N. C. Department of Environment and Natural Resources

Summary of Federal Response and State Response at CTS Site

Buncombe County

DENR Division of Waste Management (DWM)

• DWM consists of four sections and one program:

– Hazardous Waste Section– Solid Waste Section– Underground Storage Tank Section– Superfund Section– Brownfields Program

2

Superfund Section

• Site Evaluation and Removal Branch (SERB)

• Federal Remediation Branch

• Inactive Hazardous Sites Branch (IHSB)

• Special Remediation Branch3

Federal EPA Criteria• National Priority List (NPL) Site

– Must score above 28.5 using Federal Hazard Ranking System (HRS)

– 37 NPL Sites being cleaned up in North Carolina

• Removal Action

– Remove imminent threat to human health and the environment at sites that require emergency action or that have contaminant releases that exceed Removal Action Levels

– Average of 8 EPA Removal Actions per year in North Carolina

4

Inactive Hazardous Sites Branch (State DWM)

• The state Inactive Hazardous Sites Branch (IHSB) addresses sites that do not meet Federal Criteria for NPL Listing or EPA Removal Action

• 1,916 open sites in DWM IHSB Inventory– (not including preregulatory landfills)

• 319 Ongoing Assessments/Cleanups including Priority Sites and Registered Environmental Consultant Program sites

5

CTS Site Overview• Operated from 1953 to

1985. Electroplating of electrical components

• Originally a 66 acre property, 37 acres redeveloped to residential (Southside Village, built with municipal drinking water lines)

• Trichloroethylene (TCE) in groundwater has impacted seven residential water supplies

6

The CTS Site has been addressed primarily by the Federal EPA, with

concurrent work by DWM since 2007• Federal EPA has been involved in identifying threat to off site

drinking water sources and providing alternative water to impacted residents. This work also supports NPL listing requirements

• EPA has also operated a soil vapor extraction system to reduce levels of contaminants in an adjacent spring

• State DWM IHSB has been reviewing work by CTS on defining nature and extent of contaminants in groundwater at the site, primarily Trichloroethylene (TCE)

7

CTS Site History • 1952-1959 International Resistance Company (IRC)

• 1959-1985 CTS operations on site

– Both IRC and CTS used chlorinated solvents in their plating operation

• Oct. 30, 1985 – EPA Preliminary Assessment conducted. Report finds no threat to human health or the environment, but recommends follow-up site survey

• Aug. 31, 1987 – Site Assessment by Law Environmental requested by CTS (pending sale)

8

• Dec 23, 1987 - CTS sells a 54 acre parcel to Mills Gap Road Associates (MGRA)

• 1988 – DWM IHSB hires first staff; 1 to 3 project managers for first 10 years of the program

• June 18, 1990 - DWM SERB receives resident’s concerns of contamination at CTS and potential drinking water well impacts

• June 18, 1990 – DWM SERB sends letter documenting those concerns to EPA Contractor (NUS) and to EPA

CTS Site History

9

CTS Site History

• Feb. 22, 1991 – EPA contractor NUS completes Site Screening Investigation (SSI) Report. Nearest well identified as 4,000 feet away

• March 6, 1991 - EPA forwards SSI Report to DWM with cover letter stating that no further remedial action under Superfund is planned for the CTS site

• Nov. 30, 1993 – DWM IHSB ranks site based on existing data

10

CTS Site History • Aug. 19, 1997 – Mill Gap Roads Associates (MGRA) subdivides the 54

acre former CTS property. There is no requirement to notify the State of subdivision

• Aug. 22, 1997 - MGRA sells 45 acres to The Biltmore Group, retaining 9-acre fenced plant site. Southside Village was ultimately developed on the 45 acres.

• Dec. 15, 1997 – DWM IHSB issues Order to Record a Notice of Hazardous Substance or Waste Disposal Site

• Sept. 9, 1998 – MGRA records a Notice of Hazardous Substance or Waste Disposal Site on deed for the 9-acre fenced plant site retained after the subdivision and sale

11

• Jul. 12, 1999 – In response to resident’s request, State Division of Water Quality (DWQ) sampled springs on property adjoining CTS plant. First evidence of drinking water contamination

• Jul. 28, 1999 – Nine nearby potable wells sampled by DWQ. One well found contaminated.

