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UnitBd States'
Environmenial Protection
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0Ific:e 01
Emergency and
Remedial Response
EPAlRODIR04-9Ot073
September 1990
L (Jp r (
PB11--- 1tzl "1'1'
&EPA
,
Superfund
Record of Decision:
National Starch & Chemical, NC -
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
EPA Report COllection-----l
Information Resource Centel!'
\ US EPA Region 3 \
. _~~d~~hla~!.~_1~!07 -
-------
50272-101
REPORT DOCUMENTAT10N 11. REPORTNO.
PAGE EPA/ROD/R04-90/073
2.
I. A8c1pi8nt8 Ac--'- No.
4. -n..........
SUPERFUND RECORD OF DECISION
National Starch & Chemical, NC
Second Remedial Action
7. AuIIor(8)
5. A8port D88
09/28/90
..
.. FWtINmIIIg Orpnbdon Alp&. No.
.. I'8rforn*'g 0rpInIaI0n MImI end ~
10. Proj8cllTMlllWoft lINt No.
11. ~C) or ~Q) No.
(C)
12. SpoII8CIItn8 0rpnIuII0n MImI ... AdIh88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(0)
11. Type of A8port . P8Itod CoWNd
Agency
800/000
14.
15. Suppl8m8ntary No...
11. Ab81r8ct (LImIt: 20D _Ida)
The 465-acre National Starch and Chemical site is a manufacturing facility for textile
finishing and custom speciality chemicals in Rowan County, North Carolina. A portion
of the site is heavily wooded, and surrounding land use is mixed industrial and
residential. From 1971 to 1978, approximately 350,000 gallons of reaction vessel
washwater containing salt brines, sulfuric acid solutions, and solvents were disposed
of onsite in unlined trenches. Liquid plant production wastes also were disposed of in
the trenches after being held in an unlined pretreatment lagoon. In 1976, sampling by
the site operator revealed shallow ground water contamination in the trench area. A
State investigation in 1977 supported this finding, and the State requested the site
operator to cease onsite liquid waste disposal in the trench area. A 1988 Record of
Decision (ROD) addressed Operable Unit 1 (OUl), which called for onsite ground water
pumping and treatment, further investigation of soil contamination in the trench area,
continued surface water and sediment monitoring and a supplemental remedial
investigation (RI). This ROD addresses OU2, and identifies no further action as the
remedy for the trench area soil based on the supplemental RI. A subsequent ROD will
address OU3, the remediation of onsite contaminated surface water and sediment, which
(See Attached Page)
17. Doc:unwn1 An8Iy8I8 .. OMc:rIpIore
Record of Decision - National
Second Remedial Action
Contaminated Medium: none
Key Contaminants: none
Starch & Chemical, NC
b. 1d8n000000pen-Ended T-
c. casA 11 FIeIdIGroup
18. AYlIIabllIy SI8tem8nt
18. SecurI1y CI888 (11118 Report)
None
20. SecurI1y a- (TIII8 1'8118)
Nnnj:!
21. No. of P811"
164
I
22. PrIce
See ANSl-Z38.18
SH/Mlruct/ona on Ra-
(Fonnatly NTlS-35)
08p8tn8nt of Co_ce
-------
EPA/ROD/R04-90/073
National Starch & Chemical, NC
Second Remedial Action
Abstract (Continued)
are unrelated to the trench soil contamination. Results of the supplemental RI
indicate that the natural leaching process of percolating rainfall will continue to
reduce the soil contamination level. Because the existing ground water treatment
system is designed to treat contaminants leaching into the ground water, there are no
additional contaminants of concern relating to the trench area soil.
The selected remedial action for OU2 is no further action. Soil will be monitored on a
quarterly basis, and institutional controls including deed restrictions will be
implemented. The estimated present worth cost for this remedial action is $151,000,
which includes a total O&M cost of $150,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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~ ~............:...':,,~ "'-f\O~
Record of Decision
National Starch & Chemical Corp. Site
Salisbury, North Carolina
u.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
September 1990
-------
DBCLARATIOR FOR TBB RECORD OF DECISION
Site Name and Location
National Starch and Chemical Corporation
Salisbury, Rowan County, North Carolina
Statement of 9as{s and Purpose
This decision document represents the selected remedial action for
Operable Unit Number 2 at the National Starch and Chemical
Corporation Site developed in accordance with the Comprehensive
Environmental Response, compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA) 42 U. S. C. Section 9601 et. seq., and to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), 40 CFR Part 300.
This decision is based upon the contents of the Administrative Record
for the National Starch Chemical Corporation site.
The State of North Carolina conditionally concurs on the selected
remedy.
Description of the Selected Remedv
This remedy addresses the remediation of residual subsurface soil
contamination. The United States Environmental Protection Agency has
selected no (further) action for the Second Operable Unit,
specifically the soils contained in the "trench area". Monitoring
of the trench area soils will be conducted on a quarterly basis to
verify that no unacceptable exposures to risks posed by conditions at
the site occur in the future.
Declaration Statement
The selection of a no remedial action alternative is protective of
human health and the environment based on the following criteria:
o
The Record of Decision for Operable Unit 1, September 30,
1988, pre.ent. the remedy selection for the groundwater
wbich mitigate. the principal threat posed by the
caat..inated groundwater at the site. The only route of
migration for the "trench area" soils would be into the
contaminated aquifer.
o
The natural infiltration of
selected groundwater remedy
soil contamination into the
precipitation will work with the
effectively flushing residual
groundwater capture zone.
o
Monitoring of the soils will be conducted on a quarterly
basis.
i
-------
o The risk assessment evaluated all potential exposure pathways
relevant to human exposure. No public health threat exists directly
from th... .oi18. The remedy for the potential exposure from
groundwater has been addressed within the first operable unit Record
of Decision.
Since this remedy will result in hazardous substances remaining
on-site, a review will be conducted within five years after
commencement of remedial action to insure that the remedy continues
to provide adequate protection of human health and the environment.
~ ~ \~ 1 _~--~LC-
reer C. Tidwell
Regional Administrator
:111~/qc
~
ii
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
NATIONAL STARCH AND CHEMICAL CORPORATION
SALISBURY, NORTH CAROLINA
PREPARED BY:
a.s. ENVIRONMENTAL PROTECTION
REGION IV
ATLANTA, GEORGIA
AGENCY
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TABLE OF CONTENTS
~
Site Location and Description
1
Site History and Enforcement Analysis
4
Community Relations Activities
6
Scope and Role of Operable Unit 2 Resource Action
6
Site Characteristics
7
Trench Area Soils
7
Surface Water and Sediments
10
Summary of Site Risks
10
Contaminants of Concern
11
Exposure Assessment
11
Toxicity Assessment
13
Risk Characterization
13
Description of the No Action Alternative
16
Costing Information
17
Explanation of significant Differences
18
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FIGURE
1
2
3
LIST OF FIGURES
PAGE
Site Vicinity Map
2
National Starch Site
3
Soil Borings Locations
5
-------
LIST OF TABLES
T~BLE
~
1
Organic ~nalysis Results
from Boring Samples
8
2
Inorganic Analysis Results
from Boring Samples
9
3
Groundwater Contaminants of Concern
with Highest Concentrations Detected
in Groundwater, Subsurface Soil
and TCLP Leachates of SUbsurface Soil
12
4
Site-related carcinogens of
Potential Concern
14
5
Site-related Noncarcinogens of
Potential Concern
15
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX 8 - LETTER FROM SUPPORT AGENCY
-------
DECIS!ON SUMMARY FOR ~HE RECORD OF DEC!S!ON
OPERABLE UNI~ NUMBER 2
NATIONAL STARCH AND CHEMICAL CORPORATION
SITE LOCATION AND DESCRIPTION
The National Starch and Chemical Company (NSCC) site is located in
Rowan County, Nor~~ Carolina, approximately five miles south of the
City of Salisbury (Figure 1). Salisbury is located about 40 miles
northeast of Charlotte, North Carolina.
The NSCC site, also referred to as the Cedar Springs Road Plant, is
approximately 465 acres in size. The disposal area, known as the
trench area, is surrounded by heavily wooded acreage to the north,
west, and south. The chemical plant is located in the eastern
portion of the site property. Residential areas are located no less
than 1500 feet from the trench area in the northwest and southwest
directions.
Land use of the area immediately adjacent to the site consists of a
mixture of residential and industrial developments (Figure 2).
According to 1986 statistics, Rowan county covers 517 square miles in
area and has a population of 104,678. The population of the City of
Salisbury was 23,931 as of 1986. Groundwater is the source of
drinking water supplies for the community; the City of Salisbury
supplies residents located to the north, east, and south of the
site. Other nearby residents are supplied by small community wells.
Several unnamed tributaries traverse the site and flow into the
Grants Creek system. One tributary flows along the front of the
plant paralleling Cedar Springs Road and leaves the property to the
north. A small intermittent stream forms the southwestern site
boundary. A third small stream is indicated on the USGS quadrangle
map in the northwest quadrant of the site. Grants Creek forms the
western boundary of the property and continues flowing in a northerly
direction.
There is no designated North Carolina State significant Habitat,
agricultural land, or historic landmark site potentially or directly
affected by the site. There are no endangered species or critical
habitats within proximity of the site. There are no identified
coastal or fr..h-water wetlands within an area of influence of the
site.
The geologie tramework of Rowan County forms two distinct aquifers.
The first i. a shallow aquifer created by the saprolite. The second
is a bedrock aquifer formed of crystalline rocks. These two aquifers
are interconected with clay-rich saprolite. Water yielding
properties are variable. Wells drilled within the bedrock aquifer
generally have higher yields than those in the saprolite aquifer and
average approximately 40 to 50 gallons per minute.
-------
I
IV
I
.
Figure 1
Vicinity
McJl'
Cedar S
prfngs Road P1ant
Site
-------
C~,"'7: \. =! IN':'E:~'iAL. 10 FHi.
Figure 2
National Starch Site
-------
Site Historv and Enforcement Analysis
The NSCC site i8 located on the outskirts of the Salisbury city limits.
Edward Pr~or of Salisbury founded the Proctor Chemical Company in 1938. :n
September 1968, Proctor Chemical Company purchased the 465-acre Cedar Spri~gs
Road property. Within the next year, Proctor Chemical was acquired by
National Starch and operated as a separate subsidiary. Construction of the
Cedar springs Road plant began in 1970. On January 1, 1983, Proctor Chemical
Company was dissolved and its operations merged with National Starch. The
National Starch !acility is primarily a manufacturing plant for textile
finishing chemicals and custom specialty chemicals.
From 1971 to 1978, the NSCC conducted on site disposal of approximately
350,000 gallons of reaction vessel wash water into trenches which were
reported to be approximately 200 to 300 feet long and 8 feet deep. The wash
water consisted predominantly of salt brines, sulfuric acid solutions, and
solvents and is classified as D002 waste with corrosive properties and a pH ~
2. These trenches were constructed within a 5-acre tract of the western
section of the site property. The trench area is shown on Figure 3.
Liquid effluent from the plant production area flowed into the easternmost
pretreatment holding lagoon, which was unlined, and then was pumped to an
active trench in the trench area. Each trench was used until liquid no
longer readily percolated into the ground. At that time, the trench was
backfilled and seeded, and a new trench was constructed.
In 1976, NSCC installed eight monitoring wells around the site to determine
if the trenching operations had impacted groundwater quality. Four of these
monitoring wells were installed adjacent to or within the trench area.
sampling results revealed that shallow groundwater immediately within and
adjacent to the trench area was contaminated. In June 1977, sampling and
analysis conducted by the State of North Carolina verified NSCC's results.
The State subsequently requested that NSCC cease on site waste disposal in
the trench area.
The NSCC site was proprosed for inclusion on the National Priorties List
(NPL) in April 1985 with EPA assuming lead responsibility for the site.
Negotiations to allow NSCC to conduct the Remedial Investigation/Feasibility
Study (RI/FS) activities were concluded with the signature of an
Administrative Order on Consent on December 1, 1986. These activities
resulted in the iS8uance of the first Record of Decision (ROD) during
September 1988.
The first R8D address.d groundwater remediation at the site under Operable
Unit 1. Tb8 ROD specified that soil contamination in the trench area be
further inV88tigated to determine whether the area continued to be a major
source of groundwater contamination. The first ROD also required that
analytical monitoring continue on contaminated surface water and sediments to
further delineate the source.
The final Remedial Design for groundwater remediation under Operable
has been approved by EPA. Construction began in August 1990 which
constitutes the initial Remedial Action (RA).
Unit 1
-4-
-------
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Figure 3
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At EPA's direction, a Supplemental RIfFS was conducted for Operable Unit 2.
The trench area was the focal point of the investigation. Subsurface soi~s
were sampled from ten boreholes drilled in the trench area. The boreholes
were continuously sampled using split spoons, beginning at the surface and
extending to a depth of 30 feet or to the saturated zone, whichever was
encountered first. Field screening was conducted in the final selection of
the samples submi~ted for laboratory analysis. In addition, Toxicity
Characterisics ~eaching Procedure (TCLP) analyses were conducted on
severalborehole samples using both a standard and a rainwater sOluti?n
(collected in the trench) to determine certain site-specific leachability
characteristics of the soils.
The Supplemental RI also included additional monitoring of the surface water
and sediments in what is known as the northeast tributary. This tributary
was sampled in October and November of 1989 and again in July of 1990.
Results of this tributary sampling confirmed surface water and sediment
contamina~ion. Therefore, the northeast tributary will be addressed under a
third operable unit.
This decision document presents the remedial selection for the residual soil
contamination in the trench area at the NSCC site.
COMMUNITY RELATIONS ACTIVITIES
EPA's community relation efforts for the NSCC have been ongoing since 1986.
Communication with the community has included the development of several site
specific fact sheets as well as four public meetings to date. Specifically
for Operable crnit 2, the Supplemental RIfFS and Proposed Plan Fact Sheet were
distributed to the public during July 1990. The Second Operable crnit
Administrative Record was made available at the Rowan County Library during
the Public Comment Period. Public Comment was held from July 30, 1990 to
August 29, 1990.
All comments made to the Agency concerning the Proposed Plan and the site in
general have been compiled and addressed in the Responsiveness Summary which
is attached to this Record of Decision as Appendix A.
SCOPE AND ROLE OF OPERABLE UNIT 2 RESPONSE ACTION
The scope of this re.pon.e action is to address any soil contamination in the
trench ar.. a. a .ourc. control Operable crnit. The first Operable crnit
action wa. decided with the issuance of a ROD on September 30, 1988. This
ROD required the development of a groundwater interception and extraction
system to be in.talled downgradient of the contaminant plume. Pretreatment
for the extracted groundwater includes air stripping, filtration through
activated carbon, metals removal, and treatment through the company's
existing lagoon system. Discharge will be to the Salisbury Publically Owned
Treatment Works (POTW). A contingency for an alternate discharge point was
included in the ROD if permit requirements for the POTW cannot be met.
Monitoring of the surface waters on the site are also required under the
first ROD.
Objectives of Operable crnit 2 are to: ensure that cleanup standards for the
site are developed for all appropriate media, (i.e., subsurface soils and
-6-
-------
groundwater), implement a cleanup alternative that is protective of human
health and the environment, and select a remedy that meets the above cri~eria
in a cost effective manner.
SITE CHARACTERISTICS
The NSCC site was characterized during the initial RI/FS under a
comprehensive site-wide investigation. Based on the results of this initial
RI, the trench area was determined to be the only significant area from past
disposal practices that could be considered a remaining source area to
groundwater contamination. The first ROD required that the trench area be
further investigated to identify the degree of source contribution. This
decision document is limited to the characteristics as observed in the trench
area soils and is based on the Supplemental RI. The trench area is not
considered the source of contamination to the tributary.
TRENCH AREA SOILS
The Supplemental RI characterized the trench area subsurface soils with the
installation of 10 boreholes. Figure 3 provides the borehole locations.
Results of the organic analysis are shown on Table 1. Significant levels of
1,2-dichloroethane, 2-butanone, 1,2-dichloropropane, 4-methyl-2-pentanone,
toluene, ethylbenzene and xylenes were identified in the trench area
subsurface soils. Antimony and arsenic were the inorganic constituents
identified at elevated levels; these two contaminants were detected at
elevated levels in only one location. Tabulated inorganic data are presented
in Table 2.
Based on the data developed from both the initial and supplemental RIs, the
subsurface soil contamination has been observed from 5 feet below land
surface down to the water table. The top 5 feet is believed to be clean soil
which was backfilled into trenches as they were deactivated. Maximum
concentrations were observed ap~roximately 18 feet below land surface. There
is no current complete route of exposure specifically from these soils, i.e.,
no dermal exposure potential. Migration pathway is isolated to leaching into
the groundwater.
The trench area is known to be the original source of the groundwater
contamination based on historical disposal practices. The supplemental RI
was designed to measure the effectiveness of the natural soil flushing by
percolating rainfall through the soil contaminants as well as determining the
actual contaminant concentrations remaining in the trench area subsurface
soils. TbaSUpplemental RI was conducted to characterize the remaining
contaminatioD in the subsurface soils in the trench area specifically to
determine 11 remediation of the soils was necessary. Results of the
Supplemental RI indicate that the natural leaching process has resulted in
reducing the levels of the soils contamination. This is based on the
magnitude of the contamination currently in the groundwater compared to the
residual levels of the contamination left in the soil. In fact, several of
the contaminants of concern identified in the first ROD were not detected
within the trench area soils during the supplemental RI field work.
The Supplemental RI determined that the most notable contaminant
concentrations of trench area soils were approximately 18 feet below
-7-
the land
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Table
ORGANIC ANALYSIS RESULTS
FROH S
,BORING SAMPLES COLLECTED NOVEMBER
NATIONAL STARCtI:
C(O"U"lIa".'" ... In ug/kl 10"""
--.. -.--------- ---------~ _._- -- - --
.' IOU -...... 001) ''''11 ""'."
'''''UO INt.'VA' 1808 1001) _fACi If II
"''11 C-
~"UICIN
a
"a", -.. _er -.. -.. -- ..---.. ..- 18 _II _u _u
'-)' 18-11' 11-10' 18-U' II-II' U-II' .0-1" 18- 10' la-u' U-Ml'
1111 _Sf....11
l' 'r.f:~
VOl 81111 08U~'CI'
."h,l.no
-------
Table
2
NATIONAL STARCH:
INORGANIC ANALYSIS RESULTS FROM SOIL BORING SAMPLES COLLECTED NOVEMBER 1989
------ -
$lilt -,.... ANI ,...." N...IU l
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surface and were found in much lower concentrations than expected. :t
appears that residual soil contamination is effectively leaching into the
groundwat~, 80il concentrations are consequently being reduced. Any
remedial actions involving removal or treatment of these subsurface soils
will introduce additional risks to the environment or human health, by the
excavation or construction concerns inherent to any further action.
To support the potential for natural soil flushing to be considered as a
viable ~emedia: Qption in conjunction with the groundwater extraction system,
two vadose zone models were applied to the study data. The first objective
was to determine an acceptable concentration of a contaminant in soil; the
second objective was to predict the time required to achieve this acceptable
concentration. Pre-established groundwater cleanup criteria (Operable Unit 1
ROD, 1988), were considered the upward limit for contaminant concentrations
in groundwater. Soil concentrations were then back-calculated using the
soil/water equilibrium relationship. Modeling data and information are
provided in Appendix B.
The modeling approach was based on conservative assumptions and was also used
to predict the leachate concentration over time. The partition coefficients
were calculated based on site-specific results of the TCLP analysis. The
model predicts that most compounds will leach into the groundwater within 5
years. 1,2-dichloroethane is predicted to take much longer (approximately 22
years). Preliminary estimates show that the groundwater remediation effort
may take 20 to 30 years before meeting the cleanup criteria throughout the
plume.
Surface Water and Sediments
Surface water/sediment sampling was conducted during both the first and
supplemental RIs. The actual source of this contamination has not been
determined. It has been concluded that the trench area soils are not the
source. This Second Operable Unit presents the selected remedy for the
trench area soils.
Continual monitoring of the surface water system, known as the northeast
tributary, is required by the first ROD, until a source of contamination can
be defined. Purther investigation of this system will be continued under a
third Operable Unit to ultimately select an appropriate remedy.
Summary of Sit. Risk.
CERCLA dir88t8 that the Agency must protect human health and the environment
from curr881 and potential exposure to hazardous substances at the site. The
risk ass..888nt conducted during the initial RI concluded that the principal
risk pre.ented trom the NSCC site was the potential for human consumption of
contaminated groundwater. Likewise, the principal risk posed from the
trench area soils is also the potential for human consumption of contaminated
groundwater since the only route of migration of and/or exposure to the
contaminated subsurface soils is rnfiltration to groundwater. The following
section summarizes the Agency's finding concerning the risks from exposure to
groundwater related to this site and discusses the contaminated soil as a
source of exposure.
-10-
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Contaminants of Concern
Eleven carcinogens and fourteen non-carcinogens have been identified in the
groundwater at this site. The toxicity, mobility and persistence
characteri8tics of these substances at the site do not warrant the exclusion
of any of these substances from ~onsideration as chemicals of concern at the
site. The contaminants of concern for groundwater at this site are listed ~n
Table 3. This table also shows the highest concentrations of these
substances in groundwater and in the soil samples collected at the site.
Also the TCLP results for the three soil samples collected at the 12 to 18
ft. level are shown. The maximum concentrations from a rainwater and
standard leachate are shown. This table also shows the highest
concentrations of these substances in groundwater and in the soil samples
collected at the site. The maximum concertrations from a 'rainwater and
standard leachate are shown. The results of sampling from the supplemental
RI indicate levels of contaminants of concern in the soil of the trench area
are of minimal significance relative to the concentrations currently existing
in groundwater. Since the groundwater pump and treat system is designed to
capture the highly contaminated groundwater as well as lesser contaminated
groundwater originating by the leaching of rainfall through the residual
soils in the trench area, no excavation of the source is deemed necessary.
Therefore, no contaminants of concern were identified for soil.
Exposure Assessment
Groundwater in the area is a current source of drinking water; it is
classified as Class IIA based on the Agency's Groundwater Classification
Strategy. A 1988 survey of existing off-site water supply wells revealed a
total of 1,539 homes within a 3-mile radius of the site. These wells are
outside the limits of the city water lines and could potentially use the
groundwater for drinking and other domestic purposes. The closest well is
located 2,200 feet northeast of the site.
In developing the hypothetical exposure scenarios for groundwater at this
site, it was assumed that nearby residents would be exposed to water
contaminated at the highest concentrations found on site. This is a
reasonable assumption based on the facts that residences are located almost
directly along the site boundaries in the direction of apparent groundwater
flow, and because the data indicate that the groundwater plume is advancing,
rapidly. The potential routes of human exposure relative to the groundwater
include water used for drinking and other domestic purposes.
Contamin~ were identified in soil sample taken to a depth of 30 ft.
However, a ~rench-area sample taken at the 0-2 ft. depth showed low levels of
only thr.. orqanic contaminants, i.e. methylene chloride, acetone and
bis(2-ethylhexyl) phthalate. This finding of minimal contamination is
consistent with the understanding that trenched areas (8 ft. deep) had been
back filled with clean soil. Only the top 1 to 2 feet of surface soil is
considered as a direct-exposure soil source. Therefore exposure through soil
ingestion, inhalation and dermal contact could be possible to the three
organic contaminants. The more extensive contamination of the subsurface
soil would be of concern as a source of exposure through groundwater use.
-11-
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TABLE 3
Groundwater Contaminants of Concern with
Highest Concentrations Detected in Groundwater, Subsurface Soil
and TCLP Leachates of Subsurface Soil (ppb).
CARCINOGENS
MAXIMUM
WATER CONCa
MAXIMUM SOIL
CONcb
MAXIMUM TCLP
.~b,c
Arsenic
Benzene
Bis{2-chloroethyl)ether
Bromodichloromethane
chloroform
1,2-dichloroethane
l,l-dichloroethylene
Methylene chlorode
1,1,2-trichloroethane
Trichloroethylene
Vinyl chloride
310
8
14,000
7
49
350,000
11
8
11
10
90
44,000
ND
33,000
ND
ND
100,00
ND
71
ND
ND
ND
2
810
1
NON-CARCINOGENS
Actone 89,000 31,000 150
Barium 2,290 190,000 760
Beryllium 120 800
Cadmium 114 3,000
Chromium (VI) 554 27,000
1,2-dichlorpropane 29,000 100,000 19
Ethyl benzene 1,500 1,700 33
Manganese 1,400,000 964,000 5900
Nickel 5,190 23,000 30
4-nitropheno1 13,000 ND
Selenium 274 ND
Toluene 6,000 30,000 62
Xylenes (mixed) 3,800 11 ,000 95
Zinc 14,900 99,200 71
. .~~.
co;:
'...-
a
Data from Public Health Evaluation in FS Report, September, 1988.
b
Data from supplemental RI report for Second Operable Unit, May 1990.
maximum values occurred in samples taken at 10 feet or below.
All
c
Only samples collected at 12-18 ft. below surface were subjected to TCLP
analysis.
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1-
Toxicitv Assessment
Cancer pot8Dey factors (CPFs) have been developed by EPA's Carcinogenic
assessment Group for estimating excess lifetime cancer risks associated with
expsoure to potentially carcinogenic chemicals. CPFs, which are expressed in
units of (mg/kg/aay)-l, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg-day, to provide an upper-bond estimate of the excess
lifetime cancer risk associated with exposure at the intake level. The term
"upper bound" re!lects the conservative estimate of the risks calculated from
the CPF. Use of this approach makes underestimation of the actual cancer
risk highly unlikely. Cancer potency factors are derived from the results of
human epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been applied. The
Agency considers individual excess cancer risk from exposure to contaminants
at superfund site to be protective if they fall within a 10-4 to 10-6
range, i.e. 1:10,000 to 1:1,000,000. The 10-6 risk level is the desired
level for single carcinogens; the sum of site upperbound cancer risk should
not exceed 10-4.
Reference doses (RfDs) have been developed by EPA for indicating the
potential for adverse health effects from exposure to chemicals exhibiting
noncarcinogenic effect. RfDs, which are expressed in units of mg/kg-day, are
estimates of lifetime daily exposure levels for humans, including sensitive
individuals. Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological studies or
animal studies to which uncertainty factores have been applied (e.g. to
account for the use of animal data to predict effects on humans.) These
uncertainty factors help ensure that the RfDs will not underestimate the
potential for adverse noncarcinogenic effects to occur.
The CPFs for the 11 carcinogens and the RfDs for the 14 non-carcinogens
selected as the groundwater contaminants of concern are shown in Tables 4 and
5.
Risk Characterization
Excess lifetime cancer risks are determined yb multiplying the intake level
with the cancer potency factor. These risks are probabilities that are
generally expr.8sed in 8cientific notation (e.g., 1 x 10-6 or 1E-6). An
excess lif8Cm8 riak of 1 x 10-6 indicates that, as a plausible upper bound,
an individUal has a one in a million chance of developing cancer as a result
of site-r.Ia~8d expoaure to a carcinogen over a 70-year lifetime under the
specific 88p08ure conditions at a site.
Potential concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as the hazard quotient (HQ) (or the ratio of the
estimated intake derived from the contaminant concentration in a given medium
to the contaminant's reference dose). By adding the HQs for all contaminants
within a medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The HI
provides a useful reference point for gauging the potential significance of
multiple contaminant exposures with a single medium or across media.
-13-
-------
TAUI.I~ 4
S I n:-REI.An:n CARC I NtK;J':NS 010' POTI~NT I AI. CONCI':RN AT '1'111';
NATIONAl. STARCII ANn CIII.]t I CAI. CORPORAT I UN S 1'1'1':
SAI.I SliURY, NORTH CAROI.INA
COKPOUNU
flax imum
Observed
CODcerntration
(ugH)
":slimated
WUl"se Case
Intakea
(lOg/kg/day)
Wun.t Ca~ie
NU8bel"
t:xceed in",
Dete(:t iOIl
I.ImlLll
Ext: (~~i ~i
CI,..,h Cmod ich lorome thane
henzene
]SO.ooo
14.000
]10
90
II
49
II
7
H
10
8
1.00":-tOI
4 . OO,,:-()I
8. H6":-0)
2 . 5 n:-O]
].141-:-04
I .1.()Io;-O]
].14":-04
2.001-:-04
2. 291~-04
2.861-:-04
2.291-:-04
9.lm:t02
I . I m: WO
I . ~m:tOU
2 . :JUl': t 00
'j. 8UE-O I
8.lm:-02
'j. ]"IE-02
8. IUE-O'l.
~. 'l.()I':-O'l.
I . I m:-u'l.
7. 'IE-(n
9.IUI-:-OI
II .I.m:-o I
I. ]U:-U2
',.IJ I E-(rI
I . H'J.Io:-()I.
I . I n:-/,
I . HUE-Wi
l.bll':-U')
I . IIJE-U')
"I. I/",:--u(,
I ./II':-Ub
18
7
I]
"I
I
I.
'I"ichlon)ethylene
melhylene chloride
'l.
