N. C. Department of Environment and Natural Resources Summary of Federal Response and State Response at CTS Site Buncombe County
DENR Division of Waste Management (DWM) • DWM consists of four sections and one program: – Hazardous Waste Section – Solid Waste Section – Underground Storage Tank Section – Superfund Section – Brownfields Program 2
Superfund Section • Site Evaluation and Removal Branch (SERB) • Federal Remediation Branch • Inactive Hazardous Sites Branch (IHSB) • Special Remediation Branch 3
Federal EPA Criteria • National Priority List (NPL) Site – Must score above 28.5 using Federal Hazard Ranking System (HRS) – 37 NPL Sites being cleaned up in North Carolina • Removal Action – Remove imminent threat to human health and the environment at sites that require emergency action or that have contaminant releases that exceed Removal Action Levels – Average of 8 EPA Removal Actions per year in North Carolina 4
Inactive Hazardous Sites Branch (State DWM) • The state Inactive Hazardous Sites Branch (IHSB) addresses sites that do not meet Federal Criteria for NPL Listing or EPA Removal Action • 1,916 open sites in DWM IHSB Inventory – (not including preregulatory landfills) • 319 Ongoing Assessments/Cleanups including Priority Sites and Registered Environmental Consultant Program sites 5
CTS Site Overview • Operated from 1953 to 1985. Electroplating of electrical components • Originally a 66 acre property, 37 acres redeveloped to residential (Southside Village, built with municipal drinking water lines) • Trichloroethylene (TCE) in groundwater has impacted seven residential water supplies 6
The CTS Site has been addressed primarily by the Federal EPA, with concurrent work by DWM since 2007 • Federal EPA has been involved in identifying threat to off site drinking water sources and providing alternative water to impacted residents. This work also supports NPL listing requirements • EPA has also operated a soil vapor extraction system to reduce levels of contaminants in an adjacent spring • State DWM IHSB has been reviewing work by CTS on defining nature and extent of contaminants in groundwater at the site, primarily Trichloroethylene (TCE) 7
CTS Site History • 1952-1959 International Resistance Company (IRC) • 1959-1985 CTS operations on site – Both IRC and CTS used chlorinated solvents in their plating operation • Oct. 30, 1985 – EPA Preliminary Assessment conducted. Report finds no threat to human health or the environment, but recommends follow-up site survey • Aug. 31, 1987 – Site Assessment by Law Environmental requested by CTS (pending sale) 8
CTS Site History • Dec 23, 1987 - CTS sells a 54 acre parcel to Mills Gap Road Associates (MGRA) • 1988 – DWM IHSB hires first staff; 1 to 3 project managers for first 10 years of the program • June 18, 1990 - DWM SERB receives resident’s concerns of contamination at CTS and potential drinking water well impacts • June 18, 1990 – DWM SERB sends letter documenting those concerns to EPA Contractor (NUS) and to EPA 9
CTS Site History • Feb. 22, 1991 – EPA contractor NUS completes Site Screening Investigation (SSI) Report. Nearest well identified as 4,000 feet away • March 6, 1991 - EPA forwards SSI Report to DWM with cover letter stating that no further remedial action under Superfund is planned for the CTS site • Nov. 30, 1993 – DWM IHSB ranks site based on existing data 10
CTS Site History • Aug. 19, 1997 – Mill Gap Roads Associates (MGRA) subdivides the 54 acre former CTS property. There is no requirement to notify the State of subdivision • Aug. 22, 1997 - MGRA sells 45 acres to The Biltmore Group, retaining 9- acre fenced plant site. Southside Village was ultimately developed on the 45 acres. • Dec. 15, 1997 – DWM IHSB issues Order to Record a Notice of Hazardous Substance or Waste Disposal Site • Sept. 9, 1998 – MGRA records a Notice of Hazardous Substance or Waste Disposal Site on deed for the 9-acre fenced plant site retained after the subdivision and sale 11
CTS Site History • Jul. 12, 1999 – In response to resident’s request, State Division of Water Quality (DWQ) sampled springs on property adjoining CTS plant. First evidence of drinking water contamination • Jul. 28, 1999 – Nine nearby potable wells sampled by DWQ. One well found contaminated. • Aug. 16, 1999 – DWQ contacts DWM SERB about contaminated springs and well. DWM SERB contacts EPA on same day for assistance with alternative water • Aug. 23, 1999 – Bottled water supplied by EPA 12
