HRS DOCUMENTATION RECORD COVER SHEET

Name of Facility: CTS of Asheville, Inc

. E PA ID No. NCD003149556

Contact Persons

U.S. Environmental Protection Agency (EPA), Region 4:

Carolyn Callihan, Remedial Project Manager (404) 562

- 8913

Jennife r Wendel, NPL Coordinator (404) 562

- 8799

Investigation: Preliminary Assessment, 1985 Screening Site Inspection, Phase I, 1989 Screening Site Inspection, Phase II, 1990 Site Investigation, 2010

Documentation Record: Allyson Warrington

, Project Manager Oneida Total Integrated Enterprises ( 678) 355

- 5550

Pathways, Components, or Threats Not Scored

CTS of Asheville, Inc. ( CTS ) is being scored on the ground water migration pathway. The evaluation of the ground

water migration pathway yie lds a score above the National Priorit ies List ( NPL ) cutoff value of 28.50. C ontamination is

documented in private drinking water wells. The surface water migration

, air migration , and soil exposure pathway s do

not contribute significantly to the overall HRS score for the CTS site

.1 HRS DOCUMENTATION RECORD

Name of Facility: CTS of Asheville, Inc

.

E PA Region: 4 Date Prepared: March 201 1

Street Address of Facility*: 235 Mills Gap Road

City, County, State , Zip : Asheville, Buncombe County, No rth Carolina, 28803

General Location in the State: West

Topographic Map: Skyland , North Carolina

Latitude: 35 **°** 29 ' 35.07 " North Longitude: 82 **°** 30 ' 21.43 " West (Ref s . 42 p. 6; Figure 4 )

The Global Positioning System (GPS) coordinates were collected from t he easternmost building on th e CTS property, specifically the north eastern corner of the building.

*The street address, coordinates, and contaminant locations presented in this Hazard Ranking System (HRS) documentation record identify the general area i n which the property is located. They represent one or more locations that the U.S. Environmental Protection Agency (EPA) considers to be part of the property based on the screening

information EPA used to evaluate the property for National Priorit ies Lis t (NPL) listing. EPA lists national priorities among the known "releases or threatened releases" of hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous substance has been "d eposited, stored, placed, or otherwise come to be located." Generally, HRS scoring and the subsequent listing of a release merely represent the initial determination that a certain area may need to be addressed under Comprehensive Environmental Response, Compensation, and Recovery Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more information is developed as to where the contamination

has come to be located.

Scores

Air Pathway Not Scored

Ground W ater Pathway 97.28 Soil Exposure Pathway Not Scored Surface Water Pathway Not Scored

HRS SCORE 48.642 WORKSHEET FOR COMPUTING HRS SCORE

S S 2

1. G round W ater Migration Pathway Score (S gw ) (from Table 3

- 1, line 13) 97. 28 9463

. 3984

2a. Surface Water Overland/Flood Migration Component (from Table 4

- 1, line 30) NS NS

2b. Ground W ater to Surface Water Migration Component (from Tabl e 4

- 25, line 28) NS NS

2c. Surface Water Migration Pathway Score (S

sw ) Enter the larger of lines 2a and 2b as the pathway score. NS NS

3. Soil Exposure Pathway Score (S

s ) (from Table 5

- 1, line 22) NS NS

4. Air Migration Pathwa y Score (S

a ) (from Table 6

- 1, line 12) NS NS

5. Total of S gw 2 + S

sw 2 + S

s 2 + S

a 2 94 63.3984

6. HRS Score Divide the value on line 5 by 4 and take the square root 48. 64

NS

- Not Scored Reference 1, Table 3

- 13 G ROUND WATER MIGRATION PATHWAY SCORESHEET

Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release to an Aquifer:

1. Observed Release 550 550

2. Potential to Release:

2a. Containment 10

2b. Net P recipitation 10

2c. Depth to Aquifer 5

2d. Travel Time 35

2e. Potential to Release [lines 2a x (2b + 2c + 2d)] 500

3. Likelihood of Release (higher of lines 1 and 2e) 550 550

Waste Characteristics:

4. Toxi city/Mobility a 10,000

5. Hazardous Waste Quantity a 10 0

6. Waste Characteristics 100 32

Targets :

7. Nearest Well 50 5 0

8. Population:

8a. Level I Concentrations b 2 6 0

8b. Level II Concentrations b 0

8c. Potential Contami nation b 14 6

8d. Population (lines 8a + 8b + 8c) b 40 6

9. Resources 5 0

10. Wellhead Protection Area 20 0

11. Targets (lines 7 + 8d + 9 + 10) b 45 6

GROUND WATER MIGRATION SCORE FOR AN AQUIFER

12. Aquifer Score [(lines 3 x 6 x 11)/82, 500] c 100 97. 28

GROUND WATER MIGRATION PATHWAY SCORE

13. Pathway Score (S gw ), (highest value from line 12 for all aquifers evaluated) c 100 97. 28

a Maximum value applies to waste characteristics category.

b Maximum value not applicable.

c D o not roun d to nearest integer.!(CTS of Asheville, Inc.82°28'0"W82°28'0"W82°28'30"W82°28'30"W82°29'0"W82°29'0"W82°29'30"W82°29'30"W82°30'0"W82°30'0"W82°30'30"W82°30'30"W82°31'0"W82°31'0"W82°31'30"W82°31'30"W82°32'0"W82°32'0"W82°32'30"W82°32'30"W82°27'30"W

35°31'0"N 35°31'0"N

35°30'30"N 35°30'30"N

35°30'0"N 35°30'0"N

35°29'30"N 35°29'30"N

35°29'0"N 35°29'0"N

35°28'30"N 35°28'30"N

35°28'0"N 35°28'0"NCTS OF ASHEVILLE, INC.ASHEVILLE,BUNCOMBE COUNTY,NORTH CAROLINAEPA ID No.: NCD003149556FIGURE 1GENERAL LOCATION MAPAsheville,Buncombe County,North Carolina E:\GIS Workspace\Mills Gap_1165 AKA CTS of Asheville, Inc Map Author: Doug Fraley Rev:0$00.5MilesUnited States Environmental Protection AgencyBASEMAP REFERENCE:ASHEVILLE, NORTH CAROLINA,USGS QUADRANGELE 35082-E5, PUBLISHED 1979OTEEN, NORTH CAROLINA ,USGS QUADRANGELE 35082-E4, PUBLISHED 1979SKYLAND, NORTH CAROLINA,USGS QUADRANGELE 35082-D5, PUBLISHED 1979FRUITLAND, NORTH CAROLINA,USGS QUADRANGELE 35082-D4, PUBLISHED 19791Plating AreaWarehouseOfficesHazardousStorage AreaWaste PitMain PlantDryRoomPaint Curing AreaCTS OF ASHEVILLE, INC.ASHEVILLE,BUNCOMBE COUNTY,NORTH CAROLINAEPA ID No.: NCD003149556FIGURE 2PROPERTY LAYOUT MAPAsheville,Buncombe County,North Carolina E:\GIS Workspace\Mills Gap_1165 AKA CTS of Asheville, Inc Map Author: Doug Fraley Rev:0$075FeetUnited States Environmental Protection AgencyLegendCTS of Asheville, Inc. FacilityNotes:Aerial by: Digital Globe, Inc. http://www.digitalglobe.com/Facility Features obtained from 1987 Law Enviromental, Inc.Sample Location Plan Report.150&3&3&3&3&3&3&3&3&3&3&3&3&3&3&3&3&3&3@A@A@A@A@A@A@A!<!<!<&3!<!<!<BH-30ABH-30BBH-30CCTS-001-MWMGGC-GW-01MGGC-GW-03MGGC-GW-17TW-1MW-4MW-5MW-7MW-7AMW-11BMW-11AMW-11BH-13BBH-14BBH-15BBH-16BBH-17BBH-18BBH-19ABH-19BBH-19CBH-20ABH-20BBH-20CBH-21BBH-21CBH-22ABH-22BBH-22CBH-23ABH-23BBH-25BBH-25CBH-26ABH-26BBH-28BBH-29BBH-29CBH-32ABH-34BCTS OF ASHEVILLE, INC.ASHEVILLE,BUNCOMBE COUNTY,NORTH CAROLINAEPA ID No.: NCD003149556FIGURE 3SAMPLE LOCATION MAP E:\GIS Workspace\Mills Gap_1165 AKA CTS of Asheville, Inc Map Author: Doug Fraley Rev:0$0100FeetUnited States Environmental Protection AgencyNotes:CTS - CTS of Asheville, Inc.BH - Bore HoleGW - Ground WaterMGGC - Mills Gap Ground Water ContaminationMW - Monitoring WellSA - Site AssessmentSAP - Sampling and Analysis PlanTW - Temporary WellSource Area Totals: 43,859 SqFt or 1.006 AcresAerial Base Map By:Digital Globe http://www.digitalglobe.comAerial By: Digital GlobeLegendCTS of Asheville, Inc. facilitySource AreaTN &Associates, Inc. SubsurfaceSoil and Ground Water Sampling Report,Rev. 1, for EPA. April 23, 2008. (Ref. 42)!<&3MACTEC SAP Report for CTS Corporation.September 21, 2004. (Ref. 7)@AMACTEC Report of Phase I RemedialInvestigation, for CTS.July 27, 2009. (Ref. 8)200%,%,%,%,%,%,%,%,%,%,%,%,%,%,%,%,%,#*#*#*#*#*#*#*1/4 Mile Radius1/2 Mile Radius1 Mile RadiusMW-PW-04MG-SSI-29CTS-019-PWSW-DW-01MG-PT-01A/-01B/-01CMG-PW-03MG-SSI-34MG-PT-03A/-03B/-03CMG-PW-15MG-GMP4-099G1464PW9CTS-001-PWMG-SSI-119MG-PT-04A/-04B/-04CMG-PT-05AMG-PT-02A/-02B/-02C9G12979G1298Latitude: 35° 29' 35.07" North Longitude: 82° 30' 21.43" West9G1465PW29G1466PW1MG-GMP4-23CTS-016-PWCTS-018-PWCTS-030-PWCTS-031-PWCTS-075-PWMG-SSI-02MG-PW-01MG-SSI-02MG-PW-05MG-PW-06MG-SSI-01MG-GMP4-61MG-SSI-04CTS OF ASHEVILLE, INC.ASHEVILLE,BUNCOMBE COUNTY,NORTH CAROLINAEPA ID No.: NCD003149556FIGURE 4GROUND WATERSAMPLE LOCATION MAPAsheville,Buncombe County &Henderson CountyNorth Carolina E:\GIS Workspace\Mills Gap_1165 AKA CTS of Asheville, Inc Map Author: Doug Fraley Rev:0$00.25MilesUnited States Environmental Protection Agency.Notes:TCE - TrichloroethyleneParcel data provided by: Buncombe Countyhttp://www.buncombecounty.org/governing/depts/gis/LegendParcelSource AreaRadius MarkerLevel I Sample Locations#*Global Positioning System LocationNon-DetectTCE Sample Locations%,0.58 REFERENCES

Ref.
No. Description of the Reference

1. U.S . Environmental Protection Agency (EPA). Hazard Ranking System, 40 CFR Part 300, Appendix A, 55 FR 51533. December 14, 1990. Excerpt. 34 pages. [A complete copy can be obtained from the Regional Docket upon request.]

2. EPA. Superfund Chemical Data Matrix (SCDM). January 2004 with October 2006 update. Excerpt. 53 pages. [A complete copy is available at http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm ]

3. Oneida Total Integrated Enterprises (OTIE). Topographic Map of CTS of Asheville, Inc. EPA ID No. NCD003149556. October 1, 2010. 1 map.

4. R. Steve Pierce, START Leader Tetra Tech EM, Inc. Letter with Attachments to Barbara Caprita, On

- Scene Coordinator, EPA. Subject: Trip Report

, Mills Gap Site , Skyland, Buncombe County, North Carolina, TDD

No.: 04

- 9909

- 0006

. February 17, 2000. 283 pages.

5. County of Buncombe, North C arolina. Web Property Record Card. Search for Parcel Pin: 9655

- 62

- 5706

- 00000. Accessed online at http://www.buncombetax.org/PropertyCard.asp . August 5, 2010. 3 pages.

6. Amanda M io len, OTIE . Pr oject Note to File . Subject: Property deed from CTS Corporation to Mills Gap Road

Associates

. August 5, 2010. 57 pages.

7. MACTEC Engineering and Consulting, Inc . (MACTEC) . Sampling and Analysis Plan (SAP) Report. Implementation of the Sampling and Analy sis Plan. Mills Gap Road Ground water Contamination Site. One Mile East of Skyland, Buncombe County, North Carolina. EPA ID No. NCD003149556. Prepared for CTS Corporation. September 17, 2004. 667 pages.

8. MACTEC. Report of Phase I Remed ial Investigati on. Mills Gap Road Site. Skyland, North Carolina. NCD No. 003149556. Prepared for CTS Corporation. July 27, 2009. 516 pages.

9. Law Environmental, Inc. Report of Site Assessment Service s . CTS Corporation, Asheville, North Carolina. August 31, 1987. 118 pages.

10. Department of Health and Human Services, Agency for Toxic Substances & Disease Registry (ATSDR)

. ToxFAQsTM for Trichloroethylene (TCE) , July 2003 . Accessed online at: http://www.atsdr.cdc.gov/tfacts19.html

. July 15, 2010. 5 pages.

11. EP A, Superfund Technology Support Center for Ground Water. Groun d Water Issue: TCE Removal f rom Contaminated Soil and Ground Water

. January 1992. 10 pages.

12. EPA Notification of Hazardous Waste Activity . CTS of Asheville, Inc. EPA ID No. NCD003149556. August 18, 1980. 8 pages.

13. Steve Cash, Project Manager, NUS Co rporation. Letter with Attachments to A.R. Hanke, Site Investigation and Support Branch, Waste Management Division, EPA. Subject: Screening Site Inspection, Phase I. CTS of Asheville, Inc.

, Skyland, Buncombe County, North Carolina. EPA ID No. NCD 003149 556. August 30, 1989. 5 pages.

14. Electronic Code of Federal Regulations (e

- CFR) . Title 40: Protection of the Environment. Part 261, Subpart

261.31 Hazardous Wastes from Non

- specific Sources. Accessed online at: http://ecfr.gpoaccess.gov/cgi/t/text/text

- idx?c=ecfr;sid=d72ed4d11478017a0f982dafbad15

. March 25, 2010. 5

pages.9 15. Amanda Miolen , OTIE

. Project Note to File . Subject: N on

- compliance documentat ion for CTS of Asheville,

Inc. Au gust 17, 2010. 20 pages.

