United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R04-89/049
April 1989
Superfund
Record of Decision
Chemtronics (Amendment), NC
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50272.101
REPORT DOCUMENTATION I'. REPOATNO. -" a.
PAGE EPA/ROD/R04-89/049~ ?
I. A8dp1enr1 ~ No.
4. 118e... SUbII88
SUPERFUND RECORD
Chemtronics, NC
Amendment
7. AuIIIor(.,
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I. Aapart Daw
OF DECISION
04/26/89
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I. PIIf1o.miI", ~ A8pL No.
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I. ~..II CIrpIrIIIdon .... ... ....
10. '"'1acUT 8811/WorII UnIt No.
n. ~C),. Granl(G) No.
(C)
(Q)
12. --.... 0.- 1,....... .... ... ....
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
12. Typ8 of R... . P8otocI Cowr8d
Agency
800/000
14.
II. ....~~. -18I"'~ No..
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II. Ab8ftct (Un8t: 2110 WOIdaI
This Record of Decision (ROD) amends the April 5, 1988, Chemtronics ROD which included
an incorrect calculation regarding the chemical quality Qf the ground water. The
Chemtronics site is an active waste disposal facility located in a rural area of
Swannanoa, Buncombe County, North Carolina. The 1,027-acre site was developed as ~n
industrial facility in 1952 and was purchased by Chemtronics, Inc. in 1978.
Approximately 10 acres of the site were used for waste disposal operations. Records
indicate the presence of 23 individual onsite disposal areas (DAs) which are grouped
into six discrete areas: DA-6, DA-7/8, DA-9, DA-10/11, DA-23, and the acid pit. From
1952 to 1971 solid waste materials and possibly solvents were incinerated in pits and
chemical wastes, including waste materials generated in the production of the chemical
warfare agent 3-quinuclidinyl benzilate (BZ) and the tear gas agent o-chlorobenzylidene
malononitrile (CS), were placed in 55-gallon drums with a neutralizing solution, and
then-buried onsite in trench-type landfills. From 1971 to 1975 s~ll volumes of
liquid wastes were disposed of in onsite pits and trenches, and solid wastes, rocket
motors, explosive wastes, and other waste types were burned. From 1975 to 1979
Chemtronics, Inc. constructed pits and trenches as needed, for the disposal of spent
acid and various organic wastes. In 1980 the ~rate ordered Chemtronics to discontinue
(See Attached Sheet)
17. Docur8It An8Iy8Ia & Da8crtpIDta
Record of Decision - Chemtronics, NC
Amendment
Contaminated Media: soil, sediment, gw, -sw
Key Contaminants: VOCs (benzen~ toluene, PCE,
explosives, metals (arsenic, lead, chromium)
It. ~T8n118
TCE), other organics
21, No. o. Pig"
77
22. PrIce
(s.. ANSIo2:l8.18)
s.n IMI1Ut:ti- on R.-
272 (4.77)
(Formerly HTlS-351
Dep8rDnanlolComnMWCI
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EPA/ROD/R04-89/049
Chemtronics, NC
Amendment
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16.
Abstract (continued)
all discharges to site pits and trenches. The pits-were subsequently backfilled.
'Starting in 1979, Chemtronics installed a 500,000-g?llon lined lagoon over an old
leaching field for the biotreatment of wastewater. . The incompatibility of the liner with
the brominated wastes introduced into the lagoon caused the lagoon to release its
contents. The lagoon was reconstructed in August 1980, using a different liner, a.nd
deactivated in 1984. In September 1984, the U.S. Army Toxic Hazardous Materials Agency
sampled two drums in DA-10/11. These drums were suspected of containing wastes from the
production of BZ. Although no BZ was found, EPA initiated an immediate removal of these
drums in January 1985 due to heightened public awareness of the site. In the original
ROD the selected remedial action for the contaminants and contaminated so11 ln DA-23 was
soil fixation/stabilization/solidification, followed by capping. This remedy has been
changed to capping only. The original remedy was selected due to the concentration level
of the contaminant benzylic acid a benzophenone found in the ground water downgradient of
DA-23. However, a transcription error was discovered in the analytical results for this
ground water sample. The laboratory reported the concentrations as 470 mg/l instead of .
470 ug/l. Subsequent sampling verified that the correct concentration was in the 0-470
ug/l range. Therefore, EPA elected to change the source control remedial action for
DA-23 to capping only. The primary cont~~inants of concern affecting the soil, sediment,
ground water and surface water are VOCs including benzene, toluene, PCE, and TCE; other
organics including pesticides and explosives: and metals including arsenic, lead, and
chromium.
The selected remedial action for this site includes multi-layer capping of DA~6, DA-7/S,
DA-9, DA-10/11, DA~23 and the acid pit area; ground water pumping and treatment using air
stripping, carbon adsorption, or metal removal with treatment and discharge to be
determined during design: sampling of pond water and sediment and if necessary, surface
water treatment using the ground water treatment system and onsite disposal of sediments;
implementation of institutional controls and access restrictions: and sediment, ground
water, and surf~ce water monitoring. The estimated present worth cost for this remedial
action is $2,248,900 with an annual O&M cost of $501,900.
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AHBHDMBHT '1'0 TBB
BlIPORCBKBHT
RECORD OF DECISION
RBMBDIAL AI.~IVB SBI.BC'rION
CBEMTRONICS SI'l'B
SWAHHAHOA, BOHCOMBE COOH'l'Y
NORTH CAROLINA
PREPARED BY:
tt. S. EHVIRONHENTAI. PROTEC'rION AGENCY
REGION IV .
A'rIJUnA, 'GEORGIA
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DBCLARATION !'OR 'rBB UCOlU) O~ DECISION
SID NAME and LOCATION
Ch8llltronics
SwAnl1anoa, Buncombe COunty, North Carolina
STA1'EHBN'l' 01' PURPOSB
':hi. docwD8nt repre.ent. the .elected r8lD8dial action for this Site developed
in accordance with CBRCLA a. amended by SARA, and to the extent practicable,
the National COntinqency Plan.
The State of Horth Carolina has concurred on the .elected Remedy.
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STA'l'BMEN'r 01' BASIS
The decision is based upon the administrativ. record for the Chemtronics Site.
The attached index identifies the itema which comprise the administrative
record upon which the .election of a remedial action is based.
DESCRIPTION 01' THE SELECTED REMEDY
MIGRATION CONTROL
(Remediatinq COntaminated Groundwater)
Installation of a qroundwater interception and extraction system downgradient
of the disposal areas in both the 1'ront Valley and Greqq Valley. 'rhe level
and deqree of treatment of the extracted - groundwater will depend on 1) the
ultimate discharqe point of this water and 2) the level of contaminants in
the extracted qroundwater. The three water discharqe alternat~ves for the
treated water are 1) the local sewer system, 2) a surface stream and
3) on-.ite irriqation. The ranqe of treatment for the extracted qroundwater
includes air strippinq, filtration throuqh activated carbon filter and metal
removal. The point of discharge and the deqree of treatment will be
determined in the Remedial Design stage. The water discharged will meet all
ARAR's.
A monitorinq proqram, employinq bioassays, will be established for surface
water/sediment. Konitorinq loc~ions will be located on the Unnamed Stream,
Greqq Branch and Bee Tree Creek. The purpose of this monitorinq proqram is
1) to insure no adverse impact on these 8tream. durinq implementation of the
remedial action and 2) to establish a data base to use to measure the success
of the remedial action implemented. The initiation of this monitorinq
proqram will be concurrent with the remedial design activities.
Review the existinq groundwater monitorinq system and install additional
wells, if necessary, to insure proper monitorinq of qroundwater downqradient
of each disposal area. This includes disposal areas '6, '7/8, 19, 110/11,
123, and the acid pit area.
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In adc11tion to the IDOnitorinq of the gz'c-udwatar downqradient of each
dJ.8po.U area identified. above, action Iftel. for the conta~i nant. pre.ent in
the di8pO.u are.. will be 88t 80 that aft~er J:8ID8diatien levels for
groundwater have been obtained and verified throuqh IDOnitorinq, if this level
is reached in any subsequent samplinq epS-.ocia, a r8ID8dJ.al action to
peJ:lll&Dently eliminate that aourc:e of cont'~""i n,.tien will be initiated.
SOtJRCB CQBTJtQL
(R8D8diatiDg contaminated SOilS)
cap Disposal Area '6, D18posal Area '7/8, Disposal Area '9, Disposal Area
'10/11, Disposal Area '23, and the Acid Pit Area with a Multi-Layer cap which
include. a SYnthetic liner. Security fencing, vegetative covers and, where
d88lD8d nec:essary, a g.. cOllection/ventilation system will be installed. 'rhe
multi-laYer cap will meet a. a mi.nilllwD, the standards specified under 40 CJ'R
Subsection 264, subparts X-H.
Sample on-Site Pond on UI'IIU''''''' ~tream
During the R8m8dial De81gn stage, .ample the water and sediment in tb:s
pond. If the analysis indicat.Bs cont-Ami pants in either the water col IDD or
sediment, then the pond will 1.8 drained, with the water beinq treatedt';'
" through the treatment .ystem developec:l for addressing the extracted ',)
qroundwater and the sedim8nts will be transported to another disposal uea
and capped along with that disposal area.
DBCLARA'rION
'rhe .elected remedy is protective of hWD&l1 health and the environment, attains
Federal and State requirements that are applicable or relevant and appropriate,
and is cost-effective. 'rhi8 remedy satisfies the preference for treatment that
reduces toxicity, lDQ):)ility, or volume a8 a principal element. Finally, it is
determined that this remedy utilizes permanent solution ~.~ alternative
treatment technologies to the max~ extent practicable.
APR 2 6 19J9
Date
k-'/f ~?4~
Gr r C. 'ridwell
Regional Administrator
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SUMMARY 01' RmmDIAL ALTBRHATIVB SBI.BC'tIOH
CBBH'rRCHICS SID
SWANHANOA, BURCOMBB COUNTY HPR'1'B CAROLINA
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PRBPA!Um BYa
tJ. s. BHVIRORHBHTAL PRO'rBC1'ION AGBHCY
REGION IV
A'1'I.AH1'A GBORGIA
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#
5.0
6.0
7.0
8.0
1.0
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TABLB OF CONTBN'l'S
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Paae No.
I,
IntroduC't.ion[[[1
1.1
1.2
Site Location and De8cription...............................1
Site Hi.tory........................................ e.8......1
2.0
Bnforcement ADaly.i..............................................6
CUrrent Sit. S~atu...............................................6
3.0
4.0
3.1
3.2
3.3
3.4
3.5
3.6
3.7
Hydrogeologic SettiDg........~..............................6
Site COn'tamination..~.......................................1
Air COntamination...........................,...............8
8011 Contamination..........................:...............9
Groundwater COntamination...................................9
Surface Water and Sediment Data..............'.............. .16
.,
Receptor8.............................~......C'.............16
Cleanup Crit8r1......................................~..........17
Rem.ediation....................................17
'Groundwater
90i1 Remediation.......................................... .18
Surface Water/Sediment Remediation.........................18
5.1
Alternatives Bvaluated...................."............... ... . . . . .18
Modification of AprilS, 1988 Chemtronics Record
of Decision Remedial Alternative for Disposal
Ar'ea 23................................................. .18
Nine Point Evaluation Criteria for Evaluating
Remedial Action Alternatfves.............................23
Schedule. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Future ~ion8....................................
.....27
.....27
Recommended Al ternati ves. . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . .26
6.1 Description of Recommended Remedy..........................26
6.2 Operations and Maintenance............................... ..26
6.3 COst of Recommended Alternative............................27
6.4
6.5
6.6
4.1
4.2
4.3
5.2
COnsistency With Other Environmental Laws...........:......27
COJIIIDUnity Relat.ions.............................
\
Stat. Involvement...............................
. . . . . . . . . . . . . . . .27
................28
Appendices
Appendix A -
Table 8 from the Chemtronics Superfund. Site Record of
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TABLB 01' CON'rEHTS
(continued)
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Appendix B - Letter (with enclosures) from ChemtrC'l1ics, Inc. dated
September 19, 1988
l:iG .
Appendix C - October 7, 1988 Hemorandum from Wade Knight, Chief of Quality
Assurance and Laboratory Bvaluation Section, Bnvironemntal
Services Division
Appendix D - Explanation of Significant Difference Pact Sheet/Proposed
Plan P'act Sheet (P'ebruary 10, 1989)
Appendix B - Legal Notice Published in the Asheville Times/Citizen
Newspaper (March 1989)
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Appendix I' - Responsiveness Summa..ry
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Appendix G - Analytical Results of SampLLng Monitor Well SW-4~On January
4, 1989
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LIS'!' 01' P'IGURES
PAGZ-NO.
P'igure l.~ Hap Showing Site Location..................................2
P'igure 2.}~ Hap Highlighting Site Boundary............................V3
P'igure 3.. Hap Showing Location. of Individual Di.po.al Area :
on-Site in P'ront Valley and Gregg Valley.................S
P'igure 4. Hap Locating Surface/SuI:I.urface Soil Sample. in
Di8po8al Area 23........................................10
P'igure 5.
Hap Showing LocatiolUl of Honitor Well. and
COncentration. of Volatile. P'ound in the
Groundwater A880Ciated with Di8po8al Area 23............13
Hap Showing Location. of Honitor Well. and
COncentratiolUl of Other COntaminant. P'ound
in the Groundwater As.ociated with Disposal Area 23.... .15
P'igure 6.
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'l'able 1.
'l'able 2.
'l'able 3.
'l'able 4.
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LIS'l' OP 'l'ABLES
PAGE NO ;'.
COntudnant. Pound in SOil Sample8 A880ciated with
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Dispo..l Az:'.. 23........................................ .11 -, .-
COnt""''' ftant. Pound in the Groundwater in the Vicinity of
..'.,. ..
Di8po..l Az'.. 23 ...................................... .14 "
Groundwater R8m8diation
Soil Remediation Level.
Promulgated Criteria
Level. and Cited Reference.........20
for COntaminants Lacking
or S~andard8.......................21
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AHBHDHBHT TO TUB
BNJ'ORCBHBHT RECORD OP DECISION
SUMHARY OP RBHBDIAL ALTERNATIVE SBLEC'l'ION
CBBHTRONICS SITE
SWAHHAHOA, BONCOHBB COONTY, NORTH CAROLINA
1.0
INTRODtJC'l'ION
The Ch8mtron~cs Site was included on the first official National Priorities
L~at (NPL) published by EPA in December 1982. The Chemtronics Site has been
the subject of a RelDecUal Investigation (RI) and a Peasibility Study (PS)
performed by two of the potent~ally responsible part~.s (PRPs), Chemtronics,
Inc., and Northrop COrporation, under an AdIILin~strative Order of COnsent dated
OCtober 1985. The third viable PRP, Hoechst celanese COrporation, declined to
participate in the RI/PS. The RI report, which exaadned air, groundwater,
soil, and surface water and sediment contaminat~on at the Site and the routes
of exposure of these contaminants to the public and environment was accepted by
the Agency in Hay 1987. The PS, wh~ch develops, examines and evaluates
alternatives for remediation of the contamination found on site, was issued in
draft form to the publ~c in Pebruary 1988.
Th~s Record of Decision (ROD) has been prepared to summarize the remedial
alternative .election process and to present the selected remedial alternative.
1.1
SITE LOCATION AND DESCRIPTION
The Chemtron~cs Site encompasses approximately 1,027 acres and is located at
180 Old Bee Tree Road in a rural area of Swannanoa, Buncombe COunty,
approximately 8 miles east of Asheville, North Carolina. The approximate
center of the site lies at latitude 35 degrees 38' 188 north and
longitude 8~ degrees 26' 8- west. The Site is bounded on the east by Bee Tree
Road and &ee Tree Creek. The area to the north and west of the Site is
compris~ of sparsely inhabited woodlands. Immediately to the south of the
Site, there are several industrial facilities which lie on land that was once
part of the original (Oerlikon) property. The general location of the Site is
shown in Pigure 1. Pigure 2 shows the approximate boundaries of the Site in
~elationship to its immediate surroundings.
The topography of the Site is steep, ranging from 2,200 to 3,400 feet above
mean sea level (&msl). The Site lies on the southeast side of Bartlett
Mountain and is moderate to heavily vegetated. Surrounding mountains reach
elevations of approximately 3,800~eet amsl. All surface water from th'3 Site
drains into small tributaries of Bee Tree Creek or directly into Bee Tree
Creek. This creek flows into the Swannanoa R~ver which ultimately, empties
into the Prench Broad River. .
1.2
SI'l'E HISTORY
The property comprising the Chemtronics Site was first developed as an
industrial facility in 1952. The Site has been owned/operated by Oerlikon Tool
and Arms Corporation of America (1952-1959), Celanese Corporation Of America
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1': 13 MILES
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FIGURE NO.
GENERAL LOCATION MAP
CHEMTRONICS, INC.
SW ANNANOA, NORTH CAROLINA
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USGS CRAGGY PINNACLE.. N.C. & OTEEN, N.C. QUADS
SCALE 1 : 24,000
F~ NO.
SITE LOCATION MAP
CHEMTRONICS, INC.
SW ANNANOA.. NORTH CAROtJ.tA
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2
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(Boechat C81aneae COrporation) (1959-1965), Northro~~olina, Inc. (NoJ~hrop
COrporation) (1965-1971), Chemtronica, Inc., aa a~of Airtronics, Ine.."
