NORTH CAROLINA DEPARTMENT OF ENVIRONMENT … · ~~~~~ NORTH CAROLINA DEPARTMENT OF ENVIRONMENT ....

ATA NCDENR ~~~~~ NORTH CAROLINA

DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WASTE MANAGEMENT

Superfund Second Five-Year Review Report General Electric Co/Shepherd Farm

East Flat Rock, Henderson County, North Carolina EPA ill: NCD 079044426

Prepared for US EPA Region 4

August 2009

10685100

SECOND FIVE-YEAR REVIEW REPORT GENERAL ELECTRIC CO/SHEPHERD FARM

EPA ID: NCD 079044426

Prepared for the US Environmental Protection Agency

Region 4

Prepared by the State of North Carolina

Department of Environment & Natural Resources

AVA NCDENR

August 2009

SECOND FIVE-YEAR REVIEW REPORT GENERAL ELECTRIC CO/SHEPHERD FARM

EPA ID: NCD 079044426

Prepared for the US EPA Region 4

Prepared by the North Carolina Department of Environment & Natural Resources

Superfund Division US EPA Region 4

Second Five-Year Review GEiShephereJ Farm Site

East Flat Rock, NC

Table of Contents

List of Acronyms : , : iii Executive Summary : ; : v Five-Year Review Summary Form ~ , vii 1.0 Introductio~ ~ . .. ~ 1 2.0 Site Chronology 2 3.0 Background ~ 2

3.1 Site Description 2 . 3.2 Site Topography, Geology, and Hydrogeology :.: .4 3.3 Land and Resource Use , 4 3.4 . History of Contamination 5 ' 3.5' Initial Response ' ' , , ' ~. 6 3.6 Basis for Taking Action ~ 7

'4.0 Remedial Actions 8 4.1 Remedy Selection .- 9

.4.1.1 1995 Record of Decision : : 9 4.1.2 Explanation of Significant Difference ' 10 4.1.3' Second Explanation of Significant Difference ~ : 10

4.2 Remedy Implementation :............................. 11 4.2.1 Soil Remedy ~ , 11 4.2.2 Groundwater Remedy : 13

4.3 System Operation/Operation & Maintenance 14 5.0 Progress Since Last Five-Year Review , ; 16 . 6.0 Five-Year Review Process ' ; · ~.- '19

6.1 Admi~istrative Components : : 19 , 6.2 Community Involvement. : ' 19' 6.3 Document Review : 19 6.4 ARAR Review '. 19

6.4.1 Original ARARs from the 1995 ROD ; 20 6.4.2 C:urrent Applicable ARARs : , '," 21

6.5 ',' Data RevIew ,' 22 6.6 Site Inspection : , ; 28 6.7 Interviews : : ~ : :. 29

7.0 Technical Assessment. : 30 7.1 Question A: Is the remedy functioning as intended by the decision documents? :..: 30 7.2 Question B: Are the exposure assumptions, toxicity data, clean-up levels and remedial

action objectives (RAOs) used at the time of the remedy still valid? , 33 1·',: .' 7.3 Question C: Has any other infonnation come to light that could call into question .

the protectiveness of the remedy? : ' :: 33 7.4 Technical Assessment Summary 33

8.0 Issues : ; : 34 9.0 Recommendations and Follow-up Actions 34 10.0 Protectiveness Statement. , : 34. 11.0 Next Review : 35,

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Second Five-Year Review GEiShepherd Farm Site

East Flat Rock, NC

Table 1: Chronology of Site Events Table 2: Groundwater Remediation Goals as Stated in the 1995 ROD Table 3: Soil Remediation Goals as Stated in the 1995 ROD Table 4: Previous and Current ARARs for Groundwater COCs Table 5: Performance Monitoring Schedule Table 6: Summary of Mann-Kendall Trend Analysis for VOCs Table 7: Summary of Mann-Kendall Trend Analysis for Metals Table 8: GE Subsite Performance Monitoring Well Analytical Results for September 2008 Table 9: Shepherd Farm Subsite Performance Monitoring Well Analytical Results for September 2008 Table 10: Historical Summary of Groundwater Influent and Effluent Results Since GRS Start-Up Table 11: Summary ofinfluent and Effluent Air Results Since GRS Start-Up Table 12: Summary of Surface Water Results Since GRS Start-Up Table 13: Summary of Sediment Results Since GRS Start-Up

Figures

Figure 1: Site Location Map Figure 2: Location of the GE Subsite Features Figure 3: Location of the Shepherd Farm Subsite Features Figure 4: Hydraulic Containment at the GE Subsite on September 15,2008

. Figure 5: Hydraulic Containment at the Shepherd Farm Subsite on September 15, 2008 Figure 6: Location of Stream Flow Measurement Points Figure 7: Location of Sediment Monitoring Stations

Attachments

Attachment 1: List of Documents Reviewed Attachment 2: Site Inspection Check List Attachment 3: Community Interviews Attachment 4: Complete Analytical Data Table for Groundwater Attachment 5: Vapor Intrusion Assessment Attachment 6: Contour Maps of the Site

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(.

AGRS

ARAR

CERCLA

ji ' . CAA

CFR

COC

CWA

DCE

DSI

EPA

ESD

GAC

gpm

GRS .

MCL

NCAC

NCDENR

NCSWQS

NCP

NPDES

'NPL

O&M

. PCB "J' •

PCE

PCOR

ppm

ppb t,.,"

Second Five-Year Review. GEiShepherd Farm Site

East Flat Rock, NC

List of Acronyms

Accelerated Groundwater Remediation System

Applicable or Relevant and Appropriate Requirement

Comprehensive Environmental Response, Compensation, and Liability Act

Clean Air Act

Code of Fede'ral Regulations

Contaminant of Concern

Clean Water Act

1,2- Dichloroethene

. Dry Sludge Impoundment

United States Environmental Protection Agency

Explanation of Significant Difference

Granular Activated Carbon

Gallons per Minute

Groundwater Remediation System

Maximum Contaminant Level

North Carolina Administrative Code

North Carolina Department of Environment and Natural Resources

North Carolina Surface Water Quality Standards

National'Contingency Plan

National Pollut~nt Discharge Elimination System.

National Priorities List

Operation and Maintenance

Polychlorinated biphenyl

Tetrachloroethene

Preliminary Close-Out Report·

Parts per million

Parts per billion

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East Flat Rock, NC

POTW

RA

RAO

RCRA

RD

RI

ROD

RPM

RTC

SDWA

SVOC

TCE

TSCA

Ilg/L

UST

VOC

Publicly Owned Treatment Works

Remedial Action

Remedial Action Objective

Resource Conservation and Recovery Act

Remedial Design

Remedial Investigation

Record of Decision

Remedial Project Manager

Remediation Target Compound

Safe Drinking Water Act

Semi-Volatile Organic Compound

Trichloroethene

Toxic Substance Control Act

Parts per billion or ppb

Underground Storage Tank

Volatile Organic Compound

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Second Five-Year Review GEiShepherd Farm Site .

East Flat Rock, NC

Executive Summary

The GE manufacturing facility is located at the southeastern comer of Spartanburg Highway (U.S. 176) and Tabor Road (S.R. 1809) in East Flat Rock, Henderson CoUnty, North Carolina. Since 1955, this GE facility has been used to develop, design, and manufacture complete high-intensity-discharge luminaire systems. GE also manufactured "constant-current" transformers at this facility from 1955 to 1975. These transformers were filled with Polychlorinated biphenyl (PCB)-containing oil.

The GE/Shepherd Farm Site is divided into 2 subsites, the GE Subsite and the Shepherd Farm Subsite. The former Seldon Clark Subsite was deleted by EPA from the GE/Shepherd Farm Site in 1996. The GE Subsite is approximately 110 acres in size and includes the manufacturing and distribution facilities for GE Lighting Systems. The 31-acre Shepherd Farm Subsite is located on Roper Road, approximately 1,200 feet west of the Spartanburg Highway. and southwest of the GE Subsite. It is comprised of both residential and agricultural land. Mr. Shepherd's residence and a 22-acre manufactured housing community consisting of 125 lots and a community center are present on the southern portion of the Subsite. .

GE disposed of waste within two landfills on the GE property. Landfill A receiv~d waste generated at the faCility between 1955 and the 1960s. Landfill B operated during the 1970s but the exact time is unknown. In the mid-1970s, GE constructed the wastewater treatment facility consisting of a lime treatment system to adjust the pH of the treated water prior to surface water discharge. Two unlined wastewater treatment ponds were also constructed. Between 1977 and 1980, as part of the wastewater treatment process, wet and dry .sludges generated in the . wastewater· treatment facility were landspread on several plots surrounding the facility buildings. GE ~aste was also deposited at the Shepherd Farm property where it was dumped, burned, and . bulldozed in an approximate 3-acre area.

. The remedies in the Record of Decision (ROD) dated September 29, 1995 provided for remediation of contaminated groundwater and soil. The remedy for groundwater included: extraction of groundwater from the GE/Shepherd Farm Subsites that is contaminated above the Maximum Contaminant Levels (MCLs) or the North Carolina Groundwater Standards; on-site treatment of the extracted groundwater via air stripping and carbon adSOrption; in-situ bioremediation; discharge of treated groundwater to Bat Fork Creek; and, continued analytical. monitoring for contaminants in groundwater and surface water. The remedy for soils at the GE Subsite included: placement of a multi-layer cap on the areas where the soil is contaminated above the performance standards; continuous maintenance of the cap; and, usage restrictions on the capped areas. The remedy for soil at the Shepherd Subsite included: excavation of the top foot of soils contaminated above the performance standards; transportation of excavated soils to the Dry Sludge Impoundment (DSI) area on the GE property; and, backfilling, grading, and re

. vegetation of the excavated areas. . .

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East Flat Rock, NC

The ROD was modified by an Explanation of Significant Differences (ESD) signed on September 25, 1998. The requirement to place a multi-layer cap on the areas where the soil is contaminated above the performance standards was modified to: excavate Landfill A and transport the contents to the DSI and backfill with ~lean fill; excavate Landfill B and transport the contents to the DSI and backfill with clean fill; and place a multi-layer cap on the DSI.

The ROD was modified by a second ESD signed on July 27, 2000. The modifications were: delete the requirement for the in-situ bioremediation of contaminated groundwater across the entire Site; and change the discharge location of treated groundwater from Bat Fork Creek to the GE operations facility.

This is the second Five-Year Review for the GE/Shepherd Farm Site. The triggering action for this review is the signing date of the First Five-Year Review report, August 6,2004. This Five-Year Review for the GE/Shepherd Farm Site is a statutory review.

According to documents, the site inspection, and interviews with the US EPA, the exposure pathway to contaminated soil and groundwater has been mitigated. The exposure assumptions, toxicity data, clean-up levels and RAOs used at the time of the remedy are still valid for the contaminants of concern (COCs). There are no known current exposure routes to the groundwater or soil.

......

The remedies at both Subsites currently protect human health and the environment in the short-term because the main source of contamination has been remediated through the source removal. Currently no human exposure pathways exist to contaminated soil or groundwater. A current drinking water survey is being requested which would verify that no new groundwater users have installed drinking water wells. However, it is known that there are no residents between the GE property and Bat Fork Creek, a gaining stream. Bat Fork Creek would intercept any contaminated groundwater that should intersect the creek. Data has also confirmed that no VOCs have been found in existing groundwater wells that exceeded the remediation goals for residents downgradient of the GE property on the opposite side of Bat Fork Creek. At the Shepherd Farm Subsite, the Spring Haven Community is supplied municipal water and the few residents not within the subdivision are also supplied municipal water.

