_0 14 J Matals 1Antimony61pg/L Arsenic 10 10 10 H()/u 1.6 Barium NE 2000 700 pg/L 16 24 22 24 23 22 21 22 29 29 27 53 73 130 110 64 45 Cadmium 5 5 2 pg/L 9.4 0.54 Chromium NE too 10 pg/L 7.6 9.6 19 46 5.0 Cobalt NE NE 1 pgA.9.9 9.5 6.5 Cyanide 154 200 70 22 22 Iron 3800 NE 300 pg/L 1700 440 210 48 J 170 780 710 990 110 100 230 280 370 390 53 JMarvjanese 300 NE 50 pg/L 300 280 260 250 62 110 91 78 50 48 40 41 56 56 110 150 170 100 28 94 130 370 360 200 150 Nickel 100 NE 100 pg/L 25 S^enium NE 50 20 pg/L 4.7 3 1 3.0 Vanadium NE NE 0.3 Mg'L Bold Red Note* Table presents results for constituents that currently or historically exceed ROD cleanup goals. ERA MCLs. or NCAC 2L standards. ’ Record of Decision Summary of Remedial Alternative Selection, Blue Ridge Plating Site, Arden. Buncombe County. North Carolina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. ^ North Carolina Administrative Code Titie ISA. North Carolina Department of Environment and Natural Resources Division of Water Quality, Subchapter 2U Groundwater Quality Standards. 1SA NCAC 2L .0202 (Effective April 1,2013) Analyticat results exceeding the ROD Cleanup Goats are shaded. Analytical results exceeding the ERA MCL are bold. Analytical results exceeding the NCAC Grourxlwater Standard are red. ROD • Record of Decision ERA' United States Environmental Protection Agency MCL - Maximum Contaminant Level NCAC • North Carolina Administrative Code pg/L - micrograms per liter Blank - no data available; or results are nooKletect NE - not established * - denotes duplicate sample Qualffler Definitions J - The identification of the analyte is acceptable; the reported value is an estimate. N - There is presumptive evidence that the analyte is present; the analyte is reported as a tentadve identification. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in cooler wiffi temperature blank > 6 degrees C Page 9 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte ROD Oeaiup EPA NCAC 2L UnlU 1 1 I.l.l-Trichtofoethane 200 200 200 pg/L 0.97 0,23 J 0.36 J 0.24 J 1.8 0.23 J 0.22 J 0.15 J 1.1 0.14 J 0.24 J 0.15 J1.1,2*T richtoroediane NE 5 0.6 pg/L 1,1-Didiloroethane 700 NE 6 mo/l 0.86 0.16 J 0.5 U 0.18 J 1.9 0.22 J 0.25 0.20 J 0.13 J 0.76 0.019 1,1<Dichtoroethene 7 7 7 pg/L 0.85 J 0.57 0.53 0.60 4.2 0.79 0.66 0.71 0.56 J 0.44 J 2.4 J 0.26 J1,2-Dichk>roethane NE 5 0.4 pgrt- Carbon Tetrachloride NE 5 0.3 Chloroform 0.19 80 70 pg/L 4.4 0.20 J 0.059 STSTT 0.18 J 0.071 Chloromethane NE NE 3 pg/L 0.51 0.47 JTetrachloroethene 0.7 5 0.7 Mg/L 2.4 1.5 1.7 1.5 7.1 1.8 1.9 0.99 2,0 1.6J 1.2 0.52 0.12 JTrichloroethene2.8 5 3 pg/L 2.1 S.4 1.7 0.17 J Vinyl chloride NE 2 0.03 pgrt. 1,4-Dioxane NE NE 3 pgfl. 2*Methyinaphthatene 14 NE 30 pgA. Bis(2-eeiyihexy1) phlhalate NE 6 3 Po/L Carbazole NE NE 2 pg/L Naphthalene 21 NE 6 pg/i-0.13 0.14 Pentachlorophenol 0.3 1 0,3 pg/L 0.15 J 0.21 N Antimony NE 6 1 pg/L Arsenic 10 10 10 pg/L Barium NE 2000 700 pg/L 22 16 15 16 17 23 18 48 29 31 30 32 32 36 Cadmium 5 5 2 pg/L Chromium NE 100 10 pg/L 19 Cobalt NE NE 1 pg/L Cvanide 154 200 70 pg/L 11 6.8 J 3.3 JIron3800 NE 300 pg/L 3200 220 390 1600 810 190 130 400 340 230 54 JManganese300NE50pgA.320 130 270 130 180 28 16 13 13 17 14 740 23 37 32 93 26 26 28 28 27 31 Nickel 100 NE 100 pg/L 270 2.2 JSelenium NE 50 20 pg/L Vanadium NE NE 0.3 pg/L Table presents results for constituents that currently or historically exceed ROD cleanup goals, EPA MCLs, or NCAC 2L standards. ' Record of Decision Summary of Remedial Alternative Selection, Blue Ridge Plating Site, Arden, Buncombe County, North Carolina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. ^ North Carolina Administrative Code Title 1SA, North Carolina Department of Environment and Natural Resources Division of Water Quality, Subchapter 2L. Groundwater Quality Standards. 15A NCAC 2L .0202 (Effective April 1, 2013) Analytical results exceeding the ROD Cleanup Goals are shaded. Analytical results exceeding (he EPA MCL are bold. Analytical results e)u:eeding Uie NCAC Groundvrater Standard are red. Bold ROD - Record of Dedsion EPA • United States Enviroi MCL - Manmum Contaminant Level NCAC • North Carolina Administrative Code pg/L - micrograms per titer Blank - no data available; or results are norvdetect NE • not established * - denotes duplicate sample Qualifier DefinHIons J • The identification of the analyte is acceptable: the reported value is an estimate. N - There is presumptive evidence that the analyte is present; the analyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to interferences. T-1 • Sample received in cooler with temperature blank > 6 degrees C Page 10 of 13 Table 3>1 Groundwater Analytical Data Summary September 2007 • June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte ROD Cleanup EPA NCAC 2L UnHs MW15D 1 MW1SS I UmI ■■■I Volatile Organic Compounds1,1.1-Trichloroethane 200 200 200 pg/L 7.7 7.4 1.1 1.1 0.95 1.0 1.6 1.6 1.7 1.1 1,0 0.31 J 50 9.4 4.1 12 100 4.9 1,1.2-Trichloroethane NE 5 0.6 Ma/L 0.41 J 0.41 J 2.9 0,43 J 0.27 J 0.79 6.7 0.37 J700NE6WJ/L 2.0 2.1 0.75 072 0.99 1.0 1.2 12 1.2 1.1 1.1 9.6 2.0 1.0 2.6 22 1.1 1,1-Diehloroethene 7 7 7 MO/U 21 20 3.3 3.4 1.0 3.0 5.6 J 5.8 J 6.0 4.7 J 4.7 0,64 88 18 10J 27 190 J 12 1,2-Dichloroethane NE 5 0.4 Mflfl-0.21 J 0.21 J 1.2 0.21J 0.29 J 2.3 0.10 J Carbon Tetrachloride NE 5 03 Hfl/L 064 067 Chloroform 0.19 80 70 MtfL 0.59 0.60 0.14 J 0.16 0,17 0.13 J 0.09 J 0,075 0.52 Chloromethane NE NE 3 pg/L 0.35 J 0.36 J 0.36 JTetrachloroethene0.7 5 0.7 Mfl/L 3.6 3.6 2.5 2.6 3,6 3,6 4,3 4.5 5.0 5.8 J 6.7 14 2.6 1.4 4.7 40J 2.7 Trichloroethene 2.8 5 3 M9/L 1.8 1.7 1.5 1.6 1.8 2 1.8 19 14 1.1 072 7.2 1.3 0.48 J 1.4 10 0.51 Vinvl chlonda NE 2 0.03 ua/L Semlvolatile Organic Com|}ound1,4-Dioxane NE NE 3 pg/L 1.9J 1.9 J 2.5 J 2.4 2.1 40 6.9 J 5,7 J 22 2-Methyinaphthalene 14 NE 30 pg/L Bis(2-ethyd>exv1) d«halate NE 6 3 pg/L Carbazole NE NE 2 imii Naphthalene 21 NE 6 MQ/l Pentachloroohend 0.3 1 0.3 ua/L 0.045 J ■■Antimony NE 6 1 pg/L Arsenic 10 10 10 pg/L 2.7 Barium NE 2000 700 pg/L 27 31 17 18 17 16 18 18 17 19 19 580 620 1200 860 940 690 560 Cadmium 5 5 2 pg/L Chromium NE 100 10 pg/L Cobalt NE NE 1 pg/L 8.9 9.0 9.2 5.6 6.5 6.8 Cyanide 154 200 70 Iron 3800 NE 300 pg/L 190 970 170 190 190 Manganese 300 NE 50 pg/L 190 230 170 180 73 72 39 31 15 73 110 450 190 220 '170 150 140 110 Nickel 100 NE 100 pg/L 12 10 10 Selenium NE 50 20 pg/L 5.0 Vanadium NE NE 0.3 pg/L I Bold Red Notes Table presents results for constituents that currently or historically exceed ROD cleanup goals. EPA MCLs, or NCAC 2L standards. ' Record of Decision Summary of Remedial Alternative Selection. Blue Ridge Plating Site. Arden. Buncombe County, North Carolina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. * North Carolina Adminisfradve Code TiBe ISA, North Carolina Department of Environment and Natural Resources Division of Water Quality, Subcha ter 2L, Groundwater Quality Standards. 15ANCAC 2L .0202 (Effective April 1,2013) Analytical results exceeding the ROD Cleanup Goals are shaded. Analytical results exceeding Bie EPA MCL are bold. Analytical results exceeding the NCAC Groundwater Standard are red. ROD - Record of Decision EPA - United States Environmental Protection Agency MCL - Ma»mum Contaminant Level NCAC • North Carolina Administrative Code pg/L - micrograms per liter Blank • no data available; or results are non-detect NE • not established * • denotes duplicate sample Qualifier Definitions J - The identification of the analyte is acceptable; the reported value is an estimate. N - There is presumptive evidence that the analyte is present: the analyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to Interferences. T-1 - Sample received in coder with temperature Wank > 6 degrees C Page 11 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte ROD Cleanup EPA MCL^NCAC 2L St^ardH Unfta MW160 MW16S MW17D MW17S 2/10/12 I 3/26/13 I 8/12/14 | 8/12/14*1 7/14/15 ( 7/14/15*1 6/21/16 16/21/16*2/10/12 I 3/26/13 1 8/12/14 I 7/14/15 I 6;21/16 3/26/13 f 8/14/14 | 7/15/15 I 6/19/16 3/26/13 1 8/14/14 | 7/16/15 | 6/19/16 1.1.1-Trichloroethane 200 200 pg/L 7.4 2.7 5.3 5.4 4.4 4.4 4.8 5.0 0.21 J 0.25 J 0.23 J 51 1.9 6.5 2.0 1.1,2-Trichloroethane NE 5 0.6 0.15 J 0.090 J 0.18J 0.19 J 0.85 J1,1-Didiloroethane 700 NE 6 11 4.1 9.8 98 9 1 9 1 11 12 0.015 0.29 J 0,33 J 0.39 J 8.1 0.32 J 1.3 0.48 J1,1-CMchloroethene 7 7 7 37 14 J 36 36 29J 28 J 38 40 1.1 1.2 J 0.90 94 J 39 16 J 5.8 1.2-Oichlororthane NE 5 0.4 MSfl.0.16 J 0.15 J 0.28 J 0.19 J 0.20 J 0.24 J Carbon Tetrachloride NE 5 0.3 m-Chloroform 0.19 80 70 VQH 4.0 1.5 3.2 3.2 2.9 2.9 3.1 3.2 0.0082 J 0.16 J 0.12 J “3:^1 0.19 J Chtorom ethane NE NE 3 Md/L I Tetrachloroethene 0.7 5 0.7 6.1 2.5 5.7 5.S 5.2 J 4.9 J 7.3 7.4 0.79 2.9 2.4 J 3 4 26 1.1 3.8 J 1.8 Trichloroethwre 2.8 5 3 mu 61 42 J 60 60 58 55 62 64 0.2S J 