16. Amanda Miolen , OTIE

. Project Note to File . Subject: C lassification documentation for CTS of Asheville, Inc. August 17, 2010. 19 pages.

17. North Carolina Department of Environment and Natural Resources (NCDENR) , Solid and Hazardous Waste Management Branch. Resource Conservation and Recovery Act ( RCRA ) Inspection Report , CTS of Asheville,

Inc. Date unknown. 3 pages.

18. O.W. Strickland, Head, Solid and Hazardous Waste Management Branch, Environ mental Health Section, State of North Carolina. Letter to Charles Beitner, CTS of Asheville, Inc. Subject: NCD003149556. August 18,

2010. 1 page.

19. Mark Durway, Geologist, Solid and Hazardous Waste Management Branch, Environmental Health Section,

North Carolina Department of Human Resources, Division of Health Services. Letter to Denise Bland, NC CERCLA Project Officer, Air and Hazardous Material Division, EPA. Subject: Final Preliminary Assessment Report , CTS of Asheville, Inc., NCD003149556

. October 30, 1985. 4 pages.

20. R. Pinsell. Record of Communication to Keith Masters. Subject: CTS of Asheville

– Complaint. EPA Form

1300

- 6. August 18, 2010. 2 pages.

21. Stephany Fine, Project Manager, N US Corporation. Letter with Attachments to A.R. Hanke, Wa ste Programs Branch, Waste Management Division, EPA. Subject: Screening Site Inspection, Phase II , Revision 0, CTS of Asheville, Inc. , EPA ID No. NCD003149556. February 22, 1991. 196 pages.

22. Kelly Cain, Environmental Engineer, EPA. Letter to Stan Green berg, Coldwell Bankers, Hill Gatewood Realtors. Subject: CTS of Asheville, Inc. June 8, 1990. 6 pages.

23. NUS Corporation. Study Plan, Screening Site Inspection, Phase II, CTS of Asheville, Inc., Revision 0. EPA ID No. 003149556. May 31, 1990. 14 pag es.

24. Andrew Glucksman, START

- 2 Project Manager, Weston Solutions, Inc. Letter with Attachments to Dr. James Webster, On

- Scene Coordinator, EPA. Subject: Removal Assessment Letter Report, Revision 0

, Mills Gap

Road Groundwater Contamination s ite. March 6, 2003. 193 pages.

25. Kay Dechant, NCDENR, Division of Water Quality

, Groundwater Section. Facsimile to Pat Deraea. Subject: Map of CTS of Asheville, Inc. property in relation to Rice property, including analytical data

. August 16, 1999. 18 pages.

26. Fre d Stroud, On

- Scene Coordinator, EPA. Superfund Site Spill ID Request. Mills Gap Road Groundwater Contamination, Spill ID A4P5. August 23, 1999. 46 pages.

27. QuQi, Hydrogeologist, Asheville Regional Office, NCDENR . Letter with Attachments to Mr. Larry Ric e , Jr

. Subject: Spring water test results , Rice Residence

– Adjacent to Former CTS Property, Asheville, North

Carolina

. July 22, 1999. 4 pages.

28. QuQi, Hydrogeologist, Division of Water Quality , Groundwater Section, Asheville Regional Office, NCDENR

. Fac simile to Charlotte Jesneck. Subject: Analytical results of the July 1999 water supply sampling event near the former CTS facility

. August 9, 1999. 21 pages.

29. CMC, Inc. Contractor’s Final Site Report. Mills Gap Road Groundwater Contamination. April 2 0, 2001. 20

pages.10 30. EPA

. Trip Report. Mills Gap (CTS) Site. April 24, 2002. 21 pages.

31. NCDENR. Analytical data, Chain of Custody forms and logbook notes from the May 2000 event conducted at CTS of Asheville, Inc., by NCDENR. May 23, 2000. 3 6 pages.

32. Ken Woodruff, Task Leader, Lockheed Martin

- REAC. Trip Report

, Mills Gap Road , WA# 0

- 141 . December 20, 2000. 80 pages.

33. Ken Woodruff, Task Leader, Lockheed Martin

- REAC. Geoprobe ® Coring Results

, Mills Gap Road , WA # 0

- 141, Trip Report. July 12, 2001. 100 pages.

34. MACTEC Engineering and Consulting, Inc. Sampling and Analysis Plan , Revision 1, Mills Gap Road

Groundwater Contamination Site. EPA ID No. NCD003149556. May 17, 2004. 90 pages.

35. MACTEC Engineering and Consulting, Inc. Sampling and Analysi s Plan , Revision 0, Mills Gap Groundwater

Contamination Site , EPA ID No. NCD003149556. March 19, 2004. 83 pages.

36. MACTEC Engineering and Consulting, Inc. Letter with Attachments to Dr. James Webster, On

- Scene Coordinator, EPA. Subject: Removal Action Pl an
, Mills Gap Groundwater Contamination Site. February 4,

2005. 47 pages.

37. MACTEC Engineering and Consulting, Inc. Removal Report

, Mills Gap Road Groundwater Contamination

Site. August 18, 2006. 61 pages.

38. Ryan Stubbs, Project Manager, TN & Associate s, Inc. (TN&A). Letter with Attachments to David Dorian, On

Scene Coordinator, EPA. Subject: Potable Well Water, Surface Water, and Surface Soil Sampling Report

, Mills Gap , EPA ID No

. A4P5. June 19, 2009. 53 pages.

39. Ryan Stubbs, Project Manager, TN&A. Letter with Attachments to David Dorian, On

- Scene Coordinator, EPA. Subject: Potable Well Sampling Draft Report

, Mills Gap , EPA ID No. A4P5 . February 14, 2008. 451 pages.

40. Ryan Stubbs, Project Manager, TN&A

. Letter with Attachments to David Dorian, On

- S cene Coordinator, EPA. Subject: Interim Potable Water Sampling Letter Report , Mills Gap Operable Unit #2

. December 20, 2007. 18

pages.

41. EPA. Drinking Water Contaminants: National Primary Drinking Water Regulations. Accessed Online at http://water.epa.gov/drink/contaminants/index.cfm

. September 28, 2010. 6 pages.

42. Ryan Stubbs, Project Manager, TN&A

. Letter with Attachments to David Dorian, On

- Scene Coordinator, EPA. Subject: Subsurfa ce Soil and Groundwater Sampling Report, Revision 1

, Mills Gap , EPA ID No. A4P5

. April 23, 2008. 4 40 pages.

43. Ryan Stubbs, Project Manager, TN&A

. Letter with Attachments to David Dorian, On

- Scene Coordinator, EPA. Subject: Potable Well Sampling Letter R eport

, Mills Gap. July 21, 2008. 44 pages.

44. Ryan Stubbs, Project Manager, TN&A

. Letter with Attachments to Jennifer Wendel, Remedial Project Manager, EPA. Subject: Special Studies Investigation Letter Report, Revision 0

, Mills Gap (Assessment).

Novemb er 20, 2008. 6 99 pages.

45. OTIE

. Quality Assurance Project Plan/Site Sampling Plan , Quarterly Groundwater Monitoring , Revision 2

, Mills Gap. February 19, 2010. 56 pages.11 46. Ryan Stubbs, Project Manager, OTIE

- TN&A

. Letter with Attachments to Carolyn Calli han, Remedial Project Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 0

, 1 st Quarter 2009

, Mills Gap Assessment. May 26, 2009. 570 pages.

47. Ryan Stubbs, Project Manager, OTIE

- TN&A

. Letter with Attachments to Caroly n Callihan, Remedial Project Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 1

, 2 nd Quarter 2009

, Mills Gap Assessment. July 8, 2009. 523 pages.

48. Ryan Stubbs, Project Manager, OTIE

. Letter with Attachments to Caro lyn Callihan, Remedial Project Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 0

, 3 rd Quarter 2009, Mills Gap Assessment. September 25, 2009. 550 p ages.

49. Ryan Stubbs, Project Manager, OTIE

. Letter with Attachments to Carolyn Callihan, Remedial Project Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 1

, 4 th Quarter 2009

, Mills Gap Assessment. February 1, 2010. 9 4 7 pages.

50. Ryan Stubbs, Project Manager, OTIE

. Letter with Attac hments to Carolyn Callihan, Remedial Project Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 0

, 5 th Quarter February 2010

, Mills Gap Assessment. July 21, 2010. 1

, 2 81 pages.

51. Ken Woodruff, Project Leader, Lockheed M artin

- REAC. Trip Report

– Packer Testing and Domestic Well Sampling , Mills Gap Road Groundwater Contamination Site, Asheville, North Carolina, Work Assignment # 0

- 296

. June 17, 2009. 50 pages.

52. Timothy Simpson, Environmental Scientist, Superfund a nd Air Section

, Science and Ecosystem Support

Division

, EPA

. Memorandum with Attachments to Jennifer Wendel Remedial Project Manager, Superfund Remedial & Site Evaluation Branch, Superfund Division, EPA. Subject: Mills Gap Groundwater

Contamination Site

, Final R eport. January 19, 2010. 111 pages.

53. Kay Wischkaemper, Hydrologist, P.G., Technical Services Section, Superfund Division, EPA. Memorandum with Attachments to Carolyn Callihan, Site Assessment Project Manager, Superfund Division, EPA. Subject:

Technical Memorandum on the Geology and Hydrogeology in the Mills Gap Road Area of Buncombe County,

North Carolina. January 24

, 201 1

. 2 5 pages.

54. John T. Hack

. Physiographic Divisions and Differential Uplift in the Piedmont and Blue Ridge

. Geological Survey Prof essional Paper 1265. 1982. 55 pages.

55. North Carolina Department of Water and Air Resources, Division of Geology. Geology and Groundwater Resources of the Asheville Area . Groundwater Bulletin No. 16. April 1970. 141 pages.

56. North Carolina Department of Environment and Natural Resources, Division of Land Resources

, Geological Survey Section. Bedrock Geologic Map of Buncombe County, North Carolina

. Scale 1:62,500. 2007. 1 map.

57. North Carolina Geological Survey. Technical Memorandum on the Geology o f the Mills Gap Area, Buncombe County, North Carolina. September 30, 2010. 21 pages.

58. Reference Removed.

59. USGS

. Influence of Geologic Setting on Ground

- Water Availability in the Lawrenceville Area, Gwinnett County, Georgia . Scientific Investigation Rep ort 2005

- 5136. 2005. 54 pages.

60. USGS

. Ground

- Water Regions of the United States

. Geological Survey Water

- Supply Paper 2242. 1984. 87

pages.12 61. John H. Montgomery & Linda M. Welkom. Groundwater Chemicals Desk Reference

. 1990. Excerpt. 8

pages.

62. Loc kheed Martin

- REAC. Quality Assurance Plan

, Mills Gap Road. March 11, 2010. 63 pages.

63. Amanda Miolen , OTIE

. Project Note to File . Subject: MACTEC Soil Vapor Extraction ( SVE ) Progress Repor ts. August 17, 2010. 196 pages.

64. Environmental Data Resources , Inc. (EDR). The EDR Radius AtlasTM with GeoCheck ® . Mills Gap: 274 Mills Gap R oad, Asheville, NC 28803. Inquiry Number: 2355026.2s. November 3, 2008. 724 pages.

65. James L. Cummins, Senior Vice President, Administration, CTS Corporation. Letter with En closures to Senator Richard Burr, Representative Joe Donnelly, Representative Heath Shuler, and Representative Mark Souder. Subject: The Mills Gap Road Environmental Site, Skyland, North Carolina. September 28, 2009. 310 pages.

66. Amanda Miolen , OTIE. P roject Note to File . Subject: Mills Gap 104e Master List. August 5, 2009. 135

pages.

67. Harry Zinn, Environmental Engineer, Superfund Section, NCDENR

. Letter with Attachments to Carolyn Callihan. Subject: Sampling and Analysis Plan/Quality Assurance Proje ct Plan for Expanded Pre

- CERCLIS Screening Assessment

, Conner Motors Site , EPA ID No. NCD986189058. July 13, 2010. 55 pages.

68. Harry Zinn, Environmental Engineer, Superfund Section, NCDENR

. Letter with Attachments to Carolyn Callihan. Subject: Sampling and Analysis Plan/Quality Assurance Project Plan for Expanded Pre

- CERCLIS Screening Assessment

, Sheet Metal Restoration Site. July 13, 2010. 17 pages.

69. Amanda Miolen , OTIE . Project Note to File . Subject: W estern North Carolina Regional Air Quality Agen cy (WNCRAQA) Application Review Summary for Pechiney Plastic Packaging Inc. (PPPI)

. August 11, 2010. 52

pages.

70. Gregory Kowalski, Program Manager, OTIE

. Letter with Attachments to Carolyn Callihan, Remedial Project Manager, EPA. Subject: Groundwater P opulation for Determination for 0

- 1 Mile , Mills Gap Assessment

. May 27, 2010. 42 pages.

71. Ryan Stubbs, OTIE

. Project Note to File . Subject: Determination of community wells within 4 miles of the

site. September 16, 2010. 11 pages.

72. Doug Fraley, GIS Sp ecialist, OTIE . Project Not e to F ile . Subject: P rivate well locations

– Identification and

A nalysis Methodology. September 30, 2010. 2 pages.

73. U

. S

. Census Bureau . State and County QuickFacts, Buncombe County , North Carolina. Accessed online at: http://quickfacts.census.gov/qfd/states/37/37021.html

. January 17, 2011

. 2 pages.

74. Amanda Mi o len, OTIE . Project Note to F ile . Subject: Access Authorization forms for residences participa ting in the CTS of Asheville, Inc. sampling events. September 28, 2010. 361 pages.

75. Becky Robinson . Declaration . Subject: Number of F ull

- time R esidents at Dwelling

. June 25, 2009. 2 pages.

76. MacRAE’s Blue Book. Search for Spotless Enterprises in Asheville. Accessed online at http://www.macraesbluebook.com/search/company.cfm?company=457613 . October 1, 2010. 2 pages.

77. Clarke, William, Roberts & Stevens, P.A. Letter with Attachments to Lisa Ellis, Esq., Office of Environmental Accountability, EPA. Subject: Request for Information Pursuant to Section 104(e) of CERCLA, Mills Gap Road Groundwater Contamination Superfund Site (the Mills Gap Site) EPA ID No. NCSFN046988, CTS of Asheville, Inc. Site (the CTS Site) EPA ID No. NCD003149556. September 1, 2010. 350 pages.13 78. M.J. Chapman, & B.A. Huffman , USGS. Geophysical L ogging D ata from the Mills Gap Road area near Asheville, North Carolina

. USGS Data Series 538 . 2010. 58 pages.

