20045_Powers Site_Phase 1P3of3_20150821

9.
·::_2::_:
FINDINGS
As the inspectors arrived on-site for the inspection of the
facility, they were greeted by David Mcquirt, President of
Dynatech. Mr. Mcquirt explained that the operations were
presently being moved and very little operations were being
conducted. Since the offices had already been moved, no
records were present on-site. Mr . Mcquirt explained the
records were at another location. The inspectors proceeded
to inspect the facility after Mr. Mcquirt's brief synopsus
of the facility's status. ·
The rework operations of the facility were located in a
large one room warehouse with the electroplating operations
located in a small connected room. The facility's
electroplating process consisted of four static plating
baths and manual hand spray rinses. Machinery parts are
dipped into the chrome baths and then sprayed off with
water. The rinse waters fall to the curbed floor and are
collected in a sump of approximate size of 4'x4'x3'. The
collected rinse waters are pump out and returned to the
plating baths to replace water removed due to evaporation.
During the inspection an unlabeled, open container was
noticed to contain a sludge in two of its three approximate
2'x3'x4' bins. Mr. Mcquirt stated the sludge was from
accumulation within the sump over the past two years and had
been removed for the first time roughly four weeks prior to
this inspection. The sludge was judge by the inspectors to
be a F006 hazardous waste. The sump, although accumulating
F006, can not be considered a hazardous waste tank since it
is part of the designed process by collecting rinsewaters to
return to the baths. On the otherhand, if the unit has a
crack in the cement discovered during closure of the
facility, allowing the land disposal of wastes, the unit i _s
a disposal unit and land disposal restrictions have been
violated.
Dynatech was managing one satellite drum located on a pad
outside of the plating shop next to the air scrubber. A dry
air scrubber is used to pull vapors emitted from the plating
baths outdoors. The drum contained sludge generated by the
filter of the scrubber. The accumulated waste is D007. The
drum was not labeled.
Located within the warehouse portion of the facility were
nine drums of caustic wastewaters. The caustics had been
removed from a caustic cleaning tank used to remove dirt and
oils from machinery parts. The facility personnel were
-4-
10. CONCLUSIONS
After inspection and review of Dynatech, the following
deficiencies were noted.
262.11 -General Facility Standards -the facility failed to
make a hazardous waste determination on the nine drums of
wastewaters within the building, the two drums of apparent
acidic plating solution and the F006 sludge.
262.34(c)(1)(ii) -General Facility Standards-the
accumulation drum containing D007 waste located next to the
scrubber was not marked with the words "Hazardous Waste" or
with other words that identify the contents of the
container.
262.40(a) -General Facility Standards -the generator
failed to keep copies of each signed manifest for at least
three years from the date the waste was accepted by the
initial transporter .
262.40(b) -General Facility Standards -the generator
failed to keep a copy of the annual report for a period of
at least three years from the due date of the report.
268.50(a) (1) -General Facility Standards-the facility
storing F006 hazardous waste subject to Part 268
requirements failed to comply with the requirements of
262.34 as follows:
2q2.34(a) (1) in reference to 265.173(a) -the container
holding the F006 waste was not closed.
262.34(a)(1) in reference to 265.174-the owner or
operator did not inspect where the container was
stored.
262.34(a)(2) -the date upon which each period of
accumulation begins was not clearly marked and visible
for inspection on the container.
262.34(a)(3) -the container was not marked with the
words "Hazardous Waste."
262.34(a)(4) .in reference to Subpart D of 265-the
facility failed to maintain a copy of the contingency
plan at the facility (265.53(a)).
262.34(a)(4) in reference to 265.16(d),(e) -the
facility failed to maintain personnel training records.
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Ref. 5
MEMO
Date: 04/26/93
To:
From:
File
Douglas Moore [J~W:> /Vl.~
Environmental Chemist
NC Superfund
Topic: Historical Information
Dynatech Industries, Inc .
NCD 981 014 517
On Monday, April 26,1993, I spoke with Jeff Mills , Customer
Service, Engineering Department, Charlotte Mecklenburg Utilities
Department ( 1-704-399-2222) regarding water service records for
2213 Toomey Avenue. "Eastern Transit Storage" applied for a water
service connection (S-79070) in 1963. No other records could be
located for "McKittrick Textile Machinery".
Next, I spoke with Laurie Collins, Information Specialist with
the Secretary of State's Office for business information (733-
4 2 01) . The following information is listed with the Secretary of
State:
( 1)
(2)
Frank G.W. McKittrick Company
723 Law Building
Charlotte, NC
A Massachusetts Corporation
Authorized to do business in NC: September 6,1961
Business priveledges suspended: April 21,1989
Reason for suspension: failure to file with the
Department of Revenue. The company also failed to file an
Annual Report with the Secretary of State 's Office for
1991-i992. As a result, they will be dissolved in
September 1993, meaning their "Certificate of Authority"
to do business in NC will be revoked .
The registered agent for the company resigned on
June 29,1984 .
Eastern Transit Storage
changed their name to "Sunbow Industries, Inc." on
June 25,1976.
Status:
History:
Currently active
North Carolina Corporation
Incorporated on May 5,1947
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MEMO
Date:
To:
From:
Subject:
3/2/93
File
Douglas Moore ~Jc~~'f~')-flAtt1r-<..
Environmental Chemist '-
NC Superfund Section
Detailed Historical and Process
Dynatech Industries, Inc, 2213
Charlotte, NC. from 1985-1990.
Dynatech Industries, Inc.
NCO 981 014 517
Ref. 6
Information on
Toomey Avenue,
On Monday, March 1,1993, I spoke with Myron McGuirt (1-704-
358-8848), former owner/operator of the Dynatech facility located
at 2213 Toomey Avenue. We discussed specific details of the hard
chrome plating process employed at Dynatech between 1985-1990.
According to Mr McGuirt:
(1) The Building was 17 years old when he purchased it in
1985. This would place the date of construction in 1968. In 1985,
an extension was built on the back of the building that housed the
chrome plating area.
(2) The waste oil tank contained waste lubricating oil from
the lathe and grinding operations of the facility. The tank held
roughly 400 gallons, which was removed by James Oil Company of
Charlotte every 3-4 months. He estimates the volume per shipment at
around 100 gallons.
(3) Following chrome plating and rinse, plated shafts were
dipped into a 55 gallon drum of phosphoric acid as a rust
inhibitor. The process was used for 6-7 months until it was
replaced by a "M&T" acid plating solution which contained rust
inhibitor in solution. Phosphoric acid solutions were replenished
and waste was neutralized before disposal to the municipal sewer
via a drain located in the front part of the building.
(4) A caustic soda tank was located to the right hand side
of the production area facing northwest from the chrome plating
area. The tank held 400 gallons which was replenished every 9-10
months. Waste caustic was neutralized prior to disposal to the
municipal sewer via a floor drain located in the front part of the
building.
(5) The subsurface chrome pit located in the center of the
chrome room held a large 1000 gallon Steel tank with Koroseal
lining. The dimensions of the tank were 2.5 feet wide by 8 feet
long by 4 feet deep. There were three more plating tanks that held
approximately 500-600 gallons each. The dimensions of the smaller
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tanks were 2.5 feet wide by 8 feet long by 3 feet deep. During the
process, 25-50 gallons of water was lost daily due to heat
evaporation. The evaporated water was reclaimed by a scrubber
located on the south wall of the chrome plating area. A concrete
pad located outside next to the scrubber housed a 55 gallon drum
used to collect the reclaimed waste water. The floors of the
plating area were washed down once a week into a sump pit which was
used to replenish the volume of the tank by pumping waste water
from the sump pit back into the tank. A "Baume" Hydrometer was used
to determine the amount of water in solution. Excess water in the
solution was corrected by addition of sulphuric Acid and chrome
flakes. He estimates the volume of the sump pit to contain about
100-200 gallons.
(6) Mr.McGuirt was unable to provide a explanation of the
etched concrete pad located in the far Northeastern corner of the
chrome plating area. He suggested that it may be chromic acid lost
from the plating tanks.
( 7) Replenishment of the chromic acid solution was not common
at Dynatech. However, he did state that the only time chromic acid
plating solutions would be replaced is if they had a high iron con-
tent.
(8) The large elevated Stainless steel tank located behind
the rectifier was a cooling tank filled with water which was used
to cool the rectifier.
(9) Mr.McGuirt did not know the details of the
decommissioning of the septic tank.
(10) Production began at the Toomey Avenue site in JunejJuly
of 1985.
dmjd2prod
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• '' u:•••·--II lf-.._,j,p~ I •.,._ ,./ • -:/. -. . . ........._ ...... r Y./ ~-\'.
Ref. 7
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State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
Ref. 8
James B. Hunt, Jr., Governor
Division of Solid Waste Management
Telephone [phone] Jonathan B. H owes, Secretary
February 24, 1993
Mr. Doug Lair, Chief
Emergency Response and Removal Branch
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Subj: Dynatech Site (NCD981014517)
Charlotte, Mecklenburg County, NC
Dear Mr. Lair:
The NC Superfund Section recently conducted an on-1:3ite reconnaissance of the
subject site for the preliminary assessment. It was noted that the site is no
longer secure and there is evidence of routine human trespass at the site.
