Cenco_ FILE DOCKET-P 91-93-OCR

•
William F. Hamner, Ph.D.
June 1, 1994
Page -2-
•
A. The Table of contents lists 29 SWMUs; however, Table I
shows 28 SWMUs. The creek along the closed lagoons, which is SWMU
#27 in the Table of contents has been omitted in Table l and the
discussion of individual SWMUs. The wastewater treatment plant has
become SWMU #27 in Table 1.
B. On pages 5, 7 and 26 in the RFA Report, the references in
the wastewater storage tanks should be "2-15,000 gallon" tanks
rather than "2-1500 gallon" tanks.
c.
should be
Transport
shipments
Charlotte
In Section 2. 2 --Process Description on page 5, it
recognized that only 5% of tanker shipments by Central
originate from the rail siding. The other 95% of the
are loaded at off-site manufacturing locations in the
area.
D. On page 7 in Section 2.2, it should be noted that the
non-hazardous waste solids are transported to the Palmetto Landfill
operated by Waste Management in Wellford, sc, rather than the
Piedmont Landfill in Kernersville, NC.
E. In Section 2.4, References 7 and 12 are used to
substantiate the waste management aspects of the trenches and drum
storage area. These references should be deleted since neither
individual cited by the reference has any knowledge regarding the
past use of the areas as described in the RFA Report.
F. Effective March 5, 1994, Central Transport is no longer
under the stipulations in the plea agreement as mentioned in
Section 2.5 on page 11.
G. Central Transport did not receive
the MCEPD for air pollution on July 26,
Section 2.5 on page 11.
a violation notice from
1993, as indicated in
2. Specific Comments on Solid Waste Management Units.
The RFA is designed to evaluate solid waste management units
("SWMU") at the facility. we have three areas of general concern
about the RFA. First, there are a significant number of SWMUs
which are located near each other and involve the same waste
management area. In a number of cases, these should be combined
into a single SWMU. Second, there are several listed SWMUs which
are in production areas and where there have been no systematic
releases. These should not be SWMUs at all. Third, the proposals
for various SWMUs are excessively complex. For some at which an
RFI is suggested, sampling would be sufficient. For others, no
further action should be required.
•
William F. Hamner, Ph.D.
June 1, 1994
Page -3-
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SWMUs are areas of concern for releases to air, surface water,
ground water and soils. They may include "containers, tanks,
surface impoundments, waste piles, land treatment units, landfills,
incinerators, and underground injection wells." 50 Fed. Reg.
28712-3 (July 15, 1985). A SWMU may also include process areas
contaminated by "routine, systematic and deliberate discharges;"
however, , it "does not include accidental spills from production
areas and units in which wastes have not been managed (e.g.,
product storage areas)." RCRA Facility Assessment Guidance, Office
of Solid waste (Oct. 1986) at 1-4.
The EPA explained this distinction when it published regulations:
[T)he legislative history indicates that the term [SWMU) is
intended to limit EPA's jurisdiction under section 3004(u) to
discernible units. One of the questions raised by this
definition is whether an area on which a spill occurs is
intended to be viewed as a [SWMUJ. Clearly, a spill of
hazardous waste or hazardous constituents from a discernible
unit would constitute a "release."
EPA does not, however, believe that section 3004(u) applies to
spills that cannot be linked to [SWMUs). For example, a spill
from a truck travelling through a facility would not
constitute a release from a [SWMU).
50 Fed. Reg. 28712-3 (July 15, 1985).
EPA's discussion of the definition and applicability of the term
SWMU raises questions about the state's designation of 28 (or 29)
SWMUs in the RFA. rt appears that many of the 28 (or 29) do not
fall within the term SWMU, while some are merely ancillary parts or
processes of other SWMUs and should not be considered separately
from them.
Discussion of Individual SWMUs.
SWMU l. These units (the lagoons) are currently subject to a RCRA
Closure Plan approved by the State, and should be addressed
separately. The RFA Report's recommendations for additional RFis
are inappropriate, since investigations are already progressing
under the Closure Plan. The EPA has specifically stated that
"ground water releases from regulated units are not addressed in
the RFA." RCRA Facility Guidance Document, supra. at 1-3.
The post-closure obligations which CTI has already assumed preclude
the need for an RFI. Those obligations include ground water
monitoring which CTI is committed to completing.
•
William F, Hamner, Ph.D.
June l, 1994
Page -4-
•
SWMU 2. The Report states that "Sludge samples taken from Pond #3
(SWMU 2] contained the following hazardous substances:
Bisphthalate, Di-N-Octyl Phthalate, and Aluminum." There is no
such substance as "Bisphthalate" [bis(2-ethylhexyl) phthalate?],
and aluminum, per se, is not a hazardous substance. Moreover,
there is no evidence of a release from the pond, thus precluding
the need for an RFI.
SWMU 3. This area, consisting of a concrete pad and sluiceways
leading to the lagoons, was known as the Truck Wash Rack. rt is
included within the currently regulated unit, which has been
closed, and therefore, should not be considered a SWMU.
SWMUs 4,5,7. The Truck Wash Rack Collection sump (SWMU 4) was
connected by a 4-inch PVC wastewater line (SWMU 5) to a concrete-
lined trough (SWMU 7), which is now abandoned and filled in with
soil. These three items should not be considered separate SWMUs,
but, at the most, as sections of a single SWMU. The sump (which
was a 200 gallon steel wastewater treatment tank) and the line were
stated to be in good condition when they were excavated during the
lagoon closure operation. The RFA Report reports no "history
and/or evidence of release (s)." Since the RFA has produced no
evidence of "releases of hazardous materials or hazardous
constituents from the tank" or from the associated line, there
appears to be no reason for further action at SWMUs 4 and 5.
SWMU 6. The RFA Report calls for confirmatory sampling of Unit 6,
the Lagoon Sludge Stabilization (Treatment) Area. CTI already has
results of such sampling, which confirm that no contamination of
underlying soils occurred. Submission of these results should
therefore result in no further action being required.
SWMU 8.12.13.14.16. The Truck wash Area (SWMU 16) consisted of wash
bays with a concrete floor sloping towards a drainage system
connected to a concrete floor sloping towards a drainage system
connected to a concrete wastewater trough (SWMU 8). The trough led
to a concrete-lined Rinsewater Collection Sump (SWMU 12), from
which the rinsewater was pumped to two storage tanks and then to
steel treatment tanks (SWMU 13) on a concrete pad. From there,
treated water drained into a concrete tank in a concrete block-
lined pit (SWMU 14), and on into the CMUD sewer system. Since
these units are all sections of a single treatment system, they
should be regarded as a single SWMU.
The RFA Report described possible releases at these "SWMUs" as
follows:
16. No cracks were observed in the concrete floor ... No
releases from this area have been reported.
•
William F. Hamner, Ph.D.
June 1, 1994
Page -5-
•
8. There were no apparent cracks in the trough ... History and
/or evidence of release(s): None
12. No reported leaks from the basin/sump.
13. The plant area shows no evidence of spills on the
concrete pad or surrounding area ... No evidence
for ... dumping1 was discovered during our site visit.
14. No evidence of release.
Although the Report called for confirmatory sampling for units 8,
14 and 16, and RFis for units 12 and 13, there appears to be no
evidence for supporting any requirement beyond confirmatory
sampling for any of these units. The EPA has noted that
"corrective action requirements for wastewater treatment tanks
would be limited to submission of descriptive information with a
permit application •.. EPA will impose additional requirements when
this first phase turns up evidence of releases of hazardous waste
or constituents from the tank." 50 Fed. Reg. 28713 (July 15,
1985) . There is no reason to require anything beyond sampling a
this time.
SWM!J 9. This is a sewer line which connects directly to the
public sewer, and, as such, does not appear to fit any current
definition of an SWMU. Unsubstantiated allegations that "employees
were dumping untreated wastewater through the clean out lines where
it [?] passed directly into the CMUD sewer system" do not transform
this sewer connection into an SWMU. Confirmatory sampling of the
line would not prove anything.