1
I
1
'l.
-----
_._-- --_. ____'0-_____'- _.--- -..
aThe estimated worst case intake does not I"epresent any real exposure scemll"io al tlw :;itt~. It. i~. h;wl~tI 011
a 70 kg persun dt'inking 2 liters of watel" per day fOI" their entire life fl"um the munilu..-inl~ well t:uul.aiuillg
the maximum ohsel"ved concentration of a chemical. This hypothetical expusul"e m:t~na..-iu is lI~it~d lu rallk ""1-
ative toxicity based on the inherent tuxi(:ity and the maximum detected conccnlratiun ul each chemical. Thi~;
assumption assists in identifying those (:arcinogens that have the greatest potential tu puse a hazard wilh
frequent exposure over a number of years.
hCI'''' or Cancer I'otcncy "'actors were obtailletl I rom the Superfund l'uhl it: lIeallh Ev.tllI.1I iOIl Mallllal, I~I'A I'JUlI.
t:Worst case excess cancer risk
is derjvt~d frolD the elluation ":CR = CI'''' X Uose '" t~st imatctl wur~it
case inlakl~.
1I'lhlil:al"~i Ilw IIlImher uf ~iUlal)les uut. 01 "11\ Ihal CXI"I~I.tI the allalylil~..1
,1,-1 "1'1 i oil 'i '" i I I 0' 1 1,:1 1
I'h,'", i.... I ,
-------
TAIU.I': 'j
S ....t;-KEI.A'I'EU r4f1NCI\ltC I NO(:!':NS ()Io' I>O'l'I':NT I AI. CONCEKN AT Till':
NATtONAI. !;T.'\KCII ANII CIIEHICAI. COKPUKATION SITI':
~;AI.I~mIJKY. NORTII CAKUI.INA
COMPOUND
HAXIHUH
ORS~RVf.D
CONCt:NTRA1' IONS
(ug/l)
1.2-dichluropropane
1II;"II~;IIIeRe
"-11 i l rUI)henol
al:etune
nickel
(:admium
xylene (mixed)
Iteryilium
chromium (as Cr VI)
selelliura
7. I II(:
hariuCl
tuluc.:c
elhy I I~~IIZ('IIC
29..000
1..380.000
IJ.OOO
89.000
5190
114
3800
120
SS4
274
1 49()0
1290
6000
1500
---- - -- -----_.'-'--_.._-'-_._~--~----_._._-_.--
I':~;T I HATI.:n
WOKST CASE
I NTAKI':CJ
~.s/ kg/ d;!1l-
WOItST CA~;E
IIAZJ\,l/l
INIJEXh
AJC
ur Kfn
(mg/kg/clay)-Id -
SOIJItCI-:C
---- -----.- -."
n. 291':-0 I
., . I}'. J.: f 0 I
\ . /1 E-O I
2 . ')1.1': /-(J(J
I . 4nl~-O I
).2t11':-0]
1.09E-01
., .'. "":-0 'J
I . ~)lU':-02
/ . wu.:-(n
'.. U,I':-() I
(,. ')'.E-02
1 . II E-O 1
',.1.9/-:-02
1 . 7 II~-O'I
2 . 7U1~-() 1
I .om.:-oz
I . om:-() I
I .Om:-02
2 . 9()1~-O't
I . mm-()l
'j .om:-o'.
.) .om:-U"I
'J.OtJl-:-()"J
2. I m:-o I
'). 1(11':-0]
) . ()(II~-() I
1 . UU/-:-U I
'.HI.'; .'.
1/9. '}
-II . I
'/.'). '.
HCI.G
flEA
cI
KI/)
ilEA
ilEA
II EJ\
IHn
IIFA
IIF/\
111:/\
111-:/\
IU n
Itln
I '..U
11.1
10.9
(,.9
'I.I
') , (,
') ,0
I. .\
11.(,
() .'.
--.-----....
"The estimated worst case intake does nol repn!sent allY ,"eal (!xllOsun! ~;c:clI;lriu iI' tlw !;;'('. II i!; bil~;c'.1 UII "
70 kg person drinking 2 J iters of water pel" .Iay for their entire I He I "010 the monitoring wcll (:ulltaillilll~
lhe maximum oltserved concentration of a du'mil:al. 'I'hi~. hypothet.ical (!xptHHirc ~a:(~lIar;o ;!; U!;(~(1 to rallk lel;ltiVt:
loxicity Itased on theillherent toxicity anel the maximum detected concclIlrat iun uf each dlt'mi(';II. This put(!lIt iill
CJssists hi identifying those noncarcinugcns t.hal have t.he greCJtest l'ulclIl;ill t.O po~a~ a hazanl wilh fn!'I"(~IIt.
exposure over a numltec of years.
bllazard Index is derived from the e(luatiun: III = Uusc/Reference lIose. wlwr'c: III = hazan' illtlt'x.
lIu!w = 1:~;tim..II'd wor.!;t CiI!;e illl;IIII'
KclcI'cncc do:;c .~ ;It:..ept.ahl(~ illt;"'"
I or chroll;" (!XP".'"'' ,.
cliEA = lIeA 19tH,
MCU; = Maximlllll Contaminant Level (;0<11. (1-:1'/\ !lJI\(,)
hy EllvironmcntaICr;tcr-ia a 1111 1\!;!;t':;~;lIIt!1I1
01 I i I:e. EI'J\ "HV,
clUI',-iv..d hy W;;III: II... HId 10/' plwllol alltl I/:;ill/'. all alldi,i..llal ~;alcty
10' Iy 01 ',-lIil'0l'lwllol.
'.11""'- ,,, a""",:;:; 'I,,' I<.""\J" 11i/',I,,', ;11 111,.
-------
The carcinogenic upperbound risks and the non-carcinogenic Hazard Index
values for the 25 groundwater contaminants of concern are shown in Tables 9
and 10. The risk numbers are based on exposure to the maximum concen~ra~ions
detected tor each chemical during the RI investigation. The potential risk
posed by the.e chemicals from ground water contamination is being addressed
in the remedy for operable unit one (Outl). The risk summary of this ROD ~or
operable unit unit two has included a discussion of the risk from groundwater
for t~o reasons: (1) it was not adequately discussed in the ROD for OUIl and
its inclusion here provides a more accessible record and (2) it provides
important background information for the no-ac~ion remedy proposed for OU'2,
the soil source. .
The data indicate that all remaining site contaminants are in the saturated
zone or in the deep soil just above the surficial aquifer. Although minimal
data were collected to confirm this assumption, all site history information
indicate that no contamination exists in the top 2-5 ft. of soil. The three
contaminants detected in the top 2 ft. of soil discussed under the Exposure
Assessment Section were well below levels of concern. Therefore, the direct
soil exposure pathways are not relevant for this site.
,;
Groundwater contamination from deep soil leaching appears to be the only
exposure pathway to remaining site contaminants and this pathway is being
addressed under OU'l. The groundwater and deep soil data indicate that the
primary contaminants (volatile and semivolatile compounds) are moving into
the groundwater and that maximum concentrations have likely already reached
the surficial aquifer. It is likely that disturbance of the soil source of
these contaminants could result in an increase health risk by creating new
direct exposure pathways to workers and perhaps to the community. Therefore,
a no action remedy is believed to be the course that would create the least
risk from the soil source while the remedy identified under OU'l achieves
groundwater protection.
DESCRIPTION OF THE NO ACTION ALTERNATIVE
The no-action alternative would leave contaminated soils in place. This will
allow for the naturally occurring leaching or cleaning of the soil in
conjunction with groundwater remediation. Leachate from the residual soil
contamination would be extracted and treated by the groundwater extraction
system. Infiltration to groundwater is the only route of migration and
subsequent exposure potential.
A deed re.~iction would be filed identifying the areas of contamination.
The deed r88triction will prevent property transfers to uninformed purchasers
and will l~t turture utilization of the property. The.. restrictions are
easily implemented by processing the restrictions through a local attorney
and the Rowan County or City of Salisbury Register of Ceeds.
The trench disposal area itself does not present a direct health risk. As
previously stated, the risk posed .is through the migration from soils into
groundwater; subsequent contaminated groundwater consumption poses the
principal site threat. Therefore, access restriction to this area is not
required. It should be noted that the trench area lies well within the NSCC
property.
-16-
-------
The primary concern at the NSCC site is groundwater contamination. The or.~y
manner in which the soils contamination can manifest itself is through
leaching ~~o the groundwater system. The groundwater remedy was presented
in the fir8t Operable Unit ROD in 1988. The groundwater plume is to be
controlled and treated to prevent releases off the site property; therefore,
any potential exposure pathway will be mitigated. By allowing the natural
attenuation of the soil, contamination (over time) will be reduced because of
biodegradation, leaching, and volatilization of contaminants.
Any residual contaminants in the unsaturated zone will be leached naturally
by precipitation infiltration and t~en captured within the groundwater
extraction system for ultimate treatment and disposal. Contaminant transport
modeling, as presented in the Supplemental RI, predicted that most compounds
will leach into the groundwater within the projected time frame for
groundwater remediation, i.e. 20 to 30 years. This leaching process will
actually be inhanced by the groundwater extraction system. This alternative,
in conjunction with groundwater remediation, provides an effective method to
treat soil and groundwater contaminants.
Additional Remedial Alternatives addressing the trench area soils were
developed in both the initial and Supplemental FSs. These documents and all
relative data are contained within the Administrative Record.
Costinq Information
The capital costs asso~itated with the no action alternative are the attorney
fees for processing the deed restrictions. The operation and maintenance
costs associated with this alternative are for resampling and evaluating the
reduction of contaminants in the soil every five yea~s.
"
Capital Costs
Deed restriction, lawyer fees
$1.000
Subtotal $1,000
Operation and Maintenance Costs
50il sampling every five years $150,000
(30 years, pr..ent worth)
. Subtotal $150,000
~-
Present WaIiIit. :
~ PW - $1,000 + $150,000
PW .. $151,000
In summary, the trench area subsurface soil has been adequately addressed to
concludes that the contaminants existing in the soil will leach over time
into percolating rainfall. The ledchate will then become captured by the
groundwater extraction system and treated in the on-site pretreatment
system.
-17-
-------
A conservative modeling approach was used ~o predic~ ~he leachate
concentration over t~e. The parti~ion coefficients were calculated based ~n
site-8pec1t1c re.ults of leachate (TCL?) analysis. Also, the highest known
concentrat1on of each compound was used in the model to account for
uncertaint1.. in the data set. Even with this conservative approach, the
model predicts that most compounds will leach into the groundwater with 5
years. 1,2-dichloroethane, (DCA), is predicted to take 22 years before a safe
level is reached (in groundwater). PrelLminary estimates show that the
groundwater remediation effort may take 20 to 30 years before meeting the
cleanup criteria throughout the plume. Therefore, the remedial alternative of
natural soil flushing (or no further action) as described in the original and
Supplemental FS is the recommended approach.
In addition, soil samples should be collected for monitoring purposes no less
frequently than every 5 years to verify that soil remediation is progressing.
At a minimum, analysis will consist of volatile organic compounds.
EXPLANATION OF SIGNIFICANT DIFFERENCES
The selected remedy as presented in this decision docament has 00 differences,
significant or otherwi8e, from the proposed plan.
-18-
~
...
S:
-------
"
~.
.;..-
- '.
APPENDIX A - RESPONSIVENESS SUMMARY
-------
1.
RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public comment period from
July 30 through August 29, 1990 for interested parties to comment on the Remedial
Investigation/Feasibility Study
(RI/FS)
resul ts and
the
Proposed Plan
for
Operable Unit 2 at the National Starch and Chemical Corporation Site (NSCC Site
or the site) in Salisbury, North Carolina.
The Proposed Plan, included in Attachment A of this document, provides a summary
of the site's background information leading up to the public comment period.
Specifically, the Proposed Plan includes the following sections: Introduction,
Site Background, Results of the Supplemental Remedial Investigation, Endangerment
Assessment, Scope and Objectives of this Remedial Action, Public Comment Period,
EPA's Review of Public Comments, Additional Public Information, Development of
EPA's Preferred Alternative, Summary of Remedial Alternatives, EPA's Rationale
for Soliciting the Preferred Alternative and Glossary of Terms.
EPA held a public meeting at 7:00 pm on July 30, 1990 at the Salisbury Civic
Center in Salisbury, North Carolina to outline the RI/FS and describe EPA' s
proposed remedial alternatives for Operable Unit 2 (i.e., trench area soils) at
the NSCC Site.
All comments received by EPA during the public comment period
will be considered in the final selection of a remedial alternative for the areas
of contamination at the NSCC Site.
The Responsiveness Summary, required ~y the Superfund Law, provides a summary of
citizens' comments and concerns identified and received during the public comment
period, and EPA's responses to those comments and concerns.
This
Responsiveness
Summary
is
organized
into
the
following
sections
and
attachments:
1.
RESPONSIVENESS SUMMARY OVERVIEW. This section outlines the purposes
of the public comment period and the Responsiveness Summary. It
also references the appended background information leading up to
the public comment period.
1
-------
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS.
provides a brief history of community concerns
regarding the NSCC Site.
This section
and interest
III.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
MEETING AND EPA' S RESPONSES TO THESE COMMENTS. This section
summar~zes the oral comments received by EPA at the July 30, 1990
public meeting, and provides EPA's responses to these comments.
IV.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA'S
RESPONSES TO THESE COMMENTS. This section contains the one letter
received by EPA containing written comments, as well as EPA's
written response to that letter.
ATTACHMENT A: Attachment A contains the Proposed Plan which was
distributed to the public during the public meeting held on July 30,
1990 and mailed to the information repository and those included on
the mailing list.
ATTACHMENT B: Attachment B includes the sign in sheets from the
public meeting held on July 30, 1990 at the Salisbury Civic Center,
315 South Boundary Street, Salisbury, North Carolina.
ATTACHMENT C: Attachment C includes names, addresses and phone
numbers of the information repository designated for the NSCC Site.
ATTACHMENT D: Attachment D includes the official transcript of the
Public Hearing on the Proposed Plan for the Cleanup of the NSCC Site
located in Salisbury, North Carolina.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
A. Background on Community Involvement
Awareness of and concern about the National Starch plant are very high in the
communities which are adjacent to and nearby the site. National Starch has
received ~onsiderable local media attention, primarily in The Salisbury Post
(formerly the Salisbury Evening Post). In the 1960s and 1970s, Proctor Chemical
(later acquired by National Starch) experienced incidents of escaping vapor
clouds and chemical spills at the Lumber Street plant. Two such incidents were
reported in The SalisburY Post in April and October, 1979. In both incidents,
a vapor cloud escaped from the plant when a piece of equipment malfunctioned.
Chemical spills and equipment malfunctions were also reported in March and April
1980 for the Cedar Springs Road Plant, the location of the Superfund site.
2
-------
The Salisbury Post reported in 1982 that three Rowan County firms, including
Proctor Chemical on Cedar Springs Road, were included in a list of 174 sites in.
North Carolina that may contain hazardous wastes..
Proctor Chemical Safety
Director, Lane Brown, was quoted in The Salisbury Post article as stating that
about 350,000 gallo~s of waste material from the production of textile products
were stored in evaporation lagoons and trenches between 1971 and 1978.
The single event which was most significant in heightening community awareness
about National Starch was the explosion that occurred at the 'firm's Lumber Street
Plant on September 21, 1983. The explosion destroyed a section of the plant,
injured four employees and 14 firemen, sent debris over a four block area, and
required 75 families to be evacuated from the area for a short time. This
incident received national media attention.
In the aftermath of the explosion,
residents
in the nearby neighborhoods urged that National Starch move the
potentially explosive mixing operations to its Cedar Springs Road Plant. Even
though National Starch responded quickly to cleanup and repair damage to
surrounding homes, a petition was circulated urging National Starch to move their
operations to the Cedar Springs Road Plant. An article in The Salisbury Post on
October 4, 1983, indicated that the petition had been signed by 166 people.
In November, 1983, The Salisbury Post reported that the Mooresville office of the
North Carolina Division of Environmental Protection was investigating complaints
of unpleasant odors from neighborhoods in the vicinity of the Cedar Springs Road
Plant. The residents of Kings Forest and Stonybrook complained that the plant
was emitting odors which were bad smelling and irritating to the eyes. No odors
were found and the residents were told that even if the plant were emitting odors
it would be difficult to enforce North Carolina's air pollution control
regulation-in this instance.
On August 16, 1984, a production process at the Cedar Springs Road Plant boiled
over, releasing a vapor cloud containing acetic acid. The vapor cloud effected
vegetation up to 1.5 miles from the plant in a northeasterly direction. National
Starch was fined a total of $10,000 on February 11, 1985, by the North Carolina
Department of Natural Resources and Community Development, Division of
Environmental Management, for the unlawful discharge of a hazardous substance and
3
-------
for failing to immediately report the discharge to the Department. As reported
in The Salisbury Post, this release angered residents in the nearby Trailer City
mobile home park. Residents complained of breathing problems and peeling paint
on trucks and mobile homes. Residents were also reported to express concern
about the secrecy which surrounds the plant and lack of response by National
Starch's insurance company adjusters. Other residents were worried about effects
on children and not being able to open doors or windows or run air conditioners
for fear that the bad air would be drawn into their homes. A local resident has
filed a $2.5 million lawsuit against National Starch from this incident, charging
that the release damaged personal property and that personal injury occurred.
In a September 7, 1984 Salisbury Post article a local doctor was reported to have
diagnosed between five and ten cases of chemical bronchitis as a result of the
August 16, 1984 vapor cloud release from the National Starch Cedar Springs Road
Plant. The doctor and a North Carolina Department of Human Resources
toxicologist were quoted as stating that their investigations on health effects
were hampered by National Starch's refusal to provide proportions of the mix that
resulted in the vapor cloud release. According to The Salisbury Post, National
Starch officials were unavailable for comment.
An article appearing in the Thursday, September 6, 1984 edition of The Salisbury
Post reported that three of the monitoring wells on the National Starch site were
contaminated with unknown pollutants. The North Carolina Division of
Environmental Management was reported as having to rely on National Starch to
identify the substances found in the water samples. The article also referred
to tests conducted at a private well in the Little Acres Mobile Home Subdivision
in March 1984 in which a number of contaminants had been discovered.
Subsequent
testing of the well in June 1984 found no contaminants, leading officials to
believe that the March samples had been contaminated in the laboratory.
In October 1984, an article appearing in The Salisbury Post cited former and
current city employees' accounts that National Starch buried liquid w~ste from
its Lumber Street plant at the City of Salisbury's Town Creek and Grants Creek
wastewater treatment plants. The employees were not sure how much had been
dumped or how long the dumping lasted, but thought the dumping occurred as early
4
-------
as 1967 to 1971. Metal 55-gallon drums were also said to have been buried at the
city sites. City officials were quoted as saying they did not believe the
dumping had occurred. National Starch officials admitted that a dump existed at
its Cedar Springs Road Plant site but not at any other location. Subsequent
searching of the two treatment plant sites by both state and city agency
personnel found no €vidence of buried wastes.
In March,
1985, the National Starch site was selected for inclusion on the
proposed expansion of the National Priorities List.
The Hazard Ranking System
(HRS) score was 31.9.
The decision to include the site on the proposed list was
published on April 10, 1985, in the Federal Register. An article titled
"National Starch: the neighbor's views" appeared in The Salisbury Post on April
1, 1985. The article described mixed feelings in the communities near the plant.
Some of the residents within Kings Forest subdivision believed that National
Starch was a responsible company with an excellent record, and that National
Starch would work with the EPA and cleanup the dump. Residents of Trailer City
were concerned about the effects on their health and believed their community had
. borne the brunt of living near National Starch. The article reported that, at
least once per week, odors described as everything from rotten eggs to fish,
drifted through the park, forcing residents inside their mobile homes. Some
residents were reported as being ready to move but don't know where to move.
The lead story in The Salisbury Post on August 21, 1985. was about a chemical
explosion which injured two workers at the National Starch Cedar Springs Road
Plant. The explosion occurred as a pilot-scale manufacturing process was being
conducted.
No hazardous runoff or emissions resulted from the incident.
A local citizens group, Citizens for A Safe Environment (CASE), was organized in
August 1985, after the Clean Water Fund of North Carolina approached community
members who had expressed concerns about the site and offered to help them start
a citizens group. In a letter to the editor of The Salisbury Post published on
September 17, 1985, a spokesperson for the group stated that the objectives of
the group are to: 1) determine the current surface and well (aquifer) water
quality surrounding the National Starch Cedar Springs Road Plant; 2) get the
dumpsite cleaned up effectively and promptly; 3) express concern over National
5
-------
Starch's recent safety record; 4) encourage National Starch to display improved
communications and community relations; and 5) develop long-range environmental
awareness in the South Rowan County area.
A public meeting was held on September 4, 1985.
EPA officials, National Starch
representatives, members of CASE, and a representative of the Clean Water Fund
were in attendance, as well as about 60 residents. The Salisbury Post reported
in an article about the meeting that, "the assurances by high ranking National
Starch officials did little to dissuade the fears of the 60 residents" in
attendance. Residents were quoted as saying that National Starch was not showing
responsible safety or citizenship to the community and that National Starch had
made
the area around Airport Road a bad place
to live.
National Starch
representatives were reported as having met repeatedly with EPA officials and
stated that National Starch will cleanup the dump if the site makes the NPL.
National Starch officials also agreed to meet with the Clean Water Fund and
residents to address residents' demands.
Following the public meeting, held on September 4, 1985, CASE organized a rally
to coincide with the passage of a truck called the Times Beach Bullet through the
area,
which was carrying waste samples from Superfund sites in Belmont, Mount
Holly and Shelby to Washington, D.C. Participating in the rally were
representatives of the Sierra Club, National Campaign Against Toxic Hazards, and
the Clean Water Fund of North Carolina. The Salisbury Post reported that about
30 people attended the rally. A local resident was quoted that "a lot of people
are disappointed with the seemingly endless bureaucratic snarls that seem to be
part of this game." A petition, containing 815 signatures of residents from
southern Rowan county, asking that National Starch clean up the site, was sent
along
with
the
waste
samples.
It
was
reported
that
local
and
state
representatives,
Charlotte
Gardner
and Brad Ligon,
attended the
rally
to
demonstrate their support for CASE.
In keeping with discussion held at the public meeting of September 4, 1985,
National Starch arranged for a group of citizens to tour the National Starch
Cedar Springs Road Plant. A synopsis of the tour appeared in The Salisbury Post
on October 15, 1985. The tour was reported to have received mixed reviews from
6
-------
CASE members. Some residents stated they felt safer since National Starch had
told them things they had not been told before. Other residents were not
convinced that the toxic waste would not get into their water in the future.
National Starch did not provide information about the substances used at the
plant, claiming that such information was confidential. This approach left some
doubt in the minds Qf some residents. At the start of the tour, National Starch
refused to include a Salisbury Post reporter and a representative from the Clean
Water Fund on the grounds that the tour was for southern Rowan County residents
only. National Starch eventually relented and the Clean Water Fund
representative was allowed to take part in the tour, although the reporter was
not.
In April 1986, neighbors around the National Starch Cedar Springs Road Plant,
particularly those residi~g in Trailer City, complained of a strong odor that
made their eyes burn and caused dizziness. As reported in The SalisburvPost on
April 1, 1986, the Salisbury Fire Department received several calls about an odor
at approximately 7:15 pm on March 31, 1986. Fire officials could find nothing
at the plant, which had been closed for the Easter holiday.
In another article,
fire fighters responded to a call from a nearby resident who thought that an
explosion had occurred a the Lumber Street Plant. The fire department found
nothing, no explosion, no vapor cloud, and no fire.
The front page story in The Salisbury Post on June 25, 1986, reported that a
toxic cloud escaped from a reactor vessel at the National Starch Cedar Springs
Road Plant. Acrylic acid was releas:d to the atmosphere when a safety relief
valve opened to release the pressure that had built up in the reaction vessel.
The safety relief valve would not open and release chemicals to the atmosphere
under normal operating conditions. It is designed to open only when potentially
explosive conditions exist, as they did at the time of the accident. The
Salisbury Fire Department sealed off Cedar Springs Road at US Highway 60l/BUS 29
and Airport Road. Some nearby residents reported burning eyes, irritated lungs,
and headaches. Residents interviewed after the incident were quo~ed as saying
that it was not safe around the plant. Residents also complained about odors
during the evening hours.
7
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A representative of CASE appeared before the county commissioners on July 7,
1986. An account of this presentation appeared in The Salisbury Post on July 7,
1986. The commission was asked to study what could be done to improve safety and
communications at National Starch. As a result, the commissioners asked that the
county attorney look into the request to determine what the county could do. It
was reported that CA~E members faced a bureaucratic snarl, a lack of support from
county officials and secrecy from National Starch.
The community had maintained a high level of awareness and concern regarding
National Starch as a result of the incidents reported in the media. According
to the National Starch Operations Manager, National Starch has had to contend
with media reports that were, at times, either less than factual, or misleading.
The lack of information and the manner in which National Starch dealt with some
of the reported incidents may have contributed to the heightened awareness and
the lack of credibility that National Starch has within the community. Community
awareness appears to increase, sometimes unnecessarily, each time National Starch
has an incident.
As described by the National Starch Operations Manager. the
Cedar Springs Road Plant fire alarm at the Salisbury Fire Department is tied into
the plant sprinkler system, sounding the alarm whenever a water pressure drop is
sensed, whether or not the sprinkler system has been activated. The fire
department apparently races to the Cedar Springs Road Plant, sealing off Airport
Road and US Highway GOl/BUS 29 at Cedar Springs Road as a standard precaution.
Any citizen passing these points will, given National Starch's track record,
immediately assume the worst has occurred, namely an explosion similar to the one
which occurred at the Lumber Street Plant or a vapor cloud release as occurred
in 1984.
~ithout the release of adequate information, rumors get started and
what may have been a false alarm becomes a serious incident in the eyes of the
community.
Residents in the area also tend to monitor fire and police scanner radios.
They
have often listened to idle chatter or indecision among firemen, who were waiting
for directions from the fire chief o~ plant officials. This too, has allowed for
inaccurate information to be circulated through the community. Each case or
example cited above, although not directly related to the proposed Superfund
effort at the site, is evidence of the community involvement with National Starch
8
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and provides a basis for getting information about the Superfund Site to the
community in an effective and credible manner.
B. Community Concerns
During the public meeting held on September 4, 1985, a number of questions and
demands were presented by the citizens group CASE. The consensus of a cross
section of the community interviewed in preparing this community relations plan
was that these questions and demands were not directly addressed at the meeting.
Individuals who attended the meeting said that speakers confused many of the
residents by using technical terms that the residents did not understand. In
light of the general concern that officials were not paying attention to the
community members, the questions and demands presented by CASE at the public
meeting are summarized below:
Ouestions
1)
What has EPA found out about the groundwater on the National Starch site?
2)
Are the chemicals that are deposited in the trenches hazardous to our
(residents) health?
3)
Will Superfund be
investigation?
following
the
field
the
interested
in
site
more
4)
Is there any evidence of illegal dumping of chemicals at this time?
5)
How quickly will
investigation?
following
the
field
cleanup
procedures
begin,
6)
Will an alarm or horn be required for National Starch during explosions or
leaks? (Public use)
7)
What ~re the long-term effects on humans of the chemicals deposited in the
trenches?
8)
Considering the N.C. Department of Agriculture, Hardee's food distribution
warehouse, and 3 Guy's Grocery warehouse are near the National Starch
site, is there any possibility of contamination of public food?
9)
Will EPA suggest or require National Starch to finance and control its own
fire department on its own premises?
9
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4)
5)
6)
7)
10)
Will EPA Officials be more strict in the future on chemical dumping and
handling of such chemicals on this site?
Demands
1)
Residents' wells be checked in immediate area.
2)
Better public relations between National Starch, neighbors and surrounding
businesses.
3)
A public alarm system by National Starch to alert nearby businesses and
neighbors of an explosion or chemical leak.
Periodic checks by a qualified source of the National Starch site to
prohibit chemical violations. (Prefer some outside source)
The right to participate from the beginning to the end of the Superfund
process.
Timely notification of all steps in the Superfund process before they are
taken, with reasonable time allowed for comments and response.
Progress reports regarding onsite activity with provisions for citizen
comment.
Many of these same issues and concerns were expressed during the interviews with
local citizens. The community had mixed opinions regarding odors and safety
practices employed at the site, concerns which are not directly related to the
Superfund site. All of the residents interviewed agreed that if National Starch
(or its predecessor, Proctor Chemical) had disposed of hazardous wastes on the
site, National Starch should clean up the site.
Given previous incidents at
National Starch plants in Salisbury and the manner in which National Starch has
provided informa don to the communi ty , a maj ori ty of the communi ty members
interviewed had little confidence in National Starch's ability to clean up the
site or provide accurate information to the community. As a result, many people
stated that they would only feel confident if a third party such as EPA were
involved in overseeing National Starch efforts at the site.