Attached, please find a memorandum summarizing the current site co nditions. The
NC Superfund Section requests that the u.s. EPA use this new information to
reevaluate the Dynatech Site as to its status for future site work. There is a
considerable amount of waste on site i.n rolloff containers as well as unexcavated
soils which appear to be contaminated . Furthermore, there is an open pit full
of potentially contaminated water inside the plant building. Therefore, the
State requests that the site at least be resecured. We note, however, that i t
is likely the site will continue to have security problems and that an
expeditious disposal of the waste on site may thus be warranted.
Please notify Pat DeRosa two weeks or more prior to any removal activities
that may take place at this s i te. It is imperative to the HRS scoring process
that we plan and conduct the site inspection before waste is removed. If you
have any questions concerning this site, please contact Doug Moore or me at
[phone].
Sincerely,
~h~/Z/
bin/let/dynatech
attachment
cc: Mike Kelly, NC DSWM
Pat DeRosa, NC Superfund
;~poug':;Moore, NC Superfund Yred 'stroud, u.s. EPA
Craig Benedikt, U.S. EPA
Jack Butler, PE
Environmental Engineering Supervisor
Superfund Section
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] Fax # [phone]
An Equal Opportuniry Affirmative Action Emplover
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To:
From:
Subject:
Pat DeRosa
Supervisor
NC Superfund
Doug Moore !Ju~/1-o ~vf.~ •
Environmental Chemist
NC Superfund
02/23/93
Dynatech Industries Site, NCD981014517. PA Follow-up
report on site conditions.
On Monday February 22,1993, Bob Gandley, Grover Nicholson and
I inspected the former Dynatech Industries facility located at 2213
Toomey Avenue, Charlotte, Mecklenburg County, N.c. A perimeter
survey of the site indicated that the site was not secure. The
security fencing erected around the site during the prior EPA
site removal had been breached in several locations. Also, a door
located in the middle of the Southwestern wall of the building was
open allowing direct entry into the main building where the
hazardous waste drums were located.
I have attached a copy of the site map indicating the
locations where the site had been breached. The main gate located
next to the office area was damaged leaying a large hole between
the doors of the gate. At the corner of the gate next to the
parking area, the chain -link fence was intact yet bent and the
barbed wire on top was damaged from people climbing over the fence.
The door in the middle of the southwestern wall of the
building was open and there were footprints in the wet insulation
that was lying on the floor. Inside the room was a red 55 gallon
drum wh i ch had been Used to prop open the door to the production
area. The production area houses the drums of hazardous wastes
generated during the earlier remediation work plus overpacks
and drums generated by the EPA action. There were at least two
uncapped open drums in the production area marked "hazardous waste''
which contained contaminated soil.
The chain link fence located at the far Southern corner of the
building had been pulled away from the wall and rolled back
several feet. There was a distinct trail leading through the fence
to the back of the building near the chrome plating area. The pit
in the chrome plating area was filled up to the level of the
concrete pad with liquid. Pools of liquid on the unexcavated
concrete pad s howed visual evidence of Chromium contamination
(distinct yellow coloration)
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Based upon the inspection, I suggest we advise EPA Emergency
Response that the site is no longer secure and request it be
resecured until the waste onsi te can be removed. To secure the
site, the fencing needs to be repaired and the door needs to be
locked. As you are aware, it is also important that Emergency
Response notify us prior to the removal of drums and non-drum
containers from the site for HRS scoring purposes. Please advise as
to the next actions to take. If you have any questions, please let
me know.
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Charlotte, Mecklenburg County, North Carolina. On March 4, 1992
the responding OSC Fred Stroud verified the presence of a
overflowing vat located outside the building. The OSC also
observed several overturned and leaking drums in the building.
Two thirty-yard "lockboxes" containing contaminated soil had
spilled their contents onto the parking lot.
This spill provided a pathway whereby surface runoff could carry
the contaminants into the nearby creek. Stained areas near the
back of the building indicated possible soil contamination. The
North Carolina Department of Environment, Health and Natural
Resources NC (DEHNR), Superfund Section completed a Preliminary
Site Assessment (PA) in May 1993. NC (DEHNR) found that the site
was no longer secure and that there was evidence of human
intrusion. The security fence was breached in several locations,
and a door in the middle of the building had been propped open
with a 55 gallon drum. Inside the building, footprints in the
wet insulation further indicated trespassers. The production
area houses the drums and overpacks of unknown waste that were
generated during an earlier site stabilization. There are two
open drums in the production area that were marked "hazardous
waste" during the initial response that contain contaminated
soil. A pit in the chrome plating area is full of potentially
contaminated water. Pools of liquid on the unexcavated concrete
pad in the plating area show visual evidence of possible chromium
contamination.
Dynatech attempted to perform RCRA closure procedures in July
1990, but inadequate finances caused them to abandon the facility
prior to completion. In addition to the vats and drums, there
are extensive areas of soil contamination and two "lockbox"
containers of soil and debris left behind by Dynatech.
A. Site Description
1. Removal Site Evaluation
Refer to the previous Action Memorandum dated August 1,1992.
2. Physical Location
The Dynatech Industries Site occupied 5.5 acres located at 2213
Toomey Avenue in a residential area of Charlotte, Mecklenburg
County, North Carolina. The nearest resident is 125 feet to the
southwest. The nearest school is Wilmore School, located 0.45
miles to the northwest of the site. There are 744 households
within 0.5 miles of the site. The total population within a 4
mile radius of the site is 123,766. There is a 1.42 acre wetland
located on Irwin Creek approximately 0.9 miles from the Dynatech
site.
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3. Site Characteristics
The site was formerly a chrome plating facility. The facility's
primary business consisted of hard chrome plating of industrial
parts and camshafts from large scale industrial air compressors.
Parts were milled to size using a lathe or machine grinder.
These parts were then degreased by dipping them into a 400 gallon
above ground tank of caustic soda (sodium hydroxide). Other
chemicals used in the process were Varsol, Stoddard solvent,
Paraffins, Naphthenes, Alkylbenzenes and trace amounts of
benzene. There were four rectangular plating tanks located in
the plating area; three above ground tanks in the 400-500 gallon
range and one large stainless steel underground tank that held
approximately 1000 gallons. The drums generated during the
removal action are still in the warehouse. There is a large open
pit left from the removal of a plating tank. There is still a
considerable amount of contaminated soil in "lockboxes", as well
as significant volume of unexcavated soils that should be
addressed. On August 17, 1992 it was suspected that vagrants
using the office and production area building for shelter set
fire to the front office of the facility. The extent of soil and
groundwater contamination is unknown at this time. The extent of
the contamination will be determined concurrent with the removal
of containerized waste.
4. Release or threatened release into the environment of a
hazardous substance, or pollutant or contaminant
Section 300.415 (b) (2) (i): "Actual or potential exposure to
nearby human populations, animals, or the food chain from
hazardous substances or pollutants or contaminants."
The site continues to present a imminent and substantial
endangerment to the public. Hazardous substances stored in
drums, overpacks, tanks and "lockboxes" are located on site.
This provides a source for potential exposure to the compounds
and hazardous constituents contained within. There is an open
pit full of potentially contaminated water in the chrome plating
area as well as several open drums inside the production
building.
A suspicious fire was set in the front office portion of the
production area. The perimeter site fencing has been breached in
several locations indicating trespassers. Homeless people and
local residents are most at risk to exposure to chemicals present
at the site.
Section 300.415 (b) (2) (iii)): "High levels of
Hazardous substances or pollutants or contaminants in
drums, barrels, tanks, or other bulk storage
containers, that may pose a threat or release."
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There are an estimated 50 drums and overpacks staged in the
warehouse. The contents in some of the drums and overpacks are
plating solutions and liquids pumped from caustic tanks on site.
Two "lockboxes" with an estimated 96 cubic yards of contaminated
soil are staged in the parking lot. There is an open pit of
potentially contaminated water in the chrome plating area, as
well as unexcavated soil that appears to be contaminated.
Previous analytical data indicated that soil samples taken from
the excavated pit area showed hexavalent chromium contamination
at 3500 and 6700 ppm. A single water sample was analyzed which
exhibited hexavalent chromium contamination at 80 ppm.
Section 300.425 (b) (2) (v): "High levels of hazardous
substances or pollutants or contaminants in soils
largely at the surface, that may migrate."
Contaminated soil can be carried off-site by surface runoff and
windblown dust and particulate mater. Although there is no
current analytical data, previous samples were taken in the
intermittent stream that serves as the main surface drainage for
the site showed 500 ppb of chromium downgradient and less than 50
ppb of Chromium upgradient. Subsequent sampling indicated 90 ppb
of chromium downgradient with 50 ppb chromium upgradient. A berm
at the southeast corner of the property intercepts site runoff
upgradient of the site and diverts it around the plating area
that flows over exposed soil for approximently 30 feet to the
center of an asphalt parking lot. Beyond the parking lot, a
vegetated ditch diverts runoff to the stream.
Section 300.415 (b) (2) (v): "Weather conditions that may
cause hazardous substances or pollutants or contaminants to
migrate or be released."
Normal rain fall in the area would be sufficient to carry
contaminated media off site.
SECTION 300.415 (B) (2) (viii) "Availability of other
appropriate federal or state response mechanisms to respond
to a release."