79. Dennis Coil, Director

- Environment, Health & Safety, Amcor Flexibles Americas & Medical Europe. Letter to Lisa Ellis, Attorney

- Advisor, EPA, Office of Environmental Accountability. Subject: CERCLA Section 104(e) Information Request, Pechine y Plastics Packaging, Inc., Asheville, N.C. November 22, 2010. 5, 454 pages.

80. Harry Zinn, Environmental Engineer, NC Superfund Section, NCDENR. Letter to Carolyn Callihan, Superfund Site Evaluation Section, EPA. Subject: Soil Vapor Sampling Trip Rep ort, Sheet Metal Restoration

, NCN000410573. December 6, 2010. 25 pages.

81. NCDENR, Public Water Supply Section. The Wellhead Protection Program (WHPP). Accessed online at: http://swap .deh.enr.state.nc.us.swap/pages/whp/htm . January 14, 2011. 1 Page.

82. Greg Kowalski, START. Telephone conversation with Mr. Chuck Gross. Discussion: Christ School Wells Pumpage Rates for Apportionment. D ecember 2, 2010. 1 page.

83. David Edgerton, Lockhee d Martin, SERAS Project Manager. Memorandum with Attachments to Greg Powell, EPA, ERT, ERTC, Work Assignment Manager. Subject: Technical Memorandum for Stream Sediment, Surface Water, and Ground Water Investigation at the Mills Gap Road Site, Asheville, North Carolina, Work Assignment SERAS 0

- 052. January 4 , 2010. 802 Pages.14 General Facility Description and History

CTS of Asheville, Inc.

, ( CTS ) is located at 235 Mills Gap Road in Asheville, Buncombe County, North Carolina ( Refs. 3; 4 , p. 5; 5 , p. 1 ). The geographic coordinates of the CTS site as collected from the easternmost building on th e CTS

property, specifically the northeastern corner of the building

, are 35 **°** 29' 35.07" North latitude, 82 **°** 30' 21.43" West longitude ( Figure s 1 and 4 ) (Ref. 42 , p. 6)

. The property was once part of a 66.4

- acre tract that was subsequently portioned off during numerous ownership changes (Ref. 6 , pp. 2

- 3). Title information for the property exists from 1942; however, several transactions are missing in the deed s earch to date (Ref. 6 , pp. 2

- 3). A larg e, one

- story brick building is located at the northeast corner of the property, fronting Mills Gap Road (Ref. 4 , p. 5). The building is situated on a n 8.65

- acre parcel of level ground surrounded by a 6

- foot

, chain

- l inked fence topped with barbed wire (Ref s

. 4, p . 5 ; 5 , p. 1 ; 6 , p. 52 ; 7 , p. 9 ). A locking gate at the north end of the property controls property access from Mills Gap Road ( Ref.

7 , p. 9). Residential properties border CTS to the south, east, and southwe st ( Ref. 7 , p. 9).

International Resistance Corporation (IRC) owned the property and operated an electroplating facility from approximately 1952 until 1959 (Ref

. 7 , p. 9). IRC was later merged into TRW, Inc.

, pursuant to an Agreement of Merger

dated November 28, 1967, and then merged into Northrop Grumman Space & Mission System Corp oration (Ref. 7 , p. 9). CTS of Asheville, Inc., once owned by and a subsidiary of CTS Corporation

, purchased the property from IRC in 1959 and utilized the facility for man ufacturing (Ref. 7 , p. 9). Arden Electroplating, Inc

. leased a portion of the building from December 1, 1985 to December 30

, 1986 ; operations during the lease period are unknown (Ref. 8 , p. 6). Electronic components utilized in automotive parts and heari ng aids were manufactured at the facility until plant operations ceased

in April 1986 (Ref. 7 , p. 9). Mills Gap Road Associates (MGRA) purchased the property from CTS Corporation in 1987 and leased portions of the facility to several different tenants, an d otherwise utilized the building for business interests (Ref. 7 , pp. 9, 10).

The building was constructed in approximately 1953 (Ref. 9 , p. 6). The facility was primarily used to manufacture electronic components utilized in automotive parts and hearing aids , having up to 600 employees during peak production ( Ref s

. 9 , p. 6 ; 7 , p. 9 ). Electroplating operations occurred at the plant , producing wa stew ater effluent and sludge ( Ref. 9

, p. 6 ). T richloroethene (TCE) was used in the process to clean and/or deg rease metal objects prior to electroplating (Ref.

7 , p. 9). The room designated for plating operations (plating room) was centrally located in t he rear of the plant ( Ref. 9

, p. 6 ). Between 1953 and 1980, wastes that could not be reclaimed from the electr oplating process were disposed of through the city sewer system (Ref. 4 , p. 5). After 1980, wastes were stored in drums or tanks on the property prior to transportation and disposal off property or for recycling (Ref. 4 , p. 5). On an annual basis, the fa cility produced approximately 44,440 pounds of sludge ; 8,307 pounds of waste solvents ; and 52,800 pounds of other waste organic chemicals (Ref. 4 , p. 5). A 1

- foot deep draina ge conduit lined with acid brick led from the plating area to a 2

- foot by 2

- f oo t sum p that drained to the H azardous Waste Treatment Plant (HWTP) located south of the plating room ( Ref. 9 , p. 6 ). At the HWTP, t he plating residues were reportedly removed, bagged, and disposed of by a CTS contractor (Ref. 9 , p. 6). Several storage tanks w ere formerly loc ated on the CTS property , including a small above

- ground storage tank (AST) near the equipment storage area and two, 4,000

- gallon underground storage tanks (USTs) containing acetone ( Ref. 9 , p.
6 ). The USTs, along with the a ssociated pumps and piping

, were located near the nort hwes t corner of the building ( Ref.

9 , p. 6 ). The ASTs and USTs have reportedly been removed by CTS personnel ( Ref. 9 , p p . 6

- 7 ).

TCE is a colorless liquid primarily used as a solvent for cleaning metal parts ; it is also an ingredient in adhesives, paint removers, typewriter correction fluids, and spot removers (Refs. 10 , p. 1 ; 11 , p. 1 ). TCE is not thought to naturally occur in the environment (Ref. 10 , p. 1 ). However, it has been found in underground water source s and many surface waters as a result of the manufacture, use, and disposal of the chemical (Ref. 10 , p. 1 ).

In November 1980, the General Manager of CTS Corporat ion filed an EPA Notice of Hazardous Waste Activity, Resource Conservation and Recovery Act ( RCRA )

, Part A

, application stating the company was a manufacturer of electronic components and accessories for electronic industries, with a date of operation as January 3, 1953 ( Ref s

. 12 , p p

. 1

- 5 ; 13 , pp. 1

- 2 ). Information on the application included E PA hazard waste code F001, specifically spent halogenated solvents used in degreasing, including TCE and tetrachloroethylene (PCE) as a facility material ( Refs. 12 , p. 2; 14 , p. 1 ).

On February 10, 1982, the North Carolina Solid and Hazardous Waste Manage ment Branch ( SHWMB ) conducted a RCRA compliance inspection at CTS and found that no written schedule was available for inspection of safety and15 emergency equipment or security devices (Ref. 15 , p. 16) . CTS was notified of the violation on February 15, 198 2 (Ref.

15 , p. 17). CTS agreed to comply with the requirement by April 1, 1982 (Ref. 15 , p p . 16, 18)

.

On April 19, 1982

, SHWMB accepted CTS’ s request for a generator, treatment , and storage classification under RCRA (Ref. 16 , p. 19).

On July 27, 1983, a RCRA Inspection Report completed by SHWMB stated day to day operations at CTS included electroplating electrical components with tin, nickel, zinc

, and silver resulting in 2,333 pounds per month of sludge ( Ref.

17 , p. 1 ). Approximately 31 gallons a month of acetone and ethyl acetate wer e wasted from resistant coating and approximately 31 gallons per month of 1,1,1

- trichloroethane were wasted from degreasing ( Ref. 17 , p. 1 ). No deficiencies were noted (Ref. 16 , p. 18). CTS requested to be removed as a tr eatment facility under RCRA on the basis that the type of treatment of plating waste conducted at the facility was not considered treatment under RCRA (Ref. 16 , p. 16). On August 23, 1983, the request was approved by SHWMB (Ref. 16 , p. 15).

On January 2, 1984, CTS was notified of Solid Waste Management Act (SWMA) violations identified during a facility inspection (Ref. 15 , p. 15).

On January 3, 1984, CTS confirmed they would only be treating and not storing hazardous waste on the property (Ref.

16 , p. 1 1). On January 10, 1984, SHWMB requested that CTS revise their January 3, 1984 Application for Change in Classification under RCRA from storer to treater based on the information provided, and that all hazardous waste stored on the property longer than 90 days be shipped out to a proper waste handling facility immediately (Ref. 16, pp. 12, 13). CTS submitted the application to delete storage from the RCRA classification on January 17, 1984 , based on a significant decrease in the volume of waste generated at the facility (Ref. 16 , p p . 13

, 14). The request was approved by SHWMB o n January 25, 1984 (Ref. 16 , p. 10).

On January 5, 1984, in response to a formal call by SHWMB

, CTS confirmed that the company would not be filing a RCRA

, P art B

, permit applicatio n ( Ref. 18 , p. 1 ). On March 13, 1984, SHWMB formally terminated CTS ’s interim

status and denied a permit as a hazardous waste treatment, storage, or disposal facility ( Ref. 18 , p. 1 ).

On December 4, 1984, SHWMB conducted a RCRA compliance inspection at t he CTS facility and found noncompliance in several areas including the accumulation time of hazardous waste at the facility (Ref. 15 , p p . 2

- 10). On January 2, 1985, SHWMB notified CTS of the inspection findings and requested a compliance date of January 7 , 1985 (Ref. 15 , p

. 2).

On October 16, 1985, N orth C arolina D epartment of H uman R esources (NCDHR) conducted a Preliminary Assessment (PA) at CTS ( Ref. 19 , pp. 3

- 4 ). Based on the data available at that time , NCDHR recommended low priority; however, a site reconnaissance survey of the property was recommended ( Ref. 19 , p. 1 ).

On January 16, 1986, CTS submitted an application for a change in RCRA classification to small quantity generator from

a generator (Refs. 16 , p. 8; 13 , p. 2). According to the appl ication, CTS sold all plating and process equipment to Arden Electroplating, Inc.

, on December 2, 1985 ; subsequently, the only hazardous waste generat ed by CTS was oil, acetone,

and f reon (Ref. 16 , p. 8). On January 31 , 1986, SHWMB accepted CTS’ s request for change in classification (Ref. 16 , p. 7 )

. Arden Electroplating ended their lease in 1986 (Ref. 8 , p. 6).

In 1987, CTS requested Law Environmental, Inc.

, (Law) to complete a S ite A ssessment at the form er CTS of Asheville facility ( Ref. 9 , p. 2 ). The purpose of the assessment was to provide CTS with a general environmental liability status report of the facility

, which assess ed the actual and potential environmental liabilities associated with the property ( Ref.

9 , p. 5 ). During the evaluation, Law c ollected data to determine the environmental conditions within the building shell, and in soils near the ground surface (Ref. 9 , p. 8). Several areas were noted as having been formerly utilized for handling hazardous substances, including the TCE storage tank area, acetone storage tank area and as sociated piping and pumps, oil storage tank, hazardous waste storage area, and waste water retention pond (Ref. 9 , p. 13). On an excavated bench west of the plant, a small steel mounting frame remained on a grave l pad on which a single AST for TCE was previously

located (Ref. 9 , p. 13). According to CTS personnel, the tank operated on a gravity feed system to the plant (Ref. 9 , p. 13). Fuel oil was a l so stored in the tank, an d oil staining was observed on the gr avel pad and on the asphalt service road16 leading to the bench during the assessment (Ref. 9 , p. 13)

. A compressor air receiver tank, used to receive compressor oil, was formerly located near the southern portion of the plant outside of the compressor room (Ref. 9 , p. 14). The tank was removed after plant operations ceased ( Ref. 9 , p. 14). Up to 18 inches of oil

- stained soil was reportedly removed from an area approximately 13 feet by 19 feet by a CTS contractor (Ref. 9 , p. 14). In this area, oil stainin g was observed by Law personnel along the base of the plant wall (Ref. 9 , p. 14). Hazardous material s were formerly stored in a fenced area directly south o f the facility (Ref. 9 , p. 15). A 20

- by

- 20

- foot asphalt pad surrounded by a steel fence remained i n place (Ref. 9 , p. 15). During the assessment, no visible staining, material spills, or leakage, were noted (Ref. 9 , p. 15). Drainage from the pad was to the east with water collecting in a low area approximately 15 feet from the asphalt pad (Ref. 9 , p. 15). A water runoff retention pond , located approximately 125 feet north of the northwest corner of the facility

, was previously used as part of CTS’s contingency plan (Ref. 9 , p. 15). During the 1987 Site Assessment , the pond was dry (Ref. 9 , p. 15). A concrete discharge flume leads from the underground culvert on the south side of the pond to a large gate valve at the base (Ref. 9 , p. 15). A pond water discharge culvert is located behind the gate valve on the north side of the pond (Ref. 9 , p. 15). The area was overgrown with weeds and no surficial evidence of waste materials was observed during the assessment (Ref. 9 , p. 15).

In an effort to establish the internal quality of the facility, several areas

, including the plating area, paint curing ar ea, compressor room, boiler room, hazardous storage area, the warehouse, and Hazard Waste Treatment pit were assessed during the 1987 investigation (Ref. 9 , p p . 16

- 20 ) . Details of the findings are discussed in the paragraphs below.

Plating operations wer e previously conducted in an 80 foot by 28 foot room (the plating room) centrally located near the back of the facility (Ref. 9 , p. 16). Manufacturing processes that required the chemical rinsing of parts were performed in this area (Ref. 9 , p. 16). Appr oximately one

- third of the floor space is concrete

, t he other two

- thirds is composed of acid

resistant brick and masonry concrete (Ref. 9 , p. 16). A 1

- foot wide

, acid brick

- lined drainage spillway divides the room (Ref. 9 , p. 16). S everal small chemical s torage areas were within the plating room

, includ ing a TCE pit or sump, a sulfuric acid tank, and a sodium hydroxide tank (Ref. 9 , p. 16). The TCE pit was approximately 7 feet by 7 feet and 2 to

3 feet deep (Ref. 9 , pp. 16

- 17). The sulfuric acid tank and sodium hydroxide tank were formerly located on a concrete pad near the north wall (Ref. 9 , p. 17). The drainage spillway enter ed the plating area from the dye room and passe d beneath the concrete pad (Ref. 9 , p. 17). An area where acid spilled from the tank and emptied into the drainage spillway

was located w est of the concrete pad (Ref. 9 , p. 17). The concrete was dissolved in this area exposing the underlying soil (Ref. 9 , p. 17). A cid brick was not utilized in the construction of the spillway in thi s location (Ref. 9 , p. 17). The drainage spillway led to a collection sump in a room south of the plating area (Ref. 9 , p. 17). The sump was approximately 2 feet by 2 feet and 2 feet deep (Ref. 9 , p. 17). Sediment up to 1 foot in depth was encountered i n the sump (Ref. 9 , p. 17).

