United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R04-88/032
April 1988
Superfund
Record of Decision:
Chemtronics, NC
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30273-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-88/032
3. Recipient's Accession No.
** sUPE'RFU'ND"RECORD OF DECISION
Chemtronics, NC
First Remedial Action - Final
5. Rapoi
7. Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contrsct(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
19. Supplementary Note*
16. Abstract (Limit: 200 words)
The Chemtronics site, an active waste disposal facility, is located in a rural area
of Swannanoa, Buncombe County, North Carolina. The 1,027-acre site was developed as an
industrial facility in 1952. Several companies operated the facility prior to its
purchase by Chemtronics, Inc. in 1978. Waste disposal operations only occurred over
approximately ten acres of the site. Existing records indicate the presence of
twenty-three individual onsite disposal areas (DAs) which are grouped into six discfrete
areas: DA-6, DA-7/8, DA-9, DA-10/11, DA-23 and the acid pit. The_ site can also be
divided into two geographical subsections referred to as Front Valley and Gregg Valley.
Disposal practices prior to 1971 were not well defined; however, solid waste materials
and possibly solvents were incinerated in pits dug in an area previously referred to as
the burning ground and currently referred to as the acid pit area. Additionally,
chemical wastes were disposed of in trenches beside this burning ground. Waste
materials generated in the production of the chemical warfare agent, 3-quinuclidinyl
benzilate (BZ), and the tear gas agent, o-chlorobenzylidene malononitrile (CS), were
placed in 55-gallon drums with a neutralizing solution, and then buried onsite in
trench-type landfills. From 1971 to 1975, small volumes of liquid wastes were disposed
of in onsite pits/trenches. Solid wastes, rocket motors, explosive wastes, and other
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Chemtronics, NC
First Remedial Action - Final
Contaminated Media: gw, sediments, soil, sw
Key Contaminants: metals (arsenic), organics (pesticides), VOCs (benzene, PCE, TCE)
b. identifiers/Open-ended Terms
e. COSATI Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
245
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R04-88/032
Chemtronics, NC
First Remedial Action - Final
16. ABSTRACT (continued)
waste types also were burned in the burning ground area. From 1975 to 1979,
Chemtronics, Inc. constructed pits/trenches, as needed, for the disposal of spent acid
and various organic wastes. These pits/trenches were constructed in the burning ground
area, in 1980, North Carolina ordered Chemtronics to discontinue all discharges to site
pits/trenches. The pits subsequently have been back-filled. Starting in 1979,
Chemtronics installed a 500,000 gallon lined lagoon over an old leaching field for the
biotreatment of waste waters. The incompatibility of the liner with the brominated
wastes introduced into the lagoon caused the lagoon to leach its contents. The
biolagoon was reconstructed in August, 1980, with a different liner, and deactivated in
1984. In September 1984, the U.S. Army Toxic and Hazardous Materials Agency sampled two
drums at the surface in DA-10/11. These drums were suspected of containing wastes from
the production of BZ. Although no BZ was found, an immediate removal of these drums was
initiated in January, 1985, due to heightened public awareness/involvement with the
site. The primary contaminants of concern affecting the soil, sediments, ground water
and surface water include VOCs, benzene, PCE, TCE, organics, metals, arsenic,
pesticides, and explosives.
The selected remedial action for this site includes: multi-layer capping of DA 6,
DA 7/8, DA-9, DA-10/11 and the acid pit area with fencing, placement of a vegetative
cover over the cap, and installation of a gas collection ventilation system, if
necessary; treatability studies for soils associated with DA-23 to determine the most
appropriate soil fixation/stabilization/solidification process and mixing ratios
followed by onsite capping; ground water pump and treatment which may include air
stripping, carbon adsorption, or metal removal with treatment and discharge to be
determined during design; sampling of pond water and sediments, and if necessary, treat
using the ground water treatment system or the selected soil treatment/containment
process; and sediment, ground water, and surface water monitoring. The estimated
present worth cost for this remedial action ranges from $6,247,300 to $8,242,900.
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ENFORCEMENT
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
CHEMTRONICS SITE
SWANNANOA, BUNCOMBE COUNTY
NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME and LOCATION
Chemtronics
Svannanoa, Buncombe County, North Carolina
STATEMENT OF PURPOSE
This document represents the selected remedial action for this Site developed
in accordance with CERCLA as amended by SARA, and to the extent practicable,
the National Contingency Plan.
The State of North Carolina has concurred on the selected Remedy*
STATEMENT OF BASIS
The decision is based upon the administrative record for the Chemtronics Site.
The attached index identifies the items which comprise the administrative
record upon which the selection of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
MIGRATION CONTROL (Remediating Contaminated Groundwater)
Installation of a groundwater interception and extraction system downgradient
of the disposal areas in both the Front Valley and Gregg Valley. The level
and degree of treatment of the extracted groundwater will depend on 1) the
ultimate discharge point of this water and 2) the level of contaminants in
the extracted groundwater. The three water discharge alternatives for the
treated water are 1) the local sewer system, 2) a surface stream and
3) on-site irrigation. The range of treatment for the extracted groundwater
includes air stripping, filtration through activated carbon filter and metal
removal. The point of discharge and the degree of treatment will be
determined in the Remedial Design stage. The water discharged will meet all
ARAR's.
A monitoring program, employing bioassays, will be established for surface
water/sediment. Monitoring locations will be located on the Unnamed Stream,
Gregg Branch and Bee Tree Creek. The purpose of this monitoring program is
1) to insure no adverse impact on these streams during implementation of the
remedial action and 2) to establish a data base to use to measure the success
of the remedial action implemented. The initiation of this monitoring
program will be concurrent with the remedial design activities.
Review the existing groundwater monitoring system and install additional
wells, if necessary, to insure proper monitoring of groundwater downgradient
of each disposal area. This includes disposal areas #6, 07/8, #9, #10/11,
and the acid pit area.
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In addition to the monitoring of the groundwater dovngradient of each
disposal area identified above, action levels for the contaminants present in
the disposal areas will be set so that after remediation levels for
groundwater have been obtained and verified through monitoring, if this level
is reached in any subsequent sampling episode, a remedial action to
permanently eliminate that source of contamination will be initiated.
*
SOURCE CONTROL (Remediating Contaminated Soils)
Cap Disposal Area 16, Disposal Area 17/8, Disposal Area 19, Disposal Area
#10/11, and the Acid Pit Area with a Multi-Layer cap which includes a
synthetic liner. Security fencing, vegetative covers and, where deemed
necessary, a gas collection/ventilation system will be installed. The
multi-layer cap will meet as a minimum, the standards specified under 40 CFR
Subsection 264, Subparts K-N.
For the contaminants and contaminated soils associated with DA-23, determine
the most appropriate soil fixation/stabilization/solidification process and
the mixing ratios for the components involved. Following the soil
fixation/stabilization/solidification for DA-23, the entire surface of the
disposal area will be capped.
Sample On-Site Pond on Unnamed Stream
During the Remedial Design stage, sample the water and sediment in the
pond. If the analysis indicates contaminants in either the water column or
sediment, then the pond will be drained, with the water being treated
through the treatment system developed for addressing the extracted
groundwater and the sediments could be either commingled with the soils of
Disposal Area #23 for fixation/stabilization/solidification or transported
to another disposal area and capped along with that disposal area.
DECLARATION
The selected remedy is protective of human health and the environment, attains
Federal and State requirements that are applicable or relevant and appropriate,
and is cost-effective. This remedy satisfies the preference for treatment that
reduces toxicity, mobility, or volume as a principal element. Finally, it is
determined that this remedy utilizes permanent solution and alternative
treatment technologies to the maximum extent practicable.
Date Greer C. Tidwell
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CHEMTRONICS SITE
SWANNANOA, BUNCOMBE COUNTY NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA GEORGIA
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TABLE OF CONTENTS
Page No.
1.0 Introduction 1
1.1 Site Location and Description ...1
1.2 Site History 1
2.0 Enforcement Analysis 7
3.0 Current Site Status 8
3.1 Hydrogeologic Setting 8
3.2 Site Contamination 9
3.3 Air Contamination 10
3. A Soil Contamination 10
3.5 Groundwater Contamination 21
3.6 Surface Water and Sediment Data 35
3.7 Receptors 50
4.0 Cleanup Criteria 52
A.I Groundwater Remediation 52
A.2 Soil Remediation . 52
A.3 Surface Water/Sediment Remediation 55
5.0 Alternatives Evaluated 55
6.0 Recommended Alternatives 61
6.1 Description of Recommended Remedy 61
6.2 Operations and Maintenance 69
6.3 Cost of Recommended Alternative 69
6. A Schedule 69
6.5 Future Actions 70
6.6 Consistency With Other Environmental Laws 70
7.0 Community Relations 71
8.0 State Involvement 73
Appendices
Appendix A - Responsiveness Summary
Appendix B - Chronology of Community Relation Activities
Appendix C - Public Notices/Newspaper Articles
Appendix D - Concurrences from State and Federal Agencies and Other EPA
Programs
Appendix E - Administrative Record Index
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LIST OF FIGURES
PAGE NO.
Figure 1. Map Showing Site Location 2
Figure 2. Map Highlighting Site Boundary 3
Figure 3. Map Showing Locations of Individual Disposal Area
On-Site in Front Valley and Gregg Valley I....5
Figure 4. Map Showing Location of Off-Site Disposal Areas 6
Figure 5. Map Locating Surface/Subsurface Soil Samples in
Disposal Area 10/11 12
Figure 6. Map Locating Surface/Subsurface Soil Samples in
Disposal Area 23 14
Figure 7. Map Locating Surface/Subsurface Soil Samples in
Disposal Area 6 16
Figure 8. Map Locating Surface/Subsurface Soil Samples in
Disposal Area 7/8 ...18
Figure 9. Map Locating Surface/Subsurface Soil Samples in
Disposal Area 9 « 22
Figure 10 Map locating Surface/Subsurface Soil Samples in the
Area Acid Pit Area 24
Figure 11. Map Showing Locations of Monitor Wells and
Concentrations of Volatiles Found in the
Groundwater Associated with Disposal Area 10/11.........28
Figure 12. Map Showing Locations of Monitor Wells and
Concentrations of Other Contaminants Found
in the Groundwater Associated with Disposal
Area 10/11 29
Figure 13. Map Showing Locations of Monitor Wells and
Concentrations of Volatiles Found in the
Groundwater Associated with Disposal Area 23 31
Figure 14. Map Showing Locations of Monitor Wells and
. Concentrations of Other Contaminants Found
in the Groundwater Associated with Disposal Area 23 32
Figure 15. Map Showing Locations of Monitor Wells and
Concentrations of Volatiles Found in the
Groundwater Associated with Disposal Area 6 36
Figure 16. Map Showing Locations of Monitor Wells and
Concentrations of Other Contaminants Found in
the Groundwater Associated with Disposal Area 6 37
Figure 17. Map Showing Locations of Monitor Wells and
Concentrations of Volatiles Found in the
Groundwater Associated with Disposal Areas 7/8
and 9 39
Figure 18. Map Showing Locations of Monitor Wells and
Concentrations of Other Contaminants Found in
the Groundwater Associated with Disposal
Areas 7/8 and 9 40
Figure 19. Map Showing Locations of Monitor Wells and
Concentrations of Volatiles Found in the
Groundwater Associated with the Acid Pit Area 43
Figure 20. Map Showing Locations of Monitor Wells and
Concentrations of Other Contaminants Found in
the Groundwater Associated with the Acid Pit
Area 44
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LIST OF FIGURES
(Continued)
PAGE No.
Figure 21. Map Outlining the Drainage Areas for the Unnamed
and Gregg Branches 48
Figure 22. Map Locating Surface Water and Sediment Sampling
Points and Concentrations of Contaminants Found
Along the Unnamed Branch and Bee Tree Creek. 49
Figure 23. Map Locating Surface Water and Sediment Sampling
Points and Concentrations of Contaminants Found
Along Gregg Branch and Bee Tree Creek 51
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LIST OF TABLES
PAGE NO.
Table 1. Contaminants Found in Soil Samples Associated with'
Disposal Area 10/11 13
Table 2. Contaminants Found in Soil Samples Associated with
Disposal Area 23 ..15
Table 3. Contaminants Found in Soil Samples Associated with
Disposal Area 6 17
Table 4. Contaminants Found in Soil Samples Associated with
Disposal Area 7/8 19 + 20
Table 5. Contaminants Found in Soil Samples Associated with
Disposal Area 9 23
Table 6. Contaminants Found in Soil Samples Associated with the
Acid Fit Area 25 + 26
Table 7. Contaminants Found in the Groundwater in the Vicinity of
Disposal Area 10/11 30
Table 8. Contaminants Found in the Groundwater in the Vicinity of
Disposal Area 23 33
Table 9. Contaminants Found in the Groundwater in the Vicinity of
Disposal Area 6 38
Table 10. Contaminants Found in the Groundwater in the Vicinity of
Disposal Area 7/8 41
Table 11. Contaminants Found in the Groundwater in the Vicinity of
Disposal Area 9 .. .42
Table 12. Contaminants Found in the Groundwater in the Vicinity
of the Acid Pit Area 45 + 46
Table 13. Groundwater Remediation Levels and Cited References 53
Table 14. Soil Remediation Levels for Contaminants Lacking
Promulgated Criteria or Standards.... 54
Table 15. Results of Technical Evaluation of Source Control
Techniques 56 + 57
Table 16. Potential Source Control Remedial Action Alternatives
(Prior to Cost Evaluation) 58
Table 17. Cost Evaluation of Potential Source Control Alternatives..59
Table 18. Retained Source Control Remedial Action Alternatives 60
Table 19. Potential Migration Control Remedial Action Alternatives
(Prior to Cost Evaluation) ....62
Table 20. Cost Evaluation of Potential Migration Control
Alternatives 63
Table 21. Retained Migration Control Remedial Action Alternatives...64
Table 22. Summary of Source and Migration Control Alternatives...65 - 68
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ENFORCEMENT RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION »
CHEMTRONICS SITE
SWANNANOA, BUNCOMBE COUNTY, NORTH CAROLINA
1.0 INTRODUCTION
*
The Chemtronics Site was included on the first official National Priorities
List (NFL) published by EPA in December 1982. The Chemtronics Site has been
the subject of a Remedial Investigation (RI) and a Feasibility Study (FS)
performed by two of the potentially responsible parties (PRPs), Chemtronics,
Inc., and Northrop Corporation, under an Administrative Order of Consent dated
October 1985. The third viable PRP, Hoechst Celanese Corporation, declined to
participate in the RI/FS. The RI report, which examined air, groundwater,
soil, and surface water and sediment contamination at the Site and the routes
of exposure of these contaminants to the public and environment was accepted by
the Agency in May 1987. The FS, which develops, examines and evaluates
alternatives for remediation of the contamination found on site, was 'issued in
draft form to the public in February 1988.
This Record of Decision has been prepared to summarize the remedial alternative
selection process and to present the selected remedial alternative.
1.1 SITE LOCATION AND DESCRIPTION
The Chemtronics Site encompasses approximately 1,027 acres and is located at
180 Old Bee Tree Road in a rural area of Swannanoa, Buncombe County,
approximately 8 miles east of Asheville, North Carolina. The approximate
center of the site lies at latitude 35 degrees 38' 18" north and longitude 82
degrees 26' 8" west. The Site is bounded on the east by Bee Tree Road and Bee
Tree Creek. The area to the north and west of the Site is comprised of
sparsely inhabited woodlands. Immediately to the south of the Site, there are
several industrial facilities which lie on land that was once part of the
original (Oerlikon) property. The general location of the Site is shown in
Figure 1. Figure 2 shows the approximate boundaries of the Site in
relationship to its immediate surroundings.
The topography of the Site is steep, ranging from 2,200 to 3,400 feet above
mean sea level (amsl). The Site lies on the southeast side of Bartlett
Mountain and is moderate to heavily vegetated. Surrounding mountains reach
elevations of approximately 3,800 feet amsl. All surface water from the Site
drains into small tributaries of Bee Tree Creek or directly into Bee Tree
Creek. This creek flows into the Swannanoa River which ultimately, empties
into the French Broad River.
1.2 SITE HISTORY
The property comprising the Chemtronics Site was first developed as an
industrial facility in 1952. The Site has been owned/operated by Oerlikon Tool
and Arms Corporation of America (1952-1959), Celanese Corporation of America
(Hoechst Celanese Corporation) (1959-1965), Northrop Carolina, Inc. (Northrop
Corporation) (1965-1971), Chemtronics, Inc., as apart of Airtronics, Inc.,
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| . *w? irr^ n ' * ^\ »— i
CHEMTRQNICS
. '/ TR\N
' I .•Vhirr?S.]
GENERAL LOCATION MAP
CHEMTRONICS, INC.
SWANNANOA. NORTH CAROLINA
-2-
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/. /^
APPROX
BOUNDARY
CHEMTRQN1CS
USGS CRAGGY PINNACLE. N.C. & OTEEN, N.C. QUADS
SCALE 1 : 24.0OO
SITE LOCATION MAP
CHEMTRONICS, INC.
SWANNANOA, NOFTTH CAROLMA
-3-
RGURE NO.
2
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(1971-1978), and Cheotronics, Inc. (1978 - present). The Site operated under
the name of Amcel Propulsion, Inc. (1959-1965) under both Oerlikon and
Celanese. The Site is currently occupied by an active facility owned and
operated by Chemtronics Incorporated, a subsidiary of the Halliburton Company.
Waste disposal occurred over a small portion (approximately than ten acres) of
the Site. Twenty-three individual on-site disposal areas were identified and
described by reviewing existing records and through interviews with former and
current Site employees. These 23 individual disposal areas (DAs) are grouped
into 6 discrete disposal areas: DA-6, DA-7/8, DA-9, DA-10/11, DA-23, and the
Acid Pit Area. The Site can also be divided into two geographical subsections;
they will be referred to as the Front Valley and Gregg Valley. The locations
of the 23 disposal areas and the two valleys are shown in Figure 3.
In the northwest corner of the Site, Figure 3, is a group of disposal areas
that are collectively referred to as the Acid Pit Area. The acid pit area
includes Disposal Areas 1, 2, 3, 4, 5, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21,
and Trench 22. The acid pit area along with DA-6, DA-7/8 and DA-9 are located
in Gregg Valley. Disposal areas DA-10/11 and DA-23 are located in the Front
Valley.
The acid pit area was first used as the burning grounds as described in the
following pages. This area, as well as all .of the other disposal areas, were
used by more than one of the site owner/operators.
In addition to investigating the on-site disposal areas for contamination,
three off-site areas were also investigated (Figure 4). One disposal area,
designated DA-24, lies on a tract of land that was once a part of the original
acreage. This tract of land was sold in the 1970's and is now owned by another
industry. The other two off-site areas investigated as part of the RI were
local municipal landfills that were operated by the Buncombe County back in the
1970's. These two landfills, referred to as the Buckeye/Walnut Cove (B/WC)'
Landfill and the Troplgas Landfill, reportedly received waste from the Site as
well as from other industrial facilities in the vicinity. Eight additional
areas on-site were sampled since sufficient information was collected to
indicate these areas as possible areas of contamination.
Disposal practices prior to 1971 are not well defined. From 1952 to 1971,
solid waste materials and possibly solvents were incinerated in pits dug in the
burning ground. Chemical wastes were disposed of in trenches beside this
burning ground. Waste materials generated in the production of the
incapacitating, surety agent, 3-quinuclidinyl benzilate (BZ) and the tear gas
agent, o-chlorobenzylidene malononitrile (CS), were placed in 55 gallon,
rim-lid drums, reportedly covered with decontamination "kill" solution and then
buried on-site in trench-type landfills. These kill solutions neutralized the
BZ and CS compounds. These drums were disposed of in disposal areas DA-6,
DA-7/8, DA-9, and DA-10/11.
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LOCATIONS OF KNOWN/SUSPECTED DISPOSAL AREAS
CHEMTRONICS. MC.
8WAMUNOA. NOK1H CAROtMA
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APPROXIMATE
CHEMTRONICS
PROPERTY
BOUNDARY
\
DILLINGHAM
CIRCLE
DISPOSAL AREA 24
^^ 7 I " ^ V i '**
7>x'Y_xf^x,
TROPIGAS LANDFILL
1.1 MILE EAST ON
WALNUT
BUCKEYE COVE
LANDFILL
3000
SOURCE: USGS TOPOGRAPHIC MAP
GRAGY PINNACLE. N.C.. 1978
OTEEN. N.C., 1962
SCALE IN FEET
FIGURE NO. 4 LOCATIONS OF OFF-SITE AREAS SAMPLED
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-7-
From 1971-1975, most of the liquid wastes generated on-site went to the
Buncombe County Sewer System following some form of neutralization and
equalization. Small volumes were disposed of in on-site pits/trenches. Solid
wastes, rocket motors, explosive wastes, etc., were all burned in the burning
ground. From 1975-1979, Chemtronics, Inc. constructed pits/trenches, as
needed, for the disposal of spent acid and various organic wastes. These
pits/trenches were constructed in the area that was once the burning ground,
now referred to as the Acid Pit Area.
In 1980, the State ordered Chemtronics to discontinue all discharges to these
disposal pits/trenches. The pits have subsequently been back-filled.
Consequently, in 1979, Chemtronics installed a 500,000 gallon lined lagoon for
biotreatment of wastewaters on top of an abandoned leach field for the main
production/processing building (Building 113). After the lagoon was filled,
the lagoon lost its contents due to the incompatibility of the liner with the
brominated waste initially introduced into the lagoon. Reconstruction of the
biolagoon, with a different liner, was completed in August 1980 and was in use
up to 1984 at which time the biolagoon was deactivated. This entire area,
including the abandoned leach field and the biolagoon, has been designated as
DA-23.
The Site has been the subject of two previous Region IV, USEPA planned
investigations, an investigation by the U.S. Army and an emergency response
action by Region IV, USEPA. In June 1980, groundwater, surface water,
sediment, and waste samples were collected for analysis. In April 1984,
private water supply wells in the vicinity of the Site were sampled. In
September 1984, the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA)
collected samples from two drums exposed at the surface in DA-10/11. These two
drums were suspected of containing wastes from the production of the chemical
warfare agent BZ. Although no BZ was found, in January 1985, an. immediate
removal of the same two exposed drums was initiated by EPA due to heightened
public awareness/involvement with the Site. The drums were sampled and then
transported to GSX, Pinewood facility, South Carolina.
2.0 ENFORCEMENT ANALYSIS
The Chemtronics Site was included on the first NPL in December 1982, and EPA
assumed lead responsibility for the Site at that time. The Site has been
operated as an industrial facility since 1952. An EPA contractor completed a
Potentially Responsible Party (PRP) search in November 1983. Notice Letters
were sent to the six identified PRPs. Three of the PRPs were found to be
viable and EPA initiated negotiations with these three PRPs. Negotiations
began in June 1984 and were concluded in October 1985 with two of the PRPs,
Chemtronics, Inc. and Northrop Corporation, signing an Administrative Order of
Consent to perform an RI/FS. The third PRP, Hoechst Celanese Corporation
declined to participate in the RI/FS process.
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-8-
3.0 CURRENT SITE STATUS
The Site is an active facility with the majority of manufacturing activities
occurring in the Front Valley.
3.1 HYDROGEOLOGIC SETTING
The Chemtronics Site lies within the Blue Ridge geologic province. The Blue
Ridge province is predominantly composed of ancient igneous and metamorphic
rocks. These rocks have been complexly folded and faulted in a northeasterly
direction, parallel to the regional trend of the mountains. These structural
and metamorphic imprints are reflected in the topographic and drainage patterns
within the region.
There are no known geologic faults or shear zones within two miles of the Site,
and the Brevard Fault Zone lies about seven miles south of the Site. The Site
property is underlain almost entirely by biotite gneiss.
In the Front Valley, the bedrock topography is reflected in the surface
topography and has a shape similar to an elongated bowl or trough. The center
of the bedrock trough coincides roughly with the center of the topographic
valley and this is where the overburden is thickest (65 to 90 feet). Bedrock
elevations increase with the surface topography and the overburden decreases as
slopes steepen. The thickening of the overburden in the valley is most likely
due to natural weathering processes.
In Gregg Valley, the bedrock topography is more complex and is not always
reflected by the surface topography. For example, a steep bedrock slope was
identified in the northeastern corner of the acid pit area but is not reflected
by the surface topography. There is also a bedrock trough near the middle of
the acid pit area which has no surface expression. Reshaping of the topography
by man in this area is most likely responsible for masking these bedrock
features. Elsewhere in Gregg Valley, the bedrock topography is reflected by
the surface topography. As in the Front Valley, overburden in Gregg Valley
thickens in its central and lower portions.
Groundwater recharge in this area is derived primarily from local
precipitation. Generally, the depth of the water table depends on the
topography and rock weathering. The water table varies from the ground surface
in the valleys (streams) to more than 40 feet below the ground surface in
sharply rising slopes.
The aquifer underlying the Site can be subdivided into a surficial zone and a
bedrock zone. The surficial zone refers to the overlying saprolite and the
bedrock zone includes the weathered and fractured region of the bedrock. These
two zones are considered one aquifer as it was demonstrated in the RI that
these zones are interconnected.
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-9-
The groundwater underlying the Site has been classified as Class IIB, using
USEPA Groundwater Classifications Guidelines of December 1986, since there is
potential future use for this aquifer as a source of drinking water.
Therefore, the groundwater needs to be remediated to levels protective of
public health and where appropriate, to levels protective of the environment.
3.2 SITE CONTAMINATION
The field work associated with the RI for the Chemtronics Site centered on
numerous known disposal areas on-site, eight other possible areas of
contamination on-site and three off-site areas that reportedly received waste
material from the Site. Soil, groundwater, surface water and sediment samples
were collected in and around these areas and initially analyzed for the
compounds on the Hazardous Substance List (HSL) as well as other selected
compounds. After reviewing the analytical data from the HSL scans, indicator
parameters were then selected to be run on subsequent samples and sampling
episodes.
The indicator compounds selected were:
* Volatile Organic Priority Pollutants
- Benzene
- 1,2-Dichloroethane
- Methylene chloride
- Tetrachloroethene
- Toluene
- Trichloroethene/Trichloroethylene
- Trihalomethanes
- Bromoform
- Chloroform
* Explosives
- Picric Acid
- RDX
- TNT
* Chemical Agents
- BZ
- CS
- and their degradative compounds
* Metals
- Chromium
- Nickel
The Agency approved the RI report in May 1987 which documented the presence as
well as the level and extent of contaminants on-site. Contamination was found
in the following media: surface and subsurface soils, surface water and
sediment, and groundwater. In October 1987, the PRPs resampled 12 monitor
wells in an attempt to verify and confirm the levels and extent of
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-10-
contamination in the groundwater. The analytical data indicates that, to date,
no contamination has migrated pass the Site's boundaries although plumes of
contamination in the groundwater have been found emanating from several of the
disposal areas.
*
Samples collected from the three off-site areas indicated the absence of
hazardous substances in these areas. The sampling included surface and
subsurface soil samples. Surface water and sediment and groundwater samples
were collected only at the Tropigas Landfill. These transport media were not
sampled at the other two off-site areas because they were not encountered.
3.3 AIR CONTAMINATION
The most common source of air contamination at hazardous waste sites are the
volatilization of toxic organic chemicals and the spread of airborne
contaminated dust particles. During the recent RI, Site personnel used an HNu
photoionization analyzer and cyanide sensitive colorimetric indicator tubes to
monitor the air while performing the designated RI tasks. An action level of 5
ppm was established in the Chemtronics Project Operations Plan (POP) and Health
& Safety Plan. This level was only attained during the excavation of the test
pits in the disposal areas* The 5 ppm action level was surpassed on several
occasions when the HNu was placed in the test pit or near exposed waste
material unearthed during the excavation of the test pits. No cyanide was
detected by the colorimetric tube.
3.4 SOIL CONTAMINATION
The study of the soil, surface and subsurface, occurred in two parts. The
first task encompassed the excavation of test pits in the majority of the known
disposal areas and the second task centered on the collection of surface and
subsurface soil samples from borings drilled in and around the disposal areas.
These activities not only allowed the determination of the depth of the
disposed wastes but also provided data to determine the extent, vertically and
horizontally, that the contaminants have migrated in the soil. The three
disposal areas where test pits were not excavated were in DA-9, DA-23 and the
Acid Pit Area.
3.A.I SOIL CONTAMINATION IN THE FRONT VALLEY
The Front Valley contains two disposal areas, DA-10/11 and DA-23, where surface
and subsurface soil samples were collected and analyzed. Below briefly
describes the contaminants present in each disposal area.
-------
-11-
DA 10/11
The analytes detected in and around DA-10/11 include volatile organic
priority pollutants, extractable organic priority pollutants, the
pesticide 4,4,4~-DDD, RDX, CS, total organic halide, and total cyanide.
The sampling location and method of sampling (i.e., soil boring vs. test
pit) are shown in Figure 5. The analytes found are listed in Table 1.
Along with the maximum concentration found, Table 1 also identifies where
the contaminants were found as well as the frequency of their occurrence
among both on-site and off-site samples analyzed.
DA-23
The analytes detected in and around DA-23 included volatile organic
priority pollutants, explosives, CS, BZ, and their degradative products,
total organic halides, and total cyanide. The sampling locations are
shown in Figure 6. • The analytes found are listed in Table 2 along with
the maximum concentrations. Table 2 also identifies where the
contaminants were found as well as the frequency of their occurrence among
both on-site and off-site samples.
3.4.2 SOIL CONTAMINATION IN GREGG VALLEY
Gregg Valley contains several disposal areas: DA-6, DA-7/8, DA-9, and the
Acid Pit Area. Soil samples were collected from each of these areas for
analysis. Below briefly describes the contaminants present in and around
each disposal area.
DA-6
The analytes found associated with DA-6 are methylene chloride, lead, and
the BZ degradation product benzylic acid/benzophenone. Figure 7 locates
where the samples were collected and Table 3 provides the maximum
detected concentrations, the locations where these concentrations were
found and the frequency of occurrence among both on-site and off-site
samples.
DA-7/8
Samples were collected from and around DA-7/8 were analyzed for volatile
and extractable priority pollutants, explosives, metals, total organic
halide, pH, total cyanide, and pesticides/PCBs. Selected samples were
analyzed for CS, BZ and their degradative products. Figure 8 show the
location of the soil samples collected in and around DA-7/8. The analytes
detected are listed in Table 4. Boring locations at which maximum
concentration were observed are also included in Table 4 along with the
frequency of occurrence from both the on-site and off-site samples.
-------
Kl
I
BOUNDARY OF
WASTE DISPOSAL
A OA tOltKWINGS
*r
SCA1I INfflt
FIGURE NO. 5 LOCATIONS OF SURFACE/SUBSURFACE SOIL
SAMPLES IN AND AROUND DISPOSAL AREA 10/11
-------
TABLE NO. 1 CONTAMINANTS POUND IN SOIL SAMPLES ASSOCIATED WITH DISPOSAL AREA 10/11
Compound
Detected
Max i urn
Detected
Concentration
(mg/Kq)
Location
of Maxium
Detected
Concentrat ion
Boring
Interval
Sample
Depth (ft)
% of Samples Analyzedd)
in Which Compound
Was Detected
On-site Off-site
Volatile Organic Priority Pollutants
Toluene 21,000.0
Methylene chloride 0.110
1,2-Dichloroethane 0.032
Extractable Organic Priority Pollutants
DA 10/11 TP-11
D\ 10/11
DA 10/11
Dibutyl phthalate 58.0
BenzolaJanthracene <10.0
Pestictdes/PCB's
4,4,4-DDD 0.021
Explosives
RDX 290.0
CSr BZ & Degradation Products
CS 1.50
Total Organic Halides 1.0
Total Cyanide 3.98
CSS
1 (5-9)
4 (20-22)
DA 10/11 TP-11 CSS
DA 10/11 TP-14 CSS
DA 10/11 TP-14 CSS
DA 10/11 TP-14 CSS
DA 10/11 TP-7 CSS
DA 10/11 TP-7 CSS
DA 10/11 TP-14 CSS
17
92
25
8
8
25
8
8
92
N/A
N/A
N/A
N/A
N/A
N/A
0
0
22
DA = Disposal Area
TP = Test Pit
N/A = Not Analyzed
CSS = Composite Soil Sample
(1) Number of locations sampled
Number of samples collected
Number of samples analyzed
On-site Off-site
25
41
12
4
32
18
-------
Tl
/ ! ' ' '"--
OF WASTE DISPOSAL
FIGURE NO. 6 LOCATIONS OF SURFACE/SUBSURFACE SOIL
SAMPLES IN AND AROUND DISPOSAL AREA 23
-------
TABLE NO. 2 CONTAMINANTS FOUND IN SOIL SAMPLES ASSOCIATED WITH DISPOSAL AREA 23
ui
I
Maxium Location
Detected of Maxiun
Compound Concentration Detected
Detected (rag/Kg) Concentration
Boring
Interval
Sample
Depth (ft)
% of Samples Analyzed
in Which Compound
was Detected
On-site Off-site
Volatile Organic Priority Pollutantsd)
Toluene 0.014
Methylene chloride 0.140
1 , 2-Dichloroethane 2 . 70
Chloroform 0.011
Ethyl Benzene, <0.01
tetrachloroethene
Explosives^)
TNT 0.6
0.5
CS, BZ & Degradation Products Total
Benzyl ic Acid/ 9.0
Benzophenone 3.6
1.9
Total Organic Halides(2) 11.0
Total Cyanide (2) 0.18
0.58
DA = Disposal Area
N/A = Not Analyzed
(1) Number of locations sampled
Number of samples collected
Number of samples analyzed
(2) Number of locations sampled
Number of samples collected
Number of samples analyzed
DA 23-2
DA 23-4
DA 23-2
DA 23-2
DA 23-2
DA 23-2
DA 23-2
Organic Halides(2)
DA 23-2
DA 23-2
DA 23-2
DA 23-2
DA 23-4
DA 23-4
On-site Off-site
4 3
4 30
4 17
On-site Off-site
. 1 3
4 30
4 17
12 (10-12)
12 (45-85)
14 (25-27)
12 (10-12)
12 (10-12)
11 (5-9)
12 (10-12)
11 (5-9)
12 (10-12)
12 (10-12)
13 (15-19)
(20-22)
11 (0-2)
12 (4.5-8.5)
25 0
100 100
100 29
25 0
25 0
50 N/A
75 6
25 N/A
25 24
-------
I
!-•
O)
D TP44 .(
V TP-40 D
LEGEND
^•••^"•"^
Q TF TEST PITS
FIGURE NO. 7 LOCATIONS OF SURFACR/SUBSURFACE SOIL
SAMPLES IN AND AROUND DISPOSAL AREA 6
-------
TABLE NO. 3 CONTAMINANTS POUND IN SOIL SAMPLES ASSOCIATED WITH DISPOSAL AREA 6
-J
I
Compound
Detected
Maxium
Detected
Concentration
(mg/Kg)
Location Boring % of Samples Analyzedd)
of Maxium Interval in Which Compound
Detected Sample Was Detected
Concentration Depth (ft) On-site
Off-site
Volatile Organic Priority Pollutants
Methylene chloride
Metals*
Lead*
CS, BZ & Degradation
Benzylic Acid
Benzophenone
0.013
35.0 (30)
Products
<0.39
<0.39
6 TP 38, 40 CSS 100
and 44
6 TP 43 and 49 CSS 100
6 TP 38, 40 CSS 50
and 44
6 TP 38, 40 CSS 50
and 44
N/A
N/A
0
0
TP = Test Pit
N/A = Not Analyzed
CSS = Composite Soil Sample
* Metals listed are those detected at levels which exceed background concentrations
+ Background Concentration in Parentheses
On-site Off-site
(1) Number of locations sampled 10 3
Number of samples collected 10 21
Number of samples analyzed 29
-------
00
I
INITIAL ASSUMED BOUNDARY
OF WASTE DISPOSAL
ACTUAL
BOUNDARY OF
WASTE DISPOSAL
J.tOCHO
Q IF TMTWTS
OA SOIL BORINGS
AP
-------
TABLE NO. 4 CONTAMINANTS POUND IN SOIL SAMPLES ASSOCIATED'WITH DISPOSAL AREA 7/8
Compound
Detected
Maxium
Detected
Concentration
(mgAg)
Location
of Maxium
Detected
Concentration
Boring
Interval
Sample
Depth (ft)
% of Samples Analyzed
in Which Compound
Was Detected
On-site
Off -site
Volatile Organic Priority Pollutants! D
Toluene
Methylene chloride
1 , 2-Dichloroethane
.
trans-1,2-
dichloroethene
Ethyl benzene
Vinyl chloride
I
0.030
0.170
0.150
0.440
0.045
0.012
DA 7/8 TP 35
and 37
DA 7/8 4
DA 7/8 TP 35
and 37
DA 7/8 TP 35
and 37
DA 7/8 TP 35
and 37
DA 7/8 TP 35
and 37
CSS
12 (25-27)
CSS
CSS
CSS
CSS
10
100
40
20
10
10
N/A
N/A
N/A
N/A
N/A
N/A
«> Extractable Organic Priority Pollutants(2)
Bis(2-ethylhexyl)
phthalate
Pesticides/PCB*8(2)
Aroclor 1242
Explosives! 2)
RDX
CS, BZ & Degradation
CS
Orthochloro
benzaldehyde
Malononitile
1.0
0.1
9.6
Products (2)
3,100.0
7.6
<0.51
DA 7/8 TP 35
and 37
DA 7/8 TP 31
and 36
DA 7/8 TP 35
and 37
DA 7/8 TP 35
and 37
DA 7/8 TP 35
and 37
DA 7/8 TP 35
and 37
CSS
CSS
CSS
CSS
CSS
CSS
10
10
10
10
10
10
N/A
N/A
0
•
0
0
0
-------
TABLE NO. 4 CONTAMINANTS POUND IN SOIL SAMPLES ASSOCIATED WITH DISPOSAL AREA 7/8
(continued)
I
10
Compound
Detected
Total Organic Halides(2)
Total Cvnnide(2)
Metals* (2)
Copper*
Chromium*
Lead*
Maxium
Detected
Concentration
(mg/Kg)
270.0
0.8
160.0 (110)
97.0 (97)
32.0 (24)
Location
of Maxium
Detected
Concentration
DA 7/8 TP 35
and 37
DA 7/8 TP 35
and 37
DA 7/8 TP 31
and 36
DA 7/fl TP 31
and 36
DA 7/8 TP 35
and 37
Boring
Interval
Sample
Depth (ft)
CSS
CSS
CSS
CSS
CSS
% of Samples
Analyzed
in Which Compound
Was Detected
On-site
10
10
10
10
10
Off-site
0
0
22
7d
N/A
FA • Disposal Area
TP • Test Pit
N/A * Not Analyzed
CS% • Composite Soil Sample
* Metals listed are those detected at levels which exceed background concentrations
* Background Concentration in Parentheses
(1) Number of locations sampled
Number of samples collected
Number of samples analyzed
(2) Number of locations sampled
Number of samples collected
Number of samples analyzed
On-site
9
74
62
On-site
17
22
10
Off-site
13
160
79
Off-site
3
20
9
-------
-21-
DA-9
The analytes found associated with DA-9 are listed in Table 5 along with the
boring location at which the maximum concentration was observed and the
frequency of occurrence from both on-site and off-site samples. Figure 9
situates where the samples were located in and around the disposal area.
ACID PIT AREA
The analytes detected in and around the Acid Pit Area include volatile organic
priority pollutants, pesticldes/PCBs, explosives, total cyanide, total organic
halide, and metals. The analytical results are presented in Table 6. The
analytes are listed with the boring location at which the maximum concentration
was observed and the frequency of occurrence both inside and outside the
presumed boundaries of the disposal area. Figure 10 provides the location of
the soil borings in and around the acid pit area.
3.5 . GROUNDWATER CONTAMINATION
All monitor wells were sampled in June 1986 as part of the RI. Twelve (12) of
these wells were resampled in October 1987 in an attempt to verify
concentrations.
3.5.1 GROUNDWATER CONTAMINATION IN THE FRONT VALLEY
Groundwater contamination in the surficial zone of the Front Valley exists
primarily in the area downgradient of DA-23, the old leach field for Building
113 and the biolagoon. Other portions of the aquifer in this valley also
appear to have been adversely affected but the source of contamination in these
areas cannot be clearly defined. In each of these locations, volatile organic
priority pollutants are present.
The following discussion is based on the samples analyzed as part of the RI.
Figures 11 and 12 locate the monitor wells associated with DA-10/11 and
identifies the contaminants and their concentrations found during the RI. The
results of the October 1987 sampling episode are also included on these
figures, where appropriate. The analytical data is also tabulated; Table 7 is
for DA-10/11 and Table 8 is for DA-23.
As can be seen from Figures 10 and 11, there is no groundwater contamination
immediately downgradient of DA-10/11. The contaminants identified in surficial
monitor well §5 (SW-5) and bedrock monitor well 15 (BW-5) are due to disposal
area DA-23 as explained below.
The highest concentrations of volatile organics in the groundwater were
detected in monitor wells downgradient of DA-23 as shown in Figure 13.
Concentrations of 1,2-dichloroethane range from 0.15 to 7.4 mg/L. In this
area, higher concentrations of volatiles were also detected in the deeper
portion of the aquifer, indicating downward as well as lateral migration of the
contaminants. 1,2-Dichloroethane was also detected in stream sample RW-7
-------
\DA9-2
9 Soil Boring
SCAU INffIT
FIGURE NO. 9 LOCATIONS OF SURFACE/SUBSURFACE SOIL
SAMPLES IN AND AROUND DISPOSAL AREA 9
-22-
-------
TABLE NO. 5 CONTAMINANTS FOUND IN SOIL SAMPLES ASSOCIATED WITH DISPOSAL AREA 9
I
K)
U>
Maxium
Detected
Compound Concentration
Detected (mg/Kg)
Volatile Organic Priority Pollutants
Trichloroethylene 3.2
1,2-dichloroethane 1.8
Methylene Chloride 0.40
Tetrachloroethene 0.021
Extractable Organic Priority Pollutants
Bis (2-ethylhexyl) 15.0
phthalate
Pesticides/PCB's
Aroclor 5.0
Explosives
RDX 220
TNT 280
CSr BZ & Degradation Products
CS 370
Orthochloro-
benzaldehyde 22
Total Organic Halide 260
Total Cyanide 8.71
Location
of Maxium
Detected
Concentration
DA 9-4
DA 9-4
DA 9-2
DA 9-6
DA 9-4
DA 9-4
DA 9-6
DA 9-6
DA 9-6
DA 9-4
DA 9-4
DA 9-6
Boring
Interval
Sample
Depth (ft)
12 (4-10)
13 (14-16)
15 (24-36)
SS
12 (4-10)
11 (0-4)
SS
SS
SS
12 (4-10)
11 (0-4)
SS
% of Samples Analyzed
in Which Compound
Was Detected
On-site
88
63
88
25
38
13
50
50
50
63
50
63
Off-site
5
25
95
0
0
0
0
0
0
0
N/A
25
DA = Disposal Area
SS ** Surface Soil Sample
N/A = Not Analyzed
On-site Off-site
(1) Number of locations sampled . 3 3
Number of samples collected 10 35
Number of samples analyzed 8 20
-------
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LEGEND
Soil Boring
200
SCALE IN FEET
FIGURE NO. 10 LOCATIONS OF SURFACE/SUBSURFACE SOIL
SAMPLES IN AND AROUND TOE ACID PIT AREA
-24-
-------
TABLE NO. 6 CONTAMINANTS POUND IN SOIL SAMPLES ASSOCIATED WITH THE ACID PIT DISPOSAL AREA
K)
Max i urn
Detected
Compound Concentration
Detected (ing/Kg)
Location Borinq
of Maxium Interval
Detected Sample
Concentration Depth (ft)
% of Samples Analyzed
in Which Compound
Was Detected
On-site
Off-site
Volatile Organic Priority Pollutants
1,2 Dichloroe thane
Toluene
Tr ichloroethene
Ethyl benzene
Chloroform
Bromofonn
Te trachloroe thene
Methylene Chloride
1,1, 2-trichloroethane
Benzene
1 , 1 , 1-trichloroethane
Trans-1 , 2-d ichloroethene
Bromomethane
Chlorobenzene
Pesticides/PCB'3
- Endosulfan
Heptachlor
- BHC
- BHC
- BHC (Lindane)
4,4' - DDT
Dieldrin
- BHC
46.0
15.0
9.80
1.80
1.20
0.51
0.31
0.18
0.13
0.05
0.032
0.028
0.016
0.010
160.0
130.0
57.0
13.0
7.9
6.6
0.13
0.072 •
AP-7 .
AP-7
AP-7
AP-7
AP-8
AP-8
AP-7
AP-4
AP-7
AP-7
AP-18
AP-19
AP-7
AP-7
AP-9
AP-9
AP-5
AP-9
AP-11
AP-4
AP-5
AP-3
13
#6
17
13
#6
12
13
16
13
13
12
18
#9
14
12
12
13
ftl
14
»3
ftl
ftl
(9-13)
(24-26)
(29-31)
(9-13)
(25-27)
(5-9)
(9-13)
(27-29)
(9-13)
(9-13)
(4-16)
(35-37)
(39-41)
(14-16)
(5-9)
(5-9)
(28-29)
(0-2)
(14-18)
(10-14)
(0-2)
(0-2)
61
10
19
10
10
10
16
6
85
3
3
0
2
2
2
2
6
2
2
2
2
2
33
1
4
3
5
1
0
90
0
1
1
0
0
0
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
-------
I
K>
TABLE NO. 6 CONTAMINANTS POUND IN SOIL SAMPLES ASSOCIATED WITH THE
(continued)
Compound
Detected
Explosives
Picric Acid
2,4,6 TNT
Total Organic Hal ides
Total Cyanide
Metals*
Arsenic
Chromium
Lead
Zinc
Thallium
Maxium
Detected
Concentration
(ing/Kg)
22.0
0.8
8,300.0
2.20
100.0 (56)
72.0 (57)
38.0 (30)
120.0 (100)
110.0 (t)
Location
of Maxium
Detected
Concentration
AP-8
AP-3
AP-4
AP-7
AP-4
AP-3
AP-3
AP-3
AP-7
Boring
Interval
Sample
Depth (ft)
16 (25-27)
11 (0-2)
12 (5-9)
16 (24-26)
#4 (15-17)
12 (5-9)
15 (20-21)
15 (20-21)
12 (4-8)
ACID PIT DISPOSAL AREA
% of Samples Analyzed
in Which Compound
Was Detected
On-site
6
3
32
79
8
6
3
3
2
Off-site
N/A
N/A
N/A
5
0
N/A
N/A
N/A
N/A
/
AP = Acid Pit Area
N/A = Not Analyzed
CSS = Composite Soil Sample
* Metals listed are those detected at levels which exceed background concentrations
+ Backgound Concentration in Parentheses
t Below detection limit
-------
-27-
(Figure 13) Indicating that this compound is discharging with groundwater in
this vicinity into the northern tributary of the unnamed branch.
Lover concentrations of two other volatile organic compounds were also detected
in this area, specifically, 0.11 mg/L of chloroform in monitor well (MW) SW-4
and 0.013 mg/L of trans-1,2-dichloroethene in MW M85L-4.
Benzylic acid, a degradative compound of BZ, was detected in MW SW-4 at 470
mg/L (Figure 14). This implies that BZ derivatives have migrated downgradient
with the groundwater from the Building 113 leach field. RDX and picric acid
were also detected in the groundwater downgradient of DA-23. A concentration
of 0.046 mg/L of RDX in MW SW-6, which is located upgradient to DA-23, may
indicate that this well is located near the abandoned tile drainage line
leading from Building 113- to the leach field or within the upper boundary of
the leach field itself. A low concentration of bis (2-ethylhexyl) phthalate
was also detected in MW SW-6 (Figure 14).
Groundwater in the vicinity of MW SW-5, on the southwestern side of the unnamed
branch, has also been adversely affected (Figures 13 and 14). Contaminants in
this area include trichloroethene, RDX and trans 1,2-dichloroethane. According
to groundwater flow patterns in the area, it is unlikely that these
contaminants are coming from DA-23 or DA-10/11. It is feasible that these
contaminants have migrated from the leach field of Building 107 (Figure 3) or
are a result of other past activities or incidents within the upgradient area.
Lastly, 0.17 mg/L of trichloroethene was the only contaminant detected in the
furthest downgradient MW M85L-11 (Figure 13). It is unlikely that this
contaminant originated from DA-10/11 since this contaminant was not found in
either monitor wells, SW-2 or SW-3 (Figure 11), both of which are immediately
downgradient of DA-10/11. This is further supported by the fact that no
trichloroethene contamination was detected in any of the soil borings samples
(Table 1) collected from this area. The absence of trichloroethene in
groundwater downgradient of DA-23 indicates that the source of trichloroethene
in MW M8SL-11 is not DA-23 (Figure 13) and is therefore, most likely due to
some other past activity or incident.
In summary, the extent of the groundwater contamination in the surficial zone
in the Front Valley is greatest downgradient of DA-23. The majority of
contaminants from this area are migrating with the groundwater and discharging
locally into a northern tributary of the unnamed branch. Groundwater
contamination in other areas within the valley are most likely due to the
presence of other old leach fields (such as that of Building 107) or other past
activities. Finally, given that no contaminants were detected in groundwater
samples collected from wells downgradient of DA-10/11 during the RI and only
methylene chloride at 0.007 mg/L (Figure 11) in the October 1987 sampling
episode, it appears that contaminants have not moved from this area.
