IH3730_20240328_Memo to File

MEMORANDUM
March 28, 2025

TO: IHSB File
FROM: Brett Engard, Hydrogeologist
Inactive Hazardous Sites Branch
RE: General Instrument Corp
1396 Charlotte Highway
Fairview, Buncombe County 28730
IHSB ID# NCD003163730

The subject Site was transferred from the former IHSB project manager (PM) due to staff
realignment. The groundwater sampling event conducted in November 2022, was reported to
IHSB on September 5, 2023, which was not reviewed by the previous ISHB PM. The September 5,
2023, 2022 Annual Water Quality Monitoring Report, prepared by HRP Associates, Inc., on behalf
of TE Connectivity Corporation (TEC) was reviewed in February 2024. HRP assumed consulting
responsibilities for TEC in June 2022. The results of the initial IHSB review of the report were sent
via email to Ms. Tammy Hall (TEC), and HRP on February 28, 2024 (attached).

The 2023 Annual Water Quality Monitoring Report was finalized and submitted do IHSB on March
19, 2024. The report and project files are in review. The groundwater plume
containment/capture system was not operational for 85% of the previous 16-months with in the
above mentioned 2022 and 2023 Sampling reports. Neither report mentioned the operational
status of the vapor mitigation systems at 6, 8 and 10 Miller Road. Based on the data presented
in the 2023 Sampling report, increases in concentrations of chlorinated compounds were
detected in off-Site groundwater monitoring wells and in Cane Creek.

Based on this and other information contained in the report a site visit was conducted on March
22, 2024. The following are the observations made during the Site visit:
• The treatment system air strippers were audible; therefore, the plume
capture/containment wells and treatment system were assumed to be operational,
• The vapor mitigation system fans at 6, 8 and 10 Miller Road were operating,
• Water supply wells were observed and verified in-use at 33 and 48 Sayles Lyda Road, and
were sampled per the owner’s consent,
• A hand dug water supply well was identified at 65 Laura Jackson Road. The owner’s stated
that the well is approximately 57-feet in depth, but did not want the well sampled. Based

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on elevation estimates, the base of the had-dug well is approximately 22-feet higher in
elevation than the ground surface, at TEC, near the former solvent disposal area,
• A potential water supply well (plastic boulder) was observed adjacent to the site (1394
charlotte Highway/US-47) at the AT&T facility; IHSB reached out to AT&T on March 25th.

Following the Site visit, additional review of historical information, including previous water
supply well surveys, historical document review, and the March 15, 2020, 2020 Annual Progress
Report, prepared by Anchor QEA of North Carolina, PLLC (formerly Altamont Environmental, Inc.).
Below is a summary of the file review.

The incident did not follow the conventional RIWP, RI/FS, RAWP, RA. Soil remediation was
completed in burn and acid pit disposal, and hazardous drum storage areas. With regards to
groundwater, the existing groundwater plume containment/capture and treatment system was
originally an Interim Remedial Action, because of the immediate need to reduce off-site
migrations of chlorinated solvents in groundwater affecting Cane Creek. A Feasibility Stude (FS),
a Remedial Action Work Plan (RIWP), and Remedial Action was not implemented. Although, two
rounds of sodium permanganate in-situ chemical oxidization (ISCO) pilot tests were conduced
(2020, and 2017) with varied or limited success. The groundwater plume containment/capture
and treatment system has operated for approximately 27 years.