Other rooms in the building include d the paint curing room, air compressor engine room, boiler room, parts warehouse, hazardous storage area, and dye room (Ref. 9 , pp. 18

- 20). The paint curing room, approximately 20 feet by 15 feet was located northeast of the plating area (Ref. 9 , p. 18). A drainage spillway start ing at the northwest corner of the paint curing room led to the plating area (Ref. 9 , p. 18). Several air compressor engines we re located in a large room in the

s outhern portion of the plant building (Ref. 9 , p. 18). Oils used for lubrication we re present in the drip collection pans (Ref. 9 , p. 18). The boiler room wa s centrally located in the rear of the facility (Ref. 9 , p. 19). The boiler ha d a one inch

thick insulation coating of asbestos material that ha d generally been enclosed with a layer of paint sealant (Ref. 9 , p. 19). A large room at the west end of the plant was utilized as a parts warehouse where the s hipping and receiving operations

were conducted (Ref. 9 , p. 19). One large loading bay was located on the north side of the room (Ref. 9 , p. 19). Several drums of unknown substances were stored in the northwest corner of the warehouse opposite the loading bay (Ref. 9 , p. 19). Slight staining was obs erved near these drums, as well as on the base of the exterior wall outside the building (Ref.

9 , p. 19). A large room near the southeast end of the plant building was formerly utilized as a hazardous storage area (Ref. 9 , p. 19). Hazardous materials use d in manufacturing processes were stocked in this area prior to use (Ref. 9 , p. 19). A large waste pit wa s located near the southwest corner of the plant building and was formerly used for the treatment of waste waters generated by plant operations (Ref. 9 , p. 20). The waste water effluent from the plating and paint curing rooms was treated at this location (Ref. 9 , p. 20). Dimensions of the waste pit were approximately 25 feet in length by 10 feet in width and 6 feet deep (Ref. 9 , p. 20). The pit wa s c overed with steel plates, one of which wa s hinged to allow access (Ref. 9 , p. 20). Waste treating equipment used in and around the pit was r emoved from the property prior

to the assessment (Ref. 9 , p. 20). A dye room wa s located near the southwest corner of the plant (Ref. 9 , p. 20). Dyes utilized in manufacturing processes were formerly stored and maintained in this area (Ref. 9 , p. 20). Dye residues were17 present throughout th e dye room as well as outside the building near the pump assemblies (Ref. 9

, p. 20).

On October 11, 1988, CTS submitted an application for change in classification under RCRA to delete CTS as a small quantity generator (Ref. 16 , pp. 3

- 4). On October 13, 1988, the North Carolina Hazardous Waste Management Branch accepted the re quest and inactivated the EPA RCRA ID for the facility (Ref. 16 , p. 2 )

.

In August of 1989, the NUS Corporation (NUS) , EPA Region IV Field Investigation Team (FIT), completed a Screening Site Inspection (SSI) , Phase I

, at the CTS facili ty ( Ref. 13 , p. 1 ). Phase I of the inspection included a review of state and EPA file material, a target survey, and an off site reconnaissance of the f acility and surrounding area ( Ref. 13 , p. 1 ).

B ased on targets and NUS’s findings , a n SSI, Phase II

, w as recommended for CTS ( Ref. 13 , p. 3 ).

On April 20, 1990, EPA documented a p hone conversation with a resident regarding the “chemical pond” on the property ( Ref. 20 , p. 2 ). The “chemical pond” was a reference to the 10,000

- gallon pit used to hold wat er from de

- watering sludge removed during the pre

- treatment of wastes generated by operations at the company ( Ref. 20 , pp. 1, 2 ).

On June 25 through June 26, 1990, NUS conducted the SSI, Phase II at the property ( Ref s

. 21 , p p

. 1, 7 ; 22 , p. 1 ). The

Stud y Plan for the SSI was submitted on May 31, 1990 (Ref. 23 , p. 1 ). Eighteen environmental samples, including six

surface soil , four subsurface soil, five sediments, two surface water samples , and one private well sample were collected during the field inve stigati on ( Ref. 21 , p p

. 15

- 16 ). The Final SSI, Phase II

, Report

, issued February 21, 1991

, stated that several organic and inorganic substances were detected in soil, sediment, and surface wate r sa mples ( Ref. 21 , p. 6 ). Vinyl chloride, TCE

, and 1,2

- dichlo roethene (1,2

- DCE ) were detected at concentrations of 47 micrograms per kilogram ( μg/kg )

, 50 μg/kg and 330 μg/kg , respectively

, in a surface water sample (Ref. 21 , p p . 27 , 33 )

. Vinyl chloride (84 μg/kg ) and 1,2

- DCE (29 to 1,100 μg/kg ) were detected in sedi ment samples (Ref. 21 , p p . 29

, 33, 110 ). Based on the analysis of possible migration pathways, the results of the sampling investigation, and the information obtained from the file material , NUS recommended no further remedial action for CTS (Ref. 21 , p. 6).

In July 1999, the N or th C arolina D epartment of E nvironment and N atural R esources (NCDENR)

, D ivision of W ater Q uality (DWQ)

, was contacted regarding an oily leachate in a ditch on a property adjacent to CTS (Ref. 24 , p. 6). At that time, NCDENR person nel collected samples from the ditch leachate and from two springs on the neighboring properties (Ref s

. 24 , p. 6 ; 25 , p. 1 ). L ow levels of chlorinated solvents (TCE at 8.7 E parts per billion [ ppb ] ) and petroleum

constituents were detected in a leachat e s ample (Ref s

. 24 , p. 6 ; 25 , p. 5 ). One spring sample (lab no. 9G1298) contained 15,000 ppb TCE, in addition to other chlorinated solvents and petroleum constituents (Ref s

. 24 , p. 6 ; 26 , p p . 3 , 22; 27 , p. 3 ; 25 , p. 16 ). The spring was used as a potable wat er supply until about 1994, when it was abandoned due to poor taste (Ref. 24 , p. 6). The second spring sample (lab no. 9G1297) contained 21,000 M ppb TCE in addition to other chlorinated solvents (Ref s

. 24 , p. 6 ; 26 , p. 3; 27 , p. 2 ; 25 , p. 11 ). At the ti me of sampling, the spring was being used as a potable water supply for the residents at both properties (Ref. 24 , p. 6). Representatives from the NCDENR advised those residents to stop using the spring as a water source (Ref s

. 24 , p. 6 ; 27 , p. 1 ). The r esidents currently obtain water

from the municipal supply (Ref. 24 , p. 6).

On July 28, 1999, the NCD E NR DWQ identified nine drinking water wells within 0.25

- mile of CTS and subsequently sampled those wells for volatile organic compounds ( VOCs ) (Ref s

. 24 , p. 6 ; 28 , p. 1 ). One of the nine well samples ( Sample 9G1464 ) contained TCE at 270 M ppb (pre

- ground water filter) and 170 M ppb (post

- ground water filter) (Ref s

. 24 , p. 6 ; 28 , pp. 2

- 5 ; 26 , p. 3 ). The M indicated that the sample was analyzed by GC/MS ( Refs. 24 , p. 6; 28 , pp. 2

- 5). The remaining ground water wells were below the 0.25 ppb analytical detection limit for TCE (Ref s

. 24 , p. 6 ; 28 , pp. 6

- 21 ). The NCDENR advised the residents not to use their well for drinking water (Ref. 24 , p. 6). T he NCDE NR subsequently requested that the EPA Emergency Response and Removal Branch ( ERRB ) review property information

and determine if the property qualified for a removal action under the federal Superfund program (Ref. 24 , p. 6).

On August 20, 1999, CMC, In c.
, (CMC) was issued an emergency delivery order from EPA to coordinate actions needed

to connect four res idences to city or c ounty water and to supply potable wa ter as neede d ( Ref. 29 , p p . 3

- 5, 6, 18 ). CMC responded to the emer gency on August 21, 1999 ( R ef s

. 29

, pp . 10, 18 ; 30 , p. 1 ). CMC provided the affect ed residences

with potable water until a contracted plumber could begin installation of the city wat er l ines to the residences ( Ref. 29 , p. 18 ). On August 23, 1999, CMC received an additional deliver y order to excavate contaminated soil from an impacted

cre ek near the CTS property ( Ref. 29 , p. 19 ). Soils were excavated

, loaded into a dump truck

, and transported off site for18 disposal ( Ref. 29 , p. 19 ). Upon completion of the excavation activities, CMC installed a siphon dam ( Ref. 29 , p. 19 ). Topsoil was placed , seeded

, and mulched in the affecte d area ( Ref. 29 , p. 19 ). In September 1999, CMC contracted a local plumber to have two residences connected to city water ( Ref. 29 , p. 18 ).

From November 9, 1999

, through Novem ber 11, 199 9, EPA’s Superfund Technical Assistance and Response Team (START) contractor, Tetra Tech EM, Inc.

, collected 10 surface and 19 subsurface soil samples

, and three sediment samples from 16 locations at the CTS facility ( Ref. 4

, p p . 8, 10 )

. The sampling locations were determined based on suspected areas of contamination, previous site investigations, and potential migration pathw ays ( Ref. 4 , p p . 9, 10 ). All surface soil samples and sediment samples were collected at a depth of 0 to 6 inches ( Ref. 4 , p. 9 ). Subsurface soil sample depths varied between sample locations depending on the ability of the direct push to penetrate subsurface

materials (between 2 to 23 feet) ( Ref. 4 , p p

. 8, 9)

. TCE and PCE were detected in surface and s ubsurface soil samples at concentrations ranging from 3 J to 33,000 μg/kg and 310 J μg /kg , respectively (Ref. 4 , pp. 10

- 11, 17

- 18, 34

- 35, 179,

207 ).

Potable wells in the area were again sampled in May 2000 (Ref. 31 ). TCE was detected in one private w ell, sample PW9

, at 310 J micrograms per liter ( μg/L ) (Ref. 31 , pp. 19, 26).

On August 1 4, 2000

, through August 17, 2000, under EPA’s Response Engineering and Analytical Contract (REAC)

, Lockheed Martin conducted spring and sump sampling and a geoph ysical investigation with the EPA Environmental Response Team (ERT) ( Ref. 32 , pp. 1

- 3 )

. Tw o springs located on the adjacent property, east of the CTS property, were sampled for VOCs, base neutral and acid extractables (BNAs), pesticides and polychlorinate d biphenyls (PCBs), target analyte list (TAL) metals, background fluorescence, oil fingerprint analysis, and total petroleum hydrocarbons ( Ref. 32

, p. 3 ). The springs were designated as “upper” (southernmost ) and “lower” (northernmost) ( Ref. 32 , p. 3 ).

A pproximately 11,000 μg/L of TCE were detected in the lower spring ; 23 μg/L of TCE were detected in the upper spring ( Ref. 32 , p p . 3

, 5, 27, 71 ). Cis

- 1,2

- dichloroethene (cis

- 1,2

- DCE) was present in both the upper spring and lower spring at

concentrations o f 330 μg/ L and 400 μg/L, respectively ( Ref. 32 , p p . 3

, 5, 27, 71 ).

On September 12, 2000, Lockheed Martin

- REAC completed an excavation of exploratory trenches ( Ref. 32 , p. 3 ). Locations were chosen based on previous field observations and the re sults of geoph ysical surveys ( Ref. 32 , p. 3 ). Trenches generally were 15 to 20 feet long, 3 feet wide, and located in areas of disturbed soil where spills may have occurred, o r ove r geophysical anomalies ( Ref. 32 , p. 3 ). All trenches, except for Trench 8, were ap proximate ly 8 to 12 feet deep ( Ref. 32 , p. 3 ). Trench 8 was excavated 18 feet deep in order to expose as much of the verti cal s oil profile as possible ( Ref. 32 , p. 3 ). A soil sample collected from Trench 8 contained 35 μg/kg of TCE ( Ref. 32 , p p

. 4

- 5, 30, 76 ). The REAC investigation did not indicate an obvious contamination source outside of the former plant building (Ref. 24

, p. 7). Therefore, the emphasis shifted to locating possible sources directly beneath the building (Ref. 24 , p. 7).

During the w e ek of May 7, 2001, Lockheed Martin

- REAC personnel conducted a soil boring and sampling event to determine if a source of ground water contamination, particularly VOCs and petroleum hydrocarbons

, w as present beneath the CTS building ( Ref. 33 , p. 1 ). A dire ct push was used to advance and sample 10 borings through the concrete floor of the CTS building and two borings outside of the building ( Ref. 33 , p. 2 ). Each location was continuously cored to refusal using four foot long, two

- inch diameter core barrels ( Ref. 33 , p. 2 ). Soil samples collected during the event were sent to the REAC laboratory in Edison, New Jersey for analysis ( Ref. 33 , p. 2 ). TCE was detected in all samples and generally indicated the highest concentrations of all VOCs detected ( Ref. 33 , p. 2 ). The highest TCE concentration, 830,000 μg/kg, was found in the 32 to 34 foot depth sample from borehole BH

- 3 ; however, concentrations were generally detected throughout the borehole ( Ref. 33 , p p . 2 , 8

, 29, 97, 98 ). The two cores from b orehole 12 , located outside of the CTS building, exhibited TCE concentrations of 110,000 μg/kg and 140,000 μg/kg at 12 to 16 feet below ground surface (bgs) and 16 to 19 feet bgs

, respectively ( Ref. 33 , p p . 2 , 12

, 29, 31, 97 )

. Samples collected from borings

located south of the building exhibited TCE concentrations from 900 μg/kg ( 30 to 31 feet bgs in BH

- 9 ) to 830 ,000 μg/kg ( 32 to 34 feet bgs in BH

- 3 ) (Ref. 33 , pp. 3, 29, 31

, 96 ).

On April 2, 2002, an Action Memorandum was approved by the Director of the Waste Ma nagement Division to clear the way for entering into negotiations with CTS to initiate an enforcement

- lead removal at the property ( Ref. 30 , p. 1 ).

On April 24, 2002, EPA personnel completed a site reconnaissance of the CTS facility ( Ref. 30 , p. 2 ). Dur ing the site19 reconnaissance, i t was noted that access to the property was uncontrolled and the fence surrounding the property was damaged (Ref. 30 , p. 2). A large AST located adjacent to the south side of the plant building was reportedly empty (Ref.