(1971-1978), and Chemtronica( Inc. (1978 - pr.aent)~~'The Site operated'u~mer
the nama of AlDeel Propulaion," Inc. (1959-1965) under~both Oerlikcn and
celanea.. The Sit. ia currently owned by ChemtroniCiJo:.;Incorporated, a
8Ub81diary of the BallJburtOD Ccmpany. . .
..
Waate dispoaal occurred over a small portion (approxLDately than ten acres)
of the Site. 'l'wenty-three individual on-site dispoaal areas were identified
and deacriJ:)ed by reviewing exiating records and through interviews with
foz:mer and current sit. employeea. These 23 individual disposal areas (DAsI)
are grouped into 6 discrete dispoaal areaal DA-6, DA-7/8, DA-9, DA-10/11,
DA-23, and the Acid Pit Area. Th. Site can also be divided into two
g8OCJ%'aphJ.cal aubaectiona, they will be referred to aa the Pront Valley and
Gregg Valley. The locations of the 23 diaposal areas and the two valleys are
.hewn in Pigure 3.
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Disposal practices prior to 1971 are not Wt~ 1 defined. Prem 1~2 to 1971,
solid waste materials and possibly solventl were incinerated in pits dug in
the burning ground. Chemical wastes were dilposed of in trenches beside this
burning ground. Waste materials generated~a the production of'the
incapacitating, surety agent, 3-quinuclidin~ -1 benzilate (BZ) and the tear gas
agent, o-chlorobenzylidene malononitrile (C~), were placed in 55 gallon,
. rim-lid d.rwDs, reportedly covered with decontamination -kill- solution and
then buried on-site in trench-tyPe landfills. These kill solutions
neutralized the BZ and CS compounds. These drums were disposed of in
disposal areas DA-6, DA-7/8, DA-9, and DA-10/11.
From 1971-1975, most of the liquid wastes generated on-site went to the
Buncombe COunty Sewer System following some form of neutralization and
equalization. Small volumes were disposed of in on-site pits/trenches.
Solid wastes, rocket motors, explosive wastes, etc., were all burned in the
burning ground. Prom 1975-1979, Chemtronics, Inc. constructed pits I ;renches,
as needed, for the disposal of spent 'acid ,and various organic was~es. These
pits/trenches were constructed in the area that was once the b~.'ntng ground,
now referred to as the Acid Pit Area.
In 1980, the State ordered Chemtronics to discontinue a~ldischarges to thef~
disposal pits/trenches. The pits have subsequently been back-filled.
Consequently, in 1979, Chemtronics installed a 500,000 gallon lined lagoo"
for biotreatment of wastewaters on top of ~~ abandoned leach fiald for the
main production/processing building (Building 113). After the lagoon was
filled, the lagoon lost its contents due to the incompatibility of the liner
with the breminated waste initial~ introduced into the lagoon.
Reconstruction of the biolagoon, with a different liner, was ca~~leted in
August 1980 and was in use up to 1984 at which time the biola~oon was
deactivated. This entire area, including the abandoned leach field and the
biolagoon, has been designated as DA-23.
The Site has been the subject of two previous Region IV, Environmental
Protection Agency (EPA) planned investigations, an investigation by the U.S.
Army and an emergency response action by Region IV, BPA. In June 1980,
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FOR: NO
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lOCATIONS OF KNOWN/SUSPECTED DI~POSAl AREAS
CHEMTRONICS. INC.
IWANNANO NORnt CAROlINA
3
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groundwater, surface water, sediment, and waste samples were collected for
analysis. In April 1984, private water supply wells in the vicinity of the
Sit. were sampled. In September 1984, the O.S. Army Toxic and Hazardous
Haterials Aqency (OSATBAMA) collected samples from two drum8 exposed at the
8urfac. in DA-10/11. Thes. two drums were suspected of containing wastes
from the production of the chemical warfare agent BZ. Although no BZ was
found, in January 1985, an immediate removal of the same two exposed drums
was initiated by BPA due to heightened public awareness/involvement with the
site. . The drums were sampled and then transported to GSX, Pinewood facility,
South carolina.
2.0
BHI'ORCEHEH'l' ANALYSIS
Th. Chemtronic8 Site was included. on the first BPI. in December 1982, and EPA
assumed lead responsibility for the Site at that time. The Site has been
operated as an induatrial facility since 1952. An EPA contractor completed a
PRP search in November 1983. Notice Letters were sent to the six ider.tified
PRPs. Three of the PRPs were found to be viable and EPA initiated
negotiations with these three PRPs. Negotiations began in June 1984 aQd were
concluded in October 1985 with two of the PRPs, Chemtronics, Inc. and
Northrop Co~ration, signing an Administrative Order of Consent to pel:.form
an RI/PS. The third PRP, Hoechst celanese Corporation declined to
participate in the RI/PS process. .
Negotiation on a Remedial Design/Remedial Action (RD/RA) were initiated in
June 1988. Due to the inability of the three viable PRPs (Chemtronics, Inc.,
Hoechst-celanese Corporation, and Northrop Corporation), the Agency issued
the three PRPs an Unilateral Administrative Order. The effective date of the
Administrative Order was Karch 22, 1989.
3.0
CURRENT Sr'rz STA'l'US
The Site is an active facility with the majority of manufacturing activities
occurring in the Pront Valley. The property is presently being leased from
Chemtronics, Inc. by Jet Research, Inc., another suDsidiary of the
Halliburton Company. . .
3.1
HYDROGEOLOGIC SETTING
The Chemtronics Site lies within the Blue Ridge geologic province. The Blue
Ridge province is predominantly c~sed of ancient igneous and metamo~hic
rocks. These rocks have been complexly folded and faulted in a northeCo~terly
direction, parallel to the rec;ional trend of the mountains. These 9tructural
and metamorphic imprints are reflected in the topographic and drainage
patterns within the region. .
There are no known geologic faults or shear zones within two miles of the
Site, and the Brevard Pault Zone lies about seven miles south of the Site.
The Site property is underlain almost entirely by biotite gneiss.
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In the Front Valley, the bedrock topoqraphy is r.~1ected in the surface
topography and haa a shape similar to an elongated~l or trough. The
center of the bedrock trough coincides roughly wit.lh. the center of the
topographic valley and this is where the overburd8Z1.i. thickest (65 to
90 feet). Bedrock elevation. increase with the surface topography and the
overburden decrease. as .lope. steepen. The thicJceaing of the overburden in
the valley is mo8t likely due to natural weathering: proCes8e8.
In Gregg Valley, the bedrock topography is more complex and is not always
reflected by the surface topography. For example, a st_p bedrock slope was
identified in the northeastern corner of the acid pit area but is not
reflected by the surface topography. There i. al.o . bedrock trough near the
middle of the acid pit are. which baa no surface expre.sion. Re8haping of
the topography by man in this area is mo8t likely responsible for masking
these bedrock feature.. Blsewhere in Gregg Valley, the bedrock topography is
reflected by the surface topography. As in the Front Valley, overburden in
Gregg Valley thickens in its central and' lower portion..
Groundwater recharge in this area is derixed primarily from local
precipitation. Generally, the depth of t~.e water table depends on the
topography and rock weathering. The wate~: table' varies from the ground
surface.in the valleys (streams) to more:than 40 feet below the ground
8urface in sharply rising 8lopes.
The aquifer underlying the Site can be subdivided into a surficial zone and a
bedrock zone. The surficial zone refers to the overlying saprolite and the
bedrock zone include8 the weathered and fractured region of the bedrock.
These two zones are considered one aquifer as it was demonstrated in the RI
that these zones .are interconnected.
The groundwater underlying the Site has been classified as Class lIB, using
BPA Groundwater Classifications Guidelittes of December 1986, sinc~ there is
potential future use for this aquifer as a source of drinking w~~er.
Therefore, the groundwater needs to be remediated to levels protective of
public health and where appropriate, to levels protective of 'the environment.
3.2
SITE CONTAMINATION
The field work associated with the RI for the Chemtronics Site centered on
numerous known disposal areas on-site, eight other possible areas of
contamination on-site and three off-site areas that reportedly received waste
material from the Site. Soil, groundwater, surface water and sediment
samples were collected in and aro~d these areas and initially analyzed for
the compounds on the Hazardous Substance 'List (HSL) a8 well as other selected
compounds. After reviewing the analyt~cal data from the HSL scans, indicator
parameters were then selected to be run on subsequent samples and sampling
episodes.
-7-
-------
The indicator compounds selected
were: ~'ls._~-,
*
Volatile Organic Priority pollutants
. - Benzene
- 1,2-Dichloroethane
- Hat:hylene chloride
- Tetrachloroethene
- Toluene
Trichloroethene/Trichloroethylene
- 'l'rihalomet:hane.
- Bromoform
- Chloroform
;).
'J"
*
Explosive.
- Picric Acid
- RDX
- 'l'N't
~
,
*
Chemical Agents
- BZ
-cs
- and their degradative . ompounds
..
*
Metals
- Chromium
- Nickel
The Agency approved the RI report: in Hay 1987 which documented the presence
a8 well as the level and extent of contaminants on-site. COntamination was
found in the following medias surface and 8ubsurface soils, surface water and
8ediment, and groundwater. I4 OCtober 1987, the PRPs resampled 12 monitor
wells in an attempt: to verify and confizm the levels I':...a extent of
contamination in the groundwater. The analytical data indicates that, to
date, no contamination has migrated pass the Site's. boundaries although
plumes of contamJ.nation in the groundwater have been found emanating from
several of the disposal areas.
3.3
AIR CONTAMINATION
The most common source of air contamination at hazardous waste sites are the
volatilization of toxic organic chemicals and the spread of airborne
contamJ.nated dust particles. D\U'i.pg the recent RI, Site personnel used an
BHu photo ionization analyzer an~ ctanide sensitive colorimetric indicator
tubes to monitor the air whil: performing the designated RI tasks. An action
level of 5 ppm was established in the Chemtronics Project Operations Plan
(POP) and Health & Safety Plan. This le~el was only attained during the
excavation of the test pits in the disposal areas. The 5 ppm action level
was surpassed on several occasions when the BHu was placed in the test pit or
near exposed waste material unearthed during the excavation of the test
pits. No cyanide was detected by the colorimetric tube.
-8-
-------
"
3.4
SOIL CONTAMINATION
The 8tudy of the 80il, surface and subsurface, occurred in two parts. The
first taak encompassed the excavation of te8t pits in the majority of the
known di.po.al area. and the .econd ta8k centered on the collection of
.urface and .ub.urface .oil .amples from boring. drilled in and around the
dispo.al area.. The.e activitie8 not only allowed the determination of the
depth of the di.po8ed wa.te. but &180 provided data to determine the extent,
vertically and horizontally, that the contAll!li"~nts have migrated in the
8Oil. The three dispo8al areas where te8t pit8 were not excavated were in
1)1.-9, 1)1.-23 and the Acid Pit Area.
3.4.1
SOIL CONTAMINATION IN THE FRONT VALLEY
The Front Valley contains two disposal areas, I)A-10/ll and DA-23, where
.urface and sub.urface .oil .ample. were collected and analyzed. Below
briefly describes the contaminants present in each disposal area.
DA- 10/11
Refer to the Chemtronics ROI) dated April 5, 1988.
DA-23
The analytes detected in and around DA-23 included volatile organic priority
pollutants, explosives, CS, BZ, and their degradative products, total organic
halides, and total cyanide. The sampling locations are shown in Figure 4.
The analytes found are listed in Table 1 along' with the maximum
concentrations. Table 1 also identifies where the contaminants were found as
well as the frequency of their occurrence among both on-site and off-site
samples.
3.4.2
SOIL CONTAMINATION IN GREGG VALLEY
Refer to the Chemtronics ROD dated April 5, 1988.
3.5
GROUNDWATER CONTAMINATION
All monitor wel18 were 8ampled in June 1986 as part of the RI. Twelve (12)
of these wells were resampled in October 1987 in an attempt to verify
concentrations. \ ".
?j
3.5.1
GROUNDWATER CONTAMINATION IN THE FRONT VALLEY
Groundwater contamination in the 'surficial zone of the Pront Valley exists
primarily in the area downgradient of DA-23, the old leach field for Building
113 and the biolagoon. Other portions of the aquifer in this valley also
appear to have been adversely affected but the source of contamination in
these areas cannot be clearly defined. In each of these locations, volatile
organic priority pollutants are present.
-9-
-------
,. .---- -- ---
, )
1 "
"
, .
,
, , ,
I. 1
I :
'0'
I '
I '
I
.....
()
I
'.
\
,
\ "
~
-
-
==-:/
'"
-.........
o DA
lOlL IORINOI
FIGURE 00. Li (1)CATJOOS OF SURFACE/SlJASURFACE SOIL
SAMPLFS IN ANO ARaINO OISFOSAL "AREA 23
...
-------
TARLE 00. 1
CCM'AHINAN'fC3 FOUND IN SOIL SAMPLES ASSOCIATF..D WI11I DIS~ AREA 23
i
I :
Canpound
Detected
Haxi un
Oetected
Concentrat:. ion
(ng/Kg)
Incatlon
of Haxiun
rntected.
Concentration
80rinq
Interval
Sample
Depth (ft)
, of Sanples Analyzed
in ""ich Co11xxmd
Was Detected
O1-site
Off-slte
Volatile O~anic Priority Pollutants(l)
Tolu9ne 0.014 OA 23-2 12 (10-12) 25 0
Methylene chloride 0.140 OA 23-4 12 (45-85) 100 100
1,2-Dichloroethane 2.70 M 23-2 14 (25-27) 100 29
Chloroform O.Oll DI\ 23-2 12 (10-12) 25 0
Ethyl Bel\2ene, <0.01 m 23-2 12 (10-12) 25 0
tetrachlovoethene
Explosives(2)
'rnT 0.6 OA 23-2 11 ( 5-9 ) 50 N/A
0.5 DI\ 23-2 12 (10-1~)
,., ',-.t
. CS, BZ , Degradation Products 1btal Orqanic nalides(2)
.....
....
I Benzylic Acid/ 9.0 m 23-2 II (5-9)
8e nzophe none 3.6 OA 23-2 12 (10-12) 75 6
'\. 1.9 Df\ 23-2 12 (10-12)
1btal Organic Ifalides( 2) 1 \ .0 Ot\ 23-2 13 (15-19) 25 N/A
(20-22)
1btal Cyanide(2) 0.18 OA 23-4 11 (0-2) 25 24
0.58 Ot\ 23-4 12 (4.5-8.5)
()A ::; Disposal Area
N/A ::; Not Analyzed
O1-site Off-site
(1) Number of locations saJrpled 4 3
Number of samples collected 4 30
Number of samples analyzed 4 17
(fl-s i te Off-site
(2) Numher of locations s~led 1 3
Numher of samples collected 4 30
NlwWer of samrles analyzed 4 17
-------
The highest concentrations of ~atile organi.cs in the groundwater were
detected in manitor wells ~ien~ of DA-23 &8 shown in Pigure 5 and
tabulated in Table 2. COncentntiona of 1, 2-cUchloroethane range from
0.15 to 7.4 mq/L. In this arelf-,; higher concentration. of volatiles were also
detected in the deeper portion ~ the aquifer, indicating downward as well as
lateral migration of the contaminant.. 1,2-Dichloroethane was a180 detected
in .tream sample RW-7 (Pigure 5:);. indicating that this compound is discharging
with groundwater in this vicini"t)' into the northern tributary of the unnamed
branch.
Lower concentrationa of two other volatile organic compounds were also
detected in this area, .pecifically, 0.11 mq/L of chlorofonl in manitor well
(HW) SW-4 and 0.013 mq/L of trans-1,2-dichloroethene in HW H85L-4.
Benzylic acid, a degradative compound of BZ, was detected in HW SW-4 at
470 mq/L (Pigure 6). This implies that BZ derivatives have migrated
downgradient with the groundwater from the Building 113 leach field. RDX and
picric acid were also. ietected in the groundwater downgradient of DA-23. A
concentration of O. 04t. mg/I. of RDX in HW SW-6, which is located upgradient to
DA-23, may indicate t!'~~t this well is located near the abandoned tile
drainage line leading 'from Building 113 to the 1:each field or within the
upper boundary of the . .each field itself. A low concentration of
bis (2-ethylhexyl) pht. alate was also detected in HW SW-6 (Pigure 6).
Groundwater in the vicinity of HW - SW-S, on the southwestern side of the
unnamed branch, has also been adversely affected (Pigures 5 and 6).
COntaminants in this area include trichloroethane, RDX and trans
1,2-dichloroethane. According to groundwater flow patterns in the area, it
is unlikely that these contaminants are coming from DA-23 or DA-10/1l. It is
feasible that these contaminants have migrated from the leach field of
Building 107 (Figure 3) or are a result of other past activities or incidents
within the upgradient area.
Lastly, 0.17 mg/L of trichloroethene'was the ~nly contaminant detected in the
furthest downgradient HW M8SL-11 (Pigure 5\. It is unlikely that this
contaminant originated from DA-10/l1 since this contaminant was not found in
either monitor wells, SW-2 or SW-3, both of which are immediately
downgradient of DA-10/11. This is f~rther supported by the fact that no
trichloroethene contamination was d6tected in any of the soil borings samples
collected from this area. The abAence of trichloroethene in groundwater
downgradient of DA-23 indicates that the source of trichloroethene in
HW K85L-11 is not DA-23 and is therefore, most likely due to some other past
activity or incident.
"
In summary, the extent-of the groundwater contamination in the surficial zone
in the Pront Valley is greatest downgradient of DA-23. The majority of
contaminants from tb.is area are migrating with the groundwater and
discharging locally into a northern tributary of the unnamed branch.