Some of the specific concerns expressed by residents in the Kings. Forest
Subdivision included the observation that the creeks behind their homes which
drained the National Starch site have "funny smells" and frequently appear to
have oil slicks. Residents are afraid to let their children play in the creeks
10
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or on National Starch's property which adjoins their backyards. The possible
effects of the Superfund site on property values was also a frequently mentioned
concern. One resident suggested that property values may have been affected more
by articles in The Salisbury Post dealing with National Starch's problem than by
the fact that the subdivision is located adjacent to a Superfund site. Since the
Kings
Forest
subdivision
is
on
city
water,
concerns
about
groundwater
contamination were not as important as the odor and site access problems,
potential for explosion, and accidental releases of vapor clouds. Kings Forest
residents consider that they were "lucky" that the wind was blowing in the
opposite direction when the acetic acid cloud was released in 1984, but are
worried that next time they may not be so lucky. Most people expressed
disappointment that the Rowan County officials appear to be unwilling to help,
telling residents that it was a city, rather than county, matter.
Several residents referred to the September 4, 1985 public meeting, stating that
they had anticipated more direct response to their questions and concerns than
had been provided at the meeting. Residents felt that the meeting participants
. talked above their heads and were not addressing their questions. As a result,
a number of residents walked out of the meeting.
Another frequently expressed concern was that National Starch was covering up
something. This concern appears to stem from National Starch's public statement
about incidents at the plant, which appeared to suggest that "things were under
control" when, in many residents' view, they were not.
In addition, National
Starch has been reluctant to release information on the chemicals used and
refused to take CASE representatives inside the Cedar Springs Road Plant during
the plant tour.
Res idents in areas along Gaskey Road. in the Li t tie Acres Mobile Home Subdi vis ion
and in the trailer park on the east of U.S. Highway 601jBUS 29 shar~d many of the
same concerns as residents of Kings Forest, but because they relied on private
wells for water. groundwater contamination was a higher priority for the
citizens. Residents along Gaskey Road have a creek that drains the National
Starch property running through their property. These residents are concerned
11
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about domestic animals drinking the contaminated creek water, and have asked EPA
to sample the creek.
III .
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC MEETING
AND EPA'S RESPONSES TO THESE COMMENTS
The following is a summary of the major oral comments, concerns, and questions
raised during the public meeting on July 30, 1990 by the local residents together
with EPA's responses to these comments.
COMMENT: A local resident expressed concern regarding the resampling conducted
in the surface water system adj acent to the site. The results indicated low
levels of contamination in both surface water and sediment; however, the sampling
was conducted after Hurricane Hugo and may have been affected by excess rainfall
overflowing the runoff containment system. The resident questioned how EPA could
be certain of contaminant levels now or in the future when additional rainfall
and/or hurricanes occur.
RESPONSE:
EPA
recently
conducted
further testing or requested that the
Data submitted the week prior to the
northeastern tributary be resampled.
meeting indicated
study is required.
contamination in both surface water and sediments.
Further
COMMENT:
A local resident questioned whether the surface water sampled was
runoff from present operations at the site.
RESPONSE:
To date, EPA has received only preliminary surface water sampling
results and can not provide a definitive answer at this point in time.
COMMENT:
A local resident stated concern that the contamination levels detected
may be due to past operations or current site operations. The resident
questioned why EPA could not identify the source of contaminants and whether
testing would continue until the source was identified.
The res ident also
expressed frustration with EPA officials stating that Hurricane Hugo was used as
an excuse and the entire process was taking too long.
12
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RESPONSE: EPA recently received the preliminary sampling results. The
Supplementary Remedial Investigation Report stated that Hurricane Hugo and the
resulting runoff caused the contamination. EPA, however, was not satisfied with
this determination and requested additional sampl.ing which was completed earlier
in the month.
Although Hurricane Hugo
occurred ten months
earlier,
the
supplemental Remedi~l Investigation Report was not submitted then and the most
current data indicates that the contamination is not due to Hurricane Hugo.
Another problem exists.
COMMENT:
A local resident questioned if the contamination was caused by onsite
operations.
RESPONSE:
Onsite operations
may be the cause, but this cannot yet be confirmed.
contour map to explain where the resampling took
should provide more definitive information.
(The EPA official used the
place.)
Resampling efforts
COMMENT:
A local resident stated that samples from the runoff in the tributaries
were submitted by the resident two years ago and that "oi1 and junk" were present
in Grants Creek; yet EPA claims to have only recently discovered this.
RESPONSE:
This is not the first indication of contamination.
The Proposed Plan
specifically applies to the tributaries and the ROD for Operable Unit 1 requires
periodic monitoring until plans are made to address the contamination in the
tributary.
It is a long process and it has been two years.
~
COMMENT: A resident argued that five years had passed since the process began
and fourteen years had passed since the burying of waste was discontinued. The
resident expressed concern regarding the possibility that pollutants were present
in the runoff from the site and questioned whether citizens would have to wait
five more years to have this confirmed by EPA. The resident stated that EPA
should leave it out if they are not planning to resolve the problem.
RESPONSE: The investigation began in 1986 and the initial results indicated
certain water contamination. It was originally thought that the contamination
came from a trench area, but that was disproved. It was later thought that the
13
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contamination originated from the plant property; however, after the plant
incorporated spill control measures, surface water contamination remained. Now
EPA is uncertain of the source of contaminants and must reinvestigate.
COMMENT:
A local resident asked EPA to identify the contaminants.
RESPONSE:
EPA is addressing the soil problem and, as a whole, migration of
contaminants from the site will be stopped. . Once the extractions are completed,
the main source of contamination will not be as great a threat to the community.
The main contaminant is 1,2 dichloroethane and may be present because of residual
contamination or current plant operations; this has not been determined.
COMMENT:
A local resident asked EPA to confirm that contaminants are still
present, migration still occurs, and therefore, the problem is not solved.
RESPONSE: That is correct, the problem has not been solved. However, EPA
sampled further downstream and determined that once surface water left the site
property, it was no longer contaminated.
r
COMMENT:
A resident questioned how far down stream from the site the initial
search was conducted, and if it reached Grants Creek.
RESPONSE:
No.
In 1987, downstream sampling was conducted to Mr. Edison's house.
COMMENT:
A resident stated that their water was not tested.
RESPONSE:
Only surface water was sampled.
COMMENT:
A resident asked how many parts per million were detected.
RESPONSE: The levels were measured in parts per billion and the highes t
concentration detection was less th~n two parts per billion in surface water.
COMMENT:
A local resident expressed confusion regarding the map and asked what
the symbols meant.
14
-------
RESPONSE:
The map depicts the groundwater extraction system and was included in
the handouts to aid in answering questions.
COMMENT: A local resident questioned why EPA was unconcerned about contamination
discovered at a depth of 18 feet when area water wells reach depths of 100 feet.
RESPONSE:
The measurement of 18 feet pertained to the soil in the trench area;
not groundwater.
COMMENT:
A resident added the concern that if the soil was contaminated at 18
feet, the groundwater would also be contaminated and at an earlier meeting it was
explained that groundwater moves one foot per year. Therefore, there was concern
that contaminated water would eventually reach drinking water wells.
RESPONSE:
The measurement of one foot per year refers to lateral movement; not
vertical movement.
COMMENT:
A resident explained that the area is experiencing drought conditions
and that groundwater moves up and down.
RESPONSE:
The groundwater will be addressed in the pump and treat system.
Extraction wells will be installed within two months and are designed to capture
and contain the contaminate plume.
of contaminants in the groundwater.
The extraction design will stop the migration
There will also be an extensive monitoring
system to ensure that the extraction system works.
COMMENT:
A resident questioned whether the "No Action" alternative was intended
for soil, -while groundwater would be pumped out. The resident expressed
confusion regarding how the soil will remain the same while the groundwater is
under remediation.
RESPONSE: EPA representatives explained that the confusion resulted from the
existence of two separate operable units; Operable Unit 1 addressed contaminated
groundwater and Operable Unit 2 addressed contaminated trench area soils. In
1988, EPA proposed the groundwater extraction system to clean up Operable Unit
15
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1; contaminated groundwater. In addition to groundwater remediation. the Record
of Decision (ROD) for Operable Unit 1 required additional studies on the trench
area soils and monitoring of the northeast tributary to determine the contaminant
source. The present meeting proposes no further action on soils. The "No-
Action" Alternative will be considered along with the others. No further action
would allow natural rainfall to percolate through the soil. The pump and treat
system will actively draw waters through the contaminated soil area. All
alternatives are evaluated on nine criteria.
The groundwater remediation will
take 25 to 30 years. The groundwater pump and treat system will stop contaminant
migration, but the contaminants present will have to be addressed. Modeling of
soil flushing estimates that this alternative will require 22 years for
completion. In effect, the soils will be addressed with the groundwater pump and
treat system.
COMMENT:
A resident questioned how many years groundwater would be pumped.
RESPONSE:
Approximately 25 to 30 years.
COMMENT:
A resident questioned whether the cost described in the handout applied
to groundwater cleanup.
RESPONSE:
No, the figures provided apply only to soils.
COMMENT: A local resident questioned whether the wells were all installed and
operating and expressed confusion regarding the terminology used in the handout.
RESPONSE: Using a figure provided in the handouts, the EPA representative
identified. the locations of the monitoring wells for the original remedial
investigation.
COMMENT:
A resident asked how deep the wells are.
RESPONSE:
Some wells reach the saprolite, or soil material, and others reach the
Some locations have paired wells. The depth of the wells varies
bedrock.
because the depth of the bedrock varies.
16
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COMMENT:
A
resident
questioned
whether
all
the
wells
described
were
contaminated.
RESPONSE: The EPA representative used a diagram to explain that the wells near
the trench area were found to contain high levels of volatile organics. The
groundwater migrates toward the southwest tributary and the furthest downgradient
well revealed no contamination. The highest levels of contamination are in the
trench area; this area was identified as the source; therefore, wells will be
installed into the saprolite in the trench area. Three wells, indicated on the
diagram, will be installed in the trench area and will reach the bedrock system;
Pumping the bedrock wells will also influence the saprolite; aiding in the site
cleanup. . Additional wells will be installed into the bedrock downgradient of the
source area in order to stop migration.
Monitoring wells will be used to ensure
that the system of extraction wells is effective.
COMMENT:
A resident inquired about the monitoring well depths.
'RESPONSE: Monitoring well depths will vary depending on the depth of the
bedrock. Near the trench areas, bedrock is located at depths of' 20 to 30 feet.
In areas adjacent to the southwest tributary. bedrock is found at shallower
depths.
COMMENT:
A resident questioned if all monitoring wells were contaminated.
RESPONSE: Analytical results from the wells located in the trench areas
c'onfirmed contamination. Levels of contamination found decreased as distance
down gradient from the trench area increased. Analytical results from the
outlying down gradient wells indicated no contamination.
COMMENT: A resident expressed confusion stating that the soil was contaminated
at 18 feet, a well was contaminated at approximately 30 feet and the
contamination must continue deeper than 30 feet.
RESPONSE: During the initial investigation, various levels of contaminants were
found, depending on location of the boring. However, none of the sampling
17
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locations revealed levels as high as expected. Therefore, it was concluded that
groundwater was flushing through the soil. EPA proposes to allow this natural
flushing of the soil to continue and begin remediation efforts with the
contaminated groundwater.
COMMENT:
.
A resident stated that the proposed remedial alternative would take too
long.
RESPONSE:
Groundwater cleanup is a difficult process.
COMMENT:
The resident asked how long Alternatives 3, 4, and 5 would take.
RESPONSE:
Opinions vary on the duration of those alternatives.
However, no
matter what is done with the soil, groundwater remediation will require 2S to 30
years to complete.
COMMENT:
A local resident questioned why EPA should allow water to infiltrate
contaminated soil which then contaminates the water.
The resident questioned if
it would not be more beneficial to replace the contaminated soil with clean soil.
RESPONSE:
Despite
the
chosen
method
for
soil
remediation,
groundwater
remediation will require 2S to 30 years.
COM.'1ENT :
A local resident stated that remediation of the site would take less
time if Alternatives 3, 4, or 5 were chosen and cost should not be a factor in
the decision.
RESPONSE: - The appropriate alternative is chosen based on nine criteria for
evaluation.
Cost must be a part of the decision.
There seems to be confusion
regarding the levels of contamination detected at 18 feet.
contaminated at 18 feet, not the groundwater.
The soil was
COMMENT: A local resident questioned whether the groundwater was more
contaminated than the soil at 18 feet and why it would not be reasonable to
remove the soil.
18
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RESPONSE:
Originally the
source of contamination in the
soil was
serious.
However, now the soils have been flushed; reducing the level of contaminants so
they are no longer a threat to human health. The level of contamination detected
in the groundwater is a threat to human health, especially since there is a
possibility of groundwater consumption. Therefore, the groundwater must be
addressed and the r~mediation process will require 25 to 30 years to complete.
The contaminated soil is no longer a threat and it lies 18 feet below land
surface; further reducing the potential threat. Thirty years for groundwater
remediation is only an estimate. Remedial activities will continue until the
contaminants reach an acceptable level.
COMMENT:
A local resident questioned what the acceptable level is.
RESPONSE:
Monitoring wells are in place to allow continued examination of
contaminant levels.
Toxicologists have developed cleanup goals for the site that
determine the level at which the groundwater will be useable.
wells will be utilized until these usable levels are met.
The extraction
Using computer
modeling based on the contamination levels present, the remediation is estimated
to require 25 to 30 years. Technology is not available at the present time to
clean up the site in less time.
COMMENT:
A resident of Stonybrook questioned why no monitoring wells were
installed on the northeast side of the site.
Although groundwater was expected
to flow in the other direction, the resident expressed concern that some water
may seep to the northeast.
RESPONSE:
There are five wells located on that side of the site.
The trenches
are on a ridge that drops off more steeply toward the southwest than toward the
plant.
COMMENT:
A resident stated that there is another branch, called the southwest
tributary, that runs along Camp Road and into Grants Creek.
For several years
officials claimed that contamination was present in that tributary and another
business was blamed. There is a pond at the corner of Cedar Springs and National
19
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Starch. The pond is fed by a spring on the National Starch property.
resident questioned where the water came from.
The
RESPONSE:
EPA was unaware of the spring.
COMMENT:
The resident stated that the spring was approximately 100 feet from the
property line.
RESPONSE:
The contaminant plume migrates
in
the oppo site
direction.
The
contaminated groundwater cannot migrate to that spring.
COMMENT: A representative of National Starch spoke to help clear confusion
regarding the location of the pond and spring. He stated that the map was of
poor quality. The pond is near the new W.A. Brown facility and does not
originate from the National Starch property. The spring that feeds the pond does
not originate from National Starch property.
RESPONSE:
EPA recently studied onsi te groundwater and surface water flow.
Contamination will not flow upstream to the spring.
north along the northeast tributary.
Surface water flow is to the
COMMENT:
A resident asked EPA to clarify of the directions of groundwater and
surface water flow.
RESPONSE: Evidently, some of the surface water in the creeks originates from the
springs and flows to the north through the northeast tributary.
COMMENT:
A resident questioned whether that water had been tested.
RESPONSE: Yes, the water was sampled earlier and again this month.
obtained the preliminary results.
EPA has
COMMENT: A resident questioned what type of zoning restrictions will be placed
on the National Starch and Chemical Corporation Superfund Site and the
20
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surrounding 250 (approximately) acres.
industrial development will be allowed.
The
resident
questioned
if
only
RESPONSE:
EPA is unsure at this time.
It is National Starch's responsibility
to inform any prospective buyers that the site is a Superfund site.
part of the Consent Decree administered by a court of law.
This is a
COMMENT:
A resident and representative of National Starch stated that for all
practical purposes, nothing can be built on the site.
If a subdivision were
developed in the surrounding area, it is unlikely that the homes would sell.
Therefore, the potential development of the entire area is very restricted.
is why residents advocate complete site cleanup.
That
RESPONSE:
Comment acknowledged; no further response.
COMMENT:
A resident questioned where the contaminated water would be disposed.
RESPONSE:
The present design plans require utilization of several different
technologies to remove volatiles and metals from the water before discharging
into the publicly owned treatment works.
COMMENT:
A resident asked what the alternative plan is if the publicly owned
treatment works does not allow this type of discharge.
RESPONSE: An alternative discharge method will be determined. One option is to
obtain a discharge permit under the National Pollution Discharge Effluent.
COMMENT: _A resident argued that the state is having difficulty siting an
industrial waste incinerator. This could present obstacles to the water
treatment plan for this site.
RESPONSE:
No, that will not affect water treatment.
EPA is only looking for a
place to discharge the water.
2l
-------
COMMENT: A resident questioned whether the water would be transported to the
Salisbury Vaste Treatment Facility and how it would be treated.
RESPONSE: The water will be treated through air stripping before it leaves the
site. There are several stages in the treatment, including a precipitant phase
and a bio-remediation phase, that will remove the contamination to meet cleanup
goals.
COMMENT:
A resident questioned in what building the treatment would occur.
RESPONSE:
According to the Administrative Order Consent Decree, National Starch
is responsible.
COMMENT:
A local resident inquired about other facilities where water treatment
is in process that might serve as examples.
RESPONSE: There are groundwater treatment systems all around the country,
including two in North Carolina; the Celanese site in Shelby and the Sodyco site
in Charlotte.
7
COMMENT:
A resident asked if the referenced sites are performing the same
operation and, if so, how long have they been operating.
RESPONSE:
Yes.
The Celanese site has been in operation for at least a year and
the Sodyco operations began last montn.
COMMENT:
A resident expressed concern about the odor from the site and asked
if something could be done to solve the problem.
RESPONSE:
The soils in the trench area are too deep to produce emissions.
The
odor problem is not addressed under Superfund.
COMMENT: A resident stated that it was previously explained that groundwater,
soils and air were evaluated to determine an HRS score of 28.5. The resident
questioned if air was evaluated during the scoring process.
22
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RESPONSE: During the HRS scoring process, air quality is considered.
odors emitted from active operations cannot be addressed under CERCLA.
However,
CERCLA
Superfund was designed for abandoned areas; this site is a current operating
facility. The trench area was used for disposal prior to 1980; therefore. that
area is subject to CERCLA.
COMMENT: The resident questioned whether the ground surface pollution of the
northeast drainage system would be addressed since it is produced by current
plant operations.
RESPONSE:
Yes, it is addressed under Superfund.
COMMENT: A resident questioned whether regulations exist to address facility
design problems that allow discharge into the atmosphere and possible explosion.
That may be the source of contamination in the northeast drainage system.
I .
I
I
RESPONSE:
You have described a possible contamination source that will have to
.be investigated. The entire National Starch site is included on the Superfund
list. If current operations are responsible for surface water contamination, it
will be addressed.
,
COM11ENT:
A resident questioned whether chemicals would be released to the air
during the extraction and air stripping process and if an air discharge permit
is required.
RESPONSE: No contaminants will be released into the atmosphere. The system is
designed to contain the contaminants in compliance with the Clean Air Act.
COMMENT:
A resident commented that wells should be installed on the northeast
side and groundwater and surface water studies should be conducted every year or
every 2 1/2 years to determine whether the cleanup effort is successful.
RESPONSE:
Acknowledged comment; no further response.
23
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COMMENT:
A
resident
questioned how
location and in
chemicals
can be
detected
in high
concentrations at one
locations downstream.
lower concentrations (or absent)
in
RESPONSE: The chemicals detected were volatile organics which tend to evaporate.
The movement of the. water and the exposure to air caused them to evaporate.
COMMENT:
A resident disagreed stating that one chemical, l,2-dichlorobenzene,
will not evaporate.
RESPONSE:
The question was answered in general terms.
COMMENT:
A resident questioned whether heavy metals were detected downstream.
RESPONSE:
No.
COMMENT:
A resident questioned whether contaminants were found in the sediment
and whether they also migrate downstream.
RESPONSE:
Volatile organic compounds were found in the sediment but were not
detected downstream.
The saprolite soils in the trench area are weathered,
byproducts of the bedrock; mainly sandy, silt material. Residual organics were
detected in these soils. The water table depth in the area is greater than 20
feet; within the saprolite soils. Extraction wells will be installed within the
saprolite soils. The pumping will lower the water table and cause infiltration.
Some of the chemicals detected may reach acceptable levels within a few years;
however, others (e.g., l,2-dichloroethane) could require 20 to 30 years to reach
acceptable levels.
COMMENT:
A resident questioned whether the contaminants must migrate to the
water table before concentrations will diminish.
RESPONSE:
Yes,
contaminants wi 11
move
to the water
table and then be
transported to the extraction system.
24
-------
COMMENT:
A
resident
ques tioned how
location and in
chemicals
can be
de tec ted
in high
concentrations at one
lower
concentrations
(or absent)
in
locations downstream.
RESPONSE:
The chemi-cals detected were volatile organics which tend to evaporate.
The movement of the water and the exposure to air caused them to evaporate.
COMMENT:
A resident disagreed stating that one chemical, 1.2 chloride benzene,
will not evaporate.
RESPONSE:
The question was answered in general terms.
COMMENT:
A resident questioned whether heavy metals were detected downstream.
RESPONSE:
No.
COMMENT:
A resident questioned whether contaminants were found in the sediment
and whether they also migrate downstream.
RESPONSE: Volatile organic compounds were found in the sediment but were not
detected downstream. The saprolite soils in the trench area are weathered,
byproducts of the bedrock; mainly sandy, silt material.
Residual organics were
detected in these soils. The water table depth in the area is greater than 20
feet; within the saprolite soils. Extraction wells will be installed within the
saprolite soils.
The pumping will lower the water table and cause infiltration.
Some of the chemicals detected may reach acceptable levels
however, others (e.g., l,2-dichloroethane) could require 20
acceptable-levels.
within a few years;
to 30 years to reach
COMMENT:
A resident questioned whether the contaminants must migrate to the
water table before concentrations will diminish.
RESPONSE:
Yes,
contaminants will
move
to
the water
table and then be
transported to the extraction system.
24
-------
COMMENT:
A resident asked if the process is basically leaching.
RESPONSE:
The water will mix with the groundwater and become part of the
groundwater problem.
The contamination at this site involves subsurface soil and groundwater.
The
groundwater is the route of transport.
Therefore, natural leaching will correct
the soil contamination and the extraction system will correct the groundwater.
COMMENT:
A resident asked how much water will be pumped and whether the pumps
will run continuously.
RESPONSE:
The pumpage rate may vary.
In the beginning, monitoring will help
This site may require periodic pauses in
determine rates and operating times.
pumping to allow the system to rebound.
COMMENT:
A resident asked who will run the system and make daily decisions.
RESPONSE:
The system is automated and monitoring will be conducted regularly.
COMMENT:
A resident asked who will perform the monitoring.
RESPONSE:
National Starch is responsible for monitoring and for contacting EPA
when problems occur.
COMMENT: A resident questioned if it was possible for the water to migrate to
an underground water flow, other than the water table, and cause the
contamination to spread.
RESPONSE:
No.
The system is designed to set up a barrier and capture the
contaminated groundwater.
COMMENT:
A resident stated that the theory was understandable but expressed
concern that the groundwater may, possibly, move laterally (e. g. ,
fracture in the bedrock) and risk further spread of the contaminants.
through a
25
-------
RESPONSE: Extensive research was completed before this system became an
alternative. By studying permeability rates and direction of groundwater flow,
potential problems are anticipated. An extensive monitoring program was
developed to detect any problems that occur.
COMMENT:
A resident questioned whether extensive geological surveys and system
studies were conducted on the bedrock at the site.
RESPONSE:
Yes;
that was part of the remedial investigation and additional
studies were conducted during the design phase.
A computer code called "Rescue" was used to develop capture zones for the wells
and project a rate of extraction. The modeling illustrated that capture zones
will be present, in effect, providing a wall.
COMMENT:
A resident asked how the contaminant wall was spaced with regard to the
wells and how deep into the bedrock it reaches.
RESPONSE: It reaches less than 500 feet; the depth varies. The modeling program
used considers several common equations along with the slope of the water table.
The program produced a capture zone that covers the entire area and each
individual well. The contaminant plume is within the capture zone for the four
wells.
COMMENT:
depth.
The resident asked for a more specific estimate of the containment wall
RESPONSE: ?uring the remedial design it was determined that ,there are very few
fractures in the bedrock below 170 feet. The aquifer does not produce much water
at that depth and there is no reason to install wells below that depth;
therefore, the wells are above the 200 foot mark.
COMMENT:
A resident questioned how deep the contaminants are in the aquifer.
RESPONSE:
EPA has yet to determine the specific depth.
26
-------
COMMENT:
A resident questioned whether the contaminants would reach a depth of
185 feet if l8S-foot wells were installed.
RESPONSE:
The
contamination will
move wi th
the
groundwater
flow.
The
groundwater will flow horizontally within the more fractured interval rather than
moving downward.
~he extraction system allows for a large open area to pump
water from.
The wells will be open and contamination in the different zones will
move horizontally to the discharge area.
COMMENT:
A resident asked to clarify whether contaminants above 170 feet will
migrate down to that level for extraction.
RESPONSE:
Yes.
The saprolite and the bedrock are totally interconnected in the
trench area.
The contaminants percolate down through the saprolite, into the
water table and finally, into the bedrock.
COMMENTS:
A resident asked who National Starch hired as consultants and whether
the consultant will be in charge of monitoring.
RESPONSE:
National Starch hired International Technologies Corporation as
consultants.
They will be assisting throughout construction and monitoring
COMMENT:
A local resident stated that without the consulting engineers, the
is a public relations effort. In one year to 18 months further
meeting
restrictions may be placed on transporting wastes outside the state. The
resident expressed concerns that at that time, companies will do whatever they
want with hazardous wastes.
Five to 15 years have passed and there still seems
to be little control of the contamination at the National Starch site.
The resident added that a gentleman employed by EPA was paid $20,000 to work on
the site and decided that the wastes should be stored above the ground. However,
this method is not effective.
27
-------
RESPONSE: Industrial waste is a national problem. There are laws in effect now
and new laws passed every day to help control/remedy the problem.
COMMENT:
A resident stated that National Starch is in violation of their current
discharge permit and asked if EPA was aware of it.
RESPONSE:
No, EPA was not aware of it.
That is a state delegated program but
EPA will investigate the violation.
COMMENT:
A
resident
asked
if
the
method
of
treatment
discussed
would
dramatically increase the amount of effluent.
RESPONSE:
No.
One of the criteria is that the discharge effluent be within
compliance.
COMMENT:
A resident questioned whether
new,
more
restrictivce
regulations
enacted in the future would apply to this site.
RESPONSE:
Yes.
COMMENT:
A resident asked what authority the North Carolina Department of
Environmental Heal th and National Resources (DEHNR) has regarding discharges and
emissions at National Starch.
RESPONSE: There are many departments of the DEHNR. The Mooresville regional
office has authority over NPDES permits, discharge into creeks, air permits, etc.
The Superfund Section, part of the Division of Solid Waste Management, addresses
the past waste disposal practices at National Starch. Each group has its own
legislative and regulatory authority.
COMMENT:
A resident asked who, exactly, should be contacted regarding the site.
RESPONSE: Contact the Division of Environmental Management in Mooresville. For
Superfund issues, contact the Superfund Section. EPA will obtain a contact name
and telephone number for you.
28
-------
IV.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA' S
RESPONSE TO THESE COMMENTS
29
-------
"E' S."..
~ 1'.
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t~I~}
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4. PAO.,t.""
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-NSRB
september 28, 1990
Mrs. Joe Gainer, Jr.
24 Briarwood Terrace
Salisbury, North Carolina
28144
Subject:
National Starch & Chemical Corporation Site
salisbury, North Carolina
Dear Mrs. Gainer:
This letter is written in response to your letter received by the
Agency. I apologize for not getting back to you earlier.
Your letter identified concerns that you have about emissions that
occurred every night from the National Starch site. Unfortunately,
the Superfund Program cannot answer the questions you posed
concerning these emissions since we have no documentation concerning
the historical plant operations that would require burning. However,
a copy of your letter has been forwarded to the Air, Pesticides and
Toxics Management Division. Though your letter did not specifically
state it, I got the impression that the emissions no longer occur.
The Agency will ask National Starch whether any burning is conducted
currently and exactly what is burned.
I do realize that this letter does not provide you with the answers
you were looking for, but I will try to coordinate with personnel in
the Air Division to provide you with an additional response. Please
do not hesitate to contact me if you have any questions and/or
suggestions. My number is 404/347-7791.
;.;jSincerelY, /,-
...... 'i /'
I L~/' 'I /;/ '£'/ /v . /J. ' , c~(r---
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Barbara H. Benoy ,
Remedial Project Manager I
~ . I
Waste Management Division .,
~".-~}: :1 =,'cj'c:ea P:;Cr!'
-------
generation to disposal. The law requires we and
securc ~rocedur~ to be used ill truting.
uansportusg. stonag, ud disposing o( hazardous
substances. RCRA is designed to prevcnt new,
WlCOOUOUed hazardous waste sites.
RapoosjveDesi Summary: A summary of oral
and/ or wntteD public commcnU rcceivcd by EP A
during a commcnt period.