30

, p. 2). Three springs were observed just east of and downhill of the property (Ref. 30 , p. 2). The two springs ( historically referred to as Upper and Lower) had been modified to collect water for residential use (Ref. 30 , p p . 2 , 16

- 17 ). T here was a detec table organic solvent odor in the vicinity of the springs (Ref. 30 , p. 16). The discharge at each of the springs was very low, possibly less than one gallon per minute (Ref. 30 , p. 2). The third spring apparently was never used as a water source; a small underflow dam was present and the water appeared to have an oily sheen (Ref. 30 , pp. 2,

14

- 15).

Between February 2 and 3, 2003, on behalf of EPA, Weston Solutions, Inc. (Weston), collected five surface water and eight ground water samples from the area near the facility to determine the presence or absence of TCE contamination ( Ref. 24

, p p

. 4, 9 , 11 ). Surface water samples collected from 275/277 Mills Gap Road included fou r spring samples and one stream sample ( Ref. 24 , p. 9 ). G round water sample s w er e collected from each of the eight re sidential wells ( Ref. 24

, p. 9 ). In all surface water samples, TCE was present in concentrations above the N ational P rimary D rinking W ater
S tandards M aximum C ontaminant L evel (NPDWS MCL) of 5 μg/L ( Ref. 24 , p p . 1 3 , 18 )

. Cis

- 1,2

- DCE, which can be formed from the anaerobic biodegradation of TCE, was detected above the NPDWS MCL (70 μg/L ) in four surface water samples (Ref. 24 , p p . 13 , 18 ). Ground water samples did not exceed method detection limits for VO C s collected fr om the residential wells (Ref. 24 , p p. 15 , 22 ).

From June 21 , 2004 t hrough July 1, 2004, M ACTEC Engineering and Consulting, Inc.

, (MACTEC) , on behalf of CTS Corporation and Mills Gap Road Associates, conducted sampling activities pursuant to an Administrative Order on Consen t (AOC) for removal action between EPA, CTS Corporation, and the Mills Gap Road Associates ( Ref s

. 7 , p p

. 2,
6, 9 ; 34 , p. 2 ). The Sampling and Analysis Plan (SAP) was submitted to EPA on March 19, 2004

, and detail ed the objective s of the event (Ref. 35 , pp. 1

- 83 ). A ctivities included collecting continuous soil samples from 2 8 boreholes drilled using direct push technology ; three of which were developed into temporary piezometers and one was completed as a temporary monitoring wel l ( Ref. 7 , p p

. 6, 19

- 20, 99

- 120 ). Also, one soil vapor extraction (SVE) well and four SVE observation wells were drilled and installed for purposes of conducting a n SVE pilot test ( Ref. 7 , p p

. 6, 20 ). A total of 54 soil samples were collected and analyze d ( Ref. 7 , p p

. 7, 20 ). Water samples were collected from five spring sampling locations previously identified and from the temporary well installed by MACTEC ( Ref. 7 , p p

. 7, 21). VOCs detected in water samples included 1,1,1

- trichloroethane (1,1,1

- TCA ); 1,1

- dichloroethane (1,1

- DCA); 1,1

- dichloroethylene ( 1,1

- DCE ) ; benzene, methylene chloride; cis

- 1,2

- DCE; PCE; TCE; and vinyl chloride (Ref. 7 , p. 33). The highest total petroleum hydrocarbons

- diesel range organics (TPH

- DRO) concentration in water was colle cted from Spring

- 01 (14,000 μg/L) while the highest TCE concentration was detected in Spring

- 02 (22,000 μg/L ) (Ref. 7 , p. 33). The results of the SVE pilot test were presented in the Mills Gap Road Site Removal Action Pilot Study Plan (RAPSP) dated Septemb er 17, 2004 (Ref. 36 , p. 4). Details regarding the soil samples collected during this investigation will be discussed in the

source section (section 2.2) of this HRS documentation record

.

On August 18, 2006, MACTEC submitted a Removal Report, which docum ented the removal system installation activities performed at the property in June and July 2006, including well construction details and as

- built removal system drawings, and contains the proposed schedule of the system’s operation and maintenance details (Ref. 37 , p p

. 1, 4). A total of 15 SVE wells were installed on the CTS property ( Ref. 37

, p p . 5 , 10, 13 ). The system began operating on July 20, 2006 ( Ref. 37 , p. 5 ). The SVE system was expected to be used and monitored over the course of two years ( Re f.

37 , p. 7 ).

On November 27 to 28 , 2007 and December 11 to 12, 2007, NCDENR collected surface soil samples in the area surrounding the CTS facility on nearby properties (Refs. 38 , p. 8; 39 , p p

. 16, 372). TN & Associates, Inc. , (TN&A) on behalf of EPA, a ssisted NCDENR and the Buncombe County Health Department with surface water sampling, potable well water sampling

, and surface soil sampling ( Ref. 38 , p. 6 ). Samples were collected from less than 12 inches bgs (Ref.

38 , p. 8). A total of 14 surface soil samples were collected (Ref. 38 , p. 8). Of the 14 surface soil samples collected, TCE

was not detected in any of the samples (Ref. 38 , p. 9). Of the 13 surface water samples collected, TCE was detected in nine of the samples (Ref. 38 , p. 9). TCE concent rations in surface water ranged from 1.31 to 18,000 μg/L (Ref s

. 38 , p. 9 ; 39 , pp. 191, 193, 201, 203, 205, 207, 209, 211, 286 , 390, 392 ). Vinyl chloride was also detected in one sample at a

concentration of 2.8 μg/L (Ref s

. 38 , p. 9 ; 39 , p. 390 ). Cis

- 1,2

- DCE was detected in five samples at concentrations ranging from 8 to 1,320 μg/L (Ref s

. 38 , p. 9 ; 39 , pp. 206, 208, 210, 286 , 389, 391 ).20 As part of the November 2007

, sampling event, p roperty owners with a well located within a one

- mile radius of the

pro perty were allowed to request sampling of their potable wells by EPA (Ref. 38 , p. 6). From November 2007 to January 2008, NCDENR and TN&A sampled 75 residential potable water wells (Ref. 38 , p. 10). Three potable wells contained TCE at levels ranging fro m 4.32 μg/L to 929 μg/L (Ref. 39 , pp. 14, 87, 290, 376). Cis

- 1,2

- DCE was detected in two potable wells at 1.35 μg/L and 10.2 μg/L (Ref. 39 , pp. 86, 280, 289, 321). One monitoring well located on the CTS property (sample ID CTS

- 001

- MW) contained TCE at 4, 800 μg/L (Ref. 39 , pp. 14, 384, 451).

On December 13, 2007, EPA was notified by NCDENR that the analytical results for one residential potable water sample collected during the November sampling event contained TCE concentrations above the Federal Maximum

Contaminant Level ( MCL ) of 5 μg/L (Ref s

. 40 , p. 2 ; 41 , p. 4 ). The well was re

- sampled o n December 14, 2007 ; three samples (two field samples plus duplicate ) were collected from this location (Ref. 40 , p p . 2

- 3, 5, 10

- 18 ). The analytical

results indicate d TCE in all three potable water samples at concentrations ranging from 54.1 μg/L to 58.0 μg/L (Ref. 40

, p p . 3 , 10

- 18 ). Results for cis

- 1,2

- DCE ranged from 9.65 to 9. 95 μg/L (Ref. 40 , p p . 3 , 10

- 18 ).

From December 12

- 14 , 2007 and from Janua ry 14

- 16 , 2008, EPA ERT and TN&A conducted a field investigation in the

Oaks Subdivision , collecting 17 subsurface soil samples and eight temporary monitoring well ground water samples (Ref.

42 , p p . 10

- 11 ). Soil borings were advanced using a direct push d rill rig equipped with Direct

- Push Technology (DPT) (Ref. 42 , p. 11)

. One soil sample was collected from each soil boring from the depth interval indicating the highest photoionization detector ( PID ) / flame ionization detector ( FID ) reading (Ref. 42 , p. 1 1). TCE was not detected in the subsurface soil samples (Ref. 42 , p. 15). G round water samples were collected from six temporary monitoring wells installed using a direct push ( Ref. 42 , p. 11 ). Analytical results for the ground water samples indicated T CE in five samples at concentrations ranging from 13 to 1,500 μg/L ( Ref. 42 , p p . 15

- 16, 22 , 27, 29, 57, 59, 68, 74, 199, 258, 272, 426, 428, 43 8 ). Sample MGGC

- GW

- 01

, located approximately 250 feet north of the CTS building on the CTS property

,

co ntained t he highest concentration of TCE at 1,500 μg/L ; additionally, cis

- 1,2

- DCE and vinyl chloride were detected in

the same sample at 130 and 48 μg/L , respectively ( Ref. 42

, p p

. 15

- 16, 22, 27, 29, 57, 272, 428 )

.

During t he week of J une 26, 2008, TN&A, on behalf of EPA, collected potable water samples from “The Oaks”

subdivision

, located 0.673 mile northeast of the CTS property ( Ref s

. 3; 43 , pp. 1

- 2 ). Fifteen residential wells were sampled for VOCs ( Ref. 43 , p p

. 1, 2 ). The analytical results indicated the presen ce of TCE in three potable water samples at concentrations ranging from 8.8 μg/L to 51 μg/L, ten times greater than the MCL of 5 μg/L ( Ref s

. 43 , p p . 3, 9

- 11, 22 ; 41 , p. 4 ). Additionally, cis

- 1,2

- DCE was detected in the same three samples at concentrations ranging from 2.1 μg/L to 10 μg/L ( Ref

. 43 , p p . 3, 9

- 11, 22 ).

From August 2008 through July 2009, the Phase I Remedial Investigation (RI) was implemented in several phases, as directed by NCDENR (Ref. 8 , p. 9). The primary objective of the RI was to coll ect sufficient data to characterize ground water conditions in overburden (unconsolidated soil above bedrock) and bedrock (first productive fracture/zone) (Ref. 8

, p. 9). The first phase of work, conducted in August through October 2008, included the inst allation of eight overburden

mon i toring wells, and collection of soil and ground water samples for VOCs, semivolatile organic compounds ( SVOCs )

, Hazardous Substance List (HSL) metals, and cyanide (Ref. 8 , p p

. 9

- 10 ). Soil samples were required to be collec ted within several feet of the apparent water table at each monitoring well cluster during the first phase of work (September 2008) (Ref. 8 , pp. 13, 50). The soil samples (SS

- 1 through SS

- 6) were submitted for analysis of VOCs, SVOCs, HSL metals, and cyan ide (Ref. 8 , pp. 13, 50). Samples were collected from 16 to 29 feet bgs (Ref. 8 , p. 50).

The second phase of the RI , conducted in February 2009, included the installation of two monitoring wells located on the

CTS property that were sampled for VOCs, SVO Cs, HSL metals, and cyanide (Ref. 8 , p. 10). The third phase of work, conducted in March and April of 2009, included the installation of seven overburden monitoring wells located off the
property and two overburden monitoring wells on the CTS property , a nd the collection of ground water samples from the nine wells for analysis of VOCs (Ref. 8 , p. 10). TCE was detected at concentrations ranging from 6.4 to 35,000 μg/L (Ref. 8 , pp. 73, 288, 292, 308, 312, 325). Results for TCE and cis

- 1,2

- DCE were below t he reporting limit in April 2009. The final phase of work, conducted in June and July 2009, included the installation of two bedrock monitoring wells

located off the CTS property and collection of ground water samples from the two wells for analysis of VO Cs (Ref. 8 , p. 10). Cis

- 1,2

- DCE was detected at 1,900 μg/L and TCE at 35,000 μg/L (Ref. 8 , pp. 73, 350

, 3 53, 363).21 On Sept ember 15 to 18, 2008, TN&A collected potable drinking water samples from 72 residences located within a one

mile radius of the CT S facility , on behalf of EPA ( Ref. 44 , p p . 1 , 3 ). A total of 8 2 potable drinking water samples

, including nine field duplicates, were collected and submitted for analysis ( Ref. 44 , p p . 2

- 3 ). The analytical results indicated the presence of TCE in three p otable water samples at concentrations ranging from 2. 7 μg/L to 66 μg/L ; cis

- 1,2

- DCE was detected in the same three samples at concentrations ranging from 0. 84 μg/L to 13 μg/L ( Ref. 44 , p p

. 3, 14, 16, 26, 378, 387

- 388, 471

- 472, 676

- 677, 679 ). PCE was also detected in one sample ( Ref. 44 , p p. 24, 314, 460, 680 ). TCE

and 1,2

- DCE were detected at 1,100 μg/L and 95 μg/L, respectively , in the historically contaminated well ( Ref. 44 , p p

. 28, 49, 54, 681 ).

On December 1, 2008, TN&A submitted the Quality Assur ance Project Plan / Site Sampling Plan ( QAPP/SSP ) for the Quarterly Monitoring at Mills Gap on behalf of EPA (Ref. 45 , p. 48). Quarterly ground water monitoring began during

the first quarter of 2009 and continues to the present; the most recent sampling event was conducted in February 2010 (Refs. 46 , p. 3 ; 47 , p. 3; 48 , p. 2; 49 , p. 2; 50 , p. 2). Between 40 and 95 private drinking water wells were sampled during each quarterly ground water monitoring sampling event (Refs. 46 , p. 3 ; 47 , p. 3; 48 , p. 3; 49 , p. 3; 50 , p. 3). Overall, a nalytical results from the sampling event s indicate the presence of several SVOC s , VOC s and metals; TCE was

no t detected in the ground water samples (Ref s

. 46 , p. 4; 47 , p. 4; 48 , p. 3; 49 , p. 3; 50 , p p

. 4

- 6 ). N o TCE breakdow n compounds were detected (Ref s

. 46 , p. 4; 47 , p. 4; 48 , p. 3; 49 , p. 3; 50 , p p

. 4

- 6 ). However, following the fourth quarter, 2009, sampling event, TCE and its breakdown compound, cis

- 1,2

- DCE, were detected in one sample (MG

- GMP4

- 09) at

concentrations of 430 μg/L and 32 μg/L, respectively (Ref. 49 , pp. 3, 8, 10, 20, 44, 46, 696, 887, 918). TCE was first detected in this well in August 2009 when the EPA Environmental Response Team (ERT) sampled it during an attribution study (Ref. 49 , p p . 3 , 44 ). PCE was detected in the second quarter sampling, but not above the Method Reporting Limit (MRL) (Ref. 47 , p p . 4 , 24, 188 ).

In April of 2009, packer testing and private well sampling was conducted by Lockheed Martin Technology Services

REAC on behalf of the EPA ER T (Ref. 51 , p p . 1

- 2 ). The purpose of the investigation was to sample selected private wells at discrete depth zones to determine entry elevations of ground water contaminated with TCE (Ref. 51 , p. 1). Sample zones were limited to a maximum of three secti ons in each well and to depths of no more than 300 feet (Ref. 51

, p. 2). The target zones were designated “A” for the uppermost interval, “B” for the intermediate interval, and “C” for the lowest interval (Ref. 51 , p. 2). Within each well, TCE concentrat ions appeared to be relatively constant with depth (Ref.