SWMU 17. This involves the closure of a 10,000 gallon fuel UST
under the oversight of NCDEM, and this RFA Report should therefore
not require separate confirmatory sampling.
SWMU 21. This "unit" consists of a siding where rail cars are
unloaded into tanker trucks. This unit is not located on CTI
property. It is owned by CENCO, not CTI, and should not be
included within the RFA. CENCO is a partnership wholly owned by
Gary Honbarrier and his sister, Linda Honbarrier Embler. CTI, on
the other hand, is controlled by Archie Honbarrier, who owns 51% of
its stock and his wife, Louise, who owns 25%. Gary Honbarrier and
Linda Honbarrier Embler each own 12% of CTI. Archie Honbarrier,
therefore, neither owns nor controls CENCO. Gary Honbarrier is no
longer an officer of CTI, and does not control that company.
Consequently, CTI and CENCO must be viewed as separate entities.
1Dumping of drums of contaminated soil resulting from a spill of
ethyl acrylate was alleged by a disgruntled former CTI employee,
Gary Belk, in a 1987 affidavit. There is neither confirmation of
this assertion, nor any other evidence to support it.
•
William F. Hamner, Ph.D.
June 1, 1994
Page -6-
•
RCRA itself does not define 11 facility. " (see RCRA
Section 1004; 42 U.s.c. # 6903) However, the July 26, 1982 Federal
Register explained that a facility "means the entire site that is
under the control of the owner or operator engaged in hazardous
waste management." 47 Fed. Reg. 32288-89. In the Hazardous and
Solid Waste Amendments of 1984, Congress directed EPA to require
corrective action beyond the facility boundary "where necessary to
protect human health and the environment ... 11 RCRA #3004 (v), 42
U.s.c. #6924 (v). EPA thereafter amended the definition of facility
specifically to include all contiguous property under the owner or
operator's control. 40 C.F.R. # 260.10; #264.lOl(c). CTI,
however, does not own or control CENCO. CTI' s "facility, 11
therefore, does not extend to the property which it does not lease
from CENCO. Likewise, no contamination is asserted on the separate
CENCO property where corrective action is necessary to protect
human health and the environment. Consequently, corrective action
should not be required beyond the CTI-leased property.
Moreover, even it were included, there is insufficient
evidence to require an RFI. The RFA states that there was "some
discoloration of the surrounding gravel 11 , and that "a film had
developed on a wet area." In addition, "Reports filed with the
Mecklenburg County Environmental Division indicate that numerous
spills ;mgy have occurred during the rail car unloading process"
(emphasis added). The siding is presented as another potential
location for the alleged ethyl acrylate spill. Thus the evidence,
such as it is, seems highly speculative, and does not warrant the
RFA' s recommendation for a RFI. Only occasional, accidental spills
are identified, not "routine, systematic and deliberate
discharges." Therefore, this area should not be identified as a
SWMU, even apart from the fact that it is not on CTI property.
SWMU 22. This unit is on CENCO property and should not be included
in the RFA. Moreover, since earlier sampling for metals by
Mecklenburg County revealed only "chromium in concentrations above
[the practical quantitation limits]", if any work is warranted, it
seems more appropriate, at this time, to perform a more complete
program of confirmatory sampling of these former waste storage
trenches, rather than to go straight to the RFI process. Sampling
may reveal nothing which warrants the RFI step.
SWMU 23. This wooded area is on CENCO property, and should not be
in the RFA. The RFA Report states that "There are currently no
drums located here", but that "Aerial photos reveal the presence of
metal containers in this area between 1978 and 1980." rt should be
noted that aerial photos, unless at a very large scale, rarely
reveal the undisputed presence of "containers", let alone "metal
containers", but merely the presence of small objects which can
only be identified in conjunction with other evidence. If these
were containers, it has not been shown that they did, in fact,
•
William F. Hamner, Ph.D.
June 1, 1994
Page -7-
•
contain waste and not useful product or, for that matter, anything
at all. Thus there is insufficient evidence to categorize this
area as a solid waste management unit. In addition, the
requirement "to ID containers" appears, after 14 to 16 years, to be
an impossibility.
SWMU 24. This is also on CENCO property, and should not be in the
RFA. The material described in these erosion gullies may only be
construction debris and other trash used to fill in and stabilize
the area. The designation of this area as a SWMU is therefore
questionable.
SWMU 25. This product storage tank area is, once again, on CENCO
property, an should not be in the RFA, The fact that it is a
product storage area should not cause it to be classified as a
solid waste management unit. The RFA Report states that the tanks
"show no visible evidence of damage or corrosion", and that
"Ancillary piping appears in good shape." County Notices of
Violation, mostly 9 years or older, appear to relate to air
releases, since releases to soil are not specifically mentioned.
With so little evidence, the situation does not warrant further
action.
SWMU 26. This is another rail siding, on CENCO property, with
"some discoloration of the gravel". The only evidence presented in
support of the recommendation for a RFI is more unspecified county
Notices of Violation, and the suggestion that this, too, may be the
site of the alleged ethyl acrylate spill. It does not fit the
definition of SWMU discussed above.
SWMU 27, This appears to be the same area as SWMU 10, we have not
been able to review any of the asserted evidence of releases
(telephone conversations, aerial photographs and a letter).
Therefore, it is not possible to reply to this suggestion.
3. Tbe RFA Reference Materials Should be Available to CTI.
The RFA lists 33 references which were utilized in its preparation.
Many of these, such as telephone conversations, field inspection
reports, file reports, aerial photographs and letters have not been
made available to CTI. It is extremely difficult to respond fully
to many of the statements in the RFA without seeing these
materials. Consequently, pursuant to the North Carolina Public
Records law (General statutes 132-1), we request that such
materials be made available for our review,
* * *
In conclusion, we request that the RFA be amended to correct the
factual inaccuracies and to reflect our comments on the individual
•
William F. Hamner, Ph.D.
June 1, 1994
Page -a-
•
SWMUs. We are available to discuss this with the state at an early
time, and hope that the State agrees with us that such discussions
would be useful for both parties.
sincerely,
<fk~·~~
Glen Simpson
Environmental Director
GS/PS
Mr. Gary L. Honbarrier
August 7, 1980 •
Page 2 •
6. The liquids in each trench must also be analyzed by
private laboratory for determining hazardous or non-
hazardous characteristics · (if the liquids are declared
non-hazardous we may possibly be able to pump the waste
into your pre-treatment system. If the waste is declared
hazardous, we will advise you regarding proper disposal).
As soon as all the information is gathered regarding your,
waste characteristics we will advise you of proper disposal. Please
advise this office of your findings as soon as possible or you may
wish to contact Mr. John Gibson, Chemist, with the Environmental
Health Department at 374-2503.
If I can be of 'additional help, please advise.
CRD/mr
cc: Mr. Julian Foscue
Mr. 0. W. Strickland
Mr. John Gibson./
Mr. William Lynch
Sincerely,
(', R. JJo./4,s. ... ,t.sk
C. Richard ~oby, Sr., R.S.
District Sanitarian
N. C. Division of Health Services
Solid/Hazardous Waste Management Branch
169-B Rosehaven Court
Concord, NC 28025
Phone: [phone]
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CERTIFIED MAIL'-RETURN RECEIPT REQUESTED t,, " ~
MECKLENBURG COUNTY
DEPARTMENT OF ENVIRONMENTAL HEALTH
ENVIRONMENTAL MANAGEMENT DIVISION
AIR QUALITY CONTROL SECTION /
VIOLATION NOTICE·
Name ..... ~entrn.1 In.iT1.SIJ()l'.~.. ·-......................... _______ .......... .
Address ~QO Mf:!lY.l'ld~ _Ro;:i,tj ... J~arl_oH~-' ~C .. 2.~~.9.5 ...... ______ ......