The Mecklenburg County Haz-Mat team participated in the initial
response. They are also monitoring the site on a periodic bases
for security reasons. It is not expected they will be involved
in any further removal activities. It is not expected that any
state or local entity will initiate and maintain any removal
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activity at this time. It is also not expected that any previous
owner/operator will initiate any removal action.
5. NPL STATUS
The Dynatech Industries site is not listed on the National
Priorities List (NPL). The North Carolina Department of
Environmental , Health, and Resources Division of Solid Waste
Management Super fund section performed a preliminary Assessment
in May, 1993. The site received a score of 35 and was
recommended for a site investigation. The site has not been
evaluated by the Agency for Toxic substances and Disease Registry
(ATSDR) for health risk concerns. It is unlikely that this site
would be proposed for listing on the NPL following the completion
of this removal.
6. Maps,pictures and other graphic representations
Available upon request.
B. Other actions to date
1. Previous actions
On March 4, 1992, an emergency response was initiated to
eliminate and stabilize the ongoing release at the site. The
response was initiated under the OSC's delegated $50,000 response
authority. All identifiable leaking containers were stabilized
as an interim measure until disposal options could be arranged.
A RCRA closure was attempted in July, 1990 by Dynatech but
inadequate finances caused them to abandon the facility before
completion. On February 22, 1993 The NC Superfund Section
conducted a Site Inspection for the Preliminary Assessment. It
was documented that the site is no longer secure and poses a
threat to the public. A letter of findings was sent to the ERRB.
2. Current Actions
Efforts will be made to contact any previous owners/operators of
the facility. The proper state and local officials will also be
contacted prior to any site activities. There are no governmental
or private clean-up efforts occurring on-site at this time.
C. State and Local Authorities' Role
1. State and local actions to Date
On February 22, 1993 the State of North Carolina Department of
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Environmental, Health, and Natural Resources, NC (DEHNR)
Superfund Section conducted an on-site inspection site for the
preliminary assessment. On February 24, 1993 the North Carolina
NC (DEHNR) sent a memo summarizing the current site conditions to
the Emergency Response and Removal Branch in Region IV. The
Preliminary Assessment (PA) was completed in May 1993 by the
North Carolina Superfund Section.
2. Potential for continued State/Local response
The Charlotte Haz-Mat Team will continue to monitor the site for
security reasons. The State will conduct a site inspection pr1or
to removal action for the HRS scoring process. It is not
expected that any state or local entity will initiate and
maintain any removal activities at this time.
III. Threats to the public Health or Welfare or the Environment
And Statutory And Regulatory Authorities
A. Threats to the Public Health or Welfare
Any trespasser on-site could be exposed to high levels of
hexavalent chromium liquid and contaminated soil. Hexavalent
chromium routes of entry when exposed are inhalation, ingestion,
eyes and skin. The chemical has a direct corrosive effect on the
skin and mucous membranes of the upper respiratory tract.
Evidence found by the North Carolina Site Assessment indicates
the security fencing erected around the site during the prior EPA
site removal has been breached in several locations. A door
located on the south-western wall of the building is open
allowing direct access into the main building where the hazardous
waste drums are stored.
There are distinct foot prints leading through the breached fence
areas and a trail leading through the fence to the back of the
building near the chrome plating area. The pit in the chrome
plating area has filled with water and can potentially overflow
to the concrete pad. The pad area shows visible evidence of
possible chromium contamination.
B. Threats to the Environment
Surface water drainage from the plating area flows over exposed
soil for approximately 30 feet to the center of an asphalt
parking lot. Beyond the parking lot, a vegetated ditch diverts
the runoff to the stream. The surface runoff that is not
intercepted by the ditch drains into a flat plain heavily
vegetated with grass, weeds and shrubs. No security fencing
surrounds the plain and ditch. The tributary encircles the
perimeter of the plain and ditch.
The nearest resident to the plain is less than 200 feet away.
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IV. ENDANGERMENT DETERMINATION
Actual or threatened releases of the hazardous substances from
this site, if not addressed by implementing the removal action
selected in this Action Memorandum, may present an imminent and
substantial endangerment to the public health, or welfare, or the
environment.
V. EXEMPTION FROM STATUTORY LIMITS
The presence of the hazardous substances at the site continue to
present an imminent endangerment to the public health and
welfare. Continued response actions are required to mitigate the
ongoing releases and threats of releases. These threats can be
mitigated only by completion of the removal action which has been
initiated. Conditions at the site fully meet the emergency
criteria for an exemption to the 12-month statutory limit given
under sections 104(c) of CERCLA.
A. Emergency Exemption
1. There is an immediate risk to public health or
the welfare or the environment.
Conditions at the site continue to present a immediate
endangerment to the public and environment. There are numerous
drums and overpacks of unknown substances in the production area
left after prior stabilization efforts. These drums are not
secure and are accessable to trespassers.
There is an open pit in the chrome plating area full of
contaminated water. Previous data from a water sample taken in
the sump area indicated 80 ppm hexavalent chromium. The
unexcavated concrete pad area showed potential hexavalent
chromium contamination. There are "lockbox" containers of
contaminated soil staged on the outside of the building. A
recent site inspection indicates the perimeter site fencing has
been breached in several locations. Trespassers in these areas
will be directly exposed to hexavalent chromium liquid.
2. Continued response actions are immediately required to
prevent, limit, or mitigate an emergency
There are approximently 50 drums of unknown substances, overpacks
and containers of corrosive liquids. There is approximently 96
cubic yards contaminated soil left on site from the initial
response action. A pit in the chrome plating area is full of
potentially contaminated water. Evidence from a recent site
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visit confirmed the intrusion of trespassers in the warehouse
where the drums are stored and the area of the chrome plating
operation. Contaminated soil must be removed to eliminate risk of
direct contact exposure to anyone trespassing on site.
3. Assistance will not otherwise be provided on a timely
basis
Neither the state or local government have the resources or
equipment to properly address the site. It is not expected that
any state or local government will initiate and maintain any
removal activities at this time or in the foreseeable future.
VI. PROPOSED ACTIONS AND ESTIMATED COSTS
A. PROPOSED ACTIONS
1. Proposed action description
EPA's Proposed actions at the site can be divided into phases:
a. Treat and dispose the accumulated wastewater in the pit
located in the processing building.
b. Treat and or dispose of any liquids stored in drums,
vats and tanks.
c. Sample soil, and containers to determine the extent of
contamination.
d. Arrange for disposal of all wastestrearns.
e. Excavate the contaminated soil and sediment and arrange
for treatment and or disposal.
2. Contribution to remedial performance
Based Qn the information available at this time, the proposed
removal activity will abate the immediate threats identified in
this document. If further remedial actions are necessary due to
the presence of unknown contamination, then the proposed action
will remove the source of any ground water contamination and aid
in the long term clean up goals.
3. Description of alternative technologies
Because the final disposition of the waste materials at the site
has not been determined, no formal evaluation of alternative
technologies has been made. Such an evaluation will take place
as we enter the disposal phase of the response action and will be
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9
documented at that time.
4. Applicable or Relevant and appropriate requirements
(ARARS)
The Resource Conservation and Recovery Act (RCRA) is expected to
be an ARAR for this removal. However this will not be definite
until the waste is better characterized. If RCRA regulations on
the treatment, transportation, and disposal of hazardous waste
are ARARs efforts will be made to comply with them if
practicable.
5. Projected Schedule
Continued actions at the site will be initiated upon approval of
this Action Memorandum. Foregoing any unexpected delays, all
actions are expected to be completed within one year of
mobilization.
B. ESTIMATED COST Current Ceiling Increase Total
Extramural Costs
Regional Allowance cost
ERCS $ 20,000 $ 250,000 $270,000
Non-Regional
Allowance Cost
TAT $ 5,000 $ 45,000 $ 50,000
Subtotal $ 25,000 $ 275,000 $300,000
15% contingency $ -0-$ 50,000 $ 50,000
Total Extramural
Costs $ 325,000 $350,000
Intermural Costs
Direct
(500 hrs at $30.00) $ 3,500 $ 15,000 $ 18,500
Indirect
(500 hrs at $54.00) $ 1,500 $ 27,200 $ 28,500
Total Intermural
Cost $ 5,000 $ 42,000 $ 47,000
Total Site Budget $ 30,000 $ 367,000 $397,000
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VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED
OR NOT TAKEN.
If action is significantly delayed or not taken there will continue
to be a release into the environment increasing the possibility of
exposure to the public.
VIII. OUTSTANDING POLICY ISSUES
None
IX. Enforcement
See attachment "Enforcement Sensitive"
X. RECOMMENDATIONS
This decision document represents the selected removal action for
the Dynatech Industries Site, located in Charlotte, North
Carolina. It was developed in accordance with CERCLA as amended,
and is not inconsistent with the NCP. This decision was based on
the administrative record for the site.
Conditions at the site meet NCP Section 300.415 (b) (2) criteria
for removal action. Therefore I recommend your approval of the
proposed removal action, and the CERCLA section 104 (c)
requirements for exemption from the 12 month limitation. Upon
approval the projected ceiling for the removal activity will
increase from $30,000 to $397,000 an increase of $367,000. The
ERCS ceiling will thereby be increased by $250,000 from the
current $20,000 to $270,000.
CC: Bill Meyer, Director
NC Solid Waste Mgmt. Div.