The Site currently is protective in the short-term; however, to ensure long-term protectiveness; the following actions should be implemented. Impose institutional controls at both subsites to preserve the integrity of the cap, prevent exposure to contaminated soil or debris, and restrict the use of on-site groundwater. Conduct a drinking well survey downgradient of the plume to assure no new drinking water wells have been installed.

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East Flat Rock. NC

Site name (from WasteLAN): General Electric Co/Shepherd Farm

EPA ID (from WasteLAN): NCD 079044426

Region: 4 City/County: East Flat Rock/Henderson

NPL status: (:RJ Final 0 Deleted 0 Other (specify)

Remediation status (choose all that apply): 0 Under Construction (:RJ Operating

o Complete'

Multiple OUs?· 0 YES (:RJ NO Construction completion date: 10 / 20 / 2000

(Final inspection of groundwater treatment system)

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Has site been put into reuse? 0 YES (:RJ NO

REVIEW STATUS

Lead agency: (:RJ EPA 0 State 0 Tribe o Other

Author(s) name: David Mattison/Stephanie Grubbs

Author(s) title: Author(s) affiliation: NC DENR

Engineer/Hydrogeologist

Review period: 2/12/2009 to 8/6/2009

Date(s) ofsite inspection: 5/ 14/2009

Type of review: Statutory

Review number: 0 I (first) (:RJ 2 (second) 0 3 (third) 0 Other

Triggering action:

o Actual RA Onsite Construction at OU # DActual RA Start .'

o Construction Completion [RJPrevious Five-Year Review Report

.0 .Other (specify)"

Triggering action date (from WasieLAN): 8/6/2004

Due date (five years. after triggering action date): 8/6/2009

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Five-Year Review Summary Form, cont'd Issues:

1. No institutional controls have been implemented at either of the Subsites. 2. No current drinking water well survey downgradient of the plume at the GE and

Shepherd Farm Subsites has been conducted recently.

Recommendations and Follow-up Actions: Major recommendations involve: Implement appropriate institutional controls at

both the Subsites, conduct a current drinking water well survey, and continue analytical monitoring of both surface and groundwater.

Protectiveness Statement: The remedies at both Subsites are protective of human health and the environment

in the short term because no human exposure pathways exist to contaminated soil or groundwater. The main source of contamination has been remediated through source removal, and the groundwater is being address by the GW treatment system. There are

. no known residents between the GE property and Bat Fork Creek (document plume area), and data has confirmed that no VOCs have been found in existing groundwater wells that exceeded the remediation goals for residents downgradient of Bat Fork Creek. The Spring Haven community and the few surrounding residents are supplied drinking water by a municipal well. .

To ensure long-term protectiveness, the following actions should be implemented. Impose institutional controls at both Subsites to preserve the integrity of the cap, prevent exposure to contaminated soil or debris, and restrict the use of on-site groundwater. Conduct a drinking well survey downgradient of the plume to assure no new drinking water wells have been installed.

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East Flat Rock, NC

1.0 Introduction ','

. The purpose of conducting a Five-Year Review is to determine whether the remedy im-p!emented at a Site is protective of human health and the environment. The methods, . findings, and conclusions of this review are documented in the Five-Year Review report.. In addition, Five-Year Review reports identify issues found during the· review, if any, and identify recommendations to address them.

The North Carolina Department of Environment and Natural Resources (NC DENR),' Division of Waste Management, Superfund Section, on behalf of the United States . Environmental Protection Agency (US EPA), Region IV, has conducted a Five-Year Review of the remedial actions implemented at the GE/Shepherd Farm Site (Site) (US EPA ID#NCD ..' 079044426). The Site is located in East Flat Rock, Henderson County, North Carolma. The

.review was conducted from December 2008 through June 2009 and the results of the review are documented in thi's report. The review was conducted in accordance with the Comprehensive Environmental Response, Compensation, and-Liability Act (CERCLA) §121 and the National

.Contingency Plan (NCP). CERCLA §121 states:

.If the President selects a remedial action that results in any hazardous substances, . pollutarits, or contaminants remaining at the site, the President shall review such remedial .

action no less often than each five years after the initiation ofsuch remedial action to assure' that human health and the environment are being protected by the remedial action being . implemented. In addition, ifupon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104J or [106J, the President shall . take or require such action. The President shall report to the Congress a list offacilities for which such review is required, the results ofall such reviews, and any actions taken asa result ofsuch '·eviews.

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The PS EPA interpreted this requirement further in the National Oil and Hazardous Substance Pollution Contingency Plan (NCP); 40 CFR §300.430(f)(4)(ii) states:" .

Ifa remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after' the initiation ofthe selected remedial action.

The methods, findings, conclusions, and significant issues found during the review are documented in this Five-Year Review report. This Five-Year Review was performed in a. manner consistent with the latest US EPA Comprehensive Five-Year Review Guidance (US

. ;

. " EPA, 2001). ..... .

The Site coJsists of one operable unit; the remedial action provides remediation (i· ~ .

.. contaminated grp.l;lIldwater. The remedy, as stated in the ROD, provided for remediation of .

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'.", contaminated groUn~water and soil. For groundwater the remedy stated: extraction Of .; •• 11·...• '

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Second Five-Year Review GE/Shepherd Farm Site

East Flat Rock, NC

groundwater from the GE/Shepherd Farm Subsites that is contaminated above the Maximum Contaminant Levels (MCLs) or the North Carolina Groundwater Standards; on-site treatment of . the extracted groundwater via air stripping and carbon adsorption; in-situ bioremediation; . discharge of treated groundwater to Bat Fork Creek; and, continued analytical monitoringfor contaminants in groundwater and surface water. For soils at the GE Subsite the remedy ·stated: placement of a multi-layer cap on the areas where the soil is contaminated above the . performance standards; continuous maintenance of the cap; and, usage restrictions on the capped areas. For soil at the Shepherd Farm Subsite the remedy stated: excavation of the top foot of soils contaminated above the performance standards; transportation of excavated soils to the dry sludge impoundment area on the GE property; and, backfilling, grading, and re-vegetation of the . excavated areas.

The triggering action for this review is the signing date of the First Five-Year Review report, August 6, 2004. This Five-Year Review for the GE/Shepherd Farm Site is a statutory review. A statutory review is conducted when ''upon completion of the remedial action, hazardous substances, pollutants, or contaminants will remain on Site above levels that allow for unlimited use and unrestricted exposure;' (US EPA Comprehensive Five-Year Review Guidance, June 2001, Section 1.3.1). In accordance with CERCLA §121 and the NCP, a statutory review is triggered by the initiation of the first remedial action that leaves hazardous substances, pollutants, or contaminants on site above levels that allow for unlimited use and unrestricted exposure.

2.0. Site Chronology

Table 1 lists the site chronology for selected events for the GE/Shepherd Farm Site.

3.0 Background

3.1 Site Description

.The GE/Shepherd Farm site is divided into 2 subsites, the GE Subsite and the Shepherd Farm Subsite. The former Seldon Clark Subsite was deleted by the US EPA from the GE/Shepherd Farm Site in 1996. See Section 3.5 Initial Response for additional information on the partial deletion of the Seldon Clark Property Subsite. .

GE Subsite

The GE Subsite is located at the southeastern comer of Spartanburg Highway (US. 176) and Tabor Road (S.R. 1809) in East Flat Rock, Henderson County, North Carolina. This slightly hilly, approximately 11O-acre tract of land is bound on the west by Spartanburg Highway, on the north by Tabor Road, and on the east by Bat Fork Creek. The southern boundary is a fence line south, east, and west of a recreational facility. GE also owns a plot of land located to the . . southwest of Spartanburg Highway, south of Bat Fork Creek, between the curved railroad tracks and the highway (Figure 1).

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East Flat Rock, NC

The GE Subsite includes the manufacturing and distribution facilities. Two major building structures are present on site, the manufacturing plant and the finished stock warehouse. A tall barbed wire, chain-link fence surrounds the entire property with the exception of the landspreading plots and the front of the facility. Security is maIntained at all times (Figure 2): "

. East of the plant is Demonstration Street, which includes lighting fixture displays and , several support facilities such as the fork lift shop, fabricating shop, reclamation yard, boiler ' house, oil storage building, drum storage area, outside vendor storage area, water tanks and · pumps, cryogenic tanks, gasoline pumps, and storage bins. A closed 0.5 acre landfill (formerly Landfill A) IS now paved over by this street.

, East of Demonstration Street, beyond,the paved plots, are approximately 26-acres of open, grassy field that was formerly used for landspreading, which slope eastward downhill toward Bat Fork Creek. Southeast of Demonstration Street, is the location ofa properly capped,

, landfill that was formerly a sludge impoundment. Southeast of the finished stock warehouse is a large 5-acre, active stormwater treatment pond. An underground drain line leading' from the, • manufacturing plant is used to transport the stormwater runoff to the treatment pond; ';1

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The area ~()uth of Bat Fork Creek (GE property) includes a small, I-acre, active stormwater treatment pond, a recreational area with an a(jjacent playground that was formerly, used as a landspreading plot, and a closed I-acre landfill (formerly Landfill B), paris ofwh~ch

f ~ :,are paved over by a'driveway. GE reported that 2 to 3 feet of clean fill was placed:over the" f landspreading plot when constructing the recreation area. ' '

,Shepherd Farm Subsite '"

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The Shepherd Farm Subsite is located on Roper Road, approximately 1,200 feet west of the Spartanburg Highway and southwest of the GE Subsite. This hilly, unfenced 3I-acre subsite ' is bounded on the north by Roper Road, on the north-northwest by the Hill Farm, and on the'west by Bat Fork Creek It is comprised of both residential and agricultural land. Mr. Shepherd :. maintains a residence on the property. In addition to this residence, a 22-acre manufactured " ';', '

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housing community, Spring Haven, consisting of 125 lots and a cornmunitycenter are presenton , the southern portiOIi of the Subsite. A small-unnamed intermittent tributary runs through the, ' niiddleoftheSubsite bef?re discharging into Bat Fork Creek (Figure 3).

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,Pormer Seldon Clark Subsite .,

TheSeldon ,Clark Subsite is located at the northeastern comer of the Spartanburg' ; . :.! I,

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,:; .. , , Highway and: Tabor Road. This' approximately I-acre field is bolindon the west by SpartanbUrg' (\,,;':

'- .'Highway, on the south by Tabor Road, and on the east by Jones Street, and on thenorth by . ' Second 'Avenue. '

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3.2 Site Topography, Geology, and Hydrogeology

The GE/Shepherd Farm Site is located within the Appalachian Highlands inthe southern Appalachian Mountains. Topography is characterized with large hills, rounded mountains, steep slopes and narrow valleys. The Hendersonville area is within the central plateau with a relief of 500 to 600 feet. The area surrounding the site consists of gently rolling hills and an elevation of approximately 2,100 to 2,500 feet. Most soils within the Blue Ridge Province are residual soils derived from weathering of the underlying bedrock. The soil at the site is generally described as micaceous, sandy silt near the surface, grading downward to a micaceous, silty medium to coarse sand.

Shallow groundwater in the area of the Site generally occurs within the residual and alluvial soils. Water occurs within the pore spaces and within the relict fractures and secondary openings of the underlying bedrock. These two zones comprise one shallow unconfined ~quifer

since the two zones are hydraulically connected as evidence by the lack of both a confining zone and significant head difference between two zones. Groundwater flow in the area generally follows the topography. The groundwater surface at the site has been documented in monitoring wells ranging from 3 to 29 feet below ground surface. The surface water features affected by the Site are Bat Fork Creek, Mud Creek, and an unnamed tributary on the ShepherdFarm property. Runoff, from both properties, discharges into Bat Fork Creek. At the Shepherd Farm property the runoff discharges to an unnamed tributary which then discharges into the creek 400 feet to the northwest.