Groundwater contamination in other areas within the valley are most likely
due to the presence of other old leach fields (such as that of Building 107)
or other past activities. Pinally, given that no contaminants were detected
in groundwater samples collected from wells downgradient of DA-10/l1 during
the RI and only methylene chloride at 0.007 mg/L in the OCtober 1987 sampling
episode, it appears that contaminants have not moved from this area.
-12-
'." ... ,"
'-"'--"", -". ".'7;""
. .
-------
t
-... .-
FIGURE 00.
5
LOCATIONS APID CONCENTRATIONS OF VOL.~TILE CONTA~IN.~
ASSOCIATED WI'IH DISPOSAL AREA 23 roUND IN 1HE GROUNDHATER
IN TIiE FlDIT VArLEY
-13 -
-------
'''!II
. .
Ul1llrad lint
SII 6
BII )
.1
.8: f1ou"lradlent
1
S\I II .
III I
. JIll II
UII 5
II" 6
BII t)
H8'illl
H8'ilIO
HOSL 1\
T,p8
Sha II ow
lIedrock
Shallow
Inter_dlate
Bedrock
Btdroclc
Bedrock
Bedrock
E.lltln,
hlltlnl
£I I Itlnl
- . no~. Jet.otld
. . ql:4".:. In ed data
NA.. n-"~ analyzed
~
if
..
(.Q
~
ro:ti
",'b"
Volatll!!
~b
c.
.
~
J
cl"
.\
...tJII
aIel Produat,
~CI
,
~, J tI'
! .Y~
6 ~.,
~
. 'I bit
-!i ~-
f: ~
~ fill tt
fl' ~ ,di ;:
.Y :[1I\J ;
~ id' .: ,"
[!ploll'eI
I
~
~
,l' I.,
~ ~i:"
"6 S., 0
~~ ~ it
~
.~o
l
6"
"
11
~
cd'
q
(0.01 - 0.012 0.0116 - . ' III I 6.12
;" (0.01 . HI 6.30
2.1 0." (0.01 0.059 - I.' 0.01 '10 6.11,
0.511 (0.01 - III 6.01
0.5) (0.01 - 0.0) 0.0511 . 0.1100 6.60
0.15 (0.01 . 1.0 '.06
(0.01 (0.01 - (0.01 - (0.01 0.01 . II' 6.5)
(0.01 (0.01 (0.0110 1.-5
0.15 (0.01 - (0.01 - . "I ' 6.U
1.' (O.l (0.2 (0.2 0.021 ' 1.2 ' 6.16
0.110 - . 11& 6.111
- ~ .:~ " .t.'l,,?
TABLE NO.1
CONTAMINANTS FOUND IN 'I11E G~1.\J!lN'~lATER TN TilE VrCINITY OF
/HSfa3AL ARt::A 23
(I) MJ8ber or well. In thll Area: II
(~) Phlhiliale ooncentrillonl arl allU88d to be the result of contact between ,roundwater .nd phthallte-contalnln, ..tarla.a durin, well
handl hll and 8naly,., In the labontary.
(3) Contaminant Levels "'~asured in mg/l (parts per million)
In.tallatlon. or
.,. ....;...
. .~.
. .'
t
.:~,' lJ-~r .~~c
-------
"
.0.. '. -., '. -.. --. ... -.. - . ..,. .
......' ,'- . ,"~' ~...-." -, --- - --L --=-~...- '~ " ", "y'" " - '--. ' '.
. , --.. _.'~ I' .., ... ,~ f.l~""" \. ", ~. .......... - '. ..
'~"" ", /',.,." ...'..--:"',J ". - '-,. i l "", .....~" " ~' "" ,', - .'......-.-, ,... ' '"
~ ~. ~~~ .--<3-~' 'L, cC:--&.:/ ,:::=- ,::.-.:.," .......-"':~ I:-";:'~ --'--- -,', '~~.::
\ .'/ z.. '~'. , ".0--- . .~":'; ': '- - " \' "..' -'-.- ........ . '..~ '-~
)~-!/J.l-3l-F~r-4'lt_-~'$-:~{~~"'~~~~-:"""~
>.-71'{" '--:::-:;3CoCf- ',\," I:'~'>I \,£y:~,::-;~~~\\\\~. ~ \~~
. . ~ ;",.!.., ". \ -- . '- . .. . <. '-' .,. --- \, ~... "-"'-"-, ,
~ ~ ..!_~ , ~\. ~ "'.:v.~ ~..~~.. '\ '".... .~
~uc:~~~:: 1L ~ ;~""~ ..~':.. "'\~'~~\~~~ \~ --~~~~ a- f({(\';
.. OoGS';'" .', ~""J' r;;;;... \ ',:,~, ~'~' .. 12-.ctIp..::.....U ~.." ~ I
1aa1 ~d8 0-010 ~" ' . @~' ~', --, - --, U0W46 /' J 1
1aa1 "'--'- 8.....0- Ie"" ,. , .-..-. ~~ . .
---- - " I., ''''''''..... 'i.. '-" 0..- ' , r
,I,,! f ~':\"':\'\.. \! ..~ ~, " ,/" ""'7}" .! ';: r- ----. \/ iI,
r+r~.1 \'F'\)\l, , ~~:! ;, 'If';..I, \,- ~,,:£:~-: ~','" ~. ,-~ i if': ! } \
..J \ U ", ~ - ; ; :'~ :," '-~ 'I i~~~' , . -o.-rd:P"'- , /: ~r I 1 :
~\"~..:r"",,, '/,';'\. ~ri\ !..\~7 _.-~. ~,~~'L 7,;/71,"',///
It! , , ,\ I' ~O S , :;'-----/.' ,'~ /' "
1aa1 Cr;IInicll8U- ~.oao " i ! "- . . , 7, ~~-/.... /~/" ,.,/
,/' ~.~ .\ \\ '... '-. // ,I' .. "... ,,'. -. \\ ~. / / N/D ~-:::.- --"-;-<'j%:"'/"
" , , " - ,.. / i' ( , " '..-. -' , /' " ....
\ ,,:'~' "'. .",,// , \<\.' ! ~"', .... .! /:,,>: ,/ --- .-'.'/ / o",
;' , ~ . ~" I ~ ..-. .. 23 ' '/'
, ' :'': \, i N/D~:. B \'~ ,_..' "'..,.' . /""",/,,/, DISfWl M£A ~' "/1.1
~,-" ' , "/"1 ' ,I
; ~'\', - . "'.:' " ;: I " / ; "..' / I i
" \ \'\\ BW:S"'~eSw':e" :t~~/' ~ - L.20 .-' 1,,' It! 10m ..,,~,~<::::~.;~
"\ \ \: ',,\, \ '\\, ;J" " " J. l~~ , , r' / (> ' ~~-r~~~~--- O~:o CIIf ( / '/~:
: ~ .'~.~. . \ .,.. F . , i .' :.~ Dtlus.lace '\ ~ .,/ ,... .*'.--
~ . /' ,i /1, ,-,{" ~ ~CIlalJ- 0.-. ' :{' "":' ,',..'
l1l:I ~ ~" r ~.. \' , ' !,'",..
- ~ -.'-: :: :~ J'.- ':'\' "/
atzalri... O.l!O. :..:...-- :', . . , _.J . --: . . ~ ,;: :.; .
L88d o~oo //1;" : ' , .. - - . /," ': ': ':; i
." : ~: Kr 1011'7 :" ........, ..,1'.- -~_.".' ./1 o;j'.
~ .. '1 i .A : '.. ~ "-'. ~11c AcidIL.-,.J.8Q- rmr ~ I' .," I" "l~/.."--=---::':"" ~ .: :. . : '
, ':' -I' 'f,,' ,~ I i! Ptc:ncAcid 0.DZ3 ",,': 'tf.J' ,,"-,,-':--J,," ,',/:
......-. I. !~,. """"'II t ' to . . , I, .' .~~.., ..0 ., .; .
- ~'" t: ",': ~ 1 , ,': A \ ',' ,',- - - "'" ':
~_-::..-¥ ',I;;' -0' : ,: O( I' . 't ,.,;--\ .' ,eo." .0' ." '., '/
'''-';' ";../ '_....'~, I, ,,:":: ,-" f,'" ( "'-.. i: :,: ":'/ "
~-~ I. -...-. ~. " .' . \... ,. 1 ; ,. . . , . "T, ., . '..,
.-:." t.";": :1;;;"/ ,", 1":!!1, ',;:I:!",','\'\:i .,."V :,\,\,,' 'I;:,':
. :..,..- -I ',' : J. .JO' . :j' :. I. . ;". ,", .. 1. . ; It'. '0 ~... -' ": : .'
;>" ..1. 'idrl,.!i " ,~,". ~~. \'" :(::'.'~:".'.', : t \ =-..(. \" '....."':....---..:::.',:.\:;:!
" "":', :41' '-J.1 {/ :i' ,')1\, -<"':"'\~:: ", """'- ,.._-:::,:"... '."::'\", ,,',
~.,,' ," . ~ I"" \ .(. ""-"---- '. . ,\ ", \"'. ...... \ " . '. I
1...--...'-'" .,~ " j',' ' " ',',\of '-;''',:0\:,' ",'- ,""',';\'",,.
."~ -:;.- "'" .\ IS", il: :' Q" \ \ ('/ '.-: ~
. --" " ',~, '. '. ' '" ' ,I" c::-' ~"
, . ~ \ " '''; .: ;~ 1: .:' ...' . ~-.: J . o. .~.
\ 'r \..)- '\ i? ~ : :! \.. ~''-0'! '\; i It-:"! L..~" LEGEND
. \\ '0 ..... '. .; ,. . . . ,: .; ". :
-~\,"'\ \ - ,,\ \.....:-'-",' I (7", ; f : I: \,i~~~ 0 Existing l-1onitor Well
} \\ V ,I:,~~~" /-:-:~, ::' ~'.~ ;' ...~ Q Newly Installed Surficial Well
,...: . I' \' ".! " J. !" ": ,,: ;: I '.., \ ~
....,~: .:..' \ " .,~ ~,i ; :,' to";:"', ~-- . Newly Installed Bedrock Well
~> \c,-.~~/,; /' 'l: I: L: - !./ :', '\ - "'\ .,..;:: RI - Samples Collected Between
"......" , ". '/ / (, J /' c..5 /,. , \ \. " ";-\ I''--?- January + September 1 986
, Je/ 1/: , II: I: (" \ ..'" " ,....~ . \ /.
, ~' ',', I ,"/.1 I f \ '. ;:.../-" , '\' '\ '.;: 10187 - Addi ti ona 1 Samp 1 es Co 11 ected
/,';1' " I i/,,~: i ~~ "'" ~.... ,i ( ;' in October 1987
,. . ..-!. . t.'..r """'-.; ~ J \ ..' '\..,,! .
}.... ,,-;(::: BW.& It!:! .: ,,: .",...'(~\ " , Reported Levels of Cantaminants
/r" ' e8"",-0Izari- G.m' {,.. ':'::":-I"\..\')' '~'~; are mg/L (parts per million)
/" .. IW.' 4 ' \ ~ \
, ,," '... '\ ,,""',' \ \ \.\)\, NID - No Contaminants Detected
: / " ' ,': 1 I \.. Ja ' / ,"'\: \ \
'---: :?> '/ I~ I =-,-" ::;: ci \ ';y,:~.~~ ':\'~'0..~'~""'~~,~~."~~~~
~ ' ,/ \' \~~..,I.Z'~ ,~,'. " " <~
-------
. ,
The bedrock zone of,A;the aquifer in the Front Valley contains three
cont'lIftinants: 1,2-cti:chlor081:hane, bis (2-ethylhexyl) phthalate, and
chloroform. The ext:ant of this contaadnation is in the vicinity of two
wells, BW-4 and BW-5 (Figure 5 and 6). The contamJ.nant cle1:ectecl in HW BW-5
W&8 1,2-dichloroethMe at a concentration of 0.15 fDIJ/L. The source of this
conta",i fta"t could ~. DA-23 in that this well i. hydraulically downqraclient
fram thi. disposal :area. AD e.sentially horizontal fracture in the bedrock
was detectecl in HW 'aW-4 that could provicl8 a pathway for this compound. This
would explain the a~arance of this cont1lll",i ftant in of HW BW-5 but not in
HW SW-5, which was completecl in the surficial zone.
...
.- .
. "-
Thr- contamhuu'I,t. were cle1:ectecl in KW BW-4: 1,2-c1ichloroethane,
biB (2-ethylhexyl) phthalate, and chloroform. While the low concentration of
biB (2-e1:hylhexyl) phthalate i. liJcaly t.h8 result of sample contamination,
the pre_nce of 1, 2-c1ichloroethane and chloroform can be directly relatecl to
waste disposal in DA-23.
In sUIDID&rY, the only area of the bedrock zone affected by disposal activities
in the Frof1t Valley appears to be primarily in the vicinity of wells BW-4 and
BW-5. Th!. leads to the conclusion that the contam.i.nation of the bedrock
zone of t}~. aquifer in this valley is of limitecl extent and has miqratecl less
than 800 l' 8t from areas of waste disposal as evident by the absence of
contaminan':s in wells. BW-6 and intermediate monitor well '1 (IW-1).
3.5.2
GROUNDWATER CONTAMINATION IN GREGG VALLEY
Refer to the Chem1:ronics ROD datecl April 5, 1988.
3.6
SURFACE WATER AND SEDIMENT CONTAMINATION
Refer to the Chem1:ronics ROD elatecl April 5, 1988.
3.7
RECEPTORS
There has been no change in the identified receptors between now and the
April 5, 1988 Chem1:ron~~d ROD.
The routes of exposu~.. examined in the Risk Assessment were:
1) in~'88tion of contaminatecl groundwater, surface water and wild life;
2) direct contact with the contaminants in the soil, surface waters or
qrounclwater; and \
3) inhalati.on of vapors or contaminatecl particles.
The aquifer under the Chem1:ronics Site is classi.fi.ecl as Class IIB, a
potenti.al source of clri.nki.nq water, usi.nq the USEPA Groundwater
Classi.fications Gul~:;:;lines of December 1986. Although the site aquifer is
not currently used for clrinking water purposes, potential (future) use was
incorporated in the baseline risk assessment. COnsi.deration of potential
groundwater use is consistent with 40 CPR Section 300.68(e)(2)(v).
-16-
-------
"
'. ':..
Groundwater, as noted, is contaminated on-site. The general flow:qf
. -
groundwater is to the e_t and west to the unnJlll-d stream and Greg9.' Branch
and eaat - 'to Bee Tree creek, ctischarging to these surface water fea~es.
Groundwa-ter contamination w- particularly noted c10wngradient of the Acid Pit
Area and DA-23. Ho drinking water wells exist between the Bite and~the
groundwat.r discharge points, thus a pathway via c1cm8stic well usage doe. not
exist. ' "
CUrrently, fugitive dust particle generation is considered an unlikely
event. The majority of the disposal are&8 are capped by dirt and are
vegetated. one area, a1.though vegetated, has numerou8 empty drwD8 exposed at
ground le".l. This area, DA-9, was identified in the RI to have the greatest
degree of risk to exposure to the contaminants present. The chance of
exposure is greatly reduced to the remoteness of this disposal area.
COntaminated soils will continue to leach to surrounding soils and
groundwater.
--
Surface runoff from surface .oils may contaminate additioaal Boils
surface waters and .ediment., although concentrations wou~d not be
to be high.
and
expected
4.0
CLEANUP CRI'l'ERIA
There has been no change in the cleanup goals between now and the
April 5, 1988 Chemtronics ROD.
The extent of contamination was defined in Section 3.0, CUrrent Site Status.
This Bection examines the Rapplicable and relevant or appropriate
regulationsR (ARARs) associated with the contaminants found on site and the
enviroamental medium contaminated. In the cases where no specific ARAR can
be identified, a defendable minimum goal of remedial action will be
presented.
4.1
GROUNDWATER REMEDIATION
In dete~ning the degre. of groundwater clean-up, Section 121(d) of the
Superfund Amendment and Reauthorization Act of 198'" (SARA) requires ,":hat the
selected remedial action(s) establish a level or standard of Qontrol which
complies with all ARARa.
This remedy is a cost-effective r~y which will achieve a level protective
of human health as will as remove ~he threats this Site pcses to the
environment. The remedy will meet appropriate requirements, and is
cost-effective. Finally, the remedy utilizes permanent treatment
technolQ9ies to the maximum extent practicable. -,'.
The presence of several contaminated found on Site presented some special
problems with respect to the establishment of target cleanup levels. Since
these chemicals either lack or have only limited human health standards and
supporting physiochemical and toxicological data, it was necessary to develop
-17-
-------
. .-
preliminary pollutant limit values (PPLVs) for critical ~posure
pathways, using estimate. of acceptGle daily doses (DT~~d
partition coefficients. The calculations and supportinqt.~eferences
for the- PPLVs are presented in Appendix A of the pea.i;b,J.lity Study.
::t.
"
. .
por those contaminants found in the qroundwater on-site '1'cle 3
pre.ent. the levels the miqration control remedial alternAtive will
achieve at a minimum.
4.2
SOIL REMEDIATION
The Public Health and Environmental Asses8lD8nt in the RI (Chapter 4),
determined that risJc8 to human as a re.ult of exposure to on-site
contaminants via inhalation, ingestion and densal contact are very
low under present Sit. conditions. por potential future us.
scenarios, the risk i. slightly higher. Therefore, remediation and
institutional controls will be neces.ery to assure that an increased
risk to human health is not posed in the future:.
