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HomeMy WebLinkAboutSF_F_NCD986178226_20170316_FRB_PASI ROY COOPER Governor MICHAEL S. REGAN Secretary MICHAEL SCOTT Director March 16, 2017 Ms. Carolyn Callihan, RPM Superfund Restoration and Site Evaluation Section Superfund Division US EPA Region IV Waste Division 61 Forsyth Street SW, 11th Floor Atlanta, GA 30303 Subject: Preliminary Assessment (PA) Report Texfi Blends, Inc. (a.k.a., Texfi Industries) NCD 986 178 226 Fayetteville, Cumberland County, NC Dear Ms. Callihan, Under authority of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and the Superfund Amendments and Reauthorization Act of 1986 (SARA), the NC Superfund Section conducted a Preliminary Assessment (PA) at the above site. The purpose of this investigation was to collect information concerning conditions at the site sufficient to determine the need for additional CERCLA/SARA or other appropriate evaluation. Based on the results of this investigation, this site is recommended for no further action under CERCLA The scope of this investigation included reviews of transcripts of three EPA Technical Support teleconferences (January-March 2002), a Site History and Site Summary (March 2001 to August 2014) by the NC Superfund Inactive Hazardous Sites Branch (IHSB, October 2, 2014), and a contractor’s 2016 pilot remediation study, as well as discussion of subsequent site activity and current site status with NC IHSB personnel. Site Description, Regulatory History and Waste Characteristics: The site is a former textile manufacturing facility located on the west bank of the Cape Fear River in Fayetteville NC. Site geographic coordinates are 35.0842 o N Latitude and -78.8674 o West Longitude (Ref. 3). The City of Fayetteville Public Works Commission (PWC) Hoffer Water Treatment Plant abuts the former Texfi property on the south side, and the city purchased the Texfi property following bankruptcy settlement. Land within 0.25 mile to the north and west of the Texfi facility is undeveloped, with Clark Park and residential neighborhoods farther in those respective directions. The former Texfi plant is vacant and in disrepair, having undergone partial demolition (Refs. 4, 7 (Figs.1-3); Attachment 1). Texfi Industries, NCD 986 178 226Preliminary Assessment, 03/16/2017 Page 1 of 9 State of North Carolina | Environmental Quality | Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919 707 8200 Ms. Callihan March 16, 2017 Page 2 The site consists of areas within the above properties that are underlain by contaminated soil and/or groundwater. Contaminants include chlorinated volatile organic compounds (VOCs) formerly used in Texfi facility operations. VOC contamination was also detected in an intermittent drainage ditch which runs east toward the Cape Fear River along the southern Texfi property line. Detected VOCs included tetrachloroethene (PCE), trichloroethene (TCE), cis-1,2-dichloroethene (cis-1,2-DCE), trans-1,2- dichloroethene (trans-1,2-DCE) and vinyl chloride (Attachment 1; Refs. 6, 7). The Hoffer Water Treatment Plant includes a Clear Well, a 14-million-gallon covered cement reservoir constructed approximately 7 feet above and below ground surface (Figs 2-3). The Clear Well is used to store treated drinking water prior to the latter’s distribution to the Fayetteville municipal system. During normal operation, the water elevation inside the Clear Well is higher than that of groundwater in the surrounding surficial aquifer. During maintenance periods when the Clear Well was empty, groundwater was historically observed seeping into the structure. A toe drain system was installed around the periphery of the Clear Well in 1996. The bottom of the drain lies below average groundwater elevation and reportedly lowers groundwater levels adjacent to the Clear Well. Although seasonal high groundwater levels reportedly still exceed the Clear Well floor elevation, no subsequent instances have been reported of groundwater seepage into the Clear Well (Attachment 1; Refs. 6, 7, 8, 11). Water in the operational Clear Well was sampled for VOCs weekly from 2001 through 2003 and then monthly/bimonthly up to the present time. Sampling has detected halomethanes associated with the water treatment process. One sample collected in May 2001 contained a trace detection of PCE and low ug/l concentrations of benzene, toluene and xylene. Two other samples, collected in March 2012 and January 2014, contained 0.7 and 1.0 ug/L PCE, respectively. However, results from re-sampling shortly after both events were non-detect. No other VOC detections have occurred in water samples from the operational Clear Well, and the above PCE results did not exceed the 5 ug/L Maximum Contaminant Level (MCL) (Attachment 1; Refs. 6, 7, 8, 11). In 2001, NC DENR contractors (Camp, Dresser and McGee, Inc.) installed a slurry wall north and parallel to the property line between Texfi and the Hoffer treatment plant, and installed a groundwater recovery well system at the Hoffer plant, northeast of the Clear Well and downgradient from the slurry wall. The recovery well system was shut down in 2009, in part due to funding constraints, but also to reduce the diversion of contaminated groundwater into proximity with the Clear Well (Attachment 1; Ref 6, 7 (Fig 3). In 2007, asbestos contractors conducted a survey within a building demolition area near the center of the Texfi property. Thirty-six samples were collected from suspect building materials and debris piles. Thirty-four samples were non-detect for asbestos. Two samples, collected from a 100-by-25-foot debris pile on the structure floor, contained asbestos concentrations of <1% and 2.0%, respectively. The definition criterion for asbestos-containing material was 1%. The contractor recommended removal of the material (Ref. 9). Texfi Industries, NCD 986 178 226 Preliminary Assessment, 03/16/2017Page 2 of 9 Ms. Callihan March 16, 2017 Page 3 In 2008, NCDENR remediation contractors (Hart and Hickman, Inc.) injected a reductive bioremediation agent (HRC) into the surficial aquifer at the former Texfi facility. Targeted areas included