51 , p. 3). Among samples collected for the packer testing, all samples submitted for analysis contained concentrations of

cis

- 1,2

- DCE, ranging from 0.11 μg/L to 98 μg/L

, and all samples contained co ncentrations of TCE, ranging from 9 μg/L

to 990 μg/L (Ref. 51 , pp. 9

- 11, 21

- 45 ). Among the samples submitted, sample MG

- PT

- 04C had the highest

concentrations of both cis

- 1,2

- DCE and TCE (Ref. 51 , p. 9

- 11, 32).

On January 19, 2010, EPA Science and Ecosy stem Division ( SESD ) Region 4 submitted a Site Investigation Report for “Mills Gap Ground Water Contamination” (Ref. 52 , pp. 1

- 111 ). The investigation was conducted the week of November 16, 2009 , and include d surface water, sediment, and soil sampling (Re f. 52 , pp. 1, 4 ). Samples were analyzed for VOCs, SVOCs, PCBs, metals, and cyanide analyses (Ref. 52 , p. 5). Among samples submitted for analysis, one soil sample

collected at the CTS facility at Station CTS02 (Sample ID CTS021109) had a TCE concentratio n of 2.4 μg/kg (Ref. 52

, pp. 6, 13, 52

- 53, 64 , 94, 107).

A secondary source investigation was conducted at the Mills Gap Road Site from March to May 2010 by Lockheed Martin Scientific Engineering, Response and Analytical Contract (SERAS) personnel for EPA ERT (Ref. 83, p. 1). The purpose of the investigation was to assess the potential risk of TCE and toluene contamination in the Oaks Residential Area (ORA) and its relation to known contamination at the CTS property by:

**•** Collection and analysis of stream sediment and surface water samples for VOC s to determine the presence or absence of an upgradient source of contamination from the ORA as well as the collection of downgradient surface water samples from the ORA;

**•** Collection and analysis of spring samples for VOC s to determine the presence or absence of an upgradient source of contamination from the ORA and the collection of a downgradient spring sample from the ORA;

**•** Wet chemistry analysis (sodium, chloride, nitrate/nitrite, sulfate, and total dissolved so lids) of ground water samples collected from shallow fracture s for determination of possible impact by local septic systems;22 **•** Evaluation of hydraulic response and connectivity of bedrock fractures through identification of areas of local fracturing, isolati on of fracture zones using a straddle packer assemblage, and monitoring fluctuations in ground water levels in observation wells during pumping of individual fracture zones; and

**•** Collection of representative ground water samples from the most transmissive f ractures in select wells using the packer assemblage and analyzing the samples for VOC s to determine a vertical profile for TCE and toluene contamination (Ref. 83, pp. 1

- 2).

During the investigation SERAS personnel collected a total of five sediment sampl es from three stream locations (including matrix spike/matrix spike duplicate [ MS/MSD ] samples and one duplicate) and nine surface water samples from seven locations (including MS/MSD samples and one duplicate sample) for VOC analysis (Ref. 83, pp. 3

- 4, 10 , 18

- 19, 24). A total of 76 ground water samples were collected; eight shallow ground water samples were collected for wet chemistry analysis from the shallowest fracture at each well, and 68 ground water samples (including duplicates) were

collected for VOC analysis (Ref. 83, pp. 4, 17, 20, 22, 25

- 35). No VOC s were detected in any of the sediment samples collected (Ref. 83, pp. 10, 18, 24). No VOC s were detected in any surface water samples collected from the unnamed stream (Ref. 83, pp. 11, 19, 24). T oluene (0.15 μg/L) and o

- xylene (0.09 μg/L) were detected in a residential spring downgradient of CTS, and traces of methyl

- tert butyl ether (MTBE) at levels of 0.14 and 0.15 μg/L were detected in surface water samples collected from a retention pond in th e area (Ref. 83, pp. 11, 19, 24).

Site Description

The CTS of Asheville, Incorporated (CTS) site, for HRS scoring purposes, consists of the contaminated soil source underneath and adjacent to the CTS building (Source 1) , and associated releases of VOCs to ground water.Source Characterization and Containment

Source No. 1

23 2.2 SOURCE CHARACTERIZATION

Number of the source : 1

Name and description of the source : Contaminated soil

HRS Source Type : Contaminated soil Electroplating op erations at the CTS facility began in 195 2 ( Ref. 7, p. 9). In 1959, manufacturing of electronic components utilized in automotive parts and hearing aids began at the CTS facility (Ref. 7, p. 9). TCE was used to clean

m etal objects during degreasing (Ref. 7

, p. 9). The plating room was centrally located within t he back area of the plant building (Ref. 9 , p. 6). A 1

- foot deep drainage conduit lined with acid

- brick led fr om the plating area to a 2

- by

- 2

- foot

sump, which drained to a HWTP located south of the plating room (Ref. 9 , p. 6). The HWTP, used for the trea tment of waste waters generated by plant operations, consisted of a waste pit located near the southwest corner of the plant building ( Ref. 9 , p. 20). Dimensions of the waste pit were approximately 25 feet in length by 10 feet in width and 6 feet in depth (Ref. 9 , p. 20). At the HWTP, the plating residues were reportedly removed, bagged, and disposed of by a CTS contractor (Ref. 9 , p. 6). Also present at the facility was a TCE storage area, a 7

- by

- 7

- foot TCE sump, hazardous waste storage area, and an AST for TCE storage (Ref. 9 , p p . 13

- 17 ).

During the 1987 Law Site Assessment for CTS, Law personnel dug six hand

- auger borings (HA

- 1 through HA

- 6) to a depth of approximately 4 feet, where samples were collected at 6 inch vertical intervals (Ref. 9 , p p . 11, 3 2). Composites from individual samples were retained from each sample location (Ref. 9 , p. 11). The background surface soil sample (identified as BG

- CV) collected during the assessment was located approximately 125 feet south of the HWTP (Ref. 9

, pp. 15

- 16 , 29, 97 ). In comparison to background, TCE was elevated in all of the soil borings collected outside the plant building, with values ranging from 6 μg/kg to 380 μg/kg (Ref. 9 , pp. 21, 29 , 32, 105, 109 ). TCE and PCE were also

detected at elevated conce ntrations in the plating area (Ref. 9 , pp. 22, 29 , 32, 91 ). The highest detection of TCE was found in the southwest corner of the building at 53,000 μg/kg (Ref. 9 , pp. 29, 33, 93).

From November 9, 1999

, through November 11, 199 9, Tetra Tech EM, Inc.

, under EPA’s Superfund Technical Assessment and Response Team ( S TART ) contract, collected 10 surface and 19 subsurface soil samples and three sediment samples from 16 locations at the CTS facility (Ref. 4 , pp. 8, 10 ) . The sampling locations were determine d based on suspected areas of contamination, previous site investigations, and potential migration pathways ( Ref. 4 , p p . 9

, 10 ). All surface soil samples and sediment samples were collected at a depth of 0 to 6 inches (Ref. 4 , p. 8). Subsurface soil samp le depths varied between sample locations depending on the ability of the direct push to penetrate subsurface

materials (between 2 to 23 feet) (Ref. 4 , pp. 8

- 9). TCE and PCE were detected at elevated concentrations in surface and

subsurface soil and sedim ent samples at concentrations ranging from 3 J μg/kg to 33,000 μg/kg and 310 J μg /kg, respectively (Ref. 4 , pp. 10

, 11, 17

, 18, 20, 34

- 35, 179, 207).

On September 12, 2000, EPA’s REAC contractor, Lockheed Martin Technology Services

, completed an excav ation of exploratory trenches (Ref. 32 , p. 3). Locations were chosen based on previous field observations and the results of geophysical surveys (Ref. 32 , p. 3). Trenches generally were 15 to 20 feet long, 3 feet wide, and located in areas of

disturbed s oils, where spills may have occurred, or over geophysical anomalies (Ref. 32 , p. 3). All trenches, except for Trench 8, were approximately 8 to 12 feet deep (Ref. 32 , p. 3). Trench 8 was excavated 18 feet deep in order to expose

as much of the vertical s oil profile as possible (Ref. 32 , p. 3). A soil sample collected from Trench 8 contained 35 μg/kg of TCE (Ref. 32 , pp. 4

, 5, 30, 76). The REAC investigation did not indicate an obvious contamination source outside of the former plant building (Ref. 24 , p . 7). Therefore, the emphasis shifted to locating possible sources directly beneath the building (Ref. 24 , p. 7).

During the week of May 7, 2001, Lockheed Martin

- REAC personnel conducted a soil boring and sampling event to determine if a source of ground water contamination, particularly VOCs and petroleum hydrocarbons were present beneath the CTS building (Ref. 33 , p. 1). D irect push technology was used to advance and sample 10 borings through the concrete floor of the CTS building and two borings outsi de of the building (Ref. 33 , p. 2). Each location was continuously cored to refusal using four foot long, two

- inch diameter core barrels (Ref. 33 , p. 2). Soil samples collected during the event were sent to the REAC laboratory in Edison, New Jersey for a nalysis (Ref. 33 , p. 2). TCE was detectedSource Characterization and Containment

Source No. 1

24 in all samples and generally indicated the highest concentrations of all VOCs detected (Ref. 33 , p. 2). The highest TCE concentration, 830,000 μg/kg, was found in the 32 to 34 foot depth sample from borehole BH

- 3 ; however, concentrations were generally present throughout the borehole (Ref. 33 , pp. 2, 8, 29, 97, 98). The two cores from borehole 12, located outside of the CTS building, exhibited TCE concentrations of 110,000 μg/kg and 140,000 μg/kg at 12 to 16 feet below ground surface (bgs) and 16 to 19 feet bgs

, respectively (Ref. 33 , pp. 2, 12, 29, 31, 97). Samples collected from borings located south of the building exhibited TCE concentrations from 110,000 μg/kg (32 to 38 feet bgs) to 400,000 μg/kg (20

to 24 fe et bgs) (Ref. 33 , pp. 3, 27, 28, 96).

From June 21, 2004 through July 1, 2004, MACTEC conducted sampling activities pursuant to an AOC for removal action between EPA, CTS Corporation, and the Mills Gap Road Associates (Ref s

. 7 , pp. 6, 9 ; 34 , p. 2 ). The SAP was submitted on March 19, 2004, and detailed the objectives of the event (Ref. 35 , pp. 1

- 83). A ctivities included collecting continuous soil samples from 28 boreholes drilled using a direct push ; three of which were developed into temporary piezomet ers and one was completed as a temporary monitoring well (Ref. 7 , pp. 6, 19

- 20, 99

- 120). Also, one SVE well and four SVE observation wells were drilled and installed for purposes of conducting an SVE pilot test (Ref. 7 , pp. 6, 20). A total of 54 soil sam ples was collected and analyzed ( Ref. 7 , p p

. 7, 20).

Location of the source, with reference to a map of the facility : Contaminated soil covers the majority of the CTS facility property and includes the soil beneath the building

. See Figure

3 of this doc umentation r ecord for sample locations.

Containment : Release to ground water : N o evidence of a natural or man

- made liner has been documented during subsurface soil sampling activities at the property

. (Refs. 7 , pp. 1

- 667 ; 39 , pp. 1

- 457 ; 42 , pp. 1

- 440 ; 8 , pp. 1

- 516 ).

Based on Reference 1, Table 3

- 2, the contaminated soil yields a containment factor value of 10.

Ground W ater Containment Factor Value: 10 Reference: 1, Section 3.1.2.1, Table 3

- 2Source Hazardous Substances

Source No. 1

25 2.4 Waste Charac teristics

2.4.1 Hazardous Substances

The investigation detailed below include s soil samples (surface and/or subsurface) indicating elevated levels of TCE and/or its breakdown products collected from Source 1.

- 2004 Sampling and Analysis Plan Report ( MACTEC )

In June 2004, MACTEC collect ed soil samples from soil borings at the CTS property (Ref. 7 , pp. 6, 89). A designated background soil sample was not collected as part of the 2004 MACTEC investigation. Therefore, for the purposes of this

Documentation Record , samples BH

- 30A (4.5 to 5. 5 feet bgs), BH

- 30B (14.5 to 15.5 feet bgs), and BH

- 30C (17.0 to 18.0 feet bgs) collected from borehole 30, w ere used as the background (Ref. 7 , pp. 49, 60, 61, 411, 421, 427). All samples designated with “A” were compared to BH

- 30A; all samples designate d with “B” were compared to BH

- 30B, and, all samples designated with “C” were compared to BH

- 30C (Ref. 7, pp. 81, 82). Samples from borehole 30 were collected during the same week as the other field samples

, and all drilling and sampling activities includ ed collecting continuous soil samples using direct push technology (Ref. 7, pp. 6, 19, 48, 49). All s amples were submitted to Shealy Environmental Services Laboratory for target compound list ( TCL ) VOC analysis by EPA Method 8260B (Ref. 7 , p. 22, 50). Al l samples had a physical soil sample description of sand and silt (Ref. 7, pp. 99

- 126). Boring logs can be found in Appendix B of the MACTEC report (Ref. 7, pp. 99

- 126). Samples were analyzed in accordance with USEPA SW

- 846, guidance Test

Methods for Eva luating Solid Waste, Physical/Chemical Methods (Ref. 7 , p. 22). The laboratory implemented its own internal quality assurance/quality control (QA/QC) procedures for routine operations as were specified in the laboratory’s Quality Assurance Management Plan (QAMP) (Ref. 7 , p. 22). Sample locations are illustrated in Figure 3 of this

Documentation Record

.