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ENFORCEMENT ADDENDUM
Site: Dynatech Industries
A. PRP Search:
Enforcement Sensitive
Sept. 21,1993
Initial site investigations by the Technical Assistance Team
indicated that Mr. Myron David McGurit was the president of the
chrome plating facility.
B. Notification of PRPs of Potential Liability and of the
Required Removal Action:
A Notice of Liability will be issued to Mr. Myron David McGurit.
c. Negotiation and Order Issuance Strategy:
Mr. Myron David McGurit, as owner/operator of the chrome plating
operation, is the only PRP whose liability is well documented.
Based on the fact that Mr. McGurit has few assets, it is unlikely
that Mr. McGurit is capable of conducting a removal at the site.
It is not known at this time if additional PRPs will be issued
Notification of Liability. The proposed strategy is to identify
and determine the quantity of contaminants on site.
Simultaneously, additional information on potential PRPs will be
gathered. This will allow for identification of any PRPs not
known at this time. It will also allow for the possibility of
PRPs being involved in the disposal phase of the project.
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Memo
Date: March 11, 1994
To: File
From: Douglas Moore Ar ~ ~
Environmental Chemist
NC Superfund Section
Topic: Site Inspection Reconnaissance Trip Report.
Dynatech Industries, Inc.
2213 Toomey Avenue
Charlotte, Mecklenburg County, NC
US EPA ID: NCD 981 014 517
Ref. 10
On Wednesday, March 9, 1994, Harry Zinn and Doug Moore of the NC Superfund
Section visited the Dynatech Industries, Inc. site to meet with EPA Region IV Emergency
Response and Removal Branch (ERRB) On-Scene Coordinator Bill Joyner. Since
September 1993, the ERRB has been coordinating and conducting a emergency removal
action at the site. The emergency removal action was in response to a request by the NC
Superfund Section to remove hazardous materials and waste from the site.
We departed Raleigh at 0845 and arrived at the site at 1145. At 1200 hrs, we met with
Bill Joyner and Jarrell Wootan, Environmental Specialist with Mecklenburg County
Environmental Protection Division.
At 1210, Bill Joyner escorted Harry Zinn, Jarrell Wootan and Doug Moore on a tour of
the site. The main sources on the site except the septic tank area are surrounded by chain
link fence. During our tour, no visible evidence of liners, run on prevention, run-off
collection or leachate collection systems were observed at any of the sources on the site.
We visited the sump area first. The sump area (aka chrome plating area) is surrounded by
a small aluminum building. Inside the building, the actual pit had been backfilled with
clay. Mr. Joyner stated that during the removal, several rounds of samples were taken at
the sump. He stated that part of their emergency removal consisted on pumping the water
from the sump pit and testing for contamination. Mr. Joyner stated that groundwater was
observed at 9 feet below the sump in February 1994. EPA's Agency for Toxic Substances
and Disease Registry (ATSDR) had no defined action levels for chromium in water. The
most recent samples indicated that the soils contained in the sump were below the
ATSDR defined levels for an emergency removal (300 mg/kg -total chromium). As a
result, EPA decided to backfill the sump area with clean soil. He said that 9 truckloads of
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clean soil at 15 cubic yards each were transferred to the sump pit, or approximately 135
cubic yards.
At 1215, we proceeded to the scrubber area. One sample taken from the scrubber area (S-
05) detected chromium in the soils at 105 mg/kg, below the ATSDR defined limit of 300
mg/kg. The scrubber area was graded to direct overland drainage around the sump area
building and reseeded with grass. The breach in the fence along the back of the building
was fixed by ERRB at this time.
At 1220, we looked inside the main building. The floor of the main building is covered
with debris from the prior process. There is one large fiberglass tank containing
rainwater. There is a large quantity of small cylindrical green fiberglass tanks scattered
around the inside of the building, as well as pieces of heavy machinery. Mr. Joyner stated
that EPA removed a total of 62 drums from inside the main building: 34 of the drums
contained waste chromic acid, 4 contained waste hydrochloric/chromic acid and 24
contained waste caustic solution. The door at the back of the main building was repaired
and locked from the inside to prevent trespassing into the interior of the building.
At 1225, we inspected the cargo containers and parking lot overland drainage. Mr.
Joyner stated that the cargo containers contained chrome stained debris from the prior
remedial action at the site. The debris consisted of chrome contaminated soil, concrete
from the floor, metal duct work and concrete blocks from the splash wall. The materials
were categorized, manifested and disposed to the "Wayne Disposal Facility" in Belleville,
Michigan. Following removal of the materials, the cargo containers were decontaminated
and powerwashed. He estimates that between 100 -110 cubic yards of debris were stored
and removed from the cargo containers.
Mr. Joyner stated that some soil lying in a low spot in the parking lot near the drainage
ditch was sampled and found to have chromium contamination above the ATSDR
defined limits. He stated that EPA removed approximately 15 cubic yards of
contaminated soil from the low spot. The soil was manifested and shipped to the
EnvoTech/Wayne Disposal Facility in Belleville, Michigan. During the SI Recon, a
yellowish stained residual soil was observed in the low spot in the parking lot. Likewise,
yellowish stained soil was observed in the vicinity of the cargo containers.
We departed the site at 1230 for lunch and arrived back at the site at 1330.
At 1330, we met with Jim Ringwall, Specialist with the Roy Weston Technical
Assistance Team (TAT) to discuss the analytical results from samples collected by TAT
during the removal action. A copy of the site map identifying the sample identification
numbers and locations was provided along with a summary table identifying the sample
dates and analytical results. All the samples were collected by TAT. Mr. Ringwall stated
that the parking lot was used as a staging area for drums during the removal. Following
the removal, the parking lot was powerwashed by EPA using water. Additional
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information was gathered from Mr. Ringwall about the samples collected by TAT. A
bl . . 1 d db 1 f h dd' . 1 . £ t summary ta e 1s me u e e owo t e a 1t10na m orma 10n.
ID Number Sample Description Analyzed for: Analyzed by:
W-01 Water pumped from the sump pit on I Analytikem Labs
January 1994
W-02 Composite of water pumped from the V, S, I, P AquaChem Labs of
sump pit and residual water in the pit. Charlotte
Sump-01 composite of soil from under the rim of I Pace Laboratories
the pit.
Sump-02 grab sample of soil at sump pit (4-6 feet I Analytikem Labs
deep)
Sump-03 Five point composite at sump pit (4 feet I AquaChem Labs of
deep) Charlotte.
Sump-04 Three point composite at sump pit (4 feet I AquaChem Labs of
deep) Charlotte.
S-Ol Soil in low spot on parking lot I Pace Laboratories
S-02 Composite sample along drainage path I Pace Laboratories
over parking lot near cargo containers
(0-12 inches deep)
S-03/S-04 Five point composite samples taken from I AquaChem Labs of
grassy area adjacent to parking lot (0-12 Charlotte.
inches deep)
S-05 Composite sample from fume scrubber I AquaChem Labs of
area (0-12 inches deep) Charlotte.
Sed-01 Four point composite sample along I Pace Laboratories
drainage ditch (0-6 inches deep)
Sed-02 Grab sample on opposite side of Toomey I Analytikem Labs
A venue (0-6 inches deep)
Mr. Ringwall stated that there were approximately 70 empty drums contained inside the
main building. These drums were powerwashed, triple rinsed, crushed and shipped
offsite as non-hazardous waste. Mr. Ringwall departed the site at 1430.
Mr. Joyner stated that the septic tank remains in place at the site. Attempts were made to
locate the septic tank during the removal, however, the tank could not be identified.
Thus, no samples were taken by TAT of the septic tank area. The septic tank area is
located approximately 40 feet southwest of the southwest wall of the main building. The
area is not surrounded by any fencing. Heavy vegetation covers the septic tank area,
howeve, there. are trails leading through the brush. The approximate location appears to
have regular human use, as there were numerous food wrappers and bottles scattered over
the area. He also stated that TAT did not sample the E. Fesperman property located at
2315 Toomey Avenue.
Between 1450-1545, Harry Zinn and Doug Moore tracked the path of the intermittent
tributary from behind the site downstream to the site PPE in Irwin Creek. A playground
with swing sets and basketball court was noted along the intermittent tributary near 1-77.
A copy of the Surface Drainage map for the site is attached.
At 1550, we departed the site for Raleigh.
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Memo
Date: September 8, 1994
To: File
From: Douglas Moore ~ f.>.lA..A..~
Environmental Chemist
NC Superfund Section
Topic: Source Calculations
Dynatech Industries, Inc.
2213 Toomey Avenue
Charlotte, Mecklenburg County, NC
US EPA ID: NCD 981 014 517
Ref. 11
Using the CMUD Sewer Map (Figure 3 -Scale 1" = 200 feet) and a standard ruler, the
dimensions of the chrome plating area were determined to be 30 feet wide by 50 feet
long. Based upon groundwater samples taken by Delta Environmental in 1990 (Ref. 7, p.
10-12), the depth of contamination was established at 10 feet. The total volume of
contamination is 30' x 50' x 10' or 15,000 cubic feet. Divide 15,000 by 27 (cubic feet per
cubic yard) gives 555.6 cubic yards. Considering that approximately 100 cubic yards
were removed to a RCRA approved landfill, the total estimated remaining volume equals
555.6-100, or 455.6 cubic yards.
Soils in a low spot in the parking lot were found to exhibit elevated chromium levels.
The dimensions of the low spot are approximately 15 feet by 15 feet, or 225 square feet.