The GE/Shepherd Farm Site contains two wetlands that could be impacted by the groundwater plume. One wetland is small and supports a population of the federally and state listed (endangered) bunched arrowhead (Sagittariafasciculate), the Bunched Arrowhead Wetland. The other wetland of potential concern is a large wetland along Bat Fork Creek at the eastern side of the GE Subsite, the Large GE Wetland. At the beginning of the monitoring program, this type of system, the Large GE Wetland, historically may have supported the bunched arrowhead, but no plants were known to exist. GE agreed to monitor these wetlands during the Remedial Action (RA). Biological monitoring dataand water level data can be compared to baseline data to assess whether wetland and sensitive receptors are adversely impacted by groundwater withdrawals. However, it is important to note that during the 2008 monitoring event, observations confirmed the bunched arrowhead continues to persist in the Bunched Arrowhead Wetland as well as the Large GE Wetland.

3.3 Land and Resource Use

General Electric is currently operating at the facility. The general land use along Spartanburg Highway is commercial and light industrial. The Shepherd Farm Subsite is mostly rural, residential, and agricultural. The land is lightly developed along Bat Fork Creek, both upstream and downstream of the site and along Mud Creek (which Bat Fork Creek discharges into approximately 6 miles downstream of the GE property). The land use for the area has and continues to be primarily agricultural, commercial, and residential. This is also the expected future land use for the Site and the surrounding area.

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Second Five-Year Review GEiShepherd FarmSite

East Flat Rock, NC

The' majority of the residents within the vicinity of the Site are connected to the City of Henderson public water supply. The Hendersonville Water Treatment Plant draws water from the Mills River watershed. Two of these intakes, on Bradley Creek and the North Fork bfthe

,, Mills River, are located in the Pisgah National Forest and supply approximately 50 percent of the water we use by gravity. The balance is pumped from the Main Stem of the Mills River. The GE facility has been connected to this public water system since it began operations. Although, many homes and businesses near the site have relied on private wells (drilled in the shallow aquifer and averaging about 120 feet deep) for potable water in the past, and some still rely on , privatle wells, but increasing numbers are being connected to the public system.

,3.4 History of Contamination

The General Electric/Shepherd Farm Site consists of three noncontiguous dispos~l areas in East Flat Rock, Henderson County, North Carolina. These disposal areas (the subsites) are known as the GE property, the Shepherd Farm property, and the Seldon Clark property. The GE Subsite is approximately 50 acres in size and located at the southeastern comer of Spartanburg' , Highway and Tabor Road. The Shepherd Farm Subsite is approximately 31 acres in size and is' located on Roper Road, approximately 2,500 feet southwest of the GE Subsite. Th~ Seldon Clatk Subsite is 1 acre in size and is located at the northeastern comer of Spartanburg Highway and' Tabor Road, directly across the street from the GE Subsite.

,From 1955 to present the GE facility has been used to develop, design, and,manufacture . complete high-intensity-discharge luminaire systems, which consist of the assembly of optical' ,,','components, ballasts, mountings, and high mast lowering devices. Also from 1955 to 1975, GE manufactured "constant-current" transformers at this facility. The transformers were filled with PCB-containing oiL During this period, GE generated a substantial quantity of PCB waste~ , ' Disposal of this waste prior to 1980 is not well documented, but in 1984~ PCB waste was sent to Alabama for disposaL It is possible that PCB-containing electrical components were deposited.~

_along with other wastes, into the dry sludge impoundment or the waste treatment ponds.

Landfill A on the GE Subsite received waste generated at the facility between 1955 and the 1960s. No infonmition is available concerning the types of waste, but it is assumed that the , wastes are from the manufacturing process at the time of operation. Landfill B, also on the GE. Subsite, is believed to have operated during the 1970s. Currently, the two former landfills have, 'been excavated, backfilled, and restored with !iassy vegetation and/or pavement. .. ,

Wasiewat~r, generated as a result of the plant process, contains metals and solvents. 'GE constructed the wastewater treatment facility in the mid-l 970s consisting of a lime,treatment , system to adjust the pH of the treated water prior to surface water discharge. Two~lined ,

'" wastewater tteatrmmt ponds were also constructed. These ponds were -constructed~f,native clay' ','~ ",", and were approximately 10 feet deep. The larger pond has a controlled exit valve at its discharge

point into thesmaller pond. Between 1977 and 1980, as part of the wastewater treatment, ,, process,wet and dry sludges generated in the wastewater treatment facility were landspread on several 'plots surrqunding the facility buildings. '

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East Flat Rock, NC

Underground storage tanks (USTs) at eighteen locations have been used by GE for storage of fuels, liquid supplies (paints and varnishes), and liquid wastes. According to GE, all USTs have been removed as of March 199 I, and all liquid storage is now performed in above ground storage tanks and drums.

From 1957 to 1970, GE contracted Mr. Shepherd to dispose of GE waste at the Shepherd Farm property. The GE waste was dumped, burned, and bulldozed in an approximate 3-acre area. Most of the waste was reportedly deposited into an old dry pond or ravine approximately 800 feet southwestof the Shepherd residence. At the time of the disposal, only the Shepherd residence was located on the property. Since the 1970s, the Spring Haven manufactured housing community has been constructed over the dumping area.

3.5 Initial Response

In 1980, the GE facility filed a Part A hazardous waste permit for storage under the Resource Conservation and Recovery Act (RCRA). In March 1982, GE petitioned to have its electroplating sludge delisted as a hazardous waste. By April 1982, the US EPA issued a preliminary decision to declare the electroplating waste as nonhazardous. The State ofNorth Carolina accepted the petition and delisted electroplating waste in October 1982. In) 984, GE elected to dispose of accumulated wastes offsite and therefore withdrew the Part A hazardous waste permit application and related interim status. On September 19, 1988, the US EPA formally recognized the state-approved delisting of electroplating sludge as a hazardous waste. GE acquired an NPDES permit for the discharge of treated effluent into Bat Fork Creek, which became effective on May 1, 1989. GE also acquired an air permit issued on February 25, 1988, to operate several air emission sources or clean air devices. .

In 1988 and 1989, EPA conducted Site Inspections and Investigations into the contamination at the GE facility, Shepherd Farm property, and the Seldon Clark property. Results of analysis revealed the presence of PCBs in soil and volatile organic compounds in the groundwater. The results indicate tetrachloroethene as the major contaminant present in groundwater beneath the site and, as discovered before, the greatest contaminant concentrations are present along the failed drain line (the underground drain line leading from the manufacturing plant, which is used to transport the stormwater runoff to the treatment pond). However, high concentrations ofVOCs were also found along the railroad line southwest of the failed drain line area, indicating that a preferential flow path may be present along the railroad, or that another source of contamination is present in this area. One possible source identified in this investigation was an old drainage ditch, which existed prior to construction of the drain line. After the US EPA Site Inspections and Listing Site Inspections were completed, the GE Shepherd Farm and Seldon Clark properties were proposed for inclusion on the NPL on February 7, 1992, as the "General Electric Co/Shepherd Farm Site". The Site was finalized on the NPL in December 1994.

The Seldon Clark Property Subsite was deleted from the NPL on November 1, 1996. Based on data gathered during the Remedial Investigation of all three Subsites in September

6


East Flat Rock, NC

1994. Five soil samples were collected from two soil borings on the Seldon Clark Subsite. Semi-volatile organic compounds, pesticides, and PCBs were found, but all were at . concentrations under the soil cleanup levels determined in the feasibility study. One surface .. water/sedimtmt sample was taken downgradient of this Subsite. Again, semivo1atiles and PCBs.· were found at concentrations below the soil cleanup levels. One groundwater sample was'

· collected downgradient of the suspected fill area at the Seldon Clark Subsite. This sample · contained one semi-volatile compound at trace concentrations. The ROD for the Site was signed. , on September 29, 1995. The ROD recommended soil and groundwaterremediation at the GE : Subsite and the Shepherd Farm,Subsite, but not for the Seldon Clark Subsite.

The EPA, community relations activities at the Site included a public meeting on August 3, 1995 to present to the public the Agency's Proposed Plan for remediation at the Site. Public· comments received during the 60-day public comment period were considered and addressed in the Responsiveness Summary. This document was included as an appendix to the ROD. There

· are no institutional controls for the Seldon Clark Subsite. A fiv~year review will not be . . conducted at the Subsite, due to the fact that soil and groundwater contaminants are below the .

· soil cleanup levels. The concentrations found in the samples taken do not present actirrent or future threat to public health or the environment.

3.6, Basis for Taking Action

From 1986 through 1991, GE tasked Law Environmental to conduct sampling investigations of soil and groundwater around the GE plant Site. In 1988 and 1989, as stated· above, the US EPA conducted SIte Inspections and Investigati~ns at the Site. In 1990; GE also . conducted a Phase IlIA Aquifer Characterization and Growidwater Treatment Study at the.GE. facility in preparation for performing groundwater remediation. In this study, a pilot

· groundwater recovery and treatment system was designed and installed at the GE subsite.·The · system consisted of four groundwater recovery wells, a 10,000-gallon equalization tank, an air

stripping tower, and associated piping and pumps with discharge going to Bat Fork Creek. Seven observation wells were also constructed for measuring water levels during an aquifer performance test. .

The US EPA completed the RIlFS in July 1995. The ROD issued in 1995 and Consent Decree filed with the U.S. District Court in 1996 defined the remediation goals and action for

'. soil and groundwater. The Baseline Risk Assessment, which quantified the associated Site risk, .; .... ,

· ;was completed in March of 1995. The ROD was issued September 1995. . '. .' . . .

. As summarized in the 1995 ROD, "Actual or threatened releases ofhazardous .... substances from this Site, ifnot addressed by implementing the response action selected in this

· RO£), may present an imminent and substantial endangermentto public health, welfare, or the ' '.' : environment.'

The eXp~sure 'ass~ssment evaluates and identifies complete pathways ojexposure to . : human population on or near the Site. Current exposure pathways include exposure through

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ingestion ofwater from private wells. Land use assumptions include residential, commercial/ industrial and child visitor scenario. Future use scenarios consider construction ofa water supply well within the groundwater contaminant plume at GE and Shepherd Farm and ingestion ofsoil, inhalation ofdusts and dermal contact with soils at Shepherd Farms, as a worse case scenario. Possible exposure pathways for groundwater include exposure to contaminants of concern from the groundwater plume in drinking water and through inhalation ofvolatiles evolvedfrom water through household water use. "

4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action are protection of human health and the environment and compliance with ARARs. A number of remedial alternatives were considered for the Site, and final selection was made based on an evaluation of each alternative against nine evaluation criteria that are specified in Section 300.430(f)(5)(i) of the NCP. The nine criteria include:

1. Overall Protectiveness of Human Health and the Environment 2. Compliance with ARARs 3. ,Long-Term Effectiveness and Permanence 4. Reduction ofToxicity, Mobility or Volume ofContaminants through Treatment 5. Short-term Effectiveness 6. Implementability 7. Cost 8. State Acceptance 9. Community Acceptance

The Assessment of the Site in the 1995 ROD, states, "Actual or threatened releases of hazardous substances from the Site, ifnot addresses by implementing the response action selected in the Record ofDecision, may present an imminent and substantial endangerment to public health, welfare, or the environment." The Remedial Action Objectives (RAOs) as stated in the 1995 ROD, Section 8 Remedial Action Objectives, "Considering the requirements for risk reduction and the risk-based remediation levels derived in the Baseline Risk Assessment, and the ARARs discussed previously, the remediation goals specifically developedfor the soil in the source areas ofthe GE/Shepherd Farm Site are presented in Table 21. The remediation goals for groundwater across the entire site are presented in Table 22. (See Table 2 and 3 of this report for the Remediation Goals for groundwater and soil as stated in the ROD).