0.22 J 5.S 0.27 J 1.1 0.40 JVinyl chloride INE 2 0.03 pqfl. cis 1,4-Dioxane NE 3 M/L 7 7 J 3 5.]32 J 3 f 3 ('4 42-Methylt>aphthatene 14 NE 30 pg/L Bl8<2-«eiylhexyt) phthalate NE 6 3 pg/L Carbazole NE NE 2 pj/L Naphthalene 21 NE 6 ^entachloropheno^^^0.3 1 0.3 pg/LCBDHiHHi■■PHHA WKM■HAntimonyNE61pg/L Arsenic 10 10 10 pg/L 2.2 Barium NE 2000 700 pg/L 85 89 110 110 110 110 120 110 86 54 55 49 57 20 25 19 20 220 180 210 190 Cadmium 5 5 2 pg/L 2.4 2.7 2.6 2.7 3.6 Chromium NE 100 10 pg/L CobaH NE NE 1 pg/L 53 34 28 28 29 10 8.8 5.6 Cyanide 154 200 70 pgrt- Iron 3800 NE 300 pg/L 510 130 200 200 110 520 340 1300 860 1100 890 260 320 Manganese 300 NE 50 pg'L 6000 2900 2000 2000 1500 1500 780 790 1000 600 510 490 440 560 98 47 25 220 150 120 85 Nickel 100 NE 100 pgA.32 23 19 21 20 Selenium NE 50 20 pg/L 5.0 Vanadium NE NE 0.3 _!2iL. NotM Table presents results for OKtstituents that currently or historically exceed ROD cleanup goals, EPA MCts. or NCAC 2L standards. ’ Record of Decision Summary of Remedial AllemaBve Selection. Blue Ridge Plating Site. Arden. Buncombe County, North Carolina. ^ Regional Screening Levels for Chemical Contaminants at Superfund Sites. ^ North Carolina Administrative Code Title 15A. North Carolina Department of Environment and Natural Resources Division of Water Quality, Subchapter 2L, Groundwater Quality Standards. 15A NCAC 2L .0202 (Effective April 1. 2013} Bold Red Analytical results exceeding the ROD Cleanup Goals are shaded. Analytical results exceeding the EPA MCL are bold. Analytical results exceeding the NCAC Groundwater Standard are red. ROD - Record of Decision EPA - United States Environmental Protection Agency MCL - Maximum Contaminant Level NCAC - North Carolina Administrative Code pg/L - micrograms per liter Blank - no data available; or results are non-detect NE - not established • - denotes duplicate sample Qualifier Definttfons J - The identification of the analyte is acceptable; the reported value is an estimate. N - There is presumptive evidence that the analyte is present; the analyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in cooler with temperature blank > 6 degrees C Page 12 of 13 Table 3-1 Groundwater Analytical Data Summary September 2007 • June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte ROD Cleanup ERA NCAC 2L MW19D ■tTOTntlilTOIEWirJXI.-igtaiini KffninPOTncgggCTflMIJiMBIgnini nTZHglg/iWiriMbritiHiji ■TOMEiw/ai.-ttiJagwita Volatile Organic Compounds ______________________________________1,1,1-Trichloroethane 200 200 200 ug/L 2.0 1.9 1,1,2-Trichioroethane NE 5 0.6 gg/L 1 1,1-Oichloroethane 700 NE 6 MP/L 2.5 1.4 0.83 0.59 1.8 2.0 1,1-Oichloroethene 7 7 7 ng/L 4.9 J 2.8 1.8J 1.1 741J 7.9 1,2'Dichloroethane NE 5 0.4 gg/L Carbon Tetrachloride NE 5 0.3 PP/L 0.28 JChloroform0.19 SO 70 gg/L 0.72 Chtoromethane NE NE 3 gg/L Tetrachloroelhene 0.7 5 0.7 gg/L 3.7 4.4 Trichloroethene 2.8 5 3 PP/L 0.73 0.55 0.44 J 0.26 J 5.0 7,0 Vinyl chloride NE 2 0.03 0 5'.!0 25 J 1.4 1.4 2.0 1.3 1.4 1.9 1.8 32 2 3 3.0 5.8 5.6 9.8 7.3 J 9.7 0.12 J 0.95 0.74 I 0.92 0.17 J 0.23 J 0.44 J 0.23 J 0.33 J 0.32 J 0.22 J 0.24 J 0.12J 2.7 2.5 4.2 2.9 J :4.0 6.4 622 12 8.6 I 11 0.19 J 1,4-Dioxane NE NE 3 PP/L 2.6 J2-Methylnaphthalene 14 NE 30 ggfl. NE 6 3 gg/L Carbazole NE 'NE 2 Naphthalene 21 NE 6 ggA. Penlachiorophenol 0.3 1 0.3 gg/L Antimonv NE 6 1 gg/L Arsenic 10 10 10 gg/L Barium NE 2000 700 gg/L 71 79 62 88 14 16 Cadmium 5 5 2 Pp/L Chromium NE 100 10 gg/L Cobalt NE NE 1 ggn- Cyanide 154 200 70 MQ/L Iron 3600 NE 300 gg/L 2500 840 1800 2700 150 Manganese 300 NE 50 gg/L 110 68 74 74 77 17 Nickel I 100 NE 100 |JP/L Selenium NE 50 20 gg/L Vanadium NE NE 0.3 gg/L 21 20 20 21 20 33 12 5.6 6.0 46 45 59 300 290 170 120 200 290 340 330 13 '7.8 28 7.3 220 190 11 6,2 Notes Table presents results for constituents that currently or historically exceed ROD cleanup goals. ERA MCLs, or NCAC 2L standards. ’ Record of Decision Summary of Remedial Alternative Setection, Blue Rkjge Plating Site, Arden. Buncombe County, North Carolina, ^ Regional Screening Levels for Chemical Contaminants at Superfurtd Sites. ^ North Carolina Administrative Code Title ISA, North Carolina Department of Environment and Natural Resources Division of Water Quality, Subchapter 2L, Groundwater Quality Standards, 15A NCAC 2L .0202 (Effective April 1. 2013} Bold Red Analytical results exceeding the ROD Cleanup Goats are shaded. Analytical results exceeding the ERA MCL are bold. Analytical results exceeding the NCAC Grour>dwater Standard are red. ROD ■ Record of Decision ERA - United Slates Environmental Protection Agency MCL • Maximum Contaminant Level NCAC • North Carolina Administrative Code pg/L * micrograms per liter Blank • no data available; or results are non^etect NE - r>ot established ‘ - denotes duplicate sample Qualifier Definitions J - The Wentiflcalion of the analyte is acceptable; the reported value is an estimate. N - There is prKumpUve evidence that the analyte is present; the analyte is reported as a tentative identification. NA-4 - Not analyzed or reported due to interferences. T-1 - Sample received in cooler with temperature blank > 6 degrees C Page 13 of 13 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte Units MW01D MW01S 1/5/10 2/3/11 2/10/12 3/26/13 8/12/14 7/15/15 6/20/16 1/5/10 1/31/11 2/6/12 3/26/13 8/12/14 7/15/15 6/20/16 Temperature “C 14.5 15.6 15.4 13.5 16.7 16.4 16.2 12.9 14.7 15.2 13.5 16.7 17.1 19.0 Specific Conductivity pS/cm 36 41 32 41 37 39 31 1755 1160 1184 1092 944 720 610 Dissoived Oxygen mg/L 1.62 5.42 4.32 6.90 4.64 5.97 6.05 1.42 0.39 0.52 2.98 0.33 0.49 pH Unitless 5.41 5.42 5.36 5.56 5.18 4.93 5.53 5.48 5.95 6.02 6.05 5.94 5.63 6.03 ORP mV 223 290 301 151 139 143 168 44 234 131 131 -37 ,44 102 Turbidity NTU 17.3 41.4 9.9 41.6 13.7 7.6 166 1.4 0.87 0.96 2.1 2.9 2.1 2.6 Notes ®C = degrees Centigrade gS/cm = microsiemens per centimeter mV = miilivolts NTU = Nepheiometric Turbidity Units mg/L = milligrams per iiter mL = miililiter Blank - no data * = beyond readable limit of instrument Finai stabiiized readings are reported. 1 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Caroiina Analyte Units MW03S MW04S 1/5/10 1/31/11 2/6/12 3/25/13 8/12/14 7/15/15 6/19/16 1/5/10 2/3/11 2/7/12 3/25/13 8/12/14 7/15/15 6/19/16 Temperature “C 9.1 10.9 11.8 10.5 20.9 20.1 16.8 12.4 11.1 14.0 12.0 20.6 18.2 16.6 Specific Conductivity pS/cm 587 435 487 524 521 398 366 509 527 453 428 380 339 338 Dissolved Oxygen mg/L 1.53 1.44 2.63 2.92 1.25 0.21 0.53 0.91 1.35 0.55 0.44 1.31 0.15 0.33 pH Unitless 6.09 5.75 5.97 6.41 6.44 6.14 6.36 6.07 6.27 6.21 6.28 6.41 6.11 6.34 ORP mV 192 10 120 -434 46 52 32 -25 -42 19 -341 -36 -66 Turbidity NTU 5.3 9.9 3.7 9.3 1.2 9.1 2.4 6.0 5.0 10.4 4.9 10.2 9.0 6.0 Notes °C = degrees Centigrade gS/cm = microsiemens per centimeter mV = millivolts NTU = Nephelometric Turbidity Units mg/L = milligrams per liter ml = milliliter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 2 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Caroiina Analyte Units MW05S MW06D 1/5/10 2/1/11 2/7/12 3/25/13 7/15/15 6/20/16 1/7/10 2/3/11 2/10/12 3/28/13 8/13/14 7/16/15 6/21/16 Temperature “C 12.1 12.9 14.3 12.6 17.7 15.4 15.1 15.8 15.4 13.9 18.6 16.1 16.2 Specific Conductivity pS/cm 764 889 722 719 527 526 24 33 26 33 32 36 32 Dissolved Oxygen mg/L 0.95 0.75 0.27 0.31 0.26 0.32 13.65 5.75 4.35 7.20 3.75 6.21 6.85 pH Unitless 5.62 5.60 5.68 5.62 5.58 5.64 5.15 5.14 5.05 5.16 5.15 4.01 4.87 ORP mV 205 272 132 171 98 193 155 289 278 168 -147 112 149 Turbidity NTU 5.1 2.4 9.7 2.4 7.6 7.0 9.2 9.5 9.7 6.1 5.1 8.3 6.1 Notes ”C = degrees Centigrade pS/cm = microsiemens per centimeter mV = miilivolts NTU = Nepheiometric Turbidity Units mg/L = miiligrams per liter ml = milliliter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 3 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte Units MW06S MW07S 1/7/10 2/2/11 2/9/12 3/28/13 8/13/14 7/13/15 6/19/16 1/5/10 2/1/11 2/7/12 3/26/13 8/13/14 7/16/15 6/20/16 Temperature “C 15.7 15.5 15.9 14.8 17.2 18.3 16.4 10.9 10.6 12.3 9.1 17.4 17.5 17.6 Specific Conductivity pS/cm 1925 2078 1497 1739 743 992 933 351 209 279 593 753 621 849 Dissolved Oxygen mg/L 1.01 4.54 3.86 3.83 1.70 2.33 0.90 5.92 6.12 4.86 5.66 3.84 3.52 4.19 pH Unitless 5.59 5.81 6.04 5.99 6.30 6.66 5.85 5.75 5.74 5.73 5.66 5.55 5.45 5.71 ORP mV 275 260 129 195 -256 139 130 176 250 174 211 130 161 150 Turbidity NTU 7.6 4.0 2.0 0.80 5.4 9.8 9.0 3.0 10.5 10.0 5.4 1.0 4.0 1.2 Notes “C = degrees Centigrade gS/cm = microsiemens per centimeter mV = millivolts NTU = Nephelometric Turbidity Units mg/L = miliigrams per liter mL = miiiiliter Biank - no data * = beyond readabie iimit of instrument Final stabilized readings are reported. 