SUperfUDd: Thc common QaJDC used (or CERCL4..
also referred to as thc T-rust fund.
SupplemeaeaJ IUmedJa) lavesdptJoa: AdditioaaJ
field studies conduded 10 define the naturc and
extenl of contamination at a site.
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UNITED ST A TES EN VI RCNMENi AL PROTECT1CN AGENCY
REGION IV
345 COURTLAND STREET, N,E,
ATLANTA. GEORGIA 30365
4WD-NSRB
September 28, 1990
Becky Brown
Route 5, Box 131
Trinity, North Carolina
27370
Subject:
National Starch & Chemical Corporation
Salisbury, North Carolina
Dear Ms. Brown:
This letter is written in response to your phone call and letter
concerning the news article enclosed with your correspondence. Thank
you for taking the time to write and for submitting copies of the
signatures that you obtained concerning the High Rock Lake area.
Your le~~er iden~ifies concerns that you have about the discharge
from the National Starch Site located in Rowan County. The Remedial
Design, also known as RD, does provide for the final discharge of the
treated water to enter into the Wastewater Treatment Plant. This is
done after extensive treatment is conducted on site to reduce the
contamination.
The Record of Decision for the groundwater cleanup at the National
Starch site was issued in September 1988 after a formal public
comment period was held. The Administrative Record for the site is
located a~ the Rowan County Library in Salisbury. Cleanup of the
con~amination in the groundwater is essen~ial due to the use of the
groundwater aquifer for drinking water.
The State of North Carolina has
conduc~ed between the State and
from the National Starch Site.
coordinated.
suggested that a cooperative study be
EPA to evaluate the final effluent
That effort is presently being
I unde~stand that your concerns are not addressed in the manner that
you might have hoped for, but I will contact you when the coopera~ive
study between the State and EPA gets underway. Please do not
hesitate to contact me if you have any questions and/or suggestions.
I can be contacted at 404/347-7791.
Sincerely,
, ,
-1
~"'. " . ~., I
-' I ,
I ,t. ~ "
/ 'Barbara H. Benoy
)
. Remedial Project
Waste Management
. ,
'-:.... ' .
Manager
Division
P.mrea c;n M,:c'/c'ec ~ :0::"
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, The, Aaociatid Press . ,,' , ;
, :1'1, "'i",:a. ,::...~ vmg dumped 350,000 gallons I
\ '!. FederSI p!an.s to use. High'RDck ,_of .d1"",'I"A'~ into unlined i
-~Lake a€tht~i~ 'basin m' a tren~es ~~~n 19!1,and 1978, I
c~e~up of one 0( ~,~orth C~ But those plans 'for 'removing I
lina s most contamlna~ cheDll- billions of gallons of water. which
cal dum,?s are promptmg ~~nd _the EP A authorized ,in September
looks by~te ~lOcal offic~.;.1988, ~ delayed by construction
Th~";U$;.:'lli'nVU'Onmenta1,I»Pn.""1 d state d 1 ''':1 .
,~J. ,'?' ' -. .--.,-:-.",- - P aDS an an ,OC~ permlt
tect1on, ~enfY' m a..P~Ject. ~-."reviews. .!-~ ~ .'
oected.,tI~ 30 years, wanls':\o" ---~~ ,!,' - ,,'f' .. '
Cietoxify Ii Superfund me'in Ro1v- _,f ~..I1d a ~econd phase of the pro-
.an CountY by'\havU3g 200,000 ject,4~a1ing with at least 250,000
".jalloluU)Ctainted ~und water ..cubic' -~q of contamin&tec1 Soil
pum~- ~y from~rin?unifsbf ~~11 i'~t;'-state -~pro!ar:'-:-~"~'I
a. che~Ca1 plant, t:reatea !it ~e : John Ve~, the cfue.c!D~ of,t!.tih-
. "8,1~ ,~and 'P1ped.to "'a Salisbun' ,ties for Salisbury,,~~ ~~ ,the,
sewage_t. ;iJ;;.JI',\1 I' J, . EPA's plans to Dump~t:aeated.
"'Afte' -~~~~ . ;"~corlt;;;'inA~'.~-Wiif.I8' y!
...-:. " -t" ,'- J.!1:&.- 1 "1' . -d . gro.., j
urant8. ,- W . ,; . '~1ie "en ~ f~ Se te rei
P t:.~., .~::1d ... ...., '-''''''-'''1'- ,,' . \
ment. lanti'l e .water wow unmature. ,.,' :
~' .. tc>:'.~Grants C . .,~ ,.,~ EPA.has,th~~'o!1 ~,!as!i
:~d enter e n~ern,,~nd,f ~track ~t W1n be',hiid t#~eet, \
" . HiKh Rock ,..1re. ..- .. ,:. vest sald. ,"The oty has &greed.
~iF~ra1:~. i¥'; ~t fiye' : tb&"(i'fw:nt.~ ~t{~ted n-: '
, , 8Cf!8 ~~ ~~~~"nnA~ .~th~~l, ':,~r,~tJ!~Y ~ 1~ JDeet8 ~l reder~,
known ~ancer.caUhnr'co~-"'.- &1, State and ,locaI"itaridards.'!1'
. ..
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-------
The signatures listed are people that live on and around High Rock Lake
and are deeply concerned about articles stating that water from one of
North Carolina's most toxic sites is going to possibly be dumped into
the lake water. . .
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The signatures listed are people that live on and around High Rock Lake
and are deeply concerned about articles stating that water from one of
North Carolina's most toxic sites is going to possibly be dumped into '
the lake water. . CRi ,;J()kdL-J ~)f
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The signatures listed are people that live on and around High Rock Lake
and are deeply concerned about articles stating that water from one of
North Carolina's most toxic sites is going to possibly be dumped into
the lake water.
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The signatures listed are people that live on and around High Rock Lake
and are deeply concerned about articles stating that water from one of
North Carolina's most toxic sites is going to possibly be dumped into
the lake water. .
-------
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The signatures listed
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ATTACHMENT A
NATIONAL STARCH AND CHEMICAL CORPORATION SITE
PROPOSED PLAN
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,~tD sr~
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1986. These activities resulted in the i.s.suanc.e of the
fU'st ROD for tbe site.
The first ROD addreMed the remedy for the
groundwater contamination at the site. The ROD
specified that residual soil contamination in the
Lrench area be further investigated to determine
whether tbe area still could be considered a major
source of groundwater contamination. The first
ROD also required that monitoring be conducted
on tbe surface water and sediments adjacent to tbe
site. Detection of contamination in the surface
water would require a more focused study to
determine tbe source.
These rwo areas, the Lrench area and the surface
water system, are being addressed under what EP A
has termed Operable t:nit: A separate ROD is
required for each Operable Cnit.
RESULTS OF THE Sl'PPLE~E~"AL
RE~EDL~I~vCSTIGATIOS
EPA required that ~SCC conduct addjtional soils
sam rlin~ and analysis to determine the levels of
contaminants in the Lrench area, the potential
impact of the trench area on the groundwater, and
to determine the leachability of the soils in the
Lrench area. EPA also required coUection and
analysis of surface ""ater and sediment samples in
the adjacent stream to determine whether surface .
""ater was impacted. The fladings of lhese acLi..,ties
are summarized below.
Soil Quality. As directed by the first ROD,
addjtional soil samples were coDeaed in the Lrench
area and residual contamiDaUon was coaftnDed.
Significant levels of contamination was found
apprommately 18 feet below laDd surface. The oDly
route of contamination aUgratioD at this depth is
directly intO the growuiwa1er. The groundwater
remedy was selected iD 1988 (the first ROD). With
the remedial deIip completed. coasuuc:tioo On the
system begiDs Fall ol199O,
Surface Water Qualiry: Resampling was conduded
iD the surface water system adjacent to the site.
Results deteded low levels of contamiDation in boc..h
the surface water and the sediments. This sampling
was conduded immediately after the Salisbury area
was impaded by Hurricane Hugo and may be a
result o( excessive rainfall overflowing the runoff
containment system at the site. More extensive
sampling was conducted during July 1990 to obtain
CurTent data 00 the stream. Results of lh:.5
sampling effort wiD provide adequate wormation lo
determine if cootU1iDation still exists in the surhc.e
water or sedimeots. If cootamination is detected.
the sampling is designed to determine if
cootamination is from historical disposal of wastes
or if runoff from CUtTent site operations is the
prevailiDg problem. IJ1 the event that DO
cootaminatioo is deteded. the first ROD reqWrtS
that monitoring of this SLream continues 00 a
periodic: basis.
ENDANGERME~ ASSESSMENT
In the original RI report. an fDdaqermeot
asH5SIDeDt of exposure pathways was conduC1ed for
the site aDd specificaUy included the soils in the
trench area. The purpose of the asses.sment ""as to
determine prescot and future potential risks lO
public: health aDd the eDviroomeDt posed by the site.
and specifically the soils for this Operable U nn,
based on existing condjtions. EPA has conc:luded
. that the major risk to public health and the
enwooment would result from ingestion of
contaminated groundwater. This risk was addressed
in the fU'st ROD through tbe remedy selected for
groundwater. The secood operable unit will not
aff e d this see nario.
SCOPE A''D OBJECTI\-CS OF THIS
RE\fEDIAL ACTION
EPA addres.sed the immediate groundwater
problem witb the selection of the groundwater
remedy UDder the firSt Operable Unit decision to
StOp the introduc:tioD of cootaminated groundwater
into the uaaffecsed ponioD of the aquifer. The
remedial action options prcscDted in this Proposed
Plan constitute the SCCODd Operable Uai1 (or the
site.
The objccma ol Operable Unit 2 are to: ensure
that cleaDup sluclards fOt the site ue ~loped for
aU appropriate media; impiemeDt a clUDup
a1terDa~ that is prQ(ecsM o( human bealth and
the eDviroomeDl; ud select I remedy that meets
the above aiteria in a cost effective manner.
PUBLIC COMME!'(J' PERIOD
The distributioD of this Proposed Plu is required
by CERCLA. and is provided 10 explain the remedy
selectioD process and encourage participation in this
se.cond pan o( the cleanup decision. EP A IS
3
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aiteria EPA must use to 1WT0w the list down to
the final alte~ beiq considered for soil
remediation.
EP A uses the foUowing nine criteria (0 evaluate
alternatives identified La the FS. While overall
protecUon of human health and the environment is
the primary objective of the remedial aaioD., the
remedial alternati...e selected for the site must
achieve the best balance among the evaluation
aiteria considering the scope and relative degree of
contamination.
1.
Overall Protection of Human Health and the
Environment addres&e.s bow an alternative as
a whole will protect human health and the
environment This includes as assessment of
bow public bealtb and environmental risk.s are
properly eliminated. reduced. or controlled
tbroush treatment.. engineering controls or
institutional controls.
2.
Compliance with ADplicable or Relevant and
ApproDriate Requirements (ARARs)
addresses whetber or not a remedy complies
with ail state and federal environmental and
public healtb laws and requirements tbat appl~.
or are relevant and appropriate to the
conditions and cleanup options at a specific
site. If an ARAR WLQ()( be met, the analysis
of the alternative must provide the grounds for
invoking a waiver.
3.
Loni-term Effectiveness and Permaneace
refers 10 the ability of a remedy to maintain
reliable proteCtion of bWDaD health aDd the
environment over time once the cleanup goals
have been met.
4.
Reduction of To,aalV. MobililV or Volume
looks at three priDcipallDeaauremew of the
overall ~rfGl1llUCe alu aIIcnwive. Tbc
1986 amndlDotatl to the Superfwad surute
(SARA) emplwize that. wbeaevcr pos&ible,
EP A should select a remedy thai UIC$ a
treatment proce&l to perm&DeDtJy reducc the
level of toxicity of CODtamUwats at the site; the
spread of coDrJlminJinu away from the sourcc;
and the volume, or amount. of contamiutiOD
at the site.
~-------------- --~- -
s.
Shon-term Effectiveness refers to the tec.h1uQ1
and administrative f~bility or aD alternative.
Lacluding tbe availabiliry of mateNls aDd
services 'Deeded to implemenr the alrerutr.
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Incinerated materW will be analyzed prior to
replacement in disposal areas to ensure that
remediation aDd ARAR levels have been achieved.
After replacing the incinerated soils, the dIsposal
areas v.ilI be covered with topsoil aDd revegetated.
Estimated Present- Worth Costs
for excavation. onsite -incineration. disposal,
operations and maintenance: S52,l:5,CX))
Alternative 5: Excavation and Offsite Disposal
In this alternative, 250,003 cubic yards of
contaminated soil in the trench area would be
exca\iate.d and transported to a RCRA permitted
landfill for disposal.
The 250,CX)) cubic yards of contaminate soil only
addresses the soil in the u.n.saturated zone; the
contaminated soil in the !>aturated zone 'Would not
be excavated.
Estimated Present-Worth Costs
for excavation. transportation. disposal and site
restorations: S51,900,CXAJ
EPA'S R~ TIO~ALE FOR SELECT1~G THE
PREFERRED AI. TERSA TIVE
Based on current information and analysis of the
RI/FS reports., and the original and supplemental
investigatioo.s, EP A believes that the preferred
alternati..'e, Alternative I, Natural Soil Flushing (So
Further Action), for the NSCC site is consistent
with the requirements o{ the Superfund law and its
amendmen~ specifically Section U1 of CERClA
and the Nadonal CondDgeDcy Plan (NCP). All of
the alternatives preseDted in this Proposed Plao
would provide overall protectioo of human health
and the enviroameDt, indudiq the No Further
Action alterna1iYe. III EPA's aaaJysis. the No
Further Actiocl aIIauIi¥e would .Weft . MI.~
of the o.iDe sclecUoG criteria. The soils in the
trench area cao 0GIy coatn"bute contamination to
the groundwater. Grouadwater remediation bas
been decided; the desigD stage bas been completed.
construction of the pump and treat system will start
in the Fall of 1990. Remediation of groundwater
takes many years to achieve the cleanup levels as
defmed by existing environmental laws. The No
Further Action alternative works in conjunction with
the pump and treat system in a passive manner
without impacting either the schedule Of the costs of
tbe remedial aCtion at the site. A1J.y Other
alternative selection wouJd introduce concerns
including delays in the groundwater remediation.
additionaJ costs, waste handling. coastructioa and
implementation problems. The prefefTed
aJternative, Natural Soil flushing: 1) provides short-
and long-term protection of bumaD health and tbe
environment, 2) will attain Federal and state
applicable and appropriate public health and
environmental requirements (ARARs), and 3)
utilizes a permanent solution to the maximum
eXtent practicable.
GlossarY
Adminlstradve Order or Consent: A legal
agreement beC'W'een EP A and the potentially
responsible parties (PRPs) whereby the PRPs agree
to perform or pay the cost of a site cleanup. The
agreement desaibes actions to be taken at a site
and may be subje.ct to a public comment period.
AdmiDistrat.ive Record: A rue wl:Ucb is maintained
and contains all information used by the lead agency
to make its decision on the selection of a response
action under CERCLA. This rue is required to be
available for public revie'W' and a copy is £0 be
established at or near tbe site, usually at an
information repository. A duplicate file is
maintained in a central location, such as a regional
EPA and/or state office.
Aquifer: AD underground rock formation composed
of material such as sand. soil. and/or gravel that
cao store and supply groundwater to wells and
springs.
Blod....datJoa: Tbe breakdown aDd remOYa.l of
contamiauu by the use of aatuta1Jy ocauriDg
miaobial activities found in subsurface soils.
Comprebuslve EnvlronlDutal RespoDse,
Compensadon, and UablUty Ad (CERCLA): A
federal law passed in 1980 and modified in 1986 by
tbe Superfund Amendments aDd Reautborization
ACt. The Acts created a special tax thai goes into
a trust fund. commoaly mowo as Superfund. to
investigate and cleanup abandoned or uncontrolled
buardous waste sites. Under the program, EP A
can either pay for site cleanup wben the responsible
panies CaDDot be located or are unwilling or unable
7
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generation to disposal Tbe law requires safe and
secure proc:.edure& to be used in tr~ting.
transporting. storia& aod disposing o( bazardous
substances. RCRA is designed to prevent new,
uncontroUed hazardous waste sites.
ResponsiveDesi Summary. A summary o( oral
and/or written public comments received by EPA
during a comment period.
Superfund: The common name used (or CERClA,
also referred to as the Trust Fund.
Supplemental Remedial IDftStlgatJOD: Additional
field studies conducted to define the nature and
extent of contamination at a sileo
9
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ATTACHMENT B
NATIONAL STARCH AND CHEMICAL CORPORATION SITE
PUBLIC MEETING SIGN IN SHEETS
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National Starch' Chemical corporation site
PUblic Meetinq siqn In Sheet
July 30, 1990 .
Name
Telephone
Number
Do you want to
be included on
the mailing list?
Address
Affiliation
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How did you
learn about
this meeting?
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5./.~ry
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National Starch' Chemical Corporation site
PUblic Meeting sign In Sheet
July 3Q, 1990
Name
Tl'lephone
Number
Do you want to
ue included on
the mailing list?
Address
Affiliation
Wll.~ '
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ATTACHMENT C
NAMES, ADDRESSES AND TELEPHONE NUMBERS
OF THE INFORMATION REPOSITORY DESIGNATED FOR
THE NATIONAL STARCH AND CHEMICAL CORPORATION SITE
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ATTACHMENT C
1.
Rowan County Public Library
201 West Fisher Street
Salisbury. North Carolina 28144
. Contact: Jennifer Carpenter
(704) 638-3000
2.
EPA Record Center
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 347-0506
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ATTACHMENT D
THE OFFICIAL TRANSCRIPT OF THE PUBLIC INFORMATION MEETING
ON THE PROPOSED PLAN FOR CLEANUP
OF THE NATIONAL STARCH AND CHEMICAL CORPORATION SUPERFUND SITE
LOCATED IN SALISBURY, NORTH CAROLINA
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UNITED STATES ENVIRONMENTAL PROTECTION AGE~CY
2
REGION IV
3
4
5
6
7
PUBLIC INFORMATION MEETING
8
National Starch and Chemical Corporation
9
Superfund Site
10
July 30, 1990
11
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Salisbury Civic Center
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Salisbury, North Carolina
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Julia W. Biggers
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Official Court Reporter
25
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2
AGE N D A
2
3
INTRODUCTION AND WELCOME
4
SUPERFUND PROCESS OVERVIEW AND SITE STATUS
5
SITE BACKGROUND AND REMEDIAL INVESTIGATION SUMMARY
6
FEASIBILITY STUDY RESULTS
EPA'S RECOMMENDED ALTERNATIVE
7
COMMUNITY RELATIONS
8
QUESTION ~~D ANSWER SESSION
9
10 I
PARTICIPANTS:
11
Elma Akin
12
Gizelle Bennett
13
Barbara Benoy
14
Jack Butler
15
Joe Claypoole
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16 son)
Messrs. Edison (father and
17
Michael Henderson
18
Vernon Jones
19
Bruce Kolkebeck
20
R-ich Muza
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Ray Paradowski
22
Don Pruitt
23
Mike Sturdivant
24
Alfred Wilson
25
Local Citizens
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July 30, 1990, 7:00 P.M.
2
MS. BENOY:
I guess we can go ahead and get started.
3
I'm not used to a mike.
I can project usually pretty well.
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Good evening and welcome.
Good evening.
(Microphone Diffi-
culties) My name is Barbara Benoy, and I am current Remedial
6
Projects Manager for the National Starch si te here in Salisbu!'::'
7
I am am employee of the Environmental Protection Agency, and
8
I'd like to thank you for coming out to tonight's meeting.
9
The last public meeting that was held was held here in 1988
10
when the groundwater extraction system for the cleanup of
11
groundwater at the site was proposed and then approved.
It
12
was also decided at that point in time that further investi-
13
gation of the soils in the trench area needed to be done.
14 ,
I
The more extensive sampling was done under a separate remedial
15
investigation, and in order for us to do that, we broke the
16
site into operable units.
And I'll discuss that a little
17
bit further.
Operable Unit 1 addressed the groundwater con-
18
tamination and the remediation of that groundwater plume.
19
It also required periodic monitoring of the surface water
- system and the sediment, specifically the northeastern tribu-I
tary. Operable Unit 2 focused mainly on the trench area SOil~,
and the purpose of tonight's meeting is to present the find- i
ings of the trench area investigation and to propose to
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cleanlp
the community, a proposed plan for the remediation, the
of that area.
This meeting also initiates the first day of
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much covered that; the Su~erfund process,
we're ,?oin~ to
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talk about what that process is, where we are with the ~a~io~al
3
Starch site; some site history, some of which I will
co'.'er
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as a site-wide basis; and then I'll really elaborate on this
Operable Unit, this trench area, the results of the remedial
6
investigation and feasibility study for that trench area.
7
Then we will propose the EPA Proposed Plan and discuss the
8
EPA Proposed Plan, and then community relations will be dis-
9
cussed.
Then at
Michael Henderson will be presenting that.
,
I
that point in time, we do reach the question and answer perioo,
and that is the main focus of tonight's meeting.
I will try
to keep my presentation short and brief so that we can use
some of the time for your questions, and hopefully answer
all of your questions.
Comments may be submitted to us to-
night but also may be submitted to us in writing anytime
between now and August 29, 1990, which is the end of the 30-
day comment period.
There should be comment cards.
Are comm r:
cards available?
We have self-addressed stamped envelopes ou
on the table.
Please feel free to take them to submit commen s
to us.
You may think of something later on.
Please use this
opportunity to submit them to us.
Any comment that you have,
whether it's on the Proposed Plan or whether it's on any of
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the alternatives presented in the feasibility study, which is\
one of the documents located or included in the administrativ~
!
It's not just for the Proposec
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record, any comment is welcome.
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Plan, but any comment that you have, any concern.
Please
2
feel free to bring it to our attention.
if you will,
And now,
3
I have several people that are available tonight that will
4 I
be answering your questions, and I need to introduce them
5
.
at this time.
If you would, please stand when I call your
6
Michael Henderson.
name.
Michael is Community Relations
7
Coordinator with EPA for this site.
Michael has been here
8
at other public meetings.
You may already know him, have met
9
him.
Elma Akin.
Elma is with our Health Assessment Office,
10
also in Region
4 EPA Office.
Ms. Gizelle Bennett.
Gizelle'
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11
was the previous Remedial Project Manager for this site.
12
She is now my current supervisor.
She's here also as the
13
historian for the site activities.
Rich Mu..:a
Rich Muza.
14
is from our Groundwater Division, our Groundwater Technology
15
Unit of our Water Division, also an EPA employee.
Rich has
16
been involved with the review and the project for quite some
17
time.
Mr. Joe Claypoole.
Joe Claypoole is an employee of
CDMFPC.
That's a contractor to the EPA.
We are required
to have third-party oversight when the potentially responsibl
party conducts activities at the site.
It is to ensure that
EPA's protocol, procedures, the workplan that was approved,
that all of our requirements are adhered to.
Also with us
I
tonight is Mr. Jack Butler from the North Carolina Department
of Environmental Health and Natural Resources, and we would
like to thank you for corning tonight, Mr. Butler.
In 1980,
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Congress passed the Comprehensive Environmental Response
2
Compensation and Liability Act, known as CERCLA.
The act 'Nas
3
passed to deal with some of the hazardous waste sites that had
4
come into existence in this nation.
The law is also comrnonly.
5
known fiS Superfund.
This law requires the EPA to determine
6
the nature and the extent of contamination at the Superfund
7
When Superfund was reauthorized in 1986 by the Superfund
site.
8
Amendment and Reauthorization Act, known as SARA, stringent
9
i
A site can be discovered
cleanup requirements were also added.
10
in a number of ways, but usually what happens is the State
11
brings it to EPA's attention, and at that time, either the
12
State or the EPA conducts an investigation, site inspection
13
or preliminary assessment to determine if the site is in
14
fact eligible for the Superfund.
I usually have a slide.
I' ;1
15 I
I
sorry I don't have it tonight.
It would help in the explana-
16
tion.
After a preliminary assessment or site inspection is
17
conducted, data is gathered and subjected to what we call a
18
hazard ranking system, or HRS.
It's a numerical system, and
19
a score is derived.
We look at the groundwater, we look at
-surface water, and we look at air.
We look at whether or not
the water is consumed.
We also look at the environmental
factors. Any score above 28.5 makes the site eligible for i
proposal for the National Priorities List, known as EPL. j
Now, I know I use a lot of acronyms of the alphabet, so pleas,
if I need to remind you or explain what something means, plea e
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13
14
15
16
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18
19
20
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your acceptance and YOur comments.
9
All the comments from the
2
State, from the community, from the environmental data, othe=
3
environmental laws, these are all taken into accOunt in the
4
selection of the alternatives, and then the final selection
5
is contained in EPA's Record of Decision, or ROD.
The ROO
6
is then submitted to the EPA Regional Administrator for
appro~
7
val.
After approval, the EPA may then again enter into
8
I
negotiations with PRPs for them to conduct the remedial design,
9
RO, and the remedial action, RA -- known as RD, RA.
The RO
10
is the engineering plan, the design, the location, the speci-
1 J
fications, the actual plan, the writing of what the cleanup
is going to require.
The RA, the remedial action, is the
actual implementation of that cleanup.
And then only after
the remedial action, the cleanup, has been Completed can a
site be taken off of the National Priorities List.
And no'...'
for some site background.
The National Starch and Chemical
Corporation site is located just outside the Salisbury City
Limits along Cedar Springs Road.
In 1938, Edward Proctor
founded Proctor Chemical Compnay.
In 1968, thirty years late,
he eurchased a large tract of land, approximately 400 acres,
along Cedar Springs Road.
In 1969, the company was purchased
by National Starch and operated as a separate sUbsidiary.
In 1970, construction of the Cedar Springs Road Plan began.
In 1983, Proctor Chemical Company dissolved, and the opera-
tions were merged with National Starch, the overall company.
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9
10
11
12
13 I
14 ,
15 II
16
17
18
19
20
21
22
23
24
25
10
National Starch Chemical Corporation site -- I didn't say
2
that right; I'm
produci::.
is currently in operation,
sorry --
3
textile finishing products and specialty chemicals.
Durin.g
4
the period from 1971 to 1978, washwaters were disposed of i::
5
trenches in the western area of the site.
These washwaters
6
amounted to approximately 350,000 gailons and consisted of
7
salt brine, sulfuric acid solutions and solvents.
The trend"
area is about five acres and is made up of trenches which
were
200 to 300 feet long and approximately eight feet deep.
Disposal of the washwaters continued in a trench until the
water no longer readily percolated into the ground.
In 1976,
National Starch determined groundwater contamination in the
surficial aquifer, or the surface aquifer.
In 1977, North
Carolina confirmed those results.
In 1985, National Starch
was proposed to the ~ational Priorities List.
In 1986, EPA
and National Starch signed a consent order to allow them to
conduct the remedial investigation and feasibility study.
And in 1988, the first ROD, Operable Unit 1, for the ground- l
water contamination was signed. Since that time, the remedia
I
I
design of the groundwater system has been finalized, and
construction of the pumping treatment system is scheduled
to begin fall of this year.
I
Your handout is not necessarily ~
in order.
If you notice, the trench area is west of the
building or the site plan area.
You will notice also on t
.separate figure -- maybe this is the one we should -- the
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II
11
bore hole location in the trench area.
For my presentation
2
I'm going to be very general, and there will be more in:or~~-
3
tion, more specific information, provided or available whe~
4 I
we go to our question and ans~er period.
Based on the
5
.
results of the remedial investigation in the trench area,
6
contamination, visual contamination in the soils, was found,
7
but not at the concentrations that we had originally antic i-
8
It was much lower contamination levels.
pated.
The majority
9
,
of the site contamination in this area is found approximately'
18 feet below the land surface, which again is not a direct
hazard, a direct contact hazard.
It's very far, very deep
below the ground surface; and that is a major factor in how
we look at the decision for a cleanup plan.
Again, there
was residual contamination, but at concentrations lower than
what we anticipated. In fact, we have seen some concentratiots
in the groundwaters that are higher than those we found in th'
soils.
I need one of these fact sheets.
As I said when
I was discussing the Superfund process, we take different
technologies and we look at what's available, we look at the
media that's contaminated, and for Operable Unit 1, we made
a decision on the groundwater, and that design has been
implemented, and again the construction should begin this year.
50 for this particular Operable Unit, we were only looking
at the soils.
So we already had an idea of what technology
sheet, on Page 6 t-
I
I
to look at.
If you take a look at the fact
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Page 5 and Page 6 -- some of the alternatives, some of the
2
technologies that were looked at, are written and presented.
3
For soils, you can look at soil cleaning treatments, soil
4
flushing, soil washing; you can look at containment, which is
5 I
capping, or even containment which is not just a cap but a
6
diversion system -- not diversion system -- let me see if
7
I can explain.
Not just a cap, but also in the ground itsel::
8
to keep the soils from migrating any further.
You take those'
9
technologies and you apply them to the site, and you come up i
with a site-specific recommendation.