the former dye storage room in the central plant and a drum storage area to the north. In 2009, subsequent groundwater monitoring up gradient from the slurry wall documented reduction of PCE and other VOC concentrations by two orders of magnitude (Attachment 1). In 2009, the City of Fayetteville submitted a Brownfields application for the former Texfi Industries property, and the NCDENR NC Brownfields Program issued a letter of eligibility for the brownfields program to the city. In 2012, a contractor for the City (Duncklee & Dunham) submitted a risk analysis which concluded that water quality in the Clear Well had not been impacted by the site’s groundwater plume and was at minimal risk, provided that sufficient water level was maintained in the Clear Well by voluntary agreement (Ref. 10 D&D) In 2012, NCDENR remediation contractors (Hart and Hickman, Inc.) injected a reductive bioremediation agent (HRC) into the surficial aquifer at 77 location points located northeast of the Clear Well. Groundwater monitoring in 2013 documented significant decreases in PCE concentration in the HRC treatment area, although concentrations of cis-1,2-DCE (a PCE breakdown product) remained elevated and variable in the monitoring wells. The residual contamination was believed to result from VOC retention by a shallow clay layer beneath the surficial aquifer (Attachment 1; Refs. 6, 7). In 2014, PWC sampling detected 1,4-dioxane (a contaminant associated with chlorinated VOCs) in surface water in the Cape Fear River and in point-of-entry samples at the operating Clear Well. 1,4- dioxame was also detected in samples from Texfi and Hoffer plant monitoring wells near the Clear Well. However, 1,4-dioxane was not detected in other monitoring wells in the central Texfi facility, where aqueous or free product VOCs were present. Therefore, the substance likely entered the clear well via the surface water intake. The source for 1,4-dioxane was suspected to be industry (as yet unidentified) located upriver on the Cape Fear and its tributaries (Attachment 1; Ref. 6). In 2014, NCDEQ remediation contractors (Hart and Hickman, Inc.) excavated/removed approximately 140 tons of VOC-contaminated soil and 18,400 gallons of VOC-contaminated standing surface water from a 50-foot interval of the intermittent drainage ditch along the southern Texfi property line. The soil was treated on site by mobile steam distillation unit, then removed from the site for further treatment and disposal. The water was removed from the site in a frac tank and disposed of at a licensed hazardous waste Treatment, Storage and Disposal facility (Attachment 1; Ref. 7). The NCDEQ consultant’s state contract expired in August 2014. The NCDEQ used available Orphan Site funding to retain a second contractor (S&ME). The second contractor conducted two additional sampling events in August and October 2015, sampling water from the Clear Well toe drain and at former recovery wells northeast of the Clear Well. (Attachment 1; Ref. 7). Texfi Industries, NCD 986 178 226Preliminary Assessment, 03/16/2017Page 3 of 9 Ms. Callihan March 16, 2017 Page 4 The PWC conducted sampling at the Clear Well and on the Cape Fear River at intervals during 2014 and 2015, and conducted eight sampling events in 2016. PCE (1.72 ug/l) and cis-1,2-DCE (1.07 ug/l) were detected in the Cape Fear River upstream from Texfi in February 2014. PCE (2.37 ug/l) and cis-1,2-DCE (1.10 ug/l) were detected downstream from Texfi in January 2015. Methylene chloride was detected upstream from Texfi in November 2016, and toluene was detected below Texfi in December 2016. No detections occurred at the intake or in the Clear Well on these dates. A water sample colledted at the intake in March 2012 contained 1.9 ug/L PCE. However, when the intake was re-sampled one week later PCE was non-detect. To date, no site groundwater contaminants have been detected in the river or intake at concentrations exceeding their respective MCLs, and no other VOCs (except for halomethanes) have been detected during monitoring in the Cape Fear River near the site (Refs. 6, 8, 10, 11). In October 2016 consultants for the City of Fayetteville (Duncklee & Dunham) completed a remedial pilot study plan and conceptual site model to determine the feasibility of using solar-powered electrolysis for continued groundwater remediation at the site (Refs. 6, 7). Previous EPA Investigations: During 2002 and 2003, an EPA Emergence Response and Removal Branch (ERRB) and Superfund Technical Assistance and Response Team (START) contractor performed a Removal Site Evaluation at the Texfi Property. In July 2002, the START contractor collected 44 surface (1.5-2.0 feet) and subsurface (3.5-4.0 feet) soil samples at the site. The START returned to the site in January 2003 and collected 37 additional surface and subsurface soil samples. Detected sample PCE concentrations ranged up to 1.1 mg/kg in surface soil and 2.6 mg/kg in subsurface soil. Highest PCE concentrations occurred near the former Texfi PCE distillation unit. Total VOCs ranged up to 21.88 mg/kg in surface soil and 21.66 mg/kg in subsurface soil. Highest total VOC concentrations occurred beneath the southeast corner of the Texfi plant building (Ref. 12). The START contractor collected 5 groundwater samples from on-site monitoring wells and 2 water samples from the Clear Well’s toe drain system and outfall. Each of the samples contained detectable VOCs, including PCE. However, surface water samples which the START collected from the Cape Fear River were all non-detect, despite the fact that the river was at base flow (therefore having minimal dilution potential) at the time of sampling. The drainage ditch parallel to the Texfi south property line was not flowing at the time of the investigation, containing only a small pool at its upper end; the EPA characterized it as “an ephemeral stream of limited areal extent”. The START contractor collected two sediment samples from the western (upper) and eastern (lower) ends of the drainage ditch within the Texfi facility. The western sample contained VOCs (308 ug/kg total) including PCE (13 