4 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte Units MW08S MW09D 1/6/10 2/2/11 2/9/12 3/27/13 8/13/14 7/16/15 6/21/16 1/7/10 2/2/11 2/7/12 3/27/13 8/12/14 7/14/15 6/19/16 Temperature °C 13.9 15.4 14.7 14.5 16.0 16.2 16.9 16.5 19.0 16.5 15.2 16.8 18.8 16.3 Specific Conductivity pS/cm 340 963 532 400 296 391 260 30 37 31 37 38 36 36 Dissolved Oxygen mg/L 1.04 4.61 4.95 5.94 6.28 3.40 4.44 13.53 4.66 4.24 5.31 6.25 5.22 5.65 pH Unitless 5.30 5.13 5.48 5.45 5.19 5.01 5.72 5.67 5.65 5.46 5.62 4.96 5.40 3.73 ORP mV 239 291 248 169 44 155 71 150 218 132 118 144 225 256 Turbidity NTU 4.7 6.0 9.1 15.6 6.0 4.9 4.3 12.7 5.3 3.6 3.7 5.4 1.3 4.5 Notes “C = degrees Centigrade pS/cm = microsiemens per centimeter mV = miilivoits NTU = Nephelometric Turbidity Units mg/L = milligrams per liter ml = milliliter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 5 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Piating Site Arden, Buncombe County, North Carolina Analyte Units MW09S MW10S 1/4/10 2/1/11 2/7/12 3/17/13 8/11/14 7/13/15 6/19/16 1/6/10 2/2/11 2/7/12 3/27/13 8/14/14 7/15/15 6/20/16 Temperature “C 10.9 15.7 16.0 15.2 17.6 17.2 16.9 15.0 16.0 16.2 14.9 16.6 16.6 16.3 Specific Conductivity pS/cm 24 19 18 17 24 26 25 838 575 396 348 218 211 223 Dissolved Oxygen mg/L 6.45 5.83 5.44 6.09 5.31 8.26 7.02 0.61 3.44 3.68 2.17 1.69 1.82 1.48 pH Unitless 4.80 4.72 4.79 5.08 4.34 4.41 4.31 4.82 5.06 5.11 5.10 5.11 5.05 5.02 ORP mV 400 161 216 85 277 197 274 322 230 164 -358 30 185 Turbidity NTU 18.9 6.2 8.6 8.2 3.3 9.1 8.2 0.00 1.3 1.2 2.6 4.2 3.3 1.0 Notes °C = degrees Centigrade pS/cm = microsiemens per centimeter mV = millivolts NTU = Nephelometric Turbidity Units mg/L = milligrams per liter mL = milliliter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 6 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Caroiina Analyte Units MW11S MW12D 1/6/10 2/2/11 2/10/12 3/26/11 8/11/14 7/13/15 6/20/16 1/5/10 2/1/11 2/10/12 3/28/13 8/14/14 7/15/15 6/19/16 Temperature »C 15.2 14.8 14.7 15.1 16.9 17.0 16.4 12.2 18.7 12.9 16.0 18.3 16.0 17.4 Specific Conductivity pS/cm 159 184 169 187 170 145 110 339 4848 3219 4904 6132 5389 4801 Dissolved Oxygen mg/L 1.47 5.46 3.41 3.99 2.07 3.03 1.43 0.21 1.52 7.31 4.09 2.00 4.04 2.60 pH Unitless 4.45 4.53 4.60 4.52 4.32 5.14 4.44 6.20 12.52 11.98 11.99 12.33 8.10 12.59 ORP mV 287 402 289 195 53 245 170 -57 -120 -86 -61 -415 -64 99 Turbidity NTU 3.1 1.3 5.6 0.00 7.9 1.4 1.6 20.1 6.0 6.9 9.8 9.2 7.0 7.3 Notes “C = degrees Centigrade gS/cm = microsiemens per centimeter mV = millivolts NTU = Nephelometric Turbidity Units mg/L = milligrams per liter mL = milliliter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 7 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte Units MW12S MW13D 1/5/10 1/31/11 2/10/12 3/28/13 8/13/14 7/16/15 6/19/16 1/7/10 2/3/11 2/9/12 3/27/13 8/13/14 7/14/15 6/21/16 Temperature “C 12.9 14.5 13.0 11.6 16.8 16.2 15.2 14.3 14.9 14.6 15.3 16.2 16.0 17.1 Specific Conductivity pS/cm 776 802 717 440 341 438 669 44 44 35 41 58 49 70 Dissolved Oxygen mg/L 0.12 0.63 0.24 0.33 1.15 0.21 0.51 5.74 6.10 5.71 5.29 4.99 5.79 pH Unitless 5.69 5.77 5.95 5.80 6.10 5.58 5.66 5.38 5.47 5.71 5.52 4.86 5.90 5.39 ORP mV 212 226 132 189 -84 181 192 84 266 144 197 96 99 94 Turbidity NTU 0.51 0.05 5.9 1.7 2.0 2.9 0.8 3.7 8.9 16.1 9.9 5.4 8.9 9.9 Notes °C = degrees Centigrade pS/cm = microsiemens per centimeter mV = miiiivolts NTU = Nephelometric Turbidity Units mg/L = miiiigrams per iiter mL = miililiter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 8 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte Units MW13S MW14D 1/7/10 2/3/11 2/9/12 3/28/13 8/13/14 7/14/14 6/21/16 1/6/10 2/2/11 2/9/12 3/25/13 8/11/14 7/13/15 6/20/16 Temperature ”C 11.3 13.5 15.2 15.2 15.9 15.0 16.4 15.5 15.9 15.9 15.2 21.8 16.7 19.3 Specific Conductivity pS/cm 231 333 368 573 573 406 345 35 48 38 37 46 46 51 Dissoived Oxygen mg/L 1.77 1.12 0.77 0.48 1.30 0.77 0.54 16.81 6.68 7.04 7.54 5.01 7.06 4.97 pH Unitless 5.03 5.03 4.93 4.72 4.36 5.32 4.86 5.71 5.76 6.01 5.80 5.83 5.55 6.21 ORP mV 233 229 220 136 50 109 98 124 237 130 245 118 191 170 Turbidity NTU 0.40 0.31 0.89 2.5 0.56 0.69 1.1 2.3 2.3 6.8 2.3 9.5 5.5 5.4 Notes “C = degrees Centigrade gS/cm = microsiemens per centimeter mV = miliivoits NTU = Nephelometric Turbidity Units mg/L = milligrams per iiter mL = miliiliter Biank - no data * = beyond readabie iimit of instrument Finai stabiiized readings are reported. 9 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Caroiina Analyte Units MW14S MW15D 1/6/10 2/2/11 2/7/12 3/25/13 8/11/14 7/13/15 6/20/16 1/6/10 2/2/11 2/9/12 3/27/13 8/13/14 7/14/15 6/20/16 Temperature “C 14.4 14.7 15.2 12.6 17.5 17.1 19.7 14.8 15.3 14.9 14.2 15.8 15.7 15.8 Specific Conductivity pS/cm 33 39 30 28 37 35 39 111 33 25 28 32 30 34 Dissolved Oxygen mg/L 1.04 3.87 4.05 5.91 5.17 4.47 3.86 5.43 5.92 4.68 5.24 6.21 5.77 pH Unitless 4.67 4.87 4.69 4.77 4.54 4.76 4.91 5.39 5.20 5.61 5.45 4.62 5.17 5.16 ORP mV 279 209 142 311 75 148 210 89 301 194 121 75 132 201 Turbidity NTU 0.22 0.08 0.52 0.01 0.93 0.02 1.0 7.2 2.6 2.3 1.5 0.19 1.3 3.2 Notes °C = degrees Centigrade gS/cm = microsiemens per centimeter mV = millivolts NTU = Nephelometric Turbidity Units mg/L = milligrams per liter mL = milliliter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 10 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte Units MW15S MW16D 1/6/10 2/2/11 2/8/12 3/27/13 8/13/14 7/14/15 6/20/16 2/10/12 3/26/13 8/12/14 7/14/15 6/21/16 Temperature °C 13.9 13.8 13.6 13.6 16.5 15.6 15.7 14.6 14.4 17.9 15.7 15.7 Specific Conductivity pS/cm 51 92 73 60 71 142 81 151 111 152 157 187 Dissoived Oxygen mg/L 9.14 3.84 5.58 3.62 5.79 2.93 4.34 1.88 1.57 1.04 0.75 0.82 pH Unitiess 4.60 4.06 4.39 4.55 3.77 4.57 4.21 5.81 5.54 5.27 5.93 5.69 ORP mV 230 288 316 268 94 222 229 177 118 -5.4 53 214 Turbidity NTU 0.54 0.93 0.46 4.3 1.6 3.5 0.8 10.8 4.5 4.8 8.9 3.9 Notes °C = degrees Centigrade gS/cm = microsiemens per centimeter mV = miliivoits NTU = Nepheiometric Turbidity Units mg/L = miiiigrams per liter mL = miliiiiter Biank - no data * = beyond readable limit of instrument Finai stabilized readings are reported. 11 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte Units MW16S MW17D MW17S 2/10/12 3/26/13 8/12/14 7/14/15 6/21/16 3/26/13 8/14/14 7/15/15 6/19/16 3/26/13 8/14/14 7/15/15 6/19/16 Temperature “C 12.2 9.2 19.7 19.2 19.8 14.3 15.8 16.3 15.9 11.8 16.6 16.8 16.7 Specific Conductivity pS/cm 219 134 178 164 202 54 46 49 44 123 133 223 178 Dissoived Oxygen mg/L 0.54 0.71 0.32 0.29 0.55 2.59 6.38 5.42 6.87 4.19 5.92 4.44 4.59 pH Unitless 5.06 4.78 4.41 4.96 4.73 6.16 5.78 6.30 6.08 4.51 4.33 4.80 4.49 ORP mV 187 222 19 112 306 122 187 150 187 259 281 • 204 341 Turbidity NTU 8.9 2.9 5.9 5.8 3.5 5.3 5.2 0.8 12.6 0.43 4.6 0.9 3.2 Notes °C = degrees Centigrade pS/cm = microsiemens per centimeter mV = miiiivolts NTU = Nephelometric Turbidity Units mg/L = milligrams per liter ml = miiiiiiter Biank - no data * = beyond readabie limit of instrument Finai stabiiized readings are reported. 12 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte Units MW18D MW19D MW20D 3/27/13 8/12/14 7/16/15 6/21/16 3/27/13 8/12/14 3/27/13 8/12/14 7/16/15 6/21/16 Temperature “C 14.7 16.5 16.5 16.0 14.3 17.6 13.7 16.4 15.1 16.5 Specific Conductivity pS/cm 166 95 166 169 65 71 ■a0)96 83 86 86 Dissolved Oxygen mg/L 0.41 0.44 2.64 0.37 3.57 3.78 = >»0) p 2.86 3.37 4.04 2.99 pH Unitless 5.25 4.78 5.31 5.31 5.94 5.43 § %5.85 5.29 1.32 5.99 ORP mV 1.7 8.8 134 180 47 2.6 0)T3 35 23 102 150 Turbidity NTU 0.20 4.5 7.9 13.7 0.71 2.9 5.2 2.2 3.2 14.7 Notes “C = degrees Centigrade MS/cm = microsiemens per centimeter mV = miliivoits NTU = Nepheiometric Turbidity Units mg/L = milligrams per liter mL = milliliter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 13 of 14 Table 3-2 Field Parameters January 2010 - June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Caroiina Analyte Units Duke Energy Wells I AMW-3A I1 AMW-3B 11 MW-10 1 11/4/14 7/15/15 6/21/16 11/4/14 7/15/15 6/21/16 11/4/14 7/15/15 6/21/16 Temperature »C 15.9 15.2 15.8 14.8 15.1 14.9 15.8 17.7 16.9 Specific Conductivity pS/cm 845 1860 949 91 88 72 73 75 72 Dissolved Oxygen mg/L 1.33 5.70 5.55 3.37 4.67 5.34 0.85 0.47 0.43 pH Unitless 11.60 11.60 11.65 6.32 6.68 6.48 5.00 5.57 5.01 ORP mV -49 101 92 36 151 115 112 151 125 Turbidity NTU 4.1 1.4 0.4 12.8 8.9 0.4 1.8 1.6 0.7 Notes °C = degrees Centigrade pS/cm = microsiemens per centimeter mV = miliivolts NTU = Nephelometric Turbidity Units mg/L = milligrams per iiter ml = miiiiliter Blank - no data * = beyond readable limit of instrument Final stabilized readings are reported. 