Elevated chromium levels were found in soils at an identified seep area near the
southwestern corner of the main building. The seep reportedly originated from a
malfunctioning septic tank. The seepage surfaced and drained along the edge of the
property line to Toomey A venue. The dimensions of the drainage from the seep to
Toomey A venue is approximately 10 feet wide by 50 feet long, or 500 square feet.
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Memo
Date: May 20, 1994
To: File
From: Douglas Moore ~ ~~
Environmental Chemist
NC Superfund Section
Topic: Site Inspection Sampling Trip Report
Dynatech Industries, Inc.
2213 Toomey Avenue
Charlotte, Mecklenburg County, NC
US EPA ID: NCD 981 014 517
Ref. 12
On Wednesday, May 18, 1994, two sampling teams departed Raleigh for Charlotte, NC to
sample soils, sediments and surface water at the subject site. Team #1 consisted of Doug
Rumford and Doug Moore. Team #2 consisted of Harry Zinn and Bob Gandley. Team
#1 arrived at the site at 1110 and inspected the west corner of the main building. Several
days prior to our arrival, Tony Roux of the Mecklenburg County Environmental
Protection Division went to the site and marked the location of the former seep from the
septic tank area with blue and white striped surveyors flags. In 1985, Mr. Roux
responded to citizen complaints regarding a discharge that smelled like "chemicals"
originating at the site and draining down Toomey Avenue. After confirming the presence
of the seep markers, Team #1 departed the site for Fire Station #2 (FS #2) to pick up the
keys for the main gate.
Team #2 arrived at Constitution Park on West Boulevard at 1100. Team #2 surveyed the
Irwin Creek drainage for the appropriate sampling locations. At 1130, Team #2 sampled
surface water and sediments at a point approximately 30 feet downstream of the
confluence of the intermittent tributary and Irwin Creek. The confluence is marked by a
boxed culvert which runs under Interstate 77 and drains to Irwin Creek. This sample was
labeled "DI-SW-11" and "DI-SD-11" for surface water and sediments, respectively.
To make a long story short, between 1120 and 1315, Team #1 discovered that the keys
located at FS #2 and marked "2213 Toomey Avenue" did not work on the padlocks at the
main gate. A discarded padlock was found at the gate which had been broken with a pair
of bolt cutters. Surprisingly, the key from FS #2 worked in this padlock. Attempts were
made to contact the EPA OSC, but, to no avail. Finally, at 1250, we received permission
from Pat DeRosa, CERCLA Branch Head, to borrow a master key from FS #2 and cut the
padlocks at the main gate.
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At 1205-1210, Team #2 sampled surface water and sediments from a point in Irwin Creek
located approximately 445 feet upstream of the site PPE. This point was approximately
90 feet downstream from a 16 inch sewer main and vent pipe. The sample location was
chosen to address any possible overflow from the vent pipe that may have impacted Irwin
Creek. The surface water sample was labeled "DI-SW-10" and the sediment sample was
labeled "DI-SD-10".
At 1255, Team #2 sampled soil from a separate branch of the intermittent tributary near
Wilmore Drive, approximately 200 feet upgradient of the confluence with the main
intermittent tributary and 45 feet downgradient of Wilmore Drive. The soil sample was
labeled "DI-SL-08".
At 1310, Team #2 sampled soil from a point on the main intermittent tributary,
approximately 55 feet upgradient of the confluence with the separate branch of the
intermittent tributary and 300 feet downgradient of Toomey A venue. The soil sample
was labeled "DI-SL-09".
At 1315, Teams #1 and #2 departed the site for lunch. We arrived back at the site at
1430.
At 1430, Team #1 cut the padlocks from the main gate to gain access to the site.
At 1505. Team #2 collected a soil sample from the adjacent Fesperman property at 2315
Toomey A venue. The sample was collected at 2 inches below the surface, 60 feet
northeast of Mr. Fespermans driveway and approximately 5 feet from the southeastern
side of Toomey Avenue. The sample was labeled "DI-SL-07".
At 1510, Team #1 collected a subsurface soil sample in an area of stained soil adjacent to
the cargo containers. The soil underneath the broken asphalt cover had several inches of
gravel. At 4 inches, a red clay was encountered. The sample was collected from the red
clay at a depth of 6 inches. HNu readings of the subsurface soil indicated no readings
above background. The soil sample was labeled "DI-SL-02".
At 1535, Team #2 collected a soil sample from the low spot in the parking lot. Soil had
accumulated in this area from overland drainage. The sample was a dark-gray silt with a
brown coating. The silt covered an area approximately 15 feet wide by 15 feet long. The
surface soil sample from the low spot was labeled "DI-SL-03".
At 1550, Team #1 collected a composite sample of the drainage ditch . The soil sample
consisted of a three point composite collected at 6-8 inches in depth. All sample holes
were tested with the HNu in the breathing zone, 1 foot above the hole and in the hole. No
readings above background were encountered. The composite sample was labeled "DI-
SL-04".
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At 1610, the utility locator arrived at the site. The gas and telephone lines were marked
on the site to avoid damaging the lines while collecting any subsurface samples. We were
particularly concerned at the southwest side of the main building where the septic tank
was located, since most of the utilities (gas, electric, etc .. ) for the main building were
located on this wall.
At 1610, Team #2 sampled soil from the intermittent tributary on the east side of the site,
approximately 5 feet below the confluence with the drainage ditch from the parking lot.
The drainage ditch serves to divert surface runoff from the site to the intermittent
tributary. The sample was labeled "DI-SL-04".
At 1650, Team #1 sampled the intended background soil from a vacant undisturbed lot,
approximately 100 yards southwest of the site. The sample was collected at 1-2 inches
below the surface. The sample point is approximately 100 feet east of the Fesperman
house (2315 Toomey Avenue) and approximately 300 feet southwest of the south corner
of the main building. The background soil sample was labeled "DI-SL-01".
At 1715, Team #1 sampled soil from an identified seep area approximately 12 feet from
the west corner of the main building. The sample point was identified by Tony Roux of
Mecklenburg County Environmental Protection Division (EPD) as the point where septic
tank effluent was surfacing. In 1985, the seep was the cause of citizen complaints of a
discharge that smelled like "chemicals" draining along the side of Toomey Avenue.
During this time, Mr. Roux investigated the complaints and visually identified the seep as
the origin. Mr. Roux stated that the seep was caused by a malfunctioning septic tank. on
the site property. The sample was taken at a depth of 6 inches. No HNu readings were
detected above background. The sample was labeled "DI-SL-06". While investigating
the septic tank area, it was noted that a former compressor room shed along the
southwest wall of the main building was occupied by a mattress and personal belongings.
This suggests regular human use of the septic tank area.
Between 1630 and 1715, Team #2 drove to a nearby hardware store and purchased two
padlocks to resecure the site. These padlocks were used to lock the main gate and copies
of the padlock keys were given to employees at Fire Station #2. A copy of the padlock
keys were retained by the NC Superfund Section.
At 1745, Teams #1 and #2 departed the site for Raleigh. We arrived at Raleigh at 2205
following two stops for gas and food. Additional ice was purchased and placed in the
coolers to maintain the temperature overnight. All the samples were locked in the sample
coolers in the State Vans overnight.
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DYNATQ INDUSTRIES,
NCO 981 01~ 517
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Collectively, the uppermost layer is the regolith, which is composed of
saprolite, alluvium, and soil (Daniel and Sharpless, 1983). The regolith
zone consists of an unconsolidated or semiconsolidated mixture of clay and
fragmental material ranging in grain size from silt to boulders.
Saprolite is the clay-rich, residual material derived from in-place
weathering of bedrock. Saprolite deposits represent leached deposits and,
being granular material with principal openings between grabens, differ
significantly in texture and chemical composition from the parent rock which
is unweathered, crystalline rock having principal openings along fractures .
Since saprolite is the product of in-place weathering of the parent bedrock ,
some of the textural features of that bedrock are retained within the
saprolite. Evidence of r elic quartz veins, dikes, and shear zones are
commonly seen in outcrops. Alluvial deposits are unconsolidated sediments
deposited by streams and rivers. Soil is referred to as the natural medium
for the growth of plants. Saprolite is the dominant deposit in this
unconsolidated zone, with soil deposits generally restricted to the
uppermost layer, and alluvium deposits restricted to locations of current
and former stream channels and river beds.
The transition zone is where unconsolidated material grades ~nto
bedrock and consists of saprolite and partially weathered bedrock. Here,
particle size ranges from silts and clays to large boulders of unweathered
bedrock. The thickness of this zone depends a great deal on the texture and
composition of the parent rock. The best defined transitional zones are
usually associated with highly foliated metamorphic parent rock, while those
of massive igneous rocks are often poorly defined or nonexistent (C.C.
Daniel, III, U.S. Geological Survey, oral commun., 1985). In the Piedmont,
90 percent of the records for cased bedrock wells show combined thicknesses
of 97 feet or less for the regolith and transition zones (Daniel, 1987).
The uppermost part of the Piedmont crystall i ne bedrock contains
numerous closely spaced fractures which can be related to the local and
regional tectonic history of the area . As a general rule, very few
fractures occur in the Piedmont bedrock at depths greater than 400 feet
(LeGrand, 1967).