Table 4 presents remediation levels the source ~~ntrol remedial
alternative will achieve. This includes PPLVsf,r these contaminants
lacking promulgated criteria or standards.
4.3
SURFACE WATER/SEDIMENT REMEDIATION
The contaminant levels in the surface waters (the unnamed stream and
Gregg Branch) are expected to decline with the implementation of
qroundwater and soil remediation. Thus, it was concluded that the
remediation of surfacewatsr is not nec.ssary. A biomonitoring
proqram will be implemented to document that the remediation
activities do not have an adverse affect on the surface waters. The
RI did not identify any contaminants entering Bee Tree Creek from the
Site.
;'.0
ALTERNATIVES EVALUATED
Refer to the Chemtronics ROD dated April 5, 1988.
5.1 MODIFICATION OP APRIL S. 1988 RECORD OP DECISION REMEDIAL
ALTERNATIVE POR DISPOSAL AREA 23
\
Based on a correction of analytical data with regard to the chemical
quality of the groundwater downgradient of DA-23 in the Pront Valley,
it has been deemed necessary to change the source control remedy
selected for DA-23. The mandate to address post-ROD ch~~9QS is
provided by Comprehensive Environmental Response, compensation, and
Liability Act of 1980 (CERCLA) S117(c), which states:
"After adoption of a final remedial action plan --
(1) if any remedial action is taken (under
sections 104 or 120), (2) if any enforcement
-18-
),,;..
-------
~ion under s~ion 106 is taken, or (3) if any
-ett1ement or consent decree under section 106 or
section;122 i. entered into, and if 8uch action,
.ett1ement or decree differs in any 8ignificant
respects from the final plan, the lead agency
shall publish an explanation of the significant
difference. and the r...on. such changes were
made.-
5.1.1
CHANGE IN 'l'HB RECORD OP DECISION
The r8lD8clial action .elected in the Chemt:ronics April 5, 1988 ROD for the
contaminant. and contaminated soil. a..ociated with DA-23 was a soil
fixation/stabilization/solidification (f/./8) process followed by capping the
entire disposal area. The f/s/. alternative was selected due to the
concentration level of the non-volatile organic contaminant benzylic acid and
benzophenonA found in the groundwater downgradient of DA-23. The Remedial
Inve.t.igatiQn Report, dated April 1987, 8tated that the concentration for
benzylic ac~d/benzophenone in the groundwater downgradient of DA-23 in
monitor wel~ (HW) SW-4 as 470 milligram/liter (mq/l). This concentration is
equivalent to 470 part. per million (ppm). HW SW-4 is a shallow monitor well
and 470 mg/l is a relatively high concentration for a contaminant in
groundwater.
In OCtober 1987, approximately one year after the original sampling episode,
nine (9) monitor wells were resampled. KW SW-4 was one of these wells. The
analytical results for benzylic acid/benzophenone for SW-4 was 1.2 Mg/l,
which is considerably less than the 470 Mg/l level recorded in the initial
sampling episode. The concentration level of 1.2 mq/l is more in line with
the levels found in other wells downgradient of DA-23 &s can be seen in
Appendix A.
It was the Agency's rationale, based'on the level of 470 Mg/l, that the
concentration of benzylic acid/benzophenone in the soils of DA-23, the source
of this contaminant, must also be relatively high, therefore requiring a More
rigorous source control remedial action. This thought process led the Agency
to select a soil fists process &s the source control remediation for DA-23.
The fists alternative was selected over soil venting or capping due to the
fact that the contaminant of concern, benzylic acid/benzophenone, is not
readily volatilized. Although soil venting would help remove the volatile
organics from the soil, it would not remove the non-volatile organics.
Usually, it is the non-volatile o~anics that determine the length of time
necessary to pump and treat the groundwater as non-volatile organics do not
read~y moV& with grou~water through the soil &s do volatile organics. Soil
venting would help reduce the levels of volatile organics, but it does not
address the non-volatile fraction of contaminants and therefore, soil venting
was not sele~e4 as the new source control remedial action for DA-23.
Due to the lower level of benzylic acid/benzophenone than first identified as
being present in the groundwater downgradient of DA-23, and the fact that a
-19-
-------
f*
TABLE ~~" 3
'i.C
GroUNI:WA'I'ER REMEDIATIOO LEVEIS AND CITED REFERENCES
Ii
r.
'",
.' '
n. .I....,..u~
Remediaticn I.evel
m::rll
SaJ:rce'
1,2-Dic:hlcroethane
~~~thylene
Methylene Chlarlde
'l'rans-1,2-Di"'" a;oethylene
Benzene
~cz:m
EthyJbemene
TeC:achlarcethylene
- ~fCJ:D1
caz!iQl1 'l'et:rac:hlcride
. i '1'ol1J1.me
Pic.- Lc: Acid
1mX
'INl'
~ cyanides
Iead.
Chranium
Nickel
COpper
Zinc .
Benzilic Acid
Be..71Zcphencne
MCL
MCL (T!P.M)
:eaG
PPLY
RfD
RSD
USAIYQ:
i'Q:
~TLV
... .".. ~. ~. -.- . ,
0.005
0.005
0.06
0.07
0.005
0.1
0.68
0.007
0.1
0.005
2.0
14.0
0.0:35
0.044
0.200
0.05
0.05
0.5
1
5
0.021
0.152
MCL
MCL
asD
EH:I.G
MCL
MCL(TmM)
BaG
RSD
MCL(TmM)
MCL
BaG
PPLV
USAm;C
PPLV
RfD
MCL
MCL
RfD
MCL
W;C
PPLV
PPLV
,
- MaxlJIDJm 'Ccntaminant Level.
- 'nle MCL for Total Trihalanetl1anes (sum of all ccnc::sn-
trat-:tJnS) is 0.1 m:T../l. '!'IEM's include c:hlcrofoz:m,
br;~""fcmn, L.~c:uorc:methane, ani c::hlo:rc::x:iibratD-
~.ethane.
- p.1..~ Ma".,n'll"l'lm Ccntaminant level Goal. 50 m 46936-47022
(November 1:3, 1985).
- Prelimina%y Pollutant r1ut Value (see A;pend:ix A) .
- Reference rose 52 m 29992-29997 (August 12, 1987).
- Risk Specific tcse, 51 FR 21648-2J.693.
- US ArrIrJ Water Q.Jality criteria. '!he given values have
Ceen ~roved by the Arrrri surgeon General.
- Clean Water Act, Water OJality criteria for Human Health
- Adjusted for Drinkin:; Water Only, [Gold Book).
.
- CalOJlat.ed !ran a 'n1reshold Limit Value, based on a 70 )a;:
~n \Ilho drinks, 2 liters of water per day. A safety
fa~...or of 100 has also been a.wlied.
-~o-
-------
,.""
~
... ..
-
TABLE NO.
4
;;1:.;SOIL REMEDIATION LEVELS FOR CONl'AMINAl-ms tACKING
,.:,~ CRI'l'ERIA OR STANDARDS :.f);
'
...
.::
Contaminant Gram SOil Standard ~JTQ/KQt ..... Source
PCBs 10 TSCA
3-CUinuclidinol 25.7 PPLV
Benzilic Acid 9.3 PPLV
Benzophenone 9.3 PPLV
CS (2~lorobenzal- 43.3 PPLV
malononitrile) ..
'""
Malononitrile N/A+ PPLV
o-chlorobenza1dehyde 0.31 PPLV
'!'NT 305 PPLV
RDX 95 PPLV
Picrate/Picric Acid 38,000 PPLV
+ - ~alononitri1e would not persist in soil based upon Kd partition
coefficient
\
-~l-
-------
80il v~ting alternative would not decrease th& time needed to remediate
DA-23, ..theAgency selected as the preferred source control remedial
alternative for DA-23 to place a multi-layer.':Q~p, which includes a synthetic
liner, over thia disposal area inatead of tmpl9menting a f/./s process to
remediate the contAm~nAted 80ils of DA-23. The multi-layer cap will meet as
a m~n1mum, the requirements .pecified under 41)! Cl'R Sub.action 264, Subparts
K-N. A'" g&8 collection .y.tem will alao be incorporated into th8 cap if
daemecl nace..ary. -
5.1.3
DOCOMEHTATION OF A 'l'RAHSCRIP'rION BRROR
In a letter dated September 19, 1988 (App8~i" B), the PRPs informed the
Agency of a. poasible transcription error made by the laboratory contracted by
the PRPs to perform their ~ytical analy.e.. Inatead of reporting the
detected concentration as 470 microqrUUl/liter (ug/l) or. 470 parts per
billion (ppb) aa they should had done, the laboratory reported the
concentration as 470 mq/l or 470 ppm. Misplacing the decimal point by three
(3) places reaulted in a change of i:pncentration by a magnitude of three (3).
Thia information and the d0CWD8ntatlcD to 8Upport the reported transcription
error was transmj,tted to EPA, Region IV Chief of the Quality Assurance and
Laboratory Bvaluation Section (QALBS of the Environmental Services
. Division. Uter reviewing the docum':Jntation, QALBS concurs that a
transcription error had occurred (Appendix C).
5.1.4
CONPIRMATION OF GROUNDWATER QUALITY
Prior to making a final decision on whether to change the selected source
control remedy for DA-23, the Agency resampled MW SW-4 the first week of
January 1989. The analytical results for the January 1989 sample are 48 ug/l
for benzylic acid and ~400 ug/l for benzophenone. These results confirm the
lower concentration range of 0.0 to 470 ug/l and not concenr.4tions in the
hundreds of parts per million. Therefore, the Agency elec~ed to change the
source control remedial alternative for DA-23 trom soil:~/s/s to capping.
The cleanup goal, as specified in Table 3, for benzylic acid and benzophenone
are the same as stated in the AprilS, 1988 ROD. The goals for benzylic acid
and benzophenone are 21 ug/l and 152 ug/l, resp8('<:.i.vely.
Capping DA-23 will be as protective as would h.ve been a soil f/s/s process
of human health and the environment. This is based of the findings that the
exposure pathways for the contaminants found at DA-23 are consumption of
contaminated groundwater and disc~ge of contaminated groundwater to surface
streams. . These findings are documented in the Public Health and
Environmental Assessment section of \:he Remedial Investigation report and the
Endangerment Assessment incorporated into the Peasibility Study document.
Both of these pathways are mitigated by the groundwater extraction/treatment
system required for the Front Valley under tb6 Migration 'COntrol section of
the ROD. Therefore, in terms of protecting the public health and the
environment, capping DA-23 and pumping and treating the groundwater in the
Front Valley of the Chemtronics site achieves the same degree of protection
-22-
I
I .
-------
aa the _8Oil f/ s/ s proceli8f; As documented in the peaaibility Study, capping
is the Diere coat effectiv~ remec1ial action. '1'he Horth Carolina Department of
Human Resources haa been?apprised and is in complete agreement with the
Aqency' (j.~ propo.al. "
-r-
In adcUt'J.on to meeting the requirement of Superfund, being cost effective and
protecting pu):)lic health-ud the environment, capping DA-23 will al.o satisfy
the post clo.ure requirement. imposed upon the owner/operator of the facility
by the Resource, COnservation & Recovery Act (RCRA) programs of the Agency
and Horth Carolina Department of Human Resource.. '!'he RCRA proqrams are
involved with DA-23 becau.e the biolagoon was operated po.t-1980.
Under RCRA, when a bu.ine.. or individual .top. operating a .olid waste
manaqement unit (SMtJ), the SKU need. to be closed out according RCRA
regulation.. Capping DA-23 and pumping and treating the groundwater will
I1188t RCRA'. requirement..
i -
I
5.2
HINE POIN'!' EVALUATION CRI'l'ERIA !'OR EVALUATING REMEDIAL ACTION
ALTERNATIVES
Bach alternative was evaluated using a number of evaluation factors. The
- regulatory basis for thes8 factors' come. from the Hational contingency Plan
(HCP) and Section 121 of SARA. Section 121(b)(1) .tate. that, 8Remedial
actions in which treatment which permanently and significantly reduces the
volume, toxicity or mobility of the hazardous substance., pollutants and
contaminant. as a principal element, are to be preferred over remedial
actions involving such treatment. The offsite transport and disposal of
hazardous sub.tances or contaminated materials without such treatment should
be the least favored alternative remedial action where practicable treatment
technologies are available.8
Section 121 of SARA alsa requires that J~e selected remedy be protective of
human health and the -environment, cost-effective and u.e permanent solutions
and alternative trea:tment technologies or resource recovery technologies to
the maximum extent practicable.
Based on the statutory~',language and current U.S. EPA guidance, the nine
criteria u~ed to evaluate the remedial alternatives listed above were:
:::
1.
OVerall Protection of Human Health and the Environment addresses
whether or not the remedy provides adequate protection and describes
how risk8 are eliminated, reduced or controlled through treatment,
engineering controls, or ~stitutional controls.
-j
Comcliance with ARARs addresses whether or not the remedy will meet
all of the applicable or relevant and appropriate requirements of
o~her environment~'-statues and/or provide grounds for invoking a
wavier.
2.
3.
Lona-Term effectiveness and ~rmanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
-23-
-------
S"
;,
5.2.1
4.
Reductibn of ~oxicitv. mobili~v. or volume is the an~icipa~ed
perfonrance of ~he tr.atmen~ ~echnoloqies a remedy may employ.
>j.
5.
Short-t6r'ID eff~iveness involve. ~h. period of ~i.m8 needed to
aA:hieve'pro~ection and any adverse impacts on human heal~h and ~he
environQ29n~ ~hat may be po.ed during the construction and
impl8JD811tation perioda until cleanup goals are achieved.
6.
Imolementabilitv is the technical and administrative feasiDility of a
remedy including the availability of goods and services needed to
implement the cho..n .olution.
7.
COst includes capital and operation and maintenance costs.
8.
SUmx)rt Aaencv AcceDtance indicate. whet:her, based on its review of
the RI/pS and Proposed Plan, the support: agency (IDEM) concurs,
opposes, or has no comment on the preferred alternative.
9.- Community AcceMance indicates the public support of a given remedy.
( This criteria is discussed in the Responsiveness Summary.
OVERALL PROTECTION OF HtJMAN HEALTH AND 'l'HB ENVIRONMENT
The change in the selected remedial action for DA-23 will be as protective as
a f/s/s process. The primary route of exPOsure identified for DA-23 was
exposure to contaminated soils and ingestion of contaminated groundwater
emanating from the disposal area. The multi-layer cap will prevent
percolation of rain through the contaminated soils and recharging the
underlying groundwater with the resulting leachate. COupled with the
migration control remedial action, pump and treat groundwater, these two
remedial actionr will adequately protect human health and the environment.
5.2.2
COMPLIANCE WITH ARAitS
Thip ~~dification to the April 5, 1988 ROD does not trigger any new Pederal
and ~tate applicable or relevant and appropriate requirements.
5.2.3
LONG-TERM EFFECTIVENESS AND PERMANENCE
This modification to the source control remedial action for DA-23 does not
greatl" impact the long-term eff~iveness and permanence of the
remediation. The multi-cap will decrease the contaminant's mobility as well
as the risk of direct contact.
5.2.4
REDUCTION OP TOXICITY. MOBILITY. OR VOLUME
The multi-layer cap will reduce the mobility of the contaminants and the
volume of contaminated groundwater but does not address the toxicity of the
contaminants.
-24-
-------
-.
5.2.5
-'Xu
SHORT-TERM EPP'EC'l'~SS
. ,
"
During ~he construction of ~'~e mul~i-layer cap~' dust release may occur.
.=:... .
-\I-
..
5.2.6
IHPLEMENTABILITY
There should be no difficul~y wi~h the design and construction of a sui~able
mul~i-layer cap.
5.2.7
COST
capital cost for qroundwa~er remediation i. eatima~ed ~o be $239,000 wi~h
system O&M cos~ at $139,500 for 30 years, which includes sampling and
analysis. The ~o~al presen~ worth cost of ~he groundwater remedia~ion 1s
$378,500.
Capping disposal arjas DA-6, DA-7/8,~A-9, DA-10/11, DA-23, and ~he Acid Pi~
Area with a mul~i-layered cap is est~~ed ~o be $1,350,000. The O&H cos~s
for all caps iB $362,400. The above costs include engineering, overhead,
profit, contingency, and adminis~rati'l'e fees. The ~otal oresent worth cos~
ia $1,870,400.
The presen~ worth cost of ~his remedy, including bo~h source and migration
control remediation is approximately $2,248,900.
5.2.8
STATE ACCEPTANCE
The North Carolin~ Departmen~ of Human Resources has been apprised and is in
comple~e agreement with ~he Agency'. propo8~1 and since it is expected that
~he RD/RA will be undertaken by the PRPs, ~here has been no request made
under CERCLA, Section 104(c) for ~he'S~a~e ~o contribu~e ten percent of all
costs for the remedial action.
5.2.9
COMMUNITY ACCEPTANCE
Explanation of Significant Difference Pact Sheets were Bent to all those on
the Chemtronics mailing list including the four information repositories. A
legal public notice announcing the proposed amendment ~o the April 5, 1988
ROD was also published in the Asheville Timers/Ci~izen Newspaper. These were
~he ~wo mechanisms employed to no~fied interested parties, residents, media,
and local and Btat~ officials of tfte ~gency's inten~ion to amend the AprilS,
1988 ROD. In ~hese announcemen~s, .~he Agency also made it known that the
Agency would conduct public ~~eting in there was interest in the local
community.