14 of 14 Table 3-3 Summary of Mann-Kendall Statistical Calculations September 2007 - July 2015 Blue Ridge Plating Site Arden, Buncombe County, North Carolina No. of No. of Coefficient of Mann-Kendall Confidence in Well Number Constituent Samples Detections Variation Statistic Trend Concentration Trend MW01D 1,1-Dichloroethane 11 10 0.38 1 50.0%No Trend MW01D 1,1-Dichloroethene 11 10 0.52 3 56.0%No Trend MW01D Chloroform 11 8 0.31 -9 72.9%Stable MW01D Tetrachloroethene 11 10 0.45 2 53.0%No Trend MW01S Cadmium 11 11 0.72 -47 >99.9%Decreasing MW01S Manganese 11 11 0.56 -35 99.7%Decreasing MW01S Chloroform 11 9 0.56 -23 95.7%Decreasing MW01S Naphthalene 11 6 1.88 9 72.9%No Trend MW01S Pentachlorophenol 11 6 1.16 1 50.0%No Trend MW03S Cadmium 11 10 0.81 -3 56.0%Stable MW03S Iron 11 11 1.67 -12 79.9%No Trend MW03S Manganese 11 11 1.5 -25 97.0%Decreasing MW04S Iron 11 11 0.76 28 98.4%Increasing MW04S Manganese 11 11 0.23 -2 53.0%Stable MW05S Cadmium 10 9 0.6 -15 89.2%Stable MW05S Chloroform 10 8 0.63 -26 98.9%Decreasing MW05S Iron 10 8 0.85 8 72.9%No Trend MW05S Manganese 10 10 0.35 -20 95.5%Decreasing MW06D 1,1-Dichloroethane 11 11 0.2 11 77.7%No Trend MW06D 1,1-Dichloroethene 11 11 0.37 15 85.9%No Trend MW06D Tetrachloroethene 11 11 0.23 -2 53.0%Stable MW06S 1,1,1 -T richloroethane 11 11 0.59 -37 99.8%Decreasing MW06S 1,1-Dichloroethane 11 11 0.52 -25 97.0%Decreasing MW06S 1,1-Dichloroethene 11 11 0.46 -29 98.7%Decreasing MW06S Cadmium 11 8 1.15 -46 >99.9%Decreasing MW06S Chloroform 11 10 0.59 -26 97.5%Decreasing MW06S Cyanide 10 10 0.64 -37 >99.9%Decreasing MW06S Manganese 11 11 1.07 -39 99.9%Decreasing MW06S Tetrachloroethene 11 11 0.49 9 72.9%No Trend MW06S Trichloroethene 11 11 0.6 -10 75.3%Stable MW07S Cadmium 11 11 0.48 -32 99.4%Decreasing MW07S Iron 11 9 1.25 -25 99.6%Decreasing MW07S Manganese 11 11 1.34 -13 82.1%No Trend MW08S 1,1-Dichloroethane 11 11 0.91 -34 99.6%Decreasing MW08S 1,1-Dichloroethene 11 11 0.91 -28 98.4%Decreasing MW08S Cadmium 11 11 1.2 -39 99.9%Decreasing MW08S Chloroform 11 7 0.69 ‘ -27 98.0%Decreasing MW08S Iron 11 9 2.25 -9 72.9%No Trend MW08S Manganese 11 11 1.05 -41 100.0%Decreasing MW08S Tetrachloroethene 11 11 0.73 -21 94.0%Probably Decreasing IVIW08S Trichloroethene 11 11 0.91 -43 >99.9%Decreasing MW09S Tetrachloroethene 11 10 0.41 0 45.1%Stable MW10S 1,1,1-Trichloroethene 11 11 1.32 -49 >99.9%Decreasing MW10S 1,1-Dichloroethane 11 11 1.25 -39 99.9%Decreasing MW10S 1,1-Dichloroethene 11 11 1.27 -48 >99.9%Decreasing MW10S Manganese 11 11 0.75 -42 >99.9%Decreasing MW IDS Tetrachloroethene 11 11 1.23 -39 99.9%Decreasing MW10S Trichloroethene 11 11 1.27 -39 99.9%Decreasing MW11S 1,1,1-Trichloroethene 10 10 0.59 -36 >99.9%Decreasing MW11S 1,1-Dichloroethane 10 10 0.18 -7 70.0%Stable MW11S 1,1-Dichloroethene 10 10 0.36 -13 89.0%Stable MW11S Chloroform 10 10 0.26 26 98.9%Increasing MW11S Tetrachloroethene 10 10 0.24 -13 85.4%Stable MW11S Trichloroethene 10 10 0.17 4 60.3%No Trend MW12D 1,1-Dichloroethane 7 7 0.22 16 99.0%Inaeasing MW12D Chloroform 7 5 0.5 -12 94.9%Probably Decreasing MW12D Manganese 7 5 1.96 -10 95.2%Probably Decreasing Page 1 of 2 Table 3-3 Summary of Mann-Kendall Statistical Calculations September 2007 - July 2015 Blue Ridge Plating Site Arden, Buncombe County, North Carolina No. of No. of Coefficient of Mann-Kendall Confidence in Well Number Constituent Samples Detections Variation Statistic Trend Concentration Trend MW12D Tetrachloroethene 7 7 0.31 10 90.7%Probably Increasing MW12D Trichloroethene 7 7 0.27 0 37.9%Stable MW12S Cadmium 11 11 0.9 -11 77.7%Stable MW12S Chloroform 11 7 0.73 -14 84.0%Stable MW12S Manganese 11 11 0.71 -3 56.0%Stable MW12S Trichloroethene 11 11 1.21 -13 82.1%No Trend MW13D 1,1-Dichloroethane 11 11 0.73 46 >99.9%Increasing MW13D Chloroform 11 7 0.34 8 70.3%Stable MW13D Manganese 11 11 0.73 -45 >99.9%Decreasing MW13D Tetrachloroethene 11 11 0.7 43 >99.9%Increasing MW13D Trichloroethene 11 11 0.68 23 95.7%Increasing MW13S Manganese 11 11 0.63 14 84.0%No Trend MW13S Tetrachloroethene 11 7 0.79 -6 64.8%Stable MW13S Trichloroethene 11 9 1.46 1 50.0%No Trend MW14D Manganese 11 11 1.09 -39 99.9%Decreasing MW14D Tetrachloroethene 11 11 0.78 -10 75.3% Stable MW15D Chloroform 7 5 0.74 -8 84.5%Stable MW15D Tetrachloroethene 7 7 0.32 18 99.7%Increasing MW15S Manganese 7 7 0.56 -19 99.9%Decreasing MW15S Tetrachloroethene 7 6 1.52 7 80.9%No Trend MW15S Trichloroethene 7 6 1.3 5 71.9%No Trend MW16D 1,1-Dichloroethane 5 5 0.33 2 59.2%No Trend MW16D 1,1-Dichloroethene 5 5 0.33 2 59.2%Stable IVIW16D Chloroform 5 5 0.31 -1 50.0%Stable MW16D Manganese 5 5 0.83 -9 97.5%Decreasing MW16D Tetrachloroethene 5 5 0.34 -2 59.2%No Trend MW16D Trichloroethene 5 5 0.15 2 59.2%No Trend MW16S Manganese 5 5 0.37 -10 99.2%Decreasing MW17S 1,1-Dichloroethane 4 4 1.46 -2 62.5%No Trend MW17S 1,1-Dichloroethene 4 4 1.44 -2 62.5%No Trend MW17S Tetrachloroethene 4 4 1.46 -2 62.5%No Trend MW17S Trichloroethene 4 4 1.37 -2 62.5%No Trend MW17S Manganese 4 4 0.4 -6 95.8%Decreasing MW17D Manganese 4 4 1.39 -6 95.8%Decreasing MW17D Tetrachloroethene 4 4 1.33 -2 62.5%No Trend MW18D 1,1-Dichloroethane 4 4 0.64 -6 95.8%Decreasing MW18D 1,1-Dichloroethene 4 4 0.62 -6 95.8%Decreasing MW18D Manganese 4 4 0.24 -1 50.0%Stable MW20D 1,1-Dichloroethane 4 4 0.23 2 62.5%No Trend MW20D 1,1-Dichloroethene 4 4 0.24 2 62.5%No Trend MW20D Manganese 4 4 1.83 -6 95.8%Decreasing MW20D Tetrachloroethene 4 4 0.22 2 62.5%No Trend MW20D Trichloroethene 4 4 0.26 2 62.5%No Trend Interpretation of trend data: If Mann-Kendall Statistic is and Confidence is then Trend is >0 >95%Increasing >0 between 95% and 90%Probably Increasing >0 <90%No Trend <0 <90% and COV>1 No Trend <0 <90% and COV<1 Stable <0 between 95% and 90%Probably Decreasing <0 >95%Decreasing Page 2 of 2 Table 3-4 Groundwater Duplicates Relative Percent Difference (RPD) June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Caroiina Analyte MW06S MW06SX % RPD 1,1,1-Trichloroethane 92 87 5.6% 1,1,2-Trichloroethane 2.7 2.6 3.8% 1,1-Dichloroethane 61 60 1.7% 1,1-Dichloroethene 120 110 8.7% 1,2-Dichloroethane 0.56 0.57 1.8% Chloroform 0.63 0.59 6.6% cis-1,2-Dichloroethene 9.8 10 2.0% Cyanide 31 36 14.9% Tetrachloroethene 150 140 6.9% trans-1,2-Dichloroethene 1.1 1.1 0.0% Trichloroethene 26 26 0.0% 1,4-Dioxane 41 42 2.4% Aluminum 680 740 8.5% Barium 23 23 0.0% Calcium 710 700 1.4% Chromium 45 42 6.9% Cobalt 10 9.9 1.0% Magnesium 1600 1600 0.0% Manganese 40 40 0.0% Potassium 47000 46000 2.2% Selenium 8.2 8 2.5% Sodium 140000 140000 0.0% Yttrium 25 27 7.7% Average 3.7% Analyte MW13D MW13DX % RPD 1,1,1-Trichloroethane 2.9 3 3.4% 1,1,2-T richloroethane 0.17 0.15 12.5% 1,1-Dichloroethane 4.7 4.7 0.0% 1,1-Dichloroethene 13 13 0.0% 1,2-Dichloroethane 0.22 0.23 4.4% Chloroform 0.29 0.28 3.5% cis-1,2-Dichloroethene 0.36 0.35 2.8% Tetrachloroethene 19 20 5.1% Trichloroethene 6.9 6.8 1.5% 1,4-Dioxane 5.1 4.8 6.1% Aluminum 270 250 7.7% Barium 29 29 Q.0% Cajcium 4000 4100 2.5% Iron 370 390 5.3% Magnesium 1300 1300 0.0% Manganese 56 56 0.0% Methyl T-Butyl Ether (MTBE)0.13 0.14 7.4% Potassium 1300 1300 0.0% Sodium 5700 5500 3.6% Strontium 52 52 0.0% Titanium 29 30 3.4% Average 3.3% Page 1 of 2 Table 3-4 Groundwater Duplicates Relative Percent Difference (RPD) June 2016 Blue Ridge Plating Site Arden, Buncombe County, North Carolina Analyte MW16D MW16DX %RPD 1,1,1-Triehloroethane 4.8 5 4.1% 1,1,2-T richloroethane 0.18 0.19 5.4% 1,1-Dichloroethane 11 12 8.7% 1,1-Dichloroethene 38 40 5.1% 1,2-Dichiorpethane 0.19 0.2 5.1% 1,4-Dichlorobenzene 0.23 0.24 4.3% cis-1,2-Dichloroethene 1.8 1.8 0.0% Chloroform 3.1 3.2 3.2% Tetrachloroethene 7.3 7.4 1.4% trans-1,2-Dlchlbroethene 0.19 0.20 5.1% Trichloroethene 62 64 3.2% 1,4-Dloxane 3.0 4.4 37.8% Barium 120 110 8.7% Calcium 14000 15000 6.9% Magnesium 5100 5100 0.0% Manganese 780 790 1.3% Potassium 2600 2600 0.0% Sodium 8200 8500 3.6% Strontium 170 170 0.0% Average 5.4% Note: Concentrations are in micrograms per liter (pg/L) Page 2 of 2 Blue Ridge Plating Site 2016 Data Evaluation Report DRAFT FIGURES -Hi \ \ . t' Blue Ridge Plating r« ^i tf S^^ELLItilpTON 'A . f \^irrtJb Legend ' Property Line ' Streams Former Building (Demolished) Lake/Pond Feet 0 62.5 125 250 NAD83 US Stale Plane North Carolina. Feet OH WV MD Yadkin County North Carolina Blue Ridge Plating USEPA ID#; NCD044447589 Arden, Buncombe County North Carolina Figure 1-1 Site Location Map ^VERSAR I I .fe w f < : y.-i.-c',!'' . i ■ - l/i^ TO- .5> ' \ - ' ' 'Si »■ 4 mmi mi /i . J^F. IH fi Legend ^ Deep Shallow Nested Well Bedrock Former Building (Demolished) Lake/Pond Property Line Streams y*. ■: TOftsf Nested Well includes deep and shallow wells in the same casing. 0 50 100 200 NA083 US State Plane North Carolina, Feet mm Yadkin County North Carolina Blue Ridge Plating USEPA ID#; NC0044447589 Arden, Buncombe County North Carolina Figure 2-1 Monitoring Well Locations ^ VERSAR ....* ■ wtisw «n ^Bp3S«i;:- y-;i5 xS um!7si.\ .i». • ^ KBSBO©^ saaofl f ^ ^ a MW 5S' sosain SQSmDO : / *«f .