The remediation goals, presented in Tables 21 and 22 (as stated above, Tables 2 and 3 for this report), were selected as the most conservative ofthe chemical specific ARARs, the healthbased risk goals, and the contract required quantitation limit (CRQL) that was attainable. The background concentration would have been selected as the remediation goal if it had exceeded the risk-based goal, as is the normal procedure. Remediation goals were also selected based on present andfuture land use at the site, assuming the GE Subsite would remain commercial/industria?, and Shepherd Farm Subsite to be residential. "

8

. Second Five-Year Review GE/Shepherd Farm Site

East Flat Rock; NC

As noted in the ROD, the goal of the selected groundwater remedy is to restore the groundwater to its beneficial use. Because this remedy resulted in hazardous substances, pollutants, or contaminants remaining on site above health-based levels that allow unlimiteduse

" and unrestricted exposure (i.e., contaminated soil consolidated beneath the cap) Five-Year . Reviews will be conducted after 'commencement of the remedial action to ensure that the remedy. continues to provide adequate protection of human health and the environment.

.4.1 Remedy Selection

. 4.1.1 1995 Record of Decision

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• • ..

The remedies stated in theRecord of Decision (ROD) dated September 29, '1995 provided for remediation of contaminated groundwater and soil. The description of the selected

- remedies in the ROD include: - ',I

Groundwater Both Subsites

Extraction of groundwater from the GE/Shepherd Farm Subsites that is . contaminated above the MCLs or the North Carolina Groundwater Standards, whichever are more protective for each particular contaminant. On-site treatment of the extracted groundwater via air stripping and carbon adsorption. ' ; , . .

In-situ bioreinediation. Discharge of treated groundwater to Bat Fork Creek . . Continued analytical monitoring for contaminants in groundwater and surfac~'

water.

GE Subsite .

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Placement of a multi-layer cap on the area where the soil is co~tarnin~ted.aboye . _the performance standards. Continuous maintenance of the cap. Usage restrictions on the capped area.

Shepherd Subsite

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Excavation of the top foot of soils contaminated above the performance. ' . '. ~ta~dards. '. . ' .." ':.. ,> <r.·' -

Transportation of excavated soils to the Dry Sludge Impoundment (DSI) area on" -the GE property. Backfilling, grading, and re-vegetation of the excavated areas.

9

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East Flat Rock, NC

4.1.2 Explanation of Significant Difference

The ROD was modified by an Explanation of Significant Differences (ESD) signed on September 25, 1998. The requirement to place a multi-layer cap on the areas where the soil is . contaminated above the performance standards was modified to:

• Excavate Landfill A and transport the contents to the DSI and backfill with clean fill.

• Excavate Landfill B and transport the contents to the DSI and backfill with clean fill.

• Place a multi-layer cap on the DSI.

4.1.3 Second Explanation of Significant Difference

The ROD was also modified by a second ESD signed on July 27, 2000. The modifications were to the groundwater remedy and the activities were modified to:

• Delete the requirement for the in-situ bioremediation for contaminated groundwater across the entire Site.

• Change the discharge location of treated groundwater from Bat Fork Creek to the GE operations facility.

The remedies were selected to protect human health and the environment, comply with Federal and State requirements that are legally applicable or relevant and appropriate to theremedial action and be cost effective. The US EPA selected both a source control and groundwater remedy for the site. At the completion of the remedy, the risk associated with this Site has been calculated to be within the accepted risk range determined to be protective of human health and the environment.

Because these remedies result in hazardous substances remaining on site above levels that allow unlimited use and unrestricted exposure, Statutory Five-Year Reviews will be completed to assess site conditions, contaminant distributions, and any other associated site hazards.

10

SecondFive-Year Review GEiShepherd Fann Site

East Flat Rock, NC

4.2 ~emedy Implementation .. The US EPA completed the RIfFS in July 1995. TheROD issued in 1995 andConsent

, Decree fih:id with the U.S. District Court in 1996 defined the remediation goals and action for soil and groundwater. After finalization of the Consent Decree, GE became the responsible party for remediation of the Site. GE contracted HSIGeotrans as the primary remedial action '

. contractor for the remedial action. In 2007, Geosyntec took over as the contractor for GE. .

The Remedial Design (RD) for soil and groundwater was initiated on September 30,1996: . The designs of the soil remediation activities were completed in April 1999, while the design for the groundwater remediation activities identified in the ROD were completed in September 2000. .

4~2.1 Soil Remedy

Shepherd Farm Subsite

The remedial action for soils specified in the ROD for the Shepherd Farm Subsite consisted of excavation of surficial soils (0 to 1 foot depth) containing greater than 1 part per· ' million (ppm) total PCBs. The remedial activities required temporary relocation of 14 residential families in the Spring Haven Community from October 14'through November 8, 1997.· ' .'. Excavatipn began on October 14, 1997. The excavation of the area was determined based on :

.. ' . .... nearly 400 ~oilsainples collec~ed on a 25-foot grid. The excavation area was approximately 4-' : I ' .. acres in size.. Surface soil removal consisted of excavating the soil; moving the :excavated soil to;'.

~ a stock-pile; transporting the soil via dump truck to the DSI at the GE Subsite; and, confirmation .. surveying to venfy that excavation was greater than or equal to one foot in depth. The

excavat'ion of the upper one-foot of soil was confirmed using pre-excavation and post-excavation , .'": ~ topographical surveys. In conjunction with the soil excavation in the residential area, a 30-mil ' -:"J '.:'

I... · ,:; <1 .. i ......... liner was ~laced in the crawl space under each house within the excavation zone.,. ..

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,'.' .. A total of735 cubic yards oflandscaping debris (including tree trunks and root balls)

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.were transported from the Shepherd Farm property to the DSI at the GE property. A total of '.t' '7,034 c~bic yards of contaminated soil was transported from the Shepherd Farm propertY'to the',

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;".~. " •. ',< . J.. ':'" ': '., . The ~~medial actIon for soils 'specified in the ROD for Landfill A, Landfili B, ,and the DSI ".. ":. " .. ' , " ." ,.' ""consisted of a. multilayer cap in areas that exceed the total PCB concentration .of 10 ppm.. Based" '.

, '. :,op findings of investigations completed for the Preliminary Design and additional data collection ." activities for the Intermediate Design Investigation, the ROD remedy for the landfills were . :', ; ,

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", . modified to replace the capping with removal, consolidation, and on-site contaiIinient. The US' , .: '>: .";

,T, . EPA issued ~ Explanation of Significant Differences (ESD)in 1998 describi'ngthe' , . ,.'; " '; ~odificationsto the ROD for the Landfill A and Landfill B. The 1998 ESD states that if the .'

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, ., .. , ,.' "": " material within the landfills is above the clean-up levels of10 ppm for PCBs, it will be .~.' ~

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East Flat Rock, NC

Landfill A

Excavation at Landfill A began on May 24, 1999. Surficial soil removal consisted of excavating the soil from the landfill; sampling to copfirm if remediation goals were met and if goals were not met, continued excavatin'g until remediation goals were achieved; backfilling and re-vegetating the excavated area; surveying the excavated conditions; and, disposing the excavated materials in the DSI. The average PCB concentration from the pre-removal soil samples within the estimated extent of the landfill was 107 ppm with maximum concentrations reaching 870 ppm. During the excavation activities, four separate burn trenches were excavated. The burn trenches were constructed by GE and used for the disposal and partial incineration of debris. Post-removal confirmation samples were collected and the cleanup criteria of 10 ppm total PCBs was achieved or further sampling and excavation was conducted within these areas.

A total of 11,698 cubic yards of material was excavated from Landfill A. An additional 1,053 cubic yards of material was excavated from areas near the landfill and adjacent to the DSI; these areas were referred to as satellite areas. The excavated soils were transported from the landfill to the DSI.

Landfill B

Excavation at Landfill B began on June 1, 1999 after completion of the majority of the Landfill A excavation. Surficial soil removal consisted of excavating the soil from the landfill; sampling to confirm if remediation goals were met and if goals were not met, continued excavating until remediation goals were achieved; backfilling and re-vegetating the excavated area; surveying the excavated conditions; and, disposing the excavated materials in the DSI. The average PCB concentration from the pre-removal soil samples within the estimated extent of the landfill was 28 ppm. Excavation for Landfill B was complicated due to the presence of a gas line in the southern portion of the excavation area and the unknown exact extent of the contamination. The volume of the soils excavated from this landfill was ten times the initial estimate. Post-removal confirmation samples were collected and the cleanup criteria of 10 ppm total PCBs was achieved or further sampling and excavation was conducted within these areas.

A total of 20,676 cubic yards of material was excavated from Landfill B. The excavated soils were transported from the landfill to the DSI.

Dry Sludge Impoundment CDS!)

In addition to soil excavated from the Shepherd Farm Subsite, all excavated materials from Landfill A and Landfill B were placed in the DSI prior to the construction ofa multi-layer cap. The multi-layer'cap included a composite liner consisting of 18 inches of clay, a flexible membrane liner, and a geocomposite drainage layer. Vegetative soil and topsoil were placed over the multi-layer cap. The area was seeded and fenced around the entire perimeter.

12


East Flat Rock, NC '

The DSI was designed to accommodate approximately 19,000 cubic yards of material. Ultimately, 33,427 cubic yards of material were placed in the DSI. The additional material was placed in such amanner as to increase the vertical extent of the DSI while maintaining the proposed aerial extent.

4.2.2 Groundwater Remedy

The remedial action for groundwater specified in the ROD for the GE/Shepherd Farm , Site consists of extraction of groundwater from the GE and Shepherd Farm Subsites that is

contaminated above MCLs or the NC Groundwa,ter Standards; on-site treatment of the extracted,' groundwater via air stripping and carbon adsorption; in-situ bioremediation; discharge of treated groundwater to Bat Fork Creek; and, continued analytical monitoring for contaminants in groundwater and surface water. In July 2000, the US EPA modified the ROD with anESD

, based on information generated during the development of tp.e Remedial Design. The modifications were to delete the requirement for in-situ groundwater bioremediation for contaminated groundwater across the entire Site and to change the discharge location of treated groundwater from Bat Fork Creek to the GE operational facility.

, In 1997, GE con~tructed and began operations of an accelerated groundwater remediation system (AGRS). The AGRS operated from July 1997 to September 2000 to initiate mass '

,'. , removal and provide performance data to support the final design., The AGRS consisted of four' recovery wells, a treatment system, an outfall, associated pumps, piping and controls. Extracted

.. ~ ,

, groundwater from the recovery wells was treated for volatile organic compounds (VOCs) using a ' - loW' profile tray air stripper. Off gases from the air stripper were treated using a vapor phase '

graiuilated activated carbon system. The final groundwater remediation system construction began July 10, 2000 and concluded with a [mal inspection on October 20, 2000. A total ofnine

" recovery wells are installed at the Site, five at the GE Subsite and four wells at the Shepherd ' ,Farm Subsite,. The recovery wells are connected to the treatment system by buried waterlines

I.' "'. ';:, and powered and controlled by buried electrical lines. The treatment system consists of tWo bag filters that are changed out on a regular basis and are monitored by a differential pressure switch; a 4-tray air-stripper to remove VOCs and semi-volatile organic compoUnds (SVOCs); and a granular activated carbon unit to remove and contain VOCs and SVOCs for later disposal. .