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HYDROGEOLOGIC FRAMEWORK AND CONCEPTUAL MODEL OF THE FLCJW SYSTEM
Heath's (1984) concept of the ground-water system for the Piedmont and
Blue Ridge provinces has been adopted as the conceptual model for this study
with slight modifications to emphasize the transition zone between the
regolith zone and the bedrock.
The fundamental structure of the ground-water system is shown in
figure 2. The components of the system are:
1. The unsaturated zone in the regolith, which generally
_contains the organic layers of the surface soil;
2 . The saturated zone in the regolith;
3 . The transition zone between the regolith and bedrock; and
4. The fractured crystalline bedrock system.
Regolith Unsaturated Zone
The unsaturated zone extends from the land surface down to the water
table, which is the top of the saturated zone. The pore spaces of the
regolith in the unsaturated zone contain both air and water. The
unsaturated zone usually ranges from 5 to 50 feet in thickness. Daniel
(1987) found a mean depth to the water table of 31.3 feet in an examination
of 2,326 Piedmont wells. Water moves down from the land surface through the
soil zone by intergranular flow through the larger pore spaces and passages
left by burrows or decayed roots . Roots from surface vegetation can grow to
30 feet below land surface but more commonly spread laterally near the
surface. At the base of the soil zone, which is generally 3 to 8 feet
thick, th~ average grain size abruptly decreases with a corresponding
decrease in pore size as the water enters· the saprolite (C. C. Daniel, III,
U.S. Geological Survey, written commun., 1985). At this point water
movement may also be diverted somewhat by relic structures of foliation or
folds in the saprolite, which are remnants from the parent rock.
The total porosity of soil is commonly around 55 percent, and its
specific yield is about 40 percent (Heath, 1983). Saprolite has a total
porosity of 35 to 50 per cent near land surface (fig. 3), which decr eases a t
depth, and a specific yield of 20 percent (Daniel and Sharpless, 1983).
12
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Heath indicates that few fractures below 300 to 4 00 feet f rom land
surface contain substantial amounts of water, and that those which do bear
water at depth are probably associated with faults . However, Cressler and
others (1983) found that for the Atlanta, Georgia, area, nearly horizontal
stress-relief fractures at depths of 400 feet or more were often associated
with high-yielding wells. When surface material is removed by erosion,
nearly horizontal stress-relief fractures develop and widen in response to
the reduction in compressiona l stress. Daniel also reports high-yielding
wells at depths over 500 feet in the North Carolina Piedmont (Daniel, 1987).
Fractures are planar features oriented along zones of lithologic and
structural weakness. Water can move along the fractures with relative ease
to discharge points such as wells or to natural discharge areas in stream
valleys. Non-horizontal fractures may account for dramatically asymmetrical
patterns of water-level decline that may be seen around a pumped well or the
more rapid movement of water and contaminants in one direction than in
another, creating aniostrophy in the bedrock aquifer. The hydrologic
conductivity of the fractured bedrock is generally 0.001 to 3 feet per day
(Heath, 1984). The primary porosity of the bedrock ranges from about 0.01
to 2 percent (Heath, 1984).
In general, the mineral a s semblages determine the degree to which water
will dissolve aquifer material . For example, quartz is resistant to
chemical weathering and will dissolve much more slowly than less resistant
ferromagnesium minerals such as biotite and hornblende and numerous iron
minerals such as pyrite and magnetite. Generally, the mafic igneous rocks
such as diorite-gabbro contain more ferromagnesium minerals and are more
susceptible to chemical solution than the minerals of felsic rocks such as
granite. Weathering of the ferromagnesium minerals produce solution
openings and channels in the mafic rock units.
Ground water from a typical granite, composed largely of sodium and
potassium feldspars, should have relatively high concentrations of sodium
bicarbonate . Calcium and magnesium bicarbonate concentrations can be high
in ground water moving through mafic rocks, such as gabbro, which is
composed largely of calcium feldspars and ferromagnesium minerals. Ground
water from certain metavolcanic and mica-schist units contain high
concentrations of iron (Hem, 1970). However, these simple relationships are
complicated if there is mixing of waters from adjacent rock types of
different compositions or if the host rock is intermediate in composition.
21
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EXPLANATION
~ General direction of Q<"OUnd-water movement
Sh-t joints
T ectonlc joints
Water table
Ground-water
dlacharo• area
Figure 11.--Generalized ground-water flow system in the Piedmont
(from Heath, 1980) .
although with subdued relief. Thus, surface topography can be used to
predict the natural direction of ground-water flow. The distance between
the point where a drop of water or waste enters the system and the point
where it discharges into the stream down slope is commonly less than a half
mile (LeGrand, 1958). Most of the natural flow in the system is probably
confined to the upper 30 feet of bedrock, wnere fractures are concentrated,
and the overlying transition zone, which apparently has the highest
hydraulic conductivity of any part of the hydrogeologic system (C.C. Daniel,
III, U.S. Geological Survey, written commun., 1985). However, flow probably
also occurs in the deeper fractured system in a manner harder to predict by
local surface topography. In the deeper system, regional topography or
structural features may result in flow over long distances and long ground-
water residence times in the fractured rock.
The ground-water flow system in the Piedmont is directly connected to
the surface-water system. The annual contribution of ground water to total
streamflow for 11 streams flowing through the Piedmont is estimated to
average 44 percent (Harned and Daniel, 1987). Consequently, it is a concern
that ground-water contamination will eventually discharge to streams that
are water-supply sources.
23
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GROUND WATER ASSESSMENT PlAN
21'if7 HAWKINS STREET
CHARLOTTE, NORTI-I CAROLINA
DELTA PROJECf NO. 50-91-024
This report was prepared by:
Delta Environmental Consultants, Inc.
6701 Cannel Road, Suite 200
Charlotte, North Carolina 28226--3901
August 1992
Ref. 15
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CONI' AMINATION ASSESSMENT
21tr/ Hawkins Street
Charlotte, North Carolina
Delta No. 50-91-024.02
Page 6
3.4 Hydraulic Conductivity Estimates
Falling head and residual drawdown (recovery) tests were previously conducted by C.T. Main for the
determination of hydraulic conductivity.
"Two methods were chosen in order to provide a means of verification. Well 10 was pumped at a
rapid rate to achieve the maximum drawdown in the shortest period of time and recovery of water
into the well was monitored following the pumping period. Falling head slug tests were conducted
on piewmeters (wells) PZ-1 and PZ-2 by pouring distilled water into each piewmeter and rapidly
bringing the water level up several feet" (C.T. Main 1989).
C.T. Main (1989) concluded that:
"The hydraulic conductivity calculated for well 10 ranged from 0.25 (1.87 gpd/ft2) to 0.28 ft/d (2.09
gpd/ft2); for PZ-1, from 0.08 (.59 gpd/ft2) to 0.1 (.748 gpd/ft 2) ft/d; and for PZ-2, from 0.21 (1.57
gpd/ft2) to 0.22 (1.6 gpd/ft2) ft/d . The geometric mean of the aquifer testing results is 0.17 ft/d and
is considered the best estimate and typical value for the study area."
35 Estimated Ground Water Flow Velocity
Ground water flow velocity was calculated for the unconsolidated porous saturated wne above competent
bedrock in order to estimate the rate of horizontal ground water movement beneath the site. The mean
hydraulic conductivity value of .17 ft/day was determined as discussed above. The hydraulic gradient
measured across the site is estimated to be .03 ft/ft. The saturated wne above bedrock at the site is
composed of an unconsolidated porous material and was assumed to have an effective porosity of 20 percent.
Using the above estimated parameters, the average advective flow velocity was calculated to be
approximately .026 ft/day or 9.30 ft/year. This estimate should be viewed as an approximation which is
limited to the site specific hydraulic and physical parameters which may be influenced by numerous factors .
Actual transport rates may vary even more due to anisotropy of the aquifer, as well as solubility, attenuation,
dispersion, and diffusion of the contaminant.
3.6 Ground Water Contamination
The existence of ground water containing chromium at the Hawkins Street facility was documented by C.T.
main as early as February, 1986. Ground water sample analyses perfonned since the inception of assessment
activities are summarized in Table 1. No significant temporal trends in ground water contaminant
I ·
Ref. 17
HAZARDOUS WASTE SECTION
GROUNDWATER QUALITY MONITORING PLAN
AND
SAMPLING AND ANALYSIS PLAN
.',SOUTH __ BOULEV.Ag)?~PROPERTIES,;~;:1INC.•
--CHARLOTTE, -.NORTH CAROLINA
Prepared for:
South Boulevard Properties, Inc.
(Formerly known as Parks-Cramer Company)
2000 South Boulevard
Charlotte, North Carolina
Prepared by:
AWARE Environmental, Inc.