The bedrock zone of the aquifer in the Front Valley contains three
contaminants: 1,2-dichloroethane, bis (2-ethylhexyl) phthalate, and .
chloroform. The extent of this contamination is in the vicinity of two wells,
BW-4 and BW-5 (Figure 13 and 14). The contaminant detected in MW BW-5 was 1,2
dichloroethane at a concentration of 0.15 mg/L. The source of this contaminant
-------
I^'M\\^M
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LEGEND i : \ \ ! / V ;//' /^ .•/ //////./ /(
200
SCALE IN FEET
O Existing Monitor Well
O Newly Installed Surficial Well
• Newly Installed Bedrock Well
RI - Samples Collected Between
January + September 1986
10/87 - Additional Samples Collected
in October 1987
Reported Levels of Contaminants
are mg/L (parts per million)
N/D - No Contaminants Detected
/ \
(downgradient 600 ft.) - N/D
FIGURE NO. 11 LOCATIONS AND CONCENTRATIONS OF VOLATILE CONTAMINANTS
ASSOCIATED WITH DISPOSAL AREA 10/11 FOUND IN THE GROUNDIIATER
IN THE FRONT VALLEY
-28-
-------
•taul Orpnic tallta OS7
& '<>=&x: ,in%^- :<; .X'_£T
& v
RI - Samples Collected Between
January + September 1986
10/87 - Additional Samples Collected '•^$:^sf/^s-
in October 1987 ^^X-/ —
~ •* S S sf* _<-
Reported Levels of Contaminants
are mg/L (parts per million)
N/D - No Contaminants Detected
5.47J
.W-13 (dounpradianc 600 ft.) - Bis (2-«thylh«xyl 1 phthalit* 0.540
300 /r^^ \ \K-,... * ^—T\ -
SCALE IN FFET .-/..-' ./>.V •-- - \ \ ? ...
FIGURE NO. 12 LOCATIONS AND CONCENTRATIONS OF NON-VOLATILE CONTAMINANTS
ASSOCIATED WITH DISPOSAL AREA 10/11 FOUND IN THE GROUNDWATER
IN THE FRONT VALLEY
-29-
-------
I
(J
«a
Vol.it lies
7
Kitractnbles
/
Explosives
Hell Hell
Location Type
Upgradltnt
SU 1 Shallow
BW 1 Bedrock
nnungrxillent
SW Z Shallow
SU 3 Shallow
SU 5 Shallow
iu I Intermediate
IIU 2 Bedrock
BW 5 Bedrock
BU 6 Bedrock
BU 13 Bedrock
M85LII Eilallng
/ ' *
If o" >» •? V
/*° N* ,*/ / -^
// / // y //
lO.OI • •
'/ ^
/*?
„
•
w
«? /
/ /
6> / «
//
.
-
*
(t* y
•^ x
•* /
//
H*
M*
N«
Nk
NA
Nk
.
Hk
Nk
.
Nk
' /
/
/
A
7.18
9.68
.10
.00
.20
.01
. *B
.04
.53
.«5
.•I
-. qua I tried data
N* • not analyzed
- t not detected
detected but not at significant levels
(1) •uUnr or well* In thU ar«a: II
(2) riiUiaUte concentrations are assumed to be the result of contact between |roundwater and phthalate-oontalnln| Materials during well Installation
•01 liitndllni and analysis In the laboratory.
(3) Contaminant Levels Measured in mg/L (parts per million)
TABLE NO. 7
CONTAMINANTS POUND IN THE GROUNDWATER IN THE VICINITY OP
DISPOSAL AREA 10/11
-------
DISPOSAL AREA 23
Trara-l ,
twthylm QUorid*
\ .< \ '. •• «t '• • '
^ \ A v5-'.7
, >
^_^
ITB5J BTTO / ••' / .-• . •'-•-' ~,-''s^-— •^.-~-:'-:'. '.'''' •'..' ' • .•' .
•n* 0.037 0.011 .. .• / / .• .' ..V* • ..- ^ - ^-\,''.~'• ••'/•• •
tVO 0.007. i://£; ./^J f'.-"--^^-" I',//'/''/
'•ft • Y A% . • .• x ••• -•/.'/ /
' : ••,•••• < ! / i ( ! ,' /. r? i • I •' -' •' //• / , /
i : ; ,•/• /; v •. \ \ / ; •••(/ ; •- '.V;-. • , I ; < •//,
V. -,A"t,!^v,',] ! • I ^( x^.-S^,:,U - /.
.Vi!lSn>;*;^ '^- ^-^^-'^
'y
? / tfVH'V
LEGEND
O Existing Monitor Well
9 Newly Installed Surficial Well
• Newly Installed Bedrock Well
RI - Samples Collected Between
January + September 1986
3/87 - Additional Samples Collected
in October 1987
Reported Levels of Contaminants
are mg/L (parts per million)
N/D - No Contaminants Detected
«SL
me MX) ft.) - Triei>lorc.th«i. 0.170
looo ft.) - H/D
'&
200
SCALE IN FEET
FIGURE NO. 13 IDCATIONS AND CONCENTRATIONS OF VOLATILE CONTAMINANTS
ASSOCIATED WITH DISPOSAL AREA 23 FOUND IN THE GROUNDWATER
IN THE FRONT VALLEY
-------
Yf /^>^
JW#=M^
n io/n7
Braylic Add/BmznlMnan* 47fl.fl Uflfl.O
KB 0.059
Itotml Cyanid* 0.010
Totil Or^nic Halidn l.SOO
Itaul Orvmic tuiidn l.Mfl
•^S^ ^A-i #/• » // -;'. & £JJ -fil -rJaZ-'
vf \^A^;:/(j-^r> TrnPif^
A A \ \ V*t = , / >^>v ; :,'.:/; !i::(l
^•fefem/; v.\^ :
A? -'y/YY/'^X /' ?-wV-c<^ •
*\o-y/jl /JAri / / \ Vs\^$ «•
*^}s"//ir Hi/, o // v\\Tr^-
B.fl70
.'/vjl'WT:
r*
M
0.440
0.300
i />W\N
• / • \ v vo ;
V T- ^ v
^
s\S
IW-13 (donngradlcnt 1000 ft.) • B1»(2-tthylh»V1)phthiUte O.S40
LEGEND
O Existing ftonitor Well
Newly Installed Surficial Well
Newly Installed Bedrock Well
Samples Collected Between
January + September 1986
10/87 - Additional Samples Collected
in October 1987
Reported Levels of Contaminants
are mg/L (parts per million)
N/D - No Contaminants Detected
WSL 11 (do»ngr»d1ent 400 ft.) - R/D
•s-^^^^t^
^00
200
SCALE IN FEET
FIGURE NO. 14 LOCATIONS AND CONCENTRATIONS OF NON-VOLATILE CONTAMINANTS
ASSOCIATED WITH DISPOSAL AREA 23 FOUND IN THE GROUNDWATER
IN THE FRONT VALLEY
-32-
-------
Volatlles
E«ploal»es
7
Me tall
7
CS/BI Products
7
fell Type
Upgradlent
SU 6 Shallow
BU 3 Bedrock
flowngradlent
SU 1 Shallow
IU 1 Intermediate
BU 1 Bedrock
BU 5 Bedrock
BU 6 Bedrock
BU 13 Bedrock
MB514 Eil at Ing
MB5UO Eilstlng
MB5L11 Cilstlng
J/lift
/ V fr <£ * $ G +
<0.01 .
2.1 • 0.11
0.5] <0.01 0.03
0.15 -
(0.01 <0.01 (0.01
<0.01 <0.0t
0.15 <0.01
/* «?
0.012
<0.01
<0.0t
.
0.054
<0.01
<0.01
-------
-34-
could be DA-23 in that this well is hydraulically downgradient from this
disposal area. An essentially horizontal fracture in the bedrock was detected
in MW BW-4 that could provide a pathway for this compound. This would explain
the appearance of this contaminant in of MW BW-5 but not in MW SW-5, which was
completed in the surficial zone.
Three contaminants were detected in MW BW-4: 1,2-dichloroethane, bis
(2-ethylhexyl) phthalate, and chloroform (Figures 11 and 12). While the low
concentration of bis (2-ethylhexyl) phthalate is likely the result of sample
contamination, the presence of 1,2-dichloroethane and chloroform can be
directly related to waste disposal in DA-23.
In summary, the only area of the bedrock zone affected by disposal activities
in the Front Valley appears to be primarily in the vicinity of wells BW-4 and
BW-5. This leads to the conclusion that the contamination of the bedrock zone
of the aquifer in this valley is of limited extent and has migrated less than
800 feet from areas of waste disposal as evident by the absence of contaminants
in wells BW-6 and intermediate monitor well #1 (IW-1) as can be seen in Figures
11 and 12.
3.5.2 GROUNDWATER CONTAMINATION IN GREGG VALLEY
Groundwater in the central portion of Gregg Valley is primarily contaminated by
two volatile organic priority pollutants: 1,2-dichloroethane and
trichloroethene (Figures 15, 17 and 19) and (Tables 7-12). These compounds
most likely originated from the acid pits disposal area, DA-7/8 and DA-9. In
general, concentrations of these compounds are highest near the disposal
areas. Concentrations of trichloroethene and 1,2-dichloroethane in monitor
wells located approximately 100 to 200 feet downgradient of the acid pit area
(Figure 19) range from 0.04 to 9.2 mg/L and 0.014 to 9.2 mg/L, respectively*
Concentrations of trichloroethene and 1,2-dichloroethane in MW X-3,
approximately 300 feet downgradient of the acid pits, are 0.059 and 0.023 mg/L,
respectively. The presence of these two compounds in the groundwater most
likely extends further down the center of the valley but not as far as wells
BW-11 and IW-3, approximately 600 to 900 feet downgradient as neither
contaminant was detected in either of these wells.
The remainder of contaminants detected in the surficial zone of Gregg Valley
occur less frequently and generally in lower concentrations than
trichloroethene and 1,2-dichloroethane. These contaminants include other
volatile organic priority pollutant compounds, extractable organic compounds
explosives, metals, cyanide, and BZ degradation products (Tables 7-12). The
distribution of these contaminants in the groundwater does not appear to be
widespread or to extend further than 300 feet from the disposal areas according
to analytical data from the downgradient monitor wells (Figures 16, 18 and 20).
In summary, two volatile organic priority pollutants (1,2-dichloroethane and
trichloroethene) are present in the surficial zone of Gregg Valley. While
these contaminants are generally more prevalent in the upper reaches of the
surficial zone, they were also found in the lower reaches of the surficial zone
(wells M85L-5 and IW-2) as can be seen in Figure 19. This indicates that
-------
-35-
contaminants within Che surficial zone are migrating downward as well as
laterally and will enter the bedrock zone. The downgradient lateral extent of
this contamination has not yet reached the confluence of the eastern and
western tributaries of Gregg Branch. The limit of contaminant migration to
date appears to be within the area between wells X-3 and BW-11. Contamination
by chemicals other than 1,2-dichloroethane and trichloroethene, however, is
generally limited to portions of the aquifer that are close to DA-7/8, DA-9 and
the acid pit area.
Finally, no contamination of the groundwater was detected downgradient of DA-6
(Figures 15 and 16).
The bedrock zone in the vicinity of the acid pits and DA-9 contains some of the
contaminants detected in the surficial zone. In particular, three out of seven
bedrock wells showed one or more analytes (Figures 17 through 20).
Trichloroethene was the only contaminant detected in MW BW-8, which most likely
originated from the acid pits disposal area or DA-9. The concentration of
trichloroethene was relatively low, at 0.012 mg/L. In contrast, four different
contaminants were detected in the bedrock zone approximately 200 feet southeast
of the acid pits at MW BW-9, specifically: 0.94 mg/L of 1,2-dichloroethane,
0.26 mg/L of trichloroethene 0.19 mg/L of benzene, and 0.05 mg/L of methylene
chloride. The presence of these analytes at this location indicates that
chemicals disposed of in the acid pit disposal area have moved downward through
the surficial zone and have entered the bedrock zone in the vicinity of well
BW-9 through surface joints and fractures.
None of the analytes found in wells BW-8 or BW-9, or in the surficial monitor
wells in Gregg Valley were detected in wells BW-11 or BW-12 (Figures 19 and 20,
Table 12). This indicates that presently, contaminants from the acid pits,
DA-7/8 or DA-9 have not migrated this far (approximately 600 feet to BW-12 and
900 feet to BW-11). A trace quantity (0.002 mg/1) of benzylic
acid/benzophenone, a BZ hydrolysis product, was detected in MW BW-11 in the
sample collected during the the RI but was absent in the sample taken in
October 1987.
In summary, the bedrock zone of Gregg Valley is contaminated by volatile
organic priority pollutant compounds The extent of this contamination is more
pronounced southeast of the acid pit area, in the vicinity of MW BW-9, but
these contaminants have not reached wells BW-11 or BW-12. Therefore, the
downgradient lateral extent of this contamination should be within 600 feet of
the disposal areas.
3.6 SURFACE WATER AND SEDIMENT CONTAMINATION
The Site, as stated previously, can be subdivided into two small valleys formed
on an unnamed stream and the Gregg Branch (Figure 21). These two valleys are
referred to as the Front Valley and the Gregg Valley. The sizes of the
watersheds encompassed in each valley is 221 acres and 691 acres, respectively,
and both drain into Bee Tree Creek. Between the two valleys is a ridge of 44
acres draining directly into Bee Tree Creek. An additional area on the
-------
ACID PIT DISPOSAL AREA '//;
-V^M85-t2 A
~>irm
V. •/',•»./.•.'
.•'/
*X ' '-• '
LEGEND
O Existing Monitor Well
« Newly Installed Surficial Well
• Newly Installed Bedrock Well
RI - Samples Collected Between
January + September 1S86
10/87 - Additional Samples Collected
in October 1987
Reported Levels of Contaminants
are mg/L (parts per million)
• No Contaminants Detected
BW-14 (downgradient 800 fto) -
200
SCALE IN FEET
FIGURE NO. 15 LOCATIONS AND CONCENTRATIONS OF VOLATILE CONTAMINANTS
ASSOCIATED WITH DISPOSAL AREA 6 FOUND IN THE GROUNDWATER
IN GREGG VALLEY
-36-
-------
>T ACID PIT DISPOSAL AREA '//
»:.••.• \ ' V
t • \' •-•-•-. \ --.. *Cr-
-x/ •' / ' A
^sw-13 / /(' // ^./[
i_AiTCOncfli / fltxrA 'e/ / .-•'?
'"ni/xfc? -^
'•• I •• -l^-^-^f^''.-''• .t--::---., V'-.jV-I . >">/;>
///./ •' -./ .' ., I ... ;
«r%: >
\\ f !i'^--~.r- ,
LEGEND
O Existing Monitor Well
O Newly Installed Surficial Well
• Newly Installed Bedrock Well
RI - Samples Collected Between
January + September 1986
10/87 - Additional Samples Collected
in October 1987
Reported Levels of Contaminants
are mg/L (parts per million)
N/D - No Contaminants Detected
SCALE IN FEET
FIGURE NO. 16 LOCATIONS AND CONCENTRATIONS OF NON-VOLATILE CONTAMINANTS
ASSOCIATED WITH DISPOSAL AREA 6 FOUND IN THE GROUNDWATER
IN GREGG VALLEY
-37-
-------
f
Well Well
Location Type
SU 12 Shallow
SW 13 Shallow
BU IK Bedrock
/ •? / / s
/ •* & v *?
• •» » •
N > S*
& v 5*
** f?
-------
PIT DISPOSAL AREA
y-r-" . i.
- »• _ ••- " s
— N/D
DISPOSAL AREA
O Existing Monitor Well
9 Newly Installed Surficial Well
• Newly Installed Bedrock Well
RI - Samples Collected Between
January + September 1986
x^E-r^Sx
10/87 - Additional Samples Collected
in October 1987
Reported Levels of Contaminants
are mg/L (parts per million)
N/D - No Contaminants Detected
i \ -4r.
-- .--«5
(downgradient 800 ft.) - N/D
SCALE IN FEET
FIGURE NO. 17 LOCATIONS AND CONCENTRATIONS OF VOLATILE CONTAMINANTS
ASSOCAITED WITH DISPOSAL AREAS 7/8 AND 9 FOUND IN THE
GROUNDWATER IN GREGG VALLEY
-39-
-------
PIT DISPOSAL AREA
(2-ethylS.ryI)
phthalat*
Di-n-cctyl phehalat*
DISPOSAL AREA 7/8
DISPOSAL AREA
t2-«thylh«xyl)
phthalat*
Total OrgBriie
fl.fili
0.030
1.000
0.050
Dl-o-octyl phthalac*
RDt
Total On^nic Ralidn
* i /! •'' \\
O Existing Monitor Well
O Newly Installed Surficial Hell
• Newly Installed Bedrock Well
RI - Samples Collected Between
January + September 1986
10/87 - Additional Samples Collected
1n October 1987
Reported Levels of Contaminants
are mg/L (parts per million)
N/0 - No Contaminants Detected
Bis <2-«thylh«*yl)
phthalat*
W-14 (dounoradicnt 800 ft.) - Oironii» 0.060
SCALE IN FEET
FIGURE NO. 18 LOCATIONS AND CONCENTRATIONS OF NON-VOLATILE CONTAMINANTS
ASSOCIATED WITH DISPOSAL AREA 7/8 AND 9 FOUND IN THE
GROUNDWATER IN GREGG VALLEY
-40-
-------
fplatlles
EntracUblea
7~7
Metals
7
well Well
Location Type
x-«S Eilatlng
SW-8 Shallow
BU-IH Bedrock
/i / / ** //// *// * ** J '£/*//' / /* / *
(0.01 ... . * + « » . - NA
4.3 0.012 0.31 0.069 <0.01 . 0.05 0.06 0.09 0.05 ...
0.06 ......
6.«a
8.5
• i not detected
«. » delected but not In significant levels
HA t not an.ilyxed
(1) Phi hula tie concentrations are assigned to be the result of contact between groundwater and phthalate-contalnlng Mterlala during well Installation
or handling and analysis In the laboratory.
(2) Contaminant Levels Measured in mg/L (parts per million)
TABLE NO. 10
CONTAMINANTS POUND IN THE GROUNDWATER IN THE VICINITY OF
DISPOSAL AREA 7/8
-------
Volatlles
7
Extractables
7
Well Well / f a' / , / /$ // ///////$// £/ / *,
Location Type / * ^ / «* £ / V *7 / *7 / V /
8.18
and phthalate-contalnlng
TABLE NO. 11
CONTAMINAITTS POUND IN THE GROUNDWATER IN THE VICINITY OF
DISPOSAL AREA 9
-------
,-N/D
Pn DISPOSAL AREA
DISPOSAL AREAJ/8 V/^/7/|'A\
' 1\ \
1 ,2-Oi chloxoBthm
Tin
H«thyl«m Chloride
Etnylbmsmt
T*tnd)loxottt»ra
Chloroform
Brtrofora
Ccroon TcEnchlorid*
DISPOSAL AREA
x
\'- \--\v /
^. \-.\\\ {
* \v *•** ^> x*--
1.2-0ichloit»eh«n» 0.625
TrictaocoeMWM 0.530
mthylen. eWorld* 0.235
Ttan9-1.2-dichloioechcn* 0.135
in _ 10/87
TTTSB"
0.014 0.018
0.009
0.009
T«cr»e3jloro«th«n»
Chlorof
Cirtxm Tvtrmchlorid*
M 10/87
o7§7o" zT55b
0.260 0.160
0.050 0.110
0.190 0.670
-1,2-dicMoractiwnt 0.080
1,2-Di chl oro> Chun
Tti eMorachcn*
Chloride
1.2-DictUom
Ttichloro«th«»
:-. V \Jf '
• . » ._/•• , •«-
• '. X-. t. \
A V V,V^---
\ *•/,r*S5~'~~-:••''/'•' x*>
\ > -''
RI 10/87
2.700 TT750"
2.000 3.400
0.380 0.650
0.420 0.330
0.086 0.520
0.040
0.017
O Existing Monitor Well
O Newly Installed Surficial Well
• Newly Installed Bedrock Well
RI - Samples Collected Between
January + September 1986
10/87 - Additional Samples Collected
in October 1987
Reported Levels of Contaminants
are mg/L (parts per million)
N/0 - No Contaminants Detected
. -' x
BU-14 (downgrtdient BOO ft.) - VO —-S ^ X / ."-^•_-•-..; } .-
'
SCALE IN FEET
FIGURE NO. 19 IDCATIONS AND CONCENTRATIONS OF VOLATILE CONTAMINANTS
ASSOCIATED WITH ACID PIT DISPOSAL AREA FOUND IN THE
GROUNDWATER IN GREGG VALLEY
-43-
-------
V/M/^^S
ACID PIT DISPOSAL AREA
Bis (2-*thylhwtyl>
phcMlau
Di-n-cctyl
Sz^v^^'''' '' J/~^
«
DISPOSAL A 7/8 ..
r. v^^v.'-'-x .-•/ ( s^-
• •,-/—-:-.'- x / ( >^. ^~
r/x •» ; /**—ill" ~-^// / ,-frJ I/ .' X
SVS$ Bis (2^thvlh«yl) B^W-t -X-' VX/Tj-^^X-V /* // / />
VN^S ph.tai.tt \ -3 ^^'l/ :\.// /& //' ! // t
^%^^ > AY2^i>^^,///
BW-14 (deuncndicnt 800 ft J - Chronlvi* 0.060—yX 7.^--' . 1 ( / • - ^200
^ .% « = : n-. \ » \/ j j . f'l"> "! / ) / X / V ^^Ei=K^
?t>^;.......-: 5 /: • v^/V- v'>"-//-::r:^. *f\<"?S ': * . SCA
/
200
SCALE IN FEET
FIGURE NO. 20 LOCATIONS AND CONCENTRATIONS OF NON-VOLATILE CONTAMINANTS
ASSOCIATED WITH ACID PIT DISPOSAL AREA FOUND IN THE GROUNDV3ATER
IN GREGG VALLEY
-44-
-------
Well
Location
Well
Type
Upqradlent
BN 7
BN 10
8N 10
MISLS
NIM.I
NISLt
M)t2
SN 7
SN II
12
II
IN 2
IN 1
BM »
BN 11
BN 12
BN l«
Bxlitlnq
bitting
RiUtlm)
Shallow
Shallow
bUtlna
bUt Ing
Int«riMdUt«
IntanMdUt*
Bedrock
B^lrock
BMlrock
Bedrock
0.014
0.«2)
0.040
<0.0t
».2
0.021
2.7
0.»7
<0.01
<0.01
0.040 ....
o.)io o.2i)
-------
/
Entraclables
7
r<|iloslves
7 7
7
Uell Uell
Location Type
Upgradlcnt
IM 7 nedroek
BU 10 nedroek
SU 10 Shallow
Dotmgf.idlent
K85L5 Existing
M85C8 Existing
H85L9 Existing
HB5I2 Existing
SM 7 Shallow
SU It Shallow
12 Existing
13 Existing
/ J ? ?f / f A A. / //I 3 / § I 1 V I $ 1 *
/ * V *f /* 9 f / */ / */ / •* * / */ / */ / fy
0.016 - 0.90 ....
* late concentrations are assumed to be the result or contact between groundwater and
lini'll Inc. and analysis In the laboratory
(2) Contaminant Levels Measured in mg/L (parts per million)
O.M NA
NA
0.01 NA
• NA
1.0 - 0.05 - NA
0.7 NA
NA
0.06 . NA
• . - - NA
• . . . NA
0.0] - NA
NA
0.10 . NA
NA
<0.01
• . . . NA
0.06 - NA
9.U
6.75
6.60
6.31
6.88
«.77
6.32
6.06
5.61
6.73
«.92
6.12
6.08
6.53
6.23
8.16
8.18
phthalate-contalnlng materials during well Installations or
TABLE;
COMTAMINAmT? FOUND IN TOE GRDUNDWATER IN THEJ^CINITY OF
THE ACID PIT DISPOSAL AREA
-------
-47-
property east of Gregg Branch also drains directly into Bee Tree Creek. These
last two areas contain no known disposal areas. It is evident from surface
topography that surface runoff from on-site disposal areas discharge directly
to the unnamed or Gregg Branch only and not directly to Bee Tree Creek.
Surface water and sediment samples were collected from the unnamed creek
draining the Front Valley, Gregg Branch draining Gregg Valley, Bee Tree Creek,
and their tributaries (Figures 22 and 23). All sampling was conducted when
storm runoff was negligible so that the streamflow in these streams consisted
of baseflow only. Therefore, surface water contamination is indicative of
contaminated groundwater at or above the sampling point.
Analysis of surface water and sediment samples indicate contaminated baseflow
is entering the streams on-site. In all cases, concentrations decrease to
levels below detection limits downstream of the suspected sources. The major
factors contributing to the reduced levels of contamination downstream are
volatilization and/or dilution.
Analysis of sediment samples indicate erosional transport mechanisms at work
transporting contaminants away from the disposal areas. The concentrations of
the contaminants associated with the sediment also decrease downstream.
In general, metals were detected in sediments from the two ecu-site branches but
not in sediments from Bee Tree Creek. This is most likely due to the different
depositional characteristics of the sampling sites which affect the chemical
characteristics of the sediment from those on-site.
3.6.1 SURFACE WATER AND SEDIMENT CONTAMINATION IN THE FRONT VALLEY
Figure 22 provides the locations of the sampling points where surface water and
sediment samples were collected as well as a compilation of the data associated
with this sampling episode.
In summary, surface water data indicates the presence of groundwater sources of
volatile organics at DA-23 and near Building 104. Sediment analytical data
indicates surface erosion sources at DA-23, above RW-8 and above RV-12. The
surface water data also indicates that the groundwater is also contaminated by
explosives. These sources are probably either DA-23 or the leach field
associated with Process Building 115.
No explosives were detected in any if the sediment samples indicating that
surface runoff and erosion have not contributed explosives contaminants to the
surface water.
3.6.2 SURFACE WATER AND SEDIMENT CONTAMINATION IN GREGG VALLEY
Figure 23 provides the location of the sampling points where surface water and
sediment samples from Gregg Valley were collected. Also presented in Figure 25
are the contaminants found along with their concentrations.
-------
.
;/-••- .'
/ »• * •
GREGG BRANCH
WATERSHED
691 ACRES
y _x-^. N. (
/ ',.; % ^7^
^ -;'.Ns!-- T"
UNNAMED BRANCH
WATERSHED
221 ACRES
.f^k'* 1
SCALE IN FEET
FIGURE NO. 21 DRAINAGE AREAS FOR THE UNNAMED BRANCH AND GREGG BRANCH
-48-
-------
N» \\\l :. ^ '• • ( i• • A .
\ \\V~- ' \ I •'• '• * ' KT^
\ \ V>. ; \ .JL \ \
\ *» >v '—' / n\ . ; l»O>yl«r» ChloridB
• *•• ^b. / • • OUort«n»
^>
, \
1.2 Oiehloro»th«n» (w) 0.012
oaototon. <-) O.OS2 (») 0.010
MthyUm OOariito <•> 0.029
Chlorite (•) 0.016
OUardw (v) 0.0
(w) 11.000 (•) 0.085
0.011
1.1.2-McMorathm* (w) 0.012
Mthylww QUortdt (•) 0.020
OOantom (w) 0.018
1.2 Mchloracctam
1.2
Trlchlecactten*
Mtthylara QUeri
ChloidwM
K»thyl«r» OUorid* (•) 0.016
Otlortin* (w) 0.030
4.4'-OCe (») 0.020
200* 400' 600' (w) - Surface Water Sample
(s) - Sediment Sample
N/D - No Contaminant Detected
Reported Levels of Contaminants
are mg/L (parts per million)
FIGURE NO. 22 LOCATIONS AND CONCENTRATIONS OF CONTAMINANTS FOUND IN THE
SURFACE WATER AND SEDIMENT IN THE UNNAMED BRANCH AND BEE
TREE CREEK
-49-
-------
-50-
In summary, Che surface water analysis indicates a contaminated groundwater
source of volatile organics from DA-7/8 and/or DA-9. No migration of volatile
organics to surface water is indicated from the acid pit area or DA-6.
Sediment samples indicate that significant volatile organic contamination from
surface runoff does not occur from any of the disposal areas in Gregg Valley.
Water and sediment samples from RW-28, at the mouth of Gregg Branch indicates
no detectable migration of volatile organics off-site via surface water into
Bee Tree Creek.
Cyanide was detected in surface water and sediment samples. Cyanide was found
in a sediment sample from RW-21, downstream of DA-6 and the acid pit area.
Cyanide was also found in the groundwater in MW IW-2. This well is located
downgradient of DA-6 and the acid pit area. Cyanide was also found in soil
samples from the following borings: AP-3, AP-4, AP-5, AP-9, AP-11, AP-15, and
AP-19. Cyanide was also found in a test pit sample from DA-6. This indicates
that sediment cyanide at RW-21 is most likely due to runoff or erosion from the
DA-6 and/or the acid pit area. Cyanide was not found in water leaving Gregg
Valley as indicated by the analytical results for sample RW-28 (Figure 23).
3.7 RECEPTORS
The routes of exposure examined in the Risk Assessment were:
1) ingestion of contaminated groundwater, surface water and wild life;
2) direct contact with the contaminants in the soil, surface waters or
groundwater; and
3) inhalation of vapors or contaminated particles.
The aquifer under the Chemtronics Site is classified as Class IIB, a potential
source of drinking water, using the USEPA Groundwater Classifications
Guidelines of December 1986. Although the site aquifer is not currently used
for drinking water purposes, potential (future) use was incorporated in the
baseline risk assessment. Consideration of potential groundwater use is
consistent with 40 CFR Section 300.68(e)(2)(v).
Groundwater, as noted, is contaminated on-site. The general flow of
groundwater is to the east and west to the unnamed stream and Gregg Branch and
east to Bee Tree Creek, discharging to these surface water features.
Groundwater contamination was particularly noted downgradient of the Acid Pit
Area and DA-23. No drinking water wells exist between the site and the
groundwater discharge points, thus a pathway via domestic well usage does not
exist.
Currently, fugitive dust particle generation is considered an unlikely event.
The majority of the disposal areas are capped by dirt and are vegetated. One
area, although vegetated, has numerous empty drums exposed at ground level.
This area, DA-9, was identified in the Rl to have the greatest degree of risk
to exposure to the contaminants present. The chance of exposure is greatly
reduced to the remoteness of this disposal area.
-------
- -- 'i': \
&r
\
i •
\ ' .
.. \
-I
«
- "*\
- N -
'Ix
2OO* 400' 6OO'
. ^ "" .-' X''
*V /' "-
•.:—::><-'" .--^ ,-
-—-. +>- ^
-....--'','
•*-~"*<*f,Tais
(w) 0.4W ^*X«-«^-««*p**»4
*
tJHtl ^^^^^^ RW~**
U) OJJM
• ^'
. t • •
• L • *
.'>,. v:-/
.' , . ./ -~VAO - ^ \ y .^
?!~ fa i>/-c-5T '-^P
....-' V *f-'30/ --... •--.
hrf^.*._ . ^>
(•) 1.100
0.480
(v) 0.010 (•) 16.00
(•) 7.40
« • I *^^ • • * ««Bfi^VC
\\->r\_:::.- "-
vVv--~—--::..- •->•• / .-
(•) OJ10
(•) 0.720
(w) - Surface Water Sample
(s) - Sediment Sample
N/D - No Contaminant Detected
Reported Levels of Contaminants
are mg/L (parts per million)
FIGURE NO. 23 LOCATIONS AND CONCENTRATIONS OF CONTAMINANTS FOUND IN THE
SURFACE VKTER AND SEDIMENT IN GREGG VALLEY AND BEE TRE2
CREEK
-51-
-------
-52-
Contaminated soils will continue to leach to surrounding soils and groundwater.
Surface runoff from surface soils may contaminate additional soils and surface
waters and sediments, although concentrations would not be expected to be high.
4.0 CLEANUP CRITERIA
The extent of contamination was defined in Section 3.0, Current Site Status.
This section examines the "applicable and relevant or appropriate regulations"
(ARARs) associated with the contaminants found on site and the environmental
medium contaminated. In the cases where no specific ARAR can be identified, a
defendable minimum goal of remedial action will be presented.
4.1 GROUNDWATER REMEDIATION
In determining the degree of groundwater clean-up, Section 121(d) of the
Superfund Amendment and Reauthorization Act of 1986 (SARA) requires that the
selected remedial action(s) establish a level or standard of control which
complies with all ARARs.
This remedy is a cost-effective remedy which will-achieve a level protective of
human health as will as remove the threats this Site poses to the environment.
The remedy will meet appropriate requirements, and is cost-effective. Finally,
the remedy utilizes permanent treatment technologies to the maximum extent
practicable.
The presence of several contaminated found on Site presented some special
problems with respect to the establishment of target cleanup levels. Since
these chemicals either lack or have only limited human health standards and .
supporting physiochemical and toxicological data, it was necessary to develop
preliminary pollutant limit values (PPLVs) for critical exposure pathways,
using estimates of acceptable daily doses (D ) and partition coefficients.
The calculations and supporting references for these PPLVs are presented in
Appendix A of the Feasibility Study.
For those contaminants found in the groundwater on-site Table 13 presents the
levels the migration control remedial alternative will achieve at a minimum.
4.2 SOIL REMEDIATION
The Public Health and Environmental Assessment in the RI (Chapter 4),
determined that risks to human as a result of exposure to on-site contaminants
via inhalation, ingestion and dermal contact are very low under present Site
conditions. For potential future use scenarios, the risk is slightly higher.
Therefore, remediation and institutional controls will be necessary to assure
that an increased risk to human health is not posed in the future.
-------
TABLE NO. 13 GROUNDWATER REMEDIATION LEVELS AND CITED REFERENCES
cc
1,2-Dichloroethane
Trichloroethylene
Methylene Chloride
Trans-l , 2-Dichloroethylene
Benzene
Chloroform
Ethylbenzene
Tetrachloroethylene
Carbon Tetrachloride
Toluene
Picric Acid
BOX
TOT
Total Cyanides
Chromium
Nickel
Copper-
Zinc
Benzilic Acid
Benzophenone
Bemediation Level
gp/1
0.005
0.005
0.06
0.07
0.005
0.1
0.68
0.007
0.1
0.005
2.0
14.0
0.035
0.044
0.200
0.05
0.05
0.5
1
5
0.021
0.152
Source
MCL
MCL
BSD
RMCLG
MCL
MCL(TTHM)
f*£XG
BSD
MCL(TTHM)
MCL
PMCLG
PPLV
USAIHQC
PPLV
BfD
MCL
MCL
BfD
MCL
WQC
PPLV
FPLV
MCL — Maytmtim Contaminant Level.
MCL(TIHM) - The MCL for Total Trihalomethanes (sum of all concen-
trations) is 0.1 ng/1. TTHM's include chloroform,
brCtQOformf ^r' "" riirf^lft{.tiiiMO^aneT and <^»Tonrrfi'hi LIU >—
methane.
PMCLG - Proposed Maximum Contaminant Level Goal 50 TR 46936-47022
(November 13, 1985).
PPLV - Preliminary Pollutant Limit Value (see Appendix A).
BfD - Reference Dose 52 FR 29992-29997 (August 12, 1987).
BSD - Bisk Specific Dose, 51 FR 21648-21693.
USAINQC - US Army Water Quality Criteria. The given values have
been approved by the Army Surgeon General.
VJQC - Clean Water Act, Water Quality Criteria for Human Health
- Adjusted for Drinking Water Only, [Gold Book].
From TLV - Calculated from a Threshold Limit Value, based on a 70 'kg 1
person uho drinks. 2 liters of water per day. A safety
factor of 100 has also been applied.
-53-
-------
TABLE NO. 14 SOIL REMEDIATION LEVELS FOR CONTAMINANTS LACKING
PROMULGATED CRITERIA OR STANDARDS
Contaminant Group
PCBs
3-Ouinuclidinol
Benzilic Acid
Benzophenone
CS ( 2-Chlorobenzal-
malononltrile )
Malononitrile
O-Chlorobenzaldehyde
TNT
RDX
Picrate/Picric Acid
Soil Standard (mg/Kg)
10
25.7
9.3
9.3
43.3
N/A+
0.31
305
95
38,000
Source
TSCA
PPLV
PPLV
PPLV
PPLV
PPLV
PPLV
PPLV
PPLV
PPLV
+ - Malononitrile would not persist in soil based upon K
-------
-55-
Table 14 presents remediation levels the source control remedial alternative
will achieve. This includes PPLVs for these contaminants lacking promulgated
criteria or standards.
*
4.3 SURFACE WATER/SEDIMENT REMEDIATION
The contaminant levels In the surface waters (the unnamed stream and Gregg
Branch) are expected to decline with the implementation of groundwater and soil
remediation. Thus, it was concluded that the remediation of surface water is
not necessary. A biomonitoring program will be implemented to document that
the remediation activities do not have an adverse affect on the surface
waters. The RI did not identify any contaminants entering Bee Tree Creek from
the Site.
5.0 ALTERNATIVES EVALUATED
The purpose of the remedial action at the Chemtronics Site is to mitigate and
minimize contamination in the soils and ground water, and to reduce potential
risks to human health and the environment. The following clean-up objectives
were determined based on regulatory requirements and levels of contamination
found at the Site:
* To protect the public health and the environment from exposure to
contaminated on-site soils through inhalation, direct contact, and
erosion of soils into surface waters and wetlands;
* To prevent off-site movement of contaminated groundwater; and
* To restore contaminated groundwater to levels protective of human health
and the environment.
An initial screening (Table 15) of applicable technologies identified to
address both source and migration control was performed to retain those which
best meet the criteria of Section 300.65 of the National Contingency Plan
(NCP). Following the initial screening of technologies, potential remedial
action alternatives for source control were identified and analyzed. These
alternatives were further screened and those which best satisfied the clean-up
objectives, while also being cost-effective and technically feasible, were
developed further.
Table 16 identifies those source control alternatives that were retained
following the initial screening of technologies. Table 17 associates the cost
of each of these alternatives. The alternatives retained following the cost
evaluation are presented in Table 18.
The same sequence of screening and evaluations procedures was conducted on the
potential migration control remedial action alternatives that were retained
following the evaluation of these technologies on technical merit (Table 15).
Following the initial screening, the potential remedial action alternatives for
migration control were identified and analyzed (Table 19). Costs for each of
-------
TABLE NO. 15
(continued)
RESULTS OP TECHNICAL EVALUATION OF SOURCE CONTROL
AND MIGRATION CONTROL TECHNOLOGIES
l
ui
Technology Status
No Action Retained
Secondary Water Supply Rejected
Discharge to POTW Retained
Activated Carbon Adsorption Retained
Aerobic Biological Treatment Rejected
Anaerobic Biological Treatment Rejected
PACT Rejected
Fixed Film Systems Retained
Filtration Retained
Precipitatlon/Flocculatlon Retained
Sedimentation Retained
Ion Exchange/Sorptlve Resins Retained
Reverse Osmosis Rejected
Neutralization Retained
Chemical Oxidation Rejected
Chemical Reduction Rejected
Air stripping Retained
Steam Stripping Rejected
Steam Distillation Rejected
Liquid/Liquid Extraction Rejected
Llquid/CO- Extraction Rejected
Catalytic Dehydrochlortnatlon Rejected
Wot Air Oxidation Rejected
Incineration Rejected
Hydrolysis Rejected
Ultraviolet/Ozonatlon Retained
Spray Irrigation Rejected
Horizontal Irrigation Rejected
Extraction Wells Retained
Subsurface Drains and Retained
Interception Trenches
Reason
No Impacted receptors
Too low COO to support biological growth
Potentially unstable operation, too low COO to support biological growth
Too low COD to support biological growth
Potential for growth on membrane and damage to membrane from Iron and manganese
Technically Inferior to ultravlolet/ozonatlon.
Little applicability In treating Identified contaminants
No ready source of steam, unsuitable contaminants; cost
Inability to separate several contaminants from water because of similar boiling
points; cost
Cannot remove compounds to remediation levels
Less than 401 recovery rate for many organlcs
Unproven technology on full-scale basis
Chlorinated species too stable for wet air oxidation; cost
BTU value of waste stream too low; cost
Inappropriate technology
Would not remove or degrade all compounds
Would not remove or degrade all compounds
-------
TftBLE NO. 16 POTENTIAL SOURCE CONTROL REMEDIAL ACTION
ALTERNATIVES (Prior to Cost Evaluation)
1A NO Action
IB Fence DA 9; no action elsewhere
2A Cap DA 9; no action elsewhere
2B Off-site landfilling of top 2 feet in DA 9; no action
elsewhere
3A cap DA 7/8, 9, 10/11, 14, and 23; no action in DA 6 and
rest of Acid Pits
3B Cap DA 6, 7/8, 9, 10/11, 14, and 23; no action in rest
of Acid Pits
3C Cap all en-site areas
4A SoU vent DA 14 and DA 23; cap DA 6, 7/8, 9, and 10/11
4B HWT fixation of soils in DA 14 and DA 23; cap DA 6, 7/8,
9, and 10/11
4C Off-site landfilling of DA 14 and DA 23; cap 6, 7/8, 9,
and 10/11
4D On-site incineration of DA 14 and DA 23; cap DA 6, 7/8,
9, and 10/11
5A HOT fixation of soils in Table 4.14; off-site
incineration of buried drums
SB Off-site landfilling of soils in Table 4.14; off-site
incineration of buried drums
5C On-site incineration of soils in Table 4.14 and buried
-58-
-------
TABLE NO. 18 RETAINED SOURCE CONTROL REMEDIAL ACTION ALTERNATIVES
Alternative
1A Kb Action
IB Fence DA 9; no action elsewhere
2A Cap DA 9; no action elsewhere
2B Off-site lardfilling of top 2 feet in DA 9; no action
elsewhere
3A . Cap DA 7/8, 9, 10/11, 14, and 23; no action in DA 6 and
rest of Acid Pits
3B Cap DA 6, 7/8, 9, 10/11, 14, and 23; no action in rest
of Acid Pits
3C Cap all on-site areas
4A Soil vent DA 14 and DA 23; cap DA 6, 7/8, 9, and 10/11
4B HHT fixation of soils in DA 14 and DA 23; cap DA 6, 7/8,
9, and 10/11
4D On-site incineration of DA 14 and DA 23; cap DA 6, 7/8,
9, and 10/11
5C On-site incineration of soils in Table 4.14 and buried
-60-
-------
-61-
these retained alternatives are given in Table 20. These alternatives were
further screened and those which best satisfied the clean-up objectives, while
also being cost-effective and technically feasible, were retained. Table 21
identifies these migration control alternatives that were considered in
finalizing the remedial action alternative selected for the Chemtronics Site.
Table 22 summarizes all the source control and migration control alternatives
considered for determining the remedial action for the Chemtronics Site.
6.0 RECOMMENDED ALTERNATIVES
6.1 DESCRIPTION OF RECOMMENDED REMEDY
The recommended alternative for remediation of groundwater and soil
contamination at the Chemtronics Site includes extraction,' treatment and
discharge of groundwater; capping and fixation/stabilization/solidification for
contaminated soils. The capped areas will be fenced with a chain-linked fence
and marked accordingly. The disposal area fixated/stabilized/solidified will
also be capped.
The water and sediment in the pond on the unnamed stream will be sampled. If
evidence of contamination is present, the pond will be drained with the water
being sent through the treatment system set up-for treating groundwater and the
sediment could either be fixated/stabilized/solidified with the soils of DA-23
or transported to another disposal area and be capped along with that disposal
area.
A monitoring program, employing bioassays, will be established for the surface
water. Monitoring locations will be located on the unnamed stream, Gregg
Branch and Bee Tree Creek. The purpose of this monitoring program is 1) to
insure no adverse impact on these streams during implementation of the remedial
action and 2) to establish a data base to use to measure the success of the
remedial action implemented.
Treatability studies will be performed for the contaminated soils in DA-23 to
determine the appropriate fixating/stabilizing/solidification process as well
as the mixing ratios for the components involved in the process. Following
replacement of the fixated/stabilized/solidified soils, DA-23 will be capped.
Soils in disposal areas DA-6, DA-7/8, DA-9, DA-10/11, and the Acid Pit Area
will be capped with a multi-layered cap which will include an inert synthetic
liner. Where determined necessary, a venting system will also be installed.
A groundwater extraction system will be installed in both the Front Valley and
in Gregg Valley. The extracted groundwater will either be treated in each
valley or combined and treated through a single system. The treated
groundwater will be discharged meeting all ARARs.
-------
TABLE NO. 19
POTENTIAL MIGRATION CONTROL REMEDIAL ACTION
ALTERNATIVES (Prior to Cost Evaluation)
ALTERNATIVE
DESCRIPTION
ExLi.dctJ.on
GWE-1
GWE-2
GWE-3
Mb Action
Weathered zone and surficial veils Gregg
Valley (DA 7/8, 9, Acid Pits) and Front Valley
(DA. 23 Area)
Weathered zone and surf icial wells Front
Valley (DA 23 Area)
Weathered zone wells and surficial trench
Gregg Valley (DA 7/8, 9, Acid Pits)
GWT-1
GWT-2
GWT-3
GWT-4A/B
GWT-5A/B
No Action
Discharge Untreated Groundwater to FOTW
Air Stripping
Discharge to POTW
Air Stripping
Adsorption with GAC
or
Oxidation with UV/Ozone
Discharge to POTW
Precipitatlon/Flooculation with Sedimentation
and Filtration
Air Stripping
Adsorption with GAC
or
Oxidation with DV/Ozone
Discharge to Surface Water
(Bee Tree Creek)
a) POTW — Buncombe County Metropolitan Sewer District
b) GAC — Granular Activated Carbon
-62-
-------
TABLE NO. 20 COST EVALUATION OF POTENTIAL MIGRATION CONTROL ALTERNATIVES
COST
GWE-1
GWE-2
GWE-3
Treatment
GWT-1
GWT-2
GWT-3
GWT-4A
GWT-4B
GWT-5A
GWT-5B
MO Action; Groundwater Monitoring
Extraction Wells; Downgradient DA 23
and DA 7/8, Acid Pits, DA 9
Extraction Wells; Downgradient DA 23,
Ocnibined Interception Trench and
Extraction Wells Downgradient DA 7/8,
DA 9, Acid Pits
No Action (Couples with GWE-1)
Discharge Untreated Groundwater to POTW
Air Stripping
Discharge to POTW
Air Stripping
Adsorption with GAC
or
Oxidation with UV/Ozone
Discharge to FOTW
Precipitation/Flocculation with
Sedimentation and Filtration with
Air Stripping
Adsorption with GAC
with
Oxidation with DV/Ozone
Discharge to Surface Water
(Bee Tree Creek)
$300,000
$400,000
$650,000
($300,000
from above)
$100,000
$225,000
$650,000
$1,250,000
$1,300,000
$1,900,000
a) POTW — Buncombe County Metropolitan Sewer District
b) GAC — Granular Activated Carbon
-63-
-------
TABLE NO. 21" RETAINED MIGRATION CONTROL REMEDIAL ACTION ALTERNATIVES
fiESJCPI UI'IOM
GWE-1 No Action, Groundwater Monitoring
GWE-2 Weathered zone and surficial wells Gregg
Valley (DA 7/8, 9, Acid Pits) and Front Valley
(DA 23 Area)
GWE-3 Weathered zone and surficial wells Front
Valley (DA 23 Area)
Weathered zone walls and surficial trench
Gregg Valley (DA 7/8, 9, Acid Pits)
Treatment
GWT-1 No Action, (Couples with GWE-1)
GWT-2 Discharge Untreated Groundwater to POTW
GWT-3 Air Stripping
Discharge to POTW
GWT-4 Air Stripping
Adsorption withGAC
Discharge to POTW
GWT-5 Precipitation/Flocculation with Sedimentation
and Filtration
Air Stripping
Adsorption with GAC
Discharge to Surface Water
(Bee Tree Creek)
-64-
-------
TABLE NO. 22 SUMMARY OF SOURCE AND MIGRATION CONTROL LTERNATTVES
ALTER-
NATIVE
U
11
2A
28
3A
SB
DESCRIPTION
No Action;
groundwater
Monitoring
(To be copied
with CUE-1)
No Action;
Fence OA-9
groundwater
monitoring
Cap DA 9
No Action
elsewhere;
groundwater
•onitoring
Off-site
landfilling
DA 9 No
action
elsewhere;
groundwater
•onitoring
Cap DA 7/8.
9, 10/11, U.
23; no action
DA 6,
remainder of
Acid Pits;
groundwater
•onitoring
Cap DA 6. 7/8.
9. 10/11. U.