*-"'' :mm cs»»@® Source: Aerial Source; USGS 2010 Date: 12/23/2016 User: hcoats Name: Fia 3-1 GW Potentiometric Map 2016 June fShallowH Legend ^ Shallow Well Groundwater Elevation Contour (in feet) Property Line Streams Former Building (Demolished) Lake/Pond Note; Groundwater elevations measured on June 2016 L Feet I I I J 0 25 50 100 NAD83 US State Plane North Carolina, Feel wv MD Yadkin County North Carolina Biue Ridge Plating USEPAID#: NCD044447589 Arden, Buncombe County North Caroiina Figure 3-1 Groundwater Elevation Contour Map June 2016 (Shallow) VERS AR Legend Deep Well Groundwater Elevation Contour (in feet) lyyN Former Building '//a (Demolished) m Lake/Pond Property Line Streams Note: Groundwater elevations measured on June 20162208!83 MW14D 2,1.98l85i 'MW06Di2t9§S^mm 0 50 100 200 NAD83 US State Plane North Carolina. Feet MVy,16D. 21r79T91 ;^p2i1t76T62 Yadkin County North Carolina Blue Ridge Plating USEPA ID#: NCD044447589 Arden, Buncombe County North Carolina Figure 3-2 Groundwater Elevation Contour Map June 2016 (Deep) ........^ VERSAR Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX H 2017 Declaration of Perpetual Land Use Restrictions H-1 v"k}ii;.*ii6So3iii.JooJ' Buncofflbe County, NCDrew Reisinger Register of Deeds bk5529p4739-1744 DECLARATION OF PERPETUAL LAND USE RESTRICTIONS "fep : (jkdiVU ^ For Property Owned By: Carolyn Mitchell Benfield as Trustee of the Bill J. Bcnfield Family Trust Former Blue Ridge Plating Site, Buncombe County, North Carolina The real property which is the subject of this Declaration of Perpetual Land Use Restrictions ("Declaration") is contaminated with hazardous substances, and is an INACTIVE HAZARDOUS SUBSTANCE OR WASTE DISPOSAL SITE as defined by North Carolina’s Inactive Hazardous Sites Response Act of 1987, which consists of Section 130A-310 through Section I30A-310.19 of the North Carolina General Statutes ("N.C.G.S."). The real property which is the subject of this Declaration shall hereinafter referred to as the "Site." This Declaration is part of a Remedial Action Plan for the Site that has been approved by the Secretary of the North Carolina Department of Environmental Quality (or its successor in function), or his/her delegate, as authorized by N.C.G.S. Section 130A-310.3(f). The North Carolina Department of Environmental Quality shall hereinafter be referred to as "DEQ." Carolyn Mitchell Benfield as trustee of the Bill J. Benfield Family Trust is the owner in fee simple of the Site, which is located at 171 Glenn Bridge Rd. in the County of Buncombe, Biltmore Township, State of North Carolina, and is the real property legally described in Deed Book 3070, Pages 198-200 in the Office of the Register of Deeds for Buncombe County. The Site is also shown on a Notice of Inactive Hazardous Substance or Waste Disposal Site that is concurrently being recorded with this Declaration at Man BocM'lZ Pagejf^'in the Office of the Register of Deeds for Buncombe County. For the purpose of protecting public health and the environment, Carolyn Bcnfield as Trustee of the Bill J. Benfield Family Trust, hereby declares that all of the Site shall be held, sold and conveyed subject to the following perpetual land use restrictions, which shall run with the land; shall be binding on all parties having any right, title or interest in the Site or any part thereof, their heirs, successors and assigns; and shall, as provided in N.C.G.S. Section 130A- 310.3(f), be enforceable without regard to lack of privity of estate or contract, lack of benefit to particular land, or lack of any property interest in particular land. These restrictions shall continue in perpetuity and cannot be amended or canceled unless and until the Buncombe County Register of Deeds receives and records the written concurrence of the Secretary of DEQ (or its successor in function), or his/her delegate. If any provision of this Declaration is found to Page 1 of 6 9- be unenforceable in any respect, the validity, legality, and enforceability of the remaining provisions shall not in any way be affected or impaired. PERPETUAL LAND USE RESTRICTIONS The Site shall be used exclusively for commercial or industrial purposes, but shall not be used for child care centers, schools, parks, recreational areas, or athletic fields without prior approval from the DEQ or its successor in function. Notification to DEQ or its successor in function is required before making any soil modification more than five (5) feet below the existing grade. Site development or redevelopment for commercial or industrial purposes is allowed subject to the limitation in paragraph 2 of this Declaration. Any surface or underground water shall not be used as a source of potable or irrigation water, or for any other purpose. The installation of groundwater wells or other devices for access to groundwater for any purpose other than monitoring groundwater quality is prohibited without prior approval by DEQ or its successor in function. The Site shall not be used for mining, extraction of coal, oil, gas or any other minerals or non-mineral substances. Mowing of vegetation, tree pruning and other landscaping and maintenance activity is allowed at the Site. In January of each year, each person who owns any portion of the Site shall submit a letter containing that owner’s notarized signature to the Superfiind Section of the Division of Waste Management of DEQ, or its successor in function, confirming that this Declaration is still recorded in the Office of the Buncombe County Register of Deeds and that activities and conditions at the Site remain in compliance with the land use restrictions herein. No person conducting environmental assessment or remediation at the Site, or involved in determining compliance with applicable land use restrictions, at the direction of, or pursuant to a permit or order issued by, DEQ or its successor in function may be denied aceess to the Site for the purpose of conducting such activities. Each person who owns any portion of the Site shall cause the instrument of any sale, lease, grant, or other transfer of any interest in the Site to include a provision expressly requiring the lessee, grantee, or transferee to comply with this Declaration. The failure to include such provision shall not affect the validity or applicability of any land use restriction in this Declaration. Page 2 of 6 10. The owner of any portion of the Site may submit a written request to DEQ or its successor in function for modification of these restrictions, and must at the same time provide written notification to EPA Region 4’s Superfund Division that the owner is requesting DEQ to modify the restrictions. DEQ will concur with and grant such request for modification if DEQ determines, based upon a showing by the owner, that the modification is justified. REPRESENTATIONS AND WARRANTIES The owner of the Site hereby represents and warrants to the other signatories hereto: that the owner of the Site is the sole owner of the Site; that the ov/ner of the Site has the power and authority to enter into this Declaration, to grant the rights and interests herein provided and to carry out all obligations hereunder; that the owner of the Site has provided to DEQ the names of all other persons that own an interest in or hold an encumbrance on the Site and has notified such persons of the owner’s intention to enter into this Declaration; that this Declaration will not materially violate or contravene or constitute a material default under any other agreement, document or instrument to which the owner of the Site is a party or by which the owner of the Site may be bound or affected. ENFORCEMENT The above land use restrictions are an integral part of the remedy for the contamination at the Site. Adherence to the restrictions is necessary to protect public health and the environment. These land use restrictions shall be enforced by any owner, operator, or other party responsible for any part of the Site. The above land use restrictions may also be enforced by DEQ through the remedies provided in N.C.G.S. Chapter 130A, Article 1, Part 2 or by means of a civil action, and may also be enforced by any unit of local government having jurisdiction over any part of the Site. Any attempt to cancel this Declaration without the approval of DEQ or its successor in function shall constitute noncompliance with the Remedial Action Plan approved by DEQ for the Site, and shall be subject to enforcement by DEQ to the full extent of the law. Failure by any party required or authorized to enforce any of the above restrictions shall in no event be deemed a waiver of the right to do so thereafter as to the same violation or as to one occurring prior or subsequent thereto. FUTURE SALES. LEASES. CONVEYANCES AND TRANSFERS When any portion of the Site is sold, leased, conveyed or transferred, pursuant to N.C.G.S. Section 130A-310.8(e) the deed or other instrument of transfer shall contain in the description section, in no smaller type than that used in the body of the deed or instrument, a Page 3 of 6 statement that the real property being sold, leased, conveyed, or transferred has been used as a hazardous substance or waste disposal site and a reference by book and page to the recordation of this Declaration. 