Re: Premises at .. _$,\\.Ill!! _______ ........
YOU ARE HEREBY NOTIFIED THAT PURSUANT TO SECTION 22 ___ .. OF
THE MECKLENBURG COUNTY AIR POLLUTION CONTROL REGULATION, A VIOLATION
HAS BEEN COMMITTED THROUGH THE
Creation of nuisance to any number of
persons by allowing the loading of a tanker with Ethyl Acrylate without taking
reasonable means to control the emissions. The Violation occurred on July 26, 1983.
Action to be taken by the Air Quality Control Branch with regard to this violation is indi-
cated below:
D
0
D
D
lhe Agency will file a Complaint for Arrest with the Mecklenburg County Magis-
trate.
No further action will be taken at this time, With the understanding that the
necessary remedial action will be taken to insure that tho violation will not be
repeated.
No further action at this time with the condition that
Section 18 enclosed.
Served to: Aprnved by: _ . __ ,
_ .. H\\r.r:Y ... H!;.l..$e) __________ ...... ----........ ,)f;;cAkll 1/[,df&fl
(/
Central Transport, Inc.
Page 2
January 25, 1983
• •
Hopefully, these actions will help us all in our pursuit of further odor
reductions in and around the Westchester Community.
Sincerely,
{l .z/~
Dan Hardin
OH/see!;<.
Enclosures
;··;::.:;,,
• Mr. James H. Moore • Central Transport, Inc. Page 2 February 3, 1987
arrangements are made for the cleaning and removal of the
aboveground storage tanks and scrubbers.
Please notify MCOEH well in advance of the implementation of
the planned procedures addressing cleaning and/or removal of the
aboveground storage tanks and scrubbers from the premises so we
are able to interject our comments about the chosen methods.
Lastly, let me take this opportunity to thank you and the
personnel at Central Transport, Inc. /Cenco, Inc. for their
continued cooperation throughout the two year duration of the
weekly inspections that were conducted.
DH:dsb
cc: James o. Cobb
County Attorney
Jim Hollingsworth
Emergency Management Office
Robert Byers
Central Transport
Sincerely,
~"~u/;,
Dan Hardin
Industrial Hygienist
Environmental Management
Division
tr
•
.-<::.-""'>., • \'-M-EC-1'-, c .... o""u""'N1Y=:-:D:::E:;::"PA:;;R:;;H:;:;.~E:;:;N.-T no'1F
/ft··~· ·~ ~~'·. RECC"IVED '~ .t)· r;-~;j) i;..
·scJ . .;J//.t/ MAR 2 O '198b ·",~ .. ~,:·~~./
North Carolina Department of Human Resource t.-::.EN:..:.;Vl~RO;....NM;....E_N1_A_L _HE_AL_TH _ _.
Division of Health Servic::es
P.O. Box 2091 • Raleigh, North Carolina 27602·2091
James G. Marrin, Governor
Phillip J. Kirk, Jr., Secretary
Mr. Ja.'J'es H. M:lore
Central Transport, Incorporation
600 Melynda Road
Charlotte, North carolina 28208
I\a.e.r Mr. M:lore:
'Ronald H. Levine, M.D., M.P.H.
State Health Director
Date: M'rrch 10, 1986
Re: Facility ID No. NC0046148540
cesed on information supplied by you, we have processed and .accepted at the
Stete level your request for the facility identified with the above ID number
to ::e::e::.ve the indicated change in classification under RCR.!\:
Add As Delete As
x generator
x transporter
treater
storer
disposer
small generator
We are advising the EPA of the change in your status. Please notify us if
t.h::>::e is a..,.,y :further change in your operations which would again affect yotn:'
status.
Yc:.ir EPA ID NO. is x
is not
cc: D::iug McCurry, EPA Region IV
mil Breckling
being cancelled
being cancelled .
c?1{~4
!'-eith Lawson, ~Chemist
Solid & Hazardous Waste Management Branch
Environmental Health Section
Iarry Fox
v"fucklenburg·County Health Departrrent
• •
January i, 1991
be provided as necessary to the meet the BAT
standards. The need for pretreatment will be based
on visual observations and chemical analyses using
EPA method 8240. Periodic sampling will be
performed to verify that CMUD permit effluent
conditions are met. sampling will be conducted
once each month for six months
thereafter and discharge may be
and quarterly
halted during
periods of heavy rainfall/excessive flows at the
POTW. Based on the above flow rate, it is
presently estimated that it will take approximately
30 days to discharge the liquids from Lagoon 1 and
Lagoon 2. Pond 3 will be returned to its natural
drainage pattern.
E-lb(2lb stabilization of Sludge
F-lb(2lbCil Background
The sludge will be stabilized to improve its
physical characteristics and reduce the
leachability potential of the sludge.
Stabilization is a process by which industrial
wastes are treated to bind hazardous constituents
and prevent dissolution of leachable materials and
release into the environment (Tittlebaum et al.,
1985).
lJ bHilN L l·it hi.
•
Attachment 3
SWMU DATA SHEET
Page _l_I of
SWMU NUMBER: q
/ { If
-,~l! PHOTO NUMBER: --rL-\
NAME' I 5£wE--12-l,tJi:;-LFf'.tlYYI ts01cb'l".-72.oom Tb V'1sr:UMlt:r 8,-,.,,-)
TYPE OF UNIT:
-+1' q p\lc
PERIOD OF OPERATION:
PHYSICAL DESCRIPTION AND CONDITION:
WAST!"S AND/OR . HAZARDOUS . CONSTITUE_NTS MANAGED:
RELEASE PATHWAYS: Air Surface Water ( Soil
Groundwater ( Subsurface Gas (
lIIS'l'ORY AND/OR EVIDENCE OF RELEASE(s):
RECOMMENDA'l'IONS: No Further Action
REFERENCES:
COMMEN'l'S:
RFA Phase II Sampling
RFI Necessary
------------~----------~-
Project Name: C_ T 0 ate: ff /lf (q ·:::,
-12-
• •
Attachment 3
SWMU DATA SHEE'l'
Page fl_ of 2-tf
SWMU NUMBER: )_.;{ It) PHOTO NUMBER:--H I 5
NAME: VEf;/!.!'f "7£m:,
TYPE OF UNIT: :) '"' // = hL Wf.2-fl, 6'2>_5 --I /V'-' / (,, R4'J/c ~
PERIOD OF OPERATION:
PHYSICAL DESCRIPTION AND CONDITION:
(I, 17/ ('_ /2 lf7F /;tic;? OZ! ,U'!) T.4 If/ f-5
-~1f1 I/. I ( r' • l''tt.i 'fl f {.!
WASTES AND/OR llli.ZARDOUS CONSTITUENTS MANAGED:
RELEASE PATHWAYS: Air ( Surface Water ( Soil (
Groundwater ( Subsurface Gas ( )
llIS'l'QRY ANO/OR EVIDENCE OF RELEASE ( s):
RECOMMENDATIONS: No Further Action ( )
REFERENCES:
COMMENTS;
RFA Phase II Sampling ( )
RFI Necessary ( )
Project Name: (_~I/
-12-
Date:
·--_--:;r_--~
p/Y;1J
• •
Attaclunent 3
SWMU DATA SHEET
Page f_\ of 7-t/
SWMU NUMBER: fr ('f PHOTO NUMBER:-~/(
NAME: A·5tvf"' (,,rztnt,uD '£n121Jc.r;-·!410;:.s
'l'YPE OF UNIT:
4 (,,!fBlJ '?-rm:JL Tj,vts
PERIOD OF OPERATION:
·-5i1 '-f I '11 z_
PHYSICAL DESCRIPTION AND CONDITION;
LQtfe-P-l!1C ('d''l)Ti11.Ni/l) I c~;Jf!£,l!77" 8A-sE.
WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGEDi
RELEASE PATHWAYS: Air ( Surface Water ( Soil
Groundwater ( Subsurface Gas (
HISTORY AND/OR EVIDENCE OF RELEASE(s):
RECOMMENDATIONS; No Further Action
REFERENCES:
COMMEN'l'S:
RFA Phase II Sampling
RFI Necessary
P:i;oject Name: [_ T)
-12-
Date: ry/'-/ ~5
• •
Attaclunent 3
SWMU DATA SHEET
Page 3~ of
SWMU NUMBER: PHOTO NUMBER: >57) ~
NAME • ?r mnicr .,.; iJ ts
'l'YPE OF UNlT: Dµ 6 fl.vu !VP ?"f"im-L---f:d ,J t-s
PERIOD OF OPERATION: _)
s-n 1.-tPJ usr'
PHYSICAL DESCRIPTION AND CONDITION:
WASTES AND/OR.HAZARDOUS.CONSTITUENTS MANAGEDi
RELEASE PATHWAYS: Air ( Surf ace Water ( Soil
Groundwater ( Subsurface Gas (
HISTORY AND/OR EVIDENCE OF RELEASE(s):
RECOMMENDATIONS: No Further Action ( )
REFERENCES:
COMMEN'fS:
RFA Phase II Sampling ( )
RFI Necessary ( )
~--t!,...-,_1 I __________ #J_3_
Project Name: Date:
-12-
----------
•
CENTRAL TRANSPORT INC. RCRA FACILITY ASSESSMENT
NIKON PHOTOGRAPH LOG
Photograph
NWilher
Description
2.
3.
4.
5.
6.
7.
Lagoon 1, the closed regulated unit-looking south.
Lagoon 1, the closed regulated unit-looking south.
Lagoon 2' the closed regulated unit-looking south.
Pond 3' looking north.
Lagoons 1 and 2, the closed regulated unit-looking south.
Wash rack beside the boiler room-looking west.
Sludge solidification area-looking east.
from Lagoons 1 and 2 were solidified and
during the closure of the units.
Excavated sludge
stored in this area
8. Wash rack sump area-looking south. Two hundred gallon sump
was located behind the boiler room. Waste water from the
washed truck tanks, in the wash rack (Photograph 6), were
collected in the sump. The sump has been removed.
9. Excavated sewer line area-looking north. The sewer line ran
from the boiler room to the concrete trough, (Photograph
10), is visible in the foreground.
10. Abandoned concrete trough from truck wash area-looking east.
11. Existing concrete trough. Concrete trough drains waste
water generated at the truck wash area (Photographs 19 and
20) to the waste water collection sump (Photograph 15) at
the waste water treatment building (Photograph 16).
12. Former location of the four inch sewer line from the wash
rack sump (Photograph 8) to the connection with CM\JD.
13. Block basin-looking north. Use of the block basin is
unknown.
14. Waste water treatment building and waste water tanks. Waste
water collection sump (Photograph 15) is located the corner
of the concrete containment wall, by the waste water
treatment building.
15. Waste water collection sump. The waste water collection
sump pumps waste water from the truck wash area (Photographs
19 and 20) to the waste water tanks.
16. Waste water treatment building.
• •
17. Drying bed collection drain. Waste water from the drying
beds (Photograph 18) is collected in the drain.
18. Drying beds at the waste water treatment building
(Photograph 16).
19. Truck wash area-looking north. Truck tanks are washed and
cleaned in the truck wash area. The waste water is
collected and transported to the waster water collection
sump (Photograph 15) by the existing concrete trough
(Photograph 11).
20. Truck wash area-looking south.
21. Former location of the underground 10,000 gallon fuel tank.
22. Former location of the underground used oil tank.
23. The existing above ground fuel and oil tanks.
24. Parts washer in the truck maintenance area.
25. Rail car unloading area-looking east. Material is unloaded
from the rail cars to tanker trucks.
26. Area of alleged trenches containing drums with contaminated
soil.
27. Former trench area, allegedly containing drums with
contaminated soil-looking northwest.
30. Former trench area allegedly containing drums with
contaminated soils-looking northwest.
31. Former trench area allegedly containing drums with
contaminated soils-looking northwest.
32. Former container/tank/drum area, north of the former trench
area-looking northwest. This area is currently on Cenco
property. Aerial photographs indicate scattered containers,
tanks, or drums in this area.
33. The gully area, where debris was disposed and the area
reworked-looking northwest. Visible on the ground surface
was concrete and asphalt blocks, metal debris, plastic,
discarded equipment, and PVC pipes. The gully area is
currently on Cenco property.
34. The gully area, where debris was disposed and the area
reworked-looking southeast. Visible on the ground surface
was concrete and asphalt blocks, metal debris, plastic,
discarded equipment, and PVC pipes. The gully area is
currently on Cenco property.
• •
CENTRAL TRANSPORT INC. RCRA FACILITY ASSESSMENT
POLAROID PHOTOGRAPH LOG
Photograph
Number
Description
1.
2.
3.
4.
5.
6.
7.
Lagoon 1, the closed regulated unit-looking south.
Lagoon 2' the closed regulated unit-looking south.
Pond 3' looking north.
Lagoons 1 and 2, the closed regulated units-looking south.
Wash rack beside the boiler room-looking west.
Sludge solidification area-looking east.
from Lagoons 1 and 2 were solidified and
during the closure of the units.
Excavated sludge
stored in this area
Wash rack sump area-looking south.
was located behind the boiler room.
washed truck tanks, in the wash rack
collected in the sump. The sump has
Two hundred gallon sump
Waste water from the
(Photograph 6), were
been removed.
8. Excavated sewer line area-looking north. The sewer line ran
from the boiler room to the concrete trough, (Photograph
10), is visible in the foreground.
9. Abandoned concrete trough from truck wash area-looking east.
10. Existing concrete trough. Concrete trough drains waste
water generated at the truck wash area (Photographs 19 and
20) to the waste water collection sump (Photograph 15) at
the waste water treatment building (Photograph 16).
11. Former location of the four inch sewer line from the wash
rack sump (Photograph 8) to the connection with CMtJD.
12. Block basin-looking north. Use of the block basin is
unknown.
13. Waste water treatment building and waste water tanks. Waste
water collection sump (Photograph 15) is located the corner
of the concrete containment wall, by the waste water
treatment building.
14. Waste water collection sump. The waste water collection
sump pumps waste water from the truck wash area (Photographs
19 and 20) to the waste water tanks.
15. Waste water treatment building.
16. Waste water treatment building.
• •
17. Drying bed collection drain. Waste water from the drying
beds (Photograph 18) is collected in the drain.
18. Drying beds at the waste water treatment building
(Photograph 16).
19. Truck wash area-looking north. Truck tanks are washed and
cleaned in the truck wash area. The waste water is
collected and transported to the waster water collection
sump (Photograph 15) by the existing concrete trough
(Photograph 11).
20. Truck wash area-looking south.
21. Former location of the underground 10,000 gallon fuel tank.
22. Former location of the underground used oil tank.
23. The existing above ground fuel and oil tanks.
24. Parts washer in the truck maintenance area.
25. Rail car unloading area-looking east. Material is unloaded
from the rail cars to tanker trucks.
26. Former trench area
contaminated soil.
property.
allegedly containing drums with
The former trench area is on Cenco
30. Former trench area-looking northwest.
31. Former container/tank/drum area, north of the trench area-
looking northwest. Aerial photographs show scattered
containers, tanks, or drums in this area. The former
container/tank/drum area is on Cenco property.
32. The gully area which
northwest. Readily
concrete and asphalt
discarded equipment.
property.
was filled with debris-looking
visible on the ground surface was
blocks, PVC pipes, metal debris and
The former gully area is on Cenco
33. The gully area which was filled with debris-looking
southeast. Readily visible on the ground surface was
concrete asphalt blocks, PVC pipes, metal debris and
discarded equipment. The gully area is on Cenco property.
34. Cenco product tank farm-looking west. Several spills have
been documented at the tank farm.
35. Cenco rail car unloading area, the southern rail line-
looking west.