ug/kg); the eastern sample, 100 feet downgradient, was non-detect for VOCs (Ref. 12). Texfi Industries, NCD 986 178 226 Preliminary Assessment, 03/16/2017 Page 4 of 9 Ms. Callihan March 16, 2017 Page 5 The ERRB described the intermittent potential for groundwater to infiltrate the emptied Clear Well. However, the ERRB noted also that static groundwater level in the groundwater plume proximal to the Clear Well was lower than the bottom of the structure, likely due to the toe drain and other remedial measures taken at the site. Citing limited groundwater receptors, the absence of contamination in the Cape Fear River and the limited potential for human exposure to contaminated soil, the ERRB recommended the site for no further removal action status (Ref. 12). Groundwater Pathway and Targets: The site is located within North Carolina’s Coastal Plain physiographic province. The surficial geologic unit beneath the site consists of fine to coarse-grained sand with occasional gravel and some interbedded silt and silty clay. Previous investigations indicate that the surficial unit ranges from 8 to approximately 12 feet in thickness beneath the site. Beneath the surficial unit lies the upper confining unit of the Cretaceous Cape Fear Formation, consisting of dark gray stiff to hard clays and silts with some argillaceous (clayey) sands. Groundwater within the surficial (aquifer) unit is typically encountered at 4 to 6 feet depth below ground surface, under unconfined conditions (Ref. 14). Based on previous investigations, groundwater in the surficial aquifer flows naturally in a south to southeast direction, discharging ultimately to the nearby Cape Fear River during normal river flow (Refs 6, 7). The Hoffer Water Treatment Plant is the primary source of drinking water for the City of Fayetteville. Cumberland County Geographic Information Service (GIS) database indicates that municipal water lines supply the entire developed area within a 4-mile radius from the site, including the nearest residences located 0.25 mile west-northwest of Texfi (Ref. 4). The population served full time in 2016 was 205,383 (Ref. 5). NC Water Quality GIS database reports no (non-transient) community wells operating in the 4-mile radius (Ref. 15). Surface Water Pathway and Targets: Surface runoff from the site flows to the east-west drainage ditch that runs parallel to the property line between the former Texfi facility and the Hoffer Water Treatment Facility. The intermittent ditch runs east to the west bank of the Cape Fear River, which is the Probable Point of Entry (PPE) to the 15-mile Surface Water Pathway. The Cape Fear River at Fayetteville reportedly flows at a mean rate of 5000 cubic feet per second (Refs. 4, 13A, 13B, 13C). The surface water intake for the Hoffer facility is located downstream from the PPE on the west bank approximately 500 feet south of the shared property line. No other public water intakes are located within 15 miles downstream from the site (Refs. 7, 15). The Cape Fear River in general is used for recreational/subsistence fishing, although aerial images indicate limited accessibility near the site. The 15-mile surface water pathway along the Cape Fear River contains approximately 4.8 miles of mapped palustrine wetland frontage (Ref. 16). Texfi Industries, NCD 986 178 226Preliminary Assessment, 03/16/2017 Page 5 of 9 Ms. Callihan March 16, 2017 Page 6 Clear Well Target Eligibility under Hazard Ranking System: Based on discussions with the USEPA in 2002, regarding the EPA’s Hazard Ranking System, the Clear Well qualifies as neither 1) a Groundwater Target (receptor), such as an aquifer or public water- supply well, or 2) a Surface Water Drinking Water Intake. According to the EPA, an aquifer is defined as a geologic formation whose physical characteristics allow it to yield economically significant quantities of groundwater to wells or springs, and a well is similarly defined as a constructed point of withdrawal from such an aquifer. The Clear Well, by contrast, receives water originating from a surface water intake on the Cape Fear River and processed by the Hoffer plant; the Clear Well’s physical design was intended to retain treated water when filled, and to prevent (or limit) groundwater infiltration when empty. The toe drain system installed around the periphery of the Clear Well in 1996 reportedly drains away adjacent groundwater and lowers the average local water table elevation to less than that of the Clear Well floor. Therefore, future seepage of significant quantities of contaminated groundwater into the emptied Clear Well is considered unlikely, and any subsequent seepage episode that did occur would be discontinued and diluted by orders of magnitude when Clear Well operation resumed. Water-quality monitoring results from the operational Clear Well do not support VOC contamination of the supply resulting from proximity to contaminated groundwater. According to the EPA, the Clear Well is an artificial impoundment used as a source of treated drinking water, but differs from other surface-water bodies in that it is not part of a drainage system, as would be a river segment or a natural or man-made lake. Rather, the Clear Well is the end of a treatment process whose source is the raw surface-water intake on the nearby Cape Fear River. A typical EPA Surface Water Pathway evaluation would consist of assessing the migration of site contaminants to an entry point along the river, and subsequent migration to downstream targets, such as intakes, fisheries or wetlands. Migration to surface water can occur either via direct surface runoff or by discharge of contaminated groundwater from the adjacent aquifer to the river. In contrast, no surface runoff occurs from the site directly to the Clear Well interior, and significant future discharge of contaminated groundwater to the Clear Well is considered unlikely, as discussed above. Potential for Further Action designation under the EPA Hazard Ranking System: Two contaminant sources exist at the site: Groundwater contaminated with chlorinated VOCs (Volume: > 0 but unknown) and a waste pile contaminated with Asbestos (Area: 2500 sq ft). The Hoffer treatment plant’s Cape Fear surface water intake is a potential surface water receptor (population 205,383 (Ref. 5)) if site VOC contamination migrates to the Cape Fear River. However, routine sampling in the Cape Fear River has resulted in only isolated detections, below MCLs, of chlorinated VOCs. Contaminants were non-detect in the intake and Clear Well during most of the same events. The Cape Fear River’s mean annual discharge (~5178 cfs, Refs 13A-13C) would result in a considerable dilution for potential pathway receptors (drinking water population; fishery consumption; environmental receptors). Texfi Industries, NCD 986 178 226Preliminary Assessment, 03/16/2017 Page 6 of 9 Preliminary Assessment References: 1)US EPA 40 CFR Part 300, Hazard Ranking System, Final Rule, Federal Register Volume 55, No. 241 Part II, December 14, 1990. 