23; no action
remainder of
Acid Pits;
groundwater
•onitoring
PRESENT TECHNICAL
UDRTH COSTS ASPECTS
$282,800 None
S295.000 None
$383,000 Proven technology;
readily constructed;
effective since
waste is above
water table
$543,000 High level of
remediation; uses
available equipment
$1,079,600 Proven technology;
readily constructed;
effective since
waste is above
water table; special
considerations in
DA 10/11 and 23
81,155,300 Proven technology;
readily constructed;
effective since
waste is above
water table; special
considerations In
DA 10/11 and 23
PUBLIC HEALTH
ASPECTS
Risk of soil contact
OA 9 unabated;
potential of limited
groundwater contamination
Migration in future
Fence reduces risk
of soil contact;
potential of limited
groundwater contamination
•igration in future
Risk of soil contact DA 9
eliminated; future
•igration of
contaminants still
possible
Risk of soil contact DA 9
eliminated; additional
health risk during
excavation and
transportation
Risk of soil contact
eliminated; risk of
future groundwater
contamination reduced
Risk of soil contact
eliminated; risk of
future groundwater
contamination reduced
ENVIRONMENTAL
ASPECTS
*
No direct impact
on source material;
detection monitoring
included
Sources of ground-
water contamination
not affected
Continued potential of
grounduater contamin-
ation from areas
ether than DA 9
Continued potential
of future groundwater
contamination in
all areas
Potential for ground-
water contamination
reduced in
capped areas
Potential for ground-
water contamination
reduced in
capped areas
INSTITUTIONAL
ASPECTS
Nay not comply with
SARA; Class 5
alternative
Class 5 alternative
Class 1 alternative;
cap restricts use
of DA 9
Class 4 alternative
Class i alternative;
restricted use of
capped areas
Class 2 alternative;
restricted use of
capped areas
-65-
-------
TABLE .NO. .22
(continued)
SUrWARY OF SOURCE AND MIGRATION CONTROL LTERNATTVES
ALTER-
NATIVE DESCRIPTION
PRESENT
WORTH COSTS
TECHNICAL
ASPECTS
PUBLIC HEALTH
ASPECTS
ENVIRONMENTAL
ASPECTS
INSTITUTIONAL
ASPECTS
Potential for ground-
water contamination
reduced in all capped
areas
Cap all on- S1.87D.OOO Proven technology; Risk of soil contact
site disposal readily constructed; eliminated; risk of
areas; affective since off-site grounduatar
grounduater waste is above contamination reduced
titoring water table; special
considerations in
DA 10/11 and 23
4A Soil vent DA (2,277.200 Proven technologies; Risk of soil contact Potential for ground-
14. 23 soil venting eliminated most areas; water contamination
Cap OA 6, 7/8, effective with risk of future grounduater reduced in all areas;
9. 10/11; ' volatile contaminants-contamination reduced;
groundwater mobile source soil venting may
titoring material reduced require carbon filters
for emissions
Class 2 alternative;
restricted use of
capped areas
Class 2 alternative;
restricted use of
capped areas
HUT fixation S4.279.400 Long-term effective- Risk of soil contact Potential for ground-
OA 14, 23 to ness with Cheatronics'eliminated most areas; water contamination
Cap DA 6, 7/8, 35,994,400 soils are unknown, risk of future groundwater reduced in all areas;
9. 10/11; must be verified; contamination reduced;
grounduater mobile source additional health risk
monitoring material reduced during excavation
On-site $5,684,200 Proven technology;
incineration to extremely effective;
of DA 14. 23 86,773.500 transportable unit
Cap OA 6, 7/8, not available until
9, 10/11; 1988; noble source
grounduater material reduced;
monitoring ash may require
special handling
Risk of soil contact
eliminated; risk of
future groundwater
contamination reduced;
additional health risk
during excavation and
staging
Potential for ground-
water contamination
reduced in all areas;
Class 2 alternative;
restricted use of
capped areas
Class 2 alternative;
restricted use of
capped-areas
5C On-site
S7.313.300 Proven technology; Risk of soil contact
Greatest reduction in Cless 2 alternative;
incineration
of all
significant
soils and all
buried drums;
groundwater
monitoring
No Action
OA 24
to extremely effective;
$8,725,100 transportable unit
not available until
1988; significantly
reduce source
eiateriel; ash may
require special
handling
SO
Drain on-site 52.000
Pond
None
None
eliminated; greatest
reduction in risk of
future groundwater
contamination; additional
health risk during
excavation and staging
PCB levels are below
remediation standard*
None, stocking and
fishing no longer
potential for ground-
water contamination;
None
None
fewest restrictions
on future use of
disposal areas
Class 5 alternative
Class 5 atterr
-66-
-------
TABLE NO. 22
(continued)
SUMMARY OF SOURCE AND MIGRATION CONTROL LTERNATIVES
ILTER- PRESENT
IATIVE DESCRIPTION WORTH COSTS
CUT-1 Ho Action; $282,800 None
TECHNICAL PUBLIC HEALTH
ASPECTS ASPECTS
None
grounduater No treatment reqired
monitoring
(To be coupled
only with GUE-1)
ENVIRONMENTAL INSTITUTIONAL
ASPECTS ASPECTS
None None; Class 5
alternative
CUT-2 Untreated
discharge to
POTU
CUT-3 Air stripping
prior to dis-
charge to POTU
S280.300 POTU capable of
achieving high levels
of removal; trans-
nit ting grounduater
poses no difficulties;
possible transmission
line limitation
$437.600 Air stripping la
proven technology;
POTU capable of
removing contaminants;
possible transmission
line limitation
No pass through
toxicity anticipated
No pass through
toxicity anticipated
Expect high level
of removal; en-site
grounduater is
remediated
Expect high level
of removal; on-stte
grounduater ia
remediated
Modification of
pretreatment pertBit;
discharge may exceed
standards; potential
Class 3 alternative
Modification of
pretreatment permit;
discharge uill meet
TTO level; Class 1
alternative
CUT -
Air stripping,
GAC prior to
discharge
CUT-5 Metals removal,
•ir stripping,
GAC prior to
discharge to a
surface water
CUE-1 No Action;
groundwater
monitoring
S992,600 Proven technologies;
GAC cannot be
regenerated because
of explosives;
possible transmission
line limitation
81,594,700 Proven technologies;
operator may be
required; GAC cannot
be regenerated
$282,800 None
No pass through
toxicity anticipated
None,
effluent uill •
drinking water
standards
No effect on present
grounduater
contamination; no
present receptor*
identified
Expect high level
of removal; en-site
grounduater is
remediated
On-site grounduater
is remediated;
sludge generated
may reqire special
handling
Possible future
migration of
contaminated
grounduater
Modification of
pretreatment permit;
discharge uill meet
TTO level; Class 2
alternative
Requires NPDES permit
may require hazard-
ous uaste handling;
Class 2 alternative
May not comply with
all ARAR's; Class 5
alternative
GUE-2 Extraction wells $378,500
in Front and
Gregg Valleys
Proven technologies;
extraction wells are
capable of recovering
grounduater
contaminants; expect
moderate level of
removal due to
lou aquifer yield
Significantly minimizes Significantly reduces
potential for ground- future migration of
water contaminants to contaminated
reach receptors in grounduater
future
Class 2 alternative
-67-
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TABLE NO. 22
(continued)
SUMMARY OF SOURCE AND MIGRATION CONTROL LTERNATTVES
ALTER*
NATIVE DESCRIPTION
PRESENT
WORTH COSTS
TECHNICAL
ASPECTS
PUBLIC HEALTH
ASPECTS
ENVIRONMENTAL
ASPECTS
INSTITUTIONAL
ASPECTS
CUE-3 Extraction well* S653.600
in Front and
Gregg Valleys;
interception
trench in
Cregg Valley
Proven technologies;
extraction wells are
capable of recovering
groundwater
contaminants; expect
•oderate level of
ranoval due to
leu aquifer yield;
additional install*
at tor. considerations
Significantly aiiniaizes Significantly reduces Class Z alternative
potential for grand- future Migration of
Mter contaminants to contaminated
reach receptors in groundwater
future
-68-
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-69-
These recommended alternatives meet the requirements of the NCP, 40 CFR Section
300.68(j) and SARA. This recommended remedy permanently and significantly
reduces the volume of hazardous substances in the groundwater, reduces the
toxicity and/or mobility of contaminants in the soils.
6.2 OPERATIONS AND MAINTENANCE
When the remedy is completed, long-term operation and maintenance (O&M) will be
required for the caps along with long-term monitoring of the groundwater. This
will assure the effectiveness and permanence of the source control remediation
and groundwater remedies. Long-term O&M will also be required for monitoring
the groundwater extraction systems and the groundwater treatment system(s).
6.3 COST OF RECOMMENDED ALTERNATIVE
Capital cost for groundwater remediation is estimated to be $239,000 with
system O&M cost at $139,500 for 30 years, which includes sampling and
analysis. The total present worth cost of the groundwater remediation is
$378,500.
Capping disposal areas DA-6, DA-7/8, DA-9, DA-10/11 and the Acid Pit Area with
a multi-layered cap is estimated to be less than $1,282,500.
Fixation/stabilization/solidification of the soils in DA-23 followed by capping
will cost an estimated $3,998,800, with O&M cost at $280,500 for 30 years. The
O&M costs for all caps is $362,400. The above costs include engineering,
overhead, profit, contingency, and administrative fees.
The present worth cost of this remedy, including both source and migration
control remediation ranges from $6,247,300 to $8,242,900.
6.4 SCHEDULE
The planned schedule for remedial activities at the Chemtronics Site is
expected to be governed by a Consent'Decree to be signed by the FRPs, but
tentatively is as follows:
March 1988 - Approve Record of Decision
September 1988 - Begin Remedial Design/Treatability Studies
December 1988 - Install Extraction Wells
March 1989 - Complete Treatability Study
May 1989 - Complete Remedial Design and Mobilize
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-70-
6.5 FUTURE ACTIONS
Following completion of remedial activities, long-term groundwater monitoring
will be required to assure effectiveness of the groundwater cleanup and source
control remediation. Maintenance of the caps on disposal areas DA-6, DA-7/8,
DA-9, DA-10/11, DA-23, and the Acid Pit Area. Action levels for contaminants
in the groundwater will be set with the State of North Carolina's concurrence.
If these levels are reached during any sampling episode after the remedial
activities achieve goal, this will trigger an immediate permanent remediation
of the disposal area responsible for this level of contamination is reached
downgradient of that disposal area. The action levels expected to be
implemented are MCLs and PPLVs.
6.6 CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
A remedial action performed under CERCLA must comply with all applicable
Federal, State and local regulations. All alternatives considered for the
Chemtronics Site were evaluated on the basis of the degree to which they
complied with these regulation. The recommended alternatives were found to
meet or exceed all applicable environmental laws, as discussed below:
* Resource Conservation and Recovery Act (RCRA)
The recommended remedy for soil contamination includes capping and
fixation/stabilization. This is an on-site remedial action which will
meet the requirements of this regulation.
* Clean Water Act
Trace amounts of contamination were detected in surface water. The
soil and groundwater remediation will result in an end top the water
contamination.
* Floodplain Management Executive Order 11988
The CERCLA areas do not lie within a floodplain and thus are not
subject top the requirements of E.O. 11988.
* Department of Transportation
Transport of hazardous substances is regulated by the Department of
Transportation (DOT).
* Occupational Safety and Health Administration
A health and safety plan will be developed during remedial design and
will be followed during field activities to assure that regulations of
the Occupational Safety and Health Administration (OSHA) are followed.
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-71-
* Safe Drinking Water Act
Maximum Contaminant Levels (MCLs) established under the Sate
Drinking Water Act were found to be relevant and appropriate to
remedial action at the Chemttonics Site. The cleanup goals for
groundwater were established in Section 4.
* National Pollutant Discharge Elimination System
Discharge of treated groundwater is part of the recommended remedial
alternative. This discharge will meet effluent limit requirements
of the National Pollutant Discharge Elimination System (NPDES).
Aquatic life chronic tozicity values, which are used in the NPDES
permitting system, were used in determining the groundwater cleanup
goals in Section 4.
* Endangered Species Act
The recommended remedial alternative is protective of species listed
as endangered or threatened under the Endangered Species Act.
Requirements of the Interagency Section 7 Consultation Process, 50
CFR, Part 402, will be consulted during remedial design to assure
that any endangered or threatened species, if identified, are not
adversely impacted by implementation of this remedy.
* Ambient Air Quality Standards •
The soil and groundwater treatment systems will be designed and
monitored to assure that air emissions meet all State and Federal
standards.
* State Drinking Water Standards
Maximum contaminant levels established by the State of North
Carolina regulations; are adopted from those of the Federal Safe
Drinking Water Act, and will be met.
7.0 COMMUNITY RELATIONS
Fact sheets were transmitted to interested parties, residents, media, and
local, state, and federal officials throughout the RI/FS process. The Agency
also conducted several formal and informal public meetings. Two audio-visual
presentations were developed by Warren Wilson College to help educate and
inform the local community of the Chemtronics Site and the Superfund process.
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-72-
Four information repositories were established. They are located at:
Buncombe County Emergency Services
P.O. Box 7601
Asheville, NC 28807
Contact: Mr. Jerry VeHaun
Chemttonics Site Information Bureau
70 Woodfin Place
Asheville, NC 28814
University of North Carolina at Asheville
One University Heights
Asheville, NC 28804-3299
Contact; Dr. Gary Miller
Warren Wilson College Library
Warren Wilson College
701 Warren Wilson College Road
Swannanoa, NC 28778
Contact: Ms. Laura Temple-Haney
The Administrative Record is- located at Warren Wilson College's library.
A public meeting was held on February 23, 1988, at the Charles D. Owens High
School in Swannanoa, NC. At this meeting, the remedial alternatives
developed in the FS were reviewed and discussed and EPA's preferred remedial
alternative was disseminated. The migration control alternative presented is
as described prior in Section 6.1 Description of Recommended Alternative.
Several source control remedial alternatives were presented. EPA's preferred
source control alternative for Disposal Areas 6, 7/8, 9, and 10/11 was
on-site incineration. On-site incineration was preferred because of its
permanence in removing/eliminating the contaminants present on-site. A
substitute remedial alternative was also described to the public for these
disposal areas and this was to cap and monitor. For the other two disposal
areas, the source control remedial alternative identified in Section 6.1
Description of Recommended Alternative were the ones presented in the public
meeting.
Numerous comments were voiced at the public meeting. Questions and comments
fell into six major categories including: concern about public health and a
need for a health survey, thoroughness of research efforts to determine the
extent and impact of contamination, adequacy or effectiveness of the proposed
remedy to protect human health and the environment, time involved in cleaning
up the Site and restoring the land, current Chemtronics facility operations,
and government responsiveness to community concerns and inquires/availability
of Superfund Technical Assistance Grants (TAGs)/extension of the FS public
comment period.
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-73-
The public comment period was initially to conclude on March 18, 1988 but at
the request of the attendees at the public meeting, the public comment was
extended to April 1, 1988. During the comment period, approximately 340
letters/postcards and a petition containing approximately 830 names was
received by the Agency. Over 80 percent of the letters/postcards and the
petition requested the Agency to extend the public comment period two months
past the day the community received the TAG monies. Approximately 35 percent
of the letters/postcards opposed on-site incineration and approximately 15
percent of those who wrote were negative towards capping of the disposal
areas. None of the correspondences received discussed or commented on the
.migration control remedial alternative.
8.0 STATE INVOLVEMENT
Since it is expected that the RD/RA will be undertaken by the PRPs, there has
been no request made under CERCLA, Section 10A(c) for the State to contribute
ten percent of all costs for the remedial action.
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APPENDICES
-------
APPENDIX A
«
RESPONSIVENESS SUMMARY
-------
APPENDIX A ^
„ RESPONSIVENESS SUMMARY
This community responsiveness summary is divided into the following sections:
SECTION I. Overview. This action discusses EPA's preferred alternative
for remedial action and public reaction to this alternative.
SECTION II. Background on Community Involvement and Concerns. This section
provides a brief history of community interest and concerns
raised during remedial planning activities at the Chemtronics
Site.
SECTION III. Summary of Major Comments Received During the Public Meeting
and the Public Comment Period and EPA's Responses to These Comments. Both
the comments and EPA's responses are provided.
SECTION IV. Remaining Concerns. This section describes the remaining
community concerns that EPA should be aware of in conducting
the remedial design and remedial action at the Chemtronics
Site.
SECTION I. OVERVIEW
At the time of the public meeting and the beginning of the public comment
period, EPA presented its preferred alternative to the public. This
alternative addresses both the soil and groundwater contamination problems at
the Site. The preferred alternative specified in the Record of Decision (ROD)
includes: treatment of contaminated groundwater, soil
fixation/stabilization/solidification, capping, and long term monitoring.
In the public meeting, held February 23, 1988, two remedial alternatives were
proposed to the public for source control for the four disposal areas that
contain buried drums. On-site incineration of the contents of these disposal
areas was identified as EPA's preferred alternative. This was selected because
it eliminates, permanently, the source of contamination. In case the Agency
received negative feed-back on this alternative, we also proposed capping these
same disposal areas with a multi-layer cap which includes a synthetic liner.
The community, in general, favors remedial action at the Site.
SECTION II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Chemtronics Site is located in the community of Swannanoa, a rural area of
Buncombe County, east of Asheville. The population in this area is increasing
as the city of Asheville grows.
Prior to 1984, community concern over the Chemtronics Site was generally low,
according to local officials and residents. Only a small number of residents
had concerned themselves with Site activities.
-------
A-2
The Site was first brought to the attention of state officials in 1979 as a
result of complaints from a resident living near the Site. On several
occasions the resident contacted state and local officials to complain of the
foul odors and air pollution coming from the Site. In addition to the air
pollution and odors, the resident complained to state officials of open acid
pits existing on the Chemtronics property, claiming that his dog was
temporarily blinded after falling into one of the pits. These complaints first
to local, then state, then federal officials, led to an investigation by the
North Carolina Department of Natural Resources and Community Development
(NCDNRCD) in 1979 and subsequent EPA involvement beginning in June 1980.
Monitoring of the Site, conducted by the NCDNRCD in 1979, revealed a definite
organic odor in the water. As a result of this finding, personnel from EPA's
Surveillance and Analysis Division (SAD) Initiated an investigation in June
1980. The combined results from all of the samples taken during this
investigation indicated the presence of 62 organic compounds and 20 metals in
the waste pits, monitoring wells and streams samples. In addition, EPA
detected cyanide in three of the monitoring wells on the Site. The results of
this this investigation led to EPA's decision to place the Chemtronics Site on
the proposed Superfund National Priorities List (NPL), published by EPA in
December 1982.
In February 1984, Warren Wilson College conduct its annual environmental
studies seminar and used the Chemtronics Site as a case study. Citizens,
faculty members, representatives of local, regional and state agencies, EPA
representatives, as well as the president of Chemtronics, attended. As a
result of the seminar, the Buncombe County Commissioners established the
Buncombe County Hazardous Waste Advisory Board (BCHWAB), which demonstrated an
Interest in EPA's response activities at the Chemtronics Site.
According to citizens and EPA officials, primary concerns of the community
include the groundwater contamination and a lack of sufficient information .
concerning health and environmental hazards created by the Site. A few
isolated concerns were also expressed by several residents. One resident
complained about a reported decrease in property value and another resident
expressed concern that the French Broad River, which the community has cleaned
up in recent years and plans to use soon as a water supply, could be in danger
of contamination. The point at which water will be extracted from the French
Broad River, however, is upstream from the Swannanoa River.
The following points of concern are common to much of the community and may
affect relations at the Chemtronics Site:
a) Perceived Lack of Objective Information From EPA. Area resident have
expressed skepticism about the completeness and objectivity of all EPA
generated information; both information provided at meetings and
information provided in the form of reports or other EPA documents. A-
core group of citizens, including members of the BCHWAB, and
instructors at the Warren Wilson College and the University of North
Carolina at Asheville, are highly interested in the details of the
scope of work and schedule for Site activities to be conducted by EPA.
These citizens have a good technical understanding of the problems and
-------
A-3
issues associated with hazardous waste sites and are interested in
reviewing and commenting on reports and plans developed for the
Chemtronics Site. In addition, these citizens are sensitive to
anything that may appear to be a "public relations" campaign; they
are interested in knowing about Site activities either first-hand or
from what they consider an impartial or objective source of
information. If details of Site reports or plans cannot be made
available for public review and comment, for example because of
enforcement actions, the citizens expressed an interest in being
informed of what is not available and why in a timely manner.
b) Effects of BZ Production. Although facts about BZ and its production
are now being released, at the time of production, neither the Army
nor the BZ-manufacturing companies notified the public that such a
chemical was being manufactured at the facility. The true nature of
the July 7, 1965 fire that required the evacuation of more than 2,000
residents was for a long time a kept secret. The news media in the
area publicized the alleged hallucinogenic effects of BZ. No
evidence of the actual chemical BZ have been found on^site; the
material in the drums reportedly consisted of contaminated clothes
and boots used in BZ production. According to EPA, the material
found in the drums poses no real threat to human health. The two
exposed drums labeled BZ and CS/BZ were removed from the Site in
February 1985.
Since the discovery of the BZ-contaminated materials in August 1984,
people have expressed alarm that the production of such a hazardous
chemical in their neighborhood was kept secret from them for so
long. Because the discovery was made only recently, residents have
expressed concern that EPA may not know of everything that is buried
at the Site. Some residents fear that any attempted cleanup actions
could unearth more serious, unanticipated problems or could pass over
unidentified areas of waste disposal.
c) Groundwater and Surface Water Contamination. EPA first detected
groundwater contamination at the Chemtronics Site in 1979. Most of
the residents in the Swannanoa Valley rely on private residential
wells for their drinking water supply. To date, no residential wells
have been found to be contaminated due to the disposed material at
Chemtronics. Geologic characteristics of the area make a change in
the flow and speed of contaminated groundwater a slight possibility.
Such a change could increase the potential for contamination in local
wells. In November 1984, EPA sample 13 residential and industrial
wells in response to citizen fears that groundwater quality in the
area had deteriorated. EPA found no evidence of contamination in
residential wells, but discovered contaminated wells on the property
of Charles D. Owens Manufacturing near Chemtronics. Existing
evidence suggests that the contamination of these wells was not due
to spills from the Chemtronics facility, according to Donald Link of
the NCDNRCD.
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A-4
d) Employee "Right to Know"* Intertwined with community concern over
cleanup of existing hazardous wastes at the Ghentronics Site is
community concern over current chemical production procedures and
release of information to workers and residents concerning the health
effects associated with chemicals produced at the Chemtronics Site.
The "Right to Know" issue is gaining increasing public attention in
Buncombe County. This issue received additional attention because of
the announcement that BZ was produced at the Chemtronics Site.
Individuals involved with he "Right to Know" campaign have expressed an
interest in having EPA, in consultation with Chemtronics officials,
prepare and conduct a presentation on the past and present activities
at the facility, identifying the substances handled and ways for
ensuring worker safety and health.
Another concern expressed by residents involved with the "Right to
Know" efforts in Buncombe County was that Chemtronics, Inc. has
reportedly hired a group called "Handiskills" to work in manufacturing
chemical warfare decontamination kits. The group is comprised of
mentally and physically handicapped persons. Several area residents
expressed^ concern that these employees are unaware of the potentially
dangerous products manufactured by Chemtronics and the resulting
hazards of the positions in which they work and that the Handiskills
employees may be less able than other employees to react fast enough to
protect themselves in an emergency situation at the Chemtronics
facility.
III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING THE PUBLIC MEETING
AND THE PUBLIC COMMENT PERIOD AND AGENCY RESPONSES.
Comments raised during the Chemtronics public meeting and public comment
period are summarized briefly below. The comment period was open from
February 23 to April 1, 1988 to receive comments from the public on the draft
Feasibility Study and proposed remedial alternative.
Since there was a strong response from the community in both the public
meeting and the following comment period, the summaries of both are presented
separately below.
Public Meeting
The public meeting was held on February 23, 1988 at the Charles D. Owens High
School auditorium. Questions and comments fell into six major categories
including: concern about public health and a need for a health survey,
thoroughness of research efforts to determine the extent and impact of
contamination, adequacy or effectiveness of the proposed remedy to protect
human health and the environment, time involved in cleaning up the Site and
restoring the land, current Chemtronics facility operations, and government
responsiveness to community concerns and inquires/availability of Superfund
Technical Assistance Grants (TAGs)/extension of the FS public comment period.
Questions and comments from the public are summarized and paraphrased below,
followed by a summary of EPA's or another panelists response.
-------
A-5
A. Public Health and the Need for a Community Health Survey
Several citizens expressed concern about health hazards
and requested that a community health survey be conducted to
determine whether many of the health problems noted in the area,
particularly cancer cases, were related to the site. The
Harrison Hill neighborhood was specified as one area in vhich
residents consider the number of cancer cases to be suspiciously
high. Representative questions or comments included:
Qf There are something like nine cancer cases on this
road and these seem to be higher than normal
statistics. Will the health agency do a survey of
this and neighboring areas to check this out?
Q: How can we get a check done on this community and the
Bee Tree Valley? Sixteen, of the people I used to
work with at Chemtronics are now dead. Do you have
to have 24 out of 25?
ATSDR: ATSDR looked at this site and found no evidence of
the key factors that indicate a public health risk,
tnese being, paths by which the public could be
exposed to the chemicals, such as breathing them,
swimming in a contaminated creek, or eating
vegetables or animals that have absorbed chemicals
into their bodies at levels that pose a human health
threat. There was no evidence that chemicals
migrated off the site where residents could be
exposed to them. Sickness exists in every healthy
population; the American Cancer Society estimates
that one-third of the American population will
contract and die from cancer. ATSDR interviewed
16-18 men and women who had worked at Chemtronics to
try and determine if the health problems they
reported could be linked to chronic historical
exposure to working with CS and BZ. We were unable
to link them.
Q: How could you determine that without taking tests
like blood and urine tests? How can you determine
that by just sitting and talking to someone for 15
minutes?
ATSDR: ATSDR's effort, working with Dr. Leffingwell of the
U.S. Centers for Disease Control, was to talk with
the concerned employees and try and establish whether
or not they experienced common symptoms or other
factors in common that could link their health
problems to chemical exposure at the Chemtronics
facility. The information reported by these former
employees did not establish a connection to the
facility.
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A-6
Q: wnerc can we get someone to come out and talk with
the people in the area, do a study, or send a
questionnaire on health problems.
ATSDR: You would call Dr. Robert Levine at the Buncombe
County Health Department, in Raleigh. His program
has resources to address community health concerns
like cancer, or other abnormalities such as the
rashes that you report. ATSDR's involvement with EPA
and the State focuses on Hazardous waste sites. If
we detect that chemical exposures have occurred in
concentrations sufficiently high to be a human health
risk, ATSDR would proceed with further steps like
conducting medical studies, testing of area
residents, or setting up a local clinic.
COMMENT: We've called the County dozens of times and we've
called the State, now who do we do to?
ATDSR: Call the North Carolina Environmental Epidemiology
Group in the Department for Health Services at
(919) 733-3410.
COMMENT: A couple of years ago a family moved into a place
across from the Chemtronics site and pastured horses
on property that had been undisturbed for over twenty
years. Within a week both animals died and
veterinarians had no idea what killed them. If a
horse dies, people die. Horses are a lot stronger
than people.
EPA: No response.
Q: Why are you not going to clean up my property?
According to a report I received, my property has
traces of tear gas and other chemicals. Are you
willing to write me a letter stating that these
chemicals will not harm my family in any way?
ATSDR: The levels of CS found on your property were
extremely low. Nothing was found to be migrating off
the site at levels to produce a public health
threat. The presence of trace amounts does not
constitute a public health threat.
Q: If you found traces at the level at which they
sampled how do you know there aren't more chemicals
at deeper levels? They've been in there for, what,
20 years?
EPA: The sampling that was done penetrated to bedrock and
came up clean.
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A-7
COMMENT: I was part of the company and am very familiar with
the operation, the company's safety program, and the
large health problems people are having. I do
believe there are health problems related to the
chemicals, for workers in any chemical plant as far
as that goes, and I think this does need to be looked
into more carefully.
B. Thoroughness of RI/FS Research Efforts to Determine Extent
and Impact of Contamination
A number of citizens questioned whether researchers
performing the remedial investigation had considered all
possible sources of contamination at the site or had fully
considered chemical characteristics that could influence the
extent or the impact of the contamination. Their comments and
inquiries were:
Q: Who determined all of the sites that were tested?
Were the magnetomtry readings taken in every area,
including off-site locations, where workers indicated
material had been buried?
EPA: The identification of on- and off-site areas to be
tested was made based on site documents belonging to
the PRPs, responses from community members to an EPA
request issued to the public in 1984 for information
that would help the Agency locate disposal areas, and
information EPA received from former Chemtronics
employees who knew about disposal areas.
Magnetometry readings have not been taken in all
areas alleged to have been used for drum disposal.
However, a geophysical study which provides
equivalent information, was carried out for all those
areas.
Q: What equipment was used to determine the bedrock
pattern at the Chemtronics site? Can you be
confident that 37 wells are actually accounting for
cracks in the bedrock? It is a complex area here
that drains into Bee Tree Creek and other branches
where I fish. I want a guarantee that it won't be
contaminated so that I can fish in the rivers without
worrying about ingesting chemicals.
EPA: Ground-water monitoring wells were placed at
distances of 400 feet, 800 feet, and 1200 feet
downgradient of the site. Studies of a worst case
scenario have shown that if no action were to be
taken at the site, contaminants would take over 25
years to migrate to the Bee Tree Creek.
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A-8
Q: Were ground-water wells drilled in-all locations
tested that were supposed to have contained BZ? is a
record available of where and to what depth you
drilled?
EPA: Wells were installed at all locations except'one. A
ground-water monitoring well was not installed
directly into one disposal area due to the highly
concentrated chemical wastes buried in drums in that
area. We did not want to risk puncturing these
drums. Subsurface borders were placed around this
area as an added safeguard against leakage and
migration.
Q: Were the drums found on-site tested to see if they
contained BZ by-products?
SIRRINE ENVIRONMENTAL CONSULTANTS: All of the drums were not
sampled, because of the risk of leakage. Exposed
drums and materials surrounding the drums were
tested. The major concern is not so much whether BZ
is in the drum but whether any of it has migrated.
Q: Since BZ tends to be soluble in an acidic, as opposed
to aklaline condition, won't the presence of acid
pits on the site hike the chance that the chemicals
will migrate? Has tifais been considered?
SIRRINE ENVIRONMENTAL CONSULTANTS: BZ does become more soluble
where there are acid conditions however at this site
the pH levels are neutral. The acid, pit area is not
a BZ disposal area.
COMMENT: You seem to have used different testing standards for
the Chemtronics property where you sampled for BZ, CS
and other chemicals, from off-site properties where
you tested for indicator chemicals.
EPA: A full testing scan was run on all samples collected
from off-site and on-site areas. Those analyses
included BZ & CS.
Q: Why was the landfill above Tropigas not mentioned?
Did you say that Tropigas was a non-hazardous site?
EPA: The area was investigated. Ground-water sampling was
conducted and no contaminants were found in the
ground water. According to EPA's data it is a
non-hazardous site.
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A-9
Q: Did Chemtronics provide you with a list of each of
the chemicals they've used and would it be
available? When you say "hot spots" would that be as
much as two drums of cyanide? I remember two drums
of cyanide back in 1979 and can give you the name of
the director of the lab who can tell you about them.
EPA: Chemtronics is required under the Superfund and other
laws to provide that information however there is
another list that they requested be held confidential
for business purposes. We didnt find Cyanide. We
will look into any information that can be provided.
C. Adequacy/Effectiveness of EPA Proposed Remedy to Protect
Human Health or the Environment
Several attendees expressed concern over whether the
proposed remedy for the site was adequate or the most effective
option for protecting the health of community residents and the
environment. Many points focused on on-site incineration and
ground-water extraction, two components of the remedial
alternative. Questions were also raised about long-term
monitoring of the site. These points are as follows:
Q: Why was there no consideration of having a hazardous
waste management firm remove the drums and transport
them to an approved incineration facility?
COMMENT: This area has not been well researched and many
incinerators in this vicinity have been problematic.
Q: Will there be an environmental impact study performed
on the use of an on-site incinerator? We have
problems in this area with air inversions.
Q: Will you check each drum planned for incineration to
make sure that any CS contained in it is
decontaminated?
Q: If the air becomes contaminated, how will that affect
our food chain? We have dairy cattle, raise our own
vegetables and raise our own animals for meat.
Q: If you burn the contaminants, won't they be released
into the air?
Q; If incineration is not dangerous, why was the valley
evacuated in 1967 when the Chemtronics Plant caught
fire?
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A-10
Q: Where else has on-site burning of the same chemicals
been successfully performed so that we can compare
test burns to those results? Would we be the first
such incineration example?
Q: What will the incinerator be used for? Hov will its
use affect local industry? What kinds of toxic
regulations are in place?
Q: Will temperatures in the incinerator be sufficient to
achieve destruction of the toxics like chromium or
lead, and prevent dioxin from forming?
Q: Would the ash from the incinerator be buried and
capped?
Q: If you incinerate, will you test milk and dairy
animals in the area to see if anything could be
escaping or not properly done so that we know if what
we are consuming will be healthy?
SIRRINE: There may be some confusion about incineration in the
sense of comparing it to burning or an open flame.
The incineration of the hazardous wastes at the site
would involve temperatures of 1800° and higher
where wastes would remain inside the incinerator for
at least 30 minutes. Properly designed, constructed,
tested and operated incinerators should destroy all
the wastes and render the ash non-hazardous. Testing
animals and milk in the vicinity goes beyond the
normal scope of what is addressed in the FS, which
takes information generated by the RI and develops
remediation alternatives. Those issues are not at
risk at this point. There are numerous sites using
on-site incineration. For chemicals like BZ, the
U.S. Army facility at Pine Bluff, Arkansas could be
contacted to obtain information.
EPA: Before an incinerator would be allowed to operate,
pilot studies would be done to ensure that 99.99%
destruction of chemical contaminants occurs. Stack
tests would also be done to monitor emissions and if
the stack test results cause any doubt about the
incinerator performance, the engineering design would
have to be changed. EPA has the authority to deny
issuance of the permit necessary to operate an
incinerator if the Agency is not convinced that it
would protect human health and the environment.
.Stack tests are continually run to ensure that the
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A-ll
required level of destruction is taking place. Any
residual, or ash, from the incinerator would be
tested before it is disposed of and capped to ensure
that all the waste, including any metals, are
destroyed. If an incinerator were to be selected for
treatment of Chemtronics wastes, no contaminants from
other sites or industries would be brought to the
site.
EPA did consider the alternative of removing wastes
from the Chemtronics property, and transporting them
to an off-site incinerator. The level of
effectiveness of the remedy in each case would be the
same, however, off-site incineration would cost
roughly an additional 11 million dollars.
Transportation safety issues are also involved with
the off-site option. For these reasons, EPA would
prefer the on-site incineration option to
transporting the material.
Q: If your proposed ground-water extraction system were
to indicate that there is no longer any
contamination, would you cease extraction — continue
to monitor? Would a period of heavy rain in the
future cause the water table to rise, come in contact
with the contaminant source, and re-contaminate the
ground water?
SI RHINE: The waste is buried sufficiently high above the water
table to prevent contact, even in abnormal conditions
though even then fluctuations in the water table are
slight. The capping option being considered for the
site is designed to prevent infiltration of rain and •
other moisture that would carry contaminants down to
the ground water. The extraction system would then
collect, remove, and treat existing contaminated
ground water.
Q: Would Chemtronics still be allowed to test their
explosives near ground-water monitoring wells as they
did the other day? Private well water levels have
dropped as a result of the explosions.
EPA: A monitoring program on the extraction system would
be set up to make sure that it was intercepting the
entire contaminant plume. This monitoring system
would detect any well failures. The thickness of
rock layers would protect these wells against failure
due to explosions. Once the wells were installed, if
Chemtronics' activities distrupted the system, EPA
would require them to install a whole new system.
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A-12
Q: How long will EPA monitor the site? Would this be
on- and off-site veils? And how long would the cap
be monitored?
•
ATSDR: ATSDR is recommending that monitoring be done on
on-site and off-site wells to make sure nothing goes
off-site; EPA will determine the monitoring period.
EPA: Basically the monitoring period is long-term which
could range from 10 to 50 years. Most likely there
would be a thirty year monitoring period, the
lifetime of a cap. The system would be re-evaluated
every five years.
D. Time Required to Clean Up the Site, Restore the Land
Questions or comments expressing concern about the length
of the Superfund process or time required for recovery of the
land or water resources were as follows:
Q: If the area'containing waste is to be incinerated,
how long will it take to return it to usefulness or
to its full potential?
Q: How long will the cleanup take — three months?
Three years?
SIRHINE: That will depend somewhat on the remediation
selected. If the decision is based on the fact that
exposure to the chemicals is not occurring, the
selection would be to cap the area, extract and treat
the contaminated ground water, and continue to
monitor to make sure no problem develops. Those
procedures would take place quickly. Treatability
and pumping tests are needed to be able to estimate
closely, how long it would take to install and run
the ground-water extraction system. Typical
time-frames are five to seven years or more. Our
conservative estimate (to figure costs) is 30 years
but this will become more possible to determine once
tests are run. For incineration, depending on the
alternative selected, special design, safety and test
procedures would have to be set up at the site.
After that the actual incineration could take three
years.
Once destruction of materials is completed, the ash
would be buried and the ground re-vegetated. At that
time the land would be available for any use designed
for the area.
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A-13
E. Chemtronics Operating Procedures
The following two questions were posed regarding current
practices at the Chemtronics facility:
Q: Is there any explanation as to why on holidays and
weekends, we get terrible chemical odors?
Q: I'm concerned about what we breathe every day. I
dont understand why it hasn't been fully covered.
EPA: We in the EPA Superfund Program are not in position
to respond to the questions of air emissions from the
company's day-to-day chemical plant operations. We
cannot guarantee that you are not getting exposed to
air releases that are not regulated by this program.
There are no releases of pure chemicals. The odors
mentioned or any releases that may have occurred
recently should be reported to the County Health
Department the State, or the Occupational Safety and
Health Administration (OSHA).
Q: Why, when we call Chemtronics to ask about explosions
do they say they are not permitted to tell us?
ROBERT KING,
CHEMTRONICS PRESIDENT: You will get an answer to those
questions.
F. Government Responsiveness to Community Concerns or
Inquiries/Need to Extend Public Comment Period/Technical
Assistance Grants
Several aspects of concern were expressed regarding
government responsiveness to citizens or the degree to which EPA
and other agencies included citizens in the RI/FS process. Two
or three questions regarding Technical Assistance Grants and the
RI/FS process were inaudible to the court reporter. This section
includes a major point EPA made in response to those questions.
Questions or comments representing these concerns are as follows:
COMMENT: Only one copy of the draft FS was sent to the County
in December and three people knew about it. I was
asked for my comments 48 hours before the PRP's were
to meet, and had not been informed that the FS was
available. There was no way I could go through four
inches of material in 48 hours. When I asked about
the date of the public hearing, the official response
was "EPA only has to notify the media three days in
advance." Also, a videotape prepared by a public
interest organization as part of the public relations
package for Chemtronics was available in September
but not shown to the public until two weeks ago due
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A-14
to a bureaucratic nightmare. EPA should explain the
reason for this and should extend the public comment
period. I realize EPA is under pressure to complete
certain activities at many sites by the end of March, but
three weeks is insufficent time. As of tonight we have
two copies of the FS, which we will get out to the public
and we will get whatever expertise needed to review this
but we cannot do it in three weeks.
EPA: The FS was sent out to all concerned parties however
it has been learned that the Buncombe County
Hazardous Waste Advisory Board no longer exists. EPA
was not informed of its discontinuance. EPA will
consider the request to extend the public comment
period.
Q: Is there a responsiveness summary for the RI? there
were a number of comments from the community on the
RI and most of us got no answer.
EPA: The responsiveness summary process is not required
for the RI. To our knowledge Issues raised at the RI
. public meeting were addressed in some form.
COMMENT: I understand there are requirements but also there is
the philosophy that community input is encouraged and
it is discouraging to put in -many questions and
receive no answers.
COMMENT: There are people who are not sure their question will
be answered, and who fear that they are going to be
left out, which has been the case with siting
incinerators. It is clear to me there is a problem
of trust.
EPA: EPA has not decided upon incineration at this site.
If community members submit comments during the
comment period, they will be considered. A
responsiveness summary will be prepared that will
reflect EPA's consideration of questions and
comments. As long as there is Superfund activitiy on
a site, citizens can apply for Technical Assistance
Grants (TAG). Even if the EPA Record of Decision is
signed, citizens can have input to the remedial
design. Procedures for the TAG program are expected
to be published in the Federal Register by the end of
March 1988, and the application process is expected
to get under way this fall. Interested citizens can
send EPA Region IV a letter of intent to apply for
the grant. EPA will send the TAG manual and fact
sheets to interested parties, upon request as soon as
they are available to the Agency.
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A-15
Public Comment Period
Included are several letters received by the Agency during the public comment
period as well as the Agency's response.
IV. REMAINING PUBLIC CONCERNS.
In addition to those concerns voiced at the public meeting, some additional
public concerns are described below.
* Additional sampling/analysis of residential wells for volatile organics.
* Responsibility of long term monitoring of the groundwater and
maintenance of the caps.
* Effectiveness of the monitoring system.
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T
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_ HEOION
ATtANT*.OA.
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VD-SFB ' ••.'..-'•;•:- 'i-''- ~v •-/..;-•• •• -'; ' ' .- •.'•'. /••'
Ms. Anne »oa& :' "V '•.-'"• --:'•..•.... y .? , . .
140 Riddle *oad : : 11 v - '.'••••
Svannanoa, MC 28778 ~.
Dear Ma. Voah: '.; ; ''"' .. '• •• . " .--. .. • • .
This correspondence it in response to your letter the Agency received on
March 23, 1988 during the public consent period on the draft Feasibility Study. -
.and the proposed remedial alternative for the Cheatronice Superfund Site*
As you know, the original public comment period on the draft Feasibility Study
and EPA's proposed remedial .action at the Cheatroniea Site expired on March 18,
1988. Later, the comment period was extended to April 1, 1988. The
community's desire for the public consent period to be extended two months past
the date the ccasualty recelvea the Technical Assistance Grant (TAG) vaa
brought to the attention of Mr. Lee DeRihns, Acting Regional Adoiniatrator. It
vaa his decision to let stand the April 1, 1988 closing date for the public
consent period. His decision vaa based on the appraisal that even if the
coBOunity vaa selected for such a grant, ve eatiaated that it vould take
approximately eight months to a year for the Agency to make the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is mandated by Congress in the Superfund Aaendments and
leauthorization Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delays will inpede the
Agency's attempt to achieve this goal.
SARA also encourages the Agency to select permanent solutions for the clean-up
at Superfund Sites. After the Agency reviewed all the remedial technologies-
identified in the draft Feasibility Study for addressing source control for the
contaminanta found in the disposal areas containing drums, the only remedial
alternative that achieves this goal is incineration. Off-site incineration was
eliminated from consideration because it was estimated that it would be store
coat affective to incinerate these materials on-site. ; ;: : :"%}U V-!t:
Under idesl conditions with the incinerator working as designed, the only
compounds that vould be entering the environment from the incinerator vould be
the ash/soil residue froa the burnt soils and water vapor and carbon dioxide
out of the smoke stack. Therefore, virtually complete destruction of the
contaminants vould be achieved. ., . . j. " -'-" ' ' •'•'•'••"•' -
-------
This remedial alternative was aot •electedTfor several reasons, -first and
foremost, is the threat ?osed.by live ordnance buried along vith the drums to
the workers'who would be involved in thye.4 excavation of these druas in order to
prepare the* for incineration. The second issue considered vas the potential
damage that this Ordnance would have on the. incinerator itself. If these
devices exploded inside the incinerator's chamber, it would be difficult to
predict the results. .One possible scenario is the release of partially
destroyed contaminants into the environment. This coupled vlth the. fact that
the Aahevllle area is located in part of the country that experience* frequent
air inversions, vould increase the potential to exposing the connunity to these
partially destroyed chemicals if • release, for any reason, occurred. And
thirdly, a great number of eiticens voiced -a negative response towards on-site
incineration both in the public meeting and during the public comment period.
This left the Agency with basically one other remedial alternative to address
source control for these disposal areas that would adequately protect the
public health and the environment and that was to place a cap over these
disposal areas*. It was not advisable to follow a no action alternative since
the contaminants disposed of in the majority of these disposal areas are
presently migrating with the groundvater from their disposal areas.
• " • .' '.•-•»-.';"•. •.••'• ' •
SARA also encourages the Agency to implement a remedial alternative that
reduces the mobility, toxicity and volume of hazardous waste at a Superfnnd
Site. The capping of the drum disposal areas along with the capping of the
acid pit area and the soil flxation/stabilization/splidification process for
disposal area 23 along with extracting and treating groundvater will meet these
criteria. The security fences to be installed around these capped areas will
help maintain the Integrity of the caps by preventing unwanted Intruders
including man and animals alike, from damaging the cap.
In addition to the remedial activities stated above, a long term monitoring
system will be instituted for the groundvater in both valleys and surface
water. This monitoring system will provide data that will be used to indicate
whether or not the remedial action implemented is working as designed.
As directed by the Chemtronics work plan the Agency developed for the
Chemtronica Site and the Administrative Order of Consent signed by the
Chemtronics, Inc. and Northrop Corporation and the Agency, in any off-site area
that was identified with credible information voald be Investigate as past of
the Remedial Investigation (RI). Since these off-site areas are not part of
the "Chemtronics Site" as defined under the Comprehensive Environmental *
Response Compensation and Liability Act of 1980 (CERCLA), even if extensive
contamination was found, these areas could not be,addressed as part of the
Chemtronica Site. For thla reason, it was determined by the Agency to require
only three soil borings into each identified area. All samples collected by1
the Agency were analysed for the hazardous chemicals we normally look for in
addition to analyzing for the compounds of BZ and CS. All borings made in the
BuckeyeAfalnut Cove landfill and the landfill adjacent to the Tropigas building
penetrated the entire depth of the landfills and were terminated approximately
five feet into the underlying soil. - _:;:;V/::;^ ;;;:""" -
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. ..•.•' • • • . • ' > -..- - . .
.The purpose of this initiative was not to provide sufficient data to determine
how to remediate .these areas bat to see If these areas .posed an immediate
hazard to the community. The data generated daring the El indicates that these
areas do not pose a hazard. ~ .• '. •• '.' ••""•."•.•.-'.•"-="--:'•: ' .• • '
.'•',. ' ' • . • *-."" -• " - .- .. • . ".•'„.'.-."•• t- •'•'
•' ~ " I*". ••'"'<'' ' v """"•'*'-• _-"'./..*--.•.-•:' . '".--I* • • ,*.
In their Health AsaessBent for the Chemtronics 81 tie issued on March 21, 1988, •
the Agency for Toxic Substsnces and Disease Registry (ATSDB,), recomnended that
residential veils be sampled and analyzed for volatile organics. Thia
recoaaendation will be iaplevented. This is being perforaed only as a
precautionary measure to ensure that the drinking water is not contaminated by
any source. This testing of residential veils nay be a one time occurrence or
included in the long term groundvater monitoring program for the Site.
If I can of be of further help, please do not hesitate to contact me at
(404)347-7791. :: '.- :' /
Sincerely yours, . .
Jon K.
Superfund Project Manager
4WD-SFB 4WD-SFB 4WD-SFB
BORNHOLM HANfcE ' GREEN
If
Jon BornholmItelex DISK CHEMTRONICS, FILE C104, 4/26/88
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ii-vlV-Viviryi-'vJ.i^i'i;-;;- ~^_^^- -JJ.^4-'INTRODUCTION /" >.V:".' •-•-• • ,' ' " • •" :
;;>;f.i£iV.£i;'~ v-rhis-.reporc^is fceihg^submitted W iehalf ^of Hoechst
. CelanesexCoriporat'ion .tofprovide'.Comments' ;oh the Feasibility
"_S%dy-:pr)Bpai:«r4^f oV"'*the :rei^diat^ion:of^the :Chemtroriics site in
SwannarioV/; Nbrth^ Carolina^••^ The .conuniints -are based on review of
the •following* ''document sYr " - '• n'•
••• •••-•• - - --
.•;•": .the1 .-Feasibility''Study prepared by CRS Sirrine, dated
•:•''•;'. December 1987/;::- -;'•$•••• ;••;.:'; '>"yU :••.' .'• -"'• •
;• the fact sheet prepared by the EPA, Region IV, dated
February 1988;
• the endangerment assessment prepared by CRS Sirrine,
dated February 1988;
• comments prepared by the EPA and the North Carolina
Department of Human Resources, transmitted in a letter
from Jon K. Bornholm, EPA, Region IV to John F.
Schultheis,. Chemtronics, Inc., dated January 14, 1988;
and ;.', .-• •-•; .. -.' ' • . '/-' - • : '
• a letter from Jon K. Bornholm, EPA, Region IV to Susan
P. Engelman, Hoechst Celanese Corporation, dated
February 3, 1988.". .
:'r''£>'V'i£:^^ ••..-..'
:-•••••..."-./:>:-;:. ••;;. ••:.•'•.';• .-,- •::-:-;. ••^.--.'.•- •:•• -..:-., •;,•.••.,-.-.';•; -.••••-;: -..•:. . ••
The comments provided herein are not intended to be a
detailed, .critique of:the Feasibility. Study and the
afibye-r'eferenced documents ^if: Ratherv they are designed to
address issues whichvwejbeiieve are of major importance to (1)
the;'select:lo^'.o£-?a\^c^£e'rced Veinedy'lor^.the site, and (2) the .
.TV ••«•••"« i .-A-:-.J:J:J'-- *.&<^*,-,,?*..-::'-.;.- .,;-^-7 •'' \j '•'•'.;-.-•••• '• •• •'• .-.-• • :'-•': ->'• •.•:•'•- ••• •••••....'.-'.1--
manner'in which such a'remedy should be implemented. We have
^•.c •:<.;,*• ^''''^ ••^^^/i^;--;•:-:>.".:.:.K^::.- ••.: -; ••::•:. ly. '••-.- - "... .
identif ied."one major J.ssue .of concern which we believe has been
addressed^ii^ppropri^^ inadeguately in' the Feasibility
StudyV,; the deyelopinent .7of ground water cleanup criteria for
those chemicais\with limited toxicolbgicai data. In addition,
we have also presented comments on the adequacy of the
-1-
-------
'-- characterization'of contamination invthe.Tbiolagoon "area; the
""*; limited ;inf ormation.on the : system'-.proposed ;_f or: recovery and
treaVmehttof xcohtaminated ground -waters/and the risks
. Vssoc£ate"d.Tw£th' the. excavation"-of .materials~'potentially *.
^c^tainirigVe^losives/*-*^ ~v;'*vli ">; '• "; •'
;^i*?7rvc3}K;s[i£H-V^^^^ If:---^-^ Uv••.-.- -•;
V..A;i^C^x;.5.y.:-.•:^.^^L^^• t:Ei;:'$y££c'* "• *t:^ c•?rA^:, • rV.-
:- *• ;• '£-:,*'i"'^f". v i ^2-Vft-..V- ^r'v"'. 5'V'i a '"^S-^•i'-V^•i'i*!:^:•'.''1^^."'i^<.C'X o ^';: ^*. :-v':' *•• "
-------
OF GROUND. .WATER LEANUP. CRITERIA
A,"v',- Scope v of Analysis
' ^. Vi. „*"• *\ * *• TTL"""~- - . v*>i^~ "~ — " "
/-. ::•;- Appendix. A \ of the Feasibility .Study, ."Development of
Preliminary ^Pollutant , Limit ^Values -'for -Chemicals .with Limited
•'••*..* "- •''.-/ t. r> "-? 'T •"".*.*.' "• • . • - • *• .'.':..- ' ' *"" .» *-? - * .'• • ' _ .-; '•'• .. . .- ^ • T-"" . •. ... -
: Tpxi cb 1 6g i c a 1 Jpa t a 'j -Jpr esent s ; the".; der iy a t i on .• o f c 1 e anup 1 eve 1 s
;il "iand, Aground water for explosives (RDX, TNT, and picric
.acid) ,;BZ: and ;.its. breakdown products -(3-quinuclidinol, benzilic
"acid and benzpphenone) and CS and its breakdown products
(malohonitriie and o-chlorobenzaldehyde) . Since the proposed
remedy. for ^source control, i.e. /.fixation of the .soils in DA-23
and capping of the other disposal units will essentially
eliminate exposure via soil contact, our analysis has focused
on the development of ground water cleanup criteria.