Notable Historical Reports
- June 21, 1993. DEHNR Letter, Administrative Order on Consent, Communications
Instruments Inc., Draft AOC presented to CII.
- July 21, 1993. Parker, Poe, Adams, & Bernstein letter, RE: Proposed Administrative Order
on Consent, CII is not an RP, but will perform voluntary cleanup. GCI not taking
responsibility, but GCI are negotiating.
- July 23, 1993. DEHNR Letter, Communications Instruments Inc., Acknowledge
independent cleanup. Provide detailed schedule for milestones, (RIWP, RI, RAWP, RA) in
60 days, or will be referred to the Federal Superfund Program.
- September 14, 1993. Parker, Poe, Adams, & Bernstein letter. CCI and GIC in the process
of negotiations.
- October 28, 1993. ReTec Letter. Proposed Schedule for Investigation and Remediation. On
behalf of clients (CII & GIC). RAP submittal projected September 1993; Implementation
and operation October 1994; NPDES permit may change schedule.
- March 11, 1994. DEHNR SPL Letter. Site added to the Priority List.
- June 22, 1994., Interim RI Summary Report, first recommended installation of a DNAPL
Recovery well (MW-12).
- November 7, 1994, Summary of Findings from Additional Remedial Investigations at the
Communications Instruments, Inc. Facility, Fairview, North Carolina, letter first states
“design and implementation of a strategy to contain the contaminated groundwater and
initiate an effective remediation program.”

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- January 1, 1995. Aquifer Pumping Test Report, presents “Preliminary Groundwater
Containment System Strategy. Recommends performing groundwater modeling to
support design.
- May 17, 1995. DENR 2nd Draft AOC presented to CII.
- May 18, 1995. Parker, Poe, Adams, & Bernstein letter, markups to 2nd Draft AOC. Attached
RIWP (previous submittal), IRI Report (previous submittal), and Aquifer Pumping Test
Report (ne submittal).
- June 5, 1995. Parker, Poe, Adams, & Bernstein Rather letter, Wanted to have AOC, but
because of limited IHSB staff CII will perform Monthly Reporting rather than AOC.
- August 22, 1995. DEHNR Letter. Cane Creek is WS-IV and TCE from CCI Site is causing SW
exceedances. Remove GW to stop discharge, treat on-site via NPDES or transport off-Site.
- October 30, 1995. Tighe & Bond. RE: October Progress, NPDES Permit applications
submitted, and once received will build treatment building. Recovery well modeling
completed. Site plans for system layout and utility corridors have been completed.
- November 2, 1995. Communications Instruments Inc. Letter from DEHNR directs CCI to
implement the groundwater recovery system to prevent additional off-Site migration of
contaminated groundwater.
- February 12, 1996. NC EMC DEHNR, Issues permit to CCI to construct six (6) recovery wells.
- April 30, 1996. Tighe & Bond. RE: April Progress, DNAPL recovery in MW-12 has begun.
Treatment system construction planning and activity continues.
- January 22, 1997. Order to Submit, and to Record, Notice of Inactive Hazardous or Waste
Disposal Site.
- December 3, 1997. Tighe & Bond. RE: Remediation System Monitoring Report, 2nd and 3rd
Quarters, 1997. MW-12 has recovered 110-gllons DNAPL. The plume capture system was
started February 27, 1997, continuously since April 1, 1997.
- August 10, 1999. Administrative Order on Consent, Communications Instruments Inc.,
finalized.
Brief Summary of Activities
1993 – 1995 Investigations. Hand-dug well (not used) identified at 9 Miller Road;
Soil: cVOCs and daughter products, metals, dioxins,
Groundwater: cVOCs and daughter products,
9 Miller Road, which has a hand-dug well affected by PCE/TCE.
1996 – Soil Removal: Former Burn Pit area, the Former Acid Pit Area, and the Former Drum
Storage Area.
1997 – Plume Capture, Pump and Treat System installed and operational (27 years). Currently
RW-1-4 are operational, RW-6 and RW-7 are off-line).
1998 – 1405 Charlotte Highway, had-dug well and a 100-ft drilled well (unsuitable due to iron)
but used to irrigate a garden, per 1998 phone log (K. Dechant).
2005 – Quarterly progress reporting reduced to semiannual .
2006 – Indoor Air evaluation of residences, max concentrations at SG-9, 15-ft bgs, near 6/9 Miller
Road property line:

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- 1,1-DCA 0.27 ppm
- cis-1,2-DCE 30.02 ppm,
- 1,1,1-TCA 1.68 ppm,
- TCE 82.08 ppm,
- PCE 0.54 ppm
2007 – Sub-Slab soil gas and indoor air sampling at TEC; soil and sub-slab gas, and indoor aid
samples at 4 residences.
2008 – First of year, consultant changed to Altamont Environmental. VI mitigation systems
installed at 4, 6, and 12 Miller Road. HQ < 1. Except SG-18 (12 Miller Road Basement
Sitting Room Indoor Air) was deemed to be a long-term exposure issue. WSW at 1401
Charlotte Highway abandoned.
2010 – Sodium permanganate injection pilot test in the disposal sump area (WI0100089); RW-6
and RW-7 are affected by sodium permanganate and are off-line. The Site Plans presented
in the Progress Reports dated 02-08-2010, and 07-29-2010, depict different alignments
for the plant wastewater treatment system effluent (outfall 001), and the groundwater
treatment system effluent (outfall 001).
2012 – Non-Discharge GW Remediation Permit (WI00089) Modification (WQ0036156).
2014 – WSW Survey, by review of historical information – No sampling completed.
2015 – WSW historically sampled (1405 Charlotte Highway, was not sampled but is on City water.
UST Incident #41330 identified an irrigation well (unused) at 1434 Charlotte Highway).
2016 – Email approval to reduce GW monitoring reporting to annual, from semiannual.
2017 – Sodium Permanganate injection pilot test near RW-1 (WI0100488).
2018 – DEQ approved no-flow GW sampling, and approval to reduce GW sampling to annual,
from semiannual.
2020 – RW-1 back on-line. Review of Buncombe County Well permit database for WSWs.
2022 – June, transition to a different consultant; treatment system has only operated for 77 of
509 days since then (15%) to 12/31/23. November 2022 sampling event reported in
September.
2023 – System upgrades, DEQ may not have been notified.
2024 – Performed initial review of November 2022 Sampling Report, and sent consultant email
of review on 2/28/24; November 2023 Sampling Report received 3/19/23;
- PCE (9.5 ug/L) and TCE (163 ug/L) detected in treatment system effluent above 2B
Standards,
- 1,1,2-TCA, PCE, and TCE detected in Surface water at several location; PCE was > 2B at
SW-7. TCE was detected in surface water over 3000-ft from TEC (SW-4 1.2 ug/L),
- Migration off-Site has not been delineated.
Wells No Longer Sampled
Regolith:
MW-27 – Sampling stopped in 2005, 3-years ND
MW-29 – Sampling stopped in 2017, low concentrations of cis-1,2-DCE
MW-34S – Sampling stopped in 2017, all ND
MW-38S – Sampling stopped in 2009 (2 rounds), all ND

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MW-38M – Sampling stopped in 2009 (2 rounds), all ND

Bedrock Wells:
MW-28 – Sampling stopped in 2005, 5-years ND
MW-30 – Sampling stopped in2018, cis-1,2-DCE 94.4 ug/L, PCE 0.52J ug/L, TCE 11.7 ug/L
MW-35D – Sampling stopped in 2017, all ND
MW-38D – Sampling stopped in 2017, cis-1,2-DCE 300 ug/L, PCE 1.9J ug/L, TCE 4.5 ug/L

North Carolina Geologic Survey Provided Information:

The North Carolina Geological Survey provided the attached excerpts from the Oteen Quadrangle
geologic map, and rose diagrams of joints and foliations in the immediate area. A review of the
geophysical borehole logs completed at the Site and reported in 2020 Annual Progress Report.
See attached.

Water Supply Well Survey:

A review of real estate logs, google street view, and historical information was used to prepare
the attached Water Supply Well Information Map: note, there are likely many more wells than
identified in the DEQ 2024 initial review.