2)Superfund Chemical Data Matrix, Revised March 2012. 3)Zinn, Harry, NCDENR, Division of Waste Management: Texfi Latitude and Longitude Calculations per CERCLA, October 20, 2001. 4)Cumberland County Geographic Information Service (GIS) Data Viewer 2: http://www.co.cumberland.nc.us/is_technology/gis.aspx 5)NC Public Water Supply Section Water Supply Plan, Fayetteville, NC http://www.ncwater.org/Water_Supply_Planning/Local_Water_Supply_Plan/report.php?pwsid= 03-26-010&year=2016 6)Snavely, Keith; Parker, Stuart, NCDEQ Superfund Section, verbal communications, February 16- March 14, 2017. 7)Duncklee & Dunham, P.C., Cary, NC: “Remedial-Design Data Collection Work Plan for a Solar- Powered Remedial Strategy, Former Tex-fi Facility, 601 Hoffer Drive, Fayetteville, North Carolina, Site ID: NCD986178226”, prepared for City of Fayetteville Engineering and Infrastructure Department, Fayetteville, Cumberland County, North Carolina, October 27, 2016. Available for review at: http://edocs.deq.nc.gov/WasteManagement/Search.aspx?cr=1 8)City of Fayetteville NC Public Works Commission: Progress monitoring (Laboratory analytical) reports on water quality monitoring at the Clear Well, Cape Fear River and Effluent (various dates, ending December 27, 2016). S&ME, Inc. Raleigh, NC: Progress monitoring (Laboratory analytical) reports on water quality monitoring at Clear Well Toe Drain and at monitoring wells MW24C and MW-27C, August 10 and October 16, 2015. Available for review at: http://edocs.deq.nc.gov/WasteManagement/Search.aspx?cr=1 9)Hart & Hickman, Charlotte, NC: Letter report to NC DENR Re: Asbestos Survey (Demolition Area), Former Texfi Facility, Fayetteville, North Carolina, H&H Job No. TEX-001, December 28, 2007. 10)Duncklee & Dunham Environmental Geologists and Engineers: “Evaluation of Risk to the Public Works Commission Clearwell, 601 Hoffer Drive, Fayetteville, North Carolina”, Texfi BF Project # 13017-09-26, August 16, 2012. Texfi Industries, NCD 986 178 226Preliminary Assessment, 03/16/2017Page 8 of 9 11)Smith, Chris, Fayetteville PWC, e-communications to Keith Snavely, NCDEQ, December 27, 2016 and February 27, 2017. Snavely, Keith, NC Superfund Section, e-communication to Stuart Parker, NC Superfund Section, March 14, 2017. 12)US EPA Region 4, Emergency Response and Removal Branch: “Initial Pollution Report/RAT Notification Recommendation for No Further Planned Removal Activity”, Removal Site Evaluation, Texfi Industries (NCD0001075), Fayetteville, North Carolina, April 17, 2003. 13)A: “Drainage Areas of Selected Sites on Streams in North Carolina” US Geological Survey Open File Report 83-211, 1983. B: “Map of Mean Annual Runoff for the Northeastern, Southeastern and Mid-Atlantic United States, Water Years 1951-1980” US Geological Survey Water Resources Investigations Report 88-4094, 1988. C: Parker, Stuart F, Hydrogeologist, NCDEQ, Superfund Section, Memorandum to File: Cape Fear River Mean Annual Flow at Fayetteville, NC, March 18, 2017. 14)Solutions Industrial and Environmental Services, Inc., Raleigh, NC: “Environmental Site Assessment for Texfi Industries, Fayetteville, North Carolina, NONCD0001075”, August 23, 2004. 15)North Carolina Source Water Assessment Program SWAPInfo2.0 GIS Mapping Tool: nc.maps.arcgis.com 16)US Fish and Wildlife Service, National Wetlands Inventory On-line Mapper: http://wetlandsfws.er.usgs.gov/. Texfi Industries, NCD 986 178 226 Preliminary Assessment, 03/16/2017 Page 9 of 9 FIGURES (from Reference 7) ATTACHMENT 1: Texfi Site History and Site Summary (2014) Keith Snavely, Hydrogeologist, NC DEQ Superfund Section, Inactive Hazardous Sites Branch TEXFI INDUSTRIES SITE HISTORY AND SITE SUMMARY The Texfi Industries site, a former textile finishing plant located at 601 Hoffer Drive in Fayetteville NC, comprises approximately 95.6 acres with a 210,000 square foot building that is abandoned and partially demolished. The site contains five (5) above ground storage tanks, used for fuel and manufacturing chemicals, and a waste equalization basin. The former textile dye and finishing plant began its operations in 1968 and ceased operations in 2000 due to bankruptcy. The site is bordered on the east by the Cape Fear River, on the south by Fayetteville’s Public Works Commission (PWC) Hoffer Water Treatment Plant, to the north by the City of Fayetteville’s Clark Park and to the west by a CSX railroad line and residential homes. PWC contains a “clearwell” or finished drinking water tank that provides municipal drinking water for the City of Fayetteville and is located 200 feet south of the former manufacturing building. The clearwell (14 million gallon concrete structure) is partially constructed below grade and is surrounded by a french drainage system at its base called a toe drain. The water treatment plant uses water from the Cape Fear River which is captured by a surface water intake controlled by PWC that is located approximately 500-600 feet southeast of the former Texfi Plant. The groundwater on the Texfi property and on PWC property, primarily in the northeast corner of the clearwell, is contaminated with chlorinated solvents: tetrachloroethene or perchloroethene (PCE) and its daughter products cis and trans 1,2 dichlorothene, trichloroethene