.. :: . , Effluent (treated groundwater) from the system is pre-treated for metals and then discharged to

the Hendersonville Waste Water Treatment Plant or Publicly Owned Treatment WOrks (POTW). This effluent is sampled'quarterly for remediation target compounds (RTCs) before discharge to

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f thepOTW. ,Effluent air is also sampled during operations to ensure proper function 'of the air, , " : ",

" 'stripper and to ensure remediation goals are met. ' , ' '-.'

Based on Groundwater Monitoring Reports from March ZOO 1 through December· 2002, ." ,~

'"j ,:..'. ,influent and effiu'ent' air data indicated poor performance of the granular activated carbon unit. " r" ;.

': " ..-<. Frprri Marcl,J. through September 2001, the carbon unit began to accumulate condensate water and ';' , "I ,

, some carbon was released through the screen within the unit. This release of carbon may hav'e . '.;'! ,.", , cOl1tributed to elevated concentrations of the RTCs in the treatment system effluent air siunples. ,

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East Flat Rock, NC

and precautionary measures were taken to reduce water accumulation in the carbon unit (changing the controls on the air stripper, raising the height of the piping so that splashing water would fall into the air stripper and not the carbon unit, and installing a knock-out tank). Poor perfoIrnance of the granular activated carbon unit for the treatment of the air stripper effluent airwas again noted from September 2001 through September 2002. In September 2002, a duct heater was installed between the moisture separator and the carbon unit to increase the temperature of the influent air and reduce moisture ofthe unit. Based on the December 2002 inspection, these changes within the unit have drastically improved the unit performance and demonstrated significant improvements in reduction efficiency.

When the AGRS was operational, July 1997 to September 2000, a total of 31.7 million gallons of contaminated groundwater was extracted and treated. A total of 20.6 million gallons of treated water was discharged to Bat Fork Creek. The remaining 10.9 million gallons was used as process water in the manufacturing facility, treateq for metals, and then discharged to the POTW. The AGRS removed an estimated 311 pounds ofVOCs from the groundwater at the GE Subsite.

Performance data from the AGRS was used to support the design of the GRS. Construction of the GRS was completed in September 2000 in accordance with the Final Design and Remedial Action Work Plan for groundwater. It consists of five recovery wells at the GE - _ subsite, four recovery wells at the Shepherd Farm Subsite, a treatment system, associated pumps, piping, and controls. The GRS includes two bag filters, a 4-tray low-profile air stripper to remove VOCs from the extracted groundwater, and a GAC unit to remove and contain any VOCs from the air stripper emissions. Water effluent (treated groundwater) is discharged to Hendersonville Water and Sewer Department Plant or POTW. Water effluent is sampled

-quarterly for the RTCs upstream of its discharge to the POTW. Since November 2004 and in agreement with the Hendersonville Water and Sewer Department, metals pre-treatment has not been required by the POTW. The water effluent meet the Industrial Use fermit #1 held by GE in an agreement with the POTW.

The GRS has been operational since October 2000. As of September 29, 2008, the volume of groundwater extracted and treated was 106,187,570 gallons. Groundwater was extracted at an average rate of30.2 gallons per minute for pumping year 2007 to 2008.

4.3 System Operation/Operation and Maintenance

As stated by Geosyntec (Environmental Consultants ofGE Lighting Systems) regarding the O&M at the Site in the Annual Groundwater Remedial Action Performance Monitoring Report':'2008 (submitted December 2008), "As a consequence ofthe operational issues during pumping year 2006 and 2007 and the age ofthe GRS, GE budgetedforfour quarterly O&M events to conduct the recommended O&Mtasks outlined in the O&M manual; these tasks include air stripper cleaning, recovery well diagnosis, well pump cleaning, flow meter cleaning, etc. To date, three ofthese quarterly O&M events have been conducted. Additionally, Geosyntec performed at least eight separate "troubleshooting and repair" events throughout the year to address unexpected shutdowns and operational issues. Collectively, these efforts have

14

second Five-Year Review GEiShepherd Farm Site .

East Flat Rock, NC

• Relays and other electronic components were relocatedfrom below grade vaults to above grade vaults at R W-5, -6, and -7; this step has eliminated the potential for shorting andfailure ofrelays which were the most common cause for recovery

, well shutdown and subsequent GRS shutdown. • Surge protection was incorporated in the above gyound electronics vaults at the

four Shepherd Farm recovery wells and R W-5, -6, and -7; thls task has reduced the'potentialfor a programmable logic controller (PLC) input cardfailure. '.

• The PLC software was re-programmed to avoid a GRS shutdown due to a singie . motor overload; this step vastly improved the uptime ofthe GRS overall.

• Waterproofdisconnect switches were installed at each recovery well to. reduce the . potential for shorts due to surface water infiltration into the' well vaults; this task

eliminated a safety hazard as well. • A relay was installed above the Shepherd Farm PLC input card to improve the

quality and consistency ofthe voltage andprotect the input card. ' • The Sensphone Autodialer was updated and re-programmed to provide Geosyntec

with daily status faxes ofsix primary alarm conditions andalann alerts when triggered. " '

... ' The original cost estimate to implement the groundwater and soil remedial actions, as '. described in the ROD, was $4,578,440 and $855,297, respectively, with a total remedy cost of

$5,433,737. The ROD estimated the O&M at the Site to be $3,200,440 over the 15 years of the estimated operation time. No other estimated annual O&M was calculated in the ROD.· More

. detailed cost estimate documentation can be found in the Feasibility Study. The PRP reported costs for groundwater and soil were $1,350,000 and $2,200,000, respectively, (with present worth O&M not included) with a total cost of$3,550,000. Annual O&M cost as submitted by Geosyntec are shown by below: .

"f Year O&M External Costs Total Costs 2002 $36,000 $36,000 2003 $7,000** , ~$40,000

2004 $26,478 $26,478 2005 $4,287** ~$40,000

2006 $4,172** ~$40,000

2007 $39,659 $39,569 2008 $83,660' . $83,660

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$40,000. Since Geosyntec's involvement in 2007, an estimate of the proportion of the total O&M costs into regular, preventative maintenance-type tasks conducted quarterly compared to tasks for troubleshooting/repairs, modifications and upgrades. A further breakdown of these

.proportions for 2007 and 2008 is below:

Year Quarterly O&M and Troubleshooting/repairs, preventive maintenance modifications, uP2rades·

2007 $20,000 $19,569 2008 $35,000 $48,650

, 5.0 Progress Since Last Five-Year Review

This is the Second Five-Year Review Report. The Protectiveness Statement for the first. five-year review in 2004 expressed. the protectiveness of the remedial actions and that the site was protective of human health and the environment. The protectiveness statement, as written in the 2004 Five-Year Review, stated:

"The remedies at both subsites currently protect human health and the environment in the short-term because the main source ofcontamination was remediated through the source removal. Currently no human exposure pathways exist to contaminated soil or \ groundwater. Howeyer. in orderfor the remedies to be protective in the long-term, the' following actions need to be taken to ensure long-term protectiveness: Proposal of Institutional Controls and continued optimization ofthe groundwater remedial system. "

16


East Flat Rock, NC

The following table is a copy ofthe Recommendations and Follow-Up Actions that were recommended for the Five-Year Review in 2004.

Issues .Recommendations/

Follow-up Actions Party

Responsible Oversight Agency

Milestone Date

Affects Protectiveness?

(YIN)

Current Future

Implement institutional controls for the capped area as p(:r the ROD

Implement Institutional controls and review

implementation in next five-year review

GEwith agreement & cooperation

of land

EPA & State

Before next five

year review

N N

owners

Large volume of contaminated groundwater versus hydrological requirements ofthe bunched arrowhead

Continued optimization of the GRS.

GE EPA & State

Before next five

year ' review

.Y Y

.-

Groundwater clean-up goals should reflect new lower quantitation limits

- ROD needs to be modified to reflect new

goals.

EPA & State ' EPA & State

Before next five

year review

N N

Determine if treatment Evaluate levels of GE EPA & Before N N

of extracted groundwater for metals is necessary

-

metals in groundwater to determine if

treatment is necessary for discharge to the

POTW.

State next fiveyear

review ,

Unsecured monitoring well and residential well at former Womack residence.

. Properly abandon the residential wellat the

former Womack residence and

determine if the monitoring well on the property is necessary.

GE with agreement & cooperation

ofland owners

' EPA & _ State

Before next five

year review

N

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Second Five-Year Review GEiShepherd Farm Site .

East Flat Rock, NC

The following are the explanations or discussions in response to the five issues stated .during the first five-year review report: .

Recommendation

Status (Ongoing, .Complete; Considered and Not Implemented, or Carried over to this

FYR)

Status Comment Completion Date (if

applicable)

Implement ICs on the capped area

Carried over to this Five-Year Review and retained as a recommendation

Not completed as of Second Five-Year Review

Planned by August 31 , 2010

..

Continued optimization of Ongoing Geosyntec has made N/A the GRS. several modifications to

the GRS, which has resulted in a vast improvement in the uptime and productivity of the GRS.

ROD needs to be modified Not implemented The US EPA determined N/A to reflect new goals. that although the

quantitation limits for two of the COes at the Site have been lowered; the protectiveness of the numbers used as the remediation goals are protective of human health

Evaluate levels of metals Not Implemented Since November 2004 and N/A. in groundwater to in agreement with the determine if treatment is Hendersonville Water and necessary for discharge to Sewer Department, metals thePOTW. pre-treatment has not been

required by the POTW. The water effluent meets the Industrial Use Permit #1 held by GE in an agreement with the POTW.

Properly abandon the Completed Geosyntec personnel July 2008 residential well at the . visited this property and a former Womack residence small electronics store is . and determine if the now located at the monitoring well on the property. ·The property property is necessary. owner indicated that he

recalled the presence of the water well in his driveway, but that he had backfilled it with fill material and paved over it with asphalt in 2004 or 2005.

18

6.1


East Flat Rock, NC

6.0 Five-Year Review Process

Administrative Components

The NC DENR, Superfund Section, completed the five-year review process for the GE/Shepherd Farm site. David Mattison (Environmental Engineer) and Stephanie Grubbs (Hydrogeologist) from NC DENR were responsible for gathering and reviewing data for this review. Telephone or email discussions/interviews with Michael Townsend, US EPA Remedial Project Manager (RPM) were conducted. Other activities conducted for this review include document review, site inspection/site meeting on May 14,2009, community involvement interviews (conducted by Angela Miller, US EPA), and the Five-Year Report preparation.

6.2 Community Involvement

The US EPA conducts all community involvement activities regarding the remedial activities for the Site. The US EPA interviewed several members of the community by telephone, as part of the Five Year Review for the General Electric/Shepherd Farm Site. All individuals that were interviewed were notified that the Five Year Review was being conducted at the Site and that a final report will be placed in the local information repository located at the Henderson County Public Library, 310 N. Washington Street in Hendersonville, North Carolina, for the public to review. Summaries of those interviews are included in Attachment 3. After the five-year review has been approved and signed by the US EPA, a notice will be placed in the local newspaper announcing the release of the fmal Five-Year Review report and copies will be placed for the public to view at: the US EPA Record Center, 11th Floor, 61 Forsyth Street, SW, Atlanta, GA 30303; the information repository located at the Henderson County Public Library, 310 N. Washington Street in Hendersonville, North Carolina; and, on the US EPA website (http://www.epa.gov/superfundlindex.htm).