Our analysis examines those chemicals for which maximum
concentrations measured in the ground water of the site
currently exceed the calculated cleanup levels or preliminary
pollutant limit values (PPLVs) in the Feasibility Study, i.e.,
benzilic acid, benzophenone, and RDX; and also those chemicals
that . may -have been present in drummed wastes that could result
in future ground water contamination, i.e., 3-quinuclidinol,
malononitrile .and p-chlorobenzaldehyde. . BZ and CS were .not
evaluated fo.r the following reasons: ^.(D^'the .drummed BZ .is .
believed 'to "have been decontaminated and, therefore, degraded
into i.' 3-quinuclidinol «| -benzilict acid, and benzpphenone (based on
information gathered f rom .employee interview's) ; and (2) CS has
5a half, life .in water '-of ,41 minutes (Demek et; al. 1970) and
'>.->;.: .'..•.•.•;-•.::'•/:.—: irf-'tr'..;.." ' >.: *-v"y.- T"-.//' -• - - •• •• -• L-~.'.- *•'. — • • -/• • ';•!--• "•• . . -
The ."t oxi cb logical basis for the ground "wate'r PPLVs
' ' ' ' ' ' ' '' ' •
••f . -.y .-.,... •,.- •. .• - ... ...... •. .
mentioned 'above was reviewed using the reference material from
-,••. '-• . ' •>'.',<' • iT.WJ1' -'•<«-•«•"•- •J- ?'•'••• '•>.'*••'•- -.:'"'-•'-*• '-r • -^ ""-* ^ *T *• — '•»' *~ '• ~ - 3~" '•• •-
a" literature 'search of chemical/toxicological ;f iles "in Dialog
Inf ormat ion Systems'5 ;r?Based on thi s '"reference' ^at ef i al , the
PPLVs "or 'cleanup' criteria derived by ENVIRON 'differed from the
values presented in Appendix A of the Feasibility Study for
benzilic acid and RDX.
•.•;'••."'' •• ;:.>••• ;-v;:-"-:.^; • .- -3-'- : ••'
-------
. B .-.Vi'. .Evaluation of -Data 'for Benzilic .Acid and RDX •. ;. -,• : . - . "
v-^ v V';For5ienz"iiiq ?acioV.'the jionly ^available ..toxicblogical .data
:-ve^e.*three.&£^VAl\JLes :.t&''&-\£'.i*u.J.'£.- '*.^ -'-^'.^Cit, . cs -i '••?*; -.-.-- ''•••-
. :j ••••'•/ :." _..T.-r*'.3v >• • •-'- -" ' ''" - • ' '•' •" •''' • -''"•"
. _..... _. .. . .. ... . .. •. .•
r> •-.£! bra 1/LD^0- t.pf rj 2000 *:mg/kg .for /the mouse .(NIOSH 1987) ; ..
^/vV/'Oj.!^ mg/kg .for the mouse (NIOSH
'' '
rag/kg _f or the rat (McNamara
' ''
The LDg'jj value vthat was chosen in Appendix A (Rosenblatt
1988) was the intravenous LD5Q cited by McNamara (1963).
However, since the exposure route through ground water is
ingestion, it is more appropriate to choose the LD-.
associated with .the oral' route of administration. A factor of
1.5 x 10~6. (Rosenblatt .1988) was then used to convert the
oral LI>50 (2000 mg/kg) to a chronic human acceptable daily
intake (ADI) .value: .; -
^^-7J vi/»'€ £ >v^'.;^i: 7^; s-J «•:.•:;?: '.-:.-. ?:.V=: :'^\- .•-'..". - \- ' •••. •-:.-•• .
ADI -= (2000 mg/kg) (1.5 x 10~6) - 3 x 10~3 mg/kg/day
Using .this .calculated ADI and assuming that a 70 kg adult
consumes J2 : -liter ^s.;of ^water per day, the ground water PPLV is: .
Ground Water PPLV« (3 x 10~3 mgAg/day) (70 kg body weight)
.*,:-, CT :' v'-r.,
a5-*CK;L-;v;^^^^l:i'p5''mg/i:br "105 ppb. •'•:'•• ;...-'':'"-'•''">•";;. ".':-. •;: ";."s '•'-
• j*-^ *"*?•' f£'?¥¥^J^'^^&'?f£-^--^i'^r'^&''-':?*' ^va'';t'i;>.:;v^^";*''*S "*i<" '": "•* *"'• ^ • '•*
""' "'' " ' " ' " " "
- .
":"^i'/; \ The '"'behlBil'ic "acid .'PPLV "presented '.in Appendix" A is "21 ppb
'•:'<- i'!-V-:~'-i:&*-'*&'l&-zi'.M'-''-j''t."~*r--i'- -v-.-.-^-f .- -; :'•'• '•'••i^ ^T- -'r.- T % ., •> vv--. v-^-."- /•
••&•• • ^ «% ^%«v "' — • __ _^-/ *_ •_ *_ v . " ' • JK •• j"_ i_ *_ — * "* _ j ' f *_ — > _ ~ _ * i ^ ^ _ *" _" " s ^ * *_ _
FofV RDX/the "drinking water "preliminary "pollutant limit
'•*••» t*. -." •_-'"/»''-- -1siV (A * '\'^ :IL": "iTr* *"^ • *»*3» •*" C' V" . • •» " ' • ' T '.'•--• ',
: value pf r35 'p'pb;'(Ros"enblatt 1988) was based upon toxicity
information from Dacre (1980) in which an acceptable daily
-4-
-------
intake (ADI) of 1 x 10~3/mg/kg/day was -derived. ..The basis
(13 week) study in rhesus
-monkeys' -(Llttonll!?74)\yhic>':^identif led ;a NOEL -of -l 'jng/kg/day; a
• safety factory of 7X000 : was v. used .to der ive the AD I ( Rosenb 1 att ,
'personal.^commuhicatipn^'JMarch^aS; 1988) .0 We 'would endorse the
', us e l.pf this' safety '.If acjtor. ; based on the following -rationale: a
f actor "of 10 for. extrapoiation from a subchronic to a chronic •
study/'lQ -for "extrapolat ion from monkeys to humans, and 10 to
account .for 'interhuman variations in sensitivity. I. v ;:;-:.:".
.rv>::.vA more recent '.chronic ( 2. 5 "year) feeding study (Levine et.
al. "1983) has.been conducted in Fischer 344 rats/ .which -
provided a NOEL of 0.3 mg/kg/day. (It is interesting to note
that 0.3 mg/kg/day was also identified as a NOEL in a
subchronic rat study conducted by Brown [1975].) Applying a
safety factor of 100 to the NOEL (10 for extrapolation from
rats to humans, and 10 to account for interhuman variations in
sensitivity) results in an ADI of 3 x 10 mg/kg/day. This
value has been proposed by the Oak Ridge National Laboratory
(ORNL 1986) as the basis for. an RDX water quality criterion for
protection of human health. ENVIRON recommends using the 3 x
—3 '
10 mg/kg/day as the ADI, because it is based upon a chronic
study, in which the NOEL and LOEL were fairly close (0.3 and
1.5 mg/kg/day)/ as opposed to the subchronic study .in which the
NOEL and LOEL were separated by an order of magnitude (1 and 10
mg/kg/day) ;c The NOEL from -the Levine study ' also represents the
lowest NOEL'rreported ihythe. various RDX toxicity ^studies (ORNL
.1.986) r^^^/5^^hs>^4t! "ai.iiiftir«^^^XciS#4;^ia-ca/r:fAr-' •?&£ ^--^^" •"; • -••:-•:
ho:, . if 4t, is assiiihed that": a 70 kg adult consumes 2 liters of
water per 'day »"'.'. a water : concentration of 105 ppb would . .
correspond :to^thV ADI ^o^3Jx APT^. mgAg/day.:;- ^ENVIRON: '.^z'*j ;;
suggests using" 105 ppb; father -than -35 ppb, 'las the RDX limit
value for drinking ;water i^t
-5-
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three"
-; as^^per^ni^ -. --•-•-^
V asjsVciate^dJwi^hYexc
d_esign*:;b*f ;"the" grpuh"d;:watVr treatment land• "recovery system.• :
''. '•^'iicAivv--^^"-iY-Vi^^'H^;:v' •••--•' '>••:' ' .''•-••
' . ^/^::'-^;v^--'-v:;v.f.v;--f:;^i^^i/U^-i:-::"':'.-;-.•;-;•: '••- :'-. . ".- ' -
'. A.- .; Risks Associated with Excavation - ; \ ; .
, The comments''provided by EPA make note of "the possible
presence of explosives''that could prove potentially dangerous
to field workers" should a source control remedy involving
excavation be used. The information presented in the Remedial
Investigation (Metcalf & Eddy 1987) suggests the possible
presence of explosives on-site. In addition, information
provided by interviews with former employees has suggested the
possibility of explosives in the fill of the disposal areas.
While we are not aware of any definitive way of confirming
or disproving this possibility, short "of actually carrying out
the excavation work, we would suggest that this approach be
avoided if ARARs for the site can be achieved by other remedies
Biolagoon
" " We' endorse EPA's" :c6inment number 3 regarding the need for
an expanded discussion of the biolagoon, the fate of the
mixture that"was reiieayed^when the liner failed, and the
significanceof^ this ^occurrence. No analytical data are
'presented "bti the contaminants released from the biolagoon or on
.;••'.•:- .. •:.. ••.-. t-r^:.. v-iiVM-.. .•*--. ""'•-."~'-~v,V -'••..••'. ' '• .. • •'- ••; ': • .'."- • • . . •' . •
• how" such^" cpnt^lnation3night" be remediatedo ^^-:--: -. .:• . .
-^i±iJK^^ •
;cV :"•'!' be'siqh ''off'the"'Gro'und''Water Treatment and Recovery System
•/i.:vV^.'The'Feasibiii^y;study',.refers "to the use of ground water
recovery and treatment •• as 'a 'method of migration control.
••• v.,^ r'.-~r."-•:•-•••-•*••..••;• .T'T.-.-V-'^';. •.••Vi'."-"^~* -v. •'.•/•'•.•• . • •. • .-• .-. •-.•.-••."
However, no expiicit'Veference is made in the document to the
•..•--••' • •-.- • 'v •'"•'•«.' • - ~ •- ••-• " '."'"- •''-••'•••':••• •' • ' . ' • '
design of the recovery "system or to the volume of contaminated
" ' ' '
-6-
-------
mm
fu;
-345
Atlanta ;;:Geqrg ia 30365
Re: Chemtronics, Inc. Site ...";
N^:'••' .Svanrianoa, North Carolina^
:Dear;
r' i^P^'vx I 'am enclosing:''a report prepared on behalf of
:Hoechst^ Celanese Corpprat ion by ENVIRON Corporation,V;. {.'
' v.*l* • «• W ' ^K «M ^K*• 2 ^ A^f * A ,^^_^_ ^ — A- -^ * — — ' -".L t_ ^1 » ^ * 1_ • * • • _ ~ ^ . 4 «• "' ' ^t »' «
..----... ,••.-......•.- - -• .*• - . . •- ..... ..
fe^^ '";--:---0':-••;:r:-:'/- •-•-••
-------
__ BRRB
^
MAR 31198S
LbliDLbUU Lb
EPA - REOION IV
ATLANTA. OA.
COMMENTS'ON THE FEASIBILITY'^
.FOR THE CHEMTRONICS SITE,-.
••':•:•' "• .SWANNANOA, .
, BUNCOMBE COUNTY, NORTH CAROLINA
Prepared for
Skadden, Arps, Slate, Meagher & Flom
'.'.• . Washington, DC
Prepared by .;-,. • J;; •;.
ENVIRON Corporation
Jersey
cfe-K^^rK^ 31, 198
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OF CONTENTS .;.'.-
........ Page
WATER :CLEANUP' CRITERIA'"' • ' • 3'
A.' "Scope of Analysis . 3
vJ,: .'••' B. Evaluation of Data for Benzilic Acid and RDX 4
^-'.^"i;-': * • •'•••'^"»i'.'-/«:e'3'r..i';;-ii >. i"«* v'- r.. •."••.-• •••-,',-.••;.-% :•- ,•;,.- .
. III.- OTHER ISSUES '= 7 6
r-';;--^-;,,;:;.. ••:.----;j;-..V^'*.s^r:v V.:-?S£'~-: :~ • . - • . :••.
1" A. Risks Associated with Excavation/- .. ; • 6
, B. Biblagoon Failure " " 6
C. Design of the Ground Water Treatment and
Recovery System 6
REFERENCES 8
.. .
•Ai:^:?^^^:^?!i&^'^ j?. ^K'^-^^'ic
>..s •"•.:";-i''i'\.-'.''.y.i^c*'-'*'*' ^iiife'Vi?- 'r^:V.tV'i^-:vi''"•'*'='s-''i^-"-'« ;"v - vi .rv?:*v': ""•.•"./':-''rT'^r.;.'!
-------
ground water which it is- -expected -to handle and treat.
• -..".•••. ^--.-. •'•'•'• :-;~':' •'-••".'•'.'•' . • - •• •'*--•: • r;. -••••••••.'• ;.?.•••••'••;• .••:•• ' -.-.: •.• • - . •: • • '• ' • •.
.'..• EV£tkermpre;;:ii^ .attempted for the time
.''. period by eV- which'1 ?the '"system* is expected Vo have 'to operate to
-\.*-t\rfV:i.C^J>VA:S.K&V<*^ „:.; f .. . . . •.'-..
^. achieve^ ;;:S.at:ip^ctoryA :ley.§l.; of .c.leanup/^: We Relieve ;.that.- these
t:f^ evaluation of - . , ;
be. included, in the
-:'t&&^$&,•'£••#£•# •:•?.-••., *-..»."'-.••;•:•: . ;.
.-• -•- -i,• •
•*.•:•£,'*'* •...-?:-:-2
-7-"
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REFERENCES
^-;; .. . v-vADrAO244i5/2.V Maryland. University School 'of Pharmacy,
#:•;•:.." •..••'.'• Sv^Baltimore^Mp.'-iiiCRepbrted 'in ORNL ;19860V- "^ ."•/-:*-: :
vr '. •;•- '-.1 *• .i.3 .--: Vvv-=-i *-^ •'• •^•:-~'?:"" ' r - • '
. .> - -o..-. • ,.. ._, v-_ - ;•, ••--;-;-., . - • .
: DacreV* JjC.^ r.-1980 ^ Recommended -interim. .envirSninental -criteria
• - f o"r>six imunit ions compounds "; Winter im Report . . , U.S. Army
Medical ;. Bioengin'eer ing Research r:and •Development ......
.'. Laboratory ,-' Fort Detrick, Frederick, MD. (Reported in
:: Rosenblatt; 1988. ) •<. - .'".•". ";•". :- •-- ' ' '---r: ''•'.': . '
Demek, M.'''M.V:0.'T'.! Davis, W.H. 'Dennis, Jr . , A/L. Hill, R.L.
; Far rand , N . P . Musselman , R . J . Mazza , W . D . Levine , D . H .
-. . •>•-••'-. Rosenblatt and J. Epstein, i 1970. Behavior of chemical
•' agents in seawater. Edgewood Arsenal Technical Report
. EATR 4417. Dept. of the Army, Edgewood Arsenal, MD.
Levine, B.S., E.M. Furedi, V.S. Rac, D.E. Gordon, P.M. Lish.
1983. Determination of the chronic mammalian
toxicological effects of RDX: (Twenty-four month chronic
toxicity/carcinogenicity study of Hexahydro-l,3,5-trinitro-
1,3,5-triazine (RDX) in the Fischer 344 Rat). Final
Report - Phase V. Volume 1. ITT Research Institute.
IITRT Project No. L6121-Study No. 6.
Litton Bionetics, Inc. 1974. Subacute Toxicity of RDX and TNT
. in Monkeys.' AD-A044650/0. Kensington, MD. 213 pp.
(Reported in ORNL 1986.)
McNamara, B.P. 1963. Toxicological studies of effects of BZ
. •;.'.. on animals. CRDL Special Publication 2-50, U.S. Army
-.. Chemical Research and Development Laboratories > Edgewood
' ; .Arsenal . (Reported in Rosenblatt 1977).
Metcalf & Eddy.: 1987. Remedial Investigation Report,
/. ••:•';•< •.Chemtronics .Site. ..;• Swannanoa, NC.: .•:.-;.".; ^ .'. ,;:o.^ /. .''-'--. " "••
Natiohal:iristttutevfdr bccupatipnai' Safety and Health (NIOSH) .
VJ i • ^ 1987. .;•.-.; Registry of toxic effects of chemical substances
Jrv v (RTECS)^":. .U.S. -Department of Health and Human Services,
' ''''
"
Oak 'Ridge''National'Laboratory (ORNL).: 1986. Water Quality
v Criteria for Hexahydro-1,3,5-tririitro-l,3,5-triazine
3x\: (RDX);;;, Final. Report... ORNL-6178. Oak Ridge, TN. .
: ' •
Roseribiatt, D.H. '•:• 1988. -^Development" of preliminary pollutant
>: limit values for chemicals with limited toxicological
I - data.- In the Feasibility Study for the Chemtronics Site.
-8-
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^Demilitarization and Installation '"Restoration:
i ;%^©:^^ ;-;^9gf^:f.;.V'r Vyy;- ••-•-.
-------
MAY 03 1988.:.; -v ; :, ; . .:yv . .. _: . : .
WD-SPB " '. '. .'. "j'\';vV..•'.•'•"•
Ms. Susan Engelman •/ .
Boechat Celanese Corporation
loute 202-206 North
Somerville. MJ 08376 •-';.-:
Dear MB* Engelmanx ••'..' •.-•,-.•
This letter is in response to your correspondence the Agency received on
March 31, 1988 during the public cement period on the draft Feasibility Study
and the proposed remedial alternative for the Cheatronics Soperfun* Cite.
With respect to your concern of the groundwater clean-up criteria, It appears
that the data ENVI&ON used to calculate clean-up goals for benmXlic acid and
EDX became available after Sirrine performed their literature s^wrcfh. The
infomation you presented in this correspondence is being reviewed by Region
IV's Public Health Officer, Dr. Els*r Akin. I will follow his
recomaendation(s).
It is ny understanding that there vere several types of CS: CS, CS-1, and
CS-2, produced at the Ghenttonics facility with the latter species being more
hydrophobie, thereby, extending its lifetime after coming into contact vith
water. Ve did not attenpt to speciate the CS in our analyses, if it is even
feasible, between the the types of CS. Ve found several hot spots within soae
of the disposal areas with high levels of CS. Since CS was found in the soil
and exposed to water over the years fro» precipitation, one would expect that
only the degradative products of CS would be found and not "live" CS. This is
especially true if the expected half-life for CS is 41 minutes.
A groondwater sample collected during the October 1987 resampling episode for
several of the monitor wells was analyzed for BCL-462. 'This sample was :
collected from monitor well SW-A which is located downgradient of OA-23.
BCL-462 is a brominated compound and is reportedly the only chemical in the
biolagoon when the lagoon** liner disintegrate allowing the contents in the
biolagoon to enter the ground. The information provided to the Agency was that
one 55-gallon drum of BCL-462 distilled bottoms was introduced to a essentially
filled 500,000 gallon lagoon that had been seeded with microorganisms RCRA is
still looking at the Closure Plan submitted by Chemtronlcs, Inc.
The estimated volume of contaminated groundwater is incorporated into the
revised draft FS. The'volume is estimated to be 80 million gallons. It will'
not be possible to give an accurate estimate on the time required to clean the
aquifer until after additional hydrogeological data is collected during the
remedial design stage., • .ff'j--f--''':'. • ••':. . • . '"••"..' _ .
'' '' '' ''''''• '' " '''"* ' '
-------
-2-
If I can of be of farther help, please do not hesitate to contact me at
Sincerely your*,
''£*%>
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"V:.*
-.'~fTF;.7i&
- ••&*&
^
, ;,*» •~.^^>t . * 3
"•-^^
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:t
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fitif
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f- '••••'• -•"."*' .•••'" - '• • - . ' -. ' "'"••' »•'. -*• ;/' - •' .*•- '''. • .•'..'•.
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March 25, 1988
Jon Bornfiol m.,_,.."%.
Site Project Manager EPA
345 Courtland St. NE
Atlanta, 6A 30365
*~ i~ ' -\ - ' * * .' • ••
1.-.'.' ^ '•- •' •'"'• • ;;•••' >.-;•>-"•<• ••~^\>r' *;>••£ r7t' .• -..•.•'•"• •' v--.":"-'':'^'^'-i< i of • fft^i''~- •'
to extend the^ comment'period-'for the plahs.\for. the:""-'- '^-J.;
in SwannanoaV NC.: 'I feeV that, we do need, to'.da;<*>>.> vl._-
Dear Mr. Bornholm,
I want to urge you
cleanup at Chemtronics
a thorough
on with the
methodology1
to take its time-to be certain that it is indeed cleaning up
there and not just "spreading it around." It would riot serve the best interests'-^
of the community to have the EPA remove the.contaminents from the soil and
then put them into the air. Poison is poison.no matter which messenger .
brings its deadly power.' '. "../'• "^j: .;.;.-*• 1':.^,;^^,';; r; / ;;;-;v
The extra time would permit a more complete and objective investigation
of the dumping areas, a community-based health study, and more involvement
of the local community in the process. .Understandably, the community is
very concerned and need as much information as possible so that they can
interact in a creative and positive way. ' ; - - - V
Thank you for yourconsideration of this request.
Sincerely yours,
Ron Lambe
PO Box 18087
Asheville, NC 28814
cc: Clean Water Fund of
Rep. James M.
Sen. Terry
Sen. Jesse
••"•'•• •;>V'^-.-';;:.;"py^:\.,«;-- :--f-f<--:.--j.-.:
;>V'".-.Tnl'.«?5i>.V""-;'V>..-: ' M
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•:••' ^Vi ••^•^'•y '•'•!•: •:,i/::';£:^>:-.; '-• ' • 1
-.: :^ :C;-,-f ..-.-••-• : -;• :-^H^ ".•.•**-.::-.• I
-.-;;-; V; -.--;•> • f. "V >'.-X* "T '. •-' J[
MAR 2 31988
EPA - REGION IV
ATLANTA, GA.
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VD-SPB V;'~'^.-.•'••"':'! ••.•:v?-. :.'•" ••"•••-:•••-"-'•>'••-- -• ' •" ' •-•
Mr. Ion L*»be - .£.•-.•/:/" "'^^^.v''--'1.: '..' ''"• *••"..; '- --V:',: v: ,-.: .-._...
P.O. Box 18087. ••'^":: "•""'• --.-r'.-r'V-..- •' -.? • " ' '•'."".. " . '% ' !- "' " .'••
Asheville. NC 28814 : ;:. .:.. -•-., ,'. ,
Dear Mr. iJibax"--';,-L; . •' .^V/'"Jr-'Vi;1;'-'-. : ; •' ••'-. c-;-•'•-';.' ,'. : • = '.'-•"•• '• " ""
This letter is In response to jour letter received by the Agency on March 28,
1988 vith regard* to comments on the draft Feasibility Study and the proposed
remedial alternative lor the Chesitrooies Super fund Site.
Aa you know, the Original public comment period on the draft Feasibility Study
and EFA's proposed remedial action at the Chemtronics Superfund Site expired on
March 18, 1988. Later, the content period vaa extended to April 1, 1988. The
community's desire for the public comment period to be extended two months past
the date the community receives the Technical Assistance Grant (TAG) vas
brought to the attention of Mr. Lee DeHlhns, Acting Regional Administrator. It
vas his decision to let stand the April 1, 1988 closing date for the public
comment period. Bis decision vas based on the appraisal that even if the
community vere selected for such a grant, ve estimated that it vould take
approximately eight months to a year for the Agency to make the avard and for
you to procure a consultant and revlev the report the consultant developa. The
Agency, however, is mandated by Congress 'in the Superfund Amendments and
Reauthorization Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delays vill impede the
Agency's attempt to achieve this goal. • .. - '
SARA also encourages the Agency to select permanent solutions for the clean-up
at Superfund Sites. After the Agency reviewed all the remedial technologies
identified in the draft Feasibility Study for addressing source control for the
contaminants found in the disposal areas contsining drums, the only remedial
alternative that achievea this goal is incineration. Off-site Incineration vas
eliminated from consideration because it was estimated that it would be more
cost effective to Incinerate these materials bn-slte. ,
Under ideal conditions vith the Incinerator working as It vas designed, the
only compounds that vould be entering the environment from the incinerator
vould be the ash/soil residue from the burnt soils and vater vapor and carbon
dioxide out of the smoke stack. Therefore, virtually complete destruction of
the contaminants vould be achieved. •••'•:' •'->:-v>.V:;'•'.:;-;•'• .::''v' • :'•'•':'•• .*.:'•'_ • ••• • -
.•-'':-•• '' •;•'•••."•-• .:•••-•• ; • •'.'••'• v---*-:-' '•. •• : •".-•':' ""••" v-"'r;~'-::.;--'-\---'.r'~^-''^ "-"' -'• ' •'
This remedial alternative was not selected for several reasons. First and
foremost, is the threat posed by live ordnance burled along vith the drums to
the workers vho vould be involved in the excavation of these drums in order to
prepare them for incineration. The second issue considered vas the potential
-------
damage that .this ordnance .would have «n the incinerator itself. If these
devices exploded inside 'the incinerator's chamber, it would be difficult to
predict the results. One possible scenario is the release of partially
-destroyed contami nant s into the environment* This coupled vith the fact that
'the Ashevllle «rea Is Iocs ted in part of the country that experiences frequent
sir inversions, would increase, the potential to exposing the community to these
partially destroyed .chemicals if a release, for any reason, occurred. And
thirdly, a great xuiaber of ^titlcens voiced * negative response towards «n-site
Incineration ^othln the public meeting and during the public comment period.
This left the Agency vith basically one other 'remedial alternative to address
source control for these disposal areas that vould adequately protect the
public and the environment and that vas to place a cap over these disposal
areas. It vas not advisable to follow a BO action alternative since the
contaminants disposed of in the majority of these disposal areas are presently
migrating with the groundvater from their disposal areas*
SARA also encourages the Agency to implement a remedial alternative that
reduces the mobility, toxicity and voluae of hasardous waste at a Super fond -
.Site* The capping of the drum disposal areas along with the capping of the.
acid pit area and the soil flxatlon/stabillxation/solldiflcatlon process for.
disposal area 23 along with extracting and treating ground water will meet these
criteria. The security fences to be Installed around these capped areas will
help maintain the integrity of the caps by preventing unwanted intruders
Including man and animals alike, from damaging the cap*
In addition to the' remedial activities stated above, the Site will have a long
term monitoring system initiated for both the groundwater and surface water.
This monitoring system will provide data that will indicate whether or not the
remedial action implemented is working as designed.
With regard to your suggestion that the extra time during the extension of the
public comment period would allow additional studies to be conducted, the
Agency's stance is that sufficient data has already been generated to support
the selection of the remedial alternative. And it is my understanding that
North Carolina Department of Human Resources, Division of Health Services,
Environmental Epidemiology Branch may look into the reported health issue.
If I can of be of further help, please do not hesitate to contact me at
(404)347-7791. . ... ... /
Sincerely yours, • -• '''-':'T: •••••."//'- •""- ' • •' ""£,.;:V/ - ^•~''~-:l-- ' '•' '''"•'•:". ':[',:• ..
' ' •"'••' •' •"' •
Jon X* Bornholm . . ..''!.' /
Super fund Project Manager "
4WD-SPB 4WD-SFB
BORNHOLM HANKE
. . .
*Jon Bornholm /Telex DISK CHZMTRpNICS, PILE CR#3
'' ''
4/15/88
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44 Wagon Trail
Black Mountain, NC
28711-2533
704-669-5890 CRRB
March 14, 1988
r
MAR 2 i 196$
U Ib
EPA . REGION IV
T n u , ATLANTA. GA.
Mr. Jon Bornholm
Site Project Manager
US EPA
345 Courtland Street, NE
Atlanta, GA 30365
Dear Mr. Bornholm,
,
I am writing this follow up letter to my question at the hearings at
Owen High School on February 23, 1988 regarding the Superfund Cleanup
of the Chemtronics property in Swannanoa, NC.
Let me repeat my comment that your study and report are very thorough,
and you are to be congratulated on it* I was glad to know of cleanup
procedures, of which I had not read in the general chemical literature.
Let me clarify again my question about removal of the 600 drums for
incineration at existing, licensed locations by itollins, GTX, and
others. Your studies have shown that leakage to date has been minimal
and in no way life-threatening. My belief is that you probably do
not need to incinerate all the soil, as you proposed. Just remove
the drums and take them to an approved incinerator. The argument
that drums of BZ must have Army protection during transport, and >:
therefore cannot be moved, is not germane. Simply ask the Army to
do it. It will be a good training exercise for the Chemical Corps!
After the drums are gone, follow up on the studies by T. Kent Kirk
of the Department of Agriculture's Forest Products Laboratory in
Madison, Wisconsin as reported at the national meeting of the
American Chemical Society in New Orleans last September. The results
were described in "Chemical and Engineering News" September 14, 1987,
page 17-19. Certain fungi can convert PAN, PCBs and other chlorinated
aromatlcs to non-toxic dicarboxylic acids and further degradation
products. This will purify the soil which has been contaminated
to date and will, in the long run, avoid the necessity for the
costly ctfpping procedures. The area can then be reused, instead
of being a capped wasteland.
A point which I did not bring up at the hearing, since you had asked
that each questioner be limited to about five or six minutes, is this.
I find it Incredible that the option of "No Action" is retained as
a viable solution to the problem. While it is true that no dire
circumstances have developed in the fifteen to twenty years to date,
you know very well that those drums will rust through in another
five to ten years or less, releasing some 33,000 gallons of con-
taminants. At that point, the cleanup program will be infinitely
more difficult than it is today. Let us get that option out of
further consideration]
-------
Since you work for the Environmental Protection Agency, I know that
you have our best interests at heart. Let*3 remove the drums and
then biologically purify the soil and get on with the work!
Many persons in the community, who were unable to attend the hearing,
still need the opportunity to have the chance to evaluate the report
and to write to you. The five week period that you have allowed
for these letters and calls is much too short. You have had more
than two years to make your analysis* We should.be given at least
two more months. •
Thank you for your attention to this letter.
Yours truly,
Allen P. Arnold, Ph.D.
Adjunct Professor of Chemistry, UNCA
cc Congressman Jamie Clark
Dr. Dean Kahl, Chairman, Department of Chemistry Warren Wilson College
Laura Temple Haney, Department of Environment Warren Wilson College
Mr. Larry Pope, Executive Editor, Asheville Citizen-Times
Mr. Bob Clark, Swannanoa, NC
Mr. Allan Robertson, Chairman, Board of Trustees, Highland Farms
Mr. Chet Prentis, President, Highland Farms, Black Mountain, NC
-------
HAY 03 1988 - V ;
'-. WD-SFB - ' '- ' ' •v .. '•••.- • -' / - . - ••
Or* Allen Arnold
44 Kagon Trail .->: .
Black Mountain, NC 28711-2533
Dear Dr. Arnold: -;-v :' -
This correspondence is in response to your letter the Agency received on
March 21, 1988 during the public cooznent period on the draft Feasibility Study
and the proposed remedial alternative for the Chemtronics Super fund Site.
As you know, the original public cooment period on the draft Feasibility Study
and EPA's proposed remedial action at the Chemtronics Site expired on March 18,
1988. Later, the coraaent period was extended to April 1, 1988. The
community's desire for the public concent period to be extended two months past
the date the cocmunity receives the Technical Assistance Grant (TAG) was
brought to the attention of Mr. Lee DeHihns, Acting Regional Administrator. It
was his decision to let stand the April 1, 1988 closing date for the public
cooroent period. His decision was based on the appraisal that even if the
connunity was selected for such a grant, we estimated that it would take
approximately eight months to a year for the Agency to make the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is mandated by Congress in the Superfund Amendments and
Reauthorization Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delays will impede the
Agency's attempt to achieve this goal* :-
SARA also encourages the Agency to select permanent solutions for the clean-up
at Superfund Sites. After the Agency reviewed all the remedial technologies
identified in the draft Feasibility Study for addressing source control for the
contaminants found in the disposal areas containing druras, the only remedial
alternative that achieves this goal is incineration. Off-site incineration was
eliminated from consideration because it was estimated that it would be more
cost effective to incinerate these materials on-site. . •: •- .
This remedial alternative was not selected for several reasons. First and
foremost, is the threat posed by live ordnance buried along with the drums to
the workers who would be involved in the excavation of these drums in order to
prepare than for incineration. •*the second issue considered was the potential
damage that this ordnance would have on the incinerator itself. If these
devices exploded inside the incinerator's 'chamber, it would be difficult to
predict the results. One possible scenario is the release of partially
destroyed contaminants into the environment. This coupled with the fact that
-------
. -2- . . ; - .
the Asheville area is located in part of the country that experiences frequent
air inversions, would increase the potential to exposing the coonunity to these-
partially destroyed chemicals if a release, for any reason, occurred. And
thirdly, a great number of citizens voiced a negative response towards on-site
incineration both in the public meeting and during the public comment period.
This left the Agency with basically one other remedial alternative to address
source control for these disposal areas that would adequately protect the
public health and the environment and that was to place a cap over these
disposal areas. It was not advisable to follow a no action alternative since
the contaminants disposed of in .the majority of these disposal areas are
presently migrating with the groundwater from their disposal areas.
SARA also encourages the Agency to implement a remedial alternative that
reduces the mobility, toxicity and volume of hazardous waste at a Superfund
Site. The capping of the drum disposal areas along with the capping of the
acid pit area and the soil fixation/stabilization/solidification process for
disposal area 23 along with extracting and treating groundwater will meet these
criteria. The security fences to be installed around these capped areas will
help maintain the integrity of the caps by preventing unwanted intruders
including man and animals alike, from damaging the cap.
Your suggestion to employ microorganisms and/or fungi to help degradate the
chlorinated aromatic compounds in the disposal areas warrants further
investigation. Although you suggested removing the drums and then, I assume,
seeding the soil with the appropriate microorganisms to help detoxify.the
remaining contaminants in the soil. The major concern with this approach, as
identified above, is the presence of explosive devices in the disposal areas.
Although the capping option does not remove the source, this remedial
alternative does not preclude using the seeding of the soils with these
microorganisms prior to placing the cap over these areas.
He are required by the National Contingency Plan (NCP) to consider a "No
Action" alternative throughout the process. This provides a cooroon baseline
data base to ccopare each remedial alternative and the health risk associated
.with each alternative. ; V \!
If I can of be of further help, please do not hesitate to contact roe at
(404)347-7791. . ^ : •- -..
Sincerely yours, -'•-••*- -? > •-.- •/• -• - •-•-.•••••, •• ..
Jon K. Bornholm
Superfund Project Manager
4WD-SFB 4WD-SFB 4WD-SFB . "..
BORNHOLM HAF GREEN ' '
Jon BornhoBft T£lex DISK CHEMTRONICS, FILE CR92, 4/26/88
-------
s
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MAR 21 '988
ATLANTA. GA,
ER3B
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MAR.231988IJJJ
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-------
U 1988
* -" * * .*."
WD-SFB .
Mr. t Mr*. Analey
P.O. Box 535
Black Mountain, HC 28711
Dear Mr* I Mrs* Ansleyi .
This correspondence is in response to your letter the Agency received on
March 23, 1988 during the public consent period on the draft Feasibility Study
and the proposed remedial alternative for the Chemtrooics Superfund Site*
.• • * i
As you know, the original public comment period on the draft Feasibility Study
and EPA*s proposed remedial action at the Cheetronies Site expired on March 18,
1988. Later, the comment period vas extended to April 1, 1988. The
community's desire for the public comment period to be extended two months past
the date the community receives the Technical Assistance Grant (TAG) vas
brought to the attention of Mr. Lee DeRihns, Acting Regional Administrator. It
vas his decision to let stand the April 1, 1988 closing date for the public
comment period* Bis decision vas based on the appraisal that even if the
community vas selected for such a grant, ve estimated that it would take
approximately eight months to a year for the Agency to make the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is mandated by Congress in the Superfund Amendments and '. .
Reauthorizatlon Act of 1986 (SARA) to have cleanup activities underway at 175'
Superfund Sites by October 1989 and any untimely delays will impede the
'Agency's attempt to achieve this goal. '••• "•'**>'••• --.V -v-^r->>;-;,:. = •.-•-•.•;•
SARA also encourages the Agency to select permanent solutions for the clean-up
at Superfund Sites. Alter the Agency reviewed all the remedial technologies
identified in the draft Feasibility Study for addressing source control for the
contaminants found In the disposal areas containing drums, the only remedial ~
alternative that achieves this goal is inclnerstion. Off-site incineration vas
eliminated from consideration because it vas estimated that It would be more
cost effective to incinerate these materials on-site. v'- -, • • •
Under ideal conditions with the incinerator working as designed, the only
compounds that would be entering the environment from the incinerstor would be
the ash/eoil residue from the burnt soils snd water vapor and carbon dioxide
out of the smoke stack. Therefore, virtually complete destruction of the ',':
contaminants would be achieved* .••:'•.•-.•/••.*':.'.'i---._'..-.••'- '• '-.•'•• ; }•
-------
-2- -'• ..•-
This remedial alternative vac not selected for several reasons. First and
.foremost, is the threat posed by live ordnance^burled along with the drums to
-the' workers who would be involved in the excavation of these drums in order to
prepare then for incineration. The second issue considered was the potential
damage that this ordnance would have on the incinerator itself. If these
devices exploded inside the incinerator's chamber, it would be difficult to
predict the results* One possible scenario is the release of partially
destroyed contaminants into the environment. This coupled with the fact that
the Asheville area is located in part of the country that experiences frequent
.air inversions, would increase the potential to exposing the community to these
partially destroyed chemicals if a release, for sny reason, occurred. And
thirdly,' a great number of citizens voiced a negative response towarda on-site
incineration both in the public meeting and during the public comment period.
This left the Agency with basically one other remedial alternative to address
source control for these disposal areas that would adequately protect the
public health and the environment and that was to place a cap over these
disposal areas. It was not advisable to follow a no action alternative aince
the contaminants disposed of in the majority of these disposal areas are
presently migrating with the groundwater from their disposal areaa.
SARA also encouragea the Agency to implement a remedial alternative that
reduces the mobility, toxicity and volume of hazardous waste at a Superfund
Site. The capping of the drum disposal areas along with the capping of the
acid pit area and the soil fixation/stabilization/solidification process for
disposal area 23 along with extracting and treating groundwater will meet these
criteria. The security fences to be Installed around these capped areas will
help maintain the integrity of the caps by preventing unwanted intruders
Including man and animals alike, from damaging the cap.
In addition to the remedial activities stated above, a long term monitoring
system will be instituted for the groundwater in both valleys and surface
water. This monitoring system will provide data that will be used to Indicate
whether or not the remedial action Implemented is working as designed.
With respect your concern about blasting at the Site, EPA does not have
Jurisdiction over this type of activity. It would be prudent, however, on
Chemtronics part to ensure that following the Installation of the extraction
wells to remove the contaminated groundwater during the remedial action, that
they take into" account the effect* if any, the blasting could have on the
'geology and hydrogeology of the area. If the blasting alters the groundwater
regime in this vicinity then they may be required to install additional
extraction and monitor wells to accommodate the change. .-;'.
If I can of be of further help, please do not hesitate to contact me at
-: (404)347-77*1 v ~ : -> : : -- ---.: ^4^^
-Sincerely yours,! v/:-'-.-
Jon K. Bornholm.~V^c vV•'••'•^•--:.#•';
Superfund Project Manager '.:'':'*•
4WD-SFB ' 4WD-SFB 4WD-SFB
BORNHOLM HANKE./ GREEN
-------
ell
PtjLA-<*4— *y
I' fl
,4u~&ia
0=
3J J&+X~ £ .££**?*-'/*
o u
s°***l •
-------
MAY 04 1988 v .
.VD-SFB • •' -. >' ;'•• -:..V .'.7Y-' " '. • . ' ;!."
Ms. Joan Keuger '1 " ". ' " .
P.O. Box 8286 " .-..;•
Asheyille, HC 28814 ..
Dear Ma. Keugeri
-• .-• ..• . . • . .
This correspondence is in response to your letter the Agency received on
March 23, 1988'during the public comment period on the draft Feasibility Study
and the proposed remedial alternative for the Chemtronics Superfund Site*
"•-.",••»•" •
As you know, the original public comment period on the draft Feasibility Study
and EPA's proposed remedial action at the Chentronics Site expired on Karch 18,
1988. Later, the cement period was extended to April 1, 1988. The
community's desire for the public comment period to be extended tvo months past
the date the community receives the Technical Assistance Grant (TAG) vas
brought to the attention of Mr. Lee DeHihns, Acting Regional Administrator. It
vas hia decision to let stand the April 1, 1988 closing date for the public
comment period. Bis decision vas baaed en the appraisal that even if the
community vaa selected for such a grant, ve estimated that it would take
approximately eight months to a year for the Agency to make the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is mandated by Congress la the Superfund Amendments and
Reauthorizatlon Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delays will impede the •
Agency's attempt to achieve this goal. " ;. '• - . -'«
SARA also encourages the Agency to select permanent solutions for the clean-up ;
at Superfund Sites. After the Agency reviewed all the remedial technologies
identified in the draft Feasibility Study for addressing source control for the
contaminants found in the disposal areas containing drums, the only remedial
alternative that achieves this goal is incineration. Off-site incineration vas
eliminated from consideration because it vaa estimated that it would be more
cost effective to incinerate these materlala on-site. .
Under ideal conditions with the Incinerator vorking as designed, the only "'- :
compounds that vould be entering the environment from the incinerator would be
the ash/soil residue from the burnt toils and water vapor and carbon dioxide
out of the smoke stack. Therefore, virtually complete destruction of the ;
. contaidnanta would be achieved.V;<7Vv:i-pVvW^':.^.-; •:• -.-. ..'. • •-•. -._._'
':^V;^;~ ^u:.,/^^^ " "''"••'• ^-'••'•'"; '' • ' - :'"" '••'••
-------
- .-.'•-. -2- - v. -
"" - ".-'"'- • "**'
'-'"•• > •• ' .• - -....'.' .".-. •-.'. . :• .-* •-• "• •"..-;•-.-.-. " • •'
Thla remedial alternative was not. selected for several reason*. First and
:foremost, is tn« threat posed by live ordnance buried along with the druas to
.the workers who would be Involved in the excavation of these druas in order to
prepare "then for incineration. The second issue considered was the potential
daaage that this ordnance would have on the incinerator itself. If these
devices exploded inside the incinerator'* chaaber, it would be difficult to
predict the results. . One possible scenario is the release of partially
destroyed contaminants into the environment. This coupled with the fact that
the Asheville area is located in part of the country that experiences frequent
air inversions, would increase the potential to exposing the community to these
partially destroyed cheaicals if a release, for any reason, occurred. And
thirdly, a great number of citizens voiced a negative response towards on-site
incineration both in the public aeeting and during the public comment period.
This left the Agency with basically one other remedial alternative to address
source control for these disposal areas that would adequately protect the
public health and the environment and that was to place a cap over these
disposal areas•'•' It was not advisable to follow a no action alternative since
the contaminants disposed of in the majority of these disposal areas are
presently aigrating with the groundwater froa their disposal areas.
* . ...
SABA also encourages the Agency to implement a reaedial alternative that
reduces the mobility, toxicity and volume of hazardous waste at a Superfund
Site. The capping of the drum disposal areas along with the capping of the
acid pit area and the soil fixation/stabilization/solidification 'process for
disposal area 23 along with extracting and treating groundwater will aeet these
criteria. The security fences to be installed around these capped areas vill
help maintain the integrity of the caps by preventing unwanted intruders
including man and animals alike, froa damaging the cap. - -
In addition to the reaedial activities stated above, a long term monitoring
system will be instituted for the groundwater in both valleys and surface * v
water. This monitoring system will provide data that will be used to indicate
whether or not the reaedial action implemented is working as designed. .
The Remedial Investigation (RI) performed at the Cheatronics Site was
equivalent, if not more thorough, than Rls conducted at other Superfund Sites.
The primary purpose of the RI is to generate sufficient data to support the
decisions made in the Feasibility Study. This was* done at Chemtronlcs.
".'•i^r • •' ' • • '- •*". ••-••'• '••'• '•"•"•-•' ' '•"'•' •' '":':'•':': ijv:^'^:..^ v'.y-• ••-' '."•-'•
With regard to your suggestion that the extra time during the extension of the.
public comment period would allow additional studies to be conducted, the
Agency's stance ia that sufficient data has already been generated to support
the selection of the remedial alternative. And it is ay understanding that
North Carolina Department of Human Resources, Division of Health Services,
Environmental Epidemiology Branch may look into the reported health issue. -
-------
-3-
If I «an of be .of further help, pleaae do not hesitate to contact »e at
(404)347-7791. ; -'-'-=-. / -
Sincerely youra, . , ...
Jon I.
Superfund Project Manager
4WD-SFB 4WD-SFB 4WD-SFB
BORNHOLM HAMK&V GREEN
Jon Bornholm Telex DISK CHEMTRONICS, FILE C106, 4/26/88
-------
•WLgklorvd Farm.*
c v+^V K I t- 3
A. N. C. 28711
Z-l,
USA
2
Ctv* 'Tr-i***.
^C^fcX" C sjC-r^i
<
***
^ /^v.
ELSEUITEIH
EPA - REGION TV
ATUirrTA. GA.
"3 -f
-------
VD-SFB .
tic* Margret*Anderson
Apt. K 123 > .
Highlands Farms
Black Mountain, NC 28711
Dear Ma. Anderson: " . . • - :- • . .
'This correspondence ia in reaponae to your letter the Agency received on
March 23, 1988 during the public comment period on the draft Feasibility Study
and the proposed reaedlal alternative for the Chemtronlca Superfund -Site.
As you know, the original public comaent period on the draft Feasibility Study
and EPA's proposed remedial action at the Cheatronics Site expired on March 18,
1988. Later, the comment period was extended to April 1, 1988* The
community's desire for the public content period to be extended two months past
the date the community receives the Technical Assistance Grant (TAG) was -
brought to the attention of Mr. Lee DeRihns, Acting Regional Administrator* It
vas his decision to let stand the April 1, 1988 closing date for the public
comment period* His decision was based on the appralaal that even If the
community was selected for such a grant, we estimated that it would take
approximately eight months to a year for the Agency to make the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is mandated by Congress in the Superfund Amendments and
Reauthorlzatlon Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delays will Impede the .
Agency's attempt to achieve this goal* . - -.,;.-
SARA also encourages the Agency to select permanent solutions for the clean-nip
at Superfund Sites* After the Agency reviewed all the remedial technologies
identified in the draft Feasibility Study for addressing .source control for the
contaminants found in the disposal areas containing drums, the only remedial
alternative that achieves this goal is incineration* Off-site incineration was
eliminated from consideration because it was estimated that it would be aore
cost effective to incinerate these materials on-slte. • -' :>.---
Under ideal conditions with the Incinerator working as designed, the only
compounds that would be entering the environment from the incinerator would b«
the ash/soil residue from the burnt soils and water vapor and carbon dioxide .
out of the smoke stack. Therefore, virtually complete destruction of the
contaminants would be achieved* .. r '.
-------
-2-
This remedial.alternative was not selected for several reason*. First and
foremost, .is the. threat posed by live ordnance buried along with the drums to
ihe"workers who would be Involved in the excavation of these drums in order to
prepare them for incineration^..The second issue considered was the potential
damage that this ordnance would have on the incinerator itself. If these
devices exploded inside the incinerator's chamber, it would be difficult to
predict the.results. One possible .scenario is the release of partially
destroyed contaminant* into the environment. This coupled with the* -fact that
the Aaheville area is located in part of the country that experiences frequent
sir inversions, would increase the potential to exposing the community to these
partially destroyed chemicals if a release, for any reason, occurred. And
thirdly, a great number of citizens voiced a negative response towards on-site
incineration both in the public meeting and during the public comment period.
This left the Agency with basically one other remedial alternative to address
source control for these disposal areas that would adequately protect the
public health and the environment and that was to place a cap over these
disposal areas. It was not advisable to follow a no action alternative since
the contaminants disposed of in the majority of these disposal areas are
presently migrating with the groundvater from their disposal areas.
SARA also encourages the Agency to implement a remedial alternative that
reduces the mobility, toxlcity and volume of hazardous waste at a Superfund
Site. The capping of the drum disposal areas along with the capping of the
acid pit area and the soil flxatlon/stabllixation/aolidificatlon process for
disposal area 23 along with extracting and treating groundwater will meet these
criteria. The security fences to be installed around these capped areas will
help maintain the integrity of the caps by preventing' unwanted intruders
including man and animals alike, from damaging the cap.' .
.- • - - - , - - - -
In addition to the remedial activities stated above, a long term monitoring
system will be Instituted for the groundwater in both valleys and surface
water. This monitoring system will provide data that will be used to Indicate
whether or not the remedial action Implemented is working as. designed.
' . . ' .. .••-'•."...' • , .'. ~~ •.":'••'": • .»:"*-V-.". '.-,':-'":•"'-" " ...- •' "'-"V • - '
With respect your concern about blasting at the Site, EPA does not have'
jurisdiction over this type of activity. It would be prudent, however, on •
Chemtronics part to ensure that following the installation of the extraction
wells to remove the contaminated groundwater during the remedial action, that
they take into account the effect, if any, the blasting could have on the
geology and hydrogeology of the area. If the blasting alters the groundwater
regime in this vicinity then they may be required to install additional
extraction and monitor veils to accommodate the change.' ~;-
The Remedial Investigation (RI) performed at the Chemtronics Site was
equivalent, if not more thorough, than RIs conducted at other Superfund Sites.