The Explana~ion of Significan~ Difference/Proposed Plan Fact Sheet described,
in detail, ~he justification for amending the ROD. The legal notice briefly
described ~he Agency's justification. Both announced tha~ there was a three
-25-
-------
week public commeD~period associat~~with the proposed amendment to the ROD
and encouraged the. public to submit written comments to the Aqency. The
cOllllll8nt period endect March 21. ODly..ol18 comment was received during this
time frame. This l~tter dealt with eoveral other issues surrounding the
Chemt:ronics site &1.~ not the prOPOsecb.amendment to the April 5, 1988 ROD.
':s..
6.0
RECOMMENDED ALTERNATIVES
6.1
DESCRIP'UON 01' RECOMMENDED REMEDY
The recommended alternative for remediation of qroundwater and soil
contamination at the Chemt:ronics Site includes extraction, treatment
discharge of qroundwater and capping contaminated soils. The capped
will be fenced with a chain-linked fence and marked accordingly.
and
areas
The water and sediment in the pond on the unnamed stream will be sampled. If
evidence 01 contamination i present, the pond will be drained with the water
being sen1:' through the trea":pent system set up for treating groundwater and
the sediment will be transpc.~:ted to another disposal area and capped along
with that disposal area.
A monitoring program, employing bioassays, will be established for the
surface water. Monitoring locations will be located on the unnamed stream,
Greqg Branch and Bee Tree Creek. The PUrPOse of this monitoring proqram is
1) to insure no adverse impact on these streams during implementation of the
remedial action and 2) .to establish a data base to use to measure the success
of the remedial action implemented.
Soils in disposal areas DA-6, DA-7/8, DA-9, DA-10/ll, DA-23, and the Acid Pit
Area will be capped with a multi-'~yered cap which will include an inert
synthetic liner. Where determined necessary, a ven._ng system will also be
installed.
A groundwater extraction system will be installed in
and in Greqg Valley. The extracted groundwater will
each valley or combined and treated thrcngh a single
groundwater will be discharged meeting "all ARARs.
both the Front Valley
either be treated in
system. The. treated
These recommended alternatives meet the requirements of the NCP, 40 CFR
Section 300.68 ( j) and SARA. This recommended remedy permanently and
significantly reduces the volume of hazardous substances in the groundwater,
reduces thH toxicity and/or mobil~y of contaminants in the soils.
6.2
OPERATIONS AND MAINTENANCE
When the remedy is completed, long-term operation and maintenance (O&H) will
be required for the cape along with long-term monitoring of the groundwater.
This will assure the effectiveness and permanence of the source control
remediation and groundwater remedies. Long-term O&H will also be required
for monitoring the groundwater extraction systems and the groundwater
treatment system(s).
-26-
-------
6.3 COST OP RECOMMENDED ALTBRNAT~
. "'."'!f
.f
... capital cost for groundwater r81118cU~tion is estimated to be $239,000 with
. system O&M cost at $139,500 for 30 ~ears, which includes samplinq and
. ,analysis. The total present worth ,~ost of the groundwater remediation 1.
$378,500. ~
cappinq disposal areas DA-6, DA-7/8, DA-9, DA-10/11, DA-23, and the Acid Pit
Area with a multi-layered cap is estimated to be $1,350,000. The O&H costs
for all caps is $362,400. The above costs include enqineerinq, overhead,
profit, continqenc:y, and administrative fees. The total oresent worth cost
is $1,870,400.
The pre.ent worth cost of this remedy, includinq both source and migration
control remediation is approximately $2,248,900.
6.4
SCHEDULE
The planned
expected to
tentatively
:~
schedule for r8medial activities at the Chemtronics
be qoverned by a COnsent Decree to t)e siqned by the
is as follows: .
Site is
PRPs, but
April
April
Hay
OCtober
1988 - Approve Record of Decision
1989 - Amend April 5, 1988 ROD
1989 - Beqin Remedial Desiqn
1989 - COmplete Remedial Desiqn and Mobilize
6.5
FtJ'l'URE ACTIONS
Pollowinq completion of remedial activities, lonq-term qroundwater monitorinq
will be requir~ to assure effectiveness of the ~roundwater cleanup and
source control remediation. Maintenance of the caps on disposal areas DA-6,
DA-7/8, DA-9, DA-10/11, DA-23, and the Acid Pit Area. Action levels for
contaminants in the qroundwater will be set with the State of North
Carolina's concurrence. If these levels are reached durinq any samplinq
episode after the remedial act~yities achieve qoal, this will triqqer an
v~sdiate permanent remediation of the disposal area responsible for this
Jsvel of contamination is reached downqradient of that disposal area. The
action levels expected to be implemented are MCLs and PPLVs.
6.6
CONSISTENCY WITH OTHER ENVIR~NTAL LAWS
Refer to the Chemtronics ROD dated April 5, 1988.
7.0
COMMUNITY RELATIONS
Refer to the Chemtronics ROD dated April 5, 1988 for summarization of
previous community relations activities.
-27-
-------
".
'.
Explanation of Signific~: Difference Fact Sheets (Appendix D) were sent to
all those on the ChemtrOft~cS mailing list including the four information
f
repositories. A legal l~:blic notice (AppencUx B) announcing the proposed
am8ndm8nt to the April 5"~ ,1988 ROJ) was also publisheci in the Asheville
Timers/Citizen Newspaper, The8e were the two mechanisms employed to notified
intere.t8c1 parties, resi,ients, media, and local and 8tate officials of the
Agency'. intention to amt';1d the April 5, 1988 ROD. In these announcements,
the Agency a180 made it known that the Aqency would conduct public meeting in
there was interest in the local community.
"
4
The Explanation of Significant Difference/Proposed Plan Fact Sheet de8cribed,
in detail, the justification for amending the ROJ). The legal notice briefly
de.cribed the Aqency's jU8tification. Both announced that there was a three
week public coaa.nt period assOciated with the proposed amendment to the ROJ)
and encourageci the public to submit written cOlllD8nts to the Agency. The
cODllll8nt period ended March 21. ODly one comment was receiveci during this
time frame. Thi8 comment and the Agency's re8ponse can be found in
Appendix F.
The four inform,tion repositories are located at:
Buncombe county Bmergency
P.O. Box 7601
Asheville, NC 28807
COntact: Kr. Jerry VeBaun
Services
Chemtronics Site Information Bureau
70 Woodfin Place
Asheville, NC" 28814
University of North carolina
one University Heights
ASheville, NC 26804-3299
COntact: Dr. Gary Hiller
at Asheville
The Administrat_ve
Warren Wilson College Library
Warren Wilson COllege
701 Warren Wilson COllege Road
Swannanoa, NC 28778
COntact: He. Laura Temple-Haney
Record is loca~ at Warren Wilson
COllege's library.
8.0
STATE INVOLVEMENT
The North Carolina Department of Human Resources has been apprised and is in
complete agreement with the Agency's proposal and since it is expected that
the RD/RA will be undertaken by the PRPs, there has been no request made
under CERCLA, Section 104(c) for the State to contribute ten percent of all
costs for the remedial action.
-28-
-------
APPENDICES
-------
APPENDIX A
Source -- Table 8 from the Chemtronica Superfund Site
Record of Decision Signed April 5, 1988
Contaminants Found in the Groundwater
in the Vicinity of Disposal Area 23
-------
I
I .
u.! a a T,pe
Ullgradaent
SW 6 Sha Ilow
BII ) lIedrock
I 1\o~"'.r8d aent
SII . Sha II ow
HI a a ntented a ate
. BV III Bedrock
\:IllS Bedrock
811 6 Bedrock
BII I) Bedrock
H8'jLIII hllLinl
H8,)l10 hlstln.
H8SL II hhLin.
- . not ".hoted
. . quaalraed data
HA . not .naa,.ed
~
.,
l'
~
~t/
....' ti
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<0.01 - 0.012 0.0'6 - . I II I 6.12
./" (0.01 I 11& 6.)0
2.1 0.11 <0.01 0.059 - I.S 0.01 ,.,0 6.'S
O.S' <0.01 - IIA 6.01
0.1)) <0.01 - 0.0) .., o.OS' .,. . 0.'00 .. 6.60
0.15 <0.01 . 1.0 8.0'
<0.01 (0.01 - <0.01 .. <0.01 0.01 I .. 6.5)
- <0.01 <0.01 (0.0lIl0 1."5
0.15 <0.01 .. <0.01 .. I .. I 6.U
t.' <0.2 <0.2 <0.2 O.02J ' 1.2 ' '.16
0.110 .. I IIA 6..1.: .
(I. ~er or well. In thl. Area: II
12. Phthul.te ooncentrltlonl arl ...U88d to be thl re.ult or contact between lroundwater and phthalatl-contaln'nl ..terlal. dur'nc w.ll
hand I all' and anaa,sa, In the labor.tor,. .
(3) Contaminant Levels Measured in mg/L (parts per million)
TABLE NO. 8
'n.tallatlonl or
CONTAMINAm'S FOUND IN WE GroUN~TER IN THE VICINIT'i OF
DIS~AL AREA 23
-------
ili
APPBHI)IX B
Source - Letter (with enc108ures) from
Chemtronics, Inc. dated sep~ember 19, 1988
\
-------
CHEMTRONICS, INC.
..1-'9,OId Bee Tree Road . Sw8M8'108. NC 28778 . (104) 298- 7~ 1
Septeab!r 19, 1988
Mr. Jon K. Bornholm
Superfund Project Manaqer
U.S. Environmental Protection Agency
Region IV
345 COurtland Street
Atlanta, Georgia 30365
EPA - REGION IV
ATLANT A. GA.
, -
Reference:
Chemtronic:s Superfund Site RI Report of April 1987
Dear Jt'n:
It haa cane to the attention of the PRP I S at the Chemtronics Superfund Site
that there exista a data error in the RI report that was accepted by EPA in April
of 1987.
The data point of concern related to the water analysis on sw-4 in regards
to the amount of Benzylic Acid and Benzephenone found in that ~le. The
certificate of analysis presented during the RI and used in generating data
tables reported a quantity of 470 m;/liter or partS' per million. In reality the
actual result was 470,..g/liter or parts per billion. .
,
According to IT Corporation, the analytical service used during the RI, the
error was due to the failure to convert to,. glliter prior to transcription to the
raw data worksheet. Attached for your information are big letters r.eceived from
IT along with their file data on the analysis plus a corrected Certificate of
Analysis.
We seek yt)Ur guidance on the methodology for correction of the record to
reflect actual r88Ul bI ob8erved during the RI versus those reported in error.
-
Sin~rely ,
c?(~~
John F. Schul theis
pap-Coordinator
JFS:wr
CC: Dr. Gary Serio - Northrop
Tony Young - piper & Marbury
Charles Case - Moore & Van Allen
CiA Hallibul'1on Company
-------
'.
rn INTEDlATIONAL ;~~.
TECHNOLOGY :"..~.
CORPORATION ':...~;
. .
September 14~-i988
Mr. John Schultheis
Chemtronf cs, Inc.
180 Old Bee Tree Road
Swannanoa, NC 28778
Dear Mr. Schultheis,
As per a reques~ from Jim Cloonan of Sirrine Environmental, the benzylic acid
result for sample SW-4, originally reported to Metcalf & Eddy on July 18, 1986,
was re-checked. . It was discovered that the result was actually 470 \lg/L (ppb) .
rather than the 470 mg/L (ppm) as originally reported.
As such, a corrected
Certificate of Analysis has been issued to Chemtronics (see enclosure).
Please feel free to'contact me with any questions or problems.
Sincer ,
R wa9(1' ~r
Op ations Manager
RW : sm
End osure
_.-
\
Regional Office
S&i~ r.1iddlebrook Pike. KnoXVIlle. Tennessee 37921 . 615.~aa.6401
-------
-----. - -".::-;-_:-
:-.;.>
m INTDHATIONAL
TECHNOLOGY
CORPORATION
ANALYTICAL
SERVICES
...~-
.,,- .....~~
.. rI - ,,~
.-.~,~.
".' "
; ~" 8"'. \ ...~
.' "..I~-~' _.'
::,. :. 1.8,-
. .~~7-:
""-~~
~
5815 Middlebrook Pike. Knoxville, Tennessee 37921 . 615-588'61$01
CERTIFICATE OF ANALYSIS
>
"
.--- -
'.:':: ~
TO:
Chemtronics, Inc.
ATTN: John Schultheis
180 Old Bee Tree Road
Swannanoa, NC 28778
DATE REPORTED: September 14. 1988
PROJECT CODE; MEOW 22466..Corrected Certifi,
OReER NtJMSER: S- 5808
PAGE 14 OF 14
Sample Description: SW-4 (X8S98) (Water)
CS, BZ, AND DEGRADATION PRODUCTS ANALYSIS
.-
Compound
CS
o-Chlorobenzaldehyde
BZ
Benzylic Acid/Benzophenone(2)
Concentration(l)
-
-------
. .
rn INTERNATI.ONAL
TECHNOLOGY
CORPORAnON
September 16. 1988
Mr. John Schulthois
Chemtroni cs, .-7..,c..;
180 Old Bee Tree koad
Swannanoa, NC 28778
Dear Mr. Schultheis:
Enclosed please find the raw data for sample SW-4 (ITAS sample no. X8598). CS,
BZ, and their breakdown products were searched for manually using known reten-
tion time windows from standard analyses. Confirmation was based on mass
spectral match with standard and referenced (HBS and Battelle) spectra.
Estimated concentrations were calculated using the internal standard method;
calculations were based on peak height assuming a response factor. of 1 using the
nearest internal standard (IS): .
Con~entration in extract (~g/ml) . 40 ~g/ml IS x p:::kh~~~~~tIS
extract
Concentration in sample (~g/L) . ~g/ml in extract x 1.0 ml x dilution
1.0 L factor
Using the values obtained for
40 ~g/ml IS
in sample SW-4,
. 7.89 ~g/ml benzylic acid
7.89 ~g/ml benzylic acid x ~:~,~l x (2x30) . 473 ~g/L benzylic acid
As benzylic acid, the hydrolysis product from 8Z, further decomposed to benzo-
phenone, it was this latter compound that was actually measured.
Please note that the error was due to failure to convert to mg/liter prior to
transcription to the raw data worksheet; no problems in analytical approach were
seen.
\
..Si7,1-rr
Rlf;~ner
Operations Manager
RW : sm
Enclosure
Regional OUice
5815 Middlebrook Pike. Krioxv1lle. Tennessee 37921 .615.588-6401
- ...~... """"0 #- .-
. "'.
-------
~ I~) 4.-,.oocDo..'-"-;;~'~U-;'--1Ii8J1_;4. -'. '~~-I~~J~:
CS, BZ, 'Dd Deeradation Products A. lysis
. ....
.,.-~
~roJect Code:A£Dc.J ''2'1~ ~
Lab Sample': X?sq'.J2l:
.mple Matrix: Wa.Je~
Analyst/Inst: ~L- /.0 &.c.) 4 ~
*******************************************************************************~
Sample Description:
S W-I.( (G)
Compound
Conc. (~(1)
",0
CS
o-Chlorobenzaldehyde
Malononi'trile
BZ
3-Quinuclidinol
Benzylic Acid / Benzophenone (2)
".
J./?o
Remarks: .010 = Quantitation Limit (3)
ND = Not detected
(l).The concentration is based on peak heiahts with a response
tactor ot 1.00 relative to the nearest non-interfered internal
standard. .
... .'~
(2) Benzil1c.Acid deerades ~ Benzophenone. Quantitation is based' on
both compounds..
(3) Tbe quantitat~on limit is 10~ ot Inter.D~) Standard concentrati~l.
in extract as analyzed. The limit given is with respect to the
sample. .
s*******************************************************************************
~ .rted by: ~::::::1
A~lo1roved by: - - ~
Date:
?;-:J'O~
7-Z-r(.
Date:
ME003Rl
-------
"DATA FI~E: XS,9SR2
CA~IaRATICN FILE: CALO'062
SEARCH OF LIBRARYCE
SCAN
4q3
002
Sq,
1089
1443
1=23
UI-
COMPOUND
, -" ;-',.. L-,Ii----,..-._~ .~~ '~. t 'wl.;.. 8.J
LIBRARY SEARCH REPORT
EXTRACTABLE ORG'AN'IC ANALYSIS
. ~'~.A'.
" ,
" '.,.
.i--..:.'
t.
~.
DEL.TA
".. -
o
o
o
o
o
-1
*I5* 1.4-DICHLOROBENZf.NE:-D4
*15* NAPHTHA~ENE-DS
*15* ACENAPHTHENE-Dl0
*IS* PHENANTHRENE-Dl0
*15* CHRYSENE-D12
*IS* P£RYLENE-D12
~ ... l,' h, ......:..../ .
1.0
---------
1.0
ML.
x * UG/ML *
FLAGS:
\
.
Lf,
. ~. -'.--
rJ..~ ~ (DILUTION)
~::~~~ (FACTOR)
PUR-FIT
904-960
979-949
876-973
899-947
863-973
874-893
.
~o.o
A~T F~A(
<7UC;:; ,.~~ SAT
~Q 0
4tl 0
40 0
40 0
40 0
40 0
t( 7 () -III"
* X UG/ L./;J
".