EPA's Preferred Plan
for this particular Operable Unit is, if you have read the
fact sheet and no further action, based on the fact the soil
contamination was not as high as we anticipated, based on t
fact that the soils, the contamination found in the soils, ~=S
found at approximately 18 feet below the ground
surface, the:
I
that the grou:-.4-
most significant levels, and based on the fact
water pump and treat .will address those soils, EPA has
considered that the No Further Action alternative meets the
balance of the criteria that we must look at.
The ground-
water pump and treat extracts the groundwater and essentially
allows the natural water to flush the soils.
The nine criter a
I
that we're required to look at are the overall protection of i
the human health and environment; compliance with ARARs,
which are the applicable or relevant and appropriate requi-
!
ments, any environmental statutes, Clean Water Act, any state
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laws; the long-term effectiveness and permanence; the reduction
of toxicity, mobility and volume;
short-term effectiveness;
implementability, cost, which did playa large part in this;
state acceptance; and community acce~tance.
The other alte=-'
natives that were proposed or were looked at and developed
also had problems with them, such as excavation.
Tr.e proble::".$
that we have to deal with when we dig up soils, we may then, I
in fact, in the transportation of them and the finding of
places to locate them -- it's not only costly but it also
poses other hazards.
The fact that they're 18 feet below
the land surface, the cost of excavation, the cost of either
disposal or incineration, also plays into the decision-making
process.
There is some more information on the facts in the
fact sheet about the proposed land.
And now I will turn it
over to Michael Henderson.
I want to go ahead and allow the!
,
questions that you have to be the major part of our presen-
tation.
MR. HENDERSON:
As Barbara said, my name is Michael
Henderson, and I'm going to keep mine brief, too, because
this is basically your meeting, to hear your comments and
your concerns about the proposed remedies we have for Nationat
Starch. Basically, when EPA talks about community relations,!
I
I
I
community know what's going oni but we're also talking about I
!
I
we're talking about a two-way street.
We're talking about
EPA presenting information to the community and letting the
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receiving information from the community, because as it
2
stands now, our region -- we CO\Oer eight states from KentucL.:
3
to Mississippi -- is about a thousand employees but we have
4
no district office.
We work basically out of Atlanta.
So
5
we need your input from the community to know what's going
6
on in this state and what you know about the history of the
7
state.
So it's a give and take situation.
You give us
8
information; we give you information.
And we work together
9
to make it work for everybody.
,
,
is when we;
I
,
r
The idea behind it
10
corne out to deal with community relations at a site, the
11
first thing we do is what we call a Community Relations
12
Plan.
The idea is to have our contractors corne out, or, if
13
we don't have contracting monies, someone from our staff will
14
corne out, and we go and talk to the community~ those people
15
who live, say, a mile to three miles from a site.
We find
16
out about what are their economic concerns, what are some of
17
their environmental concerns, what are some of their health
18
concerns.
We use this information to develop a plan to say:
19
How will we address these concerns during the remedial proces
Or during the studies and our cleanup?
We use this to say:
Well, maybe these people need to have a public meeting --
for example, like the meeting we have today.
I
Or there may be I
a need for a situation where we need a facts sheet to be
sent out to you in the mail.
Or we may say we need to go
get a press release and put it in a newspaper or a public not'ce.
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15
We also sometimes use what we call availability sessions in
2
which ~e'll have situations where we'll set up in a library
3
and the community can come and talk to us on a one-on-one
4
basis.
We do use this type of thing.
We have also someti~es
5
gone aoor-to-door talking to the community or sitting down in
6
people's homes -- whatever we think is basically needed to
7
make sure that the community is informed of what's going on,
8
and that we are informed of what their concerns are.
9
We have what we call, as Barbara stated earlier, the informa-
10
tion repository.
The idea behind this is to take sample
11
results, information from meetings such as this, and any other
12
general information about EPA, and place it in a local situa-
13
tion in your community where you don't always have to call
EPA or write EPA for information.
As stated earlier, the
administrative record, which basically details everything
which we've done up to this point to come to that conclusion
and make that public decision, is placed there.
General
information about EPA is placed in the information repository
We are at the stage now at the end of the feasibility stage
where we do have the required public comments period, which
is from July 30 to August 30 -- August 29, I'm sorry -- a
public comments period.
I
you get to the;
I
I
,
I
I
I
I
The next stage, when
remedial design stage, there is a requirement also that we
do a remedial design fact sheet to make sure that you're
aware that this was the proposal we've accepted, this is
the I
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16
design, and you have an option to look at that and see
2
exactly what we're going to be doing.
You will be kept in-
3
formed during the entire process, all the way through the
4
remedial act and all the way through the time when it's
5
finally deleted from the National Priorities List.
We have
6
to keep you informed, one way or the other, as to what's
7
going on.
I caution you as citizens to use it.
If you've
8
got a concern, if you've got a question, use it.
Your tax
9
money pays our salaries, so make us earn it.
The only thing
10
I caution you about me is that you may not like the answer
11
that I'll give you.
You may not
I will find you an answer.
12
necessarily like it, but I will tell you the truth to the be~
13 I
14
of my ability.
One of the interesting programs that has
developed in community relations in the last couple of years
15
is a program called TAG.
It's a technical assistance grants
16
program.
What this program does is it allows a community
17
group to apply for a grant up to $50,000.00 to hire their own
18
technical consultant to interpret what EPA does.
Educational
entities, governmental entities, they're not allowed to apply
~or these grants.
National environmental groups can't.
It
has to be a local group.
One of the things about this is tha
you may get three or four groups to apply for it in a cornrnuni1Y
and we say we first try to get those groups to work together
to consolidate as one, because only one group can get the
grant.
If not, then we have to evaluate all four or all five
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17
however many apply, and then we can only take one.
There is
2
a 20 percent matching fee for this grant, but this 20 percent
3
matching fee can be done in kind.
It does not have to be 20
4
percent of the total money.
For example, if you have a lawyer
5
who ded1cates 20 hours to you and charges you $100.00 an hour,
6
Well, okay, I have $2,000.00 of in kind fees.
you say:
Or
7
somebody dedicates
free secretarial services for you.
You
8
can use all this to total up to that 20 percent.
One of the
9
other things to be aware of in this grant is that it's paid
10
after the fact.
In other words, you will hire somebody and
11
you ~rk during the quarter, and then you submit the bill to
12
EPA and we in turn give you the money to pay the bills off.
13
This is one of the things you have to look at.
If anyone is
interested in finding out more about the technical assistance
15
grant, you should call or write Denis~, D-e-n-i-s-e, Bland,
B-I-a-n-d.
She's a Technical Assistance Grant Specialist
for Region 4 in Atlanta, and that's 345 Cortland Street North
eas~, Atlant~, Georgia 30365.
This is basically just a quick
nutshell.
I will get around to answer any questions anybody
has about our community relations.
Thank you.
Back to you,
Barbara.
t-iS. BENOY:
At this point in time, we're opening
up for questions if you want to.
It's up to you.
How do you
want to do it?
Would you like me to -- okay.
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We've ham other rains since then.
Sounds like to me that
2
in the lain specter, it may be, with their operations right
3
now, it xould be historical or waste runoff from the current
4
site opeJra tions.
in the report,
If you raise that specter
5
why don't you have the results here?
6
MS. BENOY:
I --
7
UNIDENTIFIED SPEAKER:
In other words, you're going:
8
to test it until you get the right answer?
9
No, sir.
The question is two-fold, I
MS. BENOY:
10
think.
The first question is why donlt we have the results
11
tonight --
12
UNIDENTIFIED SPEAKER:
Yes.
13
MS. BENOY:
-- and EPA has just recently received
14
those results.
We received them last week.
They are still
15
prelimi~ary results.
I apologize.
That was part of what I
16
was supposed to present.
My notes --
17
UNIDENTIFIED SPEAKER:
Welve waited two years to get
18
an ans~r, and then you come up a week before and say:
19
Uh-oh, we're going to use Hugo as an excuse.
20
MS. BENOY:
No, sir.
Ilm trying to find a figure
21
NO, sir, it is not an excuse.
It was
to help out here.
22
presented in the supplementary remedial investigation that
23
I
I
I
the site caused the contamina-
I
I
That is not good enough. yo!
,
I
it was believed -- this was presented to the agency -- that
24
Hurricane Hugo and the runoff at
25
tion.
EPA responded by saying:
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must go resample.
The resampling was done earlier this ~o~t
2
Joe Claypoole was there when it was done, oversaw the activit~,
3
and the results came in last week.
J
UNIDENTIFIED SPEAKER:
Hugo was last September.
5
MS. BENOY:
Yes, sir.
6
UNIDENTIFIED SPEAKER:
That's ten months.
7
MS. BENOY:
The remedial investigation was not turned
8
l.n l.n September, but yes, sir,' I understand.
This does gl.ve
9
us the most current data though.
It i
It gives us an answer.
10
We can acknowledge that.
There is
was not Hurricane Hugo.
11
a problem.
12
UNIDENTIFIED SPEAKER:
From their on-site operationc
13
Is that what you're saying?
14
MS. BENOY:
I can't confirm that.
I can't say defini-
15
That may be the cause.
There may be historical
tively.
16
contamination.
That's what this study was designed for.
17
Their contour map, the contour lines also on this figure, if
18
you look, here's the National Starch site itself, and where
19
SW-ll, SW-l2, this flows this way through the site.
If you
20
notice these three bars, the bars with the three dots, surfac
water samples, sediment samples, and bank soil samples were
definitive infor- I
\
collected.
Hopefully it will give us more
mation.
We took samples from upstream and then from down-
stream locations, and we focused on this area right here.
'And it should give us enough information.
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UNIDENTIFIED SPEAKE~:
Two years ago I brought
2
samples in here that showed them everyone of the samples
3
that I had taken where there was runoff in tributaries, and
~ ,I
I
everyone was -- ha, ha, ha.
Now, you know, two years late~
5
you sa~ you just found it.
6
MS. BENOY:
No, sir.
7
UNIDENTIFIED SPEAKER:
and all kinds
There was oil
8
of junk in that tributary, Grants Creek, the place where --
9
MS. BENOY:
Yes, sir.
10
UNIDENTIFIED SPEAKER:
From the runoff.
11
MS. BENOY:
I don't mean to indicate that this is
12
the first indication.
Specifically, our proposed plan is
13 I
dealing with the tributaries.
The first ROD of Operable
Unit I continues to call for periodic monitoring until we
make definitive plans of how to deal with contamination in
the tributary.
Unfortunately, it is a very long process.
I agree it has been two years and we're still --
UNIDENTIFIED SPEAKER:
It has been five years since
we started this, and it has been fifteen years -- fourteen
years -- since they stopped burying the waste.
You know,
this is just -- and then you corne in here tonight and say tha
I
I
they may be letting pollutants and contamination run off thei~
!
site; and, you know, do we expect to wait five more years to
hear that?
Because that's going in Grants Creek.
MS. BENNETT:
Barbara, let me say something to that.
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UNIDENTIFIED SPEAKER:
You might as well have left
2
it out if you're not going to do anything about it.
3
MS. BENNETT:
Well, as you may know, we started this
4
investigation back in '86, and the initial result of that
5
sampling did show certain water contaminated.
We originally
6
thought it was coming from a trench area.
Later we found it
7
wasn't.
We originally thought it was run off from the plant
8
property, but the plant was put into spill ocntrol, or what-
9
and we thought that that had eliminated it.
But we
ever,
10
still are seeing surface water contamination, and we have to
11
try to find out where it's coming from.
Right now we don't
12
know.
That's why, since this latest sampling has shown
13
additional contamination, we have to go back, and we're gOlf J
14
to have to find out where that is.
15
What other contamination?
UNIDENTIFIED SPEAKER:
16
But in the meantime, we are still
MS. BENNETT:
17
doing something about it.
UNIDENTIFIED SPEAKER:
What are the contaminants?
19
MS. BENNETT:
We are still doing something about
the soil.
Barbara can tell you what the contaminants were
that we found.
But if you look at the site as a whole, we
I
are stopping migration of the main source of the contaminatioi
from the site. Once we get the extractions over, it should I
start calming down, and that would be what we would considet
a main source of the contamination and threat to the people il
I
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19
20
21
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.
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23
24
25
the area.
2
UNIDENTIFIED SPEAKER:
23
The main contaminant now
3
seen is 1, 2 dychloride, 2~d tha~'s --
4
UNIDENTIFIED SPEAKER:
5
louder?
I couldn't hear you.
6
UNIDENTIFIED SPEAKER:
Could you say that a little
The main contaminant that they
7
saw during the last sampling was 1, 2 dychloride.
That could;
8
have been from the residual contamination.
It doesn't neces-,
9
sarily mean it's coming from the plant right now.
We're stili
10
looking at the data.
11
UNIDENTIFIED SPEAKER:
12
there, still movement --
13
UNIDENTIFIED SPEAKER:
'UNIDENTIFIED SPEAKER:
But if there's still something
Right.
-- whether it's from the
present operation or whether it's past operations --
UNIDENTIFIED SPEAKER:
UNIDENTIFIED SPEAKER:
solved.
That's correct.
-- the problem hasn't been
MS. AKIN:
Well, that is corr~ct that the probleM
hasn't been solved, but what we did do is EPA went out and
sampled further downstream, and we found that once the surfac
water left the site property, it was no longer contaminated.
UNIDENTIFIED SPEAKER:
The initial search on the
lot or property, how far down to the site are we talking abou ?
Did it make it to Grants Creek or --
-------
24
~S. AKIN:
No, we sampled riqht on down there
2
the stream, specifically where Mr. Edison has pointed out
3
behind his house.
: I
C~IDENTIFIED SPEAKER:
Is that off --
(Several people speaking at one time)
6
MS. AKIN:
And when EPA came out to sample,
that was
7
about
'87, maybe?
8
UNIDENTIFIED SPEAKER:
Didn't test us.
9
MS. AKIN:
They sampled the surface water.
10
UNIDENTIFIED SPEAKER:
How many parts per million
11 "
are we talking about?
12
13 I here.
14 'I
15
t-1S. AKIN:
We're talking about parts per billion
(Several people speaking at one time)
MR. MUZA:
Okay, the highest concentration found
..
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16
was less than two parts per million in the surface water.
~
17
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Nothing left the site.
All samples were taken.
18
UNIDENTIFIED SPEAKER:
I don't understand this map.
>
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19
I wish you could explain it a little better, the numbers and
20
I don't know what it's about.
o
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1/1
MS. BENOY:
This is the
groundwater extraction systet,
I
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21
22
and the reason I brought this map was because I anticipated
23
questions.
24
MR. MUZA:
Why don't you put that other one
25
up there because it has the little --
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2S
UNIDENTIFIED SPEAKER:
If you want groundwater
2
questi~, I've got one.
I want to know how come you're
3
knockint off of doing anything about it because it's 18
4
feet dQW;l?
Groundwater goes
Our wells are 100 feet deep.
5
down.
~en we had the meeting here several years ago, they
6
assured ns that groundwater only fell one foot a year.
By
7
Jove, tins has gone faster than that.
Eighteen feet down is
8
I'm not even going to live before that
a prettc good piece.
9
danger is striking my well.
10
MS. BENOY:
The eighteen feet that I was discussing
11
earlier is the soil in the trench area.
12
UNIDENTIFIED SPEAKER:
It still goes in the ground-
13 i
water.
Okay, now, you said 18 feet down, you weren't so
14
concerned about that water, and the groundwater's down 18 feet.
15
MS. BENOY:
No, that's the soils, the residual con- !
I
16
tamination in the soil.
17
UNIDENTIFIED SPEAKER:
That still went down, didn't
18
it?
19
MS. BENOY:
Yes, ma'am.
UNIDENTIFIED SPEAKER:
If it's down there in the
soil, i~'s going to be in the groundwater, too.
MS. BENNETT:
The one foot, or whatever it is that
you sa~, that refers to the movement of the groundwater
laterally, not vertically.
UNIDENTIFIED SPEAKER:
Well, you know, we're going
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through a drought through here.
Groundwater is up and down.
2
MS. BENNETT:
Yes, it is, but the qroundwater itsel:
3
is going to be addressed in the pumping and treat system that i
4
we have. Those extraction wells will be going in within the!
I
!
next two months. So that will go ahead -- that will mitigate I
5
6
your concern about the groundwater migrating toward your well~
7
MS. BENOY:
That groundwater extraction system was
8
designed to capture, to stop movement of the contaminate
9
plume,
to contain it.
It will stop the migration of the
10
contaminants in the groundwater.
11
UNIDENTIFIED SPEAKER:
You're sure that's the design--
12
MS. BENOY:
We also have --
13
I like that word design.
UNIDENTIFIED SPEAKER:
I
14
can understand that one.
15
MS. BENOY:
There's also a monitoring -- an extensiv
16
monitoring system -- to ensure that the groundwater extraction
17
system works.
Yes, sir?
18
UNIDENTIFIED SPEAKER:
Your no further action is for
19
the soil itself?
MS. BENOY:
In the trench area, right.
UNIDENTIFIED SPEAKER:
But you're going to pump the
groundwater out?
MS. BENOY:
Yes, sir.
UNIDENTIFIED SPEAKER:
Or move the contaminants
by pumping groundwater?
That's the proposal?
No soil
r
. movemT
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but pump water out?
2
MS. BENOY:
Let me explain again because I know that
3
it's not quite -- it's not very clear.
In 1988, EPA proposed
4
in a public meeting just like this the groundwater extraction
5
system to clean up the groundwater.
EPA felt that there was
6
adequate data to make a decision concerning the groundwater,
7
and that Operable Unit, that first record of decision was
8
specifically for the groundwater extraction system.
It also
9
required that the northeast tributary be monitored on a periodic
10
basis to determine whatever source existed.
So that decision
11
on the groundwater PQ~ping treatment system was made in 1988.
12
There was a public comment period also.
Tonight's meeting
13
is a proposal for no further action on those soils.
That
14
alternative, that first option that we're looking at, number
15
one, the no further action, must be looked at by the agency
16
to determine what would exist if nothing else were done for
17
We're required to do that.
This
those particular soils.
18
option allows natural rainfall to percolate through the soil
19
much the same way the waters that were disposed there perco-
20
lated into the soil.
But the pump and treat system will
actively draw those waters through the contaminated soil area
They're designed that way.
They're located in the areas of
I
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the water through, effectively flushing, and EPA is proposing'
I
or its position is that the hazards and the problems and the I
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extensive contamination of the groundwater.
They will pull
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costs with capping, with excavating, with any other alterna
2
that we have a balance of a nine-point criteria with leaving
3
them.
Above and beyond that,
That they will be addressed.
<1
extensive modeling was performed.
The groundwater remediation
5
itself is going to take decades, in the nature of 25 to 30
6
That's where we are.
With groundwater pump and
treat,
ye ar s .
7
it will stop the migration, but what is in the groundwater now
8
has got to be addressed.
The modeling that was done on the
9
soil flushing is going to take approximately 22 years.
So
10
effectively, the soils will be addressed with the groundwater
11
pump and treat.
Did I answer your question on what's being
12
decided to clarify that?
13
The point is,
UNIDENTIFIED SPEAKER:
in essence,
14
there's no removal of any soils.
It's merely removal of the
15 Ii
groundwater and treating of groundwater.
16
But that decision -- yes, sir.
Yes,
MS. BENOY:
sl.r,
17
UNIDENTIFIED SPEAKER:
How long is it going to be
18
pumped off?
How many years is it going to be pumped off?
19
MS. BENOY:
Approximately 25 to 30 years.
UNIDENTIFIED SPEAKER:
Well, you gave a number --
UNIDENTIFIED SPEAKER:
At what cost?
Excuse me.
At what cost?
This cost that was here on this first step,
this first option?
24
MS. BENOY:
No, sir.
25
UNIDENTIFIED SPEAKER:
That doesn't deal with the
-------
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3
4
5
6
7
8
9
10
11
12
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29
groundwater cleanup, does it?
That was a separate ~ssue that
we talked about two years ago.
UNIDENTIFIED SPEAKER:
It's none of those figures thert
UNIDENTIFIED SPEAKER:
No, it's none of those figures.
MS. BENOY:
These figures are only for the soils.
That groundwater pump and treat system, the decision, record
of decision for that system, was made in 1988.
This is again
for the soils.
Yes, sir?
UNIDENTIFIED SPEAKER:
I just want to repeat my
question of half an hour ago.
MS. BENOY:
I'm sorry.
UNIDENTIFIED SPEAKER:
Could you tell me what the
wells are and are they all operating now, and just explain --
I don't understand what the bedrock -- I don't understand
exactly what -- and I sure don't understand plume, periphery,
and monitoring.
MR. MUZA:.. Okay.
Now, basically on this particular
figure just to the left of the National Starch and Chemical
Corporation plant is the trench area.
~hat's those strange-
looking boxes.
There are four of them delineated in there.
That's the source area.
That's where they were digging the
pits 8 to 10 feet deep and disposing of this waste water and
percolating it down basically into the soils and watertable.
We've got monitoring -- all those little black dots, the
,
i
for I
NS slash and then the number, those are monitoring wells
-------
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the origi~al remedial investigation.
C~IDE~YIFI£D SPE?~ER:
How dee? are they?
~!?. ~H.: Z .::.:
They're eit~er i~ the
S2.;::=:-0:':.:.'2,
Okay.
which is the soil ~aterial, or into the bedrock.
In so;:-,e
loca. ':i.o~s
there's paired wells.
There would be a well o~
t. :"'. E:
sa?rolite and a well on the bedrock.
Other locations t~e~e's
just one or the other.
U~':I:)E::'TIFIED SPEl>.KER:
How many feet down?
~:?. W":ZA:
If you're talki~g about the bedroc~
out there, it varies
as
you head dow~ toward the southwest
"
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tributar~'.
I;
U:\ IDE~';':'I FlED
SPE;'.~ER :
I know.
We li~e out that we;.
':
!'i?. ~::." z.:.. :
.;nd u:: :1ear the
~'O:J. ~..;: 0"': -:-
trenc:-,
areas,
have to go dow~ about 20 to 30 feet to get to the bedroc~,
but the water table itself is about 20 feet in depth
at that
point.
Farther down toward the
sou t;-, ~
It's in the saprolite.
west tributary you have much less soil, and the bedrock is
a much shallower depth because it slopes away from the
trench I
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bridge areas.
UNIDENTIFIED SPEAKER:
And they're all
contaminated? \
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No.
No.
UNIDENTIFIED SPEAKER:
It was the last time.
MR. MUZA:
Okay.
The wells up near the trench
area,
NS-9, NS-17, NS-8, some of those showed very high levels of
volatile organics.
Moving away --
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CXIDEXTIFIE~ SPEAKERS:
P' .
..l.c:-'. ,
v.'!-;~' don't
:'-'0-"': go u~
on the stage and ?oir.t those out?
t>1P. . ~: :-' z.:.. :
Xow, t~ose wells
are ri9~t alon~ ~e~e 3:
the periphery 0: the disposal a~eas.
~o'.'i;-.S a'..;ay, srO\..::;d''';::':e:::-
is :10~ing this ~ay toward the southwest tributory.
Gci.ns
2'\'2::' from those ,,'ells, you know, we saw' detections in SO:-:-;E
0: the
cowr:sracl.e:-'.t
wells.
The farthest downqradient C2~e
u:;:' clean.
5Q ~~ had an idea of what
the ~lume rnc~ese~':
~ . =. c:
""'-"-.
They've act-...:ally
put in
more of
these piezo~eters.
sor..e
I
think there's a couple of additional piezometers.
That's what
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P-.; is
i" this area
since ~e didn't have wells over in t~is
area.
50 we :;:~ett~. mud: deli:1eated a plume that's mo\"in~,
contamination in the
qrou!".dwa ter
that's ~oving toward tte
scuth~est tributary.
Khat we're proposi:1g to do is, as
Barbara said, decided two years ago -- the final design is
l!1,
we've looked 2t it, the EPA has dor.e some modeling to
see theoretically if it would work and such -- one of the
ideas is up in the trench areas, since that's where our highe t
levels of contamination are and that's the source area, to
-put in a series of wells.
These different boxes delineate
different things.
The circular ones, these are extraction
11
22 Ii \oJells that are going
23 !I
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to be put in.
Okay?
Those will be
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contamination
!
in the soils, in the saprolite, the trench area.
5 orne 0 f
those' soils still have contamination; some of the
is in the unsaturated zone above these locations.
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will be
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t~e 5a?rc~ite ~? here do~n into the bedrock.
\\E: 'rE:
;;"..:t~i~g
in or are going to have a series of bedroc~
extract:~~ ~ells :
put
in at t~is point to sto; the downgrajient rnigraticn 0:
the conta~ination.
50 it's a two-fold
syste:7\.
Let's clea~
~? t~e'source area as quickly as possible, as well as le~'s
s~O? t~e ffii~ration do~ngradient.
That's ""':-.at all
these
di::ere:1t
boxes mean.
As I was saying, ,these are the ~o~itor-
l:ig
...;e 1 :. s
the!"e.
put 0:-.,
Once this syste~ is
t~at a!"e o~t
:,.:;
effect,
~e'll be looking to use these monitoring ~e:15
tc de-:er:;,:':ie
~~a-: ~ater levels, how turning on these
four
~e::= here a~c t~esE s~x
t.:? her e i s a f :: e c tin ~ the ..... ate r 1 e',- e 1 s ,
~~Et~Er ~e're get~in~ the
crying
in that we
""'a~t ,
",,'hether
"f;e 're
the conta~ina~ts by plotting al~ the n~~bers
ca::~".l=i:-:~
a:-::: l~ck':':1~
to ;.,ake sure.
v;e I re going
at SOIT,e
:;,a;:5 t~ see,
to co
::-~o:-.i torin~ I
and also the!"e will be ~ater c~alitv sa~=lirlc
- - . ,-
cc!".e.
L~IDE~7I~IED SPEAKER:
Well, how are you going to
check those deep wells there, the wells that you've had a
good while?
MR. MUZA:
The bedrock wells?
I'
Well, yes.
The deep one~.
I
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,
UNIDENTIFIED SPEAKER:
No.
ME. MUZA:
The deep ones?
UNIDENTIFIED SPEAKER:
Yes, that have
been out there!
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a good while.
The monitoring wells.
~'p
...."""'''.
toW Z A :
Okay, they were sampled there i~ the
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c e s i :::-, ;::--: a s e ~ i.: s"; r e c e :"", t :: :' .
That ""'c'..llc ~.a':e bee'"' -- ...1-,,,,,. .'--
.. ....- - ' ::>
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t~e c~:c
c: t~at sa~Fl~~~?
BeC3'..lSe ts=' C", 1'.' ,.'h.=t-
.-.. -- ~ ......_","
we liKE ...0
do is, I ~e3~, as you're
sa~1 i n~
he:-e, the
.' ,
re!:.eCla-
i:"".':esti;a-
tio~
0:.'": t:-. e:-e ".: as q\: i t e
a fey,,' years age.
Be: ore we c:c 1:-.
.0
c. :; :: c. = '~:. :: :-.
t~is r.ice little
we like to get a
sna~s~.=t
syster, ,
C: .. -- .-:>--
. - ...... -_t:::'
i s t~.e
co~ta~inc.tio~ ~ow, wtat tas ha?pe~ec
::-. t:-.:s:
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cO\:Flc years period, so they were sampled within the last year
before t~e desic::-: was de:-:e.
L~::I~:~-::-: =- :rED
s:: :: .:'.::::: p. :
Tte~ the water was --
~:?. ~:._. z .:..:
Sc it's basically what we saw the:-e i:-:
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the F.:.
~he:-e is conta7inatio~.
It's ric:ht i:-: here.
E a.v,. :.~.~:.
:..:-, t:-.e re~-ec i a 1
in\'estic:a tiO!"'..
'-':: : J:::-::- : f : ::: D
---.....--
::: ;...-.."~~' :
f - ...,
\\e~.:.,
...-,--..tc:
_.iC - -
....'here
o:-.e O~
t::::se
ai-2 : : ~ is?
~:;:.. ~:'_. :.:.. :
T:-.a:. I S
...:he re
the --
=.:'2. 0: tr.es-:
',.:e l.l s
y,,'ere
£a:7\? 1 e:: .
Like I
said,
a --
u~IDEKTIFIED SPEAKER:
I can't understand.
She said
that the soil was contaminated 18 feet down.
This well here
is 30-some feet, and it's contaminated.
You Know that that
contanination has gone further down than that.
MR. MUZA:
Okay, that would -- what's happening. the
source area,
the wpy the trenches were dug out,. they were
8 to 12 feet deep, and then water, was placed in them and
allowed to infiltrate ir..
So what we started seeing was
ler
were borings done in the initial remedial investigation, and
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t~.e 5.::.1
CO:1ce:-:t=atiO:i
le~els 1:-: t~e bo=i:-:;s
t:--.c: ~
",,'ere
;, ~ a =E = ;
1!"'.
t~e5E
t~e kind c: CO:1ce:-:~==t:=~ .
cld a=e3E did:;'t te3= C~~
~e sa~ 1:; so~e 0: ~~ese ~o:;ito=i~g wells i:;
t~e g=::>u:;=""'=~e=.