The primary purpose of the RI is to generate sufficient data to support the
decisions made in the Feasibility Study. This was done at Chemtronics. •
-------
-3-
Vith regard to your suggestion Chat the extra time during the extension of the
public comment period would allov additional studies to be conducted, the
Agency's stance is that sufficient data has already been generated to support
the selection of the remedial alternative. And It Is my understanding that
Berth Carolina Department of Human Resources, Division of Health Services,
Environmental Epidemiology Branch may look into the reported health issue.
If I can of be of further help, please do not hesitate to contact me at
(404)347-7791.
Sincerely yours.
Jon K. Borrihblm" -
Superfund Project Manager
4WD-.SFB 4WD-SFB 4WD-SFB
BORNHOLM HM)pi GREEN * .
"• ^W • '
Jon Bornholm Telex DISK CHEMTRONICS, FILE C107, 4/26/88
-------
-»
ERRB
MAR 2 31933
EPA - REGION IV
ATLAriTA, GA.
-------
3 198S
HD-SFB . . .. .•• ;. •.•-..>•-• •••>"" -• ,-"• •-.':'-.''.-.".-.••: ••".' • •.
Ms. Barbara Gav ~; : - .
P.O. Box 544
Montreal, HC 28737 ; • : .
Dear Ma. Caw: ' ' .-. - ,.• -.-."•. -; - . -• \' "': • ".^ .;: ' -. '•:--. ' . • . . -
This correspondence it in response to your letter the Agency received on
March 23, 1988 during the public comment period on the draft Feasibility Study
and the proposed remedial alternative for the Cheatronics Superfund Site.
As you know, the original public coaaent period on the draft Feaaibility Study
and EPA's proposed remedial action at the Cheatronies Site expired on March 18,
1988. Later, the cement period vaa extended to April 1, 1988. The
community's desire for the public comment period to be extended two months past
the date the community receives the Technical Assistance Grant (TAG) was
brought to the attention of Mr. Lee DeHlhns, Acting Regional Administrator. It
was his decision to let stand the April 1, 1988 closing date for the public
comment period. His decision was based on the appraisal that even if the
community was selected for such a grant, we estimated that it would take
approximately eight months to a year for the Agency to nake the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is aandated by Congress in the Superfund Amendments and
Reauthorlzation Act of 1986 (SARA) to have cleanup activities underway at 17S
Superfund Sites by October 1989 and any untimely delays will impede the
Agency's attempt to achieve this goal. • : . ~
" .''•••-'•.'/:• -'•' A:'--^"ri"'-<..-;:'-^4'i...:- •'^•*'~?*^:- -.' •. - ,
• .- - -. •;'.>- .---.''.• . • " ,'"7 ' . - >
SARA also encourages the Agency to select permanent solutions for the clean-up
at Superfund Sites. After the Agency reviewed all the remedial technologies
identified in the draft Feasibility Study for addressing source control for the
contaminants found in the disposal areas containing druas, the only remedial
alternative that achieves this goal is incineration. Off-site incineration was
eliminated froa consideration because it waa estiaated that it would be acre
cost effective to incinerate these materials on-site.
Under ideal conditions with the incinerator working as designed, the only
compounds that would be entering the environment from the Incinerator would be .
the ash/soil residue froa the burnt soils and water vapor and carbon dioxide
out of the smoke stack. Therefore, virtually complete destruction of the
contaminants would be achieved. : -.^ - \ -. •
-------
-2-
This remedial alternative..was not selected for several reasons. First and
foreaost, if th« .threat posed by lire ordnance buried along vith the droas to .
the workers.who would be involved in the excavation of these druas in order to
prepare them for.Incineration. The second issue considered was the potential
daaage that this ordnance would have on the incinerator itself. If these
devices exploded Inside the incinerator's chamber, it vould be difficult to
predict the results* ..One possible'scenario is the release of partially •
destroyed contaainants into the •nvirbnaent* This coupled with the fact that
the Aaheville area is located in part of the country that experiences frequent
air inversions, would increase the potential to exposing the coaannlty to these
partially destroyed chemicals if a release, for any reason, occurred. And
thirdly, a great noaber of citizens voiced • negative response towards on-site
Incineration both in the public aeeting and during the public concent period.
This left the Agency with basically one other remedial alternative to address
source control for these disposal areas that would adequately protect the
public health and the environment and that vas to place a cap over these
disposal areas. It vas not advisable to follow a no action alternative since
the contaainants disposed of in the majority of these disposal areas are
presently aigrating with the groundwater froa their disposal areas.
SARA also encourages the Agency to lapleaent a remedial alternative that
reduces the aobility, toxlcity and voluae of hazardous waste at a Snperfund
Site* . The capping of the drua disposal areas along with the capping of the
acid pit area and the soil fixatlon/stabilication/solidification process for
disposal area 23 along with extracting and treating groundwater will aeet these
criteria* The security fences to be Installed around these capped areas will
help aalntain the integrity of the caps by preventing unwanted intruders
including aan and anlaals alike, froa daaaging the cap* ' -. :
In addition to the remedial activities stated above, a long tera aonltoring
system will be instituted for the groundwater in both valleys and surface
water. .This aonitoring systea will provide data that will be used to indicate
whether or not the renedial action implemented is.working as 'designed. ~
With respect your concern about blasting at the Site, EPA does'not have
jurisdiction over this type of activity* It would be prudent, however, on
Cheatronics part to ensure that following the Installation of thevextraction
wells to remove the contaminated groundwater during the remedial action, that
they take into account the effect, if any, the blasting could .have on the
geology and hydrogeology of the area* If the blasting alters the groundwater
regime in this vicinity then they may be required to install additional
extraction and aonitor wells to accommodate the change* . . .. '. • .
The Remedial Investigation (RI) performed at the Cheatronics Site was
equivalent, if not more thorough, than RIs conducted at other Superfund Sites.
The primary purpose of the RI is to generate sufficient data to support the
decisions made in the Feasibility Study. This was done at Cheatronics.
-------
- -3- . ' : • • • '•
With regard to jour suggestion that the extra time'during the extension of the
public comment period would alloy additional studies to be conducted, the
Agency's stance is that sufficient data has already been generated to support
the selection of the remedial alternative. And it is By understanding that
North Carolina Department of Human Resources, Division of Health Services,
Environmental Epidemiology Branch may look into the reported health issue.
If I can of be of further help, please do not hesitate to contact me at
(404)347-7791.
Sincerely yours, -* '
Jon K. Bonfttblif-^ ^ . - - -< "-
Superfund Project Manager
4WD-SFB 4WD-SFB 4WD-SFB
BORNHOLM AAft&E . GREEN
'
Jon Bornholm T&ex^DISK CHEMTRONICS, FILE C108, 4/26/88
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VD-SFB ..- • : ••'.-';_:" .- • .:.•"' •.;•""'•-..
Mr. Robert Clark
3 Lockhart Lane '
Svannanoa, SC 28778 * . . : . ,
Dear Mr. Clarkt '''•/•."'-. •' - •• ;".''-:.' '•' •'•
This correspondence is In response to your letter the Agency received on
March 23, 1988 during the public comment period on the draft Feasibility Study
and the .proposed remedial alternative for the Chemtronics Superfund Site.
Aa you know, the original public comment period on the draft Feasibility Study
and EPA'e proposed remedial action at the Cheatronics Site expired on March 18r
1988. Later, the comment period was extended to April 1, 1988. The
community's desire for the public comment period to be extended two months past
the date the community receives the Technical Assistance Grant (TAG) was
brought to the attention of Mr. Lee DeHihns, Acting Regional Administrator. It
was his decision to let stand the April 1, 1988 closing date for the public
comment period. His decision vas based on the appraisal that even if the
community vas.selected for such a grant, we estimated that it would take
approximately eight months to a year for the Agency to make the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is mandated by Congress in the Superfund Amendments and
Reauthorizatloa Act of 1986 (SABA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delays will impede the
Agency's attempt to achieve this geal,j'A-'4^:''-'^^*-"'^' '' •'" - "• • -.-••• ' ''.'•'"
SARA slso encourages the Agency to select permanent solutions for the clean-up
at Superfund Sites. After the Agency reviewed all the remedial technologies
Identified in the draft Feasibility Study for addressing source control for the
contaminants found in the disposal areas containing drums, the only remedial \
alternative that achieves this goal is incineration. Off-site incineration was
eliminated from consideration because it was estimated that it would be more \
cost effective to incinerate these materials on-site.
Under ideal conditions with the incinerator working as designed, the only '
compounds that would be entering the environment froa the incinerator would b«
the ash/soil residue froa the burnt soils and water vapor and carbon dioxide
out of the smoke stack. Therefore, virtually complete destruction of the
contaminants would be achieved. •-,-^;,; !- - • <-••.'.'."•''.'••:•''
-------
This remedial alternative vas not selected for several reasons. First and
foremost, is the threat posed by live ordnance burled along with the drums to
the workers who vould be involved in the excavation of these drums in order to
prepare thea for incineration. The second issue considered vss the potential
damage that this ordnance vould have on the incinerator Itself. If these
devices exploded inside the incinerator's chamber, it vould be difficult to
predict the results* One possible scenario is the release of partially
destroyed contaminants into the environment. This coupled with the fsct that
the Ashevilie area is located in part of the country that experiences frequent
air inversions, vould increase the potential to exposing the community to these
partially destroyed chemical* if a releaae, for any reason, occurred. And
thirdly, a greet number of citizens voiced a negative response towards on-site
Incineration both in the public meeting and during the public coaaent period.
This left the Agency with basically one other remedial alternative to address
source control for these'disposal areas that would adequately protect the
public health and the environment and that vas to place a cap over these
disposal areas. It was not sdvisable to follow a no action alternative since
the contaminants disposed of in the majority of these disposal areas are
presently migrating with the groundwater from their disposal areas. -
SARA also encourages.the Agency to Implement a remedial alternative that
reduces the mobility, toxiclty and volume of hazardous waste at a Superfund
Site. The capping of the drum disposal areas along with the capping of the
acid pit area and the soil fixation/stabilization/solidification process for
disposal area 23 along with extracting and treating groundwater will meet these
criteria. The security fences to be installed around these capped areas will
help maintain the integrity of the caps by preventing unwanted intruders
including man and animals alike, from damaging the cap. :
In addition to the remedial activities stated above, a long term monitoring
systea will be instituted for the groundwater in both .valleys and surface
water* This monitoring systea will provide data that will be used to Indicate
whether or not the remedial action implemented is working as designed.
A list of nearby private veils vas generated with the help of Horth Carolina.
Department of Natural Resources and Community Development (NCDNRCD). Froa this
list, ten veils were selected to be sampled as part of the RI. This list vss
revised during this task depending upon the veil condition and whether or not
the contractor could get access to the veil* The fact that needs to be
considered is the depth of these wells in comparison to the elevation of the
Site and the disposal areas as well as other hydraulic barriers. _Soae of these
veils may be upgradient of the Site. ^ . v•'V /^ .
The reason the samples collected froa the private veils vere only analyzed for
the "fingerprint" chemicals during the Remedial Investigation (RI) was in an
attempt.to Identify chemicals that could be traced directly back to the
Chentronics Site. Other chemicals, such as the volatile organlcs (VOs), are
widely used by industry as well as homeowners* Therefore, if these
contaminants were found in a private veil, we would not be able to trace these
chemicals directly back to Chentronics. A recommendation made by the Agency
-------
for Toxic Substances and Disease Registry (ATSDR) in Jtheir Health Assessment
for the Chemtronics Site dated March 21, 1988 was to sample residential veils
for VOs as a precautionary measure. This vould help ensure that the drinking
water is not contaminated by any source. This will probably be implemented as
part of the remedial action. ... .; • ;. = "••;."'•'•. ..'•.;'...."•'. • ••''.'
By reviewing the surface water/sediment and groundwater data, one can see that
as you move away from the disposal areas* the concentration of contamination
decreases to eventually reaching below detection levels. Below detection level
means that the contaminant .is there but at a level that cannot be analytically
detected or the contaminant.is sot there in which case the level of
contamination is zero. ' - - « ' \:-
When you ask about the groundwater testing, I am assuming you are referring to
who performed the chemical analyses on the samples. All samples collected by
the PRPs* contractor were sent to IT Laboratories located in Knoxville,
Tennessee. EPA has a well established procedure of quality assurance/quality
control (QA/QC) for fabs used by PRPs. The prime goal of this QA/QC procedure
is to verify the analytical results generated by the lab hired by the PRPs.
The analytical data generated for the Cheatronics Site by the IT lab has been
accepted by the Agency. ' . - r "
With respect your concern about the blasting issue, EPA does not have
jurisdiction over this type of activity. It would be prudent, however, on
Cheatronlcs part to ensure that following the installation of the extraction
wells to remove contaminated groundwater during the remedial action, that they
take into account the effect, if any, the blasting could have on the geology
and hydrogeology of the area. If the blasting alters the groundwater regime in
this vicinity then they may be required to install additional extraction and
monitor wells to accommodate the change. ...
The existing groundwater monitoring will be reviewed for adequacy after the
extraction wells are located. This will be done as part of the Remedial Design
stage. More likely than not, all monitor wells will be located on-site as Tree
Bee Creek acts as a groundwater divide. The schedule for sampling as well as
what the samples will be analyzed for will also be designated in the design
phase. I am assuming, however, that volatile organlo as well as BZ and CS
will be analyzed for in samples collected from these wells. A review of the RI
analytical data will be used to make this determination.. The monitoring can
last up to 30 years and, if necessary, longer. ; r ' . . :
It is my understanding that the County or the State will sample a resident's
well if they have reason to believe it is contaminated. In any event, in their
Health Assessment for the Chemtronics Site issued on March 21, 1988, the Agency
for Toxic Substances arid Disease Registry (ATSDR), recommended that residential
wells be sampled and analyzed,for volatile organics. This recommendation will
be implemented. This is being performed only as a precautionary measure to
ensure that the drinking water is not contaminated by any source. This testing
of residential wells may be a one time occurrence or included in the long term
groundwater monitoring program for the Site. ... V . - .;:""'.
-------
It Is •? understanding vith regards Co burning activities en-site that
Cheatronles, Inc. has the necessary perait(s) from the State or County. As for
the sever discharge, this falls under the jurisdiction of the Metropolitan
Sever District. ' '.
All disposal of hazardous constituents f roa Industry since 1980 has been and
will reeain to be regulated by RCRA. Superfund is not interested in vhat
Cheatronlcs, Inc. is not presently producing as a business. This Information
is not needed for Superfund program to accomplish our goal.
As for your question 15, all this information is contained in the information
repository* • • "'• •• .' ''. '•••'... .-'' • /. ' -••--."• • ••'•• ' " • .-
" ---.-". f
If I can of be of further help, please do not hesitate to contact ae at
(404)347-7791. l . .: .
Sincerely yours, • •
Jon K.
Superfund Project Manager
4WD-SFB 4WD-SFB 4WD-SFB
BORNHOLM HANZE . GREEN
Jon Bornholm lelix DISK CHEMTRONICS, FILE CR , 4/26/88
, ,-•-'-. •
'••_ ;•/.- .•;•-••-"; ?i-
-------
fcWOT 03 1988
VD-S71 ... •- '• •?- '••'•:>••:•.-• .--: • ":'...-.- -'. • -•' • •'•'•'
• • v • ' • '• . "" ''.'•- tf. '--'•' "• .- '
DC* Wayne Montgomery, Tic* Chairman . °
Buncombe County Board of Commissioners
Aaheville City Hall
Aabevllle, HC 28805.
'•*-.' .. ' "• - • '
Dear Dr. Montgomery!
Thia correspondence ia in responae to your latter the Agency received on
April 19, 1988 after the public content period on the draft Feasibility Study
and the propoaed remedial alternative for the Chemtronics Superfund Site has
been cloaed.
* *
Aa you know, the original public consent period on the draft Feasibility Study
and EPA*a propoaed remedial action at the Chemtronica Site expired on March 18, -
1988. Later, the comment period vaa extended to April 1, 1988* The
community's deaire for the public consent period to be extended two months paat
the date the community receivea the Technical Assistance Grant (TAG) vaa
brought to the attention of Mr. Lee DeRihna, Acting Regional Administrator. It
vaa hia decialon to let atand the April 1, 1988 closing date for the public
comment period. Hia deciaion vaa baaed on the appraiaal that even if the
community vaa selected for auch a grant, ve estimated that It vould take
approximately eight montha to a year for the Agency to make the avard and for
you to procure a consultant and reviev the report the consultant develops. The
Agency, however, is mandated by Congress in the Superfund Amendments and
Reauthoricatlon Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delaya will impede the .
Agency's attempt to achieve thia goal. ~ '--.:.. . . ll
':••••-..'• • v.
SARA also encouragea the Agency to aelect permanent solutlona for the clean-up
at Superfund Sitea. After the Agency reviewed all the remedial technologies
identified in the draft Feasibility Study for addressing source control for the
contaminanta found in the disposal areaa containing drums, the only remedial .
alternative that achieves this goal is incineration. Off-aite incineration vas .
eliminated from consideration because it vaa estimated that it vould be more •- ..
cost effective to incinerate theae materials on-site. r ) V . . / ;\
• .•'<•••':•::.'-'>--.•••• •-: ..:.'•. •..•:...-•.'•.->>-• .„•• . . . : ..--•.''•' . ',• - / ' - -: »
Under ideal conditions with the incinerstor working as designed, the only ^ s
compounds that vould be entering the environment from the incinerator vould be
the ash/coil residue from the burnt soils and vater vapor and carbon dioxide \
out of the smoke stack* Therefore, virtually complete destruction of the.
contaminanta vould be achieved. •'"•:'•'•••£••' ' '
-------
-2-
This remedial alternative was not selected for several reasons. First snd
foremost, is the threat posed by live ordnance buried along with the drums to
the workers who would be Involved In the excavation of these drums in order to -
prepare them for incineration. The second issue considered was the potential
damage that this ordnance would have on the Incinerator Itself. If these
devices exploded inside the incinerator's chamber, it would be difficult to
predict the results. One possible scenario la the release of partially
destroyed contaminants into the environment. This coupled with the fact that •
the Asheville area is located ia part of the country that experiences frequent
air Inversions, would increase the potential to exposing the community to these
partially destroyed chemicals if a release, for any reason, occurred. And
thirdly, a great number of citizens voiced a negative response towards on-site
incineration both in the public meeting and during the public comment period.
This left the Agency with basically one other remedial alternative to address
source control for these disposal areas that would adequately protect the
public health and the environment and 'that was to place a cap over these
disposal areas. It was not advisable to follow a no action alternative since .
the contaminants disposed of in the majority of these disposal areas are
presently migrating with the groundwater from their disposal areas.
SARA also encourages the Agency to Implement a remedial alternative that
reduces the mobility, toxlclty and volume of hazardous waste at a Superfund
Site* The capping of the drum disposal areas along with the capping of the
acid pit area and the soil fixation/stabilization/solidification process for
disposal area 23 along with extracting and treating groundwater will meet these
criteria.~ The security fences to be installed around these capped areas will
help maintain the integrity of the caps by preventing unwanted Intruders
including man and animals alike, from damaging the cap.
In addition to the remedial activities stated above, a long term monitoring
systea will be instituted for the groundwater in both valleys and surface
water. This monitoring system will provide data that will be used to Indicate
whether or not the remedial action Implemented is working as designed.
If I can of be of further help, please do not hesitate to contact me at
(404)347-7791. ,- , . . .
Sincerely yours, ;. •' .,;. ,. . .... ..:'r >:"••.• '„'-'.'.••...-W.,':
' . .-• .••*••..'..•
.;'/"- • .-•-'.".'. •-•'.-' ... '•-..-..' ••-"
Jon K. Bornhollf** ; v , —
Superfund Project Manager /!•'.- -
4WD-SFB 4WD-SFB ' 4WD-SFB
BORNHOLM HANXE/" GREEK
Jon Bornholn/Telex DISK CHEMTRONICS, FILE ClU , 4/26/88
-------
March 30, 1988
Respectfully referred to:
Craig DeRemer
Director, Office of Congressional Liaison
Because of the desire of this office to be
responsive to all inquiries and comaunlcations,
your consideration of the attached is
requested. Your findings and views, in
duplicate fora, along vith return of the
enclosure, will be appreciated by
U.S.S.
Fora 12
n
402 Ob-teen Cffica Buiidinn
Washington, D.C. SQ51O
.
£202] 224^342
-------
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-i --V -.- -r
Bee Tree Community
Development Club
y&«&
r*sw
Mr. Jon Bornholm
Site Project Manager
U.S. EPA
Mrs. Marjorie G. Gashf Presidentr
Bee Tree Community Development^:
25 Summer Haven Road ** '
Swannanoa, fl.C. 28778
Mrs. Annie Mcllahon, President'**'%
Buckeye Cove Community Club -C*^?/v:
611 Christian Creek Hoad " ..Y'.'fX "
Swan/ianoa, N.C. 28778 . ... :,: ,,
March 17, 1908 . , " .", ':.".,;?=
Courtland Street, NE • . p,
Atlanta, Georgia, 30365 . •:'.''?-c]
- ':«*
t -"* * * '
Dear Mr. Bornholm: . ••. .; •••': •"•'
V.'e are writing about the Chemtronics Site investigation, the response ..:
period, the feasibility of "a Technical Assistance grant, and public- -
concern about EPA's proposals for the cleanup. •• :
Because we represent Community Development Clubs, we want to give you
some background information about the groups. Both clubs are incorpora-
ted as non-profit community clubs under N.C. statutes. We work with
the Buncombe County Community Development Council, the Western North-~.
Carolina Development Association, and Agricultural Extension. ,We also
are associated with Quality Forward and Beautifica.tion groups, "and :tthe
fj.C. Dept. of Transportation in Buncombe County. The Bee Tree Club."'!.::.: •
includes all families on Bee Tree Koad (from the Welcome sign to the'dani).
Long Branch, and Summer Haven Roads. The Buckeye Cove Club takes in-'. ;
Buckeye Cove Hoad, Old Buckeye Cove, \Vest Buckeye Cove, Buckeye Access,
Wilson Cove, Walnut Cove, Old Fellowship Road, Domeno Drive, and Ponder-
osa Drive (about 11 miles in all)* The Buckeye Club represents about 'j
215 families; Bee Tree has not taken a census but estimates that we--have ?
about 250 families in our club area* . . .-.^.-i.-.:c;;;.::•'•_.;V. '
' • • • * * " £ «*. • •—•* "* •
"^* - S f -. *» -~f_ *r ' ' ' '
People in these Community Clubs are very concerned about proposals'for ;.''
the Chentronics cleanup. The Community Clubs wish to apply for a Techni-
cal Assistance Grant* We have several other comments* . ...
First, the Swannanoa Valley people never asked for this problem of ,'"
hazardous waste which has literally been dumped on us* There are people
here who remember initial contacts made with landowners in the 1950s. ,:
The purposes and intent of the first company, Oerllkon Tool & Arms, was " :
misrepresented to those landovmors. Those people would never have soldt
their land if they had had any idea of the present outcome. It is im-
portant to make this point because you can't build trust on mistrust &
lies.
-------
3/17/OG, cont.
Secondly, there are people in our C0r*r*t/n>»e« j tf^» fee7/;-'fjU/r'fA<;r>«M
L-.ivesti£Ctiou j*f fl+vtJi. They feel that not. all hazardous'chemicals
ware tested for at some off-site areas," that:there vare'Comissiohs.iin'?^-
the study, and that test wells wore not'drilled in Ureas that «hould'*V.-;
have been tested. .> This is where an independent preview'-of «the?remedial'^
investigation could relieve much public concern"and mistrust^iyrhefii^t^
communities most directly impacted certainly hove a ^ri^ht ^to''kri6wfcthat>
extension is essential. After all, tha hazardous waste/pFoblenfiorit-that
site has been developing for 30 years or more. '.sTt is'tpresunptuouseto'^;
expect an intelligent answer on all actions for a .plean^up'^frcmT"""
communities on such
within a 30 day
to 3&5 days at best
Pool's Day. :,
Realistically, these rural communities would do veil to even'identify *^f;
end contact' the technical experts we need within thirty 'days—llet'-ialon
come up with any answers.1 Furthermore, the Feasibility £Study ih>roa 1
Just become available, and there has been virtually nor.publielty"bnj#/!§jj:
the grants for communities such as ours. The one announcement ;.tfie.;-wri*
.
heard about these grants was on public radio in December; lit ^Wis?Just'
heard by chance and because the radio happened to be on»'?- ^'r.^y^tXiU't'V
' '
While we wish to have an additional extension, we do not :want ;
the cleanup any longer than necessary because of on- going '->lc'achliis.'»5.;.\7e
need the extension to enable us to apply for and receive tone -of .it he. ^..4?*'
technical assistance grants which were mandated by -Congress and 'which v£
are available through your office. V/e understand that EPA has riot 'yet ^*-
released the guide lines for obtaining a grant '(the writer heard It hey p
were to be available in early March), The fact that these "guidelines *$
for application will not be released until after the deadline on\ the ^ii-j
public response period on the Chemtronica cleanup certainly presentsTa'^
problem for us. Our communities need to be reassured by having -our "'own
team of independent experts review all data from the initial. inyestigdt,
through EPA's proposed cleanup* .;,.. . •• -^ ... -;^;v f'''
' ' ' '
. - . ._ .
Accordingly, our fourth point is that i;e would like to "hear /from you^at
your earliest convenience on how to go about applying for a .technical j£?
assistance grant* . • . ' ' . . •'::-:.~-::% ' ''--^'-^.
Fifth, many valley residents feel that the decision making processes
of the investigation and cleanup ore not sufficiently tied to community
concerns. Related to this, we wish to state that the community' attitud
studies conducted by the Site Advisory Committee do not represent our
communities; those studies are based on quota samples arid cannot be use
for generalizations about our communities* Any good social scientist
will tell you that you need a representational sample for valid results
Some additional concerns that are expressed by valley residents are • J
that continued blasting will cause more fissures in underlying rock : -
and result in leaching at other unexplored areas; that too many
-------
3/17/88, p. 3
. . ... .... .
explosives are stored on the site adjacent to a growing7-pbpulatiqnv4aJ
that there are unidentified hazardous chemicals leaching into'Bee^Tre
Creek and possibly the Owen Park Lake (where people;fish).'?Furthermbre^
people are concerned about on—site inceneration andHhe-lengthyTperiodi
or time it would require. There' is concern that once"such^a ^largel^-
incinerator is brought into the valley it would be a'permanentxfixture
and burn forever. Even while writing this letter another 'concern'}prompted
a neighbor to call to say that fumes from materials dumped .into 'the >sewerJ
by chemtronics were rising through the water .traps in her three^baser
ment drains; there is a bad odor from this gas and she doesn*t'|knbvTif
it is harmful. She does not believe that Chemtronics is cooporating*t*
with the local people or with regulations on air pollution and SbtKer^
dumping. • - . :'• .::i;s'.r.y^^v-1-^.^;-^^^^
- "• • : : •• --"•• '.-.;;r' •r:-'f-*:^::-*\:^r>???••:&^^%
An additional concern related to the treating of ground water under;'/£iS£:V*c:
capped areas is two-fold. There should be a provision to supply water1?;"\£
to people whose wells might be affected by downdrawing ground water.i-:"")}'^
There has been no explanation given as to why Chemtronics could not v'vX^Cgl
use this "pure" water - it was estimated at Q$ gallons per minute--; :V7:"^;1!v^
in their manufacturing processes rather than dump it into Bee Tree Creek.;;)
It would certainly reassure the communities if they wo*d this treated.,i-.i^
"pure" water rather than just discharge it into the creek* . ,.- .£-.-;•iiaSiJ^fi
•' .-."'••••;•• •--;'—j.v/1/:R'-'^; :-™
-v .v.:i .• :-'i.-:'|:i;^.v*?
Sixth, because these are rural communities, many people will expresslh/i'V^
their concerns but will not take the time to write to the EPA»--r A -;few'^; %
of these people are former employees.who are afraid that their retirem
checks will be cut off if they take any action such as speaking up or
writing a letter* It is because we know that many concerned citizens
will not write, we are using petitions and form letters to let you know %;
that the people in the Swannanoa valley do care very much about the ..£•;.-.•••, ^'.
quality of life they will have in the future, they do care about the:^*v-.:v^
earth and the total environment, they do care about having the cleanup;^^
done properly and according to the best standards and latest technology,^
• and .they do care about being heard, " . •.-,.••/?^:^:*^^^|sj^^f
- . •'••^:-:'
Sincerely yoursj/^V^jfr^ •^^•"^
- '/• ^ ?•&&£&&&(<$&
Marjorie Gash «~Anriie";HcMahoh t
. • • • •».-•. .:*..•''••.&./i*.*•-Y'I--".^'*:'.-'.:^--'- '-s
••••'.-..*• •*"«v/'• tv« s?;—V-7 -'-:-":
... • • • . .'... _.- ..;•'*'.-£- a'^^vVav"-^?;;'!":-*>'.
cc: The Honorable Jesse Helms •-•••• • . ; 'ISst:^ ^. : ,v;
PO Box 29U4, Hickory, N.C. 28603 . . ;; -L'^^. r ^ .^
The Honorable Terry Sanford -' : "•-;•
73 Federal Bldg.; P.O. Box 2137
Asheville, N.C. 20Q02 . , •
Representative James McClure Clarke
14.314. Biltmore Dldg.. 1 Pack Square
Asheville, N.C. 26801
Governor James Martin
Office of the Governor
Raleigh, N. C . 27603
-------
APR25198* • "•;;,. .--'-..- -, • . ., • v'V; W J •;...'
4RA ''". • " '•• . ..-••" .- •""•'."'. .-' "•"- :-
The Honorable Jesse A. Helms
United States Senate "-
Washington, D.C. 20510 ' V? V
Dear Senator Helms t "'" •. "_
This is in response to your inquiry of March 30, 1988 in which you referred a
copy of a letter from the Bee Tree-Community Development Club concerning the
Chemtronics Superfund Site in Swannanoa, North Carolina which also was received
by the Agency during -the public comment period. V .
Enclosed is a copy of the Agency's response from Project Manager
Mr. Jon Bornholm to this letter from the Bee Tree Community Development
Club. - -.,. ' -'. ...-•-•• -..-'.•:.;••.,-. .
Please be assured that we are doing everything possible to insure a timely
clean-up which will be protective of all aspects of human health and the
environment. , , "--
If I may be of further assistance, please do not hesitate .to contact me.
Sincerely yours,
i - :..;.••-,:•-' '. .'..
« . '.-.-. .-••':. '•••:.-... • .
- • . '• • -.••.-... .'-.i, - -••' • . ••;•. • ^..--j.- • : •
Creer C. Tidvell
Regional Administrator
• Enclosure (. - ;• " ......^ J*'.:... "~ --• ..'.._.. •:..„••
Bornholm IBM DISK CHEMTRONICS, FILE flS-CONG, 4/19/88 :l -
4WD-SFB "4WD^S.FB 4WD-SFB 4WD-SFB': \ 4WD 4PAB 4RA
BORNHOLM HANKE/ GREEN' .STOl^BRAKER TOBIN THOMPSON
-------
APR *i 1988 - •''"'. ••-:•• •=-.•-.-•
4WD-SFB
Mrs* Annie HcMahon, President
Buckeye Cove Community Club
611 Christian Creek load
Svannanoa, NC 28778 ' •"
Dear He. McMahon:
This letter is in response to yoar letter received by the Agency on March 21,
1988 with regards to coaaents on the draft Feasibility Study and the proposed
remedial alternative lor the Chemtronics Superfund Site*
As you know, the original public coaaent period of the draft Feasibility Study
and EPA*s proposed reaedial action at the Cheatronics Site expired on March 18,
1988. Later, the coaaent period «a« extended t» April 1, 1988* The
community's desire for the public consent period to be extended two aonths past
the date the community receives O3ie Technical Assistance Grant (TAG) vaa
brought to the attention of Mr. Lee DeHihns, Acting Regional Adalnistrstor. It
was his decision to let stand the April 1, 1988 closing date for the public
comment period* His decision vas based on the appraisal that even if the
community were selected for suck A .gxAnt. we estimated that it would take
approximately eight months to a ywi for t&e Agency to aake the award and for
you to procure a consultant and review the report the .consultant develops. The
Agency, however, is aandated by Congress in the Superfund Amendments and
Reauthorization Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 And any untimely delays will impede the
Agency's attempt to achieve this foal*
The Agency is not discouraging you from applying for a TAG but please be
advised that the Record of Decision (ROD) for the, Chemtronics Site was signed
April 5, 1988. The ROD is the decision document in which the Agency states the
reoedial action to be implemented at a Superfund Site* If a TAG is applied for
and awarded now, the grant the community receives would be spent on reviewing
the remedial design* I have passed your' request on to Ms. Pat Zweig who is in
charge of overseeing the TAG program in Region IV* Any future correspondence
with regards to TAGs should be directed to her attention. Her telephone number
is (404)347-2643. :;.-•'•'V.^.'V'.-..'.-'• / '
Please be advised that the Site Advisory Committee is • committee devised by
the Potential Responsible Parties* .(PRPs) for conducting community relations
activities and is not the Agency's committee. The majority of the inforaation
the Agency disseminated to the public was through either fact sheets or public
meetings. The Agency has also established three inforaation repositories were
all pertinent documents pertaining to the Cheatronics Site are located.
-------
• -2- -...:.
As^for the additional coneerne expressed by the valleyresidents, EPA has no
Jurisdiction'over'either the storage or detonation of explosives on-site. It
would be pnident» however, on Chemtronics, Inc. part to ensure that
follovingthe installation of the groundvster extraction veils during the
remedial action stage, that the coapany take .into account the effect, if any,
.the blasting could have on the geology and hydrogeology underlying the Site. '
If the blasting alters the groundvater regime of the area then they vill be
required to install additional extraction and monitor veils to accommodate the
1 change. ' '.>-'• •' ". • . ' ' •••'.'"•''' • ...--.
•i:'.-.>V :'.:'.;"-- ' •' -'I- •/••;: •'••-' ' - •" •'..
Your comment concerning Cheatrpnics, Inc. using the treated groundvater as
their source for production vater is a good idea and I vill pass this idea on
to the consultant hired to design the reoedial action. The one immediate
drawback'to this approach I see is the need for Cheatronics to build a -
containment structure.to hold the treated vater vhen there is little or no
demand'for-the treated vater. The cost of constructing this holding facility
versus the cost of obtaining a NPDES pernit to discharge the treated vater to a
surface stream or the aonthly expense of discharging to the sever system needs
to be compared. Since each if these three alternatives are equivalent in terms
of treatment and discharge, the most cost effective alternative vould probably •
be implemented. ;.
The Agency appreciates your cements and if I can be of further help, please do
not hesitate to contact me at (404)347-7791.
Sincerely yours, . ..-;"•• .
"Jon K. Bomholm
Superfund Project Manager
v^";;^v> 'J^^f- s^^^h-/• '--^ ••-:•:';
•" IBM DISK CHEMTRONICS CR, FILE CR13, 4/20/88
4WD-SFB .-4WD-SFB
BORNHOLM .
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTUANO .STREET
ATLANTA. GEORGIA 3038!
4WD-SFB
Mrs. Majorie Gasa, President
Bee Tree Community Development Club
25 Summer Haven Road
Swannanoa, NC 28778
Dear Ms. Gash:
This letter is in response to your letter received by the Agency on March 21,
1988 with regards to comments on the draft Feasibility Study and the proposed
remedial alternative for the Chemtronics Superfund Site.
As you know, the original public comment period of the draft Feasibility Study
and EPA's proposed remedial action at the Chemtronics Site expired on March 18,
1988. Later, the comment period was extended to April 1, 1988. The
community's desire for the public comment period to be extended two months past
the date the community receives the Technical Assistance Grant (TAG) was
brought to the attention of Mr. Lee DeHihns, Acting Regional Administrator. It
was his decision to let stand the April 1, 1988 closing date for the public
comment period. His decision was based on the appraisal that even if the
community were selected for such a grant, we estimated that it would take
approximately eight months to a year for the Agency to make the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is mandated by Congress in the Superfund Amendments and
Reauthorization Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delays will impede the
Agency's attempt to achieve this goal.
The Agency is not discouraging you from applying for -a TAG but please be
advised that the Record of Decision (ROD) for the Chemtronics Site was signed
April 5, 1988. The ROD ia the decision document in which the Agency states the
remedial action to be implemented at a Superfund Site. If a TAG is applied for
and awarded now, the grant the community receives would be spent on reviewing
the remedial design. I have passed your request on to Ms. Pat Zweig who is in
charge of overseeing the TAG program In Region IV. Any future correspondence
with regards to TAGs should be directed to her attention. Her telephone number
is (404)347-2643.
Please be advised that the Site Advisory Committee is a committee devised by
the Potential Responsible Parties' (PRPs) for conducting community relations
activities and is not the Agency's committee. The majority of the information
the Agency disseminated to the public was through either fact sheets or public
meetings. The Agency has also established three information repositories were
all pertinent documents pertaining to the Chemtronics Site are located.
-------
-2-
As for the additional concerns expressed by the valley residents, EPA has no
jurisdiction over either the storage or detonation of explosives on-site. It
would be prudent, however, on Chemtronics, Inc. part to ensure that following
the installation of the groundwater extraction wells during the remedial action
stage, that the company take into account the effect, if any, the blasting
could have on the geology and hydrogeology underlying the Site. If the
blasting alters the groundwater regime of the area then they will be required
to install additional extraction and monitor wells to accommodate the change.
Your comment concerning Chemtronics, Inc. using the treated groundwater as
their source for production water is a good idea and I will pass this idea on
to the consultant hired to design the remedial action. The one immediate
drawback to this approach I see is the need for Chemtronics- to build a
containment structure to hold the treated water when there is little or no
demand for the treated water. The cost of constructing this holding facility
versus the cost of obtaining a NPDES permit to discharge the treated water to a
surface stream or the monthly expense of discharging to the sewer system needs
to be compared. Since each if these three alternatives are equivalent in Cerms
of treatment and discharge, the most cost effective alternative would probably.
be implemented.
The Agency appreciates your comments and if I can be of further help, please do
not hesitate to contact me at (404)347-7791.
Sincerely yours,
-7
Ton K. Bornholm
Superfund Project Manager
-------
7
April 18, 1988 ^
' • ' . A*
Respectfully referred to:
Craig DeRemer
Director/ Office of Congressional Liaison
Equal Employment Opportunity Commission j
Because of the desire of this office to be
responsive to all inquiries and communications,'
your consideration of the attached is
requested. Your findings and views, in
duplicate fora, along with return of the
enclosure, will be appreciated by
U.S.S.
Wayne Boytes
Washington, D.C. 2051O
(202J 224-6342
-------
1
^- • ;"• - " - * •".'-. 1 - • « •
.HONORABLE JESSE. A.;H£L« -M ••^.'.'ll.:. . '.; ,.
SUBJECT AND DATE . . ..-...-.•-•;... ,-
*&vV;-<- •"•^•^'^••-^: (n)l
: CLEANUP/CHEKTRONICS SUPERFUND SITE UJ
i?:.i^;:'»- :•'..'• .'"• '• ••- • ... • , -•• ' .:. • fl
^'^•vi-;:;,'.;.:;^.-\-V^:;; UUl
.' . -, .'. . • t. : ._ • ' t • - • ..»."_• - ^. . . . - — • - ....
P^KFWW^^S i^I • • • . "- (i) '. ••*"."
ol® r:; ^ .v-U.;..; y-fci fas i •'. -.
REPLY SENT TO ..-••. . . . ''..'.. '...' . .,•• .-'. . :' .• . .
i' •'•""-{vvL; "'.' •
" ' \ . . •'•^"' *\ 4- • ' i
" ' ' A • . ••"•••.:• • . . ,N ** :. v.*
[?r?L^fif|7t?(n[y--
APR 211388
, ATLANTA. QA' ••-^-i ••-•-*••'-
iiAC/C to/^/K^^
:'i 'yfitf^j3£::.
•-;;; '. ;v •/ -v-;-' .•:-'rrc-v: •.
REMARKS • - - ' •
PREPARE REPLY FOR RA'S SIGNATURE. PLEASE FORWARD THRU. <'
-CONGRESSIONAL AFFAIRS BEFORE * AFTER .RA'S SIGNATURE. .' .^ .
^ATTACH 3 WHITE CARBON COPIES ^N ADDITION TO ANY OTHER . ^
: COPIES REQUIRED. ATTACH NECESSARY ENVELOPES FOR HAILING. -_:-:. '__
• ,:!>' '.'-r .'.'..•'; • •.-• _..'• ;...'..'' ' '-•'•' . "
' '.- :..:/:''
CONTROL NO.
-AL881695
DATEREC'D . .
; 4/26/88
OUK DATE
"5/2/88 :
; J^OcI ^Itev
^iii': •;::.:..........:
DATE RELEASED .
ACKNOWLEDGED • DATE
D -..':
NO ANSWER NEEDED
D (Expltin in remarks)
'.-•-.
*~ >;
.EPA Form 5180-1 (6-72) .
.REPLACES FWPCA FORM 72 AND
J4EW-73 WHICH MAY NOT BE USED.
».5..-.:.' ..-. .: • ..- •'.
(Remove this copy only, do not sep»r»te remtinder.)
MAIL CONTROL SCHEDULE
-------
APR 29 1988
4BA ; . .:•;•..- ."•••.•.;•-.- .;••/-•.-.
The Honorable Jess* A. Bali
United States Senate . ,
Washington, D.C. 20510 ,.
Dear Senator Reims I/*'• •-.;'-'^ •",". ':"' •' ... .,•'.< ••.'•" ' - "..'•,
This is in response to your inquiry of April 18, 1988 in which you referred a
copy of a letter from Ms* Millie Buchanan concerning the Chemtronics Superfund
Site In Swannanoa, North Carolina which also was received by the Agency during
the public comment period.
Enclosed is a copy of the Agency's response from Project Manager
Mr. Jon Bornhola to this letter fron Ma. Millie Buchanan.
Please be assured that ve are doing everything possible to insure a tiaely
clean-up which will be protective of all aspects of human health and the
environment* . =
If I may be of further assistance, please do not hesitate to contact me.
Sincerely yours, '. ' .
.
Deputy Regional Administrator ,
Greerc. Tidwell '"" ' ''"I : ..•"...'-'.•"•.' ' .•
Regional Administrator - ,....,
Enclosure •••....• ..;-' •.-.... .;.- ' . • -. '•''.-
. _ _
Bornholm IBM DISK CHEMTRONICS, PILE 1-CpNG^ 4/27/88 .:: i
4WD-SFB 4WD-SFB 4WD-SPB 4WD-SFB : r " • 4i«) 4PAB >- " 4RA
BORNHOLM HANKE GREEN SIONEBRAKEK TOBIN THOMPSON TIDWELL
•• -..-.• . .
-------
Clean Water Fund
f North Carolina
KM UID «s 13S E* Chestnut St.
. JJOOJUK-30 AH I0: OS Asheville, HC 28801
March 25, 1988
Senator Jesse Helms
4O3 Dirksen Senate Office Building
Washington, DC 2OS10
Dear Senator Helms:
Your constituents in the Swannanoa community need your help.
The Environmental Protection Agency is now deciding on the
technology and standards for the Chemtronics
site in their community. Under the ground at
Chemtronics are a mixture of chemicals, dumped there over a
period of decades by several industries. The mix includes
the warfare agents BZ (a hallucinogen) and CS (a nerve gas),
and an unknown amount of still-active explosive materials,
as well as the more usual mix of organics and metals found
at most hazardous waste sites.
The reauthorization of Superfund in October 1986 mandated
that communities have access to Technical Assistance Grants
to hire their own consultants to help them understand the
cleanup options and have a part in decisions that will
directly affect their health and their environment. Despite
that mandate 17 months ago, it was not until this week that
EPA issued guidelines for applying for the grants (Federal
Register, March 24). The neighbors of Chemtronics plan to
apply for- thg granta ao they can understand the process and
help In making the tough decisions necessary, but the public
comment period is now scheduled to end April 1. Obviously,
the community must have more time.
Please use your influence on behalf of the Swannanoa
community to urge EPA to extend the comment period and delay
decisions on cleanup options until residents have access to
technical assistance and time to take advantage of it.
Thank you for any help you can provide.
Sincerely, •
Millie Buchanan
Director, WNC Office
-------
Clean Water Fund
Of North Carolina
138 E. Chestnut St.
Ashevllle, NC 28601
March 25, 1988
Mr. Jon K. Bornholm ..-••••-
Site Project Manager •• •
U.S. EPA Region IV
345 Courtland Street NE
Atlanta, GA 3O36S
Dear Mr. Bornholns
i ' . .
Thank you for extending the public comment period on the
Chemtronics Draft Feasibility Study until April 1. As you heard
during the February 23 meeting, community residents vant to
become meaningfully involved in cleanup decisions, but feel that
to this point they have been excluded. The prompt response of
EPA to their request for an extension vas, I hope, the first step
in a process that can lead to cleanup decisions that everyone can »
feel good about.
The second step vas taken Monday night by the Chemtronics Site
Advisory Board, when it acknowledged the need for community input
into its decisions by scheduling its own meeting April 11 to hear
community concerns. That board, which vas to .serve as the bridge
between the company and the community, has in fact had minimal
contact vith the neighbors vho will be most immediately affected
by the quality of the cleanup.
The issuance March 24 of the Interim Final Regulations for
Technical Assistance Grants opens further the door of opportunity
for true, informed community Involvement. I understand you have
already received a letter from the Bee Tree and Buckeye Cove
Community Development Clubs expressing interest in applying for
technical assistance money, and other neighbors concerned about
cleanup decisions have expressed support for their proposal.
However, in order to take advantage of the grants, the community
vill obviously need more time than the current April 1 deadline
allows.
The Clean Water Fund of North Carolina supports community
requests for • further extension of the public comment period,
and a delay of any decision on cleanup options. The opportunity
of a Superfund community to get its own expertise is mandated by
the Superfund Amendments and Reauthorizatlon Act. That
opportunity Is also essential if residents are to perceive that
the cleanup options chosen are the ones most appropriate for and
protective of the community.
-------
page 2
Our organization has already obtained a promise of a preliminary
review pro bono by a scientist familiar vith Superfund cleanups,
but the April 1 deadline does not allow time for an adequate
review, given his other commitments. Since the TAG regulations
are now available, this review can serve as an outline for more
complete analysis should the community obtain a grant. We i
therefore request that the comment period be extended until at
least SO days fallowing the receipt of a Technical Assistance
Grant for the community. Sixty days is a tight schedule for
hiring consultants, obtaining a technical review, and making
comments based on that review; however, we are cognizant of the
need for remediation to begin without undue delay to avoid
further potential for offslte leaching.
In addition, we reiterate here the points raised in Clean Water
Fund comments on the Remedial Investigation (dated April 1O,
1987). Particularly, we shared then the concerns of EPA's own
reviewers about the sufficiency of testing and Investigation to
support cleanup decisions, and those concerns are still valid.
They were addressed by changing the wording In the final RI
report to indicate that conclusions are based on Incomplete
information, but the issue of what additional testing needs to be
done remains. We question the adequacy of the investigation of
offslte dumps and the minimal sampling of nearby private wells.
In addition, we object strongly to the continued proposal to use
standards less protective of human health than the Maximum
Contaminant Level Goals mandated by SARA Section 121 (d)(2)(A).
Standards for evaluating air and water quality during the cleanup
also need to be addressed, particularly if the chosen options
Include incineration and/or air stripping.
_ , •
The SARA mandate for permanent cleanup options also points to the
need for solutions beyond the .capping proposal being considered
for much of the site. Any material left onsite now due to lack
of an appropriate treatment method should not only, be thoroughly
monitored for the lifetime of any hazard it poses to the
community or the environment, but also reevaluated periodically
in light of new technology. Any consent order should Include
provisions for treatment at a later date should appropriate
permanent remedies be available.
Lastly, I have heard several residents comment favorably on your
personal willingness to respond to their calls. That type of
responsiveness will help considerably as hard decisions must be
made during the next few months, and I thank you for it.
Millie Buchanan
Director, Western NC Office
cc: Congressman James McClure Clarke
Senator Terry Sanford
(^Senator Jesse Helms
-------
1888
WD-SFB
Ms. Millie Buchanan
Clean Water Fund
138 E. Chestnut St.
Asheville, NC 28801
Dear Ma. Buchanan:
This letter is in response to your letter the Agency received on March 28, 1988
with regards to coeaenta on the draft Feasibility Study and the proposed
remedial alternative for the Cheotronics Superfund Site.
As you know, the original public comment period on the draft Feasibility Study
and EPA's proposed remedial action at the Chemtronics Site expired on March 18,
1988. Later, the comment period was extended.to April 1, 1988. The
community's desire for the public comment period to be extended tvo months past
the date the community receives the Technical Assistance Grant (TAC) was
brought to the attention of Mr. Lee DeHihns, Acting Regional Administrator. It
vas his decision to let stand the April 1, 1988 closing date for the public
comment period. Bis decision vas based on the appraisal that even if the
community vas selected for such a grant, ve estimated that it vould take
approximately eight months to a year for the Agency to make the award and for
you to procure a consultant and review the report the consultant develops. The
Agency, however, is mandated by Congress in the Superfund Amendments and
Reauthorization Act of 1986 (SARA) to have cleanup activities underway at 175
Superfund Sites by October 1989 and any untimely delays will impede the
Agency's attempt to achieve this goal*
SARA also encourages the Agency to select permanent solutions for the clean-up
at Superfund Sites* After the Agency reviewed all the remedial technologies
identified in the draft Feasibility Study for addressing source control for the
contaminants found in the disposal areas containing drums, the only remedial
alternative that achieves this goal is incineration. Off-site incineration vas
eliminated froa consideration because it vas estimated that it vould be more
cost effective to incinerate these materials on-site.
Under ideal conditions with the incinerator working as it was designed, the
only compounds that would be entering the environment from the incinerator
vould be the ash/soil residue from the burnt soils and water vapor and carbon
dioxide out of the smoke stack. Therefore, virtually complete destruction of
the contaminants vould be achieved.