6.3 Document Review

This five-year review consisted of a review of relevant documents including the signed ROD and ESDs, RI Report, Remedial Action Reports, Annual Groundwater Remedial Action Performance Monitoring Report, the previous Five-Year Review Report. Applicable groundwater and soil clean-up standards and other ARARs, as listed in the ROD, were also reviewed and checked for updates. See Attachment 1 for a complete list ofdocuments reviewed.

ARAR Review

Section 121 (d) (2) (A) ofCERCLA specifies that Superfund remedial actions must meet any federal standards, requirements, criteria, or limitations that are determined to be legally applicable or relevant and appropriate requirements (ARARs). ARARs are those standards, criteria, or limitations promulgated under federal or state law that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a

19

6.4


East Flat Rock, NC

CERCLA site. To-Be-Considered criteria (TBCs) are nonpromulgated advisories and guidance that are not legally binding, but should be considered in determining the necessary level of cleanup for protection of human health or the environment. While TBCs do not have the status of ARARS, the US EPA's approach to determining if a remedial action is protective of human health and the environment involves consideration of TBCs along with ARARs.

Chemical-specific ARARs are specific numerical quantity restrictions on individually listed contaminants in specific media. Examples of chemical-specific ARARs include the MCLs specified under the Safe Drinking Water Act as well as the ambient water quality criteria that are enumerated under the Clean Water Act. Because there are usually numerous contaminants of

.. potential concern for any Site, various numerical quantity requirements can be ARARs. The final remedies selected· for this Site were designed to meet or exceed all chemical-specific ARARs and meet location- and action-specific ARARs.

Chemical-specific ARARsidentified in the selected remedy within the ROD for the groundwater at this Site and considered for this five-year review for continued groundwater treatment and monitoring are listed in Table 4. The review of ARARs for the groundwater . contaminants identified with cleanup goals in the 1995 ROD suggests that federal standards (i.e., MCLs) and state standards for three of the contaminants have changed; however, the changes are less conservative and therefore the remediation goals set forth in the ROD are still applicable.

In performing the Five-Year Review for compliance with ARARs, only those ARARs addressing risk posed to human health and the environment (i.e., addressing the protectiveness of the remedy) were reviewed. This is in keeping with current US EPA guidance on five-year reviews.

6.4.1 Original ARARs from the 1995 ROD

Federal ARARs • 40 CFR Parts 261,263,264, and 268 promulgated under the authority of the

Resource Conservation and Recovery Act (RCRA) and RCRA as amended (40 USC Section 6901 et. seq.)

• Toxic Substances Control Act (TSCA) (40 CFR 700-789) • PCB Spill Cleanup Policy (40 CFR 761) • Guidance on Remedial Actions for Superfund Sites with PCB Contamination

(OSWER Directive No. 9355.4-01, Chapter 3) • Department of Transportation Hazardous Materials Transportation Act (49 USC

1801) • Clean Water Act (CWA 33 USC Section 1251-1376,40 CFR Part 121, 122,

125,131) • Clean Air Act ( 40 CFR Part 50, Part 60, Subpart A and Subpart B, and Part 61) • Occupational Safety and Health Administration (29 CFR 1910, Part 120) • Safe Drinking Water Act (40 USC Section 300; 40 CFR Part 141, 143) • Fish and Wildlife Conservation Act (16 USC 2901 et. seq.)

20

Second Five-Year Review GEiShepherd Fann Site

East Flat Rock, NC

.. Floodplain Management Executive Order (Executive Order 11988; 40 CPR· 6.302) .

• Endangered Species Act (16 USC 1531) • Wetlands Management Executive Order (Executive Order 119990; 40 CFR

·6.302) .

State ARARs " . . .Regulations for the Management of Hazardous Waste promulgated under the .

authority of the NC Waste Management Act (North Carolina Administrative , Code (NCAC) Title 15A,Chapter 13A) .

• Regulations for the disposal of Solid Waste promulgated under the ~uthority ~f

the NC Hazardous Waste Commission Act (NCAC Title 15A, Chapter 13B)· • . NC Drinking Water and Groundwater Standards; Groundwater Classifications

: I, , and Standards (NCAC Title 15 Chapter 2L) • NC Surface Water Quality Standards (NCSWQS) Classification and Water ': ..

Quality Standards (NCAC Title 15A Chapter 2B) . • NCSWQS Technology-Based Effluent Limitations (NCAC Title '15A Chapter 2,

.Subchapter 2B.0400) • NC Drinking Water Act (NCPWA) (General Statutes Chapter 130A, Article 10)

. . , NC SedimentationControl Rules (NCAC Title 15A Chapter 4) .

,: . , \' • ·NC Air Pollution Control Regulations (NCAC Title,15A Chapte~ 2D) ... , . :' I .. NC .Water PollutIon Control Regulation (NCWPCR) Wastewater Discharge to .,

Surface Water (NCAC Title 1~, Chapter 2; Subchapter 2H)· .

6.4.2 Current Applicable ARARs ,

For the current groundwater remedy, site-specific ARARs are identified as follows: . . Contract Required Quantitation Limit (CRQL), US EPA Safe Drinking Water ActMaximum . .Contaminant Levels (MCLs) and groundwater standards specified in NCAC 2L ar~ ARARs for

. Site groundwater. At the time the ROD was prepared, a baseline risk assessment wa~ 'conducted.. '.": '

The current NC 2L Groundwater Standards, the US EPA CRQLs and MCLs for volatile and ~' . inorganic compounds are still valid for the groundwater remedial action objectives as stated in

the ROD. Refer to Table 4 for the COCs and the associated ARARs identified in the 1995 ROD. . ', .. \

.At the time the ROD for soil was prepared, a baseline risk assessment was conducted. , ,.\,,'

. The soil clean-up gOl;lls as stated in the ROD are still applicable. The ROD specifiedrefuediation . .'.:'

. ,. goals for PCBs is 10 mg/kg at the GE Subsite and 1 mg/kg at the Shepherd Farm Subsite. .

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Second Five-Year Review GEiShephe(d Farm Site

East Flat Rock, NC

6.5 Data Review

As stated in the previous Five-Year Review and Section 4.2.1 of this Five-Year Review Report, the soil remedy was completed in 1999. Soil data since the completion of the soil remedy is limited due to the nature of the remedial action which was comprised of removal of the top one foot of contaminated soil at the Shepherd Farm Subsite and excavating and capping the soil at the GE Subsite. No soil sampling has been conducted since the last Five-Year Review.

Groundwater

Groundwater quality data is collected annually from performance monitoring well. networks at the GE and Shepherd Farm Subsites and a subset of nearby residential wells. See Table 5 for the Performance Monitoring Schedule. The most current data was collected and reported in the Annual Groundwater Remedial Action Performance Monitoring Report-2008 by Geosyntec Consultants. The following information is a summary of the data found in the Annual Groundwater Remedial Action Performance Monitorin~ Report-2008 by Geosyntec Consultants.

As reported in the Annual Groundwater Remedial Action Performance Monitoring Report-2008 by Geosyntec Consultants, significant modifications to the GRS within the last year resulted in a dramatic increase in uptime and performance. As a result, mass removal for pumping year 2007-2008 reflects similar amounts of water volume and VOC mass removal as during the first three years of operation. After eight full years of pumping, the GRS has extracted and treated over 106 million gallons of groundwater, of which 15.5 million gallons occurred in pumping year 2007-2008. Groundwater was extracted at an average rate of 30.7 gallons per minute in 2007-2208 and resulted in a removal of 33.6 pounds ofVOCs. The flow rate was close to the design flow rate of 32 gallons per minute.

A target hydraulic containment zone was·established for each Subsite during the RD through the development of a numerical groundwater model. The model was used to select all well locations and extraction rates that maximize plume containment while minimizing negative impacts to the wetlands. Figures 4 and 5 depict the observed hydraulic containment zones located around the recovery wells at the GE and Shepherd Farm Subsites, respectively. The hydraulic containment zones were determined by drawing groundwater flow lines perpendicular to the equipotential lines that define the potentiometric surface. Both figures reveal that the capture zones of each individual recovery well merge upgradient into to a single hydraulic . containment zone that encompasses much of the GE and Shepherd Farm Subsites.

A statistical analysis of the performance well data was completed using data from the annual performance monitoring data and reported on in the Annual Groundwater Remedial Action Performance Monitoring Report-2008. This report stated that, the Mann-Kendall nonparametric test was performed on each performance monitoring well for each remedial target

22


East Flat Rock, NC

co~pounds. This test was utilized to detennine if the concentrations of the remedial target compounds exhibit a statistically significant upward or downward trend at a given confidence interval (for this assessment a confidence interval of 95% was applied). Care must be taken when assessing the historical results since reporting limits have generally decreased since the inception of the GRS in 2000. When an analytical result is non-detect, a concentration value of half th~ reporting limit has been established as an input for VOCs and half the instru~ent' detection limit for metals. This is done to prevent false upward or downward trends through changitig reporting limits. Furthennore, compounds with two or fewer detections at agiven well during the historical record cannot be analyzed for trend. ' '

Table 6 and Table 7 present the results of the trend analysis for VOCs and metals, respectively. This analysis was perfonned on data collected since the GRS start-up in September 2000. Only tWo of the 47 trends analyzed for VOC concentrations (l,2-DCA in MW-27A and cis..:I,2-DCE in MW-12) and one of 18 trends analyzed for metals concentrations (manganese in MW-27) demonstrated an increasing concentration trend. Other important trends stated in the December 2008 Annual Groundwater Remedial Action Perfonnance Monitoring Report are:

':"

• The increasing trend in PCE concentrations at MW-22A and MW-66 observed in 2007 has diminished such that no significant trend (with 95% confidence) exists

'"'' at these two locations. ' ., The PCE concentration at MW-29 alongthe northern boundary oftheGE Subsite

hasbeen showing a steady decline since September 2004 andwas reported at2.0 ,ppb, only slightly higher than the remediation of I ppb. , '

• PCEat MW-16 (downgradient of RW-5)has declined from concentrations, exceeding its remediation goals since September 2006. ,

. ,"; .: • Remediation goal exceedances of PCE and TCE at MW-3 have diminished since .:',;;''-", December 2002 and VOCs have not been reported in this well since September ',' "', \ " 2006..

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.' ' Farm Subsites are shown in Figures 2 and 3, respectIvely. Perfonnance monitoring well~:'were " ..... -. "'",-...

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I Second Five-Year Review

GEiShepherd Farm Site East Flat Rock, NC

GE Suhsite

The performance monitoring network consists of 16 wells. Sampling was last conducted between September 16 and 18,2008. The results revealed the following:

VOCs • PCE was detected above the remediation goals (RGs) of 1 ppb at 13 of 16

performance well locations. The highest PCE concentration was 260 ppb at MW14.

• TCE was detected above RGs of 2.8 ppb at 9 of 16 performance well locations. The highest TCE concentration was 95 ppb at MW-27A.

• Chloroform was detected above the remediation goals (RGs) of 1 ppb at 2 of 16 performance well locations, MW-12 at 11 ppb and MW-12A at 12 ppb

• 1,2-DCA was detected above the remediation goals (RGs) of 1 ppb at 1 of 16 performance well locations, MW-27A at 3 ppb.

• Benzene, cis-1 ,2-dichloroethene (cDCE), trans-1 ,2-DCE, and vinyl chloride were not detected above their respective RGs at any of the performance well locations.

Metals • Manganese was detected above its RG of 50 ppb at 7 of 16 performance well

locations. The highest manganese concentration detected was 1,500 ppb at MW15. Note that the RG for manganese is a secondary Federal Drinking Water Standard that is based upon characteristics other than human health risk, such as taste and odor.