- Background Samples

Sample

ID Sample Type Date Sample Depth Hazardous
Substance Hazardous
Substance

Concentration (μg/kg) PQL (μg/kg) References

B H

- 30A Soil 6/28/2004 4.5

- 5.5 feet bgs (Interval A) Cis

- 1,2

- DCE 7.9 ND 7.9 7 , pp. 49, 60, 421,

512 TCE 7.9 ND 7.9

PCE 7.9 ND 7.9

BH

- 30B Soil 6/28/2004 14.5

- 15.5 bgs (Interval B) TCE 8.6 ND 8.6 7 , pp. 49, 61, 427,

512

PCE 8.6 ND 8.6 7 , pp. 49, 61, 427,

512

BH

- 30C Soil 6/28/2004 17.0

- 18.0 bgs (Interval C) TCE 6.5 ND 6.5 7 , pp. 49, 61, 411,

512

Notes:

BH

- Bore Hole Bgs

- Below Ground Surface

ID

- Identification

DCE

- Dichloroethene (Dichloroethylene)

ND

- Not detected at or above PQL

P CE

- Tetrachloroethene (T etrachloroethylene ) PQL

- Practical Quantitation Limit

TCE

- Trichloroethene (Trichloroethylene) μg/kg

- Micrograms per kilogramSource Hazardous Substances

Source No. 1

26 - Contaminated Subsurface Soil Samples (Interval A
, 4.5

- 5.5 feet bgs )

– June 2004

Sample ID Hazardous
Substance Hazardous
Substance

Concentration ( μg/kg ) PQL ( μg/kg ) References

BH

- 13A TCE 1,400 310 7 , pp. 53, 81, 89, 168,

316

BH

- 14A TCE 46 7.9* 7 , pp. 53, 81, 89

BH

- 15A TCE 12 5.5 7 , pp. 53, 81, 89, 243,

286

BH

- 16A TCE 18 0 6.0 7 , pp. 54, 81, 89, 168,

310

BH

- 17A TCE 120 5.4 7 , pp. 54, 81, 89, 168,

323

BH

- 18A TCE 62 5.2 7 , pp. 55, 81, 89, 169,

385

BH

- 19A TCE 8.7 6.7 7 , pp. 55, 81, 89, 445,

512

BH

- 20A TCE 17 7.9* 7 , pp. 55, 81, 89

BH

- 22A TCE 18 6.9 7 , pp. 57, 82, 89, 480

, 513

BH

- 23A PCE 17 5.7 7 , pp. 57, 82, 90, 550,

667

BH

- 23A TCE 600 310 7 , pp. 57, 82, 89, 550,

667

BH

- 26A TCE 20 7.1 7 , pp. 58, 82, 89, 488,

513

BH

- 32A Cis

- 1,2

- DCE 20 5.4 7 , pp. 62, 82, 169, 341

BH

- 32A PCE 1,100 290 7 , pp. 62, 82, 90, 169,

341

BH

- 32A TCE 9,100 290 7 , pp. 62, 82, 89, 169,

341

Notes:

*

- Value given is PQL for background sample since analytical data sheet is not available.

A

- First sample interval (depth)

BH

- Bore Hole

DCE

- Dichlorethene (Dichloroeth ylene)

ID

- Identification PQ L

- Practical Quantitation Limit

P CE

- Tetrachloroethene (T etrachloroethylene )

TCE

- Trichloroethene (Trichloroethylene) μg/kg

- Micrograms per kilogramSource Hazardous Substances

Source No. 1

27 - Contaminated Subsurface Soil Samples (Interval B

, 14.5

- 15.5 bgs )

– June 2004

Sample ID Hazardous
Substance Hazardous
Substance

Concentration ( μg/kg ) PQL ( μg/kg ) References

BH

- 13B TCE 36 4.9 7 , pp. 53, 81, 89, 168,

304

BH

- 14B TCE 12 8.6* 7 , pp. 53, 81, 89

BH

- 15B TCE 10 6.6 7 , pp. 54, 81, 89, 235,

286

BH

- 16B TCE 68 5.2 7 , pp. 54, 81, 89, 168,

298

BH

- 17B TCE 190 5.0 7 , pp. 54, 81, 89, 168,

331

BH

- 18B TCE 18 5.6 7 , pp. 55, 81, 89, 169,

377

BH

- 19B TCE 80 7.1 7 , pp. 55, 81, 89, 439,

512

BH

- 20B TCE 160 8.6* 7 , pp. 56, 81, 89

BH

- 21B TCE 14,000 620 7 , pp. 56, 82, 89, 561,

667

BH

- 22B TCE 12,000 430 7 , pp. 57, 82, 89, 466,

513

BH

- 23B TCE 33,000 1,200 7 , pp. 57, 82, 89, 527,

667

BH

- 25B TCE 110 4.7 7 , pp. 58, 82, 89, 633,

666

BH

- 26B TCE 69 10.0 7 , pp. 58, 82, 89, 494,

513

BH

- 28B PCE 11 8.6* 7 , pp. 60, 82, 90, 665,

667

BH

- 28B TCE 780 5.8 7 , pp. 60, 82, 89, 593, 665, 667

BH

- 29B TCE 18 6.0 7 , pp. 60, 82, 89, 257,

286

BH

- 34B PCE 4,800 3,000 7 , pp. 62, 82, 90, 354

BH

- 34B TCE 440,000 30 ,000 7 , pp. 62, 82, 89, 354

Notes:

*

- Value given is PQL for background sample since analytical data sheet is not available.

B

- Second sample interval (depth)

BH

- Bore Hole

ID

- Identification

P CE

- Tetrachloroethene (T etrachloroethylene ) PQ L

- Practical Quantitation Limit

TCE

- Trichloroethene (Trichloroethylene) μg/kg

- Micrograms per kilogramSource Hazardous Substances

Source No. 1

28 - C ontaminated Subsurface Soil Samples (Interval C
, 17.0

- 18.0 bgs )

– June 2004

Sample ID Hazardous
Substance Hazardous
Substance

Concentration ( μg/kg ) PQL ( μg/kg ) References

BH

- 19C TCE 640 8.4 7 , pp. 55, 81, 89, 451,

513

BH

- 20C TCE 240,000 6.5* 7 , pp. 5 6, 81, 89

BH

- 21C TCE 50,000 2,700 7 , pp. 56, 82, 89, 567,

667

BH

- 22C TCE 95,000 4,600 7 , pp. 57, 82, 89, 474,

513

BH

- 25C TCE 87 5.6 7 , pp. 58, 82, 89, 612,

665

BH

- 29C TCE 21 6.1 7 , pp. 60, 82, 89, 263,

286

Notes:

*

- Value given is PQL for background sample since analytical data sheet is not available.

BH

- Bore Hole

C

- Third sample interval

ID

- Identification PQ L

- Practical Quantitation Limit

TCE

- Trichloroethene (Trichloroethylene) μg/kg

- Micrograms per k ilogram

List of Hazardous Substances Associated with Source 1:

TCE

PCE

Cis

- 1,2

- DCE

Additional S upporting D ata

In addition to the 2004 MACTE C data

, several investigations conducted at CTS at or within the vicinity of S ource 1 between 1987 and 2010 have further shown the presence of TCE and related VOCs in facility soil s (Ref. 4, 9, 21, 32, 33, 52).Source Hazardous Waste Quantity

Source No. 1

29 2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity

Insufficient data is available to calc ulate the hazardous constituent quantity.

Hazardous Constituent Quantity Value (S): Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity

Insufficient data is available to calculate the hazardous wastestream quantity.

Hazardous Wastestream Quantity Valu e (W): Not Scored

2.4.2.1.3 Volume

Insufficient data is available to calculate the volume.

Volume Assigned Value (V): 0

2.4.2.1.4 Area

The area of contaminated soil was identified by creating a polygon from the perimeter samples within the area of

cont amination. Soil samples collected at CTS with elevated concentrations of contaminants of concern are plotted on Figure 3 of this Documentation Record. The borehole locations used to make the polygon (in clockwise order) include

BH

- 13, BH

- 16, BH

- 20, BH

- 25, BH

- 26 , BH

- 29 , BH

- 23, BH

- 34, BH

- 18, BH

- 19, and BH

- 14

. The soil samples that form the

sou r ce area were collected during the 2004 MACTEC investigation (Ref. 7 , pp. 1

- 667 ). The source area totals 43

, 859 feet square ( ft 2 ) o r 1. 006 acres. The square foot calculation is a function of ArcGIS.

Drilling and soil sampling activities included collecting continuous soil samples from boreholes using direct push technology (Ref. 7, p. 6). Due to the elevated results in soil samples in every sample interval and th e distance to the former facility operations , it is inferred that the contamination existing with the source area is continuous (Ref. 7 , pp. 87

- 90 ). Horizontal and vertical distribution maps of TCE (and breakdown product) contamination can be found in the 2004 MACTEC report (Ref. 7, pp. 87

- 90).

Equation for hazardous waste quantity evaluation for the area of contaminated soil is A/34,000. Therefore, 43,859 ft 2

/34,000 = 1.29

Area Assigned Value: 1.29 Reference: 1, Table 2

- 5

2.4.2.1.5 Source Hazardou s Waste Quantity Value

Source Hazardous Waste Quantity Value : 1.29 Reference: 1, Section 2.4.2.2Summary of Source Descriptions

30 SUMMARY OF SOURCE DESCRIPTIONS

Source

No. Source Hazardous Waste Quantity Value Containment

Ground Water Surface

Water Soil Air

Ga s Particulate

1 1.29 10 NS NS NS

SUM 1.29

Notes:

NS

- Not Scored

Reference: 1, Section 2.4.2.2, Table 2

- 6

2.4.2.1. 6 Other Possible Sources No other possible sources have been identified at the CTS facility; however, s everal storag e tanks were formerly located

on the CTS property, including a small AST near the equipment storage area and two, 4,000

- gallon USTs containing

acetone (Ref. 9 , p. 6 ). The AST reportedly contained TCE (Ref. 9, p. 7). The USTs, along with the a ssociated pu mps and piping

, were located near the northwest corner of the building ( Ref. 9 , p. 6). The AST and USTs have reportedly been removed by CTS personnel ( Ref. 9 , pp. 6

- 7) , but i t is not clear whether any releases that may have occurred at these

areas remain at the site.Ground Water Migration Pathway Description

31 3.0 GROUND WATER MIGRATION PATHWAY

3.0.1 GENERAL CONSIDERATIONS

Ground Water Migration Pathway Description

Regional Geology

Buncombe County is located in the Blue Ridge Highlands subdivision of the southern Blue Ridge Physiographic

Pro vince of the Appalachian Mountain system (Ref s

. 53 , p. 1; 54 ). The Blue Ridge Highlands is characterized by a complex, irregular pattern of mountain ranges, intermontane basins, and trench valleys (Ref s

. 53 , p. 1; 54 ). Approximately one

- half of the county lies in the Asheville basin with mountains making up the perimeter to the north, east, and west (Ref s

. 53 , p. 1; 54 ). Contour levels between 2,300 and 2,400 feet of elevation define the upper surface of the basin (Ref s

. 53 , p. 1; 54 ). It has a jagged, i rregular border because intervening ridges from the adjacent highlands extend some distance into the basin (Ref s

. 53 , p. 1; 54 ). Elevation s in Buncombe County range from approximately 1,720 feet above mean sea level to approximately 6,419 feet above mean sea level (Ref s

. 55 , p. 89 ; 53, p. 1 ). The Appalachian Mountains were formed during a series of Paleozoic orogenic events in which the rocks were metamorphosed, folded, faulted and uplifted into high mountains (Ref s

. 53 , p. 1; 54 ). The mountains were sub sequently uplifted and eroded to expose the rocks currently present at the surface (Ref s

. 53 , p. 1; 54 ). The metamorphic rocks that comprise the mountains have a well

- developed foliation that strikes predominantly northeast

- southwest (NE

- SW) (Ref s

. 53 , p. 1; 54 ). This foliation most commonly dips southeast (SE) but in many localities dips northwest (NW) (or almost any direction) due to folding (Ref s

. 53 , p. 1; 54 ). The majority of mountain ranges in the area have a northeast (NE) alignment generally fol lowing the regional strike (Ref s

. 55 , p. 16 ; 53, p. 1 ). Bedrock in the central portion of the county is comprised primarily of metagraywacke, schistose metagraywacke and schist with minor mafic and ultramafic rocks (Ref. 53, p. 1) . Metamorphosed Paleozoi c granitic bodies underlie the far southeastern portion of the county and Mesoproterozoic meta

- igneous units comprise the northwest portion (Ref s

. 53 , p. 1; 56 , p. 1). The rocks in the Asheville area are typically gneissic metagraywacke, schistose metagra ywacke and schist, with lesser amphibolite, ultramafics and migmatite (Ref s

. 53 , pp. 1

- 2; 56 ). The Brevard fault zone

, southeast of Asheville, separates the metasedimentary units from the granitic units and contains dolomitic marble and low metamorphic gr ade clastic metasediments (Ref s

. 53 , p. 2;

56 ).

Site Specific Geology

The geology in the CTS area is within the Ashe Metamorphic Suite

- Tallulah Falls Formation (Ref. 53 , p. 5; 57 , p. 3 ). Lithologies consist of metagraywacke, schistose metagraywacke, ( garnet) mica schist, amphibolite, quartz and quartz

tourmaline veins, and lesser zones of fault breccia and gouge (Ref s

. 53 , p. 5; 57 , p. 3). These major rock types are consistent with those identified in previous 1:24,000

- scale geologic mapping of the O tee n (Cattanach and Merschat, 2008), Asheville (Miller and Fryer, 2008), Skyland (Dabbagh and McDaniel, 1981), and Fruitland (Lemmon and Dunn, 1973) 7. 5

- minute quadrangles that meet in the study area (Ref s

. 53 , p. 5; 57 , p. 4 ).

In 2010, the North Carolina Geological Survey (NCGS) mapped the geology of an approximate 4 square mile ( mi 2 ) area around Mills Gap in Buncombe County, North Carolina (Ref. 57 , p. 2 ). The purpose of the mapping was to develop a working geologic framework to aid in the geologic and hydrogeologic assessment of CTS of Asheville (Ref. 57 , p. 2 ).

L ithologic contacts and structural features are identified in the geologic map of the area developed by NCGS (Ref s

. 53 , p. 2 ; 57 , p. 1 3 ).

The NCGS defined t hree map units in the area based on the relative percentages of lithologies in outcrop: metagraywacke, amphibolite, and schistose metagraywacke (Ref s

. 53 , p. 5; 57 , p. 4 ). T hese lithologic units have undergone structural deformation that results in compositional layering, foliation, fold s, ductile and brittle faults and

shears , plus joints and fractures throughout the mapped area (Ref. 53 , p. 5)

. Bedrock foliation and compositional layering strike principally to the NNE and NE, and to a lesser extent, to the NNW, except in the vicinity o f the Mills Gap

fault zone ( MGFZ ) (Ref. 57, p. 5 )

. Overall, bedrock foliation generally dips toward the SE except where locally deformed by folding, and where realigned in proximity to the MGFZ (Ref. 57, p. 5 ). Two map

- scale structural featuresGround Water Migration Pathway Description

32 were iden tified in the project area: 1 ) Protomylonite, mylonite and phyllonite fabrics representing a N

- to NNE

- striking zone of high strain and ductile shearing are well

- exposed in a tributary to Robinson Creek ; and, 2) A younger WNW

- ESE striking zone of brittle faulting informally designated the MGFZ (Ref. 57, p. 9 )

. The crystalline bedrock of the map area was observed by the NCGS to be covered by a mantle of regolith consisting of transported colluvial and alluvial deposits,

and residual soil formed from the in

- place weathering of bedrock (Ref. 57, p. 4 )

.