-------
-2-
This remedial alternative vaa not selected for several reasons. ,First and
foremost, is the threat posed by live ordnance buried along with the drama to
the workers who would be involved in the excavation of these drums in order to
prepare them for incineration. The second issue considered was the potential
damage that this ordnance would have on the incinerator itself. .If these
devices exploded inside the incinerator's chamber, it would be difficult to
predict the results. One possible scenario is the release of partially
destroyed contaminants into the environment. This coupled with the fact that
the Asheville area is located in part of the country that experiences frequent
air inversions, would Increase the potential to exposing the community to these
partially destroyed chemicals if a release, for any reason, occurred. And
thirdly, a great number of citizens voiced a negative response towards cm-site
incineration both in the public meeting and during the public comment period.
i
This left the Agency with basically one other remedial alternative to address
source control for these disposal areas that would adequately protect the
public and the environment and that was to place a cap over these disposal
areas. It was not advisable to follow a no action alternative since the
contaminants disposed of in the majority of these disposal areas are presently
migrating with the groundwater from their disposal areas.
SABA also encourages the Agency to implement a remedial alternative that
reduces the mobility, toxicity and volume of hazardous waste at a Superfund
Site. The capping of the drum disposal areas along with the capping of the
acid pit area and the soil fixation/stabilization/solidification process for
disposal area 23 along with extracting and treating groundwater will meet these
criteria. The security fences to be installed around these capped areas will
help maintain the integrity of the caps by preventing unwanted intruders
Including man and animals alike, from damaging the cap.
In addition to the remedial activities stated above, a long term monitoring
program will be Instituted for both the groundwater and surface water. . This
monitoring system will provide data that will be used to indicate 'whether or
not the remedial action implemented is working as designed* .
-••"•••
i . ".=
As required by SARA, the remedy identified above will meet all applicable or
relevant and appropriate requirements (ARARs) that have been promulgated and
enforceable. With respect to the second paragraph of the second page, it was
never stated by EPA that there was insufficient testing/data to support cleanup
decisions. What was stated by the Agency in the referenced document, the RI
report, is that there was insufficient data to support some of the conclusions
made by the authors. These conclusions were subsequently modified in
reiterations of the RI to acknowledge this fact*
If I can of be of further help, please do not hesitate to contact ae at
(404)347-7791.
Sincerely yours,
Jon K. Bornholm
Superfund Project Manager
-------
SUBJECT: Response to the Letter Mr. J. Patrick Price Sent to Lee Thomas
Regarding the Cnemtronlcs Superfund Site ..••~-^.*-('-1- ••'•'• ; . ••
.•-. :V-.".,'H:-:'.^V/:.;--- " '-'- --..
;-. /;. .r... TO: Patrick M.'Tobln, Director"v^--:'^;/;!•:•..;>;_•,»*• v---y'Ji"'?-'£'.\'''£-'-t'---*'^:'."':"--'-.
-:,':^-.iu.-'; -':-;-.\• v -*61'5** .Management Division';-./,rti" •^•^^^•^^^•^^•^'•^:'t-^i-\^^'^
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FROM: Jon Bornholm, Super fund Project Manager
"' '
... -__. .. .^- -. , ..„.. - .
;.;.j-;:.v;:;;;W.>: -y;">::V •. •-*-"-'••- V- '•"-.' • ••-••• --V .-.;-.; ••;.•?"-••:. • ."^l.:"*.*'^/ ..'-' " ^..^v.^".:;.^: v V
v :vi- -r THRU:.- Al jianke/ Chief V .-•- '*'"^:L;.;v^' ~'V^ '••*£•£ ,;-5:^' " .. • -'•V-'^^:j*..--l"j>t'^-?'.'
'.: ^ .••;'->- .;NC/SC-.Site Management Oait '.';->.- '"'•" .">' ; ••;!.;.':..• .... ::; ' .-•.'/.-.-V' .'?.'• V
'Richard Green, Chief
North Site Management Section ,
I .*-••. -. • ' . . . *....-.- _ . - •_ .-. ' -
'response.'to"':the pfil
'.*<'•'. Patrick Price, 'Chaifaan of .the Chemtronica Site Ccnxnunity Advisory Board ^?
'-^CSOfijT/'addressed'tb Mr.' Lee M. ThomaaV:EPA Adoainistfator^'.The"^^:^•••'#?
" 'men±?ership of the CSCAB is supposedly comprised of individuals with
various backgrounds including citizens, cotmunity interest groups, public
officials, and economic interest groups from the Asheville/Swannanoa :.
. area. These individuals were initially invited by the PRPs to join and.-. ..
: "form the Board. Si nee "then,'it: has been the'Board*s responsibility to"*'
maintain its membership which, from my understanding, has been a difficult
task due to the relative high rate of turnover. The formation of the
CSCAB was a task included in the Coranunity Relations Plan (CRP) developed
by the PRPs for the Chemtronics Superfund Site located in Swannanoa, North
Carolina. The purpose of the Board, as defined in the PRPs CPP, is to act
as a sounding board for the community's concerns and issues.
In addition to the formation'of the CSCAB, the PRPs CRP also called for
the establishment of their own information repository which is referred to
as the Chantronics Site Information Bureau (CSIB). The CSIB and C5CA3
work tocsther in releasing information to the public. On*' ' •--••• «cr>e
of the information they have released is tainted to painc a rosier picture
of tlie Site than that which actually exists.' The community is very
sersitiv? to this issue.
-------
The CSCAB has compounded some of the situations that Mr. Price has
.-.icr.iii.;.-^;" in his letter iy conveying to thi co7r-.ur.ity at lz.r-:c ih~t the
C3CAS is LP.Vs direct link to the comcunity. Tnis misnomer was brought to
niy attention through a recent telephone conversation I had with a
professor irom a local college. Trie main reason the professor called was
to ask me if EPA had sanctioned the CSCAB and the information it and the
CSIB was disseminating. My response was no. Below are two quotes taken
from letters from several community leaders in the Swannanoa area received
during the public cement period. The first quote is from the presidents
of the Bee Tree Community Development Club and the Buckeye Cove Coranunity
Club. They state "...we wish to state that the connunity attitude studies
conducted by the Site Advisory Comu'ttee do not represent our communities;
those studies are based on quota samples and cannot be used for
generalization about our comnunities...*. The second quote is from the
Garments submitted by the North Carolina Clean Water Fund representative
where she is referring to the desire of the local residents to
meaningfully involved in the cleanup decision.* She" states "The'secbria-V" r
step was taken by the Chemtronics Site Advisory Board, when it '. :"
acknowledged the need for community input into its decisions by scheduling
its own meeting April 11 to hear cortnunity concerns. That Board/,which •
was to serve as the bridge between the ccnpany and,.thev"community, ''oas.itf:.,^.':
fact, had.'minimal contact with' the neighbors; wh^.will b^^TOSt^im^iediabBiy ^
affected by the Equality of tlie cleanup...".'; Thieve .twb'quptes clearly^r.j^t;
indicate'that the CSCAB does not have as clear a handle on the situation''c-
as Mr. Price makes it appear in his letter.. It should also be noted that7
. none of the comments received by the Agency' during the "publicto«nnent^-:: - :-
period either praised .or coranended the CSCAB for lt's;comu^ty^i^;^
.representation efforts': • As.identifled above, 'severar individuals question-
the CSCAB's motives;^;"; •"'•'': '•**'•' ^T'1-'^'- ~:;;;->'v.; '•V^-^'^*:.'^:/"^''^r!;0;""^^
The majority of the comunity's mistrust stems from the fact that the PRPs
and their contractor have conducted the RI/FS; This mistrust surfaced: ;
.back in 1985 when the Agency. firs€ held some infonnal public meetings f. --c"
during the development of the Chemtronics work plan. At tiiis time, tie r;
public was informed that the PRPs may be performing the work themselves.
-The general feeling of the individuals who attended these meetings was T.
rthat. the Agency was going to let the fox guard the hen house, i Ever since>•
'• then the Agency'fiair^nad to expend extra effort to help 1aubstantiajte^.r-r'•'?'•.•]
credibility for the.work performed by.the PRFs at.the Cheratrohics Site. *r
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
343 COURTLANO STREET
ATLANTA. GEORGIA 3036S
MAY S 1988
4WD
Mr. 3. Patrick Price, Chairman
Chemtronics Site Community Advisory Board
P.O. Box 18177
Asheville, NC 28814
Dear Mr. Price:
I would like to take this opportunity to respond to your April 1, 1988 letter
addressed to Mr. Lee Thomas, EPA Administrator, regarding the Agency's
community relations activities in the Asheville/Swannanoa area in conjunction
with the Chemtronics Superfund Site.
The Agency has a very difficult task when it comes to addressing a community's
concerns associated with a Superfund site. First, the Agency is placed in an
awkward position first to explain why industry was allowed to dispose of
chemicals in the manner that the Chemtronics potentially responsible parties
did and second, to explain what is the health risk posed by the disposed
materials. It is easy to say "that was the accepted method of disposal back
then" but this does very little to reduce the fears of the community. One of
the greatest fears a community has associated with a Superfund Site is the risk
or potential risk that the Site poses toward a local citizen's health. It is
difficult to explain the health risk or potential health risk associated with a
site in terms of numbers. One of the most common risk factors used is 10"
or one in one million. First of all, one million is a large number making it
difficult for people to visualize and secondly, this risk factor becomes nearly
impossible to accept if you are one of the residents living adjacent to the
site and that one in a million could be you or a member of your family. In
these instanc3S, any risk factcr greater than zero is too high. EPA is very
sensitive to these and other issues associated with Superfund sites.
In reviewing the history of the Chemtronics facility, dating back to its
inception as an industrial plant, a fact was revealed which has compounded the
community relations problems for both the Agency as wall as for the PRPs.
Apparently, the community had absolutely no idea that either BZ or CS was being
manufactured at the Site until EPA made it public knowledge during the
development of the Remedial Investigation/Feasibility Study work plan. This
fact alona generated a significant amount of news madia intarest in the
Chentr^ -.L~3 31 is. Sinca tlicj.2 cc.r..:oi:r..:5 va_r= r.i••.uljici.ic*! specifically for the
U. S. Government (i.e., the Department of Defsr.sa)/ the Agency is even more
ser.siti-.-= £3 this issue.
-------
-2-
Zt is difficult for EPA to disseminate the massive amounts of information
generated from activities conducted at a Super fund project. The task becomes
even more complicated when you consider the diverse backgrounds of the
residents living in the Asheville/Swannanoa area. It is difficult to relate
very technical issues and/or concepts to the community at large. In an attempt
to accomplish this goal, the information on the technical issues and
considerations were drawn out with sufficient verbiage as to provide everybody
an opportunity to understand them. This approach, unfortunately/ has a
drawback which you alluded to in your letter and that is it makes it difficult
to get to the "meat" of the situation. But given the complexity of the
Chemtronics Site, it was inevitable that a certain percentage of the community
would not be able to assimilate all the information reviewed during the
February 28, 1988 public meeting.
This confusion is compounded by the fact that each newspaper that services the
Asheville/Swannanoa area has published their own understanding of the problems
associated with the Site and what the actual remedial cleanup would entail and
accomplish. This occurred even after the Agency had disseminated this
information to the news media in Fact Sheets.
Region IV has conducted significantly more community relations activities at
the Chemtronics Site than are generally performed at other Superfund sites.
From the tone of your letter it appears that this was not enough. At the sane
time, I am troubled why you did not state these questions/concerns you alluded
to in the Chemtronics Site Community Advisory Board March 28, 1988 letter the
Agency received during the public comment period. Without receiving these
specific questions/concerns from the community, it is difficult for the Agency
to respond to the community.
In the near future, the Agency will respond to the majority of correspondence
we received during the public comment period. Over eighty percent of the
comments we received requested a delay in the issuance of the Record of
Decision until two months after the community received a Technical Assistance
Grant. Unfortunately, the Agency could not honor this request. It was our
appraisal that this would result in an eight month to one year delay in" the
project which was deemed unacceptable for implementing cleanup activities at
the Site.
If I can be of further assistance, please do not hesitate to contact me.
Sincerely yours,
Patrick M. Tobi-
Wasts Man.- ' :.-i oiractsr
-------
April 1, 1988
Mr. Lee N. Thomas
Administrator
United States Environmental Protection Agency
Room W1200
401 M Street SW
Washington, DC 20460
Dear Mr. Thomas:
In a recent meeting of the Chemtronics Site Community Advisory Board, a
very serious problem emerged. It is a problem which has tremendous
impact on every decision and action related to the Site. Simply stated,
EPA has not effectively communicated with the Community and the public.
The CSCAB has and is supplied with all pertinent information relating to
the RI/FS, most of which has been read by or reviewed for the members.
In addition, the Board has been advised and counselled by Sirrine
Environmental Consultants and the PRP's. Even with this constant flow
of information, there are numerous unanswered questions in the minds of
the members regarding the EPA's remedial alternatives.
If the Board, with its myriad of resources, still has questions, imagine
how many more questions remain unanswered in the minds of the community
who has been exposed to a fraction of that information.
Under the Community Relations Program, implemented by the Chemtronics
Site Information Bureau and Visual Imagry, an incredible volume of
information has been disseminated to the public and the media:
Newsletters, press briefings, public meetings, media releases, fact
sheets, background sheets, technical papers, videotapes, slide films and
other documents have been employed. This entire program has been funded
by.the PRP's. In addition, the EPA has been and is provided with all of
the resources of the Community Relations Program.
It is the consensus of the CSCAP that the weak link in gaining the
confidence and trust of the public regarding the FS is the EPA. The
individuals and audio visual techniques used at both public meetings
were very weak and almost amateurish. Presenters failed to deal with
the "meat" of the recommendations in a credible manner. There was
little supporting material that would help the audience understand these
highly complex subjects. The only supplemental material supplied to the
public was that created and supplied by the Chemtronics Site Information
Bureau.
Beyond the public meetings, there has been virtually no communication
between the EPA and the community or region. According to independent
research conducted in the Fall of 1987, the EPA has a very low
credibility witu the community. We believe the reason is evident.
-------
It is the EPA which will issue the ROD, the final decision on what
remedial actions will be taken. If the EPA lacks credibility, every
finding, every recommendation, and all involved parties will also lack
credibility. Without it, there will never be peace of mind in the
community.
The Board feels that PRP's and their contractors have done a very
reliable and credible job on the RI/FS. Now it is critical that the
public understand the validity of the findings and the reliability of
the recommendations. This can be accomplished only with a very
intensive, cooperative community information program mounted by the
EPA. We are assured by the PRP's that the full resources of the
Chemtronics Site Information Bureau are available for those purposes.
We look forward to your evaluation.
Sincerely,
-------
JAMES .vicCLURE CLARKE
1 1TM OUTKICT. NOHTH OkHOLINA
COMMITTEE ON INTERIOR ANO
INSUL4H AFFAIRS
COMMITTEE ON
FOREIGN AFFAIRS
SELECT COMMITTEE ON
AGING
I
217
of tf)e
of
20515
March 30, 1988
W»J»I»CTC» OCIOS'S
(20:i 2IS-«401
ONI NO»T» P»c» SOUADI
SUITI 434
AjMtv.uI. "
-------
V 1
FROM ' . - _ ' >
'HONORABLE JAMES KCCUJRE CLARKE
SUBJECT AND DATE .V.y* ...„».." •:*" ".•• -;;-. . _•"./•."'. . _ •.. ..'.-.,
CLEAMJP/CHEMTRONICS SUPERF 3«fP^rpJlfi-iS2, '
W?^: : «: -"-% nfP^SL v; '
REFERRED (11 : (2) ^ U Lj_W^ STStAi ' '/
WASTE '••"":: -'^5 ^~ fe * ' ' \ JJL^^- ^/JZfi^s_>
OAT* ; : 'r\ JOS. 1 1 0 0 ^
REFL.Y SENT TO ' " " '.":""•":,• " , -. ' '•. ' - • -" '.'•'';
REMARKS • .''''"-"•"".'• ' " :
PREPARE REPLY FOR RA'S S 1 6NATURE... PLEASE .FORWARD .THRU ....
CONGRESSIONAL AFFAIRS BEFORE * .AFTER .RA'S .SIGNATURE.
ATTACH a WHITE CfiRBOH COPIES JN.JUJDmON .TO ANY. OTHER ......
COPIES REQUIRED. ATTACH NECESSARY. ENVELOPES .FOR MAILING..,
••..•.
CONTROL NO.
AL881588
DATE REC 0
4/20/88
DUE DATE
4/25/88
Ul
• . ••-.:• . . '-
DATE RELEASED
ACKNOWLEDGED • OATS '
n .:. "~;': .'.: ::'. ..
NO ANSWER NEEDED
Q (Explain in rtmarki)
EPA Form SI80-1 (6-72)
WPLACCS FWPCA rOKM 71 AND
MCW-71 WHICH MAT NOT IE USED.
(Jttmov* Alt copy onfy, do not ttparat* rematndtr.)
MAIL CONTROL SCHEDULE
-------
APR 29 1988
4SA - '":"•...,.".'';"." '.•..-.-.
Bonorable James M. Clark*
House of Representatives
Washington, D.C. 20515
Deer Mr. Clarke; ; .
/ " -v ••*•""*' ~. ''ii- .••.'..- : : •• " ' . . " - • ' =
This it in response to your March 30, 1988 letter concerning the Chemtronlcs
Superfund Site in Swannanoa, Borth Carolina. The original public content
period on the draft Feasibility Study and EPA'e proposed remedial action at the
Chemtronica Site vaa to expire on March 18, 1988. At the request of the
citizens at the public meeting, the comment period vas extended to April 1,
1988. It has recently been brought to ay attention by Mr. Jon Bornholn, the
Project Manager, tha£ both you and the concerned citizens living in the
vicinity of the Cheatronica Site would like an additional extension to the
public comment period*
The draft Feaaibility Study and the proposed remedial action were presented to
the public in a meeting conducted by Mr. Bornholm on behalf of the Agency on
February 23, 1988. In that meeting, the community was encouraged to contact
the Agency with their thoughts/coaaents/qnections regarding the information
disseminated at the public meeting. The draft Feasibility Study was made
available at the meeting and copies are currently available at the four
information repositories. ~ .
Approximately 340 letters from local residents have been received by the Agency
aince the February 23 public meeting. The Agency is aware of the interest,
concern and commitment shown by the residents of Swannanoa and surrounding
communities in protecting their environment. More than 80 percent of those who
wrote, including a petition with over 830 names, have requested that the Agency
consider an additional extension of the public comment, period beyond the
April 1 closing date. . The majority of these people are asking that the comment
period be extended for aeveral months after the community receives a Technical
Assistance Grant (TAG). .Although we are aympathetlc to the community's desire,
the Agency intends to deny their request for the following reason. If the
community were selected for such a grant, it is our estimate that it will take
approximately eight months to a year for the Agency to make the award and for
the community to procure a consultant and review the report the consultant
.develops. The Agency is, however, mandated by Congress in the Superfund
Amendments and Reauthorlzatlon Act of 1986 (SARA) to have cleanup activities
underway at 175 Superfund Sites by October 1989. Untimely delays will impede
our efforts to achieve this goal* .: The Agency is not discouraging the Swannanoa
community from applying for a .TAG. However', the TAG will not be issued prior ••
to the Record of Decision/ If the community does receive TAG monies, it can be
directed toward the review of the remedial design that will be developed for
the cleanup of the ' '
-------
-2-
Pleaae be assured that we arc doing everything possible to insure a timely
clean-up which will be protective of all aspects of human health and the
environment. . ' !. -
If I may be of further assistance, please do not hesitate to contact me.
Sincerely yours, ".
/s/Lee A. DeHihns. Ill '
Deputy Regional Administrator • -
Greer C. Tidwell :. .- '•'.
Regional AJfalnistfator :
Bornholm/Richer IBM DISK, FILE 3-CONG, it/27/86
4WD-SFB 4WD-SFB
BORNHOLM .H^KS
\. 6
4WD-SFB 4WD-SFB 4WD 4PAB
GREEN STONEBRAKER TOBIfl J THOMPSON
4RA
TIDWELL
v'
-------
APR 29 1988
4BA- •-•*;• •:_•-:. • • •-.-•• .-'• ...:--•..-• . :..
The Honorable Terry Sanford
United States Senate
Washington, D.C. 20310 .
Dear Senator Sanfordt . . ., : :
This la in response to your March 30, 1988 letter concerning the Cheatroniea
Superfund Site in Svannanoa, North Carolina. The original public comment
period on the draft Feasibility Study and EPA*a proposed remedial action at the
Cheatronics Snperfund Site vaa to expire on March 18, 1988. At the request of
the citizens at the public meeting, the cement period vas extended to April 1,
1988. It has recently been brought to ay attention by Mr. Jon Bornholm, the
Project Manager, that both you and the concerned citizens living in the
vicinity of the Ghentronics Site vould like an additional extension to the
public conment period* .
The draft Feasibility Study and the proposed remedial action were presented to
the public in a aeeting conducted by Mr. Bornholm on behalf of the Agency on
February 23, 1988. In that aeeting, the community vas encouraged to contact
the Agency vith their thoughts/comsents/questions regarding the information
disseminated at the public aeeting. The draft Feaaibility Study vas made
available at the meeting and copies are currently available at-the four
information repositories.
Approximately 340 letters from local residents have been received by the Agency
since the February 23 public aeeting. The Agency is aware of the interest,
concern and coomitaent shovn by the residents of Svannanoa and surrounding
cooaonlties in protecting their environment. More than 80 percent of those vho
vrote, including a petition vlth over 830 names, have requested that the Agency
consider an additional extension of the public comment period beyond the
April 1 closing date. The majority of these people are asking that the comment
period be extended for several months after the community receives a Technical
Assistance Grant (TAG). Although ve are sympathetic to the community's desire,
the Agency intends to deny their request for the following reason. If the
community vere selected for such a grant* it is our estimate that it vill take
approximately eight months to a year for the Agency to make the avard and for
the community to procure a consultant and reviev the report the consultant J-:
develops. The Agency Is, however, mandated by Congress in the Superfund
Amendments and Eeauthorizatloh Act of 1986 (SARA) to have cleanup activities'
underway at 175 Superfund Sites by October1989. Untimely delaya vill impede :
our efforts to achieve this goal. The Agency is not discouraging the Svannanoa,
community froa applying for a TAG. However, the TAG vill not be issued prior
to the Record of Decision. If the community does receive TAG monies, it can'be
directed toward the reviev of the remedial design that vill be developed for;
the cleanup of the Site..,-..,';;.".•. •"'•'-•-y.^-:^ .. vA. x':--?..: '
• .'• .• . "V-V--* •<'*•:•.'.-•."•.•-.'T'-' ' ' •• ' ".'-' : • . • .' • »
-------
-2-
Please be assured .that we are doing everything possible to insure a timely
clean-up which will be protective of all aspects of human health and the
environment. .-•'".." —
If I vay be of farther assistance, please do not hesitate to contact we.
"Sincerely yours, ..
7s/lee A. DeHihns.'lII , : r -. - . . :
Deputy Regional Administrate! . . r:
Creer C. Tidwell ' ..-"'.- • . : " .".;'_ '. '.. ', , - ,
Regional Adainistrator ., .-.',.. - ' ^* '~:-'~.»tm
Bornholm/Richer IBM DISK, FILE 2-cong, 4/27/88
4WD-SPB 4WD-SFB 4WD-SFB 4WD-SFB 4WD 4PAB 4RA
BORNHOLM HANKE GREEN STONEBRAXER TOBIN THOMPSON ' TIDWELL
-------
3^ Price, J. Patrick - ,.-•_._•-.
•JKCT AM DATE . - f ..• . -.
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CONTROL NO.
AX 880684..
DATE RECTO
4-14
DUE DATE
^ "v ' '
t^J ^ ^t^ ^' *
1.1. V ifj*)j - .....-..-i.-*.:.- .-*•- .•. .. -••
' '->' :r. '•-•,.'• '
' •*- .'•• ' »-.'•
DATE RELEASED
ACKNOWLEDGED • DATE
D ' ..'....'•-••••' '
NO ANSWER NEEDED \ :
PI (Explain in remtrks) ' '
PM^PK 5180-1(6-72)
EPIACCSFWPCAFORM72ANO .
CW-73 WHICH Uft MOT BE USED.
(Remove this copy only, do not separate rcmmiader.)
MAIL CONTROL SCHEDULE
-------
April 1, 1988
Mr. Lee M. Thomas
Administrator
United States Environmental Protection Agency
Room W1200
401 N Street SW
Washington, DC 20460
Dear Mr. Thomas:
In a recent meeting of the Chemtronics Site Community Advisory Board, a
very serious problem emerged. It is a problem which has tremendous
impact on every decision and action related to the Site. Simply stated,
EPA has not effectively communicated with the Community and the public.
The CSCAB has and is supplied with all pertinent information relating to
the RI/FS, most of which has been read by or reviewed for the members.
In addition, the Board has been advised and counselled by Sirrine
Environmental Consultants and the PRP's. Even with this constant flow
of information, there are numerous unanswered questions in the minds of
the members regarding the EPA's remedial alternatives.
If the Board, with its myriad of resources, still has questions, imagine
how many more questions remain unanswered in the minds of the community
who has been exposed to a fraction of that information.
Under the Community Relations Program, implemented by the Chemtronics
Site Information Bureau and Visual Imagry, an incredible volume of
information has been disseminated to the public and the media:
Newsletters, press briefings, public meetings, media releases, fact
sheets, background sheets, technical papers, videotapes, slide films and
other documents have been employed. This entire program has been funded
by the PRP's. In addition, the EPA has been and is provided with all of
the resources of the Community Relations Program.
It is the consensus of the CSCAB that the weak link in gaining the
confidence and trust of the public regarding the FS is the EPA. The
individuals and audio visual techniques used at both public meetings
were very weak and almost amateurish. Presenters failed to deal with
the "meat" of the recommendations in a credible manner. There was
little supporting material that would help the audience understand these
highly complex subjects. The only supplemental material supplied to the
public was that created and supplied by the Chemtronics Site Information
Bureau.
Beyond the public meetings, there has been virtually no communication
between the EPA and the community or region. According to independent
research conducted in the Fall of 1987, the EPA has a very low
credibility with the community. We believe the reason is evident.
-------
It is the EPA which will issue the ROD, the final decision on what
remedial actions will be taken. If the EPA lacks credibility, every
finding, every recommendation, and all involved parties will also lack
credibility. Without it, there will never be peace of mind in the
community.
The Board feels that PRP's and their contractors have done a very
reliable and credible job on the RI/FS. Now it is critical that the
public understand the validity of the findings and the reliability of
the recommendations. This can be accomplished only with a very
intensive, cooperative community information program mounted by the
EPA. We are assured by the PRP's that the full resources of the
Chemtronics Site Information Bureau are available for those purposes.
We look forward to your evaluation.
Sincerely,
L/3. Patrick Price, Chairman
Chemtronics Site Community Advisory Board
-------
MAYS
4WD - •
Mr* J. Patrick Price, Gbairtnan
Chemtronics Site Community Advisory Board
P.O. Box 18177 v- :V ; .
Asheville, 1C 28814 ': i: : ; . :
Dear Mr. Price: ...
I would like to take this opportunity to respond to your April 1, 1988 letter
addressed to Mr. Lee Thomas, EPA Administrator, regarding the Agency's
community relations activities in the Asheville/Swannanoa area in conjunction
with the Centronics Superfund Site.
The Agency has a very difficult task when it cooes to addressing a ccoxnunity's
concerns associated with a Superfund site. First* the Agency is placed in an
awkward position first to explain why industry was allowed to dispose of
chemicals in the manner that the Chontronics potentially responsible parties .
did and second, to explain what is the health risk posed by the disposed.
materials. It is easy to say "that was the accepted method of disposal back
then" but this does very' little to reduce the fears of the community. One of
the greatest fears a comcunity has associated with a Superfund Site is the risk
or potential risk that the Site poses toward a local citizen's health. It is
difficult to explain the health risk or potential health risk associated with a
site in terms of numbers. One of the most cooznon risk factors used is 10"
or one in one million. First of all, one million is a large number making it
difficult for people to visualize and secondly, this risk factor becomes nearly
impossible to accept if you are one of the residents living adjacent to the
site and that one in a million could be you or a member of your family. In
these instances, any risk factor greater than zero is too high. EPA is very
sensitive to these and other Issues associated with Superfund sites.
• • - •• ••- • -'•• "• ' ' ••'
In reviewing the history of the Chemtronics facility, dating back to its
inception as ah industrial plant, a fact was revealed which has compounded the
community relations problems for both the Agency as well as for the PRPs.
Apparently, the cccxnunity had absolutely no idea that either BZ or CS was being
manufactured at the Site until EPA made it public knowledge during the
development of the Remedial Investigation/Feasibility Study work plan. This
fact alone generated a significant amount of news media interest in the
Chemtronics Site. Since these compounds were manufactured specifically for the
0. S. Government (i.e., the Department of Defense); the Agency is even more
sensitive to this issue. :.
-------
-2-
It is difficult for EPA "to disseminate the massive amounts of information
generated from activities conducted at a Super fund project. The task becomes
even more complicated when you consider the diverse backgrounds of the
residents living in the Asheville/Swannanoa area. It is difficult to relate
very technical issues and/or concepts to the comnunity at large. In an attempt
to accomplish this goal, the information on the technical issues and
considerations were drawn out with sufficient verbiage as to provide everybody
an opportunity to understand them. This approach, unfortunately, has a
drawback which you alluded to in your letter and that is it makes it difficult*
to get to the "meat" of the situation. But given the complexity of the
Chemtronics Site, it was inevitable that a certain percentage of the community,,
would not be able to assimilate all the information reviewed during the
February 28, 1988 public meeting. . . ., . .. .
This confusion is" compounded by the fact that each newspaper that services the
Asheville/Swannanoa area has published their own understanding of the problems
associated with the Site and what the actual remedial cleanup would entail and
accomplish. This occurred even after the Agency had disseminated this
information to the news media in Fact Sheets.
Region IV has conducted significantly more comnunity relations activities at
the Chemtronics Site than are generally performed at other Superfund sites.
From the tone of your letter it appears that this was not enough. At the same
time, I am troubled why you did not state these questions/concerns you alluded
to in the Chemtronics Site Ccnrounity Advisory Board March 28, 1988 letter the
Agency received during the public comment period. Without receiving these
specific questions/concerns from the ccranunity, it is difficult for the Agency
to respond to the comnunity.
In the near future, the Agency will respond to the majority of correspondence
we received during the public comment period. Over eighty percent of the
comments we received requested a delay in the issuance of the Record of
Decision until two months after the community received a Technical Assistance
Grant. Unfortunately, the Agency could not honor this request. It was our
appraisal that this would result in an eight month to one year delay in the
project which was deemed unacceptable for implementing cleanup activities at
the Site. . -
If I can be of further assistance, please do not hesitate to .contact me. - - '
Sincerely yours,"'- - . ----.. •..__. . .-•. .
Patrick M. tobln*^' ;- ••.:'•• v •*• ••-.-• •• • .v;..V.- ..='•; '.V ''.-.?**
Waste Management Division Director . r .
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IBM DISK-CHEMTRONICS CR, FILE |CR17, 4/28/88
-------
MZMORANDCM
.;. ' DATE: ' •; "•'••';';•-• •"•"•',: '••••'-••.'•• • •' ' '
SUBJECT: Response to the Letter Mr. J. Patrick Price Sent to Lee Thomas
Regarding the Chemtronics Superfund Site -- "
TO: Patrick M. Tobin, Director " .
Waste Management Division -.-..-_ -;
FRCM: Jon Bornholm, Superfund Project Manager
THRU: Al Hanke, Chief '" • .
NC/SC Site Management Uhit
Richard Green, Chief '" :
North Site Management Section ,
Richard D. Stonebraker, Chief '
Superfund Branch " \
*.:-""' •• .1* ' ,.'•"• '.*•"-
" - " • • • •.--.-'. •• f • ;:. ''.- '.-• ' •'. -•"**." • "* ."" •
The attached letter is in response to the April 1, 1988 letter Mr. J.
Patrick Price, Chairman of the Cherotronics Site Connunity Advisory Board
(CSCAB), addressed to Mr. Lee M. Thomas, EPA Administrator. The • •. ••:" ;
manbership of the CSCAB is supposedly comprised of individuals with ?
various backgrounds including citizens, conmunity interest groups, public
officials, and economic interest groups from the Asheville/Swannanoa ;
area. These individuals were initially invited by the PRPs. to join and
form the Board. Since then, it has been the Board's responsibility to
maintain its membership which, from my understanding/ has been a difficult
task due to the relative high rate of turnover. The formation of the ~
CSCAB was a task included in the Connunity Relations Plan (CRP) developed
by the PRPs for the Chantronics Superfund Site located in Swannanoa, North
Carolina. The purpose of the Board, as defined in'.the PRPs CRP# is to act
as a sounding board for the community's concerns and issues. -^ ->>.>--• V
In addition to the formation of the CSCAB, the PRPs CRP also called for :"
the establishment of their own information repository which is referred to
as the Chemtronics Site Information Bureau (CSIB). The CSIB and CSCAB -.-./
work together in releasing information to.the public. Unfortunately, some
of the information they have released is tainted to paint a rosier picture
of the Site than that which actually exists. The conmunity is very '".".'';:
sensitive to this issue. / ... 'Vi'.'."vi••'*.'••!V.V' .'. -:-: •' ; .-. .: ....- • -. •". .
-------
-2-
The CSCAB has compounded some of the situations that Mr. Price has
highlighted in his letter by conveying to the cannunity at large that the.
CSCAB is EPA's direct link to the connunity. This misnomer was brought to
my attention through a recent telephone conversation I had with a ...'"".
professor from a local college. The main reason the professor called was
to ask me if EPA had sanctioned the CSCAB and the information it and the
CSIB was disseminating. My response was no. Below are two quotes taken -
from letters from several community leaders in the Swarmanoa area received
during the public ccranent period. The first quote is from the presidents
of the Bee Tree Community Development dub and the Buckeye Cove Community
Club. They state "...we wish to state that the cannunity attitude studies
conducted by the Site Advisory Conaittee do not represent our communities;
those studies are based on quota samples and cannot be used for
generalization about our conmunities...". The second quote is from the
comments submitted by the North Carolina Clean Water Fund representative
where she is referring to the desire of the local residents to become
meaningfully involved, in the cleanup decision. She states "The second -.
step was taken by the" Chemtronics Site Advisory Board, when it
acknowledged the need for connunity input into its decisions by scheduling
its own meeting April 11 to hear connunity concerns. That Board, which
was to serve as the bridge between the company and the community, has in .
fact, had minimal contact with the neighbors who will be most immediately
affected by the quality of the cleanup...*. These two quotes clearly -
indicate that the CSCAB does not have as clear a handle on the situation
as Mr. Price makes it appear in his letter. It should also be noted that
none of the comments received by the Agency during the public comment
period either praised or commended the CSCAB for it's community
representation efforts. As identified above, several individuals question
the CSCABfs motives.
The majority of the connunity's mistrust stems from the fact that the PRPs
and their contractor have conducted the RI/FS. This mistrust surfaced
back in 1985 when the Agency first held some informal public meetings
during the development of the Chemtronics work plan. At this time, the
public was informed that the PRPs may be performing the .work themselves.
The general feeling of the Individuals who attended .these meetings was .
that the Agency was going to let the fox guard the hen house. .Ever since
/then the Agency has *had to expend extra effort to help "substantiate
credibility for the work performed by the PRPs at the Chemtronics Site.
4WD-SFB ,v --.'..- 4WD-SFB \V,' 4WD-SFB \j ,J.'W '4WD-SFB
BORNHOEM" - HANKED • : v- GREEN vv^:':\ STONES.'
IBM DISK - CHEMTRONICS CR, FILE f CR17A, 4/28/88
-------
April 5, 1988
Respectfully roferred to:
Craig DeRemer
Environmental Protection Agency
Because of the desire of this office to be
responsive to all inquiries and cooaunications,
your consideration of the attached is
requested. Your findings and views, in
duplicate form, along with return of the
enclosure, will be appreciated by
Form f2
Direct to the-1
Wayns Eaylss
Offics of Ssnsar Jssss Halrr;
402 DirJ'^sn Cffics EuiJriing
Washington, D.C. 2CS10
[202] 224^342
-------
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-------
s<0 O&f "Set Tnt %pa<{
March 16, 1988
The Honorable Jesse Helms
Senate Office Building
Washington, D.C. 20510
Dear Senator Helms:
As you probably know, the EPA has placed the Cheratronics site in
Swannanoa on the Superfund List and the final report before clean-up is
now at hand. It is fairly obvious to those of us who live nearby, and
have first-hand knowledge of the problem that they do not intend to clean
up the problem as the R.F.I.S. indicated it should be handled.
Attached please find a copy of my letter to the EPA. I would be most
grateful if you could get involved in this. Unfortunately none of the local
government officials seem, to care—only one bothered to attend the public
hearing. »
Please advise me how you can help me and your friends in the Swannanoa
Valley. The R.O.D. ends April 1. We need it extended.
Very Since
ULL/aeh
Enclosure
-------
1 540 Old "Set Tm
Swaiuianoa. $(£ 2A77S
March 16, 1988
Mr. Jon K. Bornholm : '" '•" • •"
Emergency and Remedial Response Branch
Remedial Action Section
345 Courtland Street, N.E.
Atlanta, GA VJ365 ' " .
1 ' t
Dear Mr. Bornholm:
1 T have had a chance to eo over the final Chemtronics report, and I am
auite amazed at the difference between it and the 3.I.F.S. by Camp, Dresser,
and McKee. For instance, the eround water contamination problem which they
sav is not off the site. I'm attaching two reports that dispute that fact.
Camp, Dresser, and McKee say that the wells weren't drilled low enough to
reach the aouifier, and I believe thev are right. They also say that the
waste stream could be diverted hv geological faults. As ouch as thev blast
at Chemtronics, the earth is full of cracks way down. That's why the well
at Owen Manufacturing Company, which is 600 feet deep, shows trichloroethlene.
It's fairly obvious where it came from. Several years ago, Mr. Schultheis
showed me some slides of magnetic readings showing two plumes that definitely
were off the Chemtronics property. -
T disagree with the capping of the acid pits. Over 550 thousand gallons
of spent acid went into those pits from 1974-1979, all of which is no longer
in that vicinitv now. Downgrade from there, the dead vegetation bears that
out. It has definitely moved.
I stron&ly protest incineration only 900 feet froa my home and the homes
of two of my sons. Chemtronics claims that they could burn BZ and get 99.999*
burn when the material hasn't even been bench tested correctly. This is pure
speculation and false promises on their part. Only six of the twenty commer-
cial hazardous waste incinerators being used by the EPA are able to meet your
guidelines, end only three of your 56 approved landfills totally conform to
EPA policy. I do not want to be a part of an experimental malfunction that
very well ni2ht take the very lives of every one in this valley. Uiemtronica
and their predecessors have a poor record in handling waste, as proved by the
testimony of many former employees and by me myself. I have observed it since
1971; I have lived .beside it since 1977.
-------
Mr. Jon K. Bornholm
Page 2
March 16, 1988
I do not feel that fencing in any portion of it would-suffice. Wildlife
would still have access to the property by flying in or climbing .over. I ',
am asking for a moratorium or a rejection of the final report on Chemtronics
until we can get the government money that's available for us—once some
guidelines are given us. • :
"Wallpapering" over the problem may hide a multitude of mistakes, but
it by no means corrects the problem. I shall fight it to the bitter end.
Sincere
W. L. Lovelace
WLL/aeh
i
Enclosures 2
cc Jesse He Ins, Terry Sanford, James McClure Clark
-------
APR 251988
4RA ' ' •' '-1-' •'••'.•'.' •'.-.' •' • • " •• ''•'•'' ' ' •••'•'
. The Honorable Jess* A. Helms •
. United State* Senate • : .:
Washington, D.C. 20510 ; Vi ; .;•-'' ^'-VA: - •',' .'.•":•'•'-. :-..-. '.^^: • "•• •--:.-. '
... Dear Senator He 1ms t '.' • - : -'•" ' , .." •" ".. . • ,\ •;.• • ' . ...-.•'-.;. ''...-.••
This ia in response to your inquiry of March 30, 1988 In which yoo referred a
copy of a letter, froa Mr* V. L« Lovelace concerning the Cheatronica Super fund
Site in Svannanoa, North Carolina which also waa received by the Agency during
the public comment pe'rlod. .
Enclosed is a copy of the Agency's response from Project Manager
Mr. Jon Bornhola to this letter fro* Mr. V. L. Lovelace.
Please he assured that we are doing everything possible to insure a timely
clean-up which will be protective of all aspects of human health and the
environment. • ; ' '" .. ' :':''\. •.:"'''"'..• "'"--'"
If I may be of further assistance, please do not hesitate to contact me.
Sincerely yours, - -
./s| Joseph R. Franzmathet ; ...... . . . :.
•:• •'-.;. . - Acting • • '..-:,; • . . '. ..... "•',' ...>v.,,-.v_ ''. j;. ..--.••., :-
Greer C. Tidwell : '•,'-•"
Regional Administrator
»• '". **•**•'-:: ' , ...... -| . •_ ;•:: -•-?..•- ^ •-:': "^ . ^'
? ".."..- . Enclosure .•;...':-•"•':"••' ."' ''^ ,•'""""'','.,; .'. • ':' :'•-.'.; 4.' -.-.'''
Bornholm IBM DISK CHEMTRONICS, FILE tl^-CQttG, 4/19/88
4PAB '"• ' •• 4RA :
THOMPSON : TIDWELL
STONEBRAKER : " TOBI
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-REGION IV
343 COURTLANO STREET
ATLANTA. GEORGIA J038S
4WD-SFB
Mr. W.L. Lovelace
540 Old Bee Tree Road
Swannanoa, N,C. 28778
Dear Mr. Lovelace:
This letter is in response to your letter received by the Agency on
March 21, 1988 with respect to comments on the draft Feasibility Study and the
proposed remedial alternative for the Chemtronics Superfund Site.
According to the data generated in the investigation of the groundwater during "
the Remedial Investigation (i.e., the migration of contaminants through the
aquifer from the various disposal area), the contaminants have migrated between
400 to 800 feet downgradient from those disposal -areas where groundwater
contamination was found. Groundwater monitor wells were installed in locations
the Agency thought would provide the best information regarding the movement of
contaminants through the groundwater. These monitor wells were located where
major fractures in the bedrock were thought to exist. These major fractures
are where you would expect to find contamination. All wells were installed to
a proper depth.
At no time has the Agency's contractor Camp, Dresser and McKee, Inc. issued a
statement that the wells were not installed deep enough to intercept the
aquifer. All wells were completed la the groundwater whether they were shallow
wells or deep wells.
Neither the analytical data you received for the surface water sample collected
near your residence nor the referenced analytical data on the water quality of
the Owens Manufacturing Company's veils dispute the conclusion stated in the
Remedial Investigation report that on-site groundwater contamination has not
migrated off the Site. The stream sample you had collected near your house is
located upstreae of the Chemtronics property and the disposal areas. I would
expect that the source of the tetrachloroethylene found in this sample is
located upstream of your house (i.e., the little area off of Old Bee Tree Road
where local residents appear to be using as a dump along the banks of Bee Tree
Creek). North Carolina Department of National Resources and Community
Development has already, to a certain degree of confidence, identified the
source of the trichloroethene showing up in the Owens Manufacturing Company's
production wells. The Chemtronics Site was not identified as the source.
The map Mr. Schultheis showed you identifying two contaminated groundwater
plumes do exist but as stated previously the plumes have not nor will they
within 25 years, reach the site's boundaries. One plume is emanating from the
Acid Pit Area and the second from Disposal Area *23. Neither plume has
migrated over 800 feet.
-------
The Agency has selected the alternative for capping che drum containing
disposal areas for several reasons. First and foremost, Is the treat posed by
live ordinance buried along with the druns co the workers who would be involved
in the excavation of these drums in order to prepara them far incineration.
The second issue considered was Che potential damage that these ordinance vouid
have on the incinerator itself. If these devices exploded inside the
incinerator's chamber, it would be difficult to predict the results. One
possible scenario is the release of partially destroyed contaminants into :he
environment. This coupled with the fact that the Asheville area is located in
part of the country that experiences frequent air inversions would increase the
potential to exposing the community to these partially destroyed chemicals if a
release, for any reason, occurred. And thirdly, a great number of citizens
voiced a negative response towards on-site incineration both in the public
meeting and during the public comment period.
The Superfund Amendaents and Reauthorization Act of 1986 (SARA) encourages the
Agency to iaplement a remedial alternative that reduces Che mobility, toxicity
and volume of hazardous vasts it a Superfund Sir 3. The capping of the drum
disposal iraas along with the capping of acid pit iraa and :he soil
fixation/stabilisation/solidification process for Disposal Ar?a ''23 along with
extraction and treatment of jroundwatar will aest these criteria. The security
fences to be installed around these capped areas will help maintain the
integrity of the caps by preventing unwanted, intruders including aan and
animals alike, from damaging the cap.
In addition to the remedial activities stated above, a long term monitoring
system will be instituted for the groundwatar in both valleys and the surface
water. This monitoring system will provide data that will indicate whether or
not the remedial action implemented is working as designed.
If I can be of further help, please do not hesitate to contact me at (404)
347-7791.
Sincerely yours,
Von K. Bornholm
Superfund Project Manager
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. . .. .
Mr. Buchanan ••;•'.•.••;' - • -...'•-• -•.. • • '•'.'..
144 Anderson Branch • •-'•' . ",';-~' '•-.*•' ••••- =-•"'.'••••
Marshall, North Carolina 28753
Dear Mr* Buchanans
As you know, the original public canrent period on the draft Feasibility Study
and EPA'a proposed remedial action at the Cherctronics Superfund Site expired on
March 18, 1988. Later, the content period was extended to April 1, 1983. it
has been brought to v.y attention by Mr. Jon Bornholnr, the Project Manager, that
you and other concerned citizens living in the vicinity of the Cherctronics site
would like an additional extension to the public content period.- ;
Die draft Feasibility Study and the proposed remedial action were presented to
you at a public meeting conducted by Mr. Bornholir on behalf of the Agency on
February 23, 1988. In that ireeting, you vere encouraged to contact the Agency
with your thoughts/ccffirents/questions regarding what you heard at the public
iteeting and after you had reviewed the draft Feasibility Study. The Study was
«rade available at the iroeting and copies are currently available at the four
information repositories.
Approxiicately 340 letters have been received by the Agency since the February
23 public ireeting. -I ax gratified by the interest, concern and conriteent
shown by the residents of Swannanoa and surrounding conrunities in protecting
their environment. More than 80 percent of those who wrote, including a
petition with over 830 nates, have requested that the Agency consider an
additional extension of the public ccrarent period beyond the April 1 closing
date. The vajority of these people are asking that the canrent period be
extended for several nonths after the contunity receives a Technical Assistance
Grant (TAG). Although I understand your point of view and acr sympathetic, I -
Kust v-ake you aware of ny position. Even if the ccmrunity were selected for
such a grant, we estiirate it will take approximately eight ironths to a year for
us to-vake the award and for you to procure a consultant and review the report
the consultant develops. The Agency is, however, mandated by Congress in the
Superfund Arrendtrents and Reauthorization Act of 1986 (SARA) to have cleanup
activities underway at 175 Superfund Sites by October 1989. Untimely delays
will inpede our attarpt to achieve this goal. Ratorber, you still have an
opportunity in the near future to review and canrent on the actual remedial
design developed for the Site. ." . .
-------
-2-
After it .is developed, the Agency will hold another public meeting to present
the design. Since the design is a more technically oriented document than
either the Remedial Investigation document or the Feasibility Study, it may be
more beneficial to the community to spend the TAG monies for a third party
review at that time. This will give all concerned groups in the Swannanoa and
Black Mountain area an opportunity to organize themselves into a single entity,
become incorporated under applicable state laws, and provide 35 percent of the
total cost of the TAG project (matching funds), all of which are necessary in
order to receive a TAG.
After careful consideration of the situation at Chemtronics, I am going to let
stand the April 1, 1988 closing date for the public comment period on the
Feasibility Study and proposed remedial action for the Chemtronics Site. I
again encourage you to organize yourselves into an incorporated entity and
apply for a TAG in sufficient time to be able to procure technical assistance
to review the remedial design.
Sincerely yours,
Greer C. Tidwell 'A
Regional Administrator
-------
APPENDIX B
COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE CHEMTRONICS SITE
-------
APPENDIX B
COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE CHEMTRONICS SITE
The following is a chronological listing of community relations activities
performed with respect to the Chemtronics Site.
* In February 1984, EPA attended an annual environmental studies seminar
conducted by Warren Wilson College. The Chemtronics Site was used as a
case study.
* In November 1984, EPA participated in a series of three meetings held to
address community concerns with the Chemtronics Site. The three meetings
held were with 1) the Buncombe County Hazardous Waste Advisory Board, 2)
the administration and faculty of the college and 3) a group of local
citizens and college students.
* In March 1985, EPA released a Fact Sheet describing the history of the
Site and the RI/FS process. It also contained a glossary.
* In October 1985, EPA released a second Fact Sheet that described the
history of the site, the current status, the RI/FS process and provided
the location of the four information repositories.
* In June 1986, EPA released a third Fact Sheet that described past events
and the current status at the Site.
* In October 1986, EPA approved the first audio-visual presentation that
describes the chronological history of the Site and the objectives of the
RI/FS process. This audio-visual presentation was shown to various
community groups and organizations.
* In March 1987, EPA helped in presenting the findings of the RI to the
public in a meeting held at Swannanoa Elementary School.
* In September 1987, EPA released a Fact Sheet that described the findings
and conclusions of the RI report.
* In September 1987, EPA approved the second audio-visual presentation that
describes the RI/FS process and the RI findings with regard to the
Chemtronics Site. This audio-visual presentation was also shown to
various community groups and organizations.
* In February 1988, EPA released a Fact Sheet that described the findings
and conclusions of the FS report and the Agency's proposed remedial
alternative for the Site*
* In February 1988, EPA conducted a meeting in which the results of the FS
were summarized and the Agency's preferred remedial alternative was
presented for comment. It was stated at the meeting that the public
comment period was to end March 18, 1988.