Charlotte, North Carolina
AEI Job No. N105-01
July 1989
Revision I -March 26, 1990
l r ,. '
Table 3.1
SGUTH 30UL~VARD PROPERTIES
CHARLOTTE, NORTH CAROLINA
XONI TGRIN6 ~ELL CO~STRUCTIOH OAT~
~Ei..L I. D. TOP GF Ct1Si:;G WELL SC~E~N SCRc~N SLOT CAS i NGJ SCRE:?i
ELct/ATiati IFTl DE?TH \Fiil IlHC:RVAL iFTl t S!IE (IN)
IIW-l 103.00 ~6.00 25,i)-35.0 0.01 t, 11\H n.to 30-:'00 20.0-30.0 0.01
l'IW-3 87.00 30.·)0 20.')-30.0 0.01
l'llH aa.ia 47.~0 3o.0-46.o 0.01
t IIW-5 94.36 46.00 :o.')-~6.0 0.01
11\H 94.40 ::.so .,.., r -... r 0.01 ~.;.. . .;-.,)",..;
l'IW-7 96.H 37.~0 :~.o-~~.0 0.01
t 11:4-3 94.oa o1.oo 5?. ·)-j9. ·J 0.01
11\1-:1 9~.11 !O .'J. GO 8i.0-10t.O 0.01
11:4-lO 9oJ.ji) o:.oo ~~.0-59.0 0.01
~~~hi 96.:2 106.00 94.0-tG~.o O.Ot • M~-!2 ?., IC' 83. 5•) 70.~-S0.5 0.01 ' .... •.;
l'IW-:A 9b.o2 100.50 37.0-97.0 0.01 J"-1" 91.93 99.60 :s.o-~a.o 0.01
;I
•
To~ of cc;;;.ing =levat~ons tla~:d on s'.te bench&c.rk r:fer~nc::·:l to 100.00 f:et.
t 3elo~ ground ;;.uriac: •
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?~C -PolyYinylchloride
SS -St~inl~ss Steel
11
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i'IATc~IAL
... sc:;. ~0 PVC i. .,. SCH. 40 ?IIC i. .,. sc:-t 40 PVC .. .,. SCH. 40 ?'v'C .. .,. SCH • 40 PVC .. .,. sc:; . 40 PVC ... .,. sc:-t. 40 p·.;c i. ..,. S\::i . 40 PVC .. ... TYPE 304 ~,J i. ... T'IPE 304 ss i. ... i'fPE 304 ,.~ L ,J,J ... TYPE 304 C:" i. ~.J
2" TYPE 304 ,...,...
;),J .,. TYPE 304 ... C:'" ~.J
OUTER FGRMATlGN
CASill6 IIOH!iOREil
SAPROLI Tc
SAPROLITE
SAPROLITE
SAPROLITE
SAPROLITe
S~PROLITE
S~P~OL!Tc
SAPROLiTE
t"• IJ O.t33-5iEcL BE:i:1GC:\
SAPROLITE
4" sc:;. 40 P11C BEJRGCiC
SAP ROLITE
SAP ROLITE
4" SCH. 40 P~IC BEnP.OCK
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MEMO
Date:
To:
From:
Topic:
04/21/93
File lJttw~ n~ Douglas Moore o
NC Superfund Section
Well Data for Mecklenburg County.
Dynatech Industries, Inc.
NCO 981 014 517
Ref. 18
On Wednesday, April 21,1993, I spoke with George McCall of
McCall Brothers Well Drilling {1-704-399-1508) regarding general
well information for the Charlotte and Mecklenburg County area .
Mr.McCall stated that approximately 85% of wells in
Mecklenburg county are completed in bedrock, while the other 15%
are completed in saprolite. The average well is 160 feet and is
cased at 55 feet. Production data for wells in the area is
dependent upon the pipe radius. He stated that until 1950, drilled
wells commonly had a 2, 3 or 4 inch radius. These wells would, on
the average, yield 5 - 8 gallons per minute. Currently, many wells
are being drilled with a 6 inch radius that yield 16 gallons per
minute .
\DM\MCCALL
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MEMO
Date:
To:
From:
Topic:
01/25/93
File
Douglas Moore ik..r0A ~4
Environmental Chemist
NC Superfund Section
Ref. 19
Intakes for the Charlotte-Mecklenburg Water System
Dynatech Industries Site -NCO 981 014 517
On Monday, January 25,1993, I spoke with Mr.Terry Gross, Water
Treatment Plant Consultant with the Public Water Supply Section of
the Mooresville Regional Office {1-704-663-1699).
Mr.Gross stated that there are three intakes for the Charlotte
Mecklenburg Water system; one at Mountain Island Lake, two at Lake
Norman. He stated that there are no intakes along Irwin or Sugar
Creek, or South of Charlotte. The town of Pineville gets its water
directly from the Charlotte Mecklenburg system.
DM\D2GROSS
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MEMO
Date:
To:
From:
Re:
Ref. 20
01/28/93
File
<x u:IA __.,__ A Douglas Moore ....Jl'Y /u or-..:.-
Community Wells within the 4 mile radius of
Dynatech II .
I talked with Fred Hamilton, Engineer with the
Mecklenburg County Dept.of Environmental Protection (1-704-336-
5500). He stated that there are no community wells within the 4
mile radius of 2213 Toomey Avenue. The only community well in the
4 mile radius was Lakeside Park MHP located near the airport
which was recently connected to the city water system .
DM\D2CW
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Memo
Date: September 14, 1994
To: File
From: Douglas Moore ~ ~~
Environmental Chemist
NC Superfund Section
Topic: Private well users within a 4 mile radius.
Dynatech Industries, Inc.
2213 Toomey Avenue
Charlotte, Mecklenburg County, NC
US EPA ID: NCD 981 014 517
Ref. 21
Attached to this memo is a copy of the Charlotte Mecklenburg Utilities Department Municipal
Water Line municipal tap record maps covering a 0.5 mile radius of the subject site (Attachment
I). A review of these maps during the PA, combined with an offsite reconnaissance, found no
potential groundwater users within a 0.5 mile radius of the site. During the March 1994 Site
Inspection report for a nearby site, Cherokee Oil, one area was identified along Freedom Road
where residents did not have access to CMUD water lines (Attachment JD. On this day, I spoke
with Jeff Mills, Engineer with the Charlotte Mecklenburg Utilities Department [phone]
regarding water line coverage within a 4 mile radius of the subject site. Mr. Mills stated that
additional water lines have been extended along Brown A venue north between Freedom and
Tuckaseegee Roads, along Freedom Road beginning at Brown A venue and extending west out to
Mount Holly Road and along Tuckaseegee Road from Brown Avenue west to Toddville Road.
He stated that residents in this area now have access to water lines, but, that there are probably
residents in the area who still use private wells. He had no estimates of the number or percent of
residents in this area who are currently tapped into the CMUD water lines.
Based upon this assessment, a housecount was performed of houses along Freedom Road
between Brown Avenue and the 4 mile distance radius. Using the USGS topographic map (see
Figure 1), a total of 28 houses were identified along this segment of Freedom Road within the 3-
4 mile distance radius, a total of 59 houses were identified along Tuckaseegee Road between
Brown A venue west to the 4 mile distance radius and a total of 8 houses were identified along
Brown Avenue from Tuckaseegee Road north to Freedom Road, giving a grand total of 95
houses in the area of concern. As these are new lines, it is assumed that two-thirds of these
houses are connected to city water, leaving a total of 31 houses estimated to use ground water as
their source of potable water within a 3.0 -4.0 mile radius of the site.
Attachment I: CMUD Municipal Water Line Tap Record Maps (4)
Attachment II: Memo to File: CMUD Water Line coverage. Cherokee Oil Site. January
07, 1994.
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MEMO
Date:
To:
From:
Topic:
01/07/94
File
Douglas Moore ~·~ ,
Environmental Chemist
NC Superfund Section
CMUD Water Line coverage
Cherokee Oil Site
925 S. Summit Ave
Charlotte, Mecklenburg Co., NC
NCD 986 190 239
ATTACHMENT IT
On this day, I spoke with Jeff Mills, Engineer with the Charlotte Mecklenburg Utilities
Division (1-704-391-5146) regarding new water lines providing coverage within a 4 mile radius
of the subject site. During the PA, several areas were identified as potential groundwater users
in the 2-3 mile radius and the 3-4 mile radius. According to Mr. Mills, Wilmount Road and
West Blvd now have coverage within the 2-3 mile radius and Wilmount, West Blvd., Wilkinson
Blvd and Dowd Rd. have coverage within the 4 mile radius. The only identified area that
remains on groundwater wells is on Freedom Rd. between Brown Avenue extending northwest
to Paw Creek. Mr. Mills stated that water lines are currently under construction in this area.
Therefore, the housecount for the 2-3 mile radius equals 22 houses, roughly 55 residents. The
housecount for the 3-4 mile radius equals 154 houses, roughly 385 residents.
\cherokee\hsecnt
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MEMO
TO:
FROM:
DATE:
SUBJECT:
'I
Superfund Section Staff !), . )
Jeanette Stanley '
/_ .... ------......
Environmental Chemist i /·,>
NC Superfund Section l_>--
January 10, 1994
Update on Status of Well Head Protection Programs inN. C.
Ref. 22
I spoke with Carl Bailey, Groundwater Planning Branch Section Chief at [phone]. I
asked him about Well Head Protection Areas (WHPAs) in North Carolina. Mr. Bailey said that
Wally Venrick, Public Water Supply Section Chief, would be the most knowledgeable person
on this subject.
I called Mr. Venrick at [phone]. He said that North Carolina has extended an invitation
to communities to establish WHPAs, but none have been established. The cost to the
community of establishing a WHP A exceeds the savings realized from waivers for certain
analytical requirements . He does not anticipate that any WI-IPAs will be estabhsbed prior to
1996.
Mr. Venrick said that there are mm1mum allowable distances between wells and certain
structures (e.g. 100 feet between septic tanks and wells), but distances are arbitrary and
vary depending on the structure.