• Aug. 16, 1999 – DWQ contacts DWM SERB about contaminated springs and well. DWM SERB contacts EPA on same day for assistance with alternative water

• Aug. 23, 1999 – Bottled water supplied by EPA

CTS Site History

12

• April 2000 – EPA completed municipal water connections to impacted residents.

• Repeated sampling of nearby drinking water sources (1999, 2000, 2003, 2006)

– No additional contaminated wells identified

• 2000 and 2010 – EPA surveyed CTS site for buried drums

EPA Removal Actions

13

• 2006-2011 – Under EPA oversight, CTS operated a Soil Vapor Extraction system to remove TCE from soils beneath the plant

• Dec. 2007 – Mar. 2009: EPA Vapor Intrusion Study at nearby homes show results below EPA Removal Action Levels

• 2009-2011 - CTS ozone injection trial attempted to reduce vapor emissions from springs

EPA Removal Actions

14

EPA Remedial (NPL) Program• Five attempts to list the CTS site on the NPL:

(1985, 1991, 2001, 2006, and 2007-11)

• One-mile radius drinking water sampling (quarterly, events since 2007) has two purposes:

- Protect residents: 5 additional contaminated wells identified during this effort

- Support HRS Score that allows March 2011 Proposal to NPL

15

EPA 1-Mile Radius Quarterly Drinking Water Sampling

16

• DWM takes steps to solicit CTS assessment and cleanup of the site

• DWM IHSB oversees CTS groundwater assessment through two phases of soil and bedrock drilling at the plant

• NC Division of Land Resources Geological Survey conducts fracture study to support EPA’s NPL listing effort

• NC Division of Public Health (DPH) conducts a Public Health Assessment in response to public request

NC Actions 2007 - 2011

17

• Earliest possible cleanup, either under state authority, or under EPA authority if NPL listing successful

• Augment EPA Removal and Remedial resources

• Unified community involvement program with EPA, Buncombe County Public Health, DWM and DPH

• Dovetail DWM IHSB site groundwater assessment with EPA activities

• Improve information on attribution and drinking water risk

NC Goals 2007 - 2011

18

Mills Gap Road

DWM IHSB – Phase IA Drilling19

pandemoniumDWM IHSB – Phase IB Drilling20

Fracture Set 260-280/80

Fracture Set 260-280/80 NC DLR Geological Survey

Rock Outcrop Fracture Study

21

US Geological Survey Borehole Fracture Study

22

EPA Pump Tests

23

NC DHHS Public Health Assessment

The N.C. Division of Public Health (NC DPH) was asked to conduct a comprehensive evaluation of the potential public health hazards related to contact with the contamination identified at the CTS site.

• Concentrations of trichloroethylene (TCE) observed in private wells in 1999 may have been high enough to cause adverse health effects.

• Private well data collected from 1999 through January 2008 does not indicate the potential for adverse health effects…

• The chemical concentrations found in the outdoor air, soil, and crawl space air were too low to cause harm.

• The evaluation of cancer rates in a 1-mile radius from the site showed that the rates are not higher than what would normally be expected.

24

• October 2008 - Waterline extension to The Oaks Subdivision

• 2011 - Demolition of CTS plant building

• Active support of EPA, DWM, and DPH efforts

Buncombe County Actions 2007 - 2011

25

• 28 Public meetings since October 2007

• NPL process includes statutory community involvement steps

• Beginning March 2010 - Community Advisory Group comprised of local citizens now reviews and comments on EPA/CTS investigation work plans

• As a result of 2010 EPA Inspector General office investigation into CTS site, EPA instituted a nationwide Standard Operating Procedure for better risk communication with communities at Superfund sites

EPA Community Involvement

26

• Site proposed to NPL March 2011; Final Rule anticipated as early as March 2012

• EPA negotiating with CTS on Administrative Agreement for NPL Remedial Investigation and Cleanup

• EPA will continue quarterly monitoring of drinking water in 1-Mile Radius

EPA Actions Going Forward

27

• Support listing of the site on the NPL and cleanup of site using CTS funds

• Transition from DWM IHSB assessment to EPA NPL Remedial Investigation/Feasibility Study

• DWM Superfund Section engineers fill Support Agency oversight role under Cooperative Agreement with EPA at all NPL sites

• Additional DPH Public Health Assessment required after NPL listing

State Role Going Forward

28