• •
36. Cenco rail car unloading area, the northern rail line-
looking west.
37. Cenco rail car unloading area, the southern rail line-
looking east.
38. Cenco rail car unloading area, the northern rail line-
looking east.
39. Stream which runs south of the closed surface impoundments.
The water had a organic sheen on it. Releases to this
stream from the surface impoundments have been documented.
40. Organic sheen on the stream which runs by the closed surface
impoundments.
41. Pond 3, on the west bank of Pond 3-looking south.
42. Pond 3, on the west bank of Pond 3-looking north.
• •
SUMMARY OF LABORATORY RESULTS
JULY 3, 1991
LOCATION CONSTITUENT RESULTS REGULATORY
-LEVEL
ss~z Barium (soil) 80.4 mg/kg NA
SS-3 Barium (soil) 38.2 mg/kg NA
Chromium (soil) 71.8 mg/kg NA
Lead (soil) 6.21 mg/kg NA
SLUDGE Barium (soil) 18.7 mg/kg NA
Chromium (soil) 4.30 mg/kg NA
-11-
I '' ' • • CSX Real Property, Inc. Law Job No. 229-07680-02
Water Sam11li:
Organics* fil1:J. TW-1
Chloroform /NO ND
Tetrachloroethine ND ND
Metals*
Total lead 4 68
Total Chro111i urn ND 330
* Results in parts per billion (ppb)
ND • Not detected
NT • Not Tested
~
ND
3
21
ND
Rinse
.Bli!1k
3
ND
NT
NT
August 20, 1991
Trip NCDEH
1lli_nJ; fil:l**
ND 0.19
ND 0.7
NT 50
NT so
.. NCDEH HCL • North Carolina Division of Environmental Hanagement maximum
contaminant level
CDl*IENTS AND RECOMMENDATIONS
The concentration of tetrachloroethane present in HW-1 exceeds the maxi111U111
concentration level set by the NCDEH and therefore constitutes ground-water
conta111ination at the subject site. Data obtained frOlll Holley Consultants testing
on the parcel to the west of the subject site indicated that tetrachloroethane
was detected in the ground water at a concentration level of 4 ppb.
The concentration levels of total chromium and total lead in TW-1 exceed
the North Carolina maximum contaminant level HCL of 50 ppb. However, a filtered
ground-water sample may yield lower concentrations of these !:leta1s due to the
presence of suspended solids in these unfiltered samples. Also Piedmont soils
contain naturally occurring elevated levels of these particular metals. Holley
Consultants testing also detected elevated levels of total chro111ium and total
lead in the ground water at the parcel to the west of the subject site.
The presence of chloroform in the rinse blank is likely a result of the
residue of municipil water left on the bailer when it was decontaminated.
Chlorofor. is i breakdown product of chlorine which is added to municipal Wiler.
Based on the above infor111ation, it appears the ground-water contimination
fro111 the upstrea111 Central Transport Company has 111igrated onto the subject
property. It should be noted that concentration levels of contuiinants fluctuate
both horizontally and vertically with the move11ent of the ground water.
Tetn1ch l oroethane is denser than water hence ca 11 ed a •sinker•. Higher
concentrations of this conta111inant are usually detected with depth .
•
l:;;;;;;;;;;==;;;;==--==--=--LAW ENGINEERINGo;;;;;;;;;iiiiiii;;;;;;;;;;;;;;iiiiiii-;;;;;;;Oiiiii===-=;;;;;:J
r ·------• -----•-------~OUTHERN_~[-~ & ENVIRO~N!~' INC.
December 1, 1993
Central Transport
700 Melynda Road
Charlotte, North Carolina 28208
Re: Tank Closure Report
Central Transport
Charlotte, North Carolina
On August 9, 1993 Southern Tank and Environmental, Inc. (ST&E), was
present at Central Transport of Charlotte, North Carolina to assist
in a tank removal and closure activities. Central Transport is
located at 600 Melynda Road in Charlotte, North Carolina.
Figure 1 is an area map and provides the location of the site.
Figure 2 provides a detailed site map showing the location of the
underground storage tank (UST) it's size, contents, sample
locations and location of excavation.
Southern Tank and Environmental, Inc. was present at the Central
Transport facilities for the removal of one 4,000 gallon diesel
tank. Soils from the tank pit contained petroleum. Petroleum
contaminated soils were stockpiled on site. An estimated total of
75-80 yards of petroleum contaminated soils were stockpiled. Three
samples were collected from the tank numbered 1-3 as indicated on
the site diagram. Sample depths were approximately two (2) feet
below the tanks. Samples were placed on ice and transported to
AguaChem Environmental Laboratories for analysis. Analytical
results show that sample 3 is Below Detection Limits (BDL).
Samples l and 2 both had Hydrocarbon results above state limits.
As a result, additional soils were excavated from the tank pit.
4600 Park Rd. · Suite 1000 · Charlotte, N.C. · 28209
Central Transport
December 1, 1993
Page 2
• •
A second set of samples (1A-2A), was taken from the tank pit and
submitted for analysis. Analytical results show samples were Below
Detectable Limits. Analytical results are summarized in TABLE 1.
Complete analytical results are attached with this report.
SAMPLE
1
2
3
lA
2A
TABLE 1
Analytical Results
3550
1450
51
BDL
BDL
BDL
sample results in ppm
5030
BDL
BDL
BDL
BDL
BDL
NCDEBNR should be notified of the UST permanent closure or change-
in-service, using the attached form GW/UST-3 and submit a copy of
this tank closure report.
Southern Tank and Environmental
to be of service, and looks
Transport in the future.
Sincerely,
.~--~ }I ~7(-_;7 !.__;.f_ '
Randy Williams
President
Inc. appreciates this opportunity
forward to working with Central
Central Transport
March 26, 1993
Page 2
• •
A second set of samples (2A-6A), was taken from the tank pit and
submitted for analysis. Analytical results show samples 2A, 3A,
5A, and 6A were Below Detectable Limits. Sample 4A, taken from the
end at the motor oil tank, had a result of 1440 ppm by method 3550.
As a results, additional soils were excavated from the tank pit
area. A third sample (4B), was taken from the tank pit and
submitted for analysis. Analytical results are below detectable
limits (BDL). Analytical results are summarized in TABLE 1.
Complete analytical result:s are attached .with t:his report:.
TABLE 1
Analytical Results
SAMPLE 3550 5030
1 BDL BDL
2 72 9
2A BDL BDL
3 3370 BDL
3A BDL BDL
4 2600 BDL
4A 1440 BDL
4B BDL BDL
5 2200 28
5A BDL BDL
6 2680 86
6A BDL BDL
sample results in ppm
NCDEHNR should be notified of the UST permanent closure or change-
in-service, using the attached form GW/UST-3 and submit a copy of
this tank closure report.
southern Tank and Environmental Inc. appreciates this opportunity
to be of service, and looks forward to working with Central
Transport in the future.
Sincerely,
:·~::;-; :::,) /)/.;_..... _____.
)andy Williams
President
Central Transport
02/04/93
Page 2
LAB ID: 369F06
SAMPLE ID: 6
Parameter
TPB by 3550
TPB by 5030
•
Result Det,Limit
2680 50
86 5
Unit
PPM
PPM
•
Method
EPA 3550
EPA 5030
Date Anal. Anal.
02/02/93 LWC
02/01/93 LWC
}1_ I
~q~hem
ENVIRONMENT AL LABORATORIES, INC.