I.' - ..;.. r::.
nt:' - ---
,,:e=e:; , t
se e :. :-.,=
t~e le~els t~at you wo~ld expec: t: ;et
t:-: 0 E e t ::-::' E E c:
co:-:ta~inatio:1 i:;
tJ-,e g=ou:1d~ate=.
Tha:' 5 '..:-.~'
, . '
',...e :-.a= t:-.E
a~=i~i~~3l S2~?li~~ do~e.
7J-.e bc! :':19S
t~"'+- .,-..-
.;-.... ""'='- 0::
aO:ie, ~,e acditional borings, once again showed there is CQ:;-
ta::.:nati0:-,
i:; the soil, but it just doesn't approach the
le':e:~
a~tici~ate to get so~e 0: the
nu~be=5
'.. C 'j ...::- '..; 1 d
t:-.=~
,,;e r:3d
it showec that the
CO:1 t a:;:i:1 a:-. t s
~e=e.
K:;O..... ,
Sc, y~~
o.-:e:-e :'..lS~
::~E~:~g throu~!: t~e
':'r:ere was so~e
ac:-,es :~:=..
. ,
so~-s.
c~ co~:a~:~3:io~ o:;~c the so::
:hat exists
t c = a::', res i d :..: a :
CC:".:~:-:;"~.=.~~0:-. ,
::''..l: t:-:€
.::.- -..
-'w~1.
- ~ . ..
:';"..lE:-:e::
~L:~€ ::-.a~or:.~::'
0: i: .....as
~ c. "..'::-. "n" a ~ :.
~:t~ t~e ~e~c~:a~:~~
wate= i~~o the ;rou~=~2~e~
S"::~€:7"..
.:.:": == ~ :-. a ": ' S
r e:-.E = : =-
. . ~
t:::e :-.: 1:: :OC:;s
c: t~e
grOU:"'H:"""'c ~ e r
tio::.
The re~eciation syste~ that we're talking about here
tonight is to allow natural infiltration to flush out the
levels that we have found remaining in those soils. It ',s
going to infiltrate in, and contamination will be carried
with the infiltrating rainwater through the soils and into
the groundwater, and then become a part of our cleanup syste~
DNIDE~TIF!ED SPEAKER:
But you said you wantec it to i-
you wanted to solve 'the problems as quickly as possible.
Right?
MF.. M::ZA:
Uh-huh.
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years
:5 t:--.a~
::-.'::--. ::
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7a...'E::-. t:: ?
:'we:it:.:-:i':e?
~::=:. ~~~. :.=-,:
T,' "
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t~-=~ C:-CW:-'=""'=~e=-
;;_ea:-.~::-
i.s c~:-:;:=-:l:
.
'=:--.E C:
~~: ~~s~ j::ficult
tr~:. :'.; 5
"oA°e =ea:
.~. i ~:-. 1 :'.
e:-: \. ire :-.:- ~ :"". : ~ !.
---,-.:;,.......-c:.
I....-..~-_..-.
~
~';::: ::~::! F IED
SPEA."E? :
sele::ted
Okay.
.,. & .'1"""
. - .."'''''-
;.1 ~er:-. a t i \Oe 5
3, 4 and 5, how long would they take?
~:?,. ~'-' :;'.:
\';ell
:"~:~::::~::::IEr:::
c?::-:'1.'::-? .
...... -...~_....
Or. t~at s:~e exa~~le.
~:? .
,..... - ...
.. 0"" ,"".-.:
I thi:-.k that ~;:e :: t~e~ is
\.:s:.:-.;-
Okay,
c: -.- -
- -"",=
r. . c::'o- .; ...-
-~-_.._"':'.
:: ~: : :- .:: ~.::- : : : ~ ::1
S?~.;:-:~? :
:::1<:=-
-
i:J=i:-.€=a~i:>:; O~
~ ~,ea:-.
. - -.-
-- ---
=.:-.: ==~:-::::-.~ i-: a~--;~::', bri:'"'.~i:-~~
.::,a :.'<
~. t :-. E =
c::---:?
.."._-:-".--':'".~-"
....."---.'- -.. ...--
S ? E.=-.:-: E::. :
7:-.e :-~
c~e =i::E~e~~ c~:~i~~:.
::::::~~~:-::lE:>
SPEAKER:
It s:-:O~l':;j't
~e li;"e t:.at.
:~ yo~'re goi;:; tc
501 ':e a proble!':".,
go ahead and solve it.
MS. AKIK:
No, what we're saying is just that no
matter what we do with the soil, groundwater is still going
to take 25 to 30 years.
UNIDENTIFIED SPEAKER:
Yes, but when you filter that
water through contaminated soils, it contaminates the water
again.
You have to pick that water back up.
Right?
You're!
~ot sclving anyt~ing.
In other words, if you dig the dirt
u? to
begin with, the water is going through clean dirt
after you carry the good dirt back.
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t:';,....\-.~
... ... ",:.. \0. .
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~:.: .
;...:-.~ : ~ ~ :
E~t ~'ou~ 9=~u~~~a~e~
-- ~~e ~~=;~:~~:c~
3 !.
t~ere will stlll be ~irty.
It ",,'ill
still be
ci:-ty.
.:
~'\ E' E~::I?:;: Ez)
SPE;'_~~:':~. :
G:O~~=wa~e~ re~e=la:i~~
-
L'~: I :'=:\:!? I E:
""':-.e:-. j':'~
SPE':.FE:=.:
Eo..... ca:i it
::-e dir~y
E
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t::e 5:)il?
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MR.
~ell, whether we do that or not,
ML~ z.; :
~~:)~ k:,,:~'..
it's
gci;.~ to take
a long ti~e to clea:i the groundwate~.
~'~::Z:~:;:-~rI=:~'
c::-,....' ..--
- r :"r.!"~':':'.:
It ""'0-...2.:: be
quicke::- dc:r:g
t:--.-= 2,
.; a~.= 5.
I hea::-d t~e lad~ talki~g
a~c she saie t~a~
~?~ ~=£ cc~s:ceri~9
t::e pro~ect -- should ~2ver
consider
-~--
...0: -
:::":-.ce
:''-.e .:~:-:-:~ a :-.~.
15 ;::=.:'i~g :0::-
it -- t::e
gC":e::-n:::e~: ~ S
--- --..,-- ---
. . -.. ~.;.. -' -.. ~ - ...... -
priCE s:--.Cii,;l.d:-.' t
l~ --
e':e ::
CC:7'.E
~:-.:.=
vie..,,;.
I ------ "-
'----..-..- --
:~-= ~la=e s::=~:::~'~
,.-: i::-''--.;.
..-. --."'--.
ErA does r.ct ~a~e ~~at ~e=:si~~.
Tha-:
c.€=isio~6
CO~ES fro~ Cor.gress.
Those nine-point criteria, ~e
ha\'e no choice.
Cost must be p~rt of the decision.
Let me
see if I can --
UNIDENTIFIED SPEAKER:
See if they understand the
18-foot thing.
I want to be sure everybody is clear on this
I
,.
,.
"
18 foot.
That apparently causes a good bit of confusion.
C~~IDE~TIFIED SPEAKER:
It doesn't cause any conf~Eic~
~e just want an explanation.
UKIDENTIFIED SPEAKER:
Well, 1 think it =auses
confusion because it was soil, not the water, that was cont~-
II
ir.ated.
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p....
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\'"e ~~.=E:-stcoc
..-......-
-..e -.
yo:; sc':':: --
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(Se~e~al ~eo~l~ talking at o~ce)
C~IJE~::FIEJ S?EAKER:
T~.e so:': di~:-.' t
ha':e as :-.~:~,
,.
CO:"'. ~a:- .:..:-.a ~ io:-.
as t~e wate~ did dee~e~ than that,
P.ig~.:?
T:-.a t ...;:: s
s :>:: e '1';:-: a:.
S:;~';~lS1:"!q .
U~IDE~TIFIED S?EAKER: Doesn't it seem like it's ~~re
~easo~:~le to dig u,; that soil?
L~IJE~:!:IE~ SPEAKE~:
I knc-..' v,'::ere
YC1,;'re
CO::.:' n ~
:~c::. .
I:
I
~he~ ~he operation of
015;:'::5::"'.;
X~.
t:";" "-."'" \. .
",-,-..''''''''. .
I: I ~.ay,
e: the
i~ these trenc~es ~as
s~o,;pec,
t:-:e source 1n the
...;::te~
S -, - ,
~ ...-
'...'a ~ c 2.:: ::,ere
c~n~a~i~ate= ta:~ ~~e~.
~\e r:.a":e =::-....:=.
seen
tr.ese
seils nc: the source tha: they use:: to be.
:~'.:
n:: as
. .-
:'.1 g- :-. l ~.
C:>:"'. ~a:7.i::a t.E':' .
':'hat's c'...:.r
rationa:e for
:-.c~
dig:;ing the::. u,;.
The groundwater, the majority of
the so:.~
contamination has already leached through the groundwater, an
the groundwater was the major risk problem that.we had becaus
the consumption of groundwater could occur, but the risk that
these soils posed is not one to human health.
They're 18
feet below the groundwater.
By leavi~g them and allowing
the final flushing to occur naturally, whether we dig them
I
I
up or not, the grou~dwater contamination probleffi is a ~roble~!
we've got to deal with and we've got to acknowledge it's
i
I
majo1
going to take 30 years.
The source -- the soil is not a
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1..,...' -- ......-
a~:~c~e, a~e tha~'s the re~so~ t~a~ -- a
~.;: : ~
I'
0: tr.e
reas::::
-- t!'-.at ",'e'\'e electt:':' to a~lo'",' tr-e ""'''''r,,"
., '.-'-----
I!
:lus:-.:.:-.S.
C~~~~~::?!E~ S?E~KE~:
There's reaU.': r.ot~inc
. .
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Q -'v - -
:;0 :'ear-s
as :ast as this st~::
1:-. fact,
eit:-.er.
:7.0".- :':-. ~ ,
',,' :-. a -:
co~~:~ina::ts ar-e
""E I 11
eo is u.o~:tor u~til the
belo~ a certai~ level, cutoff level.
t.::~I:E~:Tr~IED
S?E;'.:-:ER:
Khat is your cut::: le~el
~c:n~
~c ::e-:
~:::=. ~~'..:: .::.. :
re:er-rin::
;'.'::'E ~/C~
tc the
r:-;~.r-.i t.cri::~
~'~~ see C~~ ~~e~E?
~-'~:::~::::::~: S?=:.:..~=:~\:
'~'es .
",- .,.. - ...
. - . - .
..... .. - -'"
~ ;-. i s
,,- ... . .
.0..... "'" ,
'"C ..-., ,..
.,. - ¥'\o..........._-
==:: ~=:':"".-:s
.. c:: ,.- --
...- "'..c-
c: ~::-::-:'=.:-,=-=
t.:-.e sour-::e
a:.--:::.
:-:-. a -: ',,':: '';' ~ :: t.;
-=.:-
..,- -
_...~-- ::
,.:: - ~ - '.~':::' - ""
.."- - I' .,- ':J,
,- - ,..
--to
." - -,
"::-' ~
."- --.
Ke '\'e got a ser-ies 0: ::'..;..-:-.ber-s
put t0get~er- in the
the decision that on
a hu."nan
recore,
health basis, there were contaminant concentrations.
Akin knows how those are developed.
They're developed by
toxicologists, and those are the cleanup goals, to meet
that that groundwater would be usable at those levels.
"
the criteria.
Until those levels are met, we'll be runn~ns
those extraction wells out there.
Those years a~e just a
nUITber that's given.
It's done by some projection, done
39
~a:-~
:':'"..:.~':" ::
is
",'e:1 s
1 : ,': -=
i
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level~
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That' .
Elma
by computer modeling, something that hydrologists like doing,!
i
and it's a way of projecting the time it's going to take
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base= ~. t~e co~ce~~ratio~s ~e've seeD.
longe:-. a~= that's ~~at the
..'~::' we ::c. ~:-.e
;:-.:lr~: -:.:>:- in;:.
j'
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t:: :. n ::: :..s
gQi~~ to ~orK, and
::::p", ~..
.....~ ~ ..... ~
CCi,.;ld ta!.
r.-,c'!".i tor i:-:g
is a::'l
a:'OL:.t.
7:--.at's
\\e'r.::> C.-,i",-
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t.~ I""'ai
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t=ib~:a~~ :~a~ it
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does to~ard the pla~~ itsel:.
2 '
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There's a~s.;) a
co~es
..
3
out a:-.c
do...':; a lon;
ru:'"'.s
Ca;;;;
~rar;c~ t:--.c ~
Roa::.
Okay?
It ru~s d~~~ l~~~
.:
G!""ar:ts
C=eek.
Like I said, it
ru:-:s --
They're calli:-:; th3~
t :-. -=
5
t.'~\ I :)E~\T : F I ED
SFE.:"KER:
C "
,
s~~t~~es: ~=ib~tar}..
A::parently that's it.
1: co:-:-.e s ::: :';',,':-.
C~IDE~7IFIED SPEAKER:
Now, that wooced area --
8
(~e'\:e:-al
speakin~ at one time)
U',at I 5 ",,'r.at ru:;s
tr.:-:>i.:g;. ?
7 I,
I:
the bac~ sice and comes around.
~o~, what upset me was tr.at
t. =, f i "\'e
yec.r s, '",'e ~a':e
see::--,
9
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e.:i=E~.:: ::
:-:::-:a..-,:':-.at:::-:-, ::: t~a": other
.::e~'
t,..~ ~.'.~~..,...,.
--"";-""--,:.
; : ."..= :: E
',,'=.:-.: :.: i::a."7".e E:-::',.::-, ~e:ri;e:-atio:: 0:-
-::-.::.
so:-:-.e~o~::'
like
~::,. }\:::-:E5ECr::
Okay,
Do you ha \'e
a ma;
0: t:-,e
Okay,
t::a: :-:-,akes :7.ore
se:-.se.
s\.:rrou~c:ng
property on the other side?
MS. BENOY:
I don't know if this is going to be
All right, where is the corne
Cedar Springs is that side
22
i
, of the boundary of the property that --
l:~~i:E;::-IFIED S?E;'.!<:ER:
:.;-.e~. t =€
sa:':'::; :c~ t:;e ?c.st t.....,c
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~:~::~~~:IFIED S?E~K~F:
enough.
UNIDENTIFIED SPEAKER:
of Cedar Springs property?
I
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U~IDE~TIFIED SPEAKER:
There's a pond right at t~e
corner of Cedar Springs and National Starch, and this is
fed by a springhead on National Starch's side.
II
Now, where's
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I,,;:=t e ~
!-~S. E~\2Y:
42
I'~ ~ot a~are c: the
s;ri~~, Joe, or a
j.
pend.
J..re yc~ --
C\IJ:::~:-IFIEJ
S?~.:.J,ER:
t::e } i:e .
: don't kno~ w~y you
C~:J~~7IF!~: S?~AKE?:
It's not
a h'..;:;d~ec :ee:.
wou~d::'t
be a",,'are
0: it.
\\1;ere i s it
0:; t:-. a:. ::-.o5;:?
Ii
Just co....~ to the botto~ of it from that hatched area?
Is
t::at
~~ere yo~'re talking about?
:':~:I[:':::;:7IFIE: SPE..;::EP:
S?~i:-::;=
Far::-.5 t::at ""';5
built
. i- -
I...\::
o:.~er Slce 0: that
:ar~ is -- we have 82 acres.
:.:~::::'::;::I=:~: SP=:.;KER:
t::e c:.~er ~ay, goes -- i~ does
-,....~ -=-_..
:-'-'-:----~'
so :~e=e's ~o reason t~e
'...'c'~ld co
t.:-:at,
::e c:.scharged
l~~C
It's or. the co~ner c: Cedar
there, and the0 across just ~n
The co~ta~:.~a~t F:~~e
';O€ -
net go to~a~d t~at cc=~er :- ~~
c~~~a:-.i:-:=te=
~ :" :: ~ ~ -= .~. atE: =
~n=e~ ~~a~ SFri~~.
MS. EE~~OY:
I'm not sure what area of the slte yo~'rE
talking about.
Is it along Cedar Springs Road that you're
talking about?
UNIDENTIFIED SPEAKER:
The pond is about as big as
this building, or maybe a little bigger.
UNIDENTIFIED SPEAKER:
U~IDENTIFIED SPEAKER:
The one on the farm?
The one on the farm there.
(Discussion in the audience)
MS. BENOY:
Can you point it out on the map?
U~IDE~TIFIED SPEAKER:
I don't know where Cedar
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c--;--c:
-~- -..-:--
t~.e c:or:;e:-,
is or. U'.a t ma:;.
: a :-::-. ,
~~.s. E~>:O'.:::
Is t~ere so~eone that
rnig:-.t Kr.C"'''?
~~!JE~:IFIE~ S?E~~ER:
V;c'~ld it be
rist:t
:":-. t:-.e:-e?
Is t:-..at
",,'!"'.ere ycu mean?
fig~t in t~is area --
~.~~ I ~E~:: ~ I E:>
SFE.;}\ER:
F\.;rther SOl.lt::.
(: :,sc'.;ssion,
se\'era ~
s:;e.a~:~~ at once)
M~. P;'.RADOWSKI:
I'~ Ray Paradowski from ~aticnal
C-::.....-\-
- ....-- "-...
~~:t ! t~i~~ we're
t:lkir.g a~ut is, i: ! ca~ ~~~
t:-. :. 5 --
it.'s
~c~ a sood ~a:; to look at.
We're looki~S at t~e
F... ::.:-: :.
s:te.
7~is is t::e ~ational Starch boundary wf:icr: co~es
t~.=:'J:;~. :-.e=e.
:~e ne~ i~c~::=ia~
a..--
.co:
?ar~ is basically t~is
- - - -
- -
-....- -
.....-.-":
- '...J Co -
c=~es tt:-o~;t t:e:-e ;.o~
o\'e=
i:-.t:: Ca::-.::
a:-.c back
- - -: -
.'--- -.
::-.e
?.:.=~ l-.e's
re:c==l:-.g
~s ris:-.t
1 :-.
t!"'.:S
abo-.Jt
.-'
... "''' ...
a=e~ =~~:~= ~~e~~ ~.
E=o'~'~. !-..a s
fac::::::',
.
~\;~
tte ~e....'
- - - -
.. =-::: c
:-.e..,; :aci:'.:.:.::" ""::ere
t:-.e ::' 0= 60
::e:-e's
a pc::c
~s.
~e:-e, whic:~ coes~'t really originate out of the ~ational
Starch property.
It's really on what used to be the Caldwell
farm really.
UNIDENTIFIED SPEAKER:
You know where that lake is?
MR. PARADOWSKI:
It's a small pond right about --
UNIDE~TIFIED SPEAKER:
What does that water come
from?
;.
I don't know unless it's fed fro~ sprincE
-I
It is a spring in there. !
I
r-:s. BE~OY:
..
li~ IDE!':T IFIED SPEAKER:
That's what runs down the side of National Starch until it
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It's ~ot o~t 0: ~atio:;a~ ~~3rc~'s
t":~I~~~=: I::E:> S:::::;'.::E?:
li-:t~e c:
:.:. 0:-. t::e
~:=. E~~:))::
, ,
-lne.
1"';5,
5':"::-:
C~IDE~::FrED SPEAKER:
1a~~ looks to ~c, it's
i: t.::e
, . .
s:r:.~~:-..;=:: ~s
: c c:-. 't. :-::-: C On' .
:-:-.at's
':.:-.e
la:1c
:. a ::. 15 a \,' a y .
to. -' - -." -.-
.".::. =:'.._.l:
------
..-----
. .
-::: '..: =--.~ -= ~ ~ -: a:-.::.
- - - ..-
--.- --
~'':-''':':-E
:.: - .-::n9"
~ere, t:-.e :. ::'C'..;
~s t:--lis
r~:::";~ng
cO:7.inq O~ t
t:.e \.;ay
- .
J ~..::.c::. r-- .,..,,::,
.. .'-- _.. .....-
be-::.er
a....- .,- -
....--- c.
,.- ...
" c:..:: ,
\\e 11, you ;:-,=.:'
ha\.e le::. a
Tte way the contour
c\= t::e
fro~ Proctor do~~
t~a':.
\..;a::' ,
:ro~ Proctor's si6e.
,.~. ..
..., \..i" ,
it looks to ~e a:1~ the way
site
:r i ::=::.
....--;:..:~ T
-'=----- -
:-. :, ',,' :. :-. e
:j,O\\' 0:
. . .
-:'-.e ~=.:-.:: ',;='5,
-.---
--..-
...::,..." '-
~--"..
. ,
5 C ~ 2: ".,'.-. ~ =- e ..-
-~c-
c:.__c:.
a:1c. :t
~o~ld no~ i~~a:~
, ~ -
~;'1e : -: .","
u?strear.. if the groundwater -- I mean surface water -- flows'
downstrea."'!", .
So we won't see contamination flowing upstream.
Ye~, sir?
UNIDENTIFIED SPEAKER:
the nor th ?
MS. BE~OY:
Did you say the flow was to
Surface water flow.
UKIDE~TIFIED SPEAKER:
north?
MS. BENOY:
yes, Sl.r.
Surface water flow is tc the
Yes, sir, on that northeast tributary,
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C~I:E~7I?IE~ SPEAKER:
tc t:-le
S,...,....J,..
..... -.. - ~ ,
a roc t:-.e
",'est.?
~:~ .
EE;~O'~' :
~ay I use your pen?
s;:rir:;s
t.r,at are
located in
area.
.. . .
-.:11S
a~ t~e s;r:r:gs, but
45
Okay, the srounc~ater flo~ is
There are
~o~, I eid::'t. g~
a:'1C l-:~.~~
evider:tly ttat is ~here so~e
c: t;-,,; s-..:r=a=
',:a-:e:- i:-. t:;e
creeks
ori;:!.:iates,
a:1c the :10"" i::
t:-.is ~: r::-.e :s~
tributary is
in this direction, yes.
It flows north.
t..:~! DE;::-: FlED
S?E,:'_\\E? :
I.
~~~. BE~:CY:
Yes, sir.
a;ai:-. ",'e
sa~.~lec
this
~.~~.t:--.
t'-.::se.
--.:;::~~~:I:IE~
S? ;:.:.::E;;~:
r- -....:-
"-.. -..--
-:- '"
:.:~. =:::~>:!~.:
:c:-=sc-: ::-.e
:-2:'=~
SFri~gs ~cac ri;~t here.
That ""ater has
been teste'::?
There have been s~~Fles,
ar:::
ane have preli~inary results
fr:~.
v.,"here is Ce==r
c--';--c::
-:---. ... ':"'-
- -
:. -= :: ::
i: -1-
',..;ro:-.;, ~-..::
t:::s is
It was supposed to be part 0:
. I
the solution of the first alternative, was to restrict deeds l
L~IDE~:IFIED SPEAKER:
restrict development of the site.
Are we -- in essence, noth
can be built on the Superfund site until cleanup is done.
Is it true that -- have we just zoned all this land
that
National Starch owns?
If you look around, you se~ Kir.gs Foret
sits right in the middle of it.
This block that comes ~~
there, is that going to be zoned industrial, the only alterna-
!
1
That's
tive going to be zoning it industrial at this point?
kine 0: scary.
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res?e~si~le fer t~at,
is o~ the ?rc~er:y,
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.,....,-
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MS. BE~OY:
46
The s'..:estion is
~hat is t~E zc~e rest
s ?'=:;":-~==::. :
I u~ee:-stane
t::a: yC'.~' rE ~.c:
b'..:t ir: esse~ce, if t~e
Su?e::-:~:-.= si-:e
is t:;e ...:he le
~ro?erty
subject to t:-.a':
The ~hole property rnear.ing --
In other wores,
\.:~:DE:;::::IE: S?E.i\EER:
the "":-.cle
p:""ope=~~. .
r eor:'t k::o~ hc~ rna~y acres are do~::
:'<::
era",' a ~1,;~be:-
c: 25C.
there.
I ~o1,;ld tti::k so~e~~ere arou::c in tr.ere.
I ""0-..:1:'
tr.:":-.1<
:hat t::e:-e's quite a bit 0: :a::c
do....:"'. there to
- -
;:,E 1..: 5e~
;:1'::-.::. ci::e::-E:1't
.,. - ~.. -
-.. - --
....'" - P" c:
- - C::..-
are.
,':: :,:",..-.:.
....-- --~'-_.
a:-e :':-.= t
, -
a:-e ~~ace:: C:-.
...- ..c:::
.....c:;.-.
~ =~::' ~ k~~o~..
.
I co::.' t 1<:-.0'..;
7::e q~es~ic:-.
is ",,":-.a:.
:.:-.ese
:-es-::-iC':.i'::-.s
T"~~ c::~--?
...- ---c.
CKIDE~7I::IED S?EnKER:
~hat deec restrictions, yes.
MS. BENOY:
Do you know the answer?
I don't know the answer to that question
UNIDENTIFIED SPEAKER:
It says that in here.
MS. BENOY:
Right.
I don't know what specific
restrictions -- what the deed actually says is what I nee=.
UNIDENTIFIED SPEAKER:
I
Whose responsibility wil: that
I
,
be?
MS. BENOY:
National Starch.
U~IDEKTIFIED SPEAKER:
You've got to be kidding.
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r-.e:--= ~:-
a:--.y CO:..l:-. ':.:'"
o::~=:=ls
go':e :-r.:7:e:-, t
r,i.g:-. t .
I.
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Ke, in Our fl:-=t co;.se:-:t
;..~.:~::
ce::-ee
..~.:::!~
.....- ..
",..e signed '.;it::
Sta:-c:: -- 3:-:= t::at is
a::::-.i:-:ls~e:-c.'= ;......
;:a t ional
-
-
a :c'u.rt 0: 1 av,',
a:-.:' ~i;.= c:
:"lot by EPA --
it says t:-.at in
-
t.~.::-.S.3c:i=:-".
~a':.io:"lal Sta=ct has 0:-: a:-:y 0: its
.. - ::-..
-.. - .
F:-C~E:-:::' ,
have to let the buyer be aware of the ,site being on the Super-
:\.::-:::
There are also ~er':.ain restrictions for t~e
t :-e-=-.::-
., .; C"
--- I..
"
a:-e.::.,
areas
~!:a:. \
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-,
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~E~
:~ C:..:t c:
""'.:':e:
t;-.e S:-c~;.d?
y~....: <;e~
\-,':-:e:-e a'=e
~.O~ ;=::-:g
I-
to c i S-:c s eo:: 1 t ?
'.
v- --....-..
. ; ~. ::) =-.. '. ..... :. :
cesi.g;:
In the
there's a trea':~e~:, a
"
':
t~eat~;==~ t=.::~..
se->::- a ~
':':-:-=:e ar-=
t~.i~.g s
t~.a:
a~e \..:s~=,
se':e:-a.: c:::e:-e;::
tec~nologies ttat are used to
. '
re:7,o':e \'c.:. a ': ~ -
!!
3~= :r.e opt:o~ =ig:-:t
:-:€~a~~,
;:o~ is a:tE~ t:-:e ~:c-
:-e:-:~'''e
treat~t is discharged to tr.e local publicly owned treat~e;;t
wor-':s, t:::e se',,'e: s~'ster.. -- tt.a':'s a desigr. rigr.t
no...' .
Yes,
5i: ?
~.:~~::;::-::-:?:E":' 5?E.~Y=:?:
\'::-.a t r. appe:--.s --
! ~ea:: 1.:)1,;' re
s a~~ in:::
-- 'v-.:--.at ha~F-e:-~s
:: :-::. \\ilson' 5 grou~
there
back
cecice:
't:-.e::. I:::-e 9:,ir:g
tr:at
t.~.=:',
~.O~ !<~c.".,
to p:-c,:e:t a=cinst
--"- "I - --
"""'- ...- -.':""
Ci:::
c -= := =:. i s~:.: r::-
sa:.:s
t:.e\,'re
r:ot ~ci::~
to let
~:: ~;.==.?
~~~. E :~: : ~. :
\-'"hat's
go].:"'.;
to t.a~pe:.
t::er.. I
...'e have to
deter~Lr.e an alt€~nate dis=~arge method or poi~t.
O:1e optio:,,:
would ae to have a discharge permit under the National POllut~
Dischaoge Effluent.
UNIDENTIFIED SPEAKER:
Yes, but the State is having
a very difficult time siting an industrial waste incinerator
right ~ow.
These groups could block you from treating water.
MS. AKI~:
~o, they could'tblock us fro~ treating
the \,,:a:er.'
U};IDE~':TIFIED SPEAKER:
They're blocking the governrner
of North Carolina right now.
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~:.:. .:.y: ~: :
~\'E 're
t~-=::t.:.::c
t :-. c ~. a :. e :- c :-'.
s.:.te
..... -c:.-c
-: . --..-
..,
~
c: --
t:-.E cr.::: t:-..:.::S
....:e I re
lC"':-~:':1C
:cr :5 a
C':'S::~.3~~E :c=
t!:E ""'.:t.e:-.