and vinyl chloride. These compounds were noted in groundwater in the year 2000 after a brownfield investigation was conducted on the former Texfi Property. A follow-up investigation/interim measures action by the NC Division of Waste Management (DWM) was initiated in 2001. DWM contracted Camp Dresser and McKee (CDM) in March 2001- for $600,000 to implement emergency measures at the site. The interim action involved the installation of additional groundwater monitoring wells, groundwater extraction/recovery wells (RW-1, RW-2 and RW-3), a groundwater sampling plan of the clearwell, surface water sampling and most importantly- a groundwater barrier wall extending to a depth of approximately 10 to 13 feet (to the top of a clay layer) below ground surface. This groundwater barrier was constructed to prevent additional groundwater contamination from the plant’s suspected source areas (dye and finishing room and tetrachloroethene distillation unit location) from reaching PWC property. Refer to the chronology listed below for details of the site actions: Chronology: March 2001-May 2001- Installation of groundwater barrier wall and three extraction/groundwater recovery wells; implementation of weekly sampling of clearwell; sampling of effluent from groundwater extraction well system; sampling of existing monitoring wells; sampling of surface water from on-site drainage ditches; sampling of Cape Fear River and sampling discharge of groundwater from the clearwell’s toe drain was conducted. Funding for the interim action contract with CDM consultants came from existing funds in the Inactive Hazardous Sites Branch Cleanup fund. Att. 1 Page 1 of 8 Att. 1 Page 2 of 8 Investigations in May 2001 and from previous assessments (in the above ground storage tank area) indicate groundwater is contaminated with PCE and its daughter products trichloroethene, cis and trans 1,2 dichloroethene, and vinyl chloride on the Texfi and PWC properties. Additionally, the dye carrier compound, 2-chlorotoluene was also found in groundwater near the above ground storage tank area on the Texfi plant property. Contaminant levels as high as 150 ppm of total volatile organic compounds in groundwater exist for PCE and 2-chlorotoluene compounds. Groundwater contamination is known to exist in the shallow aquifer down to 10- 13 feet below ground surface. There were no detections of contaminants in the Cape Fear River and no detections of contaminants in the drinking water from PWC’s clearwell. May 2001-December 2003: Weekly sampling of clearwell, monthly testing of effluent from groundwater recovery extraction wells RW-1, RW-2 and RW-3, and periodic sampling of existing monitoring wells on Texfi and PWC properties. December 2003- December 2006 - Clearwell tested once a month, periodic sampling of existing monitoring wells and effluent monthly sampling from recovery wells has continued. January 2007- November 2007- Continued monthly testing of clearwell, periodic sampling of existing monitoring wells, monthly testing of effluent from groundwater extraction system continued. Bankruptcy funding (approximately $941,000) from Texfi bankruptcy settlement received and encumbered in order to begin remedial actions at Texfi. Source Removal Contract for the Texfi Industries property awarded to Hart & Hickman (H&H) on August 7, 2006. Waste Removal Activities on the Texfi Plant by H&H and pilot study of HRC-A injection in the former Dye Room area of the Texfi Plant completed. CDM continues with monthly sampling of clearwell and monthly sampling and maintenance of groundwater recovery/extraction system. Work plan by H&H completed to survey monitoring well network (old and new monitoring wells). Demolition conducted to safely install test wells in the plant for future groundwater injection event of HRC-A compound, work plan for full scale implementation of HRC-A injection submitted. Demolition involved some asbestos issues that were properly regulated and removed. October 2007- April 2008- Continued monitoring of clearwell by CDM consultants, H&H Work Plan complete for implementation of HRC-A injection. Injection to involve two areas – Plant (dye room area) and drum storage area located outside and north of Plant. No work to be conducted on 2-Chlorotoluene plume. 2- Chlorotoluene somewhat recalcitrant to HRC injection. Several phases of oxidation are required to remove 2- Chorotoluene. Insufficient funding available for cleanup by oxidation May 2008- December 2008 Implementation of full scale enhanced bioremediation using injection of HRC-A by Hart & Hickman consultants; demolition of portions of building; installation of new test wells and monitoring points for injection project. Sampling of monitoring wells and injection area results. Continued monitoring of clear well and extraction system by CDM consultants. Quarterly sampling of monitoring wells in injection area began after first injection. After quarterly sampling for one year, reduce sampling frequency to once a year. Approximately 50 monitoring wells exist on Texfi site (Texfi and PWC properties). February 2009- December 2009- Recovery wells (RW-1, RW-2, RW-3) turned off. No additional funding left to upgrade recovery wells for extraction. Recovery wells were also turned off so no additional concentrations of chlorinated compounds would be drawn towards the clearwell toe drain. Review of monitoring wells behind groundwater barrier wall (May 2001) show decreased concentrations of PCE –once as high as 35ppm now less than 1.5 ppm. Continued monitoring of clearwell reduced by DWM to every other month. PWC began sampling monthly using its own funding. Monitoring of test wells in injection areas by H&H show decreased concentrations of PCE and daughter products in groundwater. Funding ended for interim action contract with CDM in October 2009 which involved monitoring the clearwell and contamination issues on PWC property. February 2010- April 2010- H&H reviewed sampling results of monitoring wells surrounding injection areas and monitoring wells near the clearwell and assessed two hot spot areas for further soil and groundwater