SAT - NUMBER OF MASS PEAKS :~.TURATED
LIB - NUMBER ~F PEAKS OUT OF CLP SPECS IN ENHANCED SPECTRUM
. '
\
-1
o
o
o
-2
-82
-------
I
109.9
I
RIC DATA: X9599R2 II
e6,27/86 21:24:00 CALI: C~_85062 15
5Af'IPLE: X 8598 (foIEDI~ 22466) BU/AE: 9.3ML EA + 6.0Ul IS, 1.5UL
COIIOS.: OWMI OIR ItIJ OU 3'3 t1 OB-5: 45-325 DEG C AT 12 D/M
RANGE I G I ,2900 LABEL: t~ 9, 4. 9 QUAf~l A 9, I. 9 J 9 BASE I U 29, 3
895
SCAtiS IS9 TO 2000
493
662
IT
J623
RIC
1444
J
.
,
I'
;' ..:\ .
935
1367.
seo
IOO~
16:40
1500
25:00
:~: 21)
2829.
/"
1891
~
2000
3:3:20
-------
-
OUANTITATION REPORT
FILE' Xa'9SR2
:'!
DATA: XS'9SR2. rl
06/~7/S6 21:24:00
SA~PLE: X e'98 (MEDW ~2466) BN/AE: 0.3ML EA+ 6.0UL IS. 1. 'UL
CONDS.: OWA4: DIR IN~ ON 30 " D8-': 4'-32' DEQ C AT 1~ DIM
'ORMULA: WATER INSTRU~ENT: OWA4.":- WEIQHT:
JB~ITTED BY: MEDW ANALYST: DDS/SAL ',: ACCT. NO. .
~MOUNT~AREA * REF. AMNT/(REF. AREA)* RESP. FAC~~;DET.LIM.. 0.00
RESP. FAC. FROM LIBRARY ENTRY.
O. 000
:!:!466
-.... ...
NO NAME
1 *15* 1.4-DICHLOROBENZENE-D4
:! *15* NAPHTHALENE-DB
3 *15* ACENAPHTHENE-DI0
4 *15* PHENANTHRENE-DI0
, *15* CHRYSENE-D12
6 *15* PERYLENE-D12
7 *5S* 2-FLUOROPHENOL
S *55* PHENOL-D'
9 *55* NITROBENZENE-D'
10 *55* ~-FLUOROBIPHENYL
11 *55* TRIBROMOPHENOL =
I:! *55* TERPHENYL-D14 "
13 N-NITR050DIMETHYLAMINE
14 PHENOL
l' BI5C2-CHLOROETHYL)ETHER
16 2-CHLCROPHENOL
17 1.3-DICHLOROSENZENE
18 1,4-DICHLOROBENZENE
19 BENZYL ALCOHOL
-0 1.~-DICHLOROSENZENE
1 2-~ETHYLPHENOL
..., BI5C2-CHLOROISOPROPYL)ETHER
.&
23 4-~ETHYLPHENOL
24 N-NITR050-DI-N-PROPYLAMINE
;!, HEXACHLOROETHANE
26 NITROBENZENE
27 I50PHORONE
28 2-NITROPHENOL
29 ;!.4-DIMETHYLPHENOL
30 BENZOIC ACID
31 BI5C2-CHLOROETHOXY)METHANE
32 2,4-DICHLOROPHENOL
33 1,2,4-TRICHLOROBENZENE
34 NAPHTHALENE
3' 4-CHLOROANILINE.
36 HEXACHLOROBUTADIENE '\
37 4-CHLORO-3-METHYLPHENOL
38 2-METHYLNAPHTHALENE
39 HEXACHLOROCYCLOPENTADIENE
40 2,4,6-TRICHLOROPHENOL
41 2,4,'-TRICHLOROPHENOL
42 2-CHLORONAPHTHALENE
43 2-NITROANALINE
44 DIMETHYL PHTHALATE
., ACENAPTHYLENE
3-NITROANILINE
-------
-- - ------~
- - - --. .."
NO NAME
47 ACENAPHTHENE
48 2,4-DINITROPHENO~
4-NITROPHENO~ ..
49 . ".4..
DISENZOFURAN . .)...
'0 "
'1 2,6-DINITROTO~UENE
'2 2,4-DINITROTOLUENE
DIETHYL.PHTHAL.ATE "
'3
'4 4-CHLOROPHENYL PHENYL-ETHER d
" FLUORENE
'6 4-NITROANIL.INF .-.
57 4,6-DINITRO-'2.-METHYLPHENOL.
'8 N-NITROSODIPHENYL.AMINE
5q 1,2-DIPHENVLHYDRAZINE
~O 4-BROMOPHENYL-PHENYLETHER
61 HEXACH~OROSENZENE
62 PENTACH~OROPHENO~
63 PHENANTHRENE
64 ANTHRACENE
6' DI-N-BUTYLPHTHA~ATE
66 F~UORANTHENE
67 BENZIDINE i
68 PYRENE
6q BUTYLSENZYLPHTHAL.ATE
70 3,3'-DICHLOROSENZIDINE
71 BENZOCA)ANTHRACENE
72 BISC2-ETHYLHEXVL)PHTHA~ATE
73 CHRVSENE
74 DI-N-OCTVLPHTHALATE
7' BENZOCB)F~UORANTHENE
76 BENZOCK)F~UORANTHENE
77 BENZOCA)PYRENE
78 INDENOC1,2,3-C,D)PVRENE
79 DIBENZOCA,H)ANTHRACENE
80 BENZ01G,H, I)PERV~ENE
81 MALONONITRILE
82 O-CHLOROSENZALDEHYDE
83 SENZILIC ACID
84 O-CHLOROSENZYLIDENEMALONONITRILECCS)
NO M/E SCAN TIME REF RRT /'1ETH AREA C HQHT > AMOUNT 7.TOT
1 152 493 8: 13 1 1.000 A S~ 663. 40.000 UG/ML 16.67
2 136 662 11:02 '2. 1.~00 A BV 21'9. 40.000 UQ/ML 16.67
3 164 89~ 14:'~ 3 1. 000 A BS 19'9. 40.000 UQ/ML 16.67
4 188 1089 18:09 4 1. 000 A SB 3743. 40.000 UQ/M~ 16.67
5 240 1443 24:03 , 1.000 A BB 2337. 40.000 UQ/M~ 16.67
.6 264 1623 27:03 6 1. ('00 A~ 2909. 40.000 UG/M'" ~6.67
7 112 1
8 99 1
9 82 2
10 172 :3
1 1 330 4
12 244 ,
13 74 1
14 q4 1
15 93 1
16 128 1
-------
--- ".
NO /"lIE SCAN TIME REF RRT ,..ETH AREACHGHT) ,"'OUNT " 7.TOT
17 146 1 ""
19 146 1
19 79 1
;:0 146 1
~1 loa 1
z~ 121 1
;:3 loa 1 ."
24 1.:30 1
~:5 117 1
26 '!7 -.-. 2
27 92 2
28 1:39 2
2q 122 2
:30 10:5 2
:31 93 2
:381 162 2
:3:3 180 2
34 1~8 2
3:5 1~7 2
:36 ~~, 2
:37 107 82
:38 141 82
39 :37 3
40 196 :3
41 196 3
481 162 :3
. 43 138 :3
44 163 3
4:5 1:52 :3
46 1:38 :3
It 154 :3
1r8 184 3
49 6' :3
:50 168 :3
51 16:5 3
52 16:5 :3
53 149 :3
54 204 3
,:5 166 3
56 138 :3
~7 lq8 3
58 169 4 I!:
59 77 3
60 248 4
61 284 4
62 266 4 \
63 178 4 ,
64 178 4
6:5 149 4
66 .,-....' 4
. ..~. c:
67 184 ,
68 202 ,
69 149 ,
70 2'2 ,
t ::28 ,
149 ,
-------
-- ---.- -- ----
NO ,.,/E' SCAN TIME REF RRT METH AREA(HGHT) MOUNT . l.TOT
73 ::8 ,
14 149 6
7' :52 6
76 :5~ 6
77 :!S2 6
78 276 6
79 278 6
SO 276 6
S1 66 1
82 139 .---4O 2
83 10' 4
84 1'3 3
NO RET(L) RATIO RRT(L) RATIO AMNT AMNT(L) R.FAC R.FAC(L) RATIO
1 8:41 0.9' 1.000 1.00 40.00 40.00 1.000 1.000 1. 00
2 11: 29 0.96 1.000 1.00 40. 00 40.00 1.000 1.000 1. 00
3 1':21 0.97 1.000 1.00 40. 00 40.00 1.000 1. 000 1. 00
4 18:36 O. 98 1. 000 1.00 40. 00 40. 00 1.000 1.000 1.00
5 24:29 0.98 1.000 1.00 40. 00 40.00 1.000 1.000 1. 00
6 27:29 0.98 1.000 1. 00 40.00 40.00 1.000 1.000 1.00
7 ':'9 0.692 0' JOO.OO O. 751
8 8:08 0.940 100.00 1.098
9 9:'6 0.868 a 100.00 0.232
10 13:5' 0.907 100.00 O. 749
11 17:06 0.921 100.00 0.182
12 22: 11 O. 906 100. 00 O. 703
13 2:37 0.303 '0.00 O. 721
14 8: 10 0.944 '0.00 1.444
1:5 8: 13 0.9'0 :50.00 1. 362
16 8: 18 O. 960 '0.00 1. 342
'7 8:34 0.990 50.00 1. 632
8 8:41 1. 004 '0.00 1.845
19 9:27 1.092 50.00 0.982
20 9: 06. 1.0'2 '0.00 1. 616
21 . 9: 27 1.092 '0.00 1.242
22 9:26 1.091 '0.00 0.353
23 9: 47. 1. 131 50.00 1.184
24 9:44 1.12' 50.00 O. 1'0
25 9:46 1. 129 '0.00 0.878
26 9: 58 0.870 '0.00 O. '09
27 10:32 0.920 '0.00 0.841
28 10:42 0.934. '0.00 O. 188
29 10:54 O.9~2 50.00 0.287
30 11: 20 0.990 '0.00 0.202
31 11:04 0.967 '0.00 0.420
:32 11:17 O.98~ \ '0.00 0.326
33 11: 23 0.994 '0.00 0.499
34 11:30 1.004 50.00 1.078
35 11:45 1.026 50.00 0.121
36 11:'8 1.04' 50.00 0.365
37 12:'4 1.127 50.00 0.357
38 13:02 1. 138 50.00 0.676
39 13:34 0.884 50.00 '0.403
40 13:46 0.897 50.00 O. 4'8
41 13:54 0.,906 50.00 O. 526
~ 14:05 0.917 50.00 1.220
-------
-- --. " . -r- .-..- -"-"-------'-'-', -- ----:".' III L'~ --- (.' lrJ 8 -~~- ~..l~- --.;~.~,~ ~.L.) -RATIO
43 14:28 0.9412 :50. 00 0.246
44 14::56 O. '973 . :50.00 1. :524
4:5 1:5:00 0.977 :50. 00 1.614
46 1:5:31 1.011 '"'i. :50. 00 0.010
47 1:5:2:5 1.004 (~ - 50. 00 1. 182
(
1:5:37 .- :50. 00
48 1.017 :'( 0.094
49 16:03 1. 046 ? :50. 00 0.0:56
SO 1':47 1. 028 :50.00 1.68:5
:51 1:5:02 0.979 '~ :50.00 0.279
52 1:5:" 1. 0'31 '.'{ '0.00 0.423
53 16:30 1.07' \.' '0.00 1.670
1.
:54 16:3' 1. 080 :)0.00 0.789
" 16:32 1.077 '0.00 1.400
56 16:32 1. 077 '0.00 0.017
57 16:48 1.094 :50.00 0.267
:58 16::51 0.908 :50.00 0.3:57
59 16::5:5 1.102 :50.00 2.071
60 17:38 0.9:50 :50.00 0.260
01 17::5' 0.96' :50.00 0.36:5
62 18:21 0.988 '0. 00 O. 169
03 18:37 A.003 :50.00 1. 167
64 18:44 1 . 009 :50.00 1. 164
65 20:06 ..083 '0. 00 1.343
66 21: 16 1 14' :50.00 1.482
67 21:48 t..890 80.00 0.028
08 21:4' (.88a :50.00 2.0:55
69 23:24 O. 9'6 :50.00 0.719
70 24:31 1.001 :50. 00 O. 1'9
71 24:27 O. 999 :50.00 1.617
72 24:47 1.012 :50.00 1. 141
73 24:32 1. 002 :50.00 ' 1.752
74 26:07 0.9:50 :50.00 1. 597
7:5 26:4' . 0.973 '0.00 1. 823
76 26:48 0.97' :50.00 2.017
77 27:23' 0.996 :50.00 1.328
7F3 29:57 1.089 :50.00 1.422
79 29: 59 1. 090 '0.00 1. 069
80 30:37 1. 113 :50.00 1.081
81 5:26 0.649 100.00 ' 2. 4' 1
82 11:01 0.9'1 100.00 1.000
63 17:27 0.936 '0.00 1.000
64 16:09 1.006' 100.00 1.000
\
I
I.
!
I
I .
. I
-------
IT ANALYTICAL SERVICES
GA/GC REPORT
FIL.E: XS'98R2
INTERNAL STANDARD AREA CHECK
__~mm-=8_____.-...--.--...-
= OUT OF 6 ARE WITHIN
'0% TO ~007. OF DAILY STANDARD AREAS.
.
.. INTERNAL STANDAR~-AREAS ARE WITHIN GC LIMITS ..
*15.
*15.
.15.
*15'"
*15.
*15.
1,4-DICHLOROBENZENE-D4
NAPHT"'ALENE-DS
ACENAPHT"'ENE-DI0
P"'ENANT"'RENE-DI0
CHRYSENE-D12
PERYLENE-D12
60 X
:51 X
68 X
63 X
'4 X
66 7.
, .
INTERNAL STANDARD RETENTION TIME CHECK
=---------=-==-===--------=----=-=----
r ~
6 OUT OF 6 ARE WITHIN +1- 30 SECONDS OF DAILY STANDARD RETENTION TIME
*... INTERNAL STANDARD RETENTION TIMES ARE. WITHIN QC LIMITS ....
\
-------
b/~7/80 21:20:29
ACQUISITION STARTED
SCAN 121 OF 2000
ACQUIRE. RUN 0;X859SR2
00/~7/S6 21:~4:00 + 2:04 ~ FREE SECTORS: 103'0
IE,.AMPLE;~-'X 8'98 (MEOW 22460r~BN/AE: 0.3MI.. EA + o.OUI..
~NDS.: OWA4: DIR IN~ ON 3~M DB-5: 45-325 DEG C AT
-FORMUI..A[ WATER INSTRUMENT: OWA4
SUBMITTED BY: MEDW ANALYST: DDS/SAL
-.- ...
LOW MASS:
HIGH MASS:
35
500
':ENT SIP: 10
FRAG SIP: 10
10
10
ACTUAL:
ACTUAL.:
MIN PEAK WIDTH:
AID THRESHOLD:
2
2
MODE:
CENTROID POSITIVE ION
INTERFACE NUMBE'~
SUB-INTERFACE NUMBER
. OF ACQU BUFFERS
INSTRUMENT TYPE
FULL SCAL.E MASS
ZERO SCALE M~SS
INTENSITY/ION
PEAK WIDTH
OFFSET AT L.OW MASS
OFFSET AT HIGH MASS
VOLTAGE SETTLING TIME(,.,S)
UP:
DOWN:
ACQUIRING
SCAN: 124
IS, 1.5UL
12 D/M
WEIGHT:
ACCT. NO.:
O. 000
22400
OF 2000
O. 97 1..*
O. 00 I..
O. 00
O. 03
TOP:
BOTTOM:
SAMP INT (MS): 0.200
SAMP INT (MS): O.~OO
PEAK WIDTH: 1000.
INTEN/ION: ~
MIN FRAQ WIDTH 7.:
BASELINE: 0
o
o
10
Q ,
SOO AMU
1 AMU
2
1000. ,.,MU
o MMU
o MMU
4
0/27/S6 21:57:'2
ACQUISITION COMPLETED .-
SCANS 1 TQ 2000 CENTROID
~ODE
-:ENTROID
SCANS
2000
SECS
1. 5
OUT OF
2000.0
x
0.1
80
MIN AREA:
2
M.S. TUNE PARAMETERS:
MULTIPLIER VOLTS: -2000.00
LOW RESOLUTION: 120.00
HIQH RESOLUTION: 127.00
ION ENERGY: 3. 53
ION PROQRAM: 8.63
, LENS YOLTAQE: -75.29
EXTRACTOR: 2.00
ELECTROMETER RANGE: 7. 00
ELECTROMETER ZERO: -1.11
PEAKS PER SCAN
13828.' 7.
PER SEC
7.
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RIC + MASS CHROMATOGPAM DATA. X8598R2 11047
06/27/86 21:24:00 CALI: CAL85862 15
SAMPLE: X 8598 (MEOI~ 22466) 8t4/AE: 0.3ML EA + 6.0UL IS, 1.5Ol
COtiOS.: 0\.A4: OIR IHJ on 30 M 08-5: 45-325 OEG C AT 12 DIM
BEN21L1C ACID
RANGE: C 1,2900 LABEL: " 0, 4.9 QUA": A 0, 1.0 J 0 BASE: U 29, 3
996
I.
Iv0.0
105
5CAHS 928 TG 1167
100.
185.831
t 0.500
/"
1089 2068.
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RIC ~ ""
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1995
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950
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~.-- 1119
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1145
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1150
1'3:10
SCAli
TInE
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l. ,RY SEARCH rmTAI X9599R2 . 99;:
86/21196 21:24:80 + 16:35 CALI: CAL05062 I 5
:lSA~FJ .~ ~399 (MEOW 22466) BH/AEI 8.3ML EA + 6.eUl IS, 1.5Ul
tONUS. I OWA41 OIR INJ OH 30 " DB-51 45-325 DEe C AT 12 0/"
ENHANCED (S 159 IN ST)
BASE M/EI 71
RICI 294.
eee
E
I I .