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MEMO
Date:
To:
From:
Topic:
September 8, 1994
File
Douglas Moore
Environmental Chemist
NC Superfund Section
Flow Calculations
Dynatech Industries, Inc.
2213 Toomey A venue
Charlotte, Mecklenburg Co., NC
NCD 981 014 517
Ref. 24
The flow for Irwin Creek and Sugar Creek was calculated using values taken from two
reports: (1) USGS Open File Report 83-211 titled "Drainage areas of selected sites on streams
in North Carolina" (2) USGS Water Resources Investigations report 88-4094 titled "Map of Mean
Annual Runoff for the Northeastern, Southeastern, and Mid-Atlantic United States, Water Years
1951-80". The drainage area value from report (1) and the runoff map value from report (2) was
put into the formula described on pg. 10 of report (2) to estimate the mean annual flow in cubic feet
per second.
Irwin Creek flow calculation:
14.0 inches per year x 26.0 sq. miles/ 13 .58 = 26.8 cubic feet per second
Sugar Creek flow calculation:
14.0 inches per year x 69.4 sq. miles/ 13.58 = 71.55 cubic feet per second
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MEMO
Date:
To:
From:
Topic:
06/07/93
File
Douglas Moore ~~
Environmental Chemist
NC Superfund Section
Irwin/Sugar Creek endangered species
Cherokee Oil Site
NCO 986 190 239
on Friday, June 4,1993, I spoke with Dr.Eugene Keferl of
Brunswick College (1-912-264-7233). Dr.Keferl had coauthored a
study of endangered freshwater mollusks in Mecklenburg County and
parts of South Carolina.
Dr.Keferl stated that they studied many of the drainages in
Mecklenburg County for endangered mollusks including Lasmigona
decorata. They studied the Irwin and Sugar Creek drainages from
above Charlotte down to the Catawba River in 1986-1987. No mollusks
were found in Irwin Creek or Sugar Creek to the Catawba River.
\cherokee\rnollusk
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Memo
Date: September 8, 1994
To: File
From: Douglas Moore ~~ ~,....___
Environmental Chemist
NC Superfund Section
Topic: Wetlands Calculations
Dynatech Industries, Inc.
2213 Toomey A venue
Charlotte, Mecklenburg County, NC
US EPA ID: NCD 981 014 517
Ref. 27
Using a 1:24000 scale calibrated planimeter and 1:24000 scale National Wetlands
Inventory maps (Charlotte East, NC; Charlotte West, NC; Derita, NC; Mountain Island
Lake, NC.), the aggregate wetland acreage was calculated withina 4 mile radius of the
subject site.
Distance Ring Wetland Acreage
0-0.25 mile 0
0.25 -0.50 mile 0
0.50-1.0 mile 14.23
1.0 -2.0 miles 12.80
2.0 -3.0 miles 27 .01
3.0-4.0 miles 112.38
Using a 1:24000 scale calibrated mapwheel and 1:24000 scale National Wetlands
Inventory maps (Charlotte West, NC; Fort Mill, SC-NC), the total wetland frontage was
calculated along Irwin and Sugar Creeks within the 15 mile surface water pathway,
downstream of the site PPE. The nearest wetland to the site is a palustirne forested
wetland having 0.1 miles of wetland frontage, located approximately 0.9 miles
downstream of the site PPE in Irwin Creek. A total of 0.1 miles of wetland frontage
were calculated bordering Irwin Creek from the site PPE to the confluence with Sugar
Creek. A total of 6.7 miles of wetland frontage were calculated bordering Sugar Creek
from the Irwin Creek confluence to the end of the 15 mile surface water pathway.
Copies of the above-mentioned National Wetland Inventory maps are attached.
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Ref. 28
Site Name: Dynatech
Site Number: NCD 981 014 517
Site Location: Charlotte, N.C.
Mecklenburg County
Latitude: 35 12 42 .0
Longitude: 80 52 1 8 .0
Date: February 15, 1993
Calculation Results
Distance from Population Number of Households
Site Location Per Ring Cumulative Per Ring Cumulative
0 to
>1/4 to
>1 /2 to
>1 to
>2 to
>3 to
Note:
1 /4 mile 744 744 320 320
1/2 mile 1,832 2 ,576 740 1,060
1
....,
L-
3
4
mile 5,977 8,55 3 2 ,323 3,383
miles 24,707 33,260 10,601 13,984
miles 38,733 71,99 3 16,970 30,954
mile s 51,773 123,766 22,352 53,306
The populations and number of households within specified
target distance rings were calculated for the NC
Superfund Section by the NC State Center for Geographic
Information and Analysis using the 1990 US Census data.
These values were calculated by summing the population
and the number of households data for each census block
located within each target ring. For census blocks lying
only partially within the ring, the per cent area of the
block within the ring was multiplied by the population
and household densities of the block.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
Ms. Pat DeRosa
North Carolina Department of Environment,
Health and Natural Resources
P.O.Box 27687
Raleigh, North Carolina 27611-7687
Subject: Superfund Chemical Data Matrix (SCDM)
Dear Ms. DeRosa:
~ ,·• .~. \
~· ·: ·-}
Ref. 29
Attached is the revised Superfund Chemical Data Matrix
(SCDM) These tables, which replace the March 1993 version of
SCDM, are to be used when evaluating sites with the Hazard
Ranking System (HRS) Changes from the previous version have
been marked with an asterisk in the tables. Also enclosed is a
separate list of the values which have been changed.
There is one change of specific importance. In the June
1994 SCDM, a benchmark has been included for lead in drinking
water. Since the former MCL of 50 ug/1 was rescinded in November
1992, the action level of 15 ug/1, which is the standard used by
the drinking water program to monitor water quality at the tap,
was included.
Please contact me at 404/347-5069, ext. 6160 or Trish
Gowland at 703/603-9017 if you have any questions.
Enclosure
Sincerely 1 . j . )A .l) f)~cd_a.taur -u,r
Deborah A. Vaughn-Wright
Region 4 NPL Coordinator
Printed on Recycled Paper

APPENDIX G

QUALIFICATIONS

Doug Cortese – Project Manager
BA – Chemistry, University of North Carolina at Wilmington
BS – Environmental Studies with a concentration in Physics, University of North Carolina
at Wilmington
Mr. Cortese has over eleven (11)years’experience in the environmental consulting field
and has performed over 400 Phase I ESAs for banks, Certified Development Companies
(CDCs), private investment groups, private landowners and commercial/industrial
facilities throughout the United States and has reviewed thousands of Phase I ESAs,
Phase II reports as a third party due diligence consultant for various financial
institutions.
Project field experience for Mr. Cortese includes:
•LBP, Radon, Air Quality, Mold and Asbestos inspections and project
supervision.
•Assessments on Gas Stations and Dry-Cleaning facilities, which involved the
identification of underground storage tanks (USTs).
•Assessments on multi-family properties.
•Industrial assessments which involved the identification of PCB containing materials, Asbestos and Lead-Based Paint along with soil and groundwater
contamination.
•Short and Long Term radon sampling on multi-residential properties along
with the identification of radon mitigation systems.
•O&M Plans.
•File reviews at local, state, and federal agencies.
•Phase II Site Investigations, which involved soil and groundwater sampling.
•Monitoring well abandonment and assessment activities.

Richard D. Fehler – National Client Manager

B.S. – Zoology, University of California, Davis

California Registered Environmental Assessor (REA I)

Mr. Fehler has over twenty-five years of environmental management experience gained
as an environmental consultant; in the chemical manufacturing industry; in the
hazardous waste management industry; and as an environmental regulator. He
specializes in all aspects of environmental due diligence, regulatory compliance and
negotiations, hazardous waste management, and auditing. Mr. Fehler has also received
training in Greenhouse Gas and Sustainability Verification.
Mr. Fehler has served as project principal on hundreds of projects with wide-ranging
scopes, including peer reviews and desktop reviews; due diligence on large portfolios
(200 sites+), as well as single assets; investigation and management of lead, asbestos,
mold, and Legionella; investigation, remediation and management of contamination in
groundwater, soil and soil vapor; regulatory compliance and auditing; and representing
clients with regulators to negotiate site closure/No Further Action and/or to develop
effective remediation strategies and budgets.

Project experience for Mr. Fehler includes:

• Multiple Site Due Diligence - Managed and designed projects for many large
portfolios (100-plus) of varied properties spread across various states. The
scopes of work frequently include Indoor Air Quality/mold issues, lead-based
paint, asbestos, and radon testing. The design of appropriate Phase II sampling is frequently required to resolve and close issues.
• Environmental Compliance Reviews – Designed and managed many
environmental compliance audits for single or multiple assets. Project activities
usually involve inspections, interviews, reviewing environmental permits, past
environmental reports, standard operating procedures, material safety data
sheets (MSDS), and other information related to regulatory compliance in the
areas of hazardous materials, hazardous and non-hazardous waste management,
workplace health & safety, air permitting and emission reporting, waste water
permitting and monitoring, storm water management, underground storage
tanks, and aboveground storage tanks.
• Regulatory Negotiation – Managed many Phase II investigations conducted in
response to regulatory requirements or to resolve issues and/or to obtain case
closure or No Further Action. Represented clients with regulators to negotiate
appropriate scopes of work and move projects to successful completion.