2017. OWNER SIGNATURE IN WITNESS WHEREOF, 1 execute these presents on this day of f cb V Signatory's name typed or printed: Carolyn M. Benfield Signature: Title: Trustee of the J. Benfield Family ^^st STATE OF NORTH CAROLINA COUNTY OF BUNCOMBE I _, a Notary Public, do hereby certify that Carolyn M. Benfield personally appeared before me this day, produced proper identification in the form of and signed this Declaration. WITNESS my hand and official seal this day of 2017. My Commission expires: /O ' Pf 9Q [SEAL] X Notary Public JEREMI COMOLLI NOTARY PUBLIC BUNCOMBE COUNTY STATE OF NORTH CAROLINA MY COMMISSION EXPIRES 10-25-2020 Page 4 of 6 APPROVAL AND CERTIFICATION OF THE NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY The foregoing Declaration of Perpetual certified. Use Restrictions is hereby approved and Bateson, KTj., Chief iTperfund Section Division of Waste Management North Carolina Department of Environmental Quality STATE OF NORTH CAROLINA COUNTY OF WAKE ______, a Notary Public, do hereby certify that ___________________ personally appeared before me this day, produced proper identification in the form of and signed this Declaration. 1 WITNESS my hand and official seal this L^^ay of p\ Vi j Civ 2017. / My Commission expires [SEAL] Public V> iin A J)\ ; KELLY B. GALANTIS i Notary Public | , Johnston Coun^ S/ 1I My Commission Expires il ~ I'* Page 5 of 6 <5 REGISTER OF DEEDS CERTIFICATION The foregoing Declaration of Perpetual Land Use Restrictions is certified to be duly recorded at the date and time, and the Book and Page, shown on the first page hereof By; Register of Deeds for Buncombe County (signature) (type or print name and title) Page 6 of 6 ntSOHW.LYAmAflA rrvvYc_K .Oci~l DAY Of s^nnjBUS; OP JAC^COUNTY POWE H6 TH8 T>e LA s?sszxa iln/jun PUBLIC («0(Un)lOQBBlIIIDDOlQlIBBDBlII E .172 ■'150 VICINITY MAP NTSuaeo TO pewoRM rnia •ufwev: ClAU OFBURVm POSmONM. ACCUIWY. Tm Of OPS ON «m PCLD ntOCtDura: JAVAD 0*Ci RM STATE DATClIj Of auBVFOMBWOi; OATUIUMOH HAD.PUflLJ CAHOLTSfliTWEUBeNFrELD V TITLE: TRUSTEE OF THE BILL J.BENFClOF NORTH CARQLBM ■UNCOMK COUWTY /i-Lffcfc'ST Roisv-v THIS tURVET WAS PREPARED WITHOUT A TTTLB TOTAL AREA GRAPHIC SCALE ^85-Oltiyw^ 210,03. lTLlA«rt;iaj«I.THATTKHAAPWAaiWJ|i|imj WACCOMAWCgWTIH U Mecca WmcaaWVKMD WO SEAI. THIS THE MOATtfUM^aiT BW9.NCCA OAra Second Five-Year Review Blue Ridge Plating Site Arden, Buncombe County, NC APPENDIX I 2017 EPA Memorandum Hydrogeology Review G-1 • • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 PRoTt<^ 4SD-SSS 61 Forsyth Street Atlanta, Georgia 30303-3104 June 19,2017 MEMORANDUM SUBJECT: FROM: THROUGH: TO: Five Year Review, Blue Ridge Plating Site, Arden, North Carolina William N. O'Steen, Physical Scientist Scientific Support Section, Superfund Division Glenn Adams, Chief Scientific Support Section, Superfund Division Jon Bornholm, Remedial Project Manager Superfund Restoration and Site Evaluation Branch This memorandum responds to your request for a review of the draft Second Five Year Review Report, Blue Ridge Plating Site, Arden, North Carolina. The document is referred to herein as “the FYR.” For your convenience, comments on the FYR are itemized and are referenced to specific sections or pages of the FYR, as applicable. A summary of comment 5 (detailed independent review of groundwater data) is at the end of this memorandum. If you have any questions about this memorandum or need additional technical assistance on this project, please contact me. 1. In the list of acronyms, PCB needs to indicate the correct organic compound. 2. On page 3, text states “Because a municipal water supply is available, the use of groundwater at the Site for potable purposes is minimal.” This statement implies there is some use of groundwater in the area for drinking water. If this is a correct interpretation of the wording, a statement needs to be added regarding where such groundwater use is present in relation to the Site and groundwater contamination associated with the Site. If no such local groundwater use is present or if it may be present but the locations of private wells are not known, that information needs to be stated in the FYR. 3. The Table 1 designation of concentrations at the bottom needs corrections. Micrograms per milligram would be correct, although a sort of standard mode of expression is milligrams per kilogram (which is consistent with Record of Decision Table 17). 4. I concur with the recommendation and commentary regarding MNA in the first paragraph answer to Question A (FYR Section V., page 16). See my detailed comment 5 below for my independent review of Site groundwater monitoring data. 5. I have some observations regarding the groundwater monitoring data, the J.M. -2- WallerA^ersar groundwater concentration trend analysis, and the assessment of monitored natural attenuation (MNA) as a potentially viable groundwater remedial alternative. The following tabulation presents some observations reg^ding the FYR Table 3-3 summary of Mann-Kendall statistical calculations (focus on the stable, no trend, and increasing trend elements of Table 3-3 only) and the monitoring data contained in FYR Table 3-1. Note that in previous comments to you on Site annual data evaluation reports (comment memos from June 2014 and November 2012), some of the earlier monitoring results from the MNA groundwater monitoring program (implemented in September 2007) may be representative of changes in groundwater quality primarily due to the Site soil remedial action and other activities, rather than due to natural attenuation processes. Often, during a soil remedial action involving removal, there can be a short-term, notable increase in groundwater concentrations during or at some period following the remedial action. This condition has been observed at multiple other Superfimd sites in EPA Region 4 and appears to be the case for some of the results from the Blue Ridge Plating Site (see Table 1 below). The additional emergency response action that occurred from December 2014 to May 2015 is another potentially confounding factor in interpreting the groundwater monitoring results, although it would only potentially be reflected in the most recent (July 2015 and June 2016) monitoring results. Table 1. Observations/Comments on FYR Table 3-3 Constituents with No Trend, Stable, or Increasing Concentration Designations Monitoring Well Contaminant Designation Observation/conunent MWOID 1,1 -dichloroethane No trend Concentrations « ROD cleanup goal and < NC 2L standard MWOID 1,1-dichloroethene No trend Some possible effects of soil remedial action during the MNA evaluation monitoring period MWOID Chloroform Stable Concentrations generally slightly above the 0.19 ug/L ROD cleanup goal, but well below NC 2L standard MWOID T etrachloroethene No trmd Some possible effects of soil remedial action during the MNA evaluation monitoring period MWOlS Naphthalene No trend As many nondetects as detects during the MNA monitoring period; 2010-2012 concentration increases consistent with a delayed reaction to the soil remedial action MWOlS Pentachlorophenol No trend As many nondetects as detects during the MNA monitoring period; MNA evaluation period concentration data consistent with significant influences from the soil remedial action MW03S Cadmium Stable January 2009 spike in the concentration may be a delayed effect of the soil remedial action MW03S Iron No trend MW04S Iron Increasing Possible short-term improvement due to soil remedial action followed by a concentration rebound to approximate pre-remediation condition MW04S Manganese Stable Table 1 is continued on the next page -3 - Table 1, continued Monitoring WeU Contaminant Designation Observation/comment MW05S Cadmium Stable Possible gradual, long-term decrease in concentration not yet confirmable through statistical testing MW05S Iron No trend Concentrations < ROD Cleanup goal MW06D 1,1 -dichloroethane No trend Concentrations « ROD cleanup goal and < NC 2L standard MW06D 1,1-dichloroethene No trend 2009-2013 concentration increases possibly consistent with a delayed reaction to the soil remedial action; average MNA evaluation period concentration < MCL and NC 2L standard MW06D T etrachloroethene Stable 2009-2012 concentration increases possibly consistent with a delayed reaction to the soil remedial action MW06S T etrachloroethene No trend 2015-2016 concentration increases possibly due to 