investigations. One area was in the vicinity of monitoring well MW-12, where free product was once measured. Free product was never found again following subsequent sampling events of this well and nearby well network. The other area was in the vicinity of the clearwell in monitoring well GW-2. Soil and groundwater was further investigated in area of GW-2. The chlorinated solvent PCE and daughter products were found in clay below 10 to 13 feet once thought to be a fully confining layer across the site. In April 2010 well GW-2 was abandoned. Removal of deep contaminated soils in area of GW-2 not possible due to close proximity of clearwell and shallow groundwater table. PWC continued to monitor clearwell monthly and collect samples from RW-2 monthly. Groundwater monitoring of the existing wells in the vicinity of the HRC-A injection area has shown decreases in PCE concentrations and increases in daughters products as well as the generation of ethene- a non- toxic compound. So, the groundwater is being affected by the injection demonstrating reductions in chlorinated solvent concentrations. August 2010- January 2011- Additional soil and groundwater testing has been conducted in the area around the clearwell and in the area at monitoring well MW-12. It is evident with past soil sampling that the clay layer below 10 to 13 feet is contaminated with chlorinated contaminants (PCE and daughters product) to depths of 30 feet in some areas. Deep drilling to 100 feet plus in the area of the waste equalization basin showed no groundwater bearing zones below 52 feet. Jan 2011, City of Fayetteville starts Brownfield Agreement with NC and purchases Texfi Property. April 2011- May 2011- Under the Texfi Source Removal Contract with the DWM, H&H completed a soil and groundwater investigation of the clay confining unit at the Texfi Industries Site. The conclusions of the soil and groundwater investigation showed that the clay confining unit contained significant concentrations of PCE and its daughter products on the former Texfi property and the PWC Hoffer property both in soil and groundwater. Concentrations in soil were found as high as 1,900 parts per million (ppm) at a depth of 10 feet below ground surface (bgs) near MW-27C and as high as 1,100 ppm in clay at depths of 34 feet bgs in MW-12D. PCE was Att. 1 Page 3 of 8 Att. 1 Page 4 of 8 detected in groundwater on the Texfi property as high as 91,200 micrograms per liter (ug/l) in MW-12D. The PWC property was investigated primarily at the northeast corner of the clearwell. The highest soil concentration of PCE in this area was detected in boring MW-24D at a concentration of 421 ppm in clay at depths 16 to 22 feet bgs. Groundwater was found to exceed 99,000 ug/l in this same boring/monitoring well. In addition to the PCE contamination, a groundwater contaminant plume of cis- 1,2 dichloroethene and 2-chlorotoluene was found to exist in the shallow sand aquifer east of the former Texfi plant in the vicinity of monitoring well MW-1 with concentrations as high 36,600 ug/l. DWM, the Public Works Commission, the City of Fayetteville and the City’s consultants, Duncklee and Dunham discussed remedial approaches to address the contamination issues. The area of soil contamination on the former Texfi and PWC properties was estimated to be eight acres by an average of 30 feet deep with a remedial cost estimated as high as $50-$60 million. Since the Texfi bankruptcy fund contained approximately $160,000 at this time, a decision was made to pursue a monitoring approach (possibly capture of contaminated groundwater from an interceptor trench focused on protecting the clearwell). August 2011- December 2011- August / September 2011- After several discussions with PWC, the City of Fayetteville and the City’s consultants and DWM, a groundwater interceptor trench was proposed for the northeast corner of the clearwell to capture and remove contaminated groundwater from this area. November 2011- US EPA’s contractor completed a Draft Site Specific Quality Assurance Project Plan (SSQAPP) related to a Targeted Brownfield Assessment (TBA) grant that the City of Fayetteville received from US EPA in August/September 2011 for the Texfi Industries property. Since the results from this TBA could possibly show that additional areas of contamination may need to be addressed for cleanup, the City and PWC requested that implementation of the interceptor trench be postponed until the TBA results were completed January 2012- February 2012- An additional $50,000 that was approved by the NC General Assembly for 2011-2012 budget year was made available for the Texfi source removal contract for assessment and remediation uses at the Texfi Site. This additional funding brought the total amount to be used for assessment and cleanup of the Texfi Site to approximately $210,000. February 2012- The TBA assessment was started by a US EPA contractor. Results of the TBA were reviewed by the City’s consultants Duncklee and Dunham and the NC Division of Waste Management’s Brownfield Section. The final TBA assessment results were delayed and the draft report was not submitted until late May 2012. May 2012- June 2012- The draft TBA results provide additional stratigraphic detail to the known contaminated areas at the Texfi and Hoffer Plant properties, and showed excessive PCE concentrations that exceed 1% of 150,000 ug/l (which indicates the presence of dense non- aqueous phase liquids of PCE) in the clay in zones north of the existing slurry barrier wall. In addition to these zones, the TBA also showed the presence of total volatile organic compounds Att. 1 Page 5 of 8 of 23,156 ug/l in surface water samples obtained from the west to east trending drainage ditch and that additional source area(s) of PCE may exist along historic drain lines that extend from the former Texfi Plant eastward to Texfi’s waste equalization basin. Since the $50,000 funding appropriated by the NC General Assembly for assessment and cleanup of Texfi was going to expire on June 30, 2012 and an interim approach for assessment/remediation had not been determined because the TBA report had