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Engard, Brett
From:Engard, Brett
Sent:Wednesday, February 28, 2024 4:34 PM
To:[e-mail]; [e-mail]; [e-mail]
Cc:Laverty, Brett; Ramey, David E
Subject:NCD003163730 - General Instrument Corp
Good a ernoon,
By way of this email, I would like to introduce myself as the assigned IHSB Site Manager for the Subject Site.
‐ Advise when the November 2023 groundwater sampling event report will be submi ed. September of 2024 is
unacceptable.
‐ What are the effec ve dates of the current NPDS Permit? Please provide a copy of the Permit.
‐ The September 2022 report recommended treatment system upgrades; what specific upgrades and were those
upgrades completed?
‐ The September 2022 report does not present 2b standards for compounds which do (e.g., cis‐1,2‐
dichloroethene, CAS # 156‐59‐2), or the addi onal standards (EPA NRWQC and NC In‐Stream Targets) where
standards are available (e.g., 1,1,2‐Trichloro‐1,2,2‐trifluoroethane – Freon 113, CAS # 76‐13‐1). The correct
applica on of the “2b” standards are the comparison of the 2b, EPA NRWQC, and NC In‐Stream Targets, and if
there is a conflict the lowest value is used. Cane Creek is a Class C Trout designated surface water body.
Exceedances, and detec ons, of site contaminants cons tutes a unpermi ed waste discharge.
‐ Provide a status and evalua on of the Pilot Test at RW‐1, or point me to the evalua on.
‐ The concentra ons of cVOCs at PZ‐S1/D1 and PZ‐D4 off‐site and near residen al structures is concerning. The
DEQ Risk Calculator shall be used to evaluate the poten al vapor intrusion risk, and if a survey is required. In
addi on, these concentra ons are detected beyond the plume containment system; what are the proposed
remedy?
‐ Based on the September 2022 report, the treatment system did not operate for the months of August, October,
or November; was anyone no fied?

I will con nue to review the historical documents. In the interim, please provide a response to the comments above, and
propose some mes we can have a teleconference in the coming weeks.

Regards,

Brett Engard, P.G.
Hydrogeologist, Inactive Hazardous Sites Branch
Division of Waste Management
NC Department of Environmental Quality

828-767-2424 cell
[e-mail]
2090 US-70
Swannanoa
NC 28778
From Oteen Quadrangle
Zagsi
bzsp
•Zaa= Ashe Amphibolite
•Zau = Ashe Ultramafic
•Za = Ashe Undivided
•Zabs = Alligator Back
Schist
•Zabf = Alligator Back Phyllite and meta-
siltstone
•Zabc = Alligator Back
metagraywacke, metasandstone, and schistose
metagraywacke
From Oteen Quadrangle
From Oteen Quadrangle
Contoured poles to
foliation. N = 65 Poles to Joints and
Unidirectional Rose
diagram. N = 35
Steronets for
map excerpts
on pages 1-3
Site
A
A’
A
From Oteen Quadrangle
From Oteen Quadrangle
2020 Annual Progress Report borehole information
2020 Annual Progress Report borehole information
2020 Annual Progress Report borehole information
Location Grd Suf, El.Depth, ft Freacture, El.Azimuth, deg Strike, deg Dip, deg
MW-46 2258.1 95.8 2162.3 231 141 15
MW-46 2258.1 117.2 2140.9 285 195 48
MW-46 2258.1 117.7 2140.4 273 183 43
MW-46 2258.1 146.4 2111.7 250 160 22
MW-46 2258.1 158.3 2099.8 186 96 18
MW-46 2258.1 158.7 2099.4 217 127 40
MW-46 2258.1 160.7 2097.4 124 34 27
MW-46 2258.1 198.1 2060.0 154 64 46
MW-49 2264.3 112.2 2152.1 185 95 29
MW-49 2264.3 112.9 2151.4 216 126 39
MW-49 2264.3 116.7 2147.6 159 69 27
MW-49 2264.3 119.4 2144.9 255 165 32
MW-49 2264.3 124.1 2140.2 236 146 27
"Minor" Water-Bearing Joint/Foliation
"Major" Water-Bearing Joint/Foliation