• Lead and Nickel were not detected above RGs at any of the 16 performance well locations.

Table 8 is the summary of the performance well analytical results for the GE Subsite September 2008 sampling event. See Attachment 4 for a complete table that shows all the performance well analytical results since September 2000 to present.

Shepherd Farm Suhsite

The four performance monitoring wells, two saprolite monitoring wells (MW-66 and MW-64) near Bat Fork Creek and two shallow bedrock monitoring wells (MW-64A and RWSF1, an active recovery well that is sampled as a performance monitoring well) at the Shepherd Farm Subsite were sampled on September 17, 2008. The results revealed the following:

VOCs • PCE was detected above RGs of 1 ppb in all four performance well locations.

PCE concentrations ranged from 11 to 60 ppb. • No other VOCs were detected above their RGs at any of the performance

monitoring well locations.

24


East Flat Rock, NC

Metals • No metals were detected above their respective remediation goals at any' of the

. four performance well locations.

These September 2008 results did not differ appreciable from those measured in September 2007. Table 9 is the summary of the performance well analytical results for the Shepherd Farm Subsite September 2008 sampling event See Attachment 4 for a complete table that shows all the performance well analytical results since September 2000 to present

Residential Well Monitoring

Seven off-site residential wells were selected for annual sampling based on their location, depths, and end-uses of the water. The intention of the sampling was to evaluate the extent of groundwater contamination, if any, outside the sampling boundary of the GE Subsite. Four of the seven residential wells have been part of the annual residential well sampling program that

. began in 1997 as part of the AGRs; three residential wells were added in 2000 when the GRS' was constructed. Residents rely on well water at two of the residences (WW-33 and WW-34)for potable purposes. As stated in the kumal Groundwater Remedial Action Performance . Monitoring Report-2008, all others reportedly are connected to city water or are provided bottled water by GE.

The off-site residential wells network has required two modifications since 2005. First, the property containing WW-17 was sold in April 2006, and since then GE's contractors have

"be~n unable to receive. permission to sample WW-17. The new owner·indicatedin·.2007 that the . well was buried in his front yard. Second, it was learned by Geosyntec in 2007dUririg the a~ual sampling event, the owner ofWW-82 had a second well on his property that is a deep bedrock welL Prior to 2007, it had been reported that WW-82 was a deep bedrock well and was sampling'

',.};;.; . via an exterior spigot However, during the 2007 sampling event that the residentialwell "" .: ".

, .'.',..'.~ , . ,' .. " . historically sampled at this residence was a shallow well, which was used for a potable source. . As such, it appears that the deep bedrock well has not been monitored and has not 'been used by ..the·residences historically during the operation of the GRS. The resideIit indicated that he . ::.. Intended to u~e the deep well, which Geosyntec assigned WW-82B in 2.007, for imgation;.'·· however, the pump has been broken since 2007 and the well has not been used according to the resid<;:Iit . '

. .

On September 17 and 18, 2008, Geosyntec collected samples from seven residential wells: WW-5, WW-28, WW-33, WW-34, WW-73, WW-82, and WW-82B. The results revealed the followin'g:

• VOCs were not detected above reporting limits or RGs in any of the se~en residential wells. These wells have been non-detect since sampling began in September 2000.

;.} " • . Manganese was detected above its RG of 50 ppb at one residential well location . (WW-82),'where it was detected at'a concentration of 120 ppb. Note that the RG(.. : J.:' ,....

:.... ..( . for manganese is a secondary Federal Drinking Water Standard that is based upon'

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Second Five-Year Review GEiShepherd Fann Site

East Flat Rock, NC

characteristics other than human health risk, such as taste and odor. • Lead was detected above the RG of 15 ppb at WW-82 at 24 ppb and WW-82B at

160 ppb. Because these wells are located hydraulically upgradient of the Site, these detections are likely to be related to plumbing or piping issues associated with each well.

See Attachment 4 for a complete table that shows all the performance well analytical results since September 2000 to present.

As stated in the protectiveness statement, a current drinking water survey is being requested which would verify that no new groundwater users have installed drinking water wells. However, it is known that there are no residents between the GE property and Bat Fork Creek, a gaining stream. Bat Fork Creek would intercept any contaminated groundwater that should intersect the creek. Data has also confirmed that no VOCs have been found in existing groundwater wells that exceeded the remediation goals for residents downgradient of the GE property on the opposite side of Bat Fork Creek. At the Shepherd Farm Subsite, the Spring Haven Community is supplied municipal water and the few residents not within the subdivision are also supplied municipal water. \

Treatment System Influent/Effluent Monitoring

Extracted groundwater is treated for VOCs using a 4-tray air stripper. Treated groundwater is piped to the GE facility ad discharge to the POTW. The air effluent from the stripper is directed through a granular activated carbon (GAC) unit prior to discharge to the atmosphere. The treatment system water and air effluent are sampled routinely during operations to ensure proper function of the air stripper and carbon ~it, to ensure remediation goals are met and to ensure POTW and air emission requirements are met.

Influent and effluent groundwater samples from the treatment system were collected approximately quarterly through June 2008, and monthly during July; August and September 2008. Effluent groundwater samples for VOCs and metal were collected within the treatment building after treatment by the air stripper. Benzene, Chloroform, 1,2-DCA, PCE, and TCE were detected in the influent sample above their respective remediation goals during the past five years. However, these four VOCs were not detected above their respective reporting limits in the corresponding effluent sample, indicating effective groundwater treatment by the air stripper. Table 10 is a historical summary of the groundwater influent/effluent results since GRS start-up.

Treatment system influent arid effluent water analytical results between December 2000 and September 2008 are Table 11. Unlike other years, additional samples were collected during July and August 2008 to verify the unexpected PCE "breakthrough" in the effluent sample from June 24, 2008.' It has been hypothesized that the June sample was collected at a time of higher than normal discharge (approximately 40 gpm), which may have influenced the result. However, the July and August samples were collected during periods oflower than normal discharge (20.3 gpm) and higher than normal discharge (46.7 pgm), respectively, and the VOCs were not detected in either effluent sample. Because of these findings and the recognition that the influent

26


East Flat Rock, NC

sample concentrations have been reasonably consistent during the year, the June 2008 effluent results are deemed anomalous.

Air influent and effluent samples from the vapor stream were collected three times in 2004, once in 2005, once in 2006,twice in 2007, and twice in 2008. The results revealed that the GAC effectively removes the bulk mass of the VOCs, which is composed primarily ofPCE. For

, the September 15, 2008 sampling event, the overall VOC removal rate was found to be 85% (96% for PCE).

,....Surface Water and Sediment

.":' ,", . .; .. ' Six surface water monitoring stations (SW-l through SW~6) are sampled annually to assess surface water quality in Bat Fork Creek. Background surface water quality in Bat Fork Creek is ,evaluated at SW-l due to its upstream location of both the GE facility and the Shepherd Farm Subsite. SW-2 is located between these locations. SW-3 lies immediately downstream of the GE Subsite at the intersection of Bat Fork Creek and Tabor Creek and provides insights into

_creek water quality as it exist the Site. Figure 6 is a location map for all surface water sample locations.

I"

Samples SW-l, SW-2, and SW-3 are analyzed for the eleven contaminants and PCBs. Three additional surface water locations (SW.,4, SW-5, and SW-6) in Bat Fork Creek at the GE

, 'Subsite are sampled for VOCs only to increase the spatial resolution of VOCs. The results have been screened against the NC DENR's Division of Water Quality Standards per 15ANCAC 2B (e.g., the "2B Standard"). The results from the surface water samples collected on September 16, 2008 reveal the following:

.' PCE was detected in only one of six samples (SW-2) and was reported at a , . ,:, concentration of 1.0 ppb, which is below the 2B Standard of 3.3 ppb.

:, ...; 1>."., ~.~ , . ", <" { .:. ::',," • Lead and total PCBs were not detected above their respective reporting limits. ' "

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• Manganese was detected in two samples; however, there is no 2B Standard for ~, :il;;:i.<:j, , this constituent: ' '

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Table 12 is a summary of surface water results since the GRS start-up. Although PCE ' ' .. ' .~. ..; "has been the only organic remedial target compound detected historically in the surface water

samples, it has not been reported at concentrations above its 2B Standard during any event. The '.. " ~ . 2008 results also provide additionalevidence that ~CE discharged to Bat Fork Creek has been ,,:: . - .. \

..', ~ , .:. greatly reduced since 2003 based o~ the reduction in the number or'detections in the creek water, , "

'.~ ,'.' o • • •• , .1·~'.,and the, related concentration declines. This trend-is noteworthy in the context of persistent \' .... ....., ,I, .;~o~ghtconditions since'2003. ",' , " ," ~. i ·t.. ."

,~):;:'~~~':<':'::"\:" ~',' ',: "three sediment sampling stations (SED-I; SED-2, a~dSEb-3)in -BaiForkCreekha\r~,' ~,:-~, ','. -' > :":' heen sampled annually. since September 200-0 to evaluatethe'pot~ntial'p~eserice'ofc6nhlinimiti<?n'_

:::t"!/.',: 1"'(,:', ::: ::j',' ,wlt~in streambed sediment; tpe~e 19c;ationscoin~idewith the thr.ee surface water s~pliIig! ;.,_,(." ",;:',:' ,~;,"'" locatipns SW-l,SW-2;and SW-3. The fIrst sediment samplinglocation-is a background:',' . ,

'. '~ . ; ~ :' -,,::;i'( ..I!-", "'1:,', lo~ation asitis l~catedin Bat Fork~reek upstre~ ofbothth~_C?E f~cilitY,a~d theS~epherd ,,' .\ .,j

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East Flat Rock, NC

Fann Subsite. SW-2 is located between these locations and SW-3 lies immediately downstream of the GE Subsite. Figure 7 is a location map for the sediment sample locations.

Sediment samples are analyzed for eleven contaminants and PCBs. Only PCBs have relevant North Carolina sediment screening criteria (e.g., 1,000 mg/kg total PCBs). The September 2008 sediment sample results are summarized as follows:

• VOCs were not detected above reporting limits in any of the sediment samples. • Total PCBs were detected at 53 ppb at both SED-2 and SED-3; however, these

concentrations are well below the NC Sediment Standard of 1,000 ppb or total PCBs.

• Lead and manganese were detected in all three sample locations, although no state standards currently exist for these constituents.

• Nickel was not detected in any of the three sediment samples.

Table 13 is a summary of sediment results since the GRS start-up. During the 8 years sampling history presented in Table 11, VOCs have only been detected twice. Tetrachloroethene was detected at 7.7 ug/kg in September 2003 and 11.8 ug/kg in September 2004 at sample location SED-2. Tetrachloroethene was not detected in sediment samples collected in 20052008. Additionally PCBs have been detected historically at SED-2 location and occasionally at the SED-3 location, the downstream-most location, none of the PCB detections have exceeded the NC Sediment Standard.

6.6 Site Inspection

The site inspection of the GE/Shepherd Farm site was conducted on May 14,2009. Attending the site visit were:

• Michael Townsend, RPM, US EPA • David Mattison, Environmental Engineer, NC DENR, Superfund Section • John Franklin, GE Lighting Systems • Tracy Martinez, GE Lighting Systems • Barry Hallock, GE Consumer and Industrial • Tod Hagemeyer, Geosyntec Consultants • Todd Kafka, Geosyntec Consultants

The Site Inspection team met on site to inspect the fonner landfills at the GE Subsite, the areas excavated at the Shepherd Fann Subsite, the capped fonner landfill, the groundwater remediation system, the areas surrounding the system for security and safety, and interview the subcontractor operating the system. All participants agreed that the remedies at the Site are functioning as designed and continued optimization of the system is important to the continued perfonnance of the remedy. This rationale was agreed upon due to the fact that system perfonnance increased significantly based on improvements to the GRS within the last year. It was also noted during the site inspection that O&M costs increased during this time; however, the benefits of the increased extraction rate due to the improvements were positive.