not been finalized, several proposals of various remedial alternatives were discussed, including the original interceptor trench proposal. Since PCE and its daughter products were found to exist in soils at the sand/clay interface, at deeper depths in the clay (14-22 feet and deeper), and in shallow groundwater and groundwater at depths of 16 to 22 feet, an in-situ injection of HRC-X down to the sand/clay interface was chosen as the remedy. The injection of HRC-X was proposed to help reduce PCE levels in the soil at the sand/clay interface, help to reduce the concentrations of PCE in groundwater, and help long term to breakdown the concentrations of PCE that may migrate from the clay into the shallow sand aquifer. This remedy was implemented from May 24 through June 1, 2012. Additionally, with this funding, DWM’s contractor H & H also sampled the west to east trending ditch and conducted a video survey of a concrete drain pipe that was connected to the ditch. The sampling of the ditch and outfall area of the concrete drain was presented in preliminary data tables submitted by H & H in an email to DWM on June 13, 2012. This preliminary sampling data report showed that the ditch contained concentrations of cis 1, 2 dichloroethene in surface water as high 1,460 micrograms per liter (ug/l) and in sediment as high as 259,000 micrograms/kilogram (ug/kg). H&H also installed a shallow groundwater monitoring well (MW-27S). The results of the sampling of this well, the final lab data from the ditch and concrete drain and the details of the field work associated with the HRC-X injection were summarized in a written report completed by H & H in July 2012. At this time, approximately $164,000 exist in the Texfi bankruptcy funds after work completed in May/June 2012. Future plans at the Texfi site will involve monitoring the HRC-X injection area in approximately six months and reviewing the most efficient use of the remaining bankruptcy funds for assessment/remediation. August 31, 2012- Drainage Assessment and HRC- X injection Report- Final results of the drainage ditch assessment were completed along with a discussion of the layout of the HRC-X injection in the area near the clearwell and installation of an additional monitoring well. There were a total of six sediment samples collected from the drainage ditch area (HHSED-1 through HHSED-6). Chlorinated solvents were detected in samples HHSED-2, 3 and 4. The contaminant concentrations of PCE in these samples range from 9.76 ug/kg in sample HHSED-3 to 259,000 ug/kg in sediment sample HHSED-2. Other chlorinated solvents found in sample HHSED-2 were trichloroethene at 22,000 ug/kg, cis-1,2 dichloroethene at 20,400 ug/kg, trans- 1,2- dichloroethene at 119 ug/kg and vinyl chloride at 570 ug/kg. In addition to sediment samples, a total of four surface water samples were collected from the site, two from the drainage ditch and two from the stormwater drain/outfall. The two surface water samples (HHSW-1 and HHSW-2) showed PCE concentrations at 40.2 ug/l and cis 1,2 dichloroethene at 1,460 ug/l , Att 1 Page 6 of 8 respectively. Samples collected in the stormwater drain outfall showed PCE concentrations at 19.8 ug/l in HHSW-3 and PCE concentrations at 1.94 ug/l in HHW-4. The video inspection (from June 2012) was conducted to assess the orientation, integrity and outfall location of the stormwater drain located east of the drainage ditch and northeast of the Clearwell. This assessment showed that a 15- inch stormwater drain is oriented north-south and crosses under PWC’s Hoffer Plant Service Road and connects with other drain pipes from the west as well as the toe drain from the clearwell. The combined flow of these pipes connects into a 36- inch drain pipe that directs flow to an outfall on the bank of the Cape Fear River. After the outfall, the flow travels through a large riprap area for a distance of approximately 60 feet before entering the Cape Fear River downgradient of PWCs drinking water intake location. The assessment also determined the pipe condition is not a sealed system because of the presence of root growth through pipe joints. The HRC-X injection (May 2012) involved the advancement of 77 injection points in a limited area northeast of the clearwell into the surficial aquifer to a depth of 11 feet or to the top of clay. Approximately 2,790 pounds of HRC-X was injected into these injection points into the surficial aquifer. The groundwater flow in the injection area is to be southwest and toward the clearwell. The orientation of the injection layout consisted of 10 offset rows positioned orthogonal to the groundwater flow direction. For future groundwater monitoring purposes, shallow monitoring well MW-27S was installed to a depth of 11 feet below ground surface within the HRC-X injection area and adjacent to deeper monitoring well MW-27C. MW-27S was sampled and showed PCE concentrations as high as 96,800 ug/l. February 2013- Results of sampling the HRC-X injection area near the clearwell and sampling monitoring wells in the HRC-Advanced (A) injection area. Sampling points were monitored in the area of HRC-X injection and also in the original HRC-A injection area. Although the number of data points are limited (one pre- injection and one post- injection sampling event) in the HRC-X injection area, early indications are that the HRC-X injection effectively reduced PCE concentrations in the area near the clearwell. Reductions of PCE concentrations at 50% (in MW-23) and greater than 99% (in MW-24 S and MW-27S) were observed between the two sampling events. Summary results from the sampling of the existing wells in the HRC-A injection area showed that most of the site monitoring wells had groundwater decreases as high as 99% since 2008. However, cis 1,2 DCE concentrations remain relatively high with the maximum concentration observed in MW-27C (53,800 ug/l) during the November 2012 sampling event. July 2013 -On June 13 and 14, 2013, H&H conducted a more extensive soil and groundwater investigation (than initial June 2012 work) in the west to east trending ditch located along the entrance road between