11176 DOWNS ROAD 7D4/S88-5076
')
CHAIN ""F CUSTODY
?!NEVILLE, NC_ 28134 • FAX [phone]-:14541 _ i / ~ _f ·-/ /~ /f -/ I ,r-' Client: / -,,, _,.__...,;/ / r-J,....< m...-/..._ ,)_....,,,..-:A..._i ... ...., ~·d---4-.· (_· ,....-":! v. ~~~ --·a--.1
-. I Address: ~-~-. --.:3,.,,{ 2,1 , ~.( /O<:>o
Ctty r-j{ .= c ~ £ , 1i State: /JC Zip:
Contact Person $~ '
Sampled By: / ' ) '
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Phone Number: ( 7:· -j <~ ? c' ?<;-<:"'
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Fax Number: I ) ____________ ___..;
Purchase Order Number: ___________ _
Date: //,,., h "'i
Requested Com'pletion Date: ---'.J,=-"-'"'42"'' "'---'-----
Rush Charges Authorized D Yes D No
By relinqWh'ngi !tis :Sams;ie(s) l:> la.boratory Pers.orviel', lwarraric Iha.I l am a:ulhori2ed to et'lter in.to lhis. agreement loc tie CliMI named above and 'thal I authoriz-a-the below analysis :subjecl ID lhe ierms and c:oncfitions o.n ma teYerSa hereol.
Ths a~t is gioYefne(I Cot Dons y'tbe '9'ief'S& .side-hereo!. Anal~ ~ sh al! be as induded in lhe laboraJOries fee :Sdledule fn eftecl ~1 ~tine QI !he ~.
R.uished By: /_~ ' Date: /ze Jr.~ Time: /·x.?~
Received By: ' Dale: / -..2 5--"-; Time: --' .3 Cl
Time: Relinquished By: Date: __________ _ -------RecewedBy: ______________________ _ Date: __________ _ Time:--------
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Please sign and return the white and yellow copies
to the Laboratory.
~(Chm ·· -.,/
Aqbd e LABORATORIES, ENC. 704/~~583-507r:6:2:§1~&=~~~--:==~ ~~--~)-:·=~~·~-'~•;;''~:_-_ _,,· . l!ONMENT AL F4X 704l5BB---· ~ _-1.l--r ENVI WNS ROAO , __. / "/ /./>' .. , ~7&~;JOOUE,~~NC~;28; 1;34· '.·=____,~;··~···;:::,~;-~:"''.-=::'.-~ ,[,:·:''-''.:·~-=~;~··~ ·;!;,?-'~=·/·: ·c-;=·::z;;::::;::;;::=;:;;::._ ,i'_,,. ·~ . i . .·He . Client · '-i··-/' r' //, ' -.-~ --· Address:
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CHAll'h.IF CUSTODY \__...
City !•. ,, , ... -.:::;f, State: ;J t
'~ .~ Contact Person -_ .. · -. ·,. " ·' --
Zip:; /~.']'-?
Phone Number: L_J, ___________ _
Fax Number: L_j ___________ _
Purchase 'order Number: ___________ _
Date: '
Requested Completion Date: __________ _
Sampled By: / Rush Charges Authorized D Yes D No ·
By rttlinqLisPing lhi.s sam.-{s}110 laboratory Pen.omel, I warrant :that t am au lhorized ID enw 1.nto this agreement fcx me Oienc named abow W tM1 J aulhorile lhe bekM a.nafysi.s wbied 10 tha t&nns and condi tiorls on Che revers.e he1eof.
Tli.s.aigraement is gowme.d by !he tt.rms and <xinditions t)!1 Iha 16'tel'se.slde he1eof. Anarysis charges :s.halil be ulndudf'd in. Che lal:aaxntes fee :sdledule in al1'eua1 Iha time cfU'te ~-
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Relinquished By:'-......:..t.Ji ,,_} .'. · C . .;c_,,_,,_.u.(
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Relinquished Byi--_' ---------------------
Date: _______ -:----Time: --------
Date: __________ _
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Time: ______ _
Date: _ -;1 .? . ~_,, :::.
Received By: ______________________ _ Date: __________ _ Time: --------
" Ji 4 <. 'J Oale&Tme l ill~ g g E ii:'}, ~ ! l Jlj I 1 f !/I .! J'. i i 4 ff Ni I !1 a'c.J OU df:.e:~ SanlielO S:uooled W>IO h Other Analysis F'reserv.!1NO
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Date Installed: _________ _ Time Installed: __________ _
Date Picked Up: ---------Time Picked Up: ----------
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Please sign and return !he white and yellow copies
to the Laboratory.
}T_ qCChem ~ ENVIRONMENT AL LABORATORIES, INC.
11175 DOWNS ROAD 704/588-507~
F'IHEYl_,.LLE. NC 2lU;i4 _ _ ..-----' ~ 704/568-24$4
client: ~, r ,-, ~ ,_; ·"' /c ;·,_/ -., "' /'--
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• CHAIA-vF CUSTODY
Address: ______________________________ _
City , State: Zip: ______ _
Contact Person i f~i,u J)r/ !_;/i u:._ 141><-:,
Sampled By: '-~ 11,J;;__,___.1 1'1/! ., /./~ -
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Phone Number: ( l ~ """'~;; -t 7 7 ~
Fax Number: ~ .-~~~~~~~-
Purchase Order Number: ___________ _
Oate: _________________ _
Requested Comple1ion Date: __________ _
Rush Charges Authorized 0 Yes 0 No
Sy relinqLlsfing lhis,samplB(sl tO laborat.oty .Personnel, I warrant lhat I am au lhorized io enter into ttn a(jl[Hmeflt ror lhEI Client name-cl above and Ul.al l authorize lhe bekM analysis subiect m !he t&mis and conditions M Iha ~.s.e ll&reof.
This .agr&emetl[ is ~ by ~ te!'lll!. and OOl'Wiitions on the reverse side heieof. Analysis charqes. .shalt be as tnciuded in tl'le labota1t1cies fH .schedule in effeo: a1 lhe-tnie or Che anarpi!i.
( j-+ l . Gl1 I ,,---i /if'! ~ 3 f ....-; .--:z Relinquished By:"---::'--. / ' ,__y J.A,<J-______,,:--Date: -' ""'---f ---'
Received By: <:'./'.'..-/'"/". r Date: s-r / _a ~
Relinquished By; Date:------------
Received By: ______________________ _ Date: ___________ _
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Time: _______ _
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Dale lns1alled: _________ _ Time Installed: __________ _
Date Picked Up: ---------Time Picked Up:---------
•
__, 0-.......
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Please sign and return the white and yellow copies
to the Laboratory.
• 1
Mr. A. L. Honbarrier
August 16, 1993
Page 2
• •
6. To identify potential sampling points for possible sampling
activities;
7. To review the site information and collect additional information
to address the data gaps identified during the PR; and,
8. To take photographs of all SWMUs and AOCs.
Our site visit is scheduled for September 14, 1993. The following
individuals will conduct the visit:
Mark A. Wilkins, Hazardous Waste Section
Robert c. McDaniel, Hazardous Waste Section
Harold (Bud) McCarty, Hazardous waste Section
James A. Carter, Hazardous Waste Section
Please inform us of any potentially hazardous conditions on site and
provide us with a site safety plan, if available. Please note that
photographs will be taken of SWMUs at the facility. Enclosed is a
proposed agenda of the site visit for your review.
Please contact Mark Wilkins at [phone] if you have any questions.
sincerely, ~----.f't:A fl.1--1-l?---
Jerome H. Rhodes, Chief
Hazardous waste Section
JHR/MAW/mb/7-8.93
Enclosure
cc: G. Alan Farmer, us EPA, Region IV
Hank Wade, CENCO, Inc.
Glen Simpson, CENCO, Inc.
William F. Hamner
James A. Carter
Mark A. Wilkins
•
William F. Hamner, Ph.D.
November 12, 1991
Page 2
•
background levels to the highest levels detected downgradient". 40 CFR Part 264 and 265
define this type of monitoring as detection monitoring, that is monitoring to determine if a
release of contaminants has occurred.
Once the type of monitoring has been determined, the second factor in determining the type
of statistical analysis to be performed is the number of observations below detection limits.
Because the number of observations below detection limits varied in the different
constituents analyzed, the constituents were placed into two separate groups and two
different analyses were performed.