-------
APPENDIX C
PUBLIC NOTICES/NEWSPAPER ARTICLES
-------
United States Region 4 . Aiasama '
Environmental ' 'ection Office of Public Affairs Florida Nortn Carolina
A9ency 345 Courtland Street. NE Georgia South Carolina
Atlanta. GA 30365 Kentucky . Tennessee
x>EPA Environmental News
(404) 881-3004
H. Michael Henderson
(404) 347 - 3004
PRESS ADVISORY
ATLANTA, GEORGIA - The IK S. Environmental Protection
Agency, Region IV (EPA) will hold a public informational
meeting on Tuesday, February 23, 1988, 7 p. m., at the
Charles D. Owens High School Auditorium on Old Black
Mountain Highway, Buncombe County, North Carolina.
The purpose of the meeting is to discuss the findings
of the Feasibility Study and to inform the community of
other EPA activities at the Chemtronics, Inc. Superfund
Site. The meeting will conclude with a question and answer
period designed to answer citizen concerns. A three-week
public comment period on the remedial alternatives suggested
in the study begins February 23rd. The comment period
will end on Friday, March 18, 1988. Written comments
should be sent to Jon Bornholm, Remedial Project Manager,
USEPA - Region IV, 345 Courtland Street, N. E., Atlanta,
Georgia 30365.
MORE -
EPA - REGION IV
AT1.1NTA.GA.
-------
Documents relating to EPA activities at the Chemtronics
site are available for citizen review at the Warren Wilson
College Library, 701 Warren Wilson College Road in Swannanoa,
NC, the Buncombe County Office of Emergency Medical Services,
8 New Leicester Highway, Asheville, NC, and the University
of North Carolina at Asheville, Ramsey Library, One University
Heights, Asheville, NC.
The Chemtronics Superfund site encompasses approximately
1,027 acres along Old Bee Tree Road in the rural Swannanoa
Valley of eastern Buncombe County of North Carolina and was
placed on EPA's Superfund National Priorities List in
December, 1982.
Iff
-------
U.S. Environmental Protection Agency
Chemtronics Superfund Site
PUBLIC INFORMATION
MEETING
TUESDAY, FEBRUARY 23, 1988
at7:00p.m.
in the
CHARLES D. OWEN HIGH SCHOOL
AUDITORIUM
Old Black Mountian Highway
Swannanoa, North Carolina
The purpose of the meeting is to present the findings of the Feasibility
Study and EPA's proposed plan to remedy contamination at the
Chemtronics Superfund Site, located in Swannanoa. The meeting will also
provide interested citizens the opportunity to express concerns and ask
questions regarding EPA's involvement at the site.
A question and answer period will follow a presentation by EPA.
-------
Environmental Protection Office of Public Affairs Flonaa
Agency 345 Courtland Street, NE Georgia
Atlanta. GA 30365 Kentucky
Nonn Carolina
South Carolina
Tennessee
EPA Environmental News
ERRS
nrp
(404) 881-3004
FEB26I988
LbliDlbUl/Lb
EPA - REGION IV
ATLANTA. GA.
H. Michael Henderson
(404) 347 - 3004
PRESS ADVISORY
ATLANTA, GEORGIA - The U. S. Environmental Protection
Agency, Region IV will extend the three-week public comment
on the remedial alternatives suggested in the Chemtronics
Superfund site Feasibility Study for two additional weeks.
The comment period began on February 23, 1988.
In response to citizen concerns expressed at the.
February 23, 1988 public informational meeting the new
deadline for comments will be Friday, April 1, 1988.
Written comments should be sent to Jon Bornholm,
Remedial Project Manager, USEPA - Region IV, 345 Courtland
Street, N. E., Atlanta, Georgia 30365.
Documents relating to EPA activities at the Chemtronics
site are available for citizen review at the Warren Wilson
College Library, 701 Warren Wilson College, Swannanoa, NC,
the Buncombe County Office of Emergency Medical Services,
8 New Leicester Highway, Asheville, NC, and the University
of North Carolina at Asheville, Ramsey Library, One University
Heights, Asheville, NC.
The 1,027 acre Chemtronics Superfund site is located
along Old Bee Tree Road in rural Swannanoa Valley of eastern
Buncombe County of North Carolina. The site was placed on
EPA's Superfund National Priorities List in December 1982.
•
ft*
-------
'4B THE CHARLOTTE OBSERVER Friday, April 5.198S
Tear Gas, Lethal Chemical Share Name
By JACK KORAN
And TEX O'NEILL
Operators of a chemical warfare and muni-
tions plant near Asheville made tear-gas shells
in the late 1960s that. In an apparent coinci-
dence. bore the name of a chemical agent that
kills by blistering the lungs of its victims.
The designation "CX" for both chemicals
has confused federal regulators and led people
who live near the. plant to wonder whether
operators made the blistering agent — and
perhaps other lethal agents — at the Buncombe
County site. ... •. • . -
Last January, The Observer disclosed that
operators secretly made 150,000 pounds of the
chemical warfare agent BZ for the Army be-
tween 1962 and 1966. BZ causes hallucinations'
similar to those produced by the drug LSD.
A just-released document prepared for the
U.S. Environmental Protection Agency (EPA)
cites experimental production of "CX" at the
plant now owned by Chemtronics Inc. "CX" is
the name the Army uses for phosgene oxime. a
lethal blistering agent, according to a chemical
warfare official (or the Army.
The official, Andrew Anderson, said he was
certain the plant produced no "surety" agents
— those that Incapacitate or kill — other than
BZ. Tear gas Is not considered a surety agent.
"I'm 99.99% sure they never made any CX
(blistering agent) at this site," said Anderson,
chief of the assessment division of the Toxic
and Hazardous Materials Agency. In Aberdeen,.
Md. "... I think It was a designation they used
locally. It's not an Army designation." .
The mention of CX appeared in a document
outlining how an investigation of hazardous
wastes buried at the site near Swannanoa will
proceed. The EPA Is overseeing a "superfund"
cleanup of the site. :' •
"At one time," the EPA document says,
"Northrop reportedly experimented with pro-
. duction of CX (burning CS)." CS stands for
tear gas. • .
Northrop Is Northrop Carolina Inc., a former
subsidiary of Northrop Inc., the Los Angeles-
based aircraft manufacturer. A' Northrop
.. spokeswoman confirmed this week the subsid-
iary made CX shells but referred further ques-
tions to the Army. ; .
Two former Northrop officials also told The
Observer the company didn't make the blister-
ing agent. •. .. • . .
John Schulthels, now president of Chem-
tronics, and P.M. Hudson, who was In charge
of BZ quality control, said they doubted phos-
: gene oxime was ever produced at the site.
. "That. CX we never messed with," saJd
Schulthels. Added Hudson: "We never did any-
thing: In the way of phosgene or phosgene-type
production out there." • :.!••...;• •
On Tuesday, the subject of CX came up in an
. EPA-sponsored public meeting In Swannanoa.
At the meeting was Mary Leslie of Camp
Dresser & McKee, Inc., an Atlanta consulting
firm thtt prepared the document and will do
the site Investigation for EPA.
When a questioner asked about CX. site
manager Leslie replied she didn't know
'whether it referred to tear gas or the blistering
agent. •
"No one really knows," she said Thursday
from a company office In Tampa. "It's some-
thing we're going to look Into."
CX, the blistering agent, has never been
stockpiled by the United States, according to
Art Whitney, spokesman for the Army Mate-
riel Command in Alexandria, Va. • •:
Whitney, citing a field manual on chemical
. warfare agents, said CX causes a bee-stlnglike
pain on the skin and forms welts that are
. followed within 24 hours by scabs. He said
Inhalation of CX Is deadly.
-------
rr' • r
mciaLs
By NANCY WEBB
SliH Writer
SWANNANOA — Environmental Protection
Agency (EPA) officials told a gathering of
about 80 Swannanoa Valley residents Tuesday
their plan for determining how much and what
kinds of hazardous waste are buried at a
former chemical warfare production site in the
area.
During a question-and-answer session, the
residents voiced concern about security at the
site, immunity for site employees who have
information about additional burial sites and
testing of private wells for possible contamina-
tion. ' • .
In January, The Observer reported that
wastes from manufacturing 3-quinuclidinyl
benzilate, a hallucinogen known as BZ. might
not have been properly neutralized before be-
ing buried at the site near Swannanoa in
' Buncombe County. BZ waste is believed buried
in 300 to 500 drums in four or five landfills.
Inhalation of even a speck of BZ can cause.
up to seven days of disorientation and halluci-
nations similar to those caused by LSD. Both.
the Army and the EPA have said there is no
imminent danger to the public from the BZ
waste. '-.".'
"The sooner this cleanup is done, the sooner
it's finished and the sooner we have some of
these companies pay the price the better off
we'll be," said area resident Henry Kreitzer, a
retired Air Force colonel. "They should not
have been burying this stuff in the first place."
The plan presented Tuesday is a guide for
the EPA's site investigation, which involves
taking samples and determining the scope of
the cleanup. '
Wastes discovered at the site, including BZ
and tear gas, were both made for the Army in
the 1960s by two previous site owners. The
wastes were left after nearly 30 years of
.manufacturing at the site now owned by
Chemtronics Inc. • .
Audience members listened intently as EPA
spokesman Jim Orban explained, that the first.
step will be a preliminary investigation, fol-
lowed by a feasibility study to determine reme-
dies for the cleanup.
Before the cleanup can begin there will be
another public meeting to explain the proposed
process to area residents, Orban said. No time-
table for the investigation or cleanup was
presented.
Lawyer Bob Warren, an area resident, told
Orban the EPA should make companies that
occupied the site produce lists of employees
and those employees should be contacted. War-
ren also suggested the employees be given
immunity from prosecution.
-------
of/e O/o^At^/2 -J?
entitled
By JACK HORAN
And TEX O'NEILL
SUII Writer t
SWANNANOA — The federal cleanup at the
Chemlronics Inc. site In Buncombe County
may have expanded Tuesday when a former
production supervisor revealed seven previ-
ously unidentified chemical warfare and muni-
tions waste sites.
The sites identified by Roy Burleson, 47,
include six on the 1.027-acre property where
the chemical warfare agent BZ — a hallucino-
genic compound — was made for the Army in
the 1960s.
The seventh site Is along U.S. 70, six-tenths
of a mile east of Swannanpa and about 2 miles
from the Chemtronics property, designated for
a "superfund" cleanup by the Environmental
Protection Agency (EPA).
EPA officials said they will Investigate the
sites that Burleson said contain waste from the
production of BZ, tear gas and explosives.
The disclosures by Burleson, who worked at
the plant from 1963 to 1968, brought to 31 the
number of known or suspected waste sites
either on the mountainous, property or else-.
where in the Swannanoa area.
"1 know all the spots probably. Everything
j was poured on the ground. Trenches dug and
; filled over," Burleson said.
': He made the disclosures at his home to EPA
. officials from Atlanta Just hours before a pub-
lic meeting on the site cleanup. He based his
Information on personal experiences and con-
versations with other workers.
Burleson said he worked for the previous
owners, Amcel Propulsion Co., a subsidiary of
•Celanese Corp., a producer of chemicals, fibers
and plastics; and Northrop Carolina Inc.. a
"subsidiary of Northrop Inc., an aircraft manu-T
See 7 MORE Next Page
Continued From Preceding Page
facturer. -. ::
In January, The Observer reported that Army
officials thought wastes from BZ — 3-quinuclidinyl
benzilate — may not have been properly neutralized
before burial.
"There was a lot of waste burled off the site. BZ
was not the only thing we were manufacturing.
Everything (types 6f waste) was buried together on
the site." Burleson said.
The EPA relied on accounts by Northrop Carolina
officials and interviews with former employees of
both companies in compiling the 23 original waste
sites. The Northrop accounts did not include the sites
Burleson named.
Asked about the suspected sites, Northrop spokes-
woman Maria Oharenko in Los Angeles said late
Tuesday that "we turned in to the EPA all the sites
we were aware of." !
Burleson also recently revealed In a television
Interview an eighth burial site near Bee Tree Creek
several hundred yards from the Chemtronics prop-
erty.
The waste site along U.S. 70 begins beside a
propane gas company and extends eastward in a
vacant field, he said.
EPA official Jim Orban said he expects to learn
about more waste sites as EPA's investigation contin-
ues.
"If there's a reality to these seven sites." Orban
said. "It adds more work, it adds more time to the
• cleanup." i
-------
Next £
aste'
Companies May
Hire Contractor
By G. DALE NEAL ' *.' '
Staff Writer . .
^ The next slop in the cleanup of
hazardous waste at the Chcmtronics
plant in Swannanoa may be taken by
ihe companies responsible for bury-
ing the toxic materials, Environmen-
tal Protection Agency officials said
Tuesday. --'
|j Chcmlronics Inc. and Northrop,
•a former owner of the site, may offer
.to hire a contractor to investigate
the 23 burial sites on the 1,037-aere
facility and devise a feasibility study.
Vo clean up the toxic wastes, accord-
ing to Jim Orban of the EPA regional
office in Atlanta.
.1 •'. The ' alternative would be for
EPA to contract-with Camp, Dresser
and McKee to do the.work, Orban
told the some 75 local residents at-
tending the public meeting at Swan-
nanoa Klemonlary School.
The Chcmlronics site was cited
on the EPA's original 1982 Supcrfund'
list as one of .the nation's most dan-
gerous toxic waste dumps, largely on
the basis of acid lagoons that drained
away years ago. •
Last fall. EPA officials learned
that BZ, a.powerful LSD-like hallu-
cinogen, •• was manufactured for
Army chemical warfare stockpiles
during the 1960s by Amccl Propulsion
dnd Northrop — former owners of
the facility.
Mary Leslie of Camp, Dresser
ilnd McKce outlined the informalion
gathered so far in the proposed work
plan for the Chemlronics site.
••£ In 'the next phase, samples will
be taken from deep wells to deter-
rfcine the.extent of groundwaler con-
tamination. Trenches will be care-'
fiilly dug through fields where drums
df waste from BZ and CS tear gas
arc buried, Leslie said.
* Given the fractured bedrock of
tnc area, locating the flow of any
contamination through Ihe ground-
water will be difficult. "Can we find
it, can we collect it, can we treat it?
These are the critical answers we
don't have yet," she said.
! To date, no contaminants from
the Chemtronics site seem to have
migrated into neighboring wells, the
officials said. There are contami-
nants in the Charles 1). Owen Co. in-
dustrial wells, but those have been
traced to another source.
•; -Not all of the toxic waste may
be removed in the final cleanup,
Qrban said. ' •
Copies of the EPA work plan for
the. Chcmlronics site are available
for. inspection al the libraries of War-
ren Wilson College and Ihe Univer-
sity of North Carolina at Ashevillc.
The EPA will take public comment
$n the drall plan until April 19.
After a final work plan is ap-
proved, the field work on sampling
the disposal sites should begin within
-------
Section .;
fthr (Charlotte (Observer
'.—Saturday,.. March 30. 1985
EPA Might
BZ
^p •-• --A-' - ....,:-.• • "... - • C?**_-
•1 o Army bite
' ""' " *
fly TEX O'NEILL
And JACK HORAN
. The Environmental Protection Agency (EPA) Is
considering digging up chemical wastes At a former
chemical warfare production site near Ashevllle and
disposing of them at an Army facility, according to a
draft plan to clean up the contaminated site.
"fThe proposal Is one of five the EPA Is considering
to dispose of various wastes. Including BZ. a halluci-
nogenic compound, and tear gas. both made for the
Army in the 1960s/ They were left after nearly 30
years of manufacturing at the site, now owned by
Chemtronlcs Inc. near Swanhanoa In Buncombe
County. •'-• .".-.,_>.•..
''The plan. Indicates the EPA may run Into difficulty
If It tries to dispose of the wastes at two hazardous-
waste landfills In Alabama and South Carolina.
' "Initial Inquiries into potential offslte disposal fa-
cilities (Pinewood, S.C., and Emelle, Ala.) have Indi-
cated that acceptance of the BZ wastes, with or
without neutralization, may be a problem," the draft
says. "This may necessitate transporting the wastes a
much greater distance from the site, thereby substan-
tially Increasing the cost of disposal." No dollar
figures are cited for the various disposal scenarios.
.. The draft suggests the wastes might be excavated,
placed in containers and taken to the Army's Pine
Bluff, Ark., arsenal.. •'.••. • ••-
at^
rfl
tw?
••The draft plan Is a guide for the EPA's site
investigation, wntch Involves taking samples and
determining the scope of the cleanup. After complet-
ing that Investigation within 15 months, the 'actual
cleanup can begin. •• .
In January. The'' Observer reported that wastes
from manufacturing 3-qulnuclldinyl benzilate, a hal-
lucinogen known as BZ, may not have been properly.
' neutralized before burial at the site. Inhalation of
only. a speck of BZ can cause up to seven days of
dlsprlentation and- hallucinations limilar to those
caused by LSD.
. The Buncombe County' site- was placed on the
EPA's cleanup list in 1982 because of groundwat
contamination apparently unrelated to the BZ pr
ductlon. BZ was manufactured for the Army by
previous owners of the Chemtronics site. Chemtron-
lcs';does not produce chemical warfare agents.
'. Other proposals In the draft plan include collecting
and treating contaminated groundwater, containing
without treatment all wastes in a landfill on the
,1,027-acre site, and doing nothing.
1 The "ho action alternative." the work plan says.
Isn't acceptable, given the level of site contamination.
.-.Although about 150.000 pounds of BZ was pro-
duced for the Army by two previous owners of the
Chemtronics site, the Army has said It will not accept
responsibility for disposal of waste from BZ produc-
tion.
.'• BZ waste is believed burled in 300 to 500 drums in
(our or five landfills at the site. Both the Army and
the EPA have said there is no imminent danger to the
public from BZ.
-------
EPA probes LSD-like chemical in dump
_ . /"v « I / 51 / i S" *
United Pita Inlernalkxwl
ASHEVILLE, N.C. - Officials are
seeking to determine If waste from a
chemical warfare agent so powerful that
one speck can cause a seven-day LSD-like
trip is dangerous 20 years after it was
burled by the Army in landfills.
The Environmental Protection Agency
is questioning workers who buried the
waste from a chemical known as BZ, or
3-quinuclidinyl benzilate, near Asheville in
the 1960s.
Experts say the chemical Is so strong
a tiny speck can produce seven days of
disorientalion and hallucinations similar
to those caused by LSD. . ' •
BZ was made In strict secrecy for the
military by two companies on the site of
the present Chemtronics Inc. plant, one.
mile north of where some 300 to SOO
drums of the waste are buried in two
landfills, the Charlotte Observer reported
Sunday.
Chemtronics does not produce chemi-
cal warfare agents.
Neither Army nor EPA officials could
be reached for comment But an Army of-
ficial raised concern at a meeting in Sep-
tember, saying BZ waste may not have
been fully neutralized by a "kill solution"
before being buried.
"He wasn't sure," said the EPA's Den-
nis Manganiello, who attended the meet-
Ing with Army official Neil Baker. "He
was talking about the worst possible case.
If BZ wasn't in a certain form, it would
be very dangerous to handle. If it was in-
ert or co-mingled win other materials, it
wouldn't be as dangerous."
The landfills are on the Superfund
hazardous waste cleanup list, and the
EPA started interviewing former employ-
ees last week to determine how they dis-
posed of the chemicals. Officials said the
Investigation will take at least a year be-
fore any hazardous wastes are removed.
The EPA has not estimated cleanup
costs, but an official at Chemtronics said
it would take five years and $5 million if
active BZ is found.
Military officials, however, say the BZ
waste, even if active, poses no immediate
danger t.o the public because it is
underground.
Amcel Propulsion Co., a subsidiary of
the New York-based Celanese Corp., and
Northrop Inc., a Los Angeles-based air-
craft manufacturer, produced 150,000 '
pounds of the chemical from 1962 to 1966 {
at the site. '
The BZ waste Is part of a legacy of ^
Army efforts dating to the 1950s to ex-
pand chemical warfare stockpiles, which
it maintained since World War L »
The Army became interested In BZ
because, unlike nerve gas, it does not kill |i
or Injure. The drug wears off in one to E
seven days. ti
-------
EPA probes chemical young
warfare site danger
FROM 1A
Unittd Prtts tnternjlionjl
ASHEVILLE, N.C. - Officials
are seeking to determine whether
waste from a chemical warfare
agent, so powerful that one speck
can cause a seven-day LSD-like trip,
is dangerous 20 years after it was
buried by the Army in landfills-.
The Environmental Protection
Agency is questioning workers who
buried the waste from a chemical
known as BZ, or 3-quinucIidinyl ben-
zilate, near Asheville in the 1960s.
Experts say the chemical is so
strong a tiny speck can produce
seven days of disoricntation and
hallucinations similar to those
caused by LSD.
BZ was made in strict secrecy
for the military by two companies
on the site of the present Chcmtron-
ics Inc. plant, one mile north of
where some 300 to 500 drums of the
waste are buried in two landfills,
the Charlotte Observer reported
Sunday.
Chemtronics does not produce
chemical warfare agents. . .
Neither Army nor EPA officials
could be reached for comment. But
an Army official raised concern at
a meeting in September, saying BZ
waste may not have been fully neu-
tralized by a "kill solution" before
being buried.
"He wasn't sure," said the
EPA's Dennis Manganiello, who at-
tended the meeting with Army offi-
cial Neil Baker. "He was talking
AT&T posts
$1.4 billion
profit in '84
From Wire Reports • - -
NEW YORK - American Tele-
phone & Telegraph Co. said today
that it earned less than expected in
the first year after divestiture but
still posted a.profit of almost $1.4
billion.
The telecommunications giant
earned 11.379 billion, or $1.25 per
share, on revenue of 133.19 billion
in 1984.
about the worst possible case. If BZ
wasn't in a certain form, It would
be very dangerous-to handle.'If it
was inert or co-mingled wih other
materials, it ,: wouldn't be as
dangerous."- . ••'-: .-..:,.. .j-. ••:,
The landfills'are on the Super-
fund hazardous waste cleanup list,
and the EPA started interviewing
former employees last week to de-
termine how they disposed of the
chemicals. Officials said the investi-
gation will take at least a'year be-
fore ,any hazardous'iw'a'stcs arc
removed. • >' •£ : v.
The EPA has not estimated
cleanup costs, but an official at
Chemtronics said it would take five.
years and $5 million if active BZ is
found.
Military officials, however, say
the BZ waste, even if active, poses
no immediate:! danger to the public,
because it is underground.
Amcel Propulsion Co., .a subsid-
iary: of the New'.York-based Celan-
ese Corp., and Northrop Inc., a Los
Angeles-based aircraft manufactur-
er, produced 150,000 pounds of the
chemical from 1962 to 1966 at the
site.
The BZ waste is part of a lega-
cy of Army efforts dating to the
1950s to expand chemical warfare
stockpiles, which it has maintained
since World War I.
The Army became interested in
BZ because, unlike nerve gas, it
does not kill or injure."! ..-. .
bcr, they'll say he hasn't done
anything,"
.Indeed, the $130 million Under-
ground Atlanta entertainment com-
plex and the $25 million renovation
of the beleaguered Atlanta Zoo rc-
'.. mainVon the "to-do" list. Those and
- othcrL'.downtown development pro-
jccts were mentioned in Young's
speech. But the best he could say
. about them was that plans were
• progressing well. :
.So Young and his staff put tb-
. gether a .list of ..facts, figures and
v trends.that he ticked off to the
. council- in his first prepared-in-ad-
: vance State of the City address. And
•although the,mayor was clearly less
'•• comfortable than he is in his usual
. .speaking mode and although thus
far he has no publicly declared
•••challenger, Young-'went on record
with some figures that are likely to
be recited agajri when the re-elec-
tion campaign is under way.
He talked, among other things,
.". about the 25,000 new jobs, the $1
billion worth of building permits,
the visits to Atlanta by six foreign
.. heads of state, the growing interna-
tional service industry, the new
sewer treatment system, the drop-
ping crime rate and the Davis Cup
tennis tournament.
Imagine his staff's frustration
when the same old complaint re-.
bounded out of .the council cham-
bers: "visionary without specifics."
Council "members charged that the
.mayor talked about what he wanted
to .do in-the future — urge develop-
ers to Work on more of a pedestrian
,,j scale, spread economic progress to
HENRY1
sets theft
the South:
and encot
ticipation
members
without c
accompli'
Altho
Officer 1
was inte
fact it de
since Y<
more thi
Eve:
cited dr.
critics,-
economi
wave of
the city1
is part i
COU!
plained
host of
little, to
in his i
-------
Chemical Weapon Waste Buried
i.
•"• TENNESSEE ! Vtf
SUN M»o Br EARNEST HART
hemlcal Dump: BZ waste is buried jn two landfills at the
present Chemtronics Inc. plant a mile north of Swannanoa.
The substance was made for the Army 20 years ago.
Secret Project's Debris Might Remain Pote\
By JACK HORAN and TEX O'NEILL
Slid WrHtn
Waste from * powerful chemical warfare
agent produced for the Army 20 years ago Is
burled near Asheville and may still be danger-
ous. The Observer has learned.
The chemical Is a hallucinogen known as
BZ. It is so powerful that only a speck can
produce seven days of dlsorientation and hal-
lucinations similar to those caused by LSD.
BZ was made in strict secrecy on the site of
the present Chemtronics Inc. plant, where the
waste is buried In two landfills. Until now,
most people didn't know the chemical warfare
agent was produced there.
.An Army official raised concern in Septem-
ber that BZ waste may not have been fully
neutralized by a "kill solution" before burial
and could remain potent.
"We were told unofficially by the Army
that that particular solution didn't always kill
BZ," said Chemtronics President John Schul-
theis. "We were led to believe that since the
days of (previous owners) Amcel and North-
rop, that ratio of kill solution to waste mate-
rial had been insufficient"
Federal officials say, however, that the BZ
waste — even If active — poses no immediate
danger to the public because It remains under-
ground. .
The U.S. Environmental Protection Agency
(EPA) plans to sample the landfills containing
an estimated 300 to 500 drums of BZ waste for
active BZ: The EPA Is involved because the
landfills are on a "superfund" hazardous-
waste cleanup site.
The BZ waste at the Chemtronics site • mile
'north of Swannanoa is a legacy of Army ef-
forts dating to the 1950s to expand chemical
warfare stockpiles, which it maintained since
World War I.
For reasons that are still classified "secret."
the Army ordered "urgent" production of the
odorless, white powder la 1961. The BZ — for
3-quinuclidinyl benzilate — v
bombs at an Arkansas arsenal. 1
over enemy troops, it would ter
pacilate the enemy soon after ini .
In all, two manufacturers pro
pounds of BZ from 1962 to 1966
according to strict Army specific
the Army disclaims any liabilit
up the BZ waste, saying it's the
of the manufacturers.
The Army has offered techni
but manufacturers want -the mi
an active role in what could be
five-year cleanup of BZ and othei
The Observer also learned:
• A July 7. 1965, fire bume
1.000 pounds of BZ. To protec
crecy, plant officials depicted t
fire in the "jet fuel factory." Usii
that the fire could set off explo:
evacuated more than 2.000 resid
See CHEMICAL Page
-------
I* THE CHARLOTTE OBSEKVEK Sun<
ay. ii***rr n. lets ..
Chemical
Weapon Waste Buried Near Asheville
Page IA
alrborn contamination by BZ. No
oot wu Infured or tipowd (o BZ.
• Manufacturers required BZ
workers to pUy Ping-Pong during
Lie Ian two houri of itch work
shift 10 fUff nuries could delect
behavioral signs or cootaminsuon
and pUci any upoMd worktn la
a padded cell.
• • Despite airtight plastic BZ. The com-
pound caused reactions ranging
InuB mert dilation of thi eyu u
.IB Inddent la which oo« disori-
ented victim broke out of ihi
padded ctU. slugged * guard and
fled ihoeleu 10 nea/by woods.
The two BZ wute Undfllli «r«
located 00 I 1.027-tcrt, mountain-
out tract la the Swannanoa Villey
of euierv Byncomtx County. less
Una t mill from Warren Wilson
College. Tat BZ wu
-------
THE CHARLOTTE OBSERVER . Sunday. January 27. 1985 9A
Federal Cleanup Of Sites Planned
Continued From Preceding Page
-• The EPA said sampling had detected
62 hazardous organic compounds and 20
. metals in the waste pits, since closed,
and In the ground water • and. surface
streams. EPA said the compounds in-
clude cancel-causing agents such as vi-
nyl chloride and benzene and poisons
such as cyanide and mercury.
Chemtronlcs's Schultheis said no
breakdown products of BZ have been
/.found In the monitoring wells at the site.
• *J. Felice Johnson, director of environ-
•r mental affairs for Chemtronlcs, said the
contaminants would take 40 years to
* reach the nearest property at the cur-
- rent ground water movement rate.
•' •'••• Nevertheless, the EPA wrote last Sep-
• tember, "As a result of such release, the
* drinking water supply of an estimated
: 350 people.'and the recreational uses of
Bee Tree Creek (which borders the site)
: may be adversely affected."
; •• The EPA's Orban said the potential
-;: for contamination exists if the water
•: enters a geologic fault and moves rap-
'-' Jdly.
- Although the EPA's attention during
the past four years apparently focused
—on the groundwater contamination only,
Chemtronics's Schultheis told The Ob-
'~ server he was certain Chemtronlcs men-
• 'tloned BZ to the EPA during the 1980
'.'. site inspection. . .
"I said, 'You people are aware there
are more burial sites on the property
than acid pits and lagoons.'" He said
they were furnished with*a map of the
burial sites. ., ....
"I think the EPA was, in one sense,
burying their heads for a while," Schul-
theis said, "because all the media and
the public were focusing on the acid
pits."
An EPA report of the 1980 Inspection
noted a drum labeled "Riot Control
Agent CS-1 XXXX" but no mention of
BZ. CS refers to tear gas, made for the
Vietnam War.
The EPA's Bornholm said the EPA
first learned about the BZ In July, when
Jt received documents from Northrop.
EPA said it discovered the exposed BZ
drums last Aug. 23 during a site visit
and asked the Army to inspect them.
The Army sent Neil Baker; Capt. Paul
Jones and Sgt. Jeffrey Hatcher, mem-
bers of the Army's Technical Escort De-
tachment, from the Pine Bluff Arsenal;
and Ed Meseke, a civilian specialist in
BZ destruction, from the Edgewood Ar-
senal in Aberdeen, Md.
Joining them at the Sept. 6 inspection
was 'Manganiello, an
onscene coordinator
,'of the EPA's Emer-
gency Remedial Re-
sponse Branch; and,
for. Chemtronics,
. Schultheis, Johnson
and Leigh. Both
Schultheis and Leigh
had worked for Am-
eel and Northrop.
After the meeting,
at which Baker dis-
cussed the possibly Leigh
Ineffective neutralization. Johnson led
the two soldiers to the drums, which sat
upright in the woods behind Building
' 104. The drums were marked with yel-
low tape reading "BZ toxic" and "CS BZ
CS" when two Observer reporters vis-
ited the site three weeks ago.
The soldiers — wearing air-purifying
respirators and dressed in rubber gloves,
boots, overalls and aprons — collected a
• single sample. '••
Baker then asked Schultheis if Chem-
• ironies would put the drums in larger
drums' and escort them to the airport,
where they would be flown to Pine
'• Bluff for further testing..
Schultheis said he refused because he
wasn't licensed to transport hazardous
wastes. He said Baker then said the
Army might send a team back and heli-
copter the drums to Pine Bluff.
The Army didn't return.
On Nov. 16, the EPA's Bornholm
wrote Brig. Gen. Bobby Robinson, com-
mander of the Army Materiel Command
. In Alexandria. Va.. asking If the Army
would help test or remove the BZ waste.
"Because of the unknowns associated
with the buried BZ at this site ... ,"
Bornholm wrnte, "we need to arrange a
meeting :c ciara'y (ihc Defense Depart-
ment's) role."
^Robinson, who died Jan. 14. was In
charge of the command that oversees
chemical weapons at the Pine Bluff.
Rock Island an,d Edgewood arsenals. ,
Bornholm said that on Dec. 5 he met
with three Army officials from Aber-
deen, Richard Roux. Andrew Anderson
and Meseke, all members of the Army's
Toxic and Hazardous Materials Agency.
At this meeting, Bornholm said, the offi-
cials told him a review of production
contracts indicated all BZ had been
properly neutralized.
Recently, Roux told The Observer
that even if the waste wasn't disposed'
of properly, he thought there was no
active BZ because it was a chemically
unstable compound that would decom-
pose in water.
He said BZ has a five-year shelf life.
meaning the Army considers it to be
reliably potent for no more than five
years.
As part of its inquiry, the EPA last
week began interviewing former em-
ployees to determine how BZ wastes
and other chemicals were disposed of.
Bornholm.said the investigation will
take at least a year before any hazard-
ous wastes are removed. While the °^
Tias no estimate of how long the cle
will take or Its cost, Schultheis t......
mated it would take five years and cost
$5 million if active BZ is found.
Schultheis said because BZ was pro-
duced for the Army, he wants any BZ
waste incinerated at the Pine Bluff Arse-
nal. When completed, it will be the only
facility anywhere capable of destroying
the compound.
According to plans filed with the
State of Arkansas, the Army says the
incineration facility is necessary because
"as the munitions age, deterioration is
inevitable, hazardous conditions may
arise, and the item may become increas-
ingly unstable."
The plans call for incinerating BZ and
BZ-filled munitions as well as wooden
containers and wastewater contami-
nated by BZ.
"Anything that has potential contact
with BZ, Including wastewater. is incin-
erated," said Schultheis of the Pine Bluff
facility. "It sort of belies the other ap-
proaches as being acceptable. They're
sort of talking out of both sides of their
mouth."
-------
f Public meeting on
Chemtronics Tuesday
:::;:: Results of an extensive Feaai-
::bflity Study (FS) for the Cham-
>tronics Superfund site in Swan-
•'oanoa will be announced at a
'"public meeting at Owen High
;. School on T\iesday, Feb. 23
•Beginning at 7:00 p.m.
;."• The U.S. Environmental Pro-
• Action Agency (EPA) from Dis-
: trict IV in Adanta will conduct
•the meeting. EPA will detail
1 recommended remedial actions
• to clean up the aite. The alteraa-
; tivea considered by EPA range
! all the way from building caps
* -for contaminated areas to
* Sophisticated "ha*""**! 9oti•"• that if
several alternative remedies
were equally effective in terms
of cleanup, relative cost would
then be considered.
Each alternative will be pre-
sented at the public meeting on
February 23 at Owen High
School The public win be able
to ""k questions <*nd nuke com-
ments. Under the law, the public
then has three weeks to make
comments and record exceptions
tO the ERA'S
Alter the public comment per-
iod, the EPA will prepare a
record of dscision which will
document what will actually be
done to implement the cleanup
at the Chemtronics Site.
-------
EPA Unveils
Chemtronics
Cleanup Plan
JLteHiViutt CXii-avJ
By CLARKE MORRISON
SUM Writer
Incineration of contaminated soil and the removal
and treatment of tainted groundwaler arc two methods
being considered (or cleaning up dump areas at Cbenv
Ironies Inc. in Swannanoa.
The U.S. Environmental Protection Agency has
come up with recommendations for destroying or con-
taining the explosives, solvents, cyanide and other chemi-
cals at the former munitions plant.
But just what measures are used could depend on
the concerns raised at a public hearing on the plan next
Tuesday at Owen High School, said EPA project man-
ager Jon Bornholm.
Burning the chemical-laced soil would be the most
permanent, effective and costly solution. But If area resi-
dents express opposition to incineration, that option may
have to be scrapped, he said
In lieu of incineration, the EPA would allow the con-
taminants to remain at the various dumps scattered
around the 1,027-acre site, but would cap them with
layers of plastic, clay and other materials to prevent rain
from washing the chemicals Into the groundwater, Born-
holm said.
In addition, the plans call for groundwater at the site
to be pumped out of the ground through wells and treated
so It wont contaminate the drinking water of adjacent
areas, he said.
The Chemtronics site off Bee Tree Road was placed
on the Superfund national priority list in December 1982
after EPA testing revealed 62 organic compounds fend
metals in wells used to monitor the site. The plant was
constructed In the 1950s and has had several owners. Ex-
plosives, solid propellants, rocket motors and chemical
warfare agents were manufactured there for the mili-
tary, and the wastes from those operations were dumped
In landfills and pits around the property.
The powerful hallucinogen BZ and a form of tear
gas called CZ are among the hazardous wastes believed
to have been burled there. However, a nine-month study
found neither of the chemicals In the X200 samples taken.
The study was conducted with EPA
supervision by an environmental con-
sulting firm hired by Chemtronics
and Northrup Corp.. one of the previ-
ous owners of the plant
• A draft feasibility study for
cleaning up the site was submitted to
EPA in December, and the recomm-
mendations will be approved after
the comment period that begins with
the public hearing and ends March
18, Bomholm said.
The cleanup will cost approxi-
mately f 12 million if incineration is
used, and considerably less If it IsnX
he said
, "Incineration would be the most
permanent remedy," Bornholm said.
"Once you burn It, it's gone."
The cleanup probably will begin
this fall, and the on-site work will
take one to two years. However, the
pumping and treatment of groundwa-
ter will go on for up to 30 years. How
long the pumping is necessary will
depend on If and how much of the
contaminated material Is inciner-
ated, he said.
"The public comments could
have an effect on the remedy," Born-
holm said. "Incineration is a hot Item
up there in North Carolina right now;
and if significant numbers don't waot
Incineration then we will have to go
back and look at our other options."".
Another factor in whether the
materials are burned is the quantity
of explosives that are found, he said.
BUI wnaiever meuwos are useo,
the EPA Is confident the measures
will "adequately protect human
health and the environment," Born-
holm said.
However. Millie Buchanan of
Asheville, a staff member of the
Clean Water Fund of North Carolina,
said she Isnt convinced by Born-.
holm's claim.
"Either of these options involve
a loljof risk to the community, but
they fnay be the best we have," she
said. "Incineration has the potential
for some serious air pollution be-
cause of what they're burning. And
with icapplng you're talking about
leaving it there, and even though
they may take efforts to contain it,
there, is always the possibility of It
getting into the groundwater."
Buchanan said she and other
area •residents need more informa-'
lion ipn the proposed cleanup and
other available options.
1 After the public hearing. EPA
I win begin negotiations with Chem-
tronics. Northrup and the Celanese
Corp. j to pay for the cleanup. Born-
holm (said that if payment Is refused.
federal monies will be used and EPA
will sue the companies to force pay-
ment;
The healing will begin at 7 p.m.
In the auditorium of Owen High
School In Swannanoa. and the public
Is urged to attend.
i V •
-------
Wednesday, Feb. 24,1988
EPA Suggests
Incinerating Soil
At Chemtronics
By CLARKE MORRISON
Staff Writer
SWANNANOA - Plans to dig up and burn
contaminated soil and explosives at a former
military munitions plant were met with skepti-
cism by approximately 200 residents who at-
tended a public bearing on the proposal Tues-
day night.
Some told the Environmental Protection
Agency officials they should conduct a study on
cancer deaths they believe were caused by the
solvents, cyanide and other chemicals dumped
at various sites around the plant now occupied
by Chemuronics Inc.
Fears were ex-
pressed at the hearing at
Owen High School over
possible pollution from In-
cineration of the chemi-
cal-laced soil and drums.
Environmentalists
said they wanted the pub-
lic comment period,
which began with the
hearing and is to end
March 18, extended to
allow more study of the
EPA's plans.
-If you burn It, is it BORN HOLM
not going to go in the air? Will we not be
breathing It?" asked Cindy Whithers, who lives
near the plant. "I want to stay here. I dont
want to run. I dont understand what's going
Chuck Pielrosewicz of the US. Public
Health " -vice assured Whiters that an incin-
erator H never be licensed if study showed
Its tniL As would be hazardous.
"Whatever method we select will be pro-
tective of human health and the environment,"
he said.
"I'm concerned for myself and for my
whole family." said Jeanette Hensley of Long
Branch Road. "We'd like to get it cleaned up."
EPA Project Manager Bomholm told the
crowd that Incineration of the chemical-laced
soil would be the most permanent, effective
and costly solution. But if enough opposition to
the burning is expressed, the chemicals may
have to be left In the ground and efforts made
to merely contain them.
Charles Dennison, representing the Harri-
son Hill Road Committee, said there has been
an abnormally high number of cancer cases in
his neighborhood because of the contamina-
tion.
Dennison asked if there had been any
studies of cancer rates in the area. Pietrose-
wlcz said there was no evidence that any of the
chemicals had migrated off the site, so such a
study wasn't warranted
Allen Arnold of Black Mountain, a retired
chemist, asked why the contaminated soil and
drums couldn't be taken to an established off-
site incinerator for disposal. Bomholm said on-
site incineration would be just as effective and
far less costly. *—
EPA scheduled the public hearing to ex-
plain and get comments on the options for
cleaning up the various dumps scattered
around the 1,027-acre tract where explosives,
solid propellants, rocket motors and chemical
warfare agents were manufactured for the
military. A
Instead of removing and bin the soil,
Sff FPA
t From Page IB
EPA may decide to cap the pits and
landfills where the chemicals were
buried with layers of plastic, clay
and other materials to prevent rain
from washing the chemicals Into the
groundwaler, Bomholm said.
The plans also call for ground-
water at the site to be pumped out
through wells and treated so It wont
contaminate the drinking water of
adjacent areas, he said.
The Chemtronics site off Bee
Tree Road was placed on the Super-
fund national priority list In Decem-
ber 1982 after EPA testing revealed
62 organic compounds and metals in
wells used to monitor the site.
The powerful hallucinogen BZ
and a form of tear gas called CZ are
among the hazardous wastes be-
lieved to have been buried there.
However, a nine-month study found
neither of the chemicals in the 2,200
samples taken. The study was con-
ducted with EPA supervision by a
environmental consulting firm hired
by Chemtronics and the Northrop
Corp., one of the previous owners of
the plant
A draft feasibility study for
cleaning up the site was submitted to
EPA in December, and the recom-
mendations will be approved after
the comment period, Bornholm ;;?id.
The cleanup will cost approxi-
mately |12 million if incineration is
used, and closer to |2 millic • I it
isn't,'« said.
The cleanup probably wut begin
this luU, and the on-site work will
take one to two years. However, the
pumping and treatment of groundwa-
ter will go on for up to 30 years.
-------
Asl ndlle Citizen-Times
Views
Sunday, Feb. 14,1988 3D
Credibility Lacking On Waste
Your excellent editorial of ~
Feb. 3 (Another How-Not-To On Haz-
ardous Waste) should be required
reading for every state legislator and
regulator — and it wouldn't hurt
their federal cohorts to study it too.
State officials say they cannot
act for a year or more to correct
'Caldwell County's long-fuming incin-
erator problem, but in the meantime
they cannot tell neighbors whether
their children can safely play out-
side. Unfortunately, this situation is
not unique. Neighbors of hazardous
waste "Superfund" sites frequently
receive similar non-answers from
federal officials to their concerns
about their drinking water, their air
and their children's safety.
Those in charge of protecting
our health and environment seem
.totally incapable of comprehending
two basic facts: (1) there is a direct
connection between officials' current
and past actions and their future
ability to inspire the confidence of
the public; (2) without public confi-
dence, dealing with our hazardous
.waste problems will become increas-
ingly more difficult and eventually
impossible.
There are serious defects in our
environmental laws, the regulations
written to enforce them, and the
agencies responsible for that en-
forcement. Until these defects are
corrected, and until public health
takes precedence over corporate
pleadings and concern for the status
quo, the public will continue to op-
pose any siting of hazardous waste ERRS
facilities, with good reason. And our . r—»-"~»-—- — ——
hazardous waste problems will con-
tinue to mount.
Milll* Buchanan
Ashevilte
FTB1619S8
u 15
CPA - REGION IV
ATLANTA. GA.
-------
APPENDIX D
CONCURRENCES FROM STATE AND FEDERAL AGENCIES
AND OTHER EPA PROGRAMS
-------
Public Health Service
DEPARTMENT OF HEALTH & HUMAN SERVICES Agency for Toxic S-t-a-:-:
and Disease Rec.s-.ry
Memorandum
Date March 25, 1988
From Senior Regional Representative
ATSDR-EPA Liaison P^ ^ _EJL? ?
Subject ATSDR Health Assessment for the Chemtronics NPL Site;
Swannanoa, North Carolina
11
MAR 2 5 1983
TO Jon Bornhplm, Project Manager
EPA WMD Superfund Branch ~ w'"EP^'REGION
^s^T j/ / ATLANTA. GA.
thru Al Hanke, Chief ^Zs^p-***^
NC/TN Unit, Superfund Branch
EPA WMD
The Agency for Toxic Substances and Disease Registry has completed its
Health Assessment for the above NPL site. A copy of our assessment,
with attendant recommendations to address public health threat and
remedial action worker safety concerns is attached for your infor-
mation and use.
As our Health Assessment for this site is now final, the attached docu-
ment can become part of the EPA Administrative Record for the site and
is now available to the general public. You may also wish to share a
copy of our assessment with the PRP's for this site.
Our conclusions and recommendations are basically straight forward in
nature and have not changed in substance since the draft assessment
document which was shared with you earlier. However, if you would like
to discuss our assessment in more detail, please let me know.
Chuck Pietrosewicz
cc: file
ATSDR/OEA
DHHS/PHS Reg. Off.: Mr. Pesses
NC DHS: Dr. Ted Taylor
NC DHS: Ms. Lee Crosby
Buncombe Co. Health Dept.: Dr. James Tenney
Chemtronics Citizen Advisory Board: Mr. Pat Price
-------
Health
for
CHEMTRONHa* SITE
SWANNANOA. KTFRTH CAROONfc
MARCH 23U, 338-8
1
HI
£ P R 5
T"™>'~~"\
£i4m
MAR 2 4 138S
Lb
EPA - REGION IV
ATLANTA. GA.
-------
SUMMARY
The Cheocronics site is • 1027-acre National Priority Listing (NPL) site
located approximately 10 miles east of Asheville, in Svannanoa,
North Carolina. Numerous disposal areas on-site and 3 off-site areas
were investigated to determine the existence and/or extent of
contamination of soil, surface water, and groundwater. Potential
exposure pathways include ingestion and direct contact with soils and
inhalation of vind entrained dust from surficial soils, and to a minimal
extent, ingestion of contaminated groundvater and surface water. The
site may pose a significant public health threat to workers remediating
the site if proper training in the use of personal protective equipment
and measures to insure worker safety in accordance Occupational Safety
and Health Administration (OSHA) regulations and the National Institute
for Occupational Safety and Health (NIOSH) guidelines are not adequately
implemented. Groundwater from some residential (domestic) wells was
analyzed for site-related contaminants. Analytical results from these
off-site wells did not demonstrate the presence of contaminants above the
detection limits. However, various volatile organic compounds (VOC's)
that were found to be major site contaminants were not included in the
testing regime. The potential for area residents to be exposed to
on-site contaminants appears negligible at this time. Although it
appears that off-site migration of contaminants has not occurred,
sampling for VOC's should be performed on off-site area residential wells
as a precautionary measure.
-------
. BACKGROUND
In 1984, che U.S. Environmental Protection Agency (EPA) approached
Chemtronics. Incorporated and Northrop Corporation, as tvo potentially
responsible parties and sought a voluntary investigation. In 1985, an
Administrative Order of Consent vas signed and a Remedial Investigation
(RI) begun. The Remedial Investigation Report vas completed in April
1987 and the draft Feasibility Study vas completed in November 1987. A
Record of Decision is scheduled for 2nd quarter 1988.
The Chemtronics site is an active industrial plant located in a rural
area of the Svannanoa Township in Buncombe County, North Carolina. The
site is heavily vooded with steep terrain. The area east of the site is
bordered by Bee Tree Creek, to the north is the Pisgah National Forest.
to the vest the property line follows a mountain ridge, and to the south
is an industrial area. The property is naturally divided into tvo
valleys, the first valley is called Front Valley and the second, Gregg
Valley.
The site has had several owners/operators since it vas first developed in
1952. A variety of products have been manufactured at the site ranging
from explosives and rocket fuel to incapacitating agents and
pharmaceutical intermediates. By-products from these manufacturing
activities include chlorinated and non-chlorinated solvents, acidic
solutions and some metal plating vastes. The owner/operators are listed
in the Appendix along with dates of operation and products manufactured.
The RI identified 23 on-site disposal areas and
3 off-site disposal areas.' The off-site areas include 2 closed municipal
landfills: Tropigas and the Walnut/Buckeye Cove Landfill. The other
off-site area is the Asheville Dye and Finishing Gravel Pits, which is
adjacent to Chemtronics.
The Agency for Toxic Substances and Disease Registry (ATSDR) and the
Centers for Disease Control, Center for Environmental Health and Injury
Control (CDC, CEHIC) have been involved vith this site since early 1985.
This involvement not only included performing a Health Assessment but
personal interviews vith former employees vho have reported they vere
suffering from numerous health problems associated vith past employment
at the site.
ENVIRONMENTAL CONTAMINATION AND PHYSICAL HAZARDS
A. ON-SITE CONTAMINATION
There vere various waste disposal practices conducted on-site including
the burning of solid wastes in trenches or on concrete pads, placing
wastes into drums and burying them in trenches, and in more recent years,
the pre-treating and discharging of liquid wastes into the county sewer
system or into open pits and biolagoons. Table 1 provides a general
summary of the vaste disposal areas, estimated surface area, type of
disposal, and some of the contaminants found.
Page 2
-------
Disposal Area
Acid Pit Disposal Area
Areas 1-5 and 12-22
-120,000 sq.ft.
Disposal Area 6
•9.000 sq.ft.
Disposal Area 7/8
-19.000 sq.ft.
Disposal Area 9
-13.000 sq.ft.
Disposal Area 10/11
-27.000 sq.ft.
Disposal Area 23
-40.000 sq.ft.
TABLE 1
Description
Open Fit/Trenches
Trench/Landfill
drummed wastes
Trench/Landfill
drummed wastes
Trench/Landfill
drummed wastes
Trench/Landfill
drummed wastes
Tile drainfield
biolagoon
Disposed Wastes
acidic solutions.
nitrated organic and
other wastestreams
hydrolyzed BZ wastes
CS contaminated clothes
and wastes, wastes from
burning ditch
hydrolyzed BZ wastes, CS
wastes, cyanide wastes
hydrolyzed BZ wastes, CS
wastes, cyanide wastes
BZ and CS liquid wastes
Table 2 summarizes by disposal area the main contaminants, the media in
which the contaminant is found (soil, groundwater, etc.), and the maximum
concentrations.