:i~E ~ayte i: yo~ ca~'t CO
tha t, r.-.a ::'~e
a:-. a:tE:--
.:
:"'.:tE ::~=.'=E ~i:-:E
:-,3::':,e
G r .:. ~ t s :!" e e ~:
c-:- s='!:".etr:i:-~g.
~
::~.::: :::~::- I:-: EJ
yo\..: .~'-=:--=
SP::.:',!-:E::. :
~~ u~cE:-st~~~i~S is
E
S2:::~ to ::~~:: it ~::
to or
it 'oJ:::
carry
tc Salis::,1;!"::'
~t'a S~;
'7
Treat~e::t :acility.
I'
~
~~~. .=-.:0:;::
sitE
,- -
:':-.E '...;a ter
~ill te treatec o~
9 .
!:7:::--= ::
'.:.::".:0:: +-"0
--_._- ""'..-
site
;:~=::ert:: ..
.:\: ::::::? :ED
SPE.z..t:'::;:\:
Ec~ can it be treatec?
'0':: ':.':"''',Or\o..
.--. ~_.'''''''''".
:'c yo~ ""'=.:-' t r.-.e
to reiterate?
:::.::: :::~::-::- I'::) S? ~..;::==F.:
I dic~'t catc~ it.
.. -
- -...,.-..
- - .,
- _0° - - ..
-:...,.. c::-_":_-.;--
..-- ----:--:;-_..'::'-
::-.ere is a
;:~-==:;:~.=.:-.~
--::::.=.
-..--- ..
:~e~E's a ~ic-re~e=i=~io~ s~=~e.
.;-.E~e ar-e
se':e r:::
s:.=~-=~
l~ :.~~ ~~€a~~E~~ 0:
t.~~:'E
',,,;a ter tc
re::-.:)':e
=.:l c: t::e
CS:-'. ~ a:-:-.~ !"4a t. ~O1'""6
do....':/
clear.1;p levels.
to our action
le\.els, ou!"
U~IDE~TIFIED SPEAKER:
That sounds like a plant almo t
Whose building is it and who operates that plant?
MS. BENOY:
National Starch is responsible for that.
It is under the administrative order consent decree which is
...-
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UNIDE~TIFIED SPEAKER:
That sounds like letting the
fox in the hen house.
!-lS. BE~OY:
Yes, sir?
j
j
that I
C~IDE~TIFIED SPEAKER:
Do you have anybody else
you've done this for?
Do you have an example of where it has
-------
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~cr~e~ :cr percr.a~ce so~e?lace else who has ha~
t ~.E: 5 a:,:"e
p~ol::e!:
a~.::: you did tr:is
a~c It ~orked, ~3S i~
t:-.e ~ro=e5s
of ~o=~i~g, or ~~ate~er?
~S. A!'::~::
~ure.
~e have grounc~ate~ t=e:~~~~~
syste::.3 all
ar~u~d the ccu~try,
Ca~:~ ::"'".!
particularly i~ ~or~~
\t.-r.e=e
~~ ~3~e t~e Cela~ese
sitei::
;. .= .: E
S:-.e1:;~'
a-...; ".:0
.'- ""-
.::ls~
the Saiyco site rig~t in Charlotte where we have the ;rou~c-
",,'ater
~reat~e~t system in existence right no~.
L~::~~:!?!E~ SPEAX~~:
It's basi.cally
sa:- e
doi.:":g t!:e
t:.ir.;- ,
fro~ ~- out fro~ u~der?
9'E:.ti~.g
tr.e poll-.;ti~r.
~'.~. ;..~::\:
Right.
'-'~~ I~,~~:::r lE~
Hov.' 10r.; ta':e
cc:~,;
c:p-'''--
- - .t...-_"".~r. :
bee:":
.. .... -..
;....f;; :
tr:a-: :==-
.." '-' u:
....':: ... .,.. T "'. .
.. --. roO.' -.'" .
Cela:-:ese has bee~ do::-:~ :: fer .::: leas:
c. :;€==-,
~-~ ~:a~ti~-~:a~i€tta
a;;;:: Sod~'co
:'7",0:-: ::-..
sta::-te::
u;: :£:5:
CKIDEK?IFIED SPEAKER:
I'd like to say o~e thing
about the smell.
It's terrible.
I don't understand why
I
I
they:
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,
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:
can't do something about that.
MS. BENOY:
Because we're required to record the
meeting, sir, I need to allow her just a moment or two.
BRIEF RECESS
MS. BENOY:
Hopefully you didn't state a lot 0:
comments that you really wanted to state to us in your cis-
cuss ion over the break.
It is important that we record r
~
, ,
50 if we can try not to have discussion and debate amongst
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ourse:ves, ~e ~ill try to do o~e o~ c~e,
a tl:-e.
O:1e at
It
is ve~y di!~:c~lt to recor~ it,
5:) i: we
could
i' . c: ..
~ -- -
:;e aware
0: t~3t,
ple::se. Yes,
sir.
Yot: ""ere --
L~::~~~I:IE~ SPEAKER:
to; e 11, !
cic:-.'t
k :-10\..;
',,'r.e t ~e::-
yc~ ..ere g:)i~g to take up t~e smell do~n there
t~at
the pla:-:t
g i ': e s c::.
: cc~'t k~0~ ~hether
-- C~
y'a::
de a~~'~~i~~ a~o~~
that?
~e call every so often to Mooresville, but the s~ell --
Idc:-. 't k :-, ::)\,,'
"'.!-, e t::e::-
it's the soil you're talking abo~t or
"":-,et~e::-
it's t~e plar.t itself.
V~
. .._'.
The soils that ~e have, that we're dis-
t: ':',.,...... .
..-_,.~. .
C"C:C:;-"" ~-
'-"- - _.1-::
the trer.c~ a::-eas, are too far beneath the lan=
S'..;~~~=e
to g:.\'e c~:
'::1::' e::-.issic:-.s.
J...:.y pla.::t e::-.issio::s or
s::-,e::s ::::::-
the:;
a:::d!:"cEse::
are ::ot. beinc
'~'!'"..=. te'!:e= ,
...,....
..- ,
Slr,
t.:.~:'E:- t:-.e
- ~-
~...:==e:-:''::-.= .
~.:?. :-:~::~E2S0~~:
Barbara, ~o~:d you kind:; re~in~ t~e~
agai:: to state ~ho they are and who they represent, please?
MS. BENOY:
Yes, could we please try to do that?
Ye
sir?
MR. JONES:
Vernon Jones, representing Stoneybrook.
In your initial remarks, you were saying that you consider
groundwater soils and air to come up with your 28.5 to
determine Superfund.
Now, you're saying air played no effect:
in coming up with that 28.5?
MS. BENOY:
There is -- in the hazard ranking
i
system ;.
I
I
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I
there is a part that we have to deal with the air.
Surplus
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~as se~e~ate= tc c~al ~ith or F~ssec into
: a....: to
ce=.: "...it~.
aban=:~e~ ~a5te sltes.
Active o~e~ations and
any :'..;:-.es cr
s;:;e:.:.s
cannct be a==ressed under CERC~A.
CE?CLA Su~er:unc
lS :c=
abandor.ec
areas, and
t~is
is a curre~t o?eratir.~
:aci~:~Y.
:~is trenc~ area ~:s ~se= as a disposa:. are:
;::"'i:J~ to --
.....el:, ot':ic'..lsly
;:-i::.r
to :'980.
S c y.':-. e:-, :: :: ::. : :.:.
was passed, that area was subject to being addressed under
CERC:'~.
~. I answering your question?
~::. .
;c~:=:s :
Yes.
Sa;..e scenar io
there.
:.:--.: s
c:r~-..:r.:
.l :"'.
surface poll~~icr. 0: the northeast drainage
5'.:'ste:-.,
oka!' ,
if it's
co~i~; fro;. theon-site or on-going operation, it's
-.~- ~!"'t';'r"-
..- - ~-_..~
to ::i::
CO':"2 rec by
~'~?erfu:1d ?
\'':: =~"-"'..'..
..-. -_.-_'.,0
I ~ ~ r::
\.. ...-
~e::-:~
cc~erec ty S-..:~er:u~=.
~:;;.. J:~:::::.::
Cka::- .
~C't"\. ,
i s t~ere an::<:: ='=::.
;: '~~~e''::
.. - --
-... "-"-'
the c~rre:a~ic~ be~~een a syste~
tr.at is cesi~:-.e~
-- .,....-,;-
\....c...-
o?era~ion is designed to disc~arge into the atmos?~ere
a!1Y-
thing from that plant.
It is a system design that if it
fails and there is an explosion, the pressure valve will be
released into the atmosphere.
This is a possible source of
your northeast contamination.
That whole building is desiqne
as a non-containment building.
It's designed to blowout.
That was in the Salisbury Post ~hen the valve Flug about
I
two years ago did not release. Has anybody correlated that? I
MR. PARADOWSKI: If I understood his question, '1
not -- that's part of the active operation of the plant. Tha,
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.....::'~. . t be
ad~:-eS5e.:::.
..
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~~~ .
-. -".r'\."
b:.....'-: :
ad-ere s see u:-..::e:-
CERC:'.~ .
:--::.. -:(::£S:
ti~r;,
c:::-.ta:7".:.::atio;: of
~~s. .!..:::~'::
53
The acti~e o?eratic;: is ~c~
t-=:~.~
I '~. 0::
t:-:e nort~east.
"\..;::a~
t......- "-
PC::'':.
I 1:- 0:'.
the ;:crtheast tre~c~es.
s~ ""'~.a t :':::-'J' re
F!"O;:'C!:: i:"'.g
to ~s
is t.:--.;~
the cur~e;:t scenario that you just de$cribed may be the
SO',HC€' 0: the
co::ta;'-.i::atio:: of
Is t:--.at
",,':-;a t
,.-"..' -c..
~. ....... - --
sa::':nS'?
:-:-:. .
-.-.,.- c:.
":V.\:'_:
~:= .
;..:~:!~~:
the su~::ace ~ater?
Yes.
Okay.
to; e 2. 1 ,
that's so~et~:::~ ~e're goin;
to ha ':e
~ : J.:-:-":
at i:-; t~e
l~o1'..e=
:".;. -: '...::-e .
Ke ta':e:-. 't
:- e a 2. ~ :."
~~~c :~E: =o~;:e:el~. ~7et, b~~
. . .
s:ce~a-;:..:::-.
-. .
a :-. :: - ::.:: .-:
V-'€ ~. :'11
take
t:-.a:
'~:-.=e:
co:-,-
~-~-
-.. -......
...----
'-.....: -
~ '...
0: : -.
i':e do;: 't je.=.:
~~......
--.. '-
.. ..: +- \.. ~ \... -
.,.. - ...... -..'::
~=~i...E ;~a~t per se,
St~:-=~.
bu~ ~~e
e ~~ t ire ~ : at.:' c :-. =. ~
site
is o~ t~e S'Jperfund list.
~e look at all the SQil su~-
face water around there, so if something in their current
operations is causing that surface water contamination', then
they're going to have to address that.
MR. .:rONES:
You should look at the conditions and
the way the pressure leak valves are set up.
MS. BE~OY:
MR. ~GLSON:
Okay.
Yes, sir?
AI:: red \\'i 1 son.
In speaking to air
quality, initially when National Starch begins ex~racting
!
water from the contaminated area, the plume, it was said thatl
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It WC~~ ~E ~rocessec throus~ ~r. air stripping
O?eratlC;;.
Is t~a~ ~~e~ t~e volatile cr.e~icals and organic CO~~o~ncs
are re:e: see
ir.to t!":e
air,
or w~at happe:;s to those~
;'.re
.'
i
t::ej' rs.easec?
Do t!":ey !":ave to have a per~it, air cise~arse
Fe~::-.~ ~, : cr
o?eraticn,
and !":ow will EF~
that
ac::ress
...--.
t.....'::' - ,
"
a :--l~ 1::: :.:s
bei.r.r;
in a nor.-~a~TIe:;t area, will it have a;.~ e~~ect
on tha't?
~:s .
I'm r.ot sure I got all o~ yo~r
~'.:es::io:;.
E=-'''!1V.
_.""""''' .
T~e f :::s:. ;: a:-t
duri~r; the air stripping process,
v ~ , ,
n -.-
...;:. c:.
""--
"
these ID~ta~i:;a:;ts be release:: into the atmosphere.
'I~e
ar: sv,'er is :-.C.
':'he s:;'sterr. is designee to cO:-.t,nn t!".e conta.::-,i-
""--.C
..='-.. --
",.:..::hir. ";~e
goes through act1~ate::
ca=:;c~
a1=,
a!1C lt
=-= --
--.-..-
:-.2:' r;e:. the
E ~'~ :: i -: i c s
...... --.. --
- - -.. -
c: :':-.e
c.e sir;:-.
- ...- -..-
::;'..:t :.~ is -- they're c:pt...:re::.
They're
not release:: i;.t.o
t:-;e a :.::-cs :::-.e re .
Tr.at's the -- the Clear. ~lr Act t~at's goir:g
ir:to e~ec:. is also going to be one of those stringent re-
quire~ts that we have to adhere to.
Just because we have
our OW1 law for CERCLA doesn't mean we can ignore the other
laws.
Yes?
UNIDENTIFIED SPEAKER:
I have a comment.
I would
really like to see some wells on the northeast side.
Anc. I
wish ~re was -- rather than wait every five years to co
a studl' on the groundwater and the surface water, 1 woulc
like t~ see it done at least every year if you think it co\
J.
be do~ that often.
If that wouldn't be possible, then I
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d:-:--. ' t.
see \,;:;:: ::':)'''': c.::-.' t cut i. t de...';") to e':e:r::'
t.,.;c a::d a ha 1 :
yea:-s at
leas:.,
a~~ eso.~_c...~c-'_'l'_: t~. E f_~rs.- .&e'.' r ~.
;J - .. years o. tl.1S
t::l~':: 5 .
it' s e~\'io'..:s
you h a .; e a sit e
~ :;Ole.::-.
here rig~,t
",..i.t~ir,
t~le state,
.ar:::: it's
]'e:..
;".5
too soe:1 to te~l,
to ~r.o...'
j~st
a. r,=9ice:1~,
I'd really like to see reallv
sO!':1etr.lr.~ -- I'd
. .
:'€:=--";"
li~e to ~~c~ t~is
ta wc~~, a:'"i::
is ...;o:r~ir.;,
sta~tins
that it's not expar.ding.
Just a cornrnent.
~:2, E~:: :'~':
0.'<:3:;:.
Yes,
sir?
l.,...-~~,._- ':""T~-
.""'-'-.'--" ---
I:-. rE~ar=
£ ?E;.:--:::?:
to the
~o;")ta::-;i:1a-
tior. o~ t~e va:~es
~r. t:-.e sur:3ce
~ate:-, ho~ ca~ t~at be
:0-'::-:':: at a
;:ci:-.t i:-. t:-,e
S trea::-.
at O:1E locat~e:-: or. the
site,
--- ----
c...- \""...CoO"
as i:.
o::-:;ite,
disa~::ea:.-
',.; = :.e:- ?
: ro::-. t::e
: - S'"..; E
~". :-. .= ~
:-.=-?::-E:-::
cor: --:a--:"'.i:-.a ~ :O:1S ?
tc :.;:cse
~:=. =~:: :'~':
':"!-'.e c:'..:estic:-: is
=- 1:-::' :-.ig:-. cc!:
:-.0"' ca:-. J'O~
. - .
ce~~==~:s~s c: c:~~~~~
~o::-. t
"'r ..'--
~.... ."..t::
:- =:-. ~ a::-.::'"'. a:: t 5
~:. o:-.e
strea::-.
a::c t~e;-. --...
see it or see less
do...'n-
concentratic.ns
stre~?
UNIDENTIFIED SPEAKER:
Well, I believe you said
earlier that none was found in the surface water after it
flowed off-site.
MS. BE~OY:
The nature of the chemicals that we're
I
seei::g are volatile. organics, and predominantly what hc?pe~s I
is ttat they evaporate.
If you have e~en certain household
che~icals, you can smell them because they volatilize.
They
evaporate.
They go into the atmosphere.
The same thing
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56
It's l~ t~e surface water,
and beca~se 0: t~e
~8ve~e~t 0: t~e ~ater and because c: the surface c: t~e water
bein~ ex?osec to tr.e air,
the na t:Ire
0: t~€ \o;=y
~:?. :=::\~::~T:
t~.a t .
If yc~'re ~alkir.g
it cissi?ates.
T!-.at's
it eva;>o:-ates.
that che~.ical
be~a\'es .
Dor. Pruitt.
I would cr.alle~ge
Y':""; C:-.
about aceto~e, alcohol -- b~t ~, 2
c~loride be~ze~e, you're talking about ,a c~lorinated ring
c:>~?ot::1d.
It ~igr.t have a boiling point of 250 degrees.
~t 's n.:>t
~oi::;-
to ::ash of:.
?-..C ~ ':"'''' -I.'; .
....-. --...- - .
~e=:era,"-
terr.s.
:'hat's
~.= t::=..."!'--.
..... ......,....... - .
::.e:: one
raje!"
c: t:-.e
.;::-.:: ::e::ze:-.E.
~'..5. =~~~: ~:.' :
v- --..--.,..
1 ~:;\ . t'" ~ ~ - ~ - :
MS. BENOY:
I was tryi~g to answer the questio~ i~
wha~ ha??er.s in surface water.
?:-.e e:ig i :-.eer ing
ge~tle~,a:-;
just
iC€:-.t.i-
co~ta~i~:nts as 1,
2 d~" ~ :-.1 c ~ .:.:: E
r,et..-':-.e
Et:-,ane.
Ethane.
1,2 dych1oride. ethane. which does
volatilize quite readily.
UNIDENTIFIED SPEAKER:
How about the heavy metal
stuff to be present?
heavy metals?
Were they found one place downstream,
U~IDENTIFIED SPEAKER:
No.
C~IDENTIFIED SPEAKER:
Were contaminants founc in
the sediment in a stream bed?
UNIDENTIFIED SPEAKER:
Volatile organic compounds
I
we1
I
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yes.
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C~IDEX7IFIE~ S?E~KER:
50 that also has;.'t been !c~~
~ ,
to ~:;rate do~~st~ea~?
.:
~XIDEX7I=IE~ 5?~AKER:
I would 1l1
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!.
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t~E co~ce;.trations ~e sa~, residual
co~ce~trat.i'
~herE -- at ~e~~:s ~here, you
:0<;'0"'" ,
~:thi;. a fe~ years ir.fl:-
trat:e!'\
i":se:f :-::.:ld
soils.
rid those cer:ta~ina~~s fro~ the
I
So~,e c:
the other o~es, like the 1,2 dychloride etha~e, ~~::~
i s v,':-: 3 t
I co~si=er tr.e predo~inant co;.ta~ir.ant 0: this
site,
t:-:~~'s a~
S:~E :-:i~:-:er levels, but as ~e're
the :: ~-::
saying,
and trea~ action could take, you know, decades.
It cou:"d take
I!
2~ 0::- 3(' :~.e=:-s.
! ~ean we're looking most likely at a ~i~i~al
"
0: 20-plus years
for that tYFe 0: process.
That's 20 yea:-s
allo',,'ir.q
:-ainfa:l
in:iltratir.g through these seils, and tr.ere
are ',,'el:"s,
I rean these are the -- the tre~=~
as yo,," ca:-. see.
a~e.=.s ~'-==e
:ri;:-.~ i~ t~.:.s
These ~ells are riqht
t.::e=-~
area.
7r:e E =.;-. ~ e
c ~ t~.:. s ::-. a?, I
~ea~ tha~'s 500 feet there.
':'r:cs-;;
',;e 1 :.. s
i:-. that
~s t.he co;.ta~inants are
~,;; :'-e:-.
a:-e =-:g::~
ar€.=.
c:: b:: ~:-:e
::-ai:::a:;'l,
they're gei;.s tc be tra~e_:~
in:i:-;rating
\"ery
shor"; distances to be extracted by those wells latera:ly;
If they're traveling vertically, we know that contamination
is within ten feet of the watertable.
The levels we're seein
are pretty much within ten feet of the watertable.
We're
seeing levels between 15 and 25 feet in some of the samples
that were taken that had contamination.
The watertable is
just over 20 feet at that area.
UNIDE~TIFIED SPEAKER:
Will the contamination have
to continue down until it reaches the watertable before ~
see the concentrations diminish?
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59
~R. Ml'ZA:
It's gQi~; to ~cve i~to
t!":e ""'3 ":.E:ta::le ,
a:1C at
t~at pci~t it ~ill be trans?crtec to the
ext:a::tlc;,
s y s t e::-. .
?art of
\-;~. : -;
the gro~nc -- ,that's t~e ~hole
t!":i~~.
...'e I re ccing
here is letting
take its
co~rse
. .
a::c ~e~t~:-.;
na-;\Jre
the gro~~~~ater re~eciation syst€~ clean it up.
T::at's
~.:-.a t ' !
~~ir,; tc
=0 t~e ~ajcr part c: tte clean~?
~~IDENTIFIED SPEAKER:
Basically a leaching.
Y'ou ' re
just letting it leach down ano then you're ?un?ir.g t~~
:eac;-.
II
o'Jt?
X:=.. M::Z.:'.:
R:ght.
It's goin~ to ~ix ~it!": t!":e
g=ou::::-
v,a te=
part of the g=ound~ater
p~o=le~..
0:1:: .::e=or':'",e a
~:.: .
E~~::'.;.. :
t i::-.e .
One at a
:'::.. ;-: "-. :: ..:. :
.;t t~.;'s
:=Ci:l~::,
~hat ~e ::a~e, ~eca~se
~~e ==~~;~:~at:o~ is
5:..:~s:.:=:a:e
sc:.l
- -
a:'.:: c:=:,-...:::=-
co:: -:a~.i :-.c: 10::
. . - - - ,,-
'" .::. -"=-
C=:'".~.:~.:.~..::.:':C:-",
't~.=-;'s
t:-.e rc~te
- . .
0: trans?==:, :~~
g=o~no~ater, and the
that's being
I
p~t ir., tr.e r.at~ral I
s~' 5 ~er-.
leaching is just letting nature take its course for what
residual soil contamination exists out there.
The ground-
water extraction system is going to clean up nature's product
basically.
UNIDENTIFIED SPEAKER:
How much volume of water are.
we talking about here for each wall?
!!
MR. MUZA:
Pumpage rate?
Offhand, I forget what
they're proj~cting.
UNIDENTIFIED SPEAKER:
Do they run continuously?
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Yes, u~less -- yes, ~ith the
sltuatic::
ce:.ns :.:.
be=rcc~, cur:r.s the
s~a=-tu~ ",,'e ':re reall~:
i::itial
gCl!:S ~ ha':e t~ dc sor..e !i.onitori,.S tc see ",,'hat type c: ra~es.
y:)u k!'l:J.,',
attainec,
and in ti~es, in this t~~~ 0:
car. be
s::'.3 t-2:7..,
t:-.e re
a pause
p~~?i!'lg that r.ight
:':'".a:: ce
r.a':e t:: be
l.:se~.
t;--.a-: -..;c'..:lc
~oulc be, you kno~,'
. -
?~~.::::. n ~ :::
.. .... -...
9't..C ~
mean
days 0= weeks anc then shut off to let the system rebound a
lit~le and the~ ~~~?age again.
That way you're surging.
'1 c''.,: I re set,:i:-.~
sc~e w:)ve~e::t, al:o~i!'lS some ~cve~e!'lt C~~!'l-
srade
;::.:...-pi :1g
out, because the bedrock setu~ li~e
~:1d the:-.
t::is,
=here's ~i~es ~he~ you
can hit an area ~here y:)u're
s:et~:':l~
ver~' ceo::
c: v;a:.er,
yo'..:
::~a;.ti ties
and othe:::- tir;,es
...=; -.,- ''''' "'!":::.~
.......-... ~ ':-....
..\-...-
...... ~C .... ..
..,.~- -::-"._-:- -7'-,
'-.'...--..--. ---'
---......--
::- ~ :,~.~=-:.:
"'rc:. ~~~,..-
.- -..-.<::
qo:.r.s
t~ ;...- -
- -<:: .:;
:.~:: -
1",..-...':;:
~-C:~-.
~-_........
~f""" ...::-. ...j....";c::
\..- ......- ......--,
yc~ goinS to -- ~C~
:'5 .:.:
C~ !'1~t..; c.::-~
go~ ns to be
sta:£ed
to handle that i: these decisio~s
are
going to have to be made on a timely basis?
Are you going
to haTe someone drive all the way from Atlanta and say:
Well
it's running pretty good today; I think I'll leave it on?
MR. MUZA:
Well, it's an automated system, but there
will be monitoring done on a regular basis, and the key ?a:::-t
is the monitoring that's going to be done.
Later samples
are taken, the water level data is taken --
'.
UNIDENTIFIED:
By EPA, or are we talking about
Natioaal Starch?
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=.:.L 1 :
~atior:al Starch.
T!:ey are
!"e:::..:::-e=
also
to contact us
t~ere's a ?ro~le~.
ste? o;.;t,
~€ don'~
¥we :-. e :;
J\,;S:
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"
0: the ~icture.
~e're i~~olved every ste; 0: the
"-'"c y.
Yes,
sir?
~~I~EX::FIE~ SPEAKER:
"'hat assurances
de ~'o:.; :-.,:':e
0= cata
0= i..ceel i:-.~
that the do~nsraei~g c: the
\o,'e II s '",'2:-. t t
increase the sF=ead of the co~taminants, the pl~~e,
CO:-, ta::\i:;-
a:.e:.
::1 u..~.e, c:.-a.~.i:1g
into, say,
:lc'~; 0:-
a~ underground ~ate=
s~~.e
ot:-.e=
t.:~:.e=:;=our:e
Is that a possibility?
stre=.:- ?
W':; \~..:- :. .
. ...',. ...L -...
In trois
setup,
you kno~, t~is syste~ here,
\,'e are
tasi call_' j \.:st doi:ig p~'i.page around tr.e so-...:rce.
This
s~'s:.e:- :s
let ~i :'"'.~ t:--.e
na :.'~r a 1 f: 0\0,'
the co~:.~~i~a~~s,
brin:;
.: :. c :-. ~ ",,;:.:, :-.
&",-1""\-
- - ...I..,
tc, -::-..=.~ :::i:--.t
-::-.~5e
:: 0\..:= \o,'e:: s ,
s =~.-c
;:';.:.- ;: = :: €
s:-
~hE~. c=~. te -:.ak€-:-.
It's basically
set:.ir::;
t:-.at
..- , ,..-
~: -'=
o\,;t..
;.:= a l:a==:.er
::ere
these '...'e12.s.
we're gc~~~ tc set
t.: ~si~g
up a
barrier, and as the groundwaters flow in fro~ here do~n-'
;
ward, headed that way, it's going to get taken out.
It's
going to be captured at that point.
UNIDENTIFIED SPEAKER:
Well, I understand the theory
They'll draw the aquifer down.
MR. MUZA: Uh-huh.
UNIDENTIFIED SPEAKER:
I
. I
Creating a pressure or a vo~d'
that the ground~ater runs forward, but it seems that the
potential is there to increase the spread of contaminants
toward those downgrading wells, and if you have movement of
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S3\' laterall\'
- - ,
gro\,;nd",'a ter,
througr. so~e vault o~ fractL
. .
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the bedr~ck, potentially it ~ould see~ like a risk to :\,;rt~::
:'
t~e conta~ina~~s.
s?rea:.
.
~!S. E:::~:O"i:
That's ~hy a lot of study goes
i::~= t:-.::
b€:o~e
t~e ~esig~ is im;:emented or even put o~ the table.
:~e per~ea~ility rate, the
direction 0: the ground~3ter :::~,
it's very much engineered.
We try to anticipate proble~s.
~e can't gua~a~~ee the proble~s will not occur.
But t:-.a t ' s
..;:-.',' t;:e
~.o!':i. -:c:- i:"l~
Frogra~ is so extensive.
L\I~:::\:IFIED SPEAKER:
Eave extensive geological
S'" ""',"c".c::.
io.o&- .. -.- -
a:-:= s~.s~e~1
studies been do::e 0: the site, on bedrc:~
at the
site:
~.:?. ~.: -,.": .:.. :
:~at ~as all ?a=~ c: t~e re~E=ia~
i~.:-==-
ti~=:.i8:-. .
st-..:idies
-\-.--..
~...=.~ ':
c.one i:-.
the desig::
:r.ere ",,;ere
!':"'Io~e
=-=>-.
i-:. d i!; r e ~ a ::- =
question on modeling,
I ,..:;,"::
""_...
t~ Yo'..lr
in-house modeling on this site, putting in these extractio::
wells and using a computer code called Rescue, which will
develop capture zones for the wells, and at the projected
rate of extraction, it shows that the capture zones' are goin9
to be there to provide a wall along this point.
MS. BENOY:
Yes, sir?
UNIDENTIFIED SPEAKER:
What's your spacing of the
wall with regard to the wells themselves?
MR. MUZA:
The wells themselves?