EPA Removal Actions • April 2000 – EPA completed municipal water connections to impacted residents. • Repeated sampling of nearby drinking water sources (1999, 2000, 2003, 2006) – No additional contaminated wells identified • 2000 and 2010 – EPA surveyed CTS site for buried drums 13
EPA Removal Actions • 2006-2011 – Under EPA oversight, CTS operated a Soil Vapor Extraction system to remove TCE from soils beneath the plant • Dec. 2007 – Mar. 2009: EPA Vapor Intrusion Study at nearby homes show results below EPA Removal Action Levels • 2009-2011 - CTS ozone injection trial attempted to reduce vapor emissions from springs 14
EPA Remedial (NPL) Program • Five attempts to list the CTS site on the NPL: (1985, 1991, 2001, 2006, and 2007-11) • One-mile radius drinking water sampling (quarterly, events since 2007) has two purposes: - Protect residents: 5 additional contaminated wells identified during this effort - Support HRS Score that allows March 2011 Proposal to NPL 15
EPA 1-Mile Radius Quarterly Drinking Water Sampling 16
NC Actions 2007 - 2011 • DWM takes steps to solicit CTS assessment and cleanup of the site • DWM IHSB oversees CTS groundwater assessment through two phases of soil and bedrock drilling at the plant • NC Division of Land Resources Geological Survey conducts fracture study to support EPA’s NPL listing effort • NC Division of Public Health (DPH) conducts a Public Health Assessment in response to public request 17
NC Goals 2007 - 2011 • Earliest possible cleanup, either under state authority, or under EPA authority if NPL listing successful • Augment EPA Removal and Remedial resources • Unified community involvement program with EPA, Buncombe County Public Health, DWM and DPH • Dovetail DWM IHSB site groundwater assessment with EPA activities • Improve information on attribution and drinking water risk 18
Mills Gap Road DWM IHSB – Phase IA Drilling 19
DWM IHSB – Phase IB Drilling 20 pandemonium
Fracture Set NC DLR Geological Survey 260-280/80 Rock Outcrop Fracture Study Fracture Set 260-280/80 21
US Geological Survey Borehole Fracture Study 22
EPA Pump Tests 23
NC DHHS Public Health Assessment The N.C. Division of Public Health (NC DPH) was asked to conduct a comprehensive evaluation of the potential public health hazards related to contact with the contamination identified at the CTS site. • Concentrations of trichloroethylene (TCE) observed in private wells in 1999 may have been high enough to cause adverse health effects. • Private well data collected from 1999 through January 2008 does not indicate the potential for adverse health effects… • The chemical concentrations found in the outdoor air, soil, and crawl space air were too low to cause harm. • The evaluation of cancer rates in a 1-mile radius from the site showed that the rates are not higher than what would normally be expected. 24
Buncombe County Actions 2007 - 2011 • October 2008 - Waterline extension to The Oaks Subdivision • 2011 - Demolition of CTS plant building • Active support of EPA, DWM, and DPH efforts 25
EPA Community Involvement • 28 Public meetings since October 2007 • NPL process includes statutory community involvement steps • Beginning March 2010 - Community Advisory Group comprised of local citizens now reviews and comments on EPA/CTS investigation work plans • As a result of 2010 EPA Inspector General office investigation into CTS site, EPA instituted a nationwide Standard Operating Procedure for better risk communication with communities at Superfund sites 26
EPA Actions Going Forward • Site proposed to NPL March 2011; Final Rule anticipated as early as March 2012 • EPA negotiating with CTS on Administrative Agreement for NPL Remedial Investigation and Cleanup • EPA will continue quarterly monitoring of drinking water in 1-Mile Radius 27
State Role Going Forward • Support listing of the site on the NPL and cleanup of site using CTS funds • Transition from DWM IHSB assessment to EPA NPL Remedial Investigation/Feasibility Study • DWM Superfund Section engineers fill Support Agency oversight role under Cooperative Agreement with EPA at all NPL sites • Additional DPH Public Health Assessment required after NPL listing 28
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