TABLE 2J
Soil
fmg/kg)
46.0
9.8
0.8
Groundwater
9.2
9.2
0.05
Surfac
fmg/1)
ND2
ND
ND
Disposal Area/
Contaminants
Acid Pits
1,2 Dichloroethane
Trichloroethylene
2.4,6 TNT
Disposal Area 6
Presently, the reported concentrations of contaminants in this area
pose no public health concerns.
Disposal Area 7/8
t-1,2 Dichloroethylene
1,2 Dichloroethane
CS 3
Chromium
0.44
0.15
3100
'7 <57)4
0.07
4.3
ND
0.06
0.08
0.48
ND
trace
Page 3
-------
TABLE 2 fco
Disposal Area/
Contaminants
Disposal Area 9
Trichloroethylene
1,2 Diehloroethane
RDX 5
2.4,6 TNT
CS
Soil
Groundwater Surface water
Disposal Area 10/11
Toluene
1,2 Dichloroethane
RDX
Chromium
Disposal Area 23
1,2 Dichloroethane
Benzylic acid
3.2
1.8
220
280
370
21.000
0.032
290
NA
2.7
9.0
0.57
0.98
ND
ND
ND
NA°
0.15
0.013
0.54
7.4
470
0.30
0.48
ND
ND
ND
NA
0.40
0.01
trace
11
NA
1 Samples collected January through June 1986.
2 ND - Not Detected
3 CS - CS tear gas, (0-chlorobenzylidene malononitrile)
4 (X)- background level
5 RDX- explosive, hexahydro-1.3,5-trinitro-l,3,5-triazine
6 NA - Not Analyzed
7 Benzylic acid, a degradation product of BZ (3-Quinuclidinyl benzilace)
B. OFF-SITE CONTAMINATION
There were three off-site disposal areas identified: the Asheville Dye
and Finishing Gravel Pits, the Tropigas Landfill, and the Valnut/Buckeye
Cove Landfill. The Asheville Dye and Finishing Gravel Fits, Disposal
Area 24, is located adjacent to the Chemtronics property. Soil samples
indicate that toluene and trichloroethylene are the contaminants of
interest. The typical soil concentrations of toluene and
trichloroethylene in this disposal area, 0.005 mg/kg and 0.070 rag/kg,
respectively, are lower than the concentrations found at the other
on-site disposal areas. Metals, explosives, and priority pollutants were
not indicated as soil contaminants in this area.
The RI reported that Tropigas Landfill and the Valnut/Buckeye Cove
Landfill were sampled for CS and its degradation products only. These
analytes were not detected in any of the samples. The rational for the
limited sampling was the municipal landfills accepted industrial wastes
from other area businesses, thus the wastes which could be traced solely
to the Chemtronics site were CS and its degradation products. Samples
split with EPA were analyzed for other contaminants, including VOC's.
The results indicated there was no contamination by the analyte
compounds.
Page 4
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Anecdotal information indicates there may be groundvater contamination in
some off-site areas south of the site from sources other than
Chemtronics. This contamination may extend into the aquifers used for
drinking water and should be investigated for its extent and composition. •
DEMOGRAPHICS OF POPULATION NEAR SITE
*
The eastern property boundary is Bee Tree Creek and on the opposite side
and parallel to the creek is the paved Bee Tree Road. There are several
residences along both sides of this road and further north there are
residences on either side of the creek. These homes are located several
thousand feet avay from the disposal areas. The area south of the site
is an industrial area with several industries and approximately 1 mile
south is Warren Wilson College. West of the site is the most densely
populated and includes the Dillingham Circle subdivision. Hovever.
Dillingham Circle is separated from the site by the ridge extending south.
from Bartlett Mountain. North of the site is the Pisgah National Forest,
which is densely wooded and sparsely populated.
There are residences within several hundred feet of the off-site disposal
areas. The former Tropigas landfill has been proposed to be developed as
a mobile home park.
EVALUATION
A. SITE CHARACTERIZATION
Chemtronics, on-site, has been well characterised through adequate sample
quantities, sample point locations, and analyses from test pit
excavations, soil borings, groundwater. surface water, drainage sediment.
and monitoring wells. The hydrogeologic characteristics were
investigated using techniques such as seismic refractory surveys, and
vertical seismic profiling. Surface water and groundwater flow
quantities were calculated using data from local rainfall records and
stream gauges. A general hydrologic budget was then developed using
these estimated flow quantities.
Samples were taken from 10 private wells in various areas around the
site. Three of the wells were on Bee Tree Road and the others in
Dillingham Circle subdivision. The analyses performed on the samples
included CS, BZ, explosives, pH, and conductivity. This analytical
protocol was approved by EPA for investigative purposes; however, to
better determine potential health implications, a more complete regime is
required. Analyses for trichloroethylene, 1,2-dichloroethane, and other
volatile organic compounds which are the site related contaminants of
concern should have been included in the analysis program. Chemtronics
receives its drinking water and its process water from the city. There
are no on-site groundwater wells currently providing water to the
facility.
Page 5
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B. QUALITY ASSURANCE AND QUALITY CONTROL
The certificates of analyses portion of the RI were not included in the
data package. A review of Appendix P, Sample Inventory, indicated some
quality control samples were included in the analytical QA Program. The
quantity of the duplicate and split samples vere minimal, and there was
indication of only one spike sample (for VOA). The EPA QC samples appear
to have been submitted only twice during the investigation; once, at the
beginning of sampling in January and, again, near the end of sampling in
June. There was no data on the accuracy and precision of the duplicates
or spike.
Some of the contaminant levels were reported as "less-than-values" that
were greater than the National Primary Drinking Water Regulations MCL's
(Maximum Contaminant Level)5 and the Ambient Water Quality Crit.eria
(AWQC)6'7. For example, some trichloroethylene and 1,2-dichloroethane
concentrations in the groundwater samples from the disposal areas were
reported as <0.01 mg/1 and the MCL is 0.005 mg/1. By using inadequately
low quantitation limits and/or indescript nomenclature (ND -for none
detected), the concentrations of contaminants which exceed the MCL and/or
the AWQC may be reported as a° less than value (which itself exceeds the
MCL) or as none detected. The lower quantitation limit should be at
least the MCL value.
The Case Narrative, prepared by the contractor, was not included in the
data package. Also, the Data Review Summary, prepared by EPA, was not
included. Although there are data gaps in the RI, it is assumed the data
has been reviewed by EPA and has met their acceptability criteria.
Conclusions contained in this Health Assessment are based on the
information received in the data package. The accuracy of these
conclusions is determined by the availability and reliability of the
data.
C. ENVIRONMENTAL PATHWAYS
Soil, groundwater. surface water, sediments, and air were the media
sampled during the (RI). Air was not considered a significant pathway
because of the depths of disposal and the low mass of contaminants
exposed to relatively high volume of air under open conditions. Air
transported contaminated dusts is not considered a significant pathway
because the RI indicated that surficial soils were contaminated in only
one area at aoderate concentrations and none of the disposal areas were
barren. Disposal areas 6, 7/8, 9 and 10/11 had been reforested with pine
trees. The acid pits areas were seeded with grass; however, there are
some parts of the acid pits that are sparsely covered. This groundcover
acts to keep erosion by rain and wind to a minimum.
Page 6
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Consumable plants and animals are not considered significant pathways
because of the isolation of the site and restricted access. In addition.
the contaminated areas afford only a limited habitat for consumable
animals.
Identified environmental pathways consist of contaminated groundwater and
contaminated soils and surface water. The Chemtronics site is divided
into 2 watershed areas: the Front Valley, containing Disposal Areas
10/11 and 23, and Gregg Valley, containing Disposal Areas 6, 7/8, 9. and
the acid pits. Monitoring wells were installed in each valley such that
data could be collected concerning migration of contaminants from each
disposal area as well as collective migration as contaminants moved
dovngradient from the separate watershed areas. The monitoring wells
were installed in three zones: the shallow bedrock aquifer,
(75-125 feet); the Intermediate, (50-75 feet); and the surficial aquifer,
(20-60 feet). It was demonstrated through low volume pump testing that
the surficial and bedrock aquifers are hydraulically interconnected to
varying degrees. Bedrock core samples were analyzed for fracture zones.
These fracture zones were typically spaced 1-5 feet apart and generally
located in the upper 20-25 feet of bedrock. There Is potential for
contaminant migration further into the bedrock, however, the degree of
migration remains undetermined.
The possibility exists for contaminated groundwater to migrate into
deeper aquifers and move off-site into drinking water wells. However,
this environmental pathway appears unlikely for two reasons: separate
recharge areas and contaminant attenuation. The probable recharge area
for the residential wells across Bee Tree Creek is on the opposite side
of the valley from the disposal areas. The residential wells on
Dillingham Circle are separated from the disposal areas by a steep ridge
that acts as a surface water divide and probable groundwater divide.
Also, the majority of contaminants are expected to discharge into on-site
surface drainage with only a very limited portion expected to migrate
into deeper bedrock zones. Dilution and attenuation would be expected to
reduce the concentrations of the contaminants to below detection limits
before reaching any residential wells.
The private wells sampled ranged in depth from 100 to 270 feet, with
1 well extending to 600 feet. These wells are in different groundvater
recharge areas than the recharge areas containing the disposal sites.
The results indicated that for the analytes of concern tested for, none
were detected.
Data from Disposal Areas 10/11 and 23, (in Front Valley) show that some
groundvater and surface water contamination has occurred. The
contaminants at levels of health concern include 1,2-dichloroethane,
trichloroethylene, chromium, and trans-l,2-dichloroethylene. A
degradation product of BZ. benzilic acid, is also present in high
Page 7
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concentrations in the soil mt Disposal Area 23 (9.6 mg/kg) and in
groundwater wells at varying concentrations (1-470 mg/1). The migration
of contaminants dovngradient in Front Valley had not exceeded 800 feet.
Monitoring wells located in Gregg Valley close to disposal areas 7/8. 9,
and the acid pits (1-5, 12-22) show groundvater contamination at levels
of health concern for 1,2 dichloroethane, trichloroethylene and
chromium. The data indicates these pollutants are migrating generally to
the southeast and have migrated less than 600 feet from the disposal
areas. None of the analytes were detected in the monitoring wells
located further dovngradient.
No analytes of interest were detected in any of the surface water samples
downstream from the acid pit disposal area. However, immediately
downstream from Disposal Areas 7/8 and 9, the analytes
1,2-dichloroethane, trichloroethylene, and trans-l,2-dichloroethylene
were found at levels of health concern. These analytes were not detected
at any sampling points further downstream.
Disposal Area 9 was the only area at the Chemtronics site that exhibited
high levels of surficial soil contamination. The analytes of highest
concentration were CS and the explosives TNT and RDX.
D. HUMAN EXPOSURE PATHWAY
The population at risk to exposure of on-site contaminants consists of
three major groups: 1. Remedial workers responsible for site cleanup,
2. Persons having direct access to the site such as employees of
Chemtronics and, 3. Those individuals who trespass on Chemtronics
property and may enter the disposal areas.
Soils
Direct contact and ingestion of contaminated surficial soil and
inhalation of dusts around Disposal Area 9 are the most probable routes
of human exposure. The contaminants of interest are CS and the
explosives TNT and RDX. Although surficial soils are apparently
contaminated in only one area, the subsurface soils from all areas are
contaminated to varying degrees. The same exposure pathways exist for
subsurface soils as for surficial soils if remediation activities involve
excavation of contaminated areas.
Surface Water
On-site surface water immediately downstream from the disposal areas was
found to contain several contaminants at levels exceeding the drinking
water standards (MCL) and the Ambient Water Quality Criteria. Although
these on-site streams are not used for recreational purposes, ingestion
of and/or direct contact with surface water in these areas may lead to
exposure.
Page 8
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Groundvater
It does not appear that off-site migration of contaminants has occurred
through groundvater. However, the major site related contaminants of
concern (VOC's) were not included in the testing regime performed on
off-site private domestic veils.
Although on-site groundvater is not being used •• a drinking vater
supply, human exposure could occur if future property ovners installed a
drinking vater veil. Fate and transport of groundvater contaminants
cannot be adequately defined to predict vhen groundvater contaminant
concentrations vould fall belov health concern levels.
Remediation Activities
Consideration of the remedial alternatives should include attention to
potential exposures to the vork crevs. If a remedial action is chosen
that involves the excavation of disposal areas and/or the buried drums,
extreme care should be exercised. The condition and contents of the drums
are unknown and their removal may result in exposure to contaminants
through leaks or ruptures. Proper training in the use of personal
protective equipment and vorker safety in accordance vith OSHA
regulations and the NIOSH guidelines is necessary.
PUBLIC HEALTH IMPLICATIONS
The vastes of primary concern are the VOC's: trichlorbethylene and
1,2-dichloroethane. These contaminants are found in high concentrations
in the subsurface soil and groundvater in virtually all disposal areas.
The contaminants CS, BZ, and the explosives TNT and RDX vere detected in
varying concentrations in the disposal areas and require consideration,
primarily during remediation activities. Although a high concentration
of toluene (21.000 ppm) vas detected in the soil at Disposal Area 10/11,
it appears to be isolated and of little concern. In general, the
subsurface soils and groundvater are of primary concern, vhile the
surficial soils, vith the exception of Disposal Area 9. indicate little
or no contamination and therefore, are of minimal concern.
Workers involved In the remediation of the site are the major population
at risk. Direct contact of site related contaminants is the major
exposure pathway. Inhalation (and ingestion) of dusts entrained by
vinds, particulates and volatile contaminants are other potential routes
of exposure. Ingestion of groundvater is not presently a public health
concern because there are no drinking vater veils on-site. the drinking
vater and process vater is purchased from the city. Hovever. groundvater
vould be of health concern if it vere to be used for any purpose.
Page 9
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Adequate and appropriate use of personal protective equipment together
vith proper adherence to worker safety precautions (to include industrial
hygiene monitoring for site related contaminants during remediation) will
reduce the risk of exposure and possible adverse health effects in these
workers.
Several contaminants detected on-site warrant health concern more for
remedial workers than the general public. They are discussed below to
insure workers are adequately advised on potential hazards.
BZ is an anticholinergic substance that has a pharmacological activity
approximately 5 times that of atropine. The effective dose level (human)
is approximately 5.0 ug/kg which may produce incapacitation,
disorientation. and/or disruptive effects on attention span,
comprehension, and memory. The duration of these effects may be as long
as 96 hours. The ADI.for chronic exposure is 0.5 ug/kg/day. The
results of the analyses for BZ and its degradation products were somewhat
implicit as to whether the parent compound, BZ, was detected at any of
the disposal areas. There were specific results for the degradation
product benzilie acid. All of the wastes associated with BZ production
were presumed to be decontaminated prior to disposal. While BZ
contamination is not explicitly indicated as a problem, there is the
potential of exposure to BZ from drums which were not decontaminated, if
remedial actions involve excavation.
The chemical agent CS has been used extensively for riot control. This
compound acts on sensory endings in the eyes and upper respiratory tract
and is extremely irritating. Dermal contact and/or inhalation may cause
lacrimation, conjunctivitis and pain in the eyes, irritation and runny
nose and coughing, excessive salivation, and a burning sensation of the
skin. These symptoms may persist as long as 30 minutes after exposure to
the compound. The current OSHA and American Conference of Governmental
Industrial Hygienists (ACGIH) ceiling value is 0.4 mg/m3 and the
Immediately Dangerous to Life or Health (IDLH) level of 2 mg/m.
Remediation of some areas could expose workers to this contaminant at
levels of health concern.
Dermal exposure to TNT or RDX may cause irritation of the eyes, nose and
throat, along with sneezing, coughing and sore throat. Ingestion of high
levels can cause drowsiness, dyspnea, and aethemoglobenia with cyanosis.
Ingestion of 1-2 grams of crystalline TNT can be fatal. The
Acceptable Daily Intake (ADI) for RDX and TNT is 0.003 mg/kg/day and
0.004 mg/kg/day, respectively11. Given the characteristics of the
site, it is not likely that contact with the reported concentrations in
the soil and groundvater would lead to exposures that exceed these
ADI'S.
Page 10
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On-site TCE groundwater concentrations greatly .exceeded EPA lifetime
Drinking Vater Equivalent Level (DUEL). The EFA's lifetime, health
advisory value of 260 ppb considers the noncarcinogenic adverse health
effect* associated-vith TCE exposure. Acute toxicity effects could be
realized from ingestion of groundwater contaminated at the maximum'level
found. In addition, TCE has been demonstrated to be carcinogenic in
animals. However, there is insufficient data to indicate carcinogenic
effects in humans. Using an EPA risk assessment model based on a
carcinogenic endpoint from TCE exposure, on-site groundwater
concentrations exceeded the level associated vith a 10 excess
lifetime cancer risk. Using the reported maximum concentration
(9.2 mg/1), the EPA carcinogenic potency factor and the assumptions
below, the excess lifetime cancer risk is estimated to be greater than
1 x 10" . The risk assessment models for TCE assume that a 70 kg
person would consume 2 liters of contaminated well water (of which there
is 100 percent absorption in the gastrointestinal tract) per day for a
70-year lifetime exposure. Therefore, any exposures to on-site
groundwater would warrant considerable health concerns.
Off-site migration of contaminants
Soil samples from the off-site disposal areas indicates there is no
contamination present which is traceable to Chemtronics. Although TCE,
as well as other VOC's, were not included in testing program for the
10 private residential wells off-site, the results for other site related
contaminants were none detected. Groundwater and surface water samples
from Chemtronics indicate there is no off-site migration by any of the
contaminants.
Although it appears that off-site migration of contaminants has not
occurred, VOC contamination of off-site area residential wells may be a
significant exposure pathway for residents using well water for potable
purposes and therefore, a potential public health threat.
.CONCLUSIONS AND RECOMMENDATIONS
Contaminants specific to the Chemtronics site were not detected in the
off-site disposal areas. Therefore, off-site disposal areas are not
considered to present a potential for public exposure to
Chemtronics-related contaminants.
The potential human health concern from exposure to on-site contaminants
to area residents appears negligible at this time. It appears that
off-site migration of contaminants has not occurred and the complex
hydrogeology of the area indicates a low probability of VOC migration to
residential wells. However, analytical procedures were inadequate to
confirm or deny VOC contamination.
Page 11
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Anecdotal information indicated that sources other than Chemtronics may
be generating VOC contamination of the drinking water aquifer.
Therefore, VOC contamination of residential veils may be a potential
public health concern, but not necessarily caused by the disposal actions
.of Chemtronics.
The site may pose a significant health threat to workers remediating the
site if proper training in the use of personal protective equipment and
measures to insure worker safety in accordance with OSHA regulations and
the NIOSH guidelines are not adequately implemented.
Recommendations are as follows:
1. Sample area residential wells for VOC's as a precautionary measure, to
ensure that the drinking vater is not contaminated (by Chemtronics or any
other source). As necessary, develop and implement long term groundwater
monitoring programs for the site and area residential wells.
2. Implement remedial actions to eliminate the source of contamination.
3. Place institutional controls on the site to prohibit future
installation of drinking vater veils on-site, if groundwater
contamination is not remediated.
PREPARERS OF REPORT
Max M. Hovie. Jr.
Environmental Health Specialist
Health Sciences Branch
John Abraham, Ph.D., M.P.H.
Environmental Health Specialist
Health Sciences Branch
Page 12
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REFERENCES
1. Remedial Investigation, Chemtronics Site, Svannanoa, North Carolina,
Medcalf and Eddy. April 1987.
2. Draft Feasibility Study, Chemtronics Site, Svannanoa, North Carolina,
Sirrine Environmental Consultants, November 1987.
3. Memorandum and attachments. From: Public Health Advisor, ATSDR-EFA
liaison. To: EFA. et al, Chemtronics CERCIA Site. July 1986.
4. Superfund Record of Communication, Personal communication between Jon
Bornholm (EPA) and Max Howie (ATSDR), January 11. 1988.
5. EPA National Interim Primary Drinking Water Regulations.
December 24, 1975.
6. EFA Ambient Water Quality Criteria for Chlorinated Ethanes, Office
of Water Regulations and Standards, Criteria and Standards Division,
Washington, DC, 1980.
7. EFA Ambient Water Quality Criteria for Trichloroethylene. Office of
Water Regulations and Standards, Criteria and Standards Division,
Washington, DC, 1980.
8. Title 29, Code of Federal Regulations, 1987 edition. Part 1910,
General Industry Standards: Occupational Safety and Health Standards.
9. Possible Long-term Health Effects of Short-term Exposure to Chemical
Agents, Vol. II, Committee on Toxicology, National Research Council,
1984.
10. Dreisbach, R.H., Robertson. W.O., Handbook of Poisoning, 12th
edition, Appleton and Lange, 1987.
11. Etnier, E. Water Quality Criteria for Munition Compounds. Oak Ridge
National Laboratory, Oak Ridge, Tennessee, 1986.
12. EPA Superfund Public Health Evaluation Manual, EPA/540/1-86/060,
Office of Emerengcy and Remedial Response, Washington DC, 1986.
Page 13
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Site Owner
Oerlikon Tool and Arms
Corp. of America
Oerlikon Tool and Arms
Corp. of America
Oerlikon Tool and Arms
Corp. of America
Celanese Corporation
of America
Celanese Corporation
of America
APPENDIX
Site Operator Date
Same
Site Use
Same
Amcel Propulsion,
Inc.
Amcel Propulsion,
Inc.
Celanese Corp.
of America
1952-'56 propellants, control
devices,' explosives
1956-'59 Site not used
1959
Site not used
Northrop Corporation Northrop Carolina
Northrop Corporation
Chemtronics, Inc.
Airtronics, Inc.
Chemtronics Div.
Chemtronics, Inc.
1959-'62 explosives, flares.
rocket motors,
incapacitating agents
1962-'65 explosives, flares,
rocket motors,
incapacitating agents
1965-'71 manufacture chemicals,
explosives, propulsion
devices
1971-'78 rocket motors, fuels,
speciality chemicals,
flame-retardant, fuel,
speciality chemicals,
pharmaceutical inter-
mediates, high-temp.
explosives
1978- to decontaminating kits,
present speciality chemicals,
high-temp, explosives,
pharmaceutical inter-
mediates, synthetic
musks, flame-retardant
chemicals
Page 14
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United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
RICHARD B. RUSSELL FEDERAL BUILDING, SUITE 1320
75 SPRING STREET, S.W.
ATLANTA, GEORGIA 30303
AprilS, 1988
ERRB
ER-88/198
APK \ 3 198G
SPA - REGION IV
ATLANTA. GA.
Jon Bornholm
Superf und Branch
Environmental Protection Agency, Region IV
345 Courtland Street
Atlanta, GA 30365
Dear Mr. Bornholm:
The Department of the Interior has reviewed the draft Record of Decision (ROD) for the
Chemtronics Superf und Site in Swannanoa, N.C. as requested. We have the following
comments to offer.
Water Resources
We have found that the document does not clearly state I) whether or not the treated
groundwater will be discharged to the streams at the site or to a treatment plant
facility, 2) whether remediation is for the groundwater in the surficial aquifer, the
bedrock aquifer, or both, and 3) which treatment processes are being proposed or
considered for the ground water clean-up. Because of these uncertainties, how can a
price for the clean-up be adequately determined?
In Section 3.6, the text reads that "analyses of ...sediment samples indicate contaminated
baseflow." This is unclear. The sediment particles are not being transported from the
groundwater body, but they may be transported by overland surface water runoff. Is
there evidence that sediments may be picking up contamination from groundwater
discharge?
It is not clear how sediment discharge in runoff is to be controlled during runoff events
at site DA-23 during fixation and stabilization.
Fish and Wildlife Resources
The recommended alternative (Page 64, Section 6.0) for the site is not identified by the
description codes provided in Table 22. However, it appears that alternative 4B will be
selected for the soil remediation and alternative GWE-2 will be selected for the
groundwater remediation. Fish and Wildlife Service would concur with the selection of
these two alternatives.
-------
The Service would like to request additional information regarding the surface water
bioassays: I) type of bioassays (e.g.,' chronic, acute, organisms), frequency of the
bioassays (e.g., quarterly, annually) and the length of time for which bioassays will be
used as a monitoring tool (e.g., 5 years, 10 years, 30 years). In addition, the Raleigh
Office of the Fish and Wildlife Service would also like to request copies of all bioassay
results as they are completed.
Under the proposed alternative for groundwater remediation, the point of discharge for
the treated groundwater will not be determined until the Remedial Design stage. In the
event that the treated groundwater is discharged into a stream instead of a wastewater
treatment plant, the Fish and Wildlife Service requests that bioassays on the treated
effluent also be conducted to ensure the absence of toxicity.
Thank you for the opportunity to review this document. If you have question, please give
me a ca11 at 331-4524.
Sincerely,
James H. Lee
-------
Dace:
Subject:
From:
To:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
349 COUMTUAND STRICT
ATLANTA. OCOMGIA JOJ«3
APR 11 1988
Record of Decision (ROD) for che Chemcronics Site,
Swannanoa, North Carolina ^ ^
James S. Kutzman, Chief
Ground-Water Protection Branch /
ERRS
J
Patrick M. Tobin, Director
Waste Management Division
APR 111338
UUIStoTSUU 15
LPA - REGION IV
ATLANTA. GA.
The ROD for the Chemtronics Site has been reviewed by my staff. We have
participated in the review and evaluation of Che Remedial Investigation
and Feasibility Study reports for this sice and also attended the Public
Hearing in Swannanoa on February 23, 1988. Excavation and incineration of
all drums and contaminated soils from all of Che disposal areas coupled
with extraction and treatment of Che contaminated ground water in both the
Front Valley and Gregg Valley is a permanent remedy for the sice and the
best alternative for long-term protection of human health and Che
environment. We acknowledge that significant public opposition Co Che
proposed excavacion and onsite incineration of druas and contaminated
soils was expressed at che Public Hearing. We also regard the possible
presence of ordnance in DA-6, DA-7/8, DA-9, and DA-10/11 as a potential
risk to'the health of workers who would be exposed during excavacion of
che drums and contaminated soils from Chese areas. Therefore, we concur
with the ROD that if Che PRPs document significant quantities of
explosives or explosive devices present in these disposal areas, the
recommenced remedial alternative specified in che ROD is appropriate,
including: (1) capping DA-6, DA-7/8, DA-9, DA-10/11, and the Acid Pics
with a multi-layer cap which includes a synthetic liner, (2) HWT fixation
of contaminated soils in DA-23 followed by capping with a vegetative
cover, (3) extraction and treatment of contaminated ground water in both
che Front Valley and Gregg Valley, and (4) long-Cerm ground-water and
surface-water monitoring downgradienc of all disposal areas. While this
alternative is noC a permanent remedy, Che presence of wastes above che
water table in all disposal areas should assure that che selected remedies
are protective of future ground-water contamination. Ground-water
withdrawal and treatment will remedy the existing contamination in :he
ground watir and protect downgradienc surface waters from future impact.
Long-tarm ground-water and surface-waCer monicoriag downgradienc of ail
disposal arsas will provide assurances that che remedial alternatives are
effective. As a result, human health and che environment will be
protected by this alternative remedy.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
349 COURTLANO STREET
MEMORANDUM ATLANTA. GEORGIA 303
-------
Comments to Draft .ROD for Chemtronics Superfund Site.
PCBs (polychlorinated biphenyls) have been identified in disposal
areas 9-4 and 7/8 at 5 ppm and 0.1 ppm respectively. These levels
are below the cleanup standards which would be applied for the re-
mediation of a PCB spill or historic FCB discharge site.
Unless PCB items (capacitors, transformers, etc) are found during
the excavation of the land fill areas, no PCB disposal regulations
would be applied to the site.
Bob Stryker
Toxics Section Chief
-------
North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
David T. Flaherty, Secretary
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jon K. Bomholm
Super fund Project Manager
US EPA, Region IV
345 Courtland Street
Atlanta, Georgia 30365
March 31, 1988
Ronald H. Levine, M.D., M.P.H.
State Health Director
EUR D
MAR 31 '.330
U E
CPA - REGION IV
ATLANTA. GA.
Re: Comments on Draft Record of Decision for the Chemtronics Superfund Site
by the State of North Carolina
Dear Mr. Bomholm:
I have been placed in an awkward position by your request to respond to the
draft Record of Decision for the Chemtronics' site. The draft was submitted
for review on the afternoon of March 25, 1988, with a requirement for written
response by April 1, 1988. Tnis is an extremely short response time to
evaluate the draft Record of Decision. You further stated that if your agency
does not receive any written comments, the agency will assume that "the State
of North Carolina concurs completely with the remedial alternative selected by
the agency."
The State concurs that there may be significate amounts of ordnance in DA-6,
DA-7/8, DA-9, and /DA-10/11. This is based on an inspection I performed in
March of 1980 that resulted in identifying buried drums and highly reactive
white crystalline solids in the approximate area of DA-7/8. I assume that trie
other areas mentioned above may contain the samp or similar materials. If at
all possible the State concurs that drums and contaminated soils from these
areas should be considered for incineration, whetuer on-site or off-site, as a
permanent solution for source removal. The State further concurs that
personnel safety and integrity of the incinerator should be balanced when
considering incineration, with temporarily capping, monitoring, and
remediation of ground water. Since the Declaration for the Record of Decision
states that if ground water contaminate levels immediately downgradient from
DA-6, DA-7/8, DA-9, and DA-10/11 readies action levels then "a remedial action
to permanently eliminate the source will be initiated immediately," it is
suggested that an on-site or off-site contingency plan for implementation be
submitted as part of the remedial design/treatability study.
Based on the data presented and personal knowledge of the area identified as
the acid pit area, the proposed capping, monitoring, aid extract ion/treatment
of ground water will probably be as close to a permanent solution for that
area as is practical. It is our belief that more monitoring wells to define
the plume and to aid in placement of extraction wells will be required.
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Mr. Jon K. Bornholm
March 31, 1988
Page 2
As you are aware the area designated as DA-23 is considered to be a joint RCRA.
and CERCLA concern. The State offers the following comments on this area:
A) Expand the soil hazardous constituent analysis using APPENDIX IX to
fully assess tne disposed materials in both the biolagoon and the
tile drain field; method:
1) Background borings immediately above both units (one
reference for each, undisturbed),
2) Borings throughout the tile drain field upstream from the
biolagoon.
Borings through the biolagoon liner, (to be sealed
afterwards, preventing further surface water intrusion) on a
grid system from die 1979 liner breach point down stream.
NOTE: Compare background and unit boring results for the tile field and the
biolagoon individually, then collate constituent results against each other to
establish point of emanation between the units (responsibility).
B) Establish individual background wells (RCRA standards) for the
biolagoon and tile field taking into account to avoid cross
interference between the units.
C) Establish individual monitoring well nests for the two units (50 ft.-
downgradient).
NOTE: Compare units individually (background/monitoring wells) then
reference results against each other.
D) Compare soil boring results to ground water in order to establish
mobility criteria of the constituaits.
E) Cap (also HWT,if required), if necessary, both units so a technically
reflective period can be allowed where more efficient/cost effective
leading edge ideas can be studied and reasonably proven based on data
obtained above.
F) Remedial ground water programs should be started as soon as the
plumes can be further defined to stem the further migration of
hazardous constituents and magnification of future corrective ground
water action.
G) Explore the natural bioattenuation process existing in the
surrounding soils given the hazardous constituaits which may be
discovered by the methods described above.
NOTE: The State shall be included in all decisions as they apply to
analytical test methods/results and corrective action system prior to draft
submittal leading to future inception.
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Mr. Jon K. Bornholm
March 31, 1988
Page 3
I have included additional comments from the N.C. Department of Human
Resources' Environmental Epidemiology Branch and Division of Environmental
Management, Groundwater Section. These comments are to be included in the
administrative record for the Record of Decision on Chemtronics as part of the
State comments.
It is apparent to me that the N.C. Groundwater Classification Standards were
either not considered or considered and rejected. I would appreciate a
response from EPA on this issue. It is a major concern since it will have an
impact on level of cleanup, length of time required for remedial action, aid
cost of remedial action.
Our staff has reviewed a publication titled Advanced Chemical Fixation of
Organic and Inorganic Content Waste by Jeffrey P. Newton of International
Waste Tecnnologies.We assume that his technology is the proposed method for
soil fixation on the Cnemtronics' site. We are particularly interested in
organophilic properties in this matrix. We would appreciate any scientific
data for fixation of organics by this matrix to include types of organics,
concentrations of organics, and methods of chemical and physical fixation.
Of major concern to tie State is the perception that the citizens in the
community around Chemtronics appear to be totally frustrated by the
Government's effort to afford adequate technical assistance and explanation as
to almost all issues associated with activities to manage the Chemtronics1
site. If the Record of Decision cannot be modified, as it now is drafted,
with further public comment, then the State strongly suggest delaying a final
decision on the Reocrd of Decision until the community can obtain a technical
assistance grant and can offer comments based on good technical merit.
If you have any questions or need any assistance, please contact me at
(919) 733-2178.
Respectfully,
William L. Meyer, Chief
Solid Waste Management Section
W.M/ppb6414A(89-91)
Attachments I and II
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North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
David T. Flaherty, Secretary
Ronald H. Levine, M.D., M.P.H.
State Health Director
March 30, 1988
MEMORANDUM
TO:
THROUGH:
FROM:
SUBJECT:
William L. Meyer, Chief
Solid Waste Management Section
John I. Freeman, D.V.M., M.P
Environmental Epidemiology B
Jenifer S. Heath, Ph.D., Toxicologist
Environmental Epidemiology Branch
Chemtronics Superfund Site Record of Decision
We have reviewed the draft Record of Decision for the Chemtronics site and have
several concerns which fall into four categories: 1) apparent gaps in
groundwater monitoring analyses, 2) use of the PPLV as-a remediation level for
CS, 3) absence of North Carolina's groundwater standards in the list of
relevant laws, and 4) public perceptions of the risk management process.
1) It is not clear whether samples from the potential off-site waste areas
(Tropigas and Walnut/Buckeye Cove Landfills) were analyzed for volatile
organic chemicals (VOCs). While it is true that VOCs present in these
areas could have been contributed by other landfill users, it is also true
that Chemtronics could be responsible.
Along these lines, it seems unfortunate that samples from the private
wells in the area were not analyzed for VOCs. This might have confirmed
the conclusion that no VOCs have migrated off-site from the identified
disposal areas and the implied conclusion that there are no unidentified
disposal areas from which VOCs may have migrated.
Finally, it is not clear that the chemical agents CS and BZ (or its
breakdown products) were consistently included in groundwater analyses.
2) The logic behind use of the Preliminary Pollutant Limit Value (PPLV) for
CS is unclear. The publicly-available literature suggests that CS may
cause dermal sensitization. It is possible that the PPLV is not
protective against dermal sensitization, yet this health concern is not
addressed. .
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Meyer Memorandum
Page 2
March 30, 1988
3) Section 6.6 lists a number of state and federal regulations which may
apply to the Chemtronics site. This list fails to include the state's
groundwater quality standards. This is a significant oversite and could
result in remedial levels which would be inconsistent with North
Carolina's commitment to maintaining the quality of our groundwater
resources. I believe that this concern will be addressed more fully by a
representative of the Groundwater Section of the Division of Environmental
Management.
4) Finally, we are concerned about the credible perception held by some
members of the public in Swannanoa that a lack of time and resources has
prevented thert from participating meaningfully in this decision-making
process which will so intimately affect their feelings about their homes
and their community (not to mention their future attitude toward
environmental regulators).
Please feel free to call me at (919) 733-3^10 if you wish to discuss these
concerns.
JSH:km
c: Ted Taylor, Ph.D.
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DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
March 30, 1988
MEMORANDUM
TO: William L. Meyer, Chief
Solid Waste Management Section
FROM: Perry F. Nelson
SUBJECT: Draft ROD, Chemtronics Superfund Site
This mprning I received a copy of EPA's Record of
Decision for the Chemtronics site, covered by a letter to
you advising that, should EPA not receive any written
comments by April 1, they would assume that North Carolina
concurs with the remedial alternative selected by the
Agency.
It is not feasible for my staff to review and comment
on this document by Wednesday, in time for a response to
reach Atlanta by April 1. I am amazed that no more time for
review was provided.
A cursory examination of our Chemtronics file revealed
that at least three letters had been sent to Mr. Bornholm
since October, 1987, regarding EPA remediation plans. Two
of the letters called his attention to North Carolina's
groundwater quality standards (15 NCAC 2L), and their
applicability to the Chemtronics' site. The ROD, however,
ignores these standards, failing to even acknowledge their
existence in Section 6.6 of the report (Consistency with
Other Environmental Laws).
In view of the limited time provided for review, I can
do no more than remind EPA again of the "Classifications and
Water Quality Standards Applicable to the Groundwater of
North Carolina" (15 NCAC 2L). These rules address the issue
of restoration of groundwater to substandard levels of
quality.
Attachments
cc: R. Paul Wilms
tej
-------
State of North Carolina
Department of Natural Resources and Community Development
Ashcville Regional Office
James C. Martin. Governor David R Spain
S. Thomas Rhodes. Secretary Regional Managrr
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROl'NDWATER SECTION
Mr. Jon K, Bornhola
U. S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta. Georgia 30365
Subject: Buried Drum Removal
Burial Sites 6. 7. 8. 9. 10. and II
Cheatronics. Inc.
Groundwater Incident No. 381
4 Buncombe County. North Carolina
'Dear Mr. Bornholrc:
In our telephone conversation of February 2. 1988. we discussed the
possibility of leaving approximately 2200 barrels of contaminated clothing and
possibly other types of waste in place on burial sites 6, 7. 8, 9, 10. and 11
and capping the sites. After discussion of this matter with Lee Laymon,
Assistant Chief of the Groundwater Section, it is our recommendation that the
drums should be removed from the site since leakage will ultimately occur and
could be expected Co further contaminate groundwaters on site.
If you have any further questions, please do not hesitate to contact me
at 704-251-6208.
Sincerely.
Donald R. Link. P. G.
Hydrogeological Regional Supervisor
DRL:ar
cc: .Jkee Laymen
Buddir* 59 \Xfaodfin PUce, KJ BOK J70. Arfwville. NC 28802-0170 • Telephone 704-251 -6208
An Fqiul Ofnwntu««v Atfirmwivr Ai !•»• KmnliuTT
-------
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James C. Martin, Governor R. Pauj
S. Thomas Rhodes, Secretary October 8, 1987 Director
Mr. Jon K. Hornholm
Superfund Branch
U.S. Environmental Protection Agency
345 Courtland Street
Atlanta, GA 30365
Dear Mr. Bornholm:
As per our telephone conversation, please find attached
a copy of 15 NCAC 2L, . "Classifications and Water Quality
Standards Applicable to the Groundwaters of North Carolina,'"
These . standards are applicable to all underground waters,
as defined 'at 15 NCAC 2L.0102 (20). The standards, both
numerical and narrative, are found at 15 NCAC 2L.0202.
* Should you have any questions concerning the relationship
between the standards and remedial actions, you may wish to
refer to 15 NCAC 2C.0101 (d) or to contact me or Douglass
Dixon at the address given on the stationary or telephone
(919) 733-3221.
If you should require any additional information or
have any questions concerning the standards, groundwater
classifications or requirements for remedial actions to
restore groundwater quality/ please contact us at your
earliest convenience.
Sincerely/
William O^Jeter
Supervisor, Incident
Management and Technical
Services Unit
Attachments
cc: Perry Nelson
William Meyer
Incident Management Files
tej
Pollution Prtvtnho* Payt
ROBrw J7A*7 P.I--1. »• • - '
-------
» UNITED STATES ENVIRONMENTAL PROTECT/ON AGENCY
f REGION IV
345 COURTLAND STREET
ATLANTA. GEORGIA J03CS
2 : 1937
4WD-SFB
Mr. William L. Meyer, Head •'.'"' • •
Solid & Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
Raleigh, NC 27602-2091
Re: ARARs for the Chemtronics NPL Site
Swannanoa, North Carolina
Dear Mr. Meyer:
This correspondence is a follow up to a letter I sent you dated March 17,
1987. In this referenced letter, I requested the State.of.North Carolina to
identify to EPA the State's applicable or relevant andJappropriate.requirements
(ARARs) as they pertain to the Chemtronics NPL site located in Swannonoa. 1
"have had some telephone conversations with Dr. Ted Taylor of your staff with
regards to this topic. During our conversations, he expressed his feelings
as to where he thought the State was headed with clean up levels/criteria for
contaminants in the groundwater but unfortunately he did not have anything in
writing to send on to me.
The potentially responsible parties (PRPs) are now in the process of screening
remedial alternatives and identifying and developing clean up goals for the
contaminants on site. Since the Agency has not received a response from your
office on what specific ARARs the State has that would apply to this site, it
is the Agency's assumption that the State of North Carolina has no ARARs that
apply to the Chemtronics site and/or the contaminants found on site. Therefore,
the clean up levels/criteria being used were obtained from existing Federal
laws and regulations. If this is an erroneous assumption, then you need to
identify, in writing, the specific State ARARs that pertain to this site by
October 9, 1987. If I do not receive a list of specific ARARs from the State
by this date then it is clear that the State does not have any ARARs that
pertain to the Chemtronics site and I will inform the PRPs that the clean up
levels/criteria they are presently considering are the ones the Agency will
enforce.
If you have any questions, I can be contacted at (404)347-3402.
Sincerely yours,
<
Jon K. Bomholm
Regional Project Manager
Superfund Branch
-------
State of North Carolina
Department ot Natural Resources and Community Development
Asheville Rc^oJMl Oiricc
DIVISION OF ENVIRONMENTAL MANAGEMENT
James C. Morrin. Governor GROUN'DWATER SECTION S. Tromas
Oeceober 22. 1987
Mr. Jon K. Rornholi;:
L:. S. Environmental Protection Agency
Region IV
3*5 Courtland Screen
Atlanta. Georgia 30365
Subject: Feasibility Study for Chemtronirs 5iu-
Groundwnrer Incident No. 381
Buncombe County, North Carolina
Dear Mr. Bo mho 1m:
In view of the complexity of the Feasibility Study for the Chemtronics
Site and the Halted tine available for the review, I have generalized ay
comaents as follows:
I. Contaminated materials, including soils with contaminant
concentrations high enough to affect groundwaters. should
be removed from the site or treated to an acceptable
level on site. If this proves impractical, the con*
tarainated material should be protected so it does not
continue to contribute to groundwater contamination on
site.
II. NCAC Title 15 Subchapter 2L, "Classifications and Water
Quality Standards Applicable to the Groundwaters of North
Carolina" require that contaminated groundwaters be
remediated to the standards set forth in the classifications.
If this level is not obtainable due to economic or available
technology, a variance to these standards may be granted by
the Director.
I'mcrcKinji- Building ?«• ^Wnn llu-c. PO So-. JTU A.Krvilc NT >*>r
-------
Mr. Jon K. Bornholm
Page 2
December 22. 198?
If you have any questions. Please do not hesitate to contact
cc: ^.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
J4S COURTLANO STREET
ATLANTA. GCORCIA JOJ«3
4WD-SFB
Mr. William L. Meyers, Chief
Solid Waste Management Section
Division of Health Services
North Carolina Department of Human Resources
P.O. Box 2091
Raleigh, NC 27602-2091
Re: Comments on Draft Record of Decision for the Chemtronics
Superfund Site
Dear Mr. Meyers:
Enclosed for your review and comment is a copy of.the draft Record of Decision
(ROD) for the Chemtronics site. Briefly, the remedial alternative the Agency
is proposing for this Site includes capping, soil/fixation, extracting and
treating groundwater, and monitoring groundwater quality.
The Agency has elected to pursue capping of the disposal areas containing
drums, Disposal Areas: DA-6, DA-7/8, DA-9, and DA-10/11, for two reasons.
First, there is a genuine threat posed by the presence of small explosives or
explosive devices in a couple of these disposal areas. It is difficult, at
this time, to estimate the danger these explosives would present to the workers
during excavation or to the integrity of the incinerator. Secondly, the public
has expressed a strong dissatisfaction with the incineration alternative. This
opposition was voiced both in the public meeting the Agency conducted on
February 23, 1988 on the draft Feasibility Study and in over 80Z of the
comments the Agency has received since the public meeting. The main
environmental factor that numerous letters have alluded to is the frequent
atmospheric inversions that occur in the Asheville area. There also is a great
mistrust/misunderstanding/misconception of what incineration actually
accomplishes. The majority of the authors of the letters sent to the Agency do
not realize or understand that the components of the gaseous emissions from the
incinerator would be water and carbon dioxide, with the other components being
removed by the scrubber*.
Since capping is not considered a permanent remedy, the Agency is required by
SARA to review the contaminants and contaminated environmental media every five
years in light of newly developed technologies. In the event that a new,
permanent technology is developed that can be used at the Site, the Agency may
require the PRPs to implement this new technology.
-------
Please review the ROD and submit jour comments to the Agency by April 1,
1988. The ROD briefing for the Regional Administrator is scheduled for
March 29. 1988. I plan to call you on March 28 so that I can pass any
concerns you voice on to him. If the Agency does not receive any written
comments by April 1 then, it is the Agency's assumption the State -of North
Carolina concurs completely with the remedial alternative selected by the
Agency.
If you have any questions, I can be reached at (404)347-7791. Please note
that this is a new number.
Sincerely yours,
>n K. Bornholm
Superfund Project Manager
Enclosure
-------
PEEH REVIEW CLEARANCE FORM
Route To: James H. Scarbrough, Chief, RCRA Branch
Return To: Jon Bornholm, Superfund Branch
/
'Peer Review Originator (Panel Member): Jon Bornholm
Dace Transnisted: 3/23/8£
Dace Returned:
Project Title: . Draft Record of Decision (ROD) for the Chemtrom'cs Superfund Site
in Swannanoa, NC. •• ••'
Project Manager: Jon BornhoTm (x-7791)
Originator's Instructions: Please review and comment on the attached document and
the Aoency's proposed remedial alternative for this Site. •
Inforaacion Copies Sent To: Bruce Barrett. James Finoer. James Saroent. James Scarbrouoh,
and Winston Smith
1 Signature
(Panel Member)
s\
\hrt^tfJcsdt*d
Date
Received
3/tt/BB
Date
Cleared
3/3/IX&
Concur
}/ turf**
Ce/vj/n&fijf
Non-cor.cur
JL
(I
Reviewing Officials
Dace
Received
• Date
Review Completed
Reviewer's Signature
1.
2.
3.
5.
Reviewing Panel Member's Comments: Per the March 31, 1988 conservation*
and Nancy Bethune, revision will be made to the text of the Declaration,
neV
.
replacing the first paragraph, third page, should convey the following Informations -^
— ec
After remediation levels for groundwater have been verified through monitorgig, ite% action
for the contaminants may be set. If this level is reached in any subsequent monitoring,
remedial action will be intitiated immediately to permanently eliminate the source of con- •
tamlnation.
-------
ENFORCEMENT
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
CHEMTRONICS SITE
SWANNANOA, BUNCOMBE COUNTY
NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
-------
DECLARATION FOR THE RECORD OF DECISION
SITE NAME and LOCATION
Chemtronics
Swannanoa, Buncombe County, North Carolina
STATEMENT OF PURPOSE
This document represents the selected remedial action for this Site developed
in accordance with CERCLA as amended by SARA, and to the extent practicable,
the National Contingency Plan.
The State of North Carolina has concurred on the selected remedy.
STATEMENT OF-BASIS
The decision is based upon the administrative record for the Chemtronics Site.
The attached index identifies the items which comprise the administrative
record upon which the selection of a remedial action is based.
DESCRIPTION OF-THE SELECTED REMEDY
GROUNDWATER
In both the Front Valley and Gregg Valley, a groundwater extraction system
will be installed to intercept and extract contaminated groundwater
migrating through the ground. The level and degree of treatment of the
extracted water will be determined by 1) the level of contaminants in the
-------
extracted groundwater and 2^_the ultimate discharge point of the treated
water. These facts will be determined in the Remedial Design stage.
SOIL
Based on the results of the RI/FS process, EPA's proposed alternative for
addressing soil contamination, and thereby containing the source of
contamination, is to cover the following disposal areas with a multi-layer
cap, which will include a synthetic liner: DA-6, DA-7/8, DA-9, DA-10/11,
and the acid pit area. Security fencing, vegetative covers and, where
necessary, a gas collection/ventilation system will be installed. Soil
fixation/stabilization via HWT fixation process for the contaminated soils
associated with DA-23. DA-23 will also be capped and provided a vegetated
cover and enclosed within a security fence. Groundwater monitoring
immediately downgradient of each disposal area will be required. This may
result in the installation of additional monitor wells.
-------
In addition to the monitoring of the groundwater downgradient of each
disposal area identified above, action levels for the contaminants present
in the disposal areas will be set so that if this limit is reached during
any sampling episode during monitoring of the groundwater, a remedial
action to permanently eliminate that source will be initiated, immediately.
On-site incineration of the drums and contaminated soils from DA-6, DA-7/8,
DA-9, and DA-10/11 remains a viable alternative. The elimination of this
source control remedial alternative is dependent on acceptable
documentation of the presence of ordnance in these disposal areas. If it
can be documented to EPA's satisfaction by the PRPs that significant
quantities of explosives or explosive devices were also disposed of in
these disposal area, then due to the health risk to which the workers would
be exposed during excavation of the drums and contaminated soils, this
alternative would be eliminated.
DECLARATION
The selected remedy is protective of human health and the environment, attains
Federal and State requirements that are applicable or relevant and appropriate,
and is cost-effective. This remedy satisfies the preference for treatment that
reduces toxicity, mobility, or volume as a principal element. Finally, it is
determined that this remedy utilizes permanent solution and alternative
treatment technologies to the maximum extent practicable.
r I have also determined that the action being taken is appropriate when balanced
\ against the availability of trust fund monies for use at other sites.
Date Lee A. DeHihns III
Acting Regional Administrator
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APPENDIX E
ADMINISTRATIVE RECORD r,v;tx. *
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