-.. -T . I . . . . . --.. I -. . .
18.0 I£THANONE,DIPHEHYl- CAS I 119-61-9
{R~
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ns
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;6.03 1,2,4-TRIOXOlANE,3,3,S-TRIPHEHYL- CAS' 23246-12-0
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. CAS'
183-33-3
;.58
198
Ise
~90
250
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APPDDIX C
~oDer 7, 1988 K8m0ranclum frcaa Wade Knight,
Chief of Quality A.88Urance and Laboratory Bvaluation
Section, Bnvironmental. Service. Divi.ion
, ..
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~...,"UP4",
or ".
1 A ..
I_I
'=~~..,
UNI~~~ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
,~~~',
DNtRONMENTAL SONIC:U DIVISION
ATHENS. GEO~1A 308'3
.. .1
.. -
MEfo()RANDUM
DA TE :
SUBJECT:
October 7, 1988
FRCJ4:
Data Error - Chemtronics RI Report
Wade Knight, Chief iU:. L }L. ~f.1.
Laboratory Evaluation & Quality Assurance
Jon K. Bornholm
. Proj ect Manager
Superfund Branch
.. Wa ste Management
Secti on
TO:
Division
We have revie~d the infonnation suppl ied by Chemtronics concernin~ a report-
ing error for Sanple SW-4 analyzed June 6,.1986. According to Chemtronics,
the val ue for benzyl ic acid was reported- as 470 mg/L when it shoul d have been
reported as 470 ug/L.
From our review of the raw data, we agree that the
val ue shoul d have been reported as 470 ug/L.
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APPBHDIX D
Explanation of Significant Difference
in A component of the R8m8dy to be
Implemented at the Chemtronic8 Superfund Site
Pact Sheet Dated Pebruary 10, 1989
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'\."WIIII~i
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UNITED STATES ENVIRONMENTAL PROTECTION AGENC,~::'
..
"aGIO" IV
U. COUltTLAND 8TR.I:T
ATLANTA,OeOROIA ,oan
.'
. .
Ixplaaatioft of Significant Difference in A
CCImpOftent of the R8III8dy to be Impl8lD8ftt8d at
the Chemtroftic. Superfund Sit.
Pebruary 10, 1989
~he mandate to addre.. post-ROD change. i. provided by CZRCLA Sl17(c), which
stat.. s
wAfter adoption of a final remedial action plan --
(1) if any remedial action is taken (under
sections 104 or 120), (2) i~ any enforcement
action under section 106 is takeD, or (3) if any
settlement or consent dbcree under section 106 or
section 122 i. entered into, and if .uch action,
settlement or decree differs in any significant
respects from the final plan, the lead agency
shall publish an explanation of the 8ignificant
differences and the reasons such chang.. were
mad..w
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'.
Dr1'RODUCTIOH
Baaed on a ~ion of &D&lytical data vith requd to the ch8m1cal quality of
the groundwater dowDqr&d1ent of Di.po.al Area 23 (DA-23) at the Ch8llltronic.
Superfund Sita, the u.s. BDviroDIII8Dtal Protection Agency i. propo.inq to chanqe
the aource control r8D8dy .elected fo~ DA-23 in the RecoreS of D8ci.ion (ReD).
Thi8 c!ocwD8nt. i. an ezpl&D&tiol! of the eSifference between the aource control
remedy.. originally .pecified in the ROD ancS the remedy BPA now propo... to be
implemented. The rationale aneS eSata aupportinq the pr0p08ecS change i.
8pecified below.
BACKGROtnm
Site Descrigtion
The Chemtronic. Site encamp...e. approximately 1,027, acre. aneS i. locateeS at
180 OleS B- Tr- Roaciin a rural are.. of Svannanoa, Buncombe COunty,
apProximately 8 mile. ea.t of A.hevil1e, North carolina. The approximate
center of the .ite Ue. at latitueSe 358 38' 18- north aneS longitude 828 26' 8-
we.t. The Site i. bovnded on the ea.t by B- Tr- Road and Bee Tr.. Creek.
The area to the north and veat of the Site i. compri.ed of 8par.ely inhabited
woodland.. Immediately to the 80uth of the Site, there are 8everal indu.trial
facilities vhich lie on land that va. once part of the original (08rlikon)
property.
Site Historv
The property compriaing the Chemtronic. Site v.. first developed as an
induatrial facility in 1952. The Site has been owned/operated by oerlikon Tool
aneS Arm8 COrporation of America (1952-1959), Celane.e COrporation of America
~Hoech.t-calane.e CC'rporation) (1959-1965"), Northrop carolina, Inc. (Northrop
COr~ration) (1965-1971), Chemtronica, Inc., ~8 apart of Airtronics, Inc.,
(1971-1978), and Chemtronics, Inc. (.1978 - present). The Site operated under
the name of Ameel Propulaion, Inc., (1959-1965) under both oerliJcon and
celaneae. The Site ia currently occupied by an active facility owned and
operated by Chemtronics Incorporated, a subaidiary of the Halliburton COmpany.
Waste disposal occurred over a small portion (approximately than ten acres) of
the Site. Twenty-three individual on-site eSi.po.al area. were identified and
deacribed by reviewing existing records and through interview. vith former and
current Site employee.. Theae 23 individual dispo.al area. are grouped into 6
discrete diapo.al are... DA-6, DA-7/8, DA-9, DA-l0/1l, DA-23, and the Acid Pit
Area. The Sit. can &180 be divid{td into two geographical sub.ectiona, they
vill be referred to aa the Front~lley and Gregg Valley.
Diaposal Area 23 i. located in the Front Valley. DA-23 conaista of a lined
40,000 gallon neutralization b~.in and a lined 500',000 gallon biolagoon built
on top of an abandoned tile leach field. Th. tile field w.. built in
association with Building 113, the main production building. The tile field
was abandoned in the 1960'8. The neutralization ba8in and the biolagoon were
partially built, on top of the abandoned leach fieleS. Soils contaminated due to
the tile field were probably used in the conatruction of the berms to 8Upport
thQ basin and biolagoon.
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When the bJ.o1Agoon tm,S originally contructed in 1979, the iDJ.ti.al .ynthetic
liner f&i.leci vb8IL the, owner/operator introducec1 the content. of a 55 gallon
druID of BCL 462 (a brCllDinated compoW1Cl) "into the bi.olagoon to acclimate the
bacteri.a pre.ent i.n ~h8 lagoon. The brcaai.nated ccaapound di..inteqrated the
li.ner, rele..i.ng the content. of the 55 gallon druID and approximately 300,000
gallons of water. A 88Cond li.ner wa. in.talled i.n 1980 and was u.ed unti.l 1984
when the owner/operator decommi.ssioned the bi.olagoon. Appendi.x A provi.des a
li." of the wute. and the approximate quanti.ty treated throuqh the bi.olaqoon.
An accurate i.nventory of wute. di.spo.8d of throuqh the leach fi.eld i. not
po..i.ble a. no recorda of di..posal were JD&i.nt&i.n8d.
RBCORD 01' DBCISIOH
In Apri.l 1988, BPA prepared the ROD based on the fi.ndi.ng. of the Rem8di.al
Inve.ti.qati.on (Apri.l 1987), .upplemental groundwater data collected in October
1987, the Fe.asi.bi.li.ty Study (March 1988), and the publi.c cClllD8nt. recei.ved
duri.ng the fi.ve week cOlDlll8nt period followinq the pea.i.bi.li.ty Study public
ID88ti.nq held February 23, 1988. The ROD (av&i.lable at the four information
repo.i.torie.) .peci.fi.ed the following remecii.al action for DA-23 and groundwater
contami.nati.on foUnd i.n the pront Valleys
Inatallati.on of a groundwat.er interception and. extracti.on system
downgradi.ent of the disposal area.. in both the Front Valley and Gregg
Valley. The level and degree of treatment of the extracted groundwater
will depend on 1) the ultimate discharqe point of t.his water and 2) the
level of contami.nant. in the extracted qrounc1water. The t.hr- water
di.charqe alt.ernative. for the treat.ed water are 1) the local sewer system,
2) a .urface stream and 3) on-sit.e irrigation. The range of treatment for
the extracted groundwater includes air strippinq, filtration through
activat.ed carbon filt.er and met.al removal. The poi.nt of discharge and the
degr- of treatment w1l1 be <1etermi.ned i.n the Remedial Design s~aqe. The
water discharqed will meet all ARAR's. .
Review t.he exist.i.nq groundwater monitori.nq system and install additional
wells, if nece.sary, t.o insure proper moni.tori.nq of groundwater
downqradi.ent of each disposal area.
In addi.tion to the monitorinq of the qroune1water downqradient of each
dispo.al are. identified above, action level. for the contAIII4 nants present
i.n the cU.8po.a1 area. will b4\ set so that after r8ID8CU.ation levels for
groundw.~ have been obtaine~ and verified throuqh monitori.nq, if this
level i. reached i.n any subsequent sampli.nq epi.ode, a remedial action to
permanently el ivli nate that source of contami.nation will be i.nitiated.
For t.he con~am4~~nt. and contaminated soils a.sociated with DA-23,
. determi.ne the IDOst appropriate soil fi.xation/stabilization/solidification
process and the mi.xi.nq ratios for the components involved. Pollowi.nq the
soil fi.xation/st&bi.lization/solidification for DA-23, the entire surface of
the disposal area will be capped.
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CBMG1I 111 'I'D DCQ1U) O~ D1ICISIOII
J;
.~.! J
ne orig~ 8OUZ'Ce control r~iat~6n action .elected:: for DA-23 i. Rated
a):)ove. The fuation/.tabilization/.olic11.f1.cation altem.tive wa. .elected due
to the concentration level of the non-volatile organic cont.M~n.nt benzylic
acid and benzophenone found 1n the groundwater downgradient of DA-23. The
ItAlmecUal Inve.tigation Report, dated April 1987, Rated that the concentration
for benzylic:: acid!beDzophenone in the groundwater downqradient of DA-23 in
mautor well (KW) SW-4 &8 470 milligram/liter (1119/1). ':hi. concentration i.
equivalent to 470 part. per million (ppm). HN SW-4 i. a .hallow monitor well
and 470 1119/1 i. a relatively high concentration for a contaminant in
groundwater.
In OCtober 1987, approxima~.ly one year after'~he original .ampling episode,
nine (9) monitor well. W8r~ re.ampled. KW SW...4 W&8 one of these wella. ':he
analytical re.ult. for ben~lic acid/beDzopheuone for SW-4 was 1.2 mq/l, which
i. con.iderably le.. than the 470 1119/1 level recorded 1n the initial .ampling
epi.ode. The concentration level of 1.2 1119/1.1. more in line with the levela
found in other well. downgracUent of DA-23 a.: can be s_n in Appendix B.
It wa. the Agency'. rationale, ba.ed on the level of 470 mq/l, that the
concentration of benzylic acid/benzophenone in the .oil. of DA-23, the .ource
of this cont~in.nt, IINR a180 be relatively high, therefore requiring a more
rigorous source control remedial action. Thi. thought proce.. led the Agency
to .elect a soil fixation/.tabilization/.olidification proce.. a. the source
control remediation for DA-23.
The fixation/stabilization/solidification alternative waa selected over soil
venting or capping due to the fact that tiie contuU.'!&nt of concern, benzylic
acid/benzophenone, i. not readily volatilized. Although soil ventin~-would
help remove the volatile organics from the .bil, it would not remove the
.non-volatile organic.. Usually, it ia the non-volatile organics that determine
the length of time nece.sary to pump and treat the groundwater as non-volatile
organic. do not readily move with groundw&ter through the soil aa do volatile
organics. Soil venting would help reduce the levels of vQlatile organics, but
it doe. not address the non-volatile fraction of contAmi~~nts and therefore,
.oil venting was not .elected as the new .ource control. remedial action for
DA-23.
. Due to the lower level of benzylic acid/benzophenone than first identified as
being pre.ent in the groundwater ~owngradient of DA-23, and the fact that soil
venting alternative would not accelerate the ~ime needed to remediate DA-23,
the Agency now propo.e. that DA-23 be capped with a multi-layer cap, which
includes a .ynthetic liner. The ~l~i-layer cap will meet as a minimum the
specified under 40 en Subsection 264, Subpart. It-H. ,. .1. ga. collection sy.tem
will also be incorporated into the cap if deemed nece.sary. .
DOCUMEN'rA'1'IOH OF A 'l'RANSCRIP'rIOH ERROR
In a letter dated September 19, 1988 (Appendix C), the potentially responsible
parties (PRPS) informed the Agency of a po.sible transcription error made by
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the labo~a~ c:onUacted by the PRPs to perifo.na their analytical analyses.
In8'tead of zoeporting tha'c.8tected concentratJoon .. 470 microqrame/lit~ (ug/l)
o~ 470 parts per billion ..'ppb) .. thef 'hould~f:1.ad done, the labo~ato~ reported
the concentration.. 470 ng/l o~ 470 ppD. nsplaciDq the decimal point by
three (3) places ~e8Ultec1 in a change of concf)~t~ation by a magnitude of t~ee
(3) ..
'!'his information and the documentation to support this ~eported t~ansc~iption
8rJ:'0~ was tranamitted to BPA, Reqion IV Chief of the QuaJ.ity Ass~ance and
Labo~ato~ Bva1.uation Section (~S) of the BDvJ.roamenta1. S8~ice Division.
Aft~ reviewing the dccwD8ntation, QALBS concurs that a tr&l18c~iption e~~o~
had occurred (Appead1z D).
CCIIPIBMATI01I OI~GJU)mmWA1'Bi\ QUALITY
Prior to m.~~ng~. final decision on ~hetherto change the selected source
cont~l remedy fo~ DA-23, the Agency!!resampled HW SW-4 the first week of
January 1989. The analytical resul~ for the January 1989 sample are 48 ug/1
for bensylic acid and 3400 ug/l fo~ henzophenone. These results confirm the
lower concentration range of 0.0 to..,70 ug/l and not concentrations in the
parts per million. The~efore, the Agency p~oposes to change the sou~c. control
remedial alternative fo~ DA-23 from 80il fixation/stabilization/801idification
to capping. The cleanup goal, as specified in Table 13 of the ROD, for
bensylic acid and benzophenone has not changed and remains at 21 ug/1 and 152
'19/1, respectively (Appendix B).
Capping will be as p~tective of human health and the environment as the soil
~ixation/stabilization/solidification process. This is based of. the findings
that the expos~. pathways for the con~~Mi~ants found at DA-23 are consumption
of contf.!ftinatec1 groundwater and discharge of contaminated gr" .mdwater to
s~face streame. These findings are documented in the PuJ:)~ic Sealth and .
Bnvironmental Asses8lD8nt section of the Remedial Investi' ;",tion report and the
Endangerment Assessment incorporated into the Peasibility Study document. Both
of these pathways are mitigated by the groundwate~ extraction/treatment system
required for the P~nt Valley under the Higratior: tAntrol section of the ROD.
Therefor., in terma of p~ot.ecting the public hef&l1:h and the environment, caping
DA-23 and pumping and treating the groundwater' in the F~nt Valley of the
Chemtronics site achieves the same degree of protection as the soil
fixation/stabilization/solidification process. As documented in the
Peasibility ~dy, capping is th~more cost effective remedial action. The
North carolina D'~t of suma.ii Resourc.s has been apprised and is in
complete agr...nt with the Agency's' proposal.
In addition to meeting the requirement of Superfund, being cost effective and
protecting public health and the .nvironmen~. ~apping DA-23 will also satisfy
the post clos~e requirements impose upon the own.r/ope~ator of the facility by
the Reso~ce, COnse~ation t& Rec:ove~ Act (RCRA) programs of the Agency and
North Carolina Department of Suman Resources. The RCRA programs are involved
with DA-23 because the biolagoon was operated post-1980.
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Onder RCRA, wMD a bu.1ne.. or incU.vidual': .top. operat1.nq a .01J.d wut.
III&I1&g8ID8At wUt (SHtl), the SHtl n88d8 to b8 clo.ed out accordJ..nq RCRA
regulationa. CApp1.nq DA-23 and pump18g.ana tr.at1.nq the groundwater will ID88t
RCRA'. requ~..
CCMMBlITS noJI TBB PtlBLIC
~
Th. public i. encouraq8d to .ubm1t written CClllD8l1t. on the above chanq.. Th.
~lic cCllllD8nt period will .nd thr- (3) weeD aft.r the date on the title paq.
of t:h1. document. C'~nt. will be 8W111D&rized and r..pen... provided in the
R.88pOnaivene.. SWIIID&rY that will be placed in the Information
Repo.itori../aAMini.trative Record. The Agency i. &180 willinq to meet with
local r..id8nt. to addre.. their concern.. Written cCllllD8nt. or reque.t. for
further information 8hould be 8~ft tOI
Jon Bornholm .
OS BPA ~.~
345 COurtland'- Str_t, NB
Atlanta, GA 30365
404/347-7791
. .
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APPDDIX B
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Leqal No1:iC:.8 Publi.h8d in the
Aaheville T~8./Citiz8D New.paper
March 1989
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R8v1ew the eziRinq qroundwater IIIOnitorin~ 8YR8ID and in8tall aclcUtiou), wells;
if D8C.ssary, to in8ur. proper IIIOnitoriDg of groundwater downqradient of each
dispoaaJ. area.