UNIDENTIFIED SPEAKER:
The containment wall that's -.
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Sa sic all::' less t~.=:; 500
~:"'ZA:
~eet, s:>~.e'...'~.e:e
In
t~.at
t::;I:)t:~TIF:=::> SPEA}<:ER: ,That 's t:-:e de?t~.?
~:=..
i:;to
MCZ;'. :
They're
the t'ecrock.
The::' 're
- --
i'
i:-:~:, the
bedrock.
L":;IDE~7IfIE:)
S? ::::A:-:E?:
I k:;~~ tr.e bedroc~
~s l'S-sE
t.han 20 feet.
Ho~ far into the bedrock?
You want 100 :ee:,
28:. :ee::, 500
:eet:
~~?~. ~ :.: z.;.,. :
The co:;ta~ination
the r.'.c:;: tc= :::-.;
:ro:c\
.,.,. e 1 : s i 5 see n - -
ir. bedrock asui:ers, the most :ractures 0:
t;.: ::-.05-:
~e=~ea=le zone for flow is in the uF?er par:.
50
~:-.::'~~ '-h-il2.
be screer.ec withir. the u??er regi~:;s
0: tf.e
be~~~=~.
.: cC:-.'-: --
: ca:1' t :-.::':"".::=ize all tr:CSE :;'..:..-:-:.be:-s.
I I~. s:~=-::.
~~:D=:~7IFI=:: SFE~~E?:
Yo...: said yo'.: did
. .. ...
C-.€: ::-,oce~::-.~.
:: :: ',..: C e e ~
-- .,.,.tat I s
the cone 0: ce~ressic:; o~
tr.ese?
~:;. MCZA:
The best way t.o ans~er that is the pro~r~
that I used produces.. a capture zone.
The cone of depression
doesn't always give you the answer.
You know, people sit
there and they use certain equations and say:
Okay, this is
thernid-point between these two wells based on this equation.
: Now, if we get one foot of dry-down froIT. this well, one
foot from that well, it should work.
That's not always the
way to do it because you have to use the slope of the
takes into account the slope of the water table.
i
I
Based on thaj
watertable also, and the program that I worked with, Rescue,
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F=c;ra~, I could~'t tell you exactly t~e
co~e 0: de?ressior
anc r.o~ :ar t~lS co~e 0: de?ressio~ fror tr.is ~e:: ~lll exte~d'
i
I
fro:.. that \o;ell.
~~at it produced ~as a c3Fture zo~e t~at s~c~
the capture zones fer each indi~idua: we:l were o~erlaF?ed,
a~~ l~ t~~s entire area, let's just say in generic ter~s,
t:-. is
e:--~:=e
area :!.ike this
was socked in, was ~itr.i~ t~e
capture zone of those four wells.
And that's what we were
;,
,.
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18:>:'-.i:19 at.
7::a~'s
...:hat ",,'e ",,'ar.tec
to k:-.::'''''.
Tha t \...a::' t1-.e
I'
deli:1eatec is within that capture area of those four
F: '~~.e ".-:e
p
- ,
""'E_...S.
l"~: :JE::\7I?IE:=-
SPEAKER:
You car.'t give me a ballpark
:-:~~.;:e=
C~- r-.~'~' ~ee~
:.:-.e ....;ells are
to be?
go:.. :-.;
....:: V"--.
....... ..."-'-.;...
::: :orgot.
~::=. .
C =-.:.~~:? :;c':..:: :
Abo u t 1 8 5 : -= e t .
L":~ID:::~:I::i~: SPE:?-.KER:
\'::-.0 .::. =e
you?
ME. CLi'.YPOOLE:
My nar..e is Joe Claypoole ~ith CD~.
w~ile they were doing the remedial design, they put in several
bedrock wells and they drilled down to approximately 200 feet
below ground surface, and the fracture system -- basically thE
fractures -- you get less fractures with depth, and down to
about 170 feet, that's substantial fractures.
Below that,
you hardly saw any fractures, and therefore, the aquifer
doesn't produce much water down there.
That's pretty much
the extent of the aquifer.
There would be no reason to
wells below that depth.
That's the reason they're above the
-------
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Sorry, 1 sho~ld ha~e stepped i~ soc~e:.
2CC-~oot
Y.S. B~~C':.":
T:-,ai.~ l'c~'
cc r, t a::-.i i.a~.";. s
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L~l~~~:lFl~~ SFSAKS~:
nO"'" deep :-Ia':e
bee:":
:ou~= i~ t~e aqui:er u~=er the site?
6e?t.:-., )" :,'.,.
Jo - -' .
1". -.,.
1 do~'t ~no~ the specific
~'.:= .
~.:-.: Z r. :
a~d t:-~ere ...:~ =
c: these wells are bedrock wells,
,-,,,.. a r.~~;:.e!'
I would ha~e to get
contamination detected in thOSe wells.
c'.;t t:-;e table.
I mean we're talking. you know, there's 24
wells
cu:. c;. t:-.at
site.
~~at if yOU put the l8S-foot
~:;IS~~~!FI£D SFEAKER:
YO'';;' c:e";.
corlt.a~;ina:",.ts
.e::S ~~ t~ere a~c yOU pu~~ it until
.~ i :.:. bE :. ::-,." r. t. c'
,..,.~
-- - ,
a ~. ::: :. ~. E :-.
e.;e:::. '.;31:" Y t:-.e
co::t 3;.,i r. a:-. t 5
ccr~e:~?
~c=' :eet.:
15 :-~.a:'
rouS;~ll::.
t~ ~.c.\:e .~.... t.~.
...ill
tE:"".:".
The co~:.a~i~atiO~
~'.::.. ~':::~.:
-- ""':" :.:-.
",,'e:' is
:ractu:es
t~.e
;::::~~6~at.er :lo~, a::c i:
~ -, -
......t::
like thiS .ith becrock area, yOU ~retty much woulc use a~
open section throughout the fractured bedrock.
If the con-
tamination is within the upper 40 feet of the fractured
bedrock. that'S the way it'S going to go.
I mean I look at
groundwater flow and contaminant migrations -- it'S energy.
And it'S going to take the least. YOU know, hardworking path.
22 l'
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It'S going to flow horizontallY within that more fractured
interval rather than being sucked downward. and that'S
I
.ith this type of setup yOU get a large open area that yOU 'rei
Even when, yOU knOw,
going to be pumping the water out of.
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FEople have a ~c~estic well, yo~ ~a~ have to d~ill t~at ~~
"
200 :eet
dee;::
:eet
a~~ ~'ou ~ay have to have it o?e~ fro~ 10:
,:
to 20:
fee t ts
~,~ -c:.
.. - '"- c-
'"'a-." J:"'ac~""'ec: - " .
... .'OJ.. ...u... - as :,CSSlo.e
to get
e~.='...l=t.
~.
I.
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~ater to exist for, ycu kno~, daily CO~5u~?ticn.
It' 5 t:--.E
S,::.~e type
cf t:--.i;:~ ::ere.
p.ret ty ~..~.::-.
T~ose ~e:ls ~ill te
o;::e:-.,
a;:d a:;y
zC:-.es 15 ~:::..;.:;
cc:;ta~.inatior. i:1
the different
I'
,.
to move horizo:1tally through those zones to the discharge.
t.:\: :~~::::- IE:) SPE';KE?:
It's just ass~~e= that dow;.
to 170
feet it's all one aquifer
a;:d abo~e that you assu~e
Ii
the co;.ta~ination
extending down to that level will be pl~.e~
I'
fro~,
t r. a t 1 e \: e : ?
~:::. ~:.::.:...:
::-.a t 's ......ha t
Basical:y i;.
I'::; sayi:1g.
~ ::--E~. =:-.
anc the
tr.ey're
tCta::~'
be::roc~,
t:-.-= s=~:-c::. ":€
~=~~=,
i:-.-:e==c:"'::1ec:ec. .
-::-.e =ec::a.=~e
ZO;:E.
':':-:e
::-.e sa::rclite is
CC~t,::.~:..~stic;.s ~ere percolating
a:;:: the waste ~ater
C 0',,':-. ,
!
was ?U~ ir: a
trench, percolated do~n through the saprolite
into the watertable
and the saprolite, and continued to work
its way down into the bedrock.
And that's the data showing
that the contamination moved down into the bedrock wells, and
that's the permeable zone where. horizontal movement princi-
pally takes place.
MS. BENOY:
Yes, sir?
C~IDE~TIFIED SPEAKER: It's obvious that Kational
Starch has hired some consultants.
I don't really know w.
they are.
Are you dealing with these consultants?
Are they
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~~.. -,- .-
":' - -. 0"':; ~-
~ f h" "
c..a:-se 0 t 15 r..or.lt.:.ri:-.:;
a:-.c
~-= l:":
0: t::e
v,'E:: S,
1: t:-:ey are,
"";f.': are they?
Sorry,
y~u gave ~e SO~E
:;"".:~:~:s
J,....q. ,.
~- "" -
..:: ~ ...: - I ..
--;...... ..
\.:!1dersta:-:c.
.... ~:. ' i 11.
.. -- --~
x.:.
S-,._,.
~..'_'l :
T!':e c;uestior.s
ar-e \I,;!,:c t:as
~a t.i.c.:-.a:
- .
~ :. Eo =- =-.-.
re:ainec as their consultants
a:1d --
r..:~~::; =:~::::-! =::'
S?E":.i-:EF. :
\.::-, at
t~e::.. be
\I;i:l
Cf..:::-~~';:
mO:1etar-ily?
Is that a tricky question?
,
I,
\':: =.:-".._\..
....... --.--...
Ray, wo~ld YOu like to address
t. .-.a t
q:.Jes-
tio:-,:
:-~~. Pr.:_:':;O\.,"S}::r:
Yes, Ray raradov,'ski fro:7", ::ational
c--,...-'-
....\"..:..,-...
i':e r.a \"E
I~ternat~or.al Tec~;.c:ogies Cor?orat.io~
e::gage.=
c. s =: '-.s''':: :c;.:--::.s.
:'!"'.€~: a=e
one of t!':e ~0S: quali:ie;:, : t~i~~,
c:;.::=::--.~.=:-.ta-
a~::--.=les :r:
co:-.s'~ltinc; :lr~,s. ::-.E~'
the ar-ea,
:-,=.':e
~~~~ ~c~;::~~ ~:~~
a::::
.. 0': .
- -- -, ,
:..:s, = ~".:es 5 ,
: =- ~:-:--. --
S~:"".CE
e': <2:"".
=E:=~~
~r.1S.. .
(i:-.au:::tle)
':":-.€:" ~-:::
v,'E-
be, 'u:-.:e:~
:-. a ': e
so:-:;e fall:;:; out
of some sort,
to the best of my know-
ledge, they will be working with us through the construction
of the entire facility and then assisting us with whatever
monitoring is required by us in conjunction with the State
and EPA type agencies.
MS. BENOY:
Thank you.
Yes, sir?
MR. PR!:ITTc
Yes, I would like to make just one
co~~ent and then I'll shut up and everybody can clap or
whatever.
What bothers me -- and
My name is Don Pruitt.
I think more or less this is the -- if we take away the
-------
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68
. . .
C~r.s~lt~ng eng:r.ee~s,
..~.
....;lS
is ~ore or less j~st a
~-..;=~ic
relat:cns e:for:.
! think we've ~re~tv We" S=,~
~ 4 ..- -...-
::-.a: .
T!':is sta:e is a:-.'.-,.:~;ere :ro:c a
ye=.r
to ei;~teer. ~cr.~!':s a~a~ ::c
..
1\
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not bei :-.; a!: Ie
~o co a:1::"tr.:r.;
:,.."i th
t::eir
ine~stria: ~a5::.
- '.
They car. --
as ?ros?ects look,
a:::: :~ 5:-.:':: -
t:-.e::' ',..;:11 not be
E
it o-..:tsic.e t'1e
bc~=e:-s
c': t~li 5
=0 :--.c e:- :-. =: 7"'".-2
state, a:iC ",,'hat
ane what
concerns ~e with you folks is you're so s;:in~ere~
8
:::t.o di::e~e:-.:.
that i::
~ontr.5, ~it:: ~hese
. '\...
el.g..teen
q :c,-..:;: 5
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-y-..-":: -,....~
c:.- '- ~.,h... c...-
:::, no,
~O, t~e~.'=~ sa~.i~;
9ro~!='s ::"1.::-.:".:' :"'I~
c:. -.... ..........
-Q4...J,~
to store t::is st~~: abc~e
gr01;:;c.
like in recyclinq, like yo'..:
i
~o a:~ir.~~ cans an= ne~s?apers ar.e clear glass.
v;-=::'l, the
~as~ 40 tc 50 ~.ears ~as S~O~~ t~at does~'t ~c=~:,
so:: ::-.
E~~~~ee~ ~~~:.~S, a:: ~~es~
:c=~e i:--.='~5-::-~al
- - "I ,..-
"== - ...;. ':
F-a~.":s =::-e
t:;J bE
g~~e~ ca~~e t~a~c~e.
t.:-.e::.':-,= ~..::::
1:-. ct::er
...~:~:,,=s ,
q;:;:,;:;
t::) ha.\"e a:;::t:::;:q tc CO t~t e:.:..-:-.:: i t o~t
-. -... -
:~e~= a~=
i- .......-
-"" ""'.~t::'
cig trenches ane d~~p it in the rivers.
A.nd what are you
~ people going to do then?
I mean you can't even get the
people from Mooresville, and I feel for them because if they
come out, ~y're ~as~ by other people, but, you know, this
is my concern, is that, you know, we're down the road here
j anywhere from five to fifteen years, and you corne in here and
"
22 Ill; yo'~' 1, ntroduce
- possibly new evidene that they're still -- they
Ii
23 II still don't have control over chemicals on the site. And
I
24 I
I then we're looking down the road to a year to eighteen mo~
c
.
,.
10.
1/1
2S
liS
from now when the State is going to say:
Hey, National Starch
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hey Hoescht-Celanese, take care c~ yo~r o~n ~aste.-
T:-.ere's
2
0:-. ~ :'
It. en t~e
t~2 a:ter~ati~es.
They ei ther b'..:r~
it, s?reac
3 !
siee
roai or try tc incinerate it themselves, ~~~c~
0: t:-.e
J .
is the sa~e as burning it, or they dig a hole like these gu~s
:
c::. a~:. ~~t it
t!-:lni< we're,
i!", a trend:.
Ane, yeu kno~, I
6
yc~ kno',,; --
it's unbelievable that five years down the roac
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anc ob\'iously this is not O:1e of the more critical site s,
but : i \'e years d o..m the rcai, we're still talkir.; ar.:: '".;e' re
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stil~ saying that we don't have answers, ane, you know, I
;:ity
Y~i.1:-- :0:: ir:
trying to keep up with these sites here
in :\ert~.
Ca~c~i~a ~~~~ i~
e:g~tee:. months these
;:€ople - are;.' t
--.. --
-w--..-
tc r.a'.:e
~:> p~-: ~:-.e:r
',..'aste.
i:.:-. ::"....':-:e :- e
~:.: E:::::~ .~':
:~:=. F';:"'"...:i t t, :",'c'':
-::-.=-: --
a:-e rigJ-.:.
,,- --.----
. - - - .
....'. ...--"-'
:'et ::-.e
a=c. '::--.e
cO;.~":1en t .
7::ere's a
~e~::E~.~~ ~~: i~~~~i~le~ ~~~SE:~
as ~c:-king :or t:-:e EF~ ~t=
ca~e :'0 t:-:15 cou~ty ane was paid sorne~:-:ere aroune 520,000.00
i
i
by some of these groups, and came here and said:
The answer,
is to store this waste above ground.
Well, my friend,- that's
what we've been doing for 20 to 40 years, putting it in barre:
and burying it in the ground or digging trenches and burying
it in the ground.
The answer has got to be if we all -- our
jobs, their jobs, my job, everybody's job in here, depe:1ds
on industry, and there has got to be a way that you people
have got to convince Bush and his cronies to give you enough I
money to go out here and police these people, because in
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E ig!"! tE~. rre;: t.!". s, t!-.ey' re not
~oi~g tc havE a~ythi~s to do
!;
"
A:,,~= tn,;.
b;;t g,:i~.~ c-.;t.
,. .
a~j= Clggl:1g a
t:-e~c!-: a:-.d
b-.;:-yir1g Ti',ore.
are ~'e 5:i:1
28 :::ea:-s
: ro;-,
noY,' gcir.~
to be
cOr:iing bac/.: :":-.
..
he:-e -- ~cst 0: ~s -- ~ell, these two b~ck ~E:-e ~ill be b=:~
.'
but e~~rybody else ~ill be dead and gone.
,.C --,-/""-".
,.-. ~;',,_.~:
~:::-. Pr...: i t t, I
ap;:reciate
5:: a. !" l. :-. ~
yo~r
that.
T!-:e inc~st:-ial waste, the waste Froble~ that we have
i~ t~i~ cou~try is a
national proble~.
There are laws that
a:-e i~ e~~ect to~ay.
~e are having ne~ laws on the booKs
e\'e:-y
cay.
~e'~E ;::-opose~ to Co~gress, both in the federal
arena as ~e:: as t!-:e sta~e 'arena.
And 1
ap;;:-e:iate
your
c::~~,...;--
-..-- _....~
~:-..a ~ .
:-:. :.~
:: ~:'~
:;roble~. ,
yes,
1:''''-
-...- .
~~::JE:.:::~:E~ S?E~KEF.:
I rea~ i~ t~E
S=lisbi.lry Pc
t:-.a t
\a~:8~.~:" 5~=.~::-. :s
l~ vlcl=t~c~ c~ thei:-
c~rre~t C15C~:~g~
-,:.""'--- -
---...---
I~ ;:~:.:::--.:=.:" --
:: ~Ea:;
is EF;'. a'".are
,...: ....--~c:
-- .......-1
a nc. r,c',,'
~ill a=ditional c.isc~a:-~e
:rorr.
this treatment syste~ be
handlec by ~ational Star~~ and how will that be dealt with?
MS. BENOY:
The discharge permit that you are dis-
cussing, your question is are we aware of the violations in
the permi t .
Is that your question?
UNIDENTIFIED SPEAKER:
Yes.
MS. BENOY ~
The program that you're speaking of is
a state delegated proble~, and it'. under also a separate
24
No, sir, I am not aware of it.
federal group in the EPA.
25
The State would be the first line of action.
1 will look int
that.
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:':~;::=:~::F!::D
S P ::;..!<~ E F. :
Si!)ce you're
a~~r,:)': :..;:;
t:-.:s
wethoc :o~ t=e=~~e;;~,
yC'u knot,;,
it see7.S
ob',' i 0'''; S
tr.a~
t.:-.lS
would
d;- a:-.a ": i c a:'l y
the a;:-.:>-.:r. t
0: e::lue:-.t.
.:;"\crease
r-~=. ?E~:'2.:::
0:.e 0:
c.:. ~ :~.:.:;-e
the crit~ria is t~at t~e
e : : L,.:'e !"'. t
te "i t:-::.r.
co!'!',?liance.
r f ,,:e have a:;
0~t-O:-C2~~::=~=
disc~cr~e ~rc=~e~,
then no, si~,
~e c~~lc no": -- ~e ~c~:= ;::":
add t:J
~~.at proble;:-,.
Yes, sir?
T_-;::: ~:::- I =-! E:)
S?E;..!:~~:
go~~g t:)
Is the ciscr.arce
te gr=;;=:=t~€:e=, i: ~e~ and ~ore restrictive criteri: co:-es
l:;:'C
e::ec~
t!-.a t t:-:e
would be lowered, the sa:ts
sta:1card
~e:- r:.:.l:::'::~.
~o""'ere= ,
is this discharge
g':Jir:g tc be
...,:C'''':-= .::e
F' "..: :. :. ::. ~. :; c ",.: t
tc be g~a~d:at~e~e=?
-- gc:,,~
::.:. =:::~::._':
Yes, s.:..~.
"- . -
. - --
- - --
T;-;e g:..::=a::ce ~'E
:':".:-:-:-
s~~:~;e~: =e~~:~e~e~ts
co~e i:.to l:A, t~e;;
s::-,
yes,
~'e :-.a-:e
.' .
~~ a~~ere ":: tnose ~cre
strin~e~t reguire~e;;":s.
t.:KI~:::,T:i? I:::' SPEAKEF.:
Another point here.
\\r-.a tis
the 'relation of the North Carolina Department
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of Environmental
I
,
i
Health and Natural Resources and their present operation?
MS. BENOY:
I don't understand your question.
UNIDENTIFIED SPEAKER: ,Everybody keeps saying:
well!
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effec
that's the regional office,
DEHNR,
and so forth,
v.'ha t
are -- you mentioned just a moment a90 that this violatior.
~ill state it comes under DEM or DEH~R -- how and what autho=i
do they have over National Starch as far as permitting dis-
charges and emissions?
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~S. E :'::'Y:
Jack Butler?
~1F. .
- -...--
t, ....:":-.:
~'itr.
:-:::' na:':".e is Ja::~ Butler.
! ¥..c:-~
\'
3 !: t~e S..:::erfu::c.
Section of DEESR..
I might ex:::lain t~at
there
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are a :c~ of par~s of
the DeFart~ent cf
Er. ': i rO!'l::".e n ta 1
Ee:;,2.~::
=: I
a~c ~it~ra2. Reso~rces, ne~ deFart~ents.
The ~oores\"ille
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re~:Q~a: Q::ice is re~~irec to,
as part
of the Di\"isi:~ c:
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i j; E::'; i ro~,ental Hanager..ent, they have au-thori t...' over a j".:..-:-~er
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:..'".::;;s, including ~~?JS perri.its, c:s::harge in cree;:;s, air
;e:"~.i.. ts,
e~,,'iro:'.:':1er.~al per:7.its with plants.
The
o::-gC::-J9"
S~:::er:~nd Section
is a section of the Division of Selic
\.. =- s :. e
!>:ar.ageme:'.~ .
7r.is
is actually three se=tions under the
~:\.':"S:C:-'. c:
~cl:.=
~1anage;,:",er. t..
One 0: the:,:", 15, in t11l
\.'" C::" ~
'-- 1..-
~ c : :..:: :.; a : t e
Se:::.:c:-" :s
is Eazardc~= ~aste
la:ic.::lls; o:.e
E~=~~o~1 ~~ic~ ~s ~~e reg~lar ~ro;~a~;
ar.d there's a:so the
- -..-
~~per:~~~ ~ect:.~~,
~~lC~ is ~hat I'~ 1;'.
F~CF~C cec.ls y--.:.t.~..
RECRO require~e;.ts -- Resource, Conservatiou anc Recovery Act
of the operation at National Starch.
Superfund Section deals
with past waste disposal practices at National Starch.
I
realize all those different groups are really confusing, but
each group has its own legislative authority and regulatory
authority.
We have our own limitations of what we can addres
and what we're not allowed to address, and if we have to,
we refer to another section.
If that answers your question -.
UNIDENTIFIED SPEAKER:
Well, let's narrow it dow.
a little more.
Who -- these folks over here said they called
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:-!oc:res\':..l~€ a:-,c got r.o ar:s\,,;er.
The~ said it ~as ~~d€r
Sl:=.e=-
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,-
fu~d.
Eo~ de ~e a~ci6 not
in~o that
roac::~:Jci<
rU:1!""~l:-:;
agai:-.: :
\\-:-. ~ c a:-.
\oo'€ cO:i~ac~?
"'- -"---1:1
...-q t:>...l_:'..:
Again, the present o~-goi~g
o?e!'=.~::~
",,'o'...:lc'D€ a-::c.:-essec by the Di\'isio:-. 0: £r:viro!'lJ':1er:tal !-~a~a:;€~~:-.";,
..;..~-~ ic:
'ftI...- _.. --
t~e ~o=res~ille o!:ice.
~~~~~ir.g to de ~it~
S-..:=-==:-..::\::
or the S:..:?erfLmd
Section, I can give you our phone nu~ber if
yo-..:
',.;ou:c li!
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APPENDIX B - LETTER FROM SUPPORT AGENCY
-
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.~~......~. .
..-<- STAt! ;
....~....
: >~ r ~ , .~.
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~{~;:!.~ ..:W..t"
'-<~.-:' ./
"t<...=:6"._J
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687' Raleigh, North Carolina 27611.7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
William L. Meyer
Director ~
September 24, 1990
Mr. Greer C. Tidwell
Regional Administrator
C .5. EPA Region IV
345 Courtland Street
Atlanta. G;~ 30365
Concitional Concurrence with the Record of Decision (Operable Unit #2)
1\ational Starch and Chemical Company NPL Site
Salisbury. Rowan County, 1\C
RE:
Dear ~1r. Tidwell:
1\orth Carolina appreciates the opportUnity to comment on the attached Draft
Record of Decision (ROD) for the subject site, and we look forward to working with EPA
on the final resolution of the problems at this site. The State concurs with the ROD for
Operable enit #2 subject to the following comments, conditions, or exceptions listed below.
1.
Contamination in the northeast tributary is not addressed in the ROD for
Operable Unit #2. Because repeated sampling events show the tribUtary
sediments and water to be contaminated, it is imperative that this creek be
remediated. It is our understanding that an Operable Unit #3 will be created
to specifically address contamination in the northeast tributary.
2.
The proposed plan to allow natural soil flushing to remediate the
contamination is understandable given the levels and depth of the
contaminants, however subsurface samples should be taken periodically to
monitor declining soil concentrations. It is understood that groundwater
extraction/treatment will be continued until groundwater cleanup goals have
been met. The current contaminated subsurface soil may prolong the time
period for groundwater extraction, therefore we would advise that a more
thorough analysis of the benefits of soil vapor extraction and soil flushing be
conducted.
-------
Mr. Greer C. Tidwell
26 September 1990
Page 2
3.
Stat6 concurrence in the Draft Record of Decision and Remedial Alternative
Selection is based solely upon the information contained in the attached Dr~~.:
Record of Decision and Remedial Alternative Selection. Should the St~~e
receive new or additional information which significantly affects the
conclusions or remedy selection comained in the Draft Record of Decision
and Remedial Alternative Selection, it may modify or v.ithdraw thi~
concurrence, effective immediately. upon v.Titten notice to EPA Region I\".
Such notice shall contain a statement of the reason or reasons for the
modification or withdrawal of State concurrence.
4.
State concurrence in this Draft Record of Decision and Remedial Action
Alternative Selection in no way binds the State to concur in future decisions
or commits the State to participate in furure activities regarding this site
including but not limited. to remedial design selection or State participation.
financial or ot~erwise, in the clean up of the site. The State reserves the right
to re\iew, comment and make independent assessmems of all future work
relating to this site.
In addition to the comments on the ROD for Operable enit #2. the State has
concer:1~ about the overall Remedial Plan at the site which concern the remedial plans for
the groundwater which is no\\" in place.
1.
The ROD for Operable Cnit # 1 states that the pretreated groundwater \\111
be discharged to the National Starch Wastewater lagoon for further treatment.
After review. we feel this violates RCRA rules because the lagoon does nO!
meet RCRA minimum technical requirements (i.e., there is no double liner.
no leachate collection system, nor 4 monitoring wells). It is imperative that
this be corrected before implementing the remedial plan.
2.
The air stripper operation must conform to the Air Toxics Standards
promulgated in May 1990 (NCAC Title 15A, Chapter 2, Section .0610).
3.
Community and State concerns dictate that risk assessments be conducted on
the treated water discharges and air emissions from the site. The air
emissions risks should .be assessed at the property line and added to the
ambiem baseline risk. The total risk should not exceed the 1 x 10~ level.
Likev.ise for surface water, the risk assessment should consider the risks posed
by ,gJJ sources "discharging to High Rock Lake. The risk from the site plus
risks from other dischargers should not exceed the 1 x 10~ level.
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1-
Mr. Greer C. Tidwell
26 September 1990
Page 3
Again, the State appreciates the opportunity to comment on the Draft ROD, and we
look forward to working v.rith you on this site in the future.
Respectfully yours,
rJ~cln~..J
William L. Meyer
\VLM / acr
cc:
George Everett
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RISK ASSBSSMENT CBRTIPICATION
The Region IV risk assessment staff has reviewed the PRP-
generated risk ~ssessment for the National Starch and Chemical
Company NPL Site, Salisbury, N.C. for compliance with current
Agency health risk guidance and policy. It was discovered during
ROD preparation that the risk assessment had inadequately
documented the assumption that direct soil exposure pathways were
incomplete. Subsequent sample data and site history have
supported this assumption as stated in the risk assessment.
summary in the Record of Decision (ROD). Other aspects of the
risk assessment were satisfactory. In accordance with the
requirement of OSWER Directive No. 9835.15 (8/28/90), it has been
determined that the risk assessment as summarized in this ROD
conservatively conveys the upperbound cancer and the systemic
~oxicity risks posed through all reasonably likely current and
future exposure scenarios by contaminants identified at this
site. Therefore, it is acceptable to the Agency.
~
/J,,~
7/2.- ~ '[0
I E
ELMER W. AKIN
HEALTH ASSESSMENT OFFICER
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