Texfi Industries and PWC properties, collected groundwater samples Att. 1 Page 7 of 8 from a newly installed monitoring well near the sump/oil water separator located at the plant’s east entrance and collected surface water samples from the plant’s waste equalization basin. The results of the soil and groundwater sampling in the west to east trending ditch area showed PCE concentrations as high as 15,400 mg/kg in a soil sample collected in the ditch at a depth of 3 feet below the water surface of the ditch. The ditch had approximately 0.5 feet of water during sampling. A groundwater monitoring well installed approximately 10 to 15 feet from the ditch location was sampled for VOCs. PCE concentrations of 24.9 ug/l were detected in this groundwater sample. A review of sample results from May 2012 from this ditch area showed elevated sediment sample results of 249 mg/kg of PCE. The elevated concentration of this sediment sample and the soil sample result that showed 15,400 mg/kg of PCE indicates this ditch area is a possible source of PCE contamination. The groundwater sample collected from the monitoring well located near the sump/oil water separator showed low levels of PCE, elevated levels of 1,2 dichloroethene and petroleum compounds. The presence of PCE and 1,2 DCE concentrations in this newly installed monitoring well are not a suspected separate source are but are attributed to nearby injections of HRC- Advanced. Earlier sampling results (2006) of the sump showed no significant VOC’s. The petroleum compounds detected are attributed to petroleum surface spills in the area near the sump. Based on these sampling results, the sump/oil water separator does not appear to be a suspected source area of PCE contamination. No VOC’s were detected in the surface water samples collected in the waste equalization basin. Future remediation plans are to excavate the contaminated soil from the west to east trending ditch or inject a plug of HRC at the depth of the contaminated soil sample. Shallow groundwater may limit the depth of the excavation if the contamination is found to be located at deeper depths. August 2013- September 2013 Proposal and implementation of testing soil samples via TCLP to determine if samples collected from drainage ditch are a hazardous waste. October 2013- H&H proposal submitted for ditch soil excavation at Texfi. Based on TCLP results the contaminated soil with PCE is characterized as hazardous waste for disposal after removal. January 2014- Implementation of H&H proposal for ditch soil excavation. Excavation work from May 5 through May 9th. Excavation delayed until May 2014 because of multiple rain events and delays associated with scheduling EVO’s (subcontractor) treatment unit. February 2014- April 2014: Sampling events of groundwater wells on Texfi and PWC property for 1,4 Dioxane. 1,4 Dioxane detected in Cape Fear River and also noted in monitoring wells on Texfi and PWC property in vicinity of clearwell and in point-of-entry samples of the clearwell. PWC continues to investigate and monitor this issue. Suspected source(s) of 1,4 Att. 1 Page 8 of 8 dioxane are unknown industries that affect the Cape Fear River and/or other surface water bodies that flow into the Cape Fear River. July 2014- Texfi Ditch soil excavation report complete. Soils were removed from the hot spot area down to a depth of 8 to 13 feet below the base of the drainage ditch. The depth of the ditch prior to excavation was 3 to 4 feet below the land surface. Soils were removed along a section 3 ft north and 3 ft south of the center line of the ditch in an approximately 50 ft section west of the driveway culvert. Soils were removed and screened with a PID until the highly impacted soils were removed. Not all contaminated soil was removed because of its deep depths and the existence of groundwater impeding the removal of deeper contaminated soil even with existing water mitigation to block or dam water from entering the excavation. Excavated soil was removed and treated in EVO’s Mobile Steam Distillation Unit. Approximately 140 tons of soil was treated in the unit and removed from the site to be transported for additional treatment before final disposal. In addition to the soil, approximately 18,400 gallons of water containing PCE from the ditch excavation was removed in a frac tank and disposed as hazardous waste at Clean Harbors facility. Confirmation soil samples were collected from the drainage ditch walls and showed that although contamination still exists above protection of groundwater standards- the concentrations of 15,100 mg/kg were removed to levels of 201mg/kg. The ditch area was backfilled with first a low permeability flowable concrete fill at the base of the ditch. Coffer dams were removed to allow the water to fill in the ditch after backfill and proper grading of the ditch was completed. Approximately 50 tons of soil, matting, sod, Bermuda grass and straw were used along the banks of the ditch to minimize the potential for bank erosion. August 2014- Final Groundwater Monitoring Report – Summary Shallow groundwater flow is generally to the east-southeast towards the Cape Fear River. A secondary component is towards the southwest in the direction of the toe drain. The overall groundwater flow in the confining clay unit is similar to that observed in the surficial aquifer. The flow is generally toward the Cape Fear River. The area of HRC-A injection has shown a reduction in groundwater contaminant concentrations of PCE at about 99% or greater since 2008. However, significant contamination still remains in groundwater. The 2012 injection of HRC-X has shown to reduce the PCE concentrations to greater than 99% in wells MW-23, MW-24, and MW-27s. However, MW-24 C and MW-27C have shown irregular PCE concentration trends. Significant contamination remains in the confining unit in groundwater. The PCE concentrations have shown to breakdown to their daughter products in the injection areas and continue the break down to the non-toxic compound of ethene. However, cis-1,2 dichloroethene remains high when compared to other PCE daughter products.