2014-2015 emergency response action MW06S Trichloroethene Stable 2015-2016 concentration increases possibly due to 2014-2015 emergency response action MW07S Manganese No trend Possible 2009-2013 short-term improvement due to soil remedial action followed by a concentration rebound to approximate pre-remediation condition; September 2007 concentration spike may be an initial effect of the soil remedial action MW08S Iron No trend June 2008 concentration spike may be an initial effect of the soil remedial action; all other MNA evaluation monitoring results < ROD cleanup goal MW09S T etrachloroethene Stable MWllS 1,1-dichloroethane Stable No obvious effects from soil remedial action. Concentrations are < ROD cleanup goal but > NC 2L standard. MWllS 1,1-dichloroethene Stable Possible gradual, long-term decrease in concentration not yet confirmable through statistical testing MWllS Chloroform Increasing Concentrations > ROD cleanup goal and « NC 2L standard MWllS Tetrachloroethene Stable No obvious effects from soil remedial action. MWllS Trichloroethene No trend No obvious effects from soil remedial action. MW12D 1,1-dichloroethane Increasing Concentrations « ROD cleanup goal and < NC 2L standard MW12D T etrachloroethene Probably Increasing No pre-remedial data MW12D Trichloroethene Stable No pre-remedial data MW12S Cadmium Stable 2008-2010 concentration increases possibly consistent with a delayed reaction to the soil remedial action; 2015-2016 concentration increases possibly due to 2014-2015 emergency response action -4- MW12S Chloroform Stable Concentrations generally slightly above 0.19 ug/L ROD cleanup goal, but well below NC 2L standard Table 1 is continued on the next page Table 1, continued Monitoring WeU Contaminant Designation Observation/comment MW12S Manganese Stable 2009-2010 concentration increases possibly consistent with a delayed reaction to the soil remedial action; 2015-2016 concentration increases possibly due to 2014-2015 emergency response action MW12S Trichloroethene No trend 2008-2009 concentration increases possibly consistent with a delayed reaction to the soil remedial action; 2015-2016 concentration increases possibly due to 2014-2015 emergency response action MW-13D 1,1-dichloroethane Increasing Concentrations « ROD cleanup goal and < NC 2L standard MW-13D Chloroform Stable Concentrations generally slightly above 0.19 ug/L ROD cleanup goal, but well below NC 2L standard MW-13D T etrachloroethene Increasing MW-13D Trichloroethene Increasing MW13S Manganese No trend Concentrations generally < ROD cleanup goal but > NC 2L standard MW13S T etrachloroethene Stable Concentrations generally < ROD cleanup goal and NC 2L standard MW13S Trichloroethene No trend Concentrations generally < ROD cleanup goal and NC 2L standard MW14D T etrachloroethene Stable Concentrations generally about 2 to 3x above 0.7 ug/L ROD cleanup goal and NC 2L standard MW15D Chloroform Stable Concentrations generally < ROD cleanup goal and « NC 2L standard MW15D T etrachloroethene Increasing MW15S .T etrachloroethene No trend 2015 concentration increase possibly due to 2014- 2015 emergency response action MW15S Trichloroethene No trend 2015 concentration increase possibly due to 2014- 2015 emergency response action MW16D 1,1 -dichloroethane No trend Concentrations « ROD cleanup goal and generally > NC 2L standard MW16D 1,1-dichloroethene Stable Concentrations > ROD cleanup goal and NC 2L standard MW16D Chloroform Stable Concentrations > ROD cleanup goal and < NC 2L standard Table 1 is continued on the next page -5- Table 1, continued Monitoring WeU MW16D MW16D MW17S MW17S MW17S MW17S MW17D MW18D MW20D MW20D MW20D MW20D Contaminant Tetrachloroethene Trichloroethene 1,1-dichloroethane 1,1-dichloroethene T etrachloroethene Trichloroethene Tetrachloroethene Manganese 1,1-dichloroethane 1,1-dichloroethene T etrachloroethene Trichloroethene Designation No trend No trend No trend No trend No trend No trend No trend Stable No trend No trend No trend No trend Observation/comment Concentrations > ROD cleanup goal and NC 2L standard Concentrations > ROD cleanup goal and NC 2L standard Possible concentration decrease due to soil remedial action; only four samples_______ Possible concentration decrease due to soil remedial action; only four samples Possible concentration decrease due to soil remedial action; only four samples_______ Possible concentration decrease due to soil remedial action; only four samples; three most recent sample concentrations < ROD cleanup goal and NC 2L standard Concentrations > ROD cleanup goal and NC 2L standard; only four samples Concentrations < ROD cleanup goal and > NC 2L standard Concentrations « ROD cleanup goal and generally < NC 2L standard; only four samples Possible concentration increase; only four samples Possible concentration increase; concentrations > ROD cleanup goal and NC 2L standard; only four samples Possible concentration increase; concentrations > ROD cleanup goal and NC 2L standard; only four samples Table 1 shows that many of the Site monitoring wells have one or more contaminants that are showing no definable concentration changes in response to the remedial action. A few constituents are apparently increasing at a few of the wells. At some of the wells where concentrations are either stable (or no trend) or increasing, other constituents are decreasing in concentration. Based on Table 1 and the ongoing statistical trend analyses of Site groundwater monitoring data, there is no current basis for concluding that monitored natural attenuation is a viable groundwater remedial action for the Blue Ridge Plating Site. MWlOS is the only well where groundwater concentrations of potential concern are showing only a decreasing trend. A few other wells with long-term records (records that include data preceding the remedial action) are mostly showing decreasing concentrations of constituents of concern. These wells are MWOlS, MW06S, MW07S, and MW08S. All wells showing mostly positive indications of concentration decreases are shallow -6- monitoring wells located within about 100 feet of the former plating facility. These are the wells that one would expect to most likely show the effects of the 2006-2007 soil remedial action. Of these four wells plus MWlOS, three wells (MW06S, MW08S and MWlOS) have historically monitored groundwater with the most significant levels of overall contamination. Some of the key time-concentration trends in samples from these wells are evaluated in this review. MW6S had pre-remedial concentrations of several chlorinated compounds, plus cadmium, cyanide, and manganese that exceeded ROD cleanup goals. In the post-remediation environment, all of these contaminants appear to be decreasing, with the possible exception of PCE. The inorganic constituents have decreased to less than ROD cleanup goals and are not discussed further. 1,1,1 -trichloroethane has also decreased to below its ROD cleanup goal and is not discussed further. Although chloroform remains above its ROD cleanup goal of 0.19 ug/L, it has decreased to less than 1 ug/L and is a relatively inconsequential contaminant in terms of its concentration. The chlorinated compounds that are considered further for this well are 1,1-dichloroethane, 1,1-dichloroethene, PCE, and TCE. Figure 1 below shows time-concentration plots for the MW6S chlorinated compounds. The four compounds show increasing concentrations late in the monitoring history for MW6S. I interpret these increasing concentrations to the influence of the 2014-2015 emergency response action. This upward concentration pattern may be transient but adds a complicating factor to the assessment of natural attenuation for MW6S. Also, the first few samples from the MNA evaluation period show concentration patterns and decreases that I interpret as reflecting mostly the lingering effects of the 2006-2007 remedial action, not MNA. This early post-remediation influence on the time-concentration data is suggested by the fluctuating concentrations (most notable for 1,1-dichloroethane) and the steep decline in concentrations that are present from the third to fourth or fifth sample events. The fluctuating concentrations are suggestive of a disequilibrium condition. Such a condition is often the result of a change in Site hydrogeologic and chemical conditions associated with soil excavation and removal. Data that may reflect natural attenuation of groundwater contamination monitored by MW6S are likely in the 2010 to 2014 monitoring interval. These data do not show significant attenuation of the chlorinated compound concentrations. MW8S had pre-remedial concentrations of several chlorinated compounds that exceeded ROD cleanup goals. The remedial action appears to have actually caused brief increases in contaminant concentrations (Figure 2 below). This phenomenon has been observed at other Superfund sites in EPA Region 4 where soil removal has occurred. The rise in concentrations apparently occurs due to increased groundwater recharge through contaminated areas as they are being excavated or otherwise disturbed. The increased recharge is likely accompanied by increased mass transfer of contaminants to the dissolved phase due to disruption of soil structures (e.g. clay lenses) that may have been chemical or hydraulic “traps” for soil contaminants. These disruptions to the Site hydrology and hydrostratigraphy briefly accelerate the mass flux of contaminants into and through the groundwater. -7- The MW8S inorganic constituent with a “no trend” designation is iron. However, the last eight MW8S samples have had iron below the ROD cleanup goal and the iron data are not discussed further. Other inorganic constiments of potential concern have apparently decreased to less than ROD cleanup goals and are also not discussed further. Although chloroform may remain above its ROD cleanup goal of 0.19 ug/L, the five most recent MW8S samples have had chloroform below its cleanup goal. Chloroform is therefore not considered further. The chlorinated compounds that are considered further for this well are 1,1 -dichloroethane, 1,1 -dichloroethene, PCE, and TCE. Figure 2 shows time-concentration plots for the evaluated MW8S chlorinated compounds. As previously noted, the chlorinated compounds show an increase in concentration just after the completion of the remedial action that I interpret to be a response to changing Site conditions during the remedial action. There are some notable concentration fluctuations for the first several samples after the short-term increase in concentrations. This fluctuation period is followed by a relatively flat time-concentration trend from 2013 onward. The fluctuation period is a probable condition where groundwater is in a lingering state of disequilibrium around MW8S until about four to five years after the completion of the remedial action. Only the last four years of MW8S data may represent the natural attenuation component of groundwater quality changes at MW8S. However, the 2014-2015 emergency response action superimposed another disturbance on the Site conditions. This second source area disturbance may be reflected in the slight uptick in concentrations in July 2015 relative to the August 2014 sample. Although the nonparametric Mann-Kendall trend analysis indicates an improvement in MW8S groundwater quality for the MNA evaluation period, the results would be misleading with regard to indicating natural attenuation is effectively reducing contaminant concentrations. The positive aspect to the MW8S data is that the most recent sample results show relatively low concentrations. Therefore, if future monitoring results indicate natural attenuation is a potentially effective remediation process, there is not a tremendously high degree of contamination present around this well. MWlOS had pre-remedial concentrations of several chlorinated compounds and manganese that exceeded ROD cleanup goals. In the post-remediation environment, all of these contaminants appear to be decreasing. Manganese has apparently decreased to less than its 300 ug/L ROD cleanup goal as of August 2014, has continued to decrease in concentration since then, and is therefore not discussed further. 1,1,1-trichloroethane has decreased to below its ROD cleanup goal and is not discussed further. As for MW6S and MW8S, the chlorinated compoimds that are considered further for this well are 1,1- dichloroethane, 1,1-dichloroethene, PCE, and TCE. Figure 3a below shows time-concentration plots for the MWlOS chlorinated compounds. The four compounds (particularly 1,1-dichloroethene and PCE) show large concentration declines for the first five monitoring periods following the remedial action. The large concentration decreases are interpreted as being indicative of the effects of the remedial action on groimdwater monitored by this well, not a result of natural attenuation. The January 2010 to February 2011 concentration decline may reflect a period of transition from a predominantly remedial action-influenced downward concentration trend to a concentration trend dominated by natural attenuation effects. From the 2011 sample -8- onward to perhaps the July 2015 sample, groundwater concentrations are interpreted as reflecting natural attenuation effects. The 2016 sample may show a delayed response to the 2014-2015 emergency response action, with some increase in concentrations for all four contaminants. Because there is a three order of magnitude variation in contaminant concentrations shown on Figure 3a, concentration changes are not clear during the period interpreted to represent the period of natural attenuation effects. Figure 3b below shows the MWlOS concentrations for just the period from February 2011 until June 2016. Figure 3b shows that during the period interpreted to be representative of mostly or entirely natural attenuation influence on concentrations, concentrations of contaminants were declining. Between the August 2014 and the July 2015 samples, the emergency response action occurred. After that event, chlorinated compound concentrations in MWlOS samples began to increase, with the June 2016 sample having clearly higher concentrations of contaminants. Particularly noteworthy is Ae large increase in the 2016 PCE concentration compared to the 2015 concentration. The June 2016 PCE at MWlOS is the highest PCE observed at this well since a sample from 2009. I interpret the 2016 MWlOS results to represent a delayed effect of the 2014-2015 emergency response action. The 2015 and 2016 data points introduce a confounding aspect to what appears to be declining MWlOS concentration trends that are presumptively attributable to natural attenuation. Further monitoring will be necessary to understand the ability of natural attenuation to attain ROD goals for groundwater monitored by MWlOS. For this well, the data from the 2011 to 2014 monitoring period are promising. 6. You should check with the EPA risk assessor as well as the ORC lawyer assigned to this Site regarding FYR-proposed modifications to the groundwater cleanup goals for some of the metals. It is my understanding that state criteria that are not based upon a risk to human health are not applied to Superfund remedial action goals. Also, there may be some question as to whether or not EPA currently considers as ARARs the North Carolina 2L standards. There are a number of constituents identified in FYR Table 9 where the current cleanup goal does not match a NC 2L value. The FYR review recommends the cleanup goals be changed to the NC 2L value. Additions to the list of contaminants with cleanup goals are also recommended in the FYR (see Table 10 and Section VI. Issue 1 on FYR page 18). Also refer to Appendix E, the ARAR review part of the FYR. 7. Ideally, the Appendix B site chronology would include the date when the remedial action was completed. As noted at the beginning of this memorandum, this closing statement is a summary of the groundwater data review contained in comment 5. The Site groundwater monitoring results from the MNA evaluation period do not support selection of MNA as a groundwater remedial alternative at this time. Results only appear to be promising for MNA from one shallow monitoring well located adjacent to the former facility, in the area of the 2006-2007 soil remedial action. Elsewhere, decreasing contaminant concentrations observed during the MNA evaluation period appear to mostly be reflective of concentration changes in response to the soil remedial action. -9- The time needed before MNA can be evaluated as a remedial alternative will be variable. For deeper wells or wells further from the source area remedial action, it may be a decade or longer before MNA can be assessed as a remedial alternative. cc: Glenn Adams, Chief, SSS (electronic copy) - 10- Figure 1. MW06S Time-Concentration Plots (Concentrations in ug/L) 10/10/200C 2/22/2008 7/6/2009 11/18/2010 4/1/2012 8/14/2013 12/27/2014 5/10/2016 9/22/2017 Figure 2. MW08S Time-Concentration Plots (Concentrations in ug/L) 1/14/2004 5/28/2005 10/10/2006 2/22/2008 7/6/2009 11/18/2010 4/1/2012 8/14/2013 12/27/2014 5/10/2016 9/22/2017 -0-M-<iid>loR>ctha>M -O-14-ctkhloroethcna -O-PCE C TCE -11 - Figure 3a. MWlOS Time-Concentration Plots (Concentrations in ug/L) 10/10/2006 2/22/2008 7/6/2009 11/18/2010 4/1/2012 8/14/2013 12/27/2014 5/10/2016 9/22/2017 Figure 3b. MWlOS Time-Concentration Plots (Concentrations in ug/L] 11/18/2010 7/26/2011 4/1/2012 12/7/2012 8/14/2013 4/21/2014 12/27/2014 9/3/2015 5/10/2016 1/15/2017 9/22/2017 -4^ lyl'ctichtoroethane -O-1,1‘dichloroethene -^PCE TCE