. ~
In addition ~o the monitoring of the c;roun~ater downgradient of each ~;..posaJ.
area identified above, action level. for the cont.",4ft.nta present in the
disposal areas will be set 80 that after remediation levels for groundwater
have been o))tained and verified through monitoriDg, if this level is reached in
any 8UJ:)sequent .amplinq epiaode, a r8lD8dial action to permanently elimJ.nate
that source of contamination will be initiated.
Per the cont.aminant.s and contaminat.ed 80ils aa8OCiat.ed with DA-23, determine
the most. appropriate 80il fixation/stabilizat.ion/801idification proce.. and the
lDi.zinq ratio. for the component a involved. Followinq the 80il
fixation/.tabilization/80lielifiC'..\tion for DA-23, the entire s"\rface of the
elisposal area will be capped. '
.1;
J'
IN'l'RODOC'1'ION
Ba.ed on a correction of analytical data with regard to the chemical quality of
the groundwater dOWDgracU.ent of Dispo.al Area 23 (DA-23) at the Chemtronic.
Superfund Site, the O.S. Bnvironmental Prot8Ct.ion Agency ia propo.ing to change
the source control remedy selected for DA-23 in the Record of Decision (ROD).
Thi. document is an explanation of the 'difference between the source control
remedy a. originally 8pecified in the ROD and the r81D8dy BPA now proposes to 1
imp18lll8Dted. The rationale and data supportinq the propo.ed change is
specified b.low.
CHANGB IN 'l'BB RBCORD 01' DBCISION
The original source cont%ol %emediation action sel8C1;.ed for DA-23 1s 8tated
above. The fixation/stabilization/solidification alternative was selected due
to the concentration level of the non-volatile ~rganic contaminant benzylic
acid and benzophenone found in the groundwater downqradient of DA-23. Th-:;;
Remedial Investigation Report, dated April 1987, .tated that the concentration
for benzylic acid/benzophenone in the groundwater downqradient of DA-23 in
monitor well (KIf) SW-4 as 470 milligram/liter (mq/l). Thi. concentration is
equivalent to 470 parta per million (ppD). HW SW-4 is a .hallow monitor well
and 470 mq/l ia a relatively high concentration for a contaminant in
qroundwuer. \
In OCtober 1987, approximately one year after the original @ampling episode,
nine (9) monitor well. were %esampled. HW SW-4 waa one of the.. wells. The
analytical %esult. for benzylic acid/benzophencna for SW-4 waa 1.2 ~/l, which
is considerably less than the 470 mq/l level %8Corded in the initial sampling
episode. The concentration level of 1.2 mq/l is more in line with the levels
found in other wells downgradient of DA-23 as can be seen in Appendix B.
It was the Agency's %at.ionale, based on t.he level of 470 f1J4/l, that t.he
concentration of benzylic acid/benzophenone in the soils of DA-23, the source
of t.his contaminant, must also be relatively high, therefore %equiring a lDO%e
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~igoroua 8OW:C8 coDUol ~8III8dial ac::i.on. Thi. Uough~ .-proce.. led the Aq8DCy
to ..lect a 8011 flxa~iOD/8tabilization/.olidification p~oce.. .. the 8curee
conuel ~--.41ation f~ DA-23. '.j;"
. ;
The fix&tion/~iliz&tion/801idific&tion altU'D&tive WI". ..lected over 80il
veDting o~ cappinq due to the f~ ~hat the cont.",t n.~t of CODCern, benzylic
aci4!benzophenol18, i. DOt ~eadily volatilized. Al~gh 80il venting would
help remove the volatile o~ganic. frcm the 80il, it would not remove the
noD-volatile o~ga.nic.. U.ually, it i. the DOn-volatile o~ganic. that determine
the length of time D8Ce..~ to pump and treat the c;roundwate~ a8 non-volatile
o~a.nic. do not readily move with groundwater through the 80il a. do volatile
o~anic.. Soil vantinq would help ~educe the level. of volatile organic., but
it doe. not &4~e.. the DOn-volatile f~~ion of contamt~.~t. and therefore,
80il venting wa. DOt 8el~ed .. the new .ource control ~8ID8dial ~ion for
DA-23.
Due to the l~ l.vel of~benzylic acid/benzophenone than f~.t identified a.
beinq p~e.ent in the gr~ate~ downgradient of DA-23, and the fact that 80il
venting alt8r11&tiva would':'"not accelerate the time needed to remediate DA-23,
the Agency now propo... that DA-23 be capPed wJ.th a multi-layer cap, which
include. a aynthetic lin~" The multi-layer cap will ID881: a8 a minimum the
8pecified unde~ 40 CPR Sub8~ion 264, Subparts X-Me A ga. coll8C1:ion .yst8m
will a180 be incorporated into the cap if deemed nece..ary.
COMHBNTS FROM TBB PUBLIC
The public is encouraged to suDmi.t written cOllllll8nt. OD the aJ:Iove change to:
Jon Bornholm
US BPA
345 COurtland Street, n
Atlanta, GA 303$5
404/347-7791
Written commen~. 8hould be postmarked no; later than Tue8day, Kar.ch 21, 1989.
COmment. will be .ummarized and responses provided in the Responsiveness
Summary that will be placed in the Information Repo.ito~ies/Administrative
Rec:o~d. Hatui&l. ~elating to the aJ:Iove change and othe~ information regarding
the Ch8llltrozU.c:. .ite are, also, available fo~ citizen review the infoJ:1ll&tion
repo.ito~iee~. The four information repositories to~ the Chemtronic. Superfund
8ite are located at: '\
D~. Gary Kille~
:Bnv~onmental Studies
University of Horth Carolina
@ Asheville
One University Height8
Asheville, HC 28804-3299
Hr. Jerry VeH-"'""..Zn
BuncCXDbe County Bme~gency
P.O. Box 7601
Asheville, HC 28807
Services
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,.
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c:h8aICroD1c. Site IAformat.!oD Bureau
P.O. Boa 18111
70 WoocUiA Place
Aah8ville,.C 28814
W~~. Wil80n COllege Library
Warran Wil.on COllege
701 w.irren Wil.on COll8ge Read
t ~ Swa.a.nai1O&, HC 28778
't.
(.
The o. S. BnviroDlD8ntal prot:8Ct:1on Agenc:y, Region IV, upon ei tizen reque.t, will
ID88t with loeal r..id8nt. to addr... their eOI1C8rD8.
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APPB1mIX P
Reapon.i ven... SWIIID&J:'y .
COmments Rec:.i ved by the Aq8ncy
and the Aqency'. Re.pons..;'~
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Jon Bornholm
Region IV, US EPA
345 Courtland Street, NE
Atlanta, GA 30365
Re:
Explanation of Siqnificant Difference. . . Chemtronics
Superf~d Site
Dear t.u.".
Bcrriholm:
Contrary to statements in both the Record of Decision (ROD)
and the Feb. 28, 1989, Explanation of Significant Difference
(ESD),stated remediation levels for contaminated
groundwater do not meet applicable or relevant and
appropriate requirements. Groundwater remediation levels as
set in Table 13 of the ROD have not been approved by North
Carolina's Department of Environmental Management, a
'violation of CERLCA and SARA Section 121(d) (2) (a) (ii), and
are not set at the most stringent chemical-specific levels.
Until EPA has completed the process, including public
hearing, required for seeking a variance from North
Carolina's existing groundwater quality standards, neither
the ROD or the ESD can set definitive groundwater
remediation goals.
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The groundwater remediation goal for this site should be
recovery to naturally-occurring state. Therefore,
remediation levels should be set at detection levels for all
synthetic, man-made substances. EPA's current suggested
levels do not begin to attempt this goal. At the least,
remediation levels:should be set at maximum contaminant
level goals (MCL~s) (see Sara Section 121(d) (2) (a) where
they are more stringent than MCLs. However, using drinking
water standards for remediation levels, particularly in
North Carolina, means that remediation levels are not as
"clean" as background l~vels; in essence, this standard
allows a continuing level of degradation, which is
unaccep~able. If site capping and groundwater interception
and extraction options chosen for remedial action cannot
assure contaminant levels in groundwater no greater Lhan
detection levels, then corresponding action levels for
groundwater may not protect the public health and t~e
environment, as required by law.
Contrary to the ROD and the ESD, capping and groundwater
extraction/treatment/monitoring do not constitute a
permanently effective treatment technology which, according
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to SARW,: is preferable. Accordinq to the Of!.!ce of
Techna1:'6qy Assessment Special Report OTA-ITE-"362 (June.
1988) , . )::Ontainment, an imcermanent technolog}"., will likely
requir~ future cleanups for the wastes left in the ground,
and is an impermanent techno~oqy chosen too frequently by
EPA fo~~remedial action. All manmade attempts to control
surfac~~and subsurface are susceptible to failure over time.
The rem6dial action chosen for the Chemtronics site promises
a "band-aid" cleanup. The chosen remedial action virtually
assures that the PRPs, the community, and EPA will have to
deal with this site once aqain in the future.
The ROD and the ESD fail to address off-site hazardous waste
dumps used by the PRPs. Specifically, neither document
addresses the dumps in Buckeye Cove (Mary Crain's land), the
Tropigas site on highway 70, or the site south of
Chemtronics property (Asheville DyeinJ and Finishing).
Though the RI/FS acknowledges PRP dumping of hazardous
-wastes at these sites, EPA fails to held the PRPs
,responsible for these sites. This represents gross
,,'1eqligence on the part of the PRPs anc EPA. Questions of
~thics and accountability aside, the ~ublic health and the
environment continue to be endangered by the failure to
address the off-site dumps.
Since:?] , "
O~~
~"ie ~. Rom~nqer
cc:
Senator Terry Sanford
Conqressman James McClure Clarke
William L. Mey~~ '
Perry Nelson
Citizens' W~tch for a Clean Environment
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R88p01188 to C-~. 1t8c:8iV8d During Public ('~ut Pu'iod on
bplanation of SignJ.ficant Differ.nc. for Ch8artronic. Superfund Site
Dear b. p......in~erl
ThJ.. corr..pond8nc:. i. in re.poD88 to your Karch 20, 1989
Agency'. bplanation of SignJ.ficant Difference (Amendment
Deci.ion) for th. c:b8aatronic. Superfund Sit.. The public
thi. docwD8n~ ,.nded Karch 21, 1989.
latter on the
to the R8cord of
COlllll8R period for
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The cl.anup ~al. the Agency s.lected for contaaainated groundwater and 80il
war. baaed on the information, calculati0D8 and conclu.ions pre.ented in the
Public a.alth and BnviroDlll8ntal A8...8ID8nt and the Bndang.J:'ID8nt A8s.s8lD8nt.
The Public Bealth and BnviroDlll8ntal A8...8ID8nt can be found in the R81D8dial
Inve.tigation report and the Bnviroamental A8...8ID8Dt i. loeateet in the
J'ea.ibility Study (I'S) docwD8nt. Also pre.ented in the J'S are the
calculation. for d.riving Prelf",4n&ry Pollutant Limit Valu.. (PPLV.). PPLV.
are cl.anup goal. for specific cont~t. found at the Chemtronic. 8ite
that have DO e.tabli.hed cleanup goal. or .tandard.. SiDc. the calculated
PPLV. are J::ta.8d on limited toxicological data, a con.ervative, protective
approach w- utilized to arrive at the.. cleanup lev.l.. Sasect on existing
toxicological data, the Agency i. confident in Rating that the remediation
level. set forth in Table 13 of the Record of Deci.ion. (ROD) will be
protective of human health and the 8I1viroament.
Provision. in Sec1:ion 121 of the COmprehen.ive BnviroDm8ntal Response,
COIIIpensation, and Liability Act: of 1980 (CERCLA) .. amended by the Superfund
Amendment. and Reauthorization Act: of 1986 (SARA) allow the Aquncy to waive
-applicable or r.levant and appropriate requirements- (ARARa) under six
.ituatioD8. One of the- situations, compliance i. technically.
impracticabl., appli.. 1:0 the Chemt:ronic. .ite. Th. Aqency'. position i8 8et
forth in the Aqency'. latter to the Stat. of North C&rolJ.z1a requ..tiDg a
varianc. to JroJ:"t.b CarolJ.z1a Admini.trativ. Code, Titl. 15, Subchapter 2L,
Paragraph .0202 (15 HOC 21.) dat-,\ Karch 1, 1985. I hav8 enc:lo.GId a-copy of
thi. requ.8t:. Pre88Dtly, the Agency i. waiting f~ a re.pons. f~QID the North
Carolina Divi.ion. of BnviroD1D8ntal K&n&g8lll8Dt OD the Aqency'. ~eque.t.
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The Ag8DCy ..,imo-ledge. th8 fact tha~ capping the dJ,apo.a1 u.... i. DOt
COD8~ . p-ruoft8t'~ r8lD8cUal action. A8 Rated ~ the n puDlic lD88ting
conduc1:8d on F8bzuazy 23, 1988, the ~.. pref8ued r8lD8d1.~ alt8J:'D&tive
for adck88.1.n9 the con~amina~8d 8Oil. v.. on-.ite iDcineratiok1 vith a fall
back po.ition of capping the di.po..l are... Sinc. capping i. DOt a
penI&I18D~ r8lD8dial action, 1:h8 Agency i. required UJ1d8r S8ct:ion 121 of SARA
to revi.i~ 1:h8 .i~. ev.ry five (5) year.. 'rhi.. revi... is to a.sure tha~
human hea11:h and the environment are beinq protected and to con.ider the
r8lD8dy iD liglrC of n... ueat:ment technolocn developed during the iD~8Z'iID.
'this revi... proce.. may re.ul~ i.n 1:h8 pot8D1:ia11y reaponaibl. par1:ie. (PUS)
cond~ing addi~ional r8lll8dial action eff~s at a latu da~..
The off-.i~. are.. of Buckey. COve landfill and the landfill off of Highway
Jtcu~. 70 are DOt par1: of the Chemtronic. .i~.. A8 ~'OU know, the Agency
compelled the PRP. to conduct limited i.n~Rigative;: field work iD the.e
landfills to dftermiJ1e if an iulDinent and-"8Ub.~an~il41 hazard 8Xi.~ed.
Jlfft"".l con~amin&~ion va. found. 'trace 1..''8ls of CS' were found a~ Buckeye
COve landfill and large molecular organicf4i,. ~ypicall 'I found i.n municipal
landfill., wer. found iD the landfill off ...f Rt. 70. 'the level of CS i.n the
BucJutye cov. landfill vaa below the action lev.l, 1:h8 PPLV, SK for this
con~aminant in 1:h8 ROD, Table 13. The Agency for Toxic Sub.~ance. and
. Di..... Reqiatry reviewed the anal~ical da~a g8Dua~ed from this field work
and advi.ed the Agency that neith.r the pu!:»lic DOr 1:h8 enviromD8n~ are a~
risk due to 1:h8 levels of con~emf~an~s'found iD 1:h8.. landfills.
'the ~hJzd off-.ite landfill, de.ignated .. Diaposa1 Are. 24 (DA-24) iD the
Chealtronic. RI and FS reports was al.o i.nve.~igated .. par1: of the
Cheaatronic. RI field work. Based on the anal~ical da~. generated frOID the
enviroDlD8D~.l 8amples collected frOID DA-2., the Agency dft8rmined that DA-24
did ~ requJze remediation. 'the enviroWD8D~al .ample. included bc"-~h surflZ.l.:;e
and sub.urface 80il .amples.
If I can of be of furthu help, please do n~ he8i~ate to con~ac:t me a~
(404)347-7791.
SiDcerely Y0ur8,
Jon It. ~1a
SUp8Z'fund P2:0.j-= Hanager
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Enclo.ur.
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APPBBDU G
Anal.yt1cal Re8ult. of Sampling Monitor
Well SW-4 Oft January 4, 1989
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0. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV, ATHENS. GEORGIA
MEMORANDUM
DATE:
FEB061989
SUBJECT: Results of Sampling at Chemtronics, Ind'.:, Swannanoa, North
Carolina. ESD Project No. 89-194.
FROM: James C. Gray j*£JV
Hazardous Waste-section
Environmental Compliance Branch
Environmental Services Division
TO: Jon Bornho1m
Superfund Branch
Waste Management Division
THRU: M. D. Lair, Chief
Hazardous Waste Section
Environmental Compliance Branch
Environmental Services Division
ERHB
nr?
FEB 81999
IbliiJLbU \J 15
EPA - REGION IV
ATLANTA, GA.
As per your request of December 5, 1988, well SW-4 at the Chemtronics site in
Swannanoa, North Carolina was sampled. Sampling was conducted on January 4,
1989. Present at the sampling was Beverly Ashbrook of Chemtronics to whom
split samples were given. The following data were collected during the
sampling and subsequent analysis.
• Well Sounding and Purging. Sounding of the well gave a depth to the
water of 9.20' below the top of the well casing. The total depth of
the well was determined to be 53.23*-, leaving a water column of
44.03'. For a 2" diameter well this volume of water calculated out to
be 7.18 gallons. After 25 gallons of water had been purged from the
well, the sample was collected.
• oH. Conductivity and Temperature. At the time of the sample, the pH of
the groundwater was determined to be 5.85, the conductivity was 210
micromhos per square centimeter, and the temperature was 15 degrees
centigrade.
• Analytical Results. Final analysis of the sample gave a concentration
for benzylic acid of 48 micrograms per liter, and for benzophenone of
3400 micrograms per liter, k
A copy of the analytical report is attached to this memo. Should you have
any questions regarding these results or should you require additional
information, please call me at FTS: 250-3589.
cc: Finger/Patton
Lair/Mundrick
Knight
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