28


East Flat Rock, NC

, ,During the inspection, all groundwater treatment system monitoring records were noted as readily available and up-to-date. The treatment system was noted as being in good condition, all chemicals and equipment properly stored, and the system is operating and functioning properly. The Site is fenced and secured with locks. The monitoring wells were properly secured, locked, functioning and in good condition, and all wells were easily located.

The landfill cap was also inspected and in good condition with no erosion, signs of stress ' and no bulges observed. Cover penetrations, passive gas vents were properly secured and locked.

6.7 Interviews

The US EPA conducted all the community interviews, by telephone, as part o( the Five Year Review for the General Electric/Shepherd Farm site located in East Flat Rock, North Carolina. All individuals that were interviewed were notified that the Five Year Review was being conducted at the Site and that a final report will be placed in the information repository . located at the Henderson County Public Library, 310 N. Washington Street in Hendersonville, ' North Carolina, for the public to review.

Interviews were conducted with citizens that live in the area or own property in the area and were impacted by the cleanup at the Site. Most of the citizens interviewed were pleased with the cleanup and think that since the area has been remediatedthat people are pleased. Most stated that people do not even talk about it anymore. However, one citizen that was interviewed is still very unhappy. This citizen does not live there anymore, but still owns the property. See

,. 'Attachment 3 for the complete interview. ' " "

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East Flat Rock, NC

7.0 Technical Assessment 7.1 Question A: Is the remedy functioning as intended by the decision

documents?

Groundwater

Yes, the remedial action continues to be operating as designed. However, institutional controls as part of the remedy have not been implemented to date. .

Based on the current annual progress report, several modifications and improvements by Geosyntec to the GRS has increased performance and significantly improved the uptime and productivity of the system within the past year. This is evident by its 53% increase in total flow compared to the last year. The monitoring data indicates that the contaminated groundwater plume is being contained and that the levels are decreasing.

In the Annual Groundwater Remedial Action Performance Monitoring Report, several recommendations were made by Geosyntec regarding monitoring performance modifications. The recommendations were made in advance of this upcoming Five-Year Review and are provided in this report for consideration; however, have not been reported as major recommendations and issues for the Site for this Five-Year Review (i.e. Sections 8.0 Issues and 9.0 Recommendations and Follow-up Actions). These "Recommended Performance Monitoring Modifications" will need to be address by the US EPA and the NC DENR, not by this Five-Year Review Report. The recommendations are as follows:

• Modification to the RTC list and performance well network. A preliminary examination of the historical RG exceedances at each performance monitoring well for each of the RTCs has been performed. It has been suggested by GE and Geosyntec tpat several RTCs could be removed from the subsequent performance monitoring events. Five organics (l,2-DCA, benzene, chloroform, cDCE, and tDCE) meet the Remedial Goals Verification Plan (RGVP) criteria for requesting removal from the list. . Three metals (lead, nickel, and manganese) will be further evaluated to support the removal of these metals from the RTC list.

• Modifications to residential water well network and analytical suite. Geosyntec has reported that VOCs have not been detected in any of the residential water wells since the inception pfthe GRS in 2000. Historic. detections have been limited to manganese having the greatest frequency of RG exceedances.

. Geosyntec considers it prudent to pursue an examination of the historical total metals results at the residential wells in conjunction with the. total metals results in the performance monitoring wells in relation to groundwater flow direction to determine if the residential well network need to be modified.

• Modification of the GRS effluent analysis. The GRS effluent is piped to the GE facility and is mixed with other effluent from the plant. A portion of the GRS effluent can be reused in the plant as process water, sent through a metals pretreatment process, and discharged to the POTW. GE performs water quality monitoring of the plant effluent per the POTW permit. Since the GRS does not

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Second Five-Year Review GElShepherd Farm Site

East Flat Rock, NC

actually perform any metals treatment, and GE monitors the plant effluent per the permit requirements of the POTW, Geosytec stated that the GRS effluent sampling is redundant to the plant effluent sampling. Therefore, they recommended that the dissolved metals analyses from the quarterly influent/effluent samples be eliminated. GE would continue to conduct sampling of the plant effluent per the permit with the POTW.

• Evaluation of the GAC in treatment train. The eflluent from the air stripper has had VOC concentrations at least three orders of magnitude below the NC Air Standards per 15A NCAC 2Q.0711. GE will examine its air pemlitting ,

" obligations in greater detail to determine the feasibility of removing the GAC tank from the treatment train, subject to the US EPA and NC DENR approval. '

• Modification of the bunch arrowhead monitoring program. It was recommended to make modifications to the wetland monitoring. When the wetland monitoring methods were first developed as part the performance monitoring program, it was understood that the bunched arrowhead was present in the Bunched Arrowhead, wetland and not in the Large GE Wetland. However, since the inception of the monitoring, several bunched arrowhead populations have been discovered in the Large'GE Wetland and the Bunched Arrowhead Wetland. It is recommended by GE and Geosytec that the methods used to monitor the Bunched Arrowhead Wetland ~e u~ed to monitor the Large GE Wetland, with some slight modifications to account for Site conditions observed since the inception of the." monitoring program. In addition, it is being recommended that the monitoring ofthe Bunched Arrowhead. Wetland. be discontinued.. '

The remedial action objectives (RAOs) for soils were developed to prevent direct contact exposure to soils containing levels of contaminants that produce unacceptable risk levels. All . remediation goals were achieved during the remedial action for soil. However, no mstitutional controls or appropriate land use restrictions have been implemented.

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East Flat Rock, NC

As stated above, Institutional controls for the Site have not been implemented, below is an Institutional Controls Evaluation Table.

Meaia . . ~.j":,"; ",

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Ground Water

Soils

Ground water

Its :Neede~"

Yes

Yes

Yes

ICs Called . for in the 1(: ,lnstrum~ilt in (i'O" ,:.,. ..

Objective'

"';Decision -Place- i>o~~'m~nts' '.,

GE Subsite

Restrict

No installation of

Noneground water

wells.

Restrict land and soil use to

Yes protect the

Nonelong term

in~egrity of the cap.

Shepherd Fann Subsite

Restrict

No installation of

Noneground water

wells

Notes

None

None

None

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Soil Yes No Restrict land and soil use None None

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East Flat Rock, NC . . .....

7.2 Question B: Are the exposure assumptio';'s; toxicity data, clean-up levels and , remedial action objectives (RAOs) used at the time ofthe remedy still valid?'

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. Y~s, the exposure assumptions; toxicity data, cle~-up k~vels, and RAOs used at 'the time ...t;.:

..... ;:. of the remedy are still valid for theCOCs. Some of the chemical-specific ARARs (i.e., CRQLs,·· . ,, . ,

'. MCLs, and the State Groundwater Standards) have changed for the COCs from the Remediation : ! Goals given inthe ROD. However, the changes in general, are less stringent than the

remediation goals established in the Rob. The GRS is operating as intended and,no new.huinan· health or ecological routes of exposure have been identified or modified inanyJway that would .change the protectiveness of the remedy.

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)". . .:. A vapor intrusion assessments has been pe~formed by the US EPA and based on the risk "

:' . .range for residential properties, the Site is well within the' acceptable fisk levels. See Attachment·

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:.:~:;;~;>:: ':~.. "' ..' A cUrrent drinking water surVey is beingrequest~dwhichwould confirm that no ~~~.: ., . , .:'~.~ . ,:': ·· .. groundwater users hav~ installed drinking water wells. However, it is kno"Yn that there are no .

.·/)iH:',:'!,r,:./:.:,;· •. :,:: ..r~sidents betWeenthe GE property and Bat Fork Creek, a.gainin·g stream. Bat For~ Creek would ':.... .',' '.: .:interc.ept any contaminated groundwater that should intersect the creek. Data lias 'also confirmed"

thatno VOCs have' been found in existing groundwater wells that exceeded the. remediation '. goals for residents downgradient of the GE property on the opposite side. of Bat Fork Creek. At the Shepherd Farm Subsite, the Spring Haven Community is supplied municipal water and the

,':, few residents not within the subdivision are. also supplied municipal water. . .

There have been no changes in the physical conditions of the Site that would negatively . affect th~ protectiveness of the remedy. .. .

7.3 Question C: Has any o~her information come to light that could call into question the protectiveness ofthe remedy? ' :'

:., No additional information has come to light thatcould call into question the

protectiveness of the remedy.

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" . .... According"to document's, the site inspection, and hIterview's with the uS EPA; the' . . , "exposure pathway to contaminated soil and groundwater 'has been ·mitigated. Theexposme' '. .,':.,<

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, ::, ;,<.,., assumptions, toxicity data, clean-up levels and RAOs usedat the time of the remedy are still' " . ~,'

, ." ..... '.:~' .... ~ valid for the COCs.. There are no, known current exposure routes to the groundwater or soil ~d 'the remedy remains effective." A recent vapor intrusion assessment has been performed and the :"-,: :'

:~": ...:' Si~e is '~iihlri the acceptable risk range for residential properties. However, acurrent well survey'· ....,. . is neede~. Perrrianent land use restrictions or other appropriate institutional controls also need to .' '~~., .'

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8.0 Issues

There are two main issues that have been identified during this review. Each is discussed further in the recommendation section of this report.

1. No institutional controls have been implemented at either of the Subsites. 2. No current drinking water well survey downgradient of the plume at the GE and

Shepherd Farm Subsites has been conducted recently.

9.0 Recommendations and Follow-up Actions

The Recommendations and Follow-up Actions for the GE/Shepherd Farm Site are as follows:

Issues .Recommendations/

Follow-up Actions Party

Responsible Oversight Agency

Milestone Date

Affects Protectiveness?

(Y/N)

Current Future

Implement institutional controls at both Subsites.

Implement Institutional controls

and review implementation in

next five-year review

GE with agreerrient & cooperation

of land owners

EPA & State

August 31, 2012

N Y

No current drinking water well survey has been completed.

A current well survey should be

completed to document that no

GE EPA & State

August 31, 2012

N Y

new drinking water wells exists.

10.0 Protectiveness Statement

The remedies at both Subsites are protective of human health and the environment in the short term because no human exposure pathways exist to contaminated soil or groundwater. The . main source of contamination has been remediated through source removal, and the groundwater is being address by the GW treatment system. Th~re are no known residents between the GE property and Bat Fork Creek (document plume area), and data has confirmed that no VOCs have been found in existing groundwater wells that exceeded the remediation goals for residents downgradient of Bat Fork Creek. The Spring Haven community and the few surrounding residents are supplied drink~ng water by a municipal well.

To ensure long-term protectiveness, the following actions should be implemented. Impose institutional controls at both Subsites to preserve the integrity of the cap, prevent exposure to contaminated soil or debris, and restrict the use of on-site groundwater. Conduct a

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Second Five-Year Review· GElShepherd Farm Site

East Flat Rock, NC .

. drinking well survey downgradient of the plume to assure no new drinking water wells have . ..

been installed.

11.0 Next Review

The next Five-Year Review for the GE/Shepherd Farm site is required to be completed within five year·s from the EPA Region 4 Superfund Division Director's (or his designee)

.signature/approval date of this document.

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NORTH CAROLINA DEPARTMENT OF ENVIRONMENT … · ~~~~~ NORTH CAROLINA DEPARTMENT OF ENVIRONMENT ....

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