Composition of Data Set -Wells and Sampling Dates
The upgradient bedrock wells were considered to be MW-6, MW-9, and MW-10. The
downgradient bedrock wells were considered to be MW-7, MW-8 and MW-11. These wells
were used in the analysis because they contained the most complete and reliable data set.
Ground water quality data from MW-12 was not used because of elevated pH levels
observed in the well cause the data to be suspect. Ground water quality data from MW-14
was not used because the well appears to be located at a flow divide, and is not considered
to be either upgradient or down gradient; in addition only three sets of data have been
collected from this well. An equal number of rounds of data from all wells included in the
analysis is desired, in order not to weight one well any more or less than the others.
Ground water quality data from MW-13 and MW-16 were not used because only two rounds
of samples have been collected form these wells.
Complete sampling rounds were performed on unfiltered ground water samples in 10/89,
6/90, 12/90, 3/91, and 6/91. All of these sampling rounds will be used in the analysis as
the quarterly frequency of sampling will reduce the effects of seasonal variations. Table 1
summarizes the sampling results, and the percentage of observations above detection limits
for each constituent.
Analysis Methods
Figure 1 is a flow chart taken from chapter 5 of the reference document showing the
rational for selection of the two methods used. For constituents where more than 50% of
the observations were below detection limits, but at least 10% of the observations were
above detection limits, a test of proportions was performed (arsenic, cadmium, silver and
mercury). For constituents where more than 50% of the observations were above detection
limits, a non-parametric one way analysis of variance (ANOV A) was performed (barium,
chromium, and lead). The non-parametric ANOV A was used because the proportion of
•
William F. Hamner, Ph.D.
November 12, 1991
Page 3
•
non-detects was greater than 15% and Figure 1 indicates that a non-parametric analysis
should be performed in this case. Selenium was not detected in either the upgradient or
downgradient wells.
Test of Proportions
The test of proportions determines whether the proportionate number of observations above
detections limits in the downgradient wells differ significantly from the proportionate
number of observations above detection limits in the upgradient wells. A significant
difference, defined as greater than the 97 .5 percentile from the standard curve, indicates
statistical evidence of contamination. The procedure and results of the test of proportions
is given in Table 2. Table 2 indicates that there is no statistical increase in arsenic,
cadmium, silver, or mercury in downgradient wells. It should be noted that one of the
required criteria for a constituent to be analyzed using the test of proportions is that at least
5 observations were above detection limits. This criteria is met for all the constituents
except mercury, where only 3 observations were made above detection limits. For
consistency, and because no other methods were presented for this case in the reference
document, mercury was analyzed using the test of proportions.
One-Wax Non-Parametric Analysis of Variance
The purpose of the one-way non-parametric ANOVA is to test the null hypothesis that all
wells (or groups of wells) around "regulated units" have the same median concentration of
a hazardous constituent. The procedure used in the one-way non-parametric ANOV A is
called the Kruskal-Wallis test. The procedure and results of the Kruskal-Wallis test is
summarized on Table 3. Table 3 shows that the null hypothesis holds for barium,
chromium, and lead. Suggesting there is no statistical evidence that barium, chromium or
lead contamination is present.
Conclusions
The results of the analyses performed on the unfiltered ground water samples from the
lagoons at the Charlotte facility indicate that there is no statistically significant evidence of
a release from the lagoons.
PARAMETER I
. --------
Arsenic
Bar-i Lin
C.adnii..m
~~~-i s i l
H.ercury
Seleni 1.JJ1
PARAMETER
A.rseni c
B-ar-i um
cacmiun
ctiromiuii
Lead
Silver
Mercury
'Selenim-•
~W-6
10/89 06/90 12190 03/91
Table 1
Ground ~ater Results and Wo~ of Observations Above Detection lirnits
Statistical Analysis of RCRA ~etals on Unfiltered Ground Water Samples
Central Transport, Inc ••
Charlotte, North Carolina
LIPGRADIE~T WELLS
MW-9 Mll-10
06/91 I 10/89 06{90 12190 03/91 06/91 10/89 06/90 12/90 ~o. of abservations 03/91 06/91 above detection limjts Upgradi ent (Pu)
--------------------------------------------------------------------------------------------------------------------------------------------------------------0.01 0.04 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 .<0.01 <0.01 <0.01 <0.01 3115
2.09 0.4 <0.1 <0.1 <0.1 0.28 ~.1 <0.1 <0.1 <0.1 0.48 0.16 <0.1 <0.1 <0.1 6/15
<0.01 <0.01 0.02 0.01 <0.01 0.06 <0.01 0.02 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 5115
0.41 0.08 0.01 0.01 0.07 0.06 <0.01 0.02 <0.01 0.02 0.17 0.04 0.02 <0.01 <0,01 11/15
0.26 0.08 0.03 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 0. 15 0.02 0.03 <0.02 0.04 6115
<0.01 0.09 <0.01 0.01 <0.01 <0.01 0.07 <0.01 <0.01 <0.01 <0.01 0.04 <0.01 <0.01 <0.01 4/15
<0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 0115
<0.01 <0.01 <0.01 <0.01 <0.01 <0,01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0/15
DtllmGRADIE~T WELLS
HW·7 !114·8 MW-11 No* of observations
10/89 06/90 12/90 03/91 06/91 \0/89 06/90 12/90 03/91 06/91 10/89 06/90 12{90 03/91 06/91 above detection limits
Upgradient (Pd)
----------------------------------------------------------------------------------------------------------------------------------------------------------------0.1 0.13 <0.01 <0.01 <0.01 0.04 <0.01 <0.01
1.14 0.87 <0.1 0.12 0.82 2.11 0.1 0.56 <0.01 <0.01 0.02 0.01 <0.01 <0.01 <0.01 0.01 0.58 0.21 0.08 0.04 <0.01 2.65 <0.01 1.8
1.45 0.32 0.17 0.08 0.05 0.06 <0.02 <0.02
<0.01 0.15 <0.01 <0.01 <0.01 <0.01 0.08 <0.01 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 0.003
<0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
<0.01 <0.01 <0.01 <0.01 <0.01
0.12 <0.1 0.19 0.37 0.65
0.02 <0.01 <0.01 <0.01 0.01 1-28 0.02 <0.01 0.16 0.2
<0.02 <0.02 <0.02 0.04 0.1 <0.01 <0.01 <0.01 0.04 <0.1
0.004 0.0028 <0.0005 <0.0005 <0.0005
<0.01 <0.01 <0.01 <0.01 <0.01
<0.01
0.2
0.01
0.04
<0.02
<0.1
<O. 0005
<0.01
<0.01 3115 <0.1 12/15
0.01 7115
0.78 12115
0.03 9115 <0.1 3115
<0.0005 3/15
<0.01 0/15
Total Observations
PARAMETER I above detection limits
Arsenic
Sari'l.ITI
t:adni IJl1
Chromillll
Lead
Silver-
Mercur-y
SeleniUTI
~o. X
6/30
18/30 12/30
23/30 15/30
7/30 3{30
0/30
20
60
40
77
50
23
lO
0
Table 2 Method of Proportions
Statistical Analysis of RCRA ~etals on Unfiltered Ground Yater SalJlliles Central Transport, lnc •.
Charlotte, Horth Carolina
x = nllri:Jer of upgradient wells in which constituent was detected
y = nurber of downgradient wet ls in which constituent was detecttd
n =total ntnber of upgradient we\ Ls analyzed
m = total ntllber of down.gradient wells analyzed
Pu= x/n =proportion of observations above detection limits in upgradient wells
Pd= y/m =proportion of obser-vations above dete.ction limits in downgradient wells
• {[(• + y)/(n + m)J
Z = (Pu -Pd)/SO
[1 -ex + yJ/(n + mll E1/n + \/ml J '1/2 = standard err<>r of the difference in proportions
The calculated value of z is c~red to 97.5th pereentile form the standard normal distribution, 1.96.
If the absolute value of Z exceeds 1.96m this provides statistically significant evidence at the SX significance level
that the proportion of downgradient wells samples wliere the c~ was detected exceeds the proportion of upgradlent wells
where the constituent was detected. This would be interpreted as evidence ofcontamination.
No~ of observations No. of observations Standard Error Z Statistic rs absolute value of z !Statistical Evidence of PAR~METERI above detection \imits above detection limits (SD) (Z) greater than 1.96? Contami nat Jon
Upgrad; ent (Pu) Upgradient (Pd)
·---·--·-1··-····--·---·---·--·-·---··-···--·-··--···--···-·· ---······-····-· . --·. -·· .. --. ···---·-···--··-···--··-·-----··----··---··--·--·-
.ic 3/15 3/15 0.146 0 no no
· Liii ;115 7/1S 0.179 ·0.949 no no
r 4/15 3/15 0.167 ·0.18 no no Mercury 0/ 15 3/\S 0.109 1.82 no no
Poge 1 of 2
K = the nurber of observations in each group
ni : the nurber of observations in the ith group
N : total n~r of all observations
Ri = slJll of the ranks of the ith group
K
Table 3
One Yay Non·Parametric Analysis of Variance
Statistical Analysis of RCRA Metals on Unfiltered Ground Mater SEMJ1>les
Central Transport, Jnc •.
Charlotte, North Carolina
H = {{12/H(H + Hl I SIGMA (Ri~2/Hi)]} · 3CN + 1 l = the Kruskal-Wil l is statistic
i =1
1. Rank all N observations of the gr0\4ls from the least to the greatest
As a convention, the upgradient well observations wilt all be put lnto one group~
2. Add the ranks of the observations in each group.
3. C~te the Kruskal-Wallis Statistic
4. c~re the calculated value of H to the tabulated chi·squered value with (K-1) degrees of freedom
Using Table 1 from Apperdix B of the refernce doclJllOnt, with 3 degrees of freedom at the 5X significance level this value equals 9.348.
~ the c~ted value exceeds the chi-squared value, reject the null hypothesis.
NOTE: [n the case of observatfons at the same value, determine the ranks the tied observations would have received if they
had been slightly different from each other, but still in the same place with respect to the other observations. Add these ranks and divide by the nL.lllber of observations tied to get an average rank.
For exSl!l"le: If there are three observation• tied at 0.2, that would of had a rank of 4, 5 ard 6 ff they had been slightly different
The three observations would all be given the rank of S, the result of ave-raging 4,SJ and 6.
RESULTS OF ONE-WAY NOH-PARAMETRIC Al/OVA
The concentration of each SB111>te is gtven on the left and the rank of that sa111>le fs given in parenthesis
•
BARIU~ N = 30 ~ = 4
10/ 89 06/90 12/911 03/91 06/91 C D Upgradi ent Mel ls I Group fl I ni I R i I
lconc. Rank lcOl'lc. Rank lconc. Rank lcorc. Rank Jeane. Rank
--··---------+------------+------------+-----··-----+------------+··-------·--+·-------+--·---··+--·--·--+
Hl/·6
Hl/·9
Hll· 10
2.09 (29)
0.28 (20)
0 .48 (23)
0.4 C22l l<0.1 (6.5) l<0.1 (6.5J l<O .1 (6.5) 0.1 (13.5) <0.1 (6.5) <0.1 (6.5) <0.1 (6.5) 0.16 (17) <0.1 (6.5) <0.1 (6.5) <0.1 (6.5)
15 183
Downg rodi ent Mells I Group # I ni I R i I
10/89 06/90 12/90 03/91 06/91 ( i) lconc~ Rank lconc. Rank lconc. Rank lconc. Rank lconc~ Rank ····-----·-·-+·--·---·----+------------+----·--·----+------··----+---··--·--··+------·-+·-------+·-----·-+
Ml/· 7
~M-8
~W· 11
1.14 (27)
2.11 (30)
0.19 (18)
0.87 (28) 1·0.1 (6.5) 10.12 (15.5)10.82 0.1 (13 .5) 0.56 <24) 0.12 ( 15. 5) <0.1
0.37 (21) 0.65 (25) 0.2 (19) <0.1
(26)
(6. 5)
(6.S)
2
3
4
5
5
5
H = {!12/(30 x31)1 [((183'2)/15) + ((103'2)/5) + ((89.5'2)/5) + ((89.5'2)/5)]) -(3 x 31) = 4.516
103
89.5
89.5
4.516 < 9.348, therefore the ...,ll hypothesis C all wells ar<l<l:>d the lagoon have the same median concentration) holds
Page 2 of 2
•
•
CHROMIUM
Table 3
One Way Non-Para1110tric Analysis of Variance
Statistical Analysis of RCRA Metals on Unfiltered Grocnd Water s...,tes Central Transport, Inc ••
Charlotte, North Carolina
10/ 89 06/90 12/90 03/91 06/91 ( il Upgradi ent Wells I Group # I n! I Ri I
Iconic. Rank tcor.c. Rank lcanc~ Rank lconc. Rank lconc. Rank -------------+------------+------------+------------+------------+------------+--------+--------+--------+
Ml/·6 MW·9 MW-10
0.41 (25)
0.06 (16)
0.17 (22)
0.08 (18.5)10.01 (6.5) 10.01 (6.5) 10.07 (17) <0.01 (3) 0.02 (9.5) <0.01 (3) 0.02 .(9.5)
0.04 ( 13) 0.02 (9.5) <0.01 (3) 0.05 (15)
10/89 06/90 12/90 03/91 06/91 ( iJ
1
1
1
15 1n.5
Downgrodi ent Wells I Group # l n 1 I R 1 J
)cone. Rank lconc. Rank ]cone. Rank lconc. Rank lconc. Rank
-------------+------------+------------+------------+------------+------------+--------+--------+--------+
Ml/· 7
Mll-8
MW-11
0.56 (26)
2.65 (30)
<0.01 (3)
0.21 C24J <0.01 (3)
0.16 (16)
0.08 (!8.5)10.04 (13) 1.8 (29) 1.28 (28)
0.2 (23) 0.04 (13)
<0.01 (3)
0.02 (9.5)
0. 78 l27J
2
.3
4
5
5
5
101.5
99.5
67
H = 4.24; 4.24 < 9.348 therefore null hypothesis holda
LE/di
10189 06190 12190 03191 06191 c n Upgrodient Wells IGr<>up # ! ni I RI j
lconc. Rank lconc. Rank leonc. Rank lconc. Rank lconc. Rank -------------+-----~------+-~---·------+·--~---~·--~+---~---~~---+----·-------+---~--~-+-------~+--------+
Ml/·6 MW·9
Ml/· 10
0.26 C28J 10.08 (23.5)10.03 C17J l<0.02 (7.5Jl<0.02 (7.5) <0.02 (7.5) <0.02 (7.5) <0.02 (7.5) <0.02 (7.5) <0.02 (7.5)
0.15 (26) 0.02 (15) 0.03 (17) <O.OZ (7.5J 0.04 C19.5J
Oowng radi ent lle\l •
10/89 06/90 12/90 03/91 06/91 (i )
1
1
1
15 194
IGroup # ) n! I Ri
!cone. Rank lconc. Rank lconc. Rank lconc. Rank lconc. Rank I
~---~--------+-----~------+-~---~--~---+~------~----+-------~----+----~---~---+~-------+~--~---~+--~-----+
Ml/· 7
Ml/·8
Mii· 11
1.45 (30) 10.32 (29) 10.17 C27J 10.0B C23.5JI0.05 (21) 0.06 (22) <0.02 (7.5) <0.02 (7.5) <0.02 (7.5) <0.02 (7.5)
<0.02 (7.5) 0.04 (19.5) 0.1 (25) <0,02 (7.5) 0.03 (17)
H = 5.11; S.11 < 9.348 therefore null hypothesis holds
2
3
4
5
5
5
130.5
51
76.5