Site Aquifer Description

– Bedrock Aquifer System

R egolith and fractured bedrock components comprise o ne aquifer system beneath the study area (Ref s

. 53 , p. 8; 59 ). Recharge to the aquifer system occurs thro ugh infiltration of precipitation at the land surface (Ref. 53, p.7). The infiltrating water collects in the regolith component and recharges the underlying fractured bedrock component (Ref. 53, p. 7). The fractured bedrock component has low angle folia tion

- parallel parting fractures, and high angle fracture planes (joints) which have been observed and documented in the CTS site area both by the NCGS surface geologic mapping and by the United States Geological Survey (USGS) subsurface borehole geophysic al mapping and data collection (Ref s

. 53

, p. 8; 57 ; 59; 78 ). High

- angle fractures allow water to seep into the rock, serving as recharge conduits (Ref s

. 53 , p. 8; 59 ). Discharge may occur along high

- angle fractures near streams or other discharge boundar ies (Ref s

. 53 , p. 8; 59 ). Low

angle foliation

- parallel partings connect high

- angle recharging fractures (Ref s

. 53 , p. 8; 59 ). Pumping of the private

wells will alter the natural flow conditions in the area (Ref s

. 53 , p. 8; 59 ).

Aquifer Components

Groun d water can be obtained from two components within the one continuous aquifer system underlying the study area (Ref. 53, p. 8 ). These two components are termed the regolith and fractured bedrock (Ref. 53, p. 8 ). Because the porosity of the regolith is muc h greater than that of the bedrock, the regolith has the capacity to store a much larger volume of water (Ref. 53 ). The interconnection between the regolith and the bedrock within the Blue Ridge geologic setting is as

follows : 1) the regolith functions as a reservoir which slowly feeds water downward into the fractures in the bedrock ; and 2) t he fractures serve as an intricate interconnected network of pipelines that transmit water either to springs or streams or

to wells ( Ref s

. 53 , p. 8; 60 ).

Regolith Co mponent

The regolith component of the bedrock aquifer system in the CTS area consists of transported colluvial and alluvial deposits and residual soil formed from the in

- place weathering of bedrock (Ref s

. 53 , p. 8; 57 , p. 4 ). In general,

accumulations of unconsolidated colluvium and alluvium, and deeply weathered bedrock are thicker in the drainages and toes of slopes than on adjacent steeper areas upslope (Ref s

. 53 , p. 8; 57 , p

. 4 ). The zone of overburden (i.e., regolith)

determined from boreholes at th e CTS facility ranges in thickness from 28 to 81 feet below ground surface (Ref s

. 53 , p. 8; 57 , p. 4 ; 8, p. 23 ). Structural fabrics (e.g., discontinuities inherited from the parent, unweathered bedrock are preserved in most regolith exposures of the weath ered bedrock component (Ref s

. 53 , p. 9; 57 , p. 4 ; 8 ). Throughout this “Ground Water Migration Pathway” section of the HRS documentation record , discontinuity means joints, foliations, and lithologic contacts that provide hydraulic connection

. Discontinui ty in this regard is not a hydraulic barrier as described in the HRS definition. Indeed these geologic discontinuities provide a pathway for ground water migration (Refs. 1,

S ection 3.0.1.2.2; 53, p. 8; 57)

. The weathered bedrock zone of the regolith exhi bits enhanced weathering, mineral dissolution and secondary mineral precipitation along bedrock discontinuities including foliation, compositional layering, joints (fractures), and faults (Ref s

. 53 , p. 9; 57 , p. 4 ). Enhanced bedrock weathering, particularl y along faults and joints, is observed in association with the MGFZ (Ref s

. 53 , p. 9; 57 , p. 4 ).

Bedrock Component

The rocks within the bedrock component are a metamorphosed and deformed package of sediments interlayered with

minor mafic intrusives and vo lcanics (Ref s

. 53 , p. 9; 57 , p. 3 ). Lithologies consist of metagraywacke, schistose metagraywacke, (garnet) mica schist, amphibolite, quartz and quartz

- tourmaline veins, and lesser zones of fault breccia and gouge (Ref s

. 53 , p. 9; 57 , p

. 3). Three map u nits were defined in the study area based on the relative percentages of lithologies in outcrop: 1) metagraywacke with lesser schistose metagraywacke, schist and amphibolite; 2) schistose metagraywacke and schist with lesser metagraywacke and amphibolite; 3) amphibolite (Ref s

. 53 , p. 9; 57 , p. 4 ). TheGround Water Migration Pathway Description

33 bedrock fractures that serve as an interconnected network of pipelines to transmit water within the bedrock are described

below in the next section.

Bedrock Discontinuities and Related Structures

This se ction presents the structural features that act as pathways for ground water flow (Ref. 53 , p. 9). These features have resulted from tectonic activity in the area that metamorphosed and deformed the rock by folding, faulting and fracturing (Ref. 53 , p. 9) . Subsequent weathering at land surface and associated unloading at depth may have enhanced the opening of these discontinuities (Ref s

. 53 , p. 9; 57 ). These secondary features control ground water flowpaths that

both run parallel to cross

- cut rock fabric (foliation), compositional layering, and map unit contacts (Ref s

. 53 , p. 9; 78, pp. 17, 19 ).

Secondary features documented in bedrock within t he MGFZ provide p otential flow paths parallel to that zone’s W/NW

E/SE trend (Ref. 53, pp. 8

, 9). Outside t he MG FZ , secondary features documented in bedrock throughout the mapped areas provide p otential flow paths that are parallel a) to the regional strike of geologic map units, b) to the general strike

of b edrock foliation

, compositional layering and mylonitic fol iation, and c) to the strike of quartz

- tourmaline veins , all of

which share a N/NE

- S/SW strike (Ref s

. 53 , p. 9; 78, pp. 1, 10 ). The se two general groups of features in the Mills Gap Road area have developed and provide ground water flow pathways from the CTS plant property to ward the E /SE and

to ward the N/NE for considerable distances (Ref s

. 53 , p. 9 )

.

Planar bedrock discontinuities identified in the study area consist of foliation, mylonitic foliation, veins, joints (fractur es), and faults (Ref s

. 53 , p . 10; 57 , p. 4 ). These bedrock discontinuities can be grouped into two main categories, ductile features or brittle features (Ref s

. 53 , p. 10; 57 , p. 4 ). Ductile features, such as foliations, mylonitic foliations and mineral elongation lineations, form w hen the rock is in a plastic state during metamorphism (Ref s

. 53 , p. 10; 57 , p. 4 ). Brittle features, such as joints (fractures), fault breccia, gouge and slickenlines, form in lower temperature environments where the rock breaks in response to stresses i n the crust (Ref s

. 53 , p. 10; 57 , p. 4 ). Quartz and quartz

- tourmaline veins show evidence of both ductile and brittle deformation (Ref s

. 53 , p. 10; 57 , p. 4 ).

Foliation. The dominant planar bedrock discontinuity identified is a foliation produced an d modified during one or more stages of regional, sillimanite

- grade metamorphism (Ref s

. 53 , p. 11; 57 , p

. 5 ). Migmatization also occurred during metamorphism resulting in alternating bands of light

- and dark

- colored minerals imparting a gneissic texture t o the rock in many exposures (Ref s

. 53 , p. 11; 57 , p. 5 ). Younger foliations developed as lower temperature, axial planar fabrics, and as high shear strain planar fabrics associated with zones of mylonite and phyllonite (Ref s

. 53 , p. 11; 57 , p. 5 ).

B edrock foliation and compositional layering strike principally to the NNE and NE, and to a lesser extent, to the NNW, except in the vicinity of the MGFZ (Ref s

. 53 , p. 11; 57 , p. 5 ). Mapping and a stereonet analysis of foliations, of compositional layering , and of a younger mylonitic foliation all indicate these fabrics are realigned from a regional NE

SW strike trend to that of a WNW trend in those areas that are near the MGFZ (Ref s

. 53 , p. 11; 57 , p. 5 ).

Mylonitic foliations outside of the MGFZ are pre valent and penetrative , and like foliations and compositional layering, predominantly strike in the N

- NE direction (Ref s

. 53 , p. 11; 57 , p. 5 ). These c losely spaced, low to moderately SE

dipping mylonitic foliations realign and displace a pre

- existing fol iation (Ref s

. 53 , pp. 6

- 7, 11; 57 , p. 5 ).

Veins. Quartz and quartz

- tourmaline veins with thicknesses ranging from inches to a few feet have been identified in several locations north, east, and south of the CTS facility area (Ref s

. 53 , p. 11; 57 , p. 6 ) . Most of these veins strike N

NE, dip moderately to steeply to the NW or SE, and for the most part, occupy bedrock discontinuities that crosscut earlier foliations (Ref s

. 53 ; p. 11; 57 , p. 6 ). This is significant as evidence of the hydraulic connection between rock units (Ref s

. 53 , p. 11; 57 , p. 6 ). Many of these veins show evidence of ductile deformation (folding and mineral elongation), and younger brittle deformation (slickenlines and brecciation) (Ref s

. 53 , p. 11; 57 , p. 6 ). The predominantly N

- NE strike of these quartz veins suggests they were emplaced in fracture and/or fault zones prior to, or concurrent with early stages of brittle deformation (Ref s

. 53 , pp. 11

- 12; 57 , p. 6 ). These veins are intersected and presumably offset by the fractures an d faults associated with the MGFZ (Ref s

. 53 , p. 12; 57 , p. 6 ).

Faults. Faults of different orientations occur in the study area, but can be divided into two groups (Ref s

. 53 , p. 12; 57 , p.Ground Water Migration Pathway Description

34 6 ). Contractional thrust faults that strike N

- NW to N

- NE (Ref s

. 53 , p. 12; 57 , p. 6 ). Strike

- slip and oblique

- normal faults that strike WNW and ENE, and represent conjugate transtensional and extensional faults associated with movement along the MGFZ (Ref s

. 53 ; p. 12; 57 , p. 6 ).

Mills Gap Fault Zone. The WNW

- tre nding Mills Gap fault zone (MGFZ) occupies a linear topographic low of the same general trend (azimuth 115

- 295 **°** ) as the outcrop

- scale brittle structures in the Mills Gap area, and it is aligned with numerous local and regional lineaments (Ref s

. 53 , p. 12; 57 , p. 6 ). In most outcrops the MGFZ appears as deeply weathered and oxidized saprolite (completely

- to

- partly decomposed rock) containing clast

- supported and clast

- in

- matrix breccia fabrics (Ref s

. 53 , p. 12; 57 , p. 6 ). Outcrops of strike slip and oblique normal faults with slickenlines, breccias and gouge and associated drag folding were used to constrain the delineation of the MGFZ (Ref s

. 53 , p. 12; 57 , p. 6 ).

The MGFZ can be traced for at least 5,500 feet west of the CTS property (Ref s

. 53 , pp. 3, 12 ; 57 , p. 5). Direct evidence for the eastward extent of the MGFZ is limited to a fault and found approximately 550 feet (0.25 km) east of the CTS property (Ref s

. 53 , p. 12; 57 , p. 6 ). East of Robinson Creek, short segments of linear topographic lows are present for a distance of at least 5,300 feet (Ref s

. 53 , p. 12; 57 , p. 6). The trends of these short lineaments appear to change from WNW orientations to those of an ENE orientation (Ref s

. 53 , p. 12; 57 , p p . 6 , 7 ).

Although the MGFZ has not been traced t o the ESE beyond the vicinity of Robinson Creek, joints associated with it occur beyond the mapped extent of the fault zone (Ref s

. 53 , p. 13; 57 , p. 7 ). Joints that have similar orientations to the MGFZ [azimuth 115

- 295o (+15o)], and the conjugate set [az imuth 85

- 265o (+15o)] occur beyond the mapped extent of the MGFZ (Ref s

. 53 , p. 13; 57 , p. 7).

Joints measured in surface outcrops

. The population of joint s measured in surface outcrop by the NCGS is divided into six sets based on orientations (Ref s

. 53 , p. 13; 57 , p. 8 ). The sets are defined as 15o on either side of the principal azimuthal strike direction and its 180o counterpart (Ref s

. 53 , p. 13; 57 , p. 8 ).

These sets can be grouped into the following three broad, overlapping categories:

Group 1 Joints

Azimuth 115

- 295o (±15o)

– Joints related to the primary WNW

- ESE trend of the MGFZ and associated outcrop

scale faults, n=80 (Ref s

. 53 , p. 13; 57 , p. 8 ).

Azimuth 85

- 265o (±15o)

– Joints related to the ENE

- WSW trend of conjugate joints and outcrop

- scale faults associated with the MGFZ, n=51 (Ref s

. 53 , p. 14; 57 , p. 8 ).

Group 2 Joints

Azimuth 25

- 205o (±15o), n=41; and, azimuth 55

- 235o (±15o), n=30

– Joints that strike sub

- parallel to the predominant NE

- SW direction of bedrock layering and foliation strike, N

- NE striking outcrop

- scale faults, and N

NE striking quartz and quartz

- tourmaline veins (Ref s

. 53 , p. 14; 57 , p. 8 ).

Group 3 Joints

Azimuth 145

- 325o (±15o)

– Regional set of NW

- SE

- striking joints, that likely includes some joints associated wit h the MGFZ, n=37 (Ref s

. 53 , p. 14; 57 , p. 8 ).

Azimuth 175

- 355o (±15o)

– Regional sets of N

- S

- striking joints that likely include some joints that strike sub

- parallel to the predominant N E

- S W

- striking bedrock layering and foliation, n=22 (Ref s

. 53 , p. 14; 57 , p. 8 ).

For data collected from surface outcrops, t he greatest frequencies of joints in all sets have high dip angles in the range of

61

- 90o (Ref s

. 53 , p. 14; 57 , p. 8 ). An intermediate number of all joint groups have moderate dip angles that range f rom 31

- 60o, followed by the fewest number of joints with shallow dip angles less than 30o (Ref s

. 53 , p. 14; 57 , p. 8 ).

Brittle features tabulated for outcrops throughout the entire NCGS study area are dominated by WNW and ESE trending

features. NCGS geol ogists visited a relatively larger number of outcrops located within the MGFZ than they did outcrops located outside the MGFZ ( Refs 53, p p

. 14

, 15; 78, p. 4). A s a result

, it is useful to consider the statistics for brittleGround Water Migration Pathway Description

35 outcrop data in separate sets, one set for those data collected from the MGFZ, and another for those collected outside the MGFZ (Ref. 78, p. 4). Viewed this way, NW/SE

- striking Group 1 Joints are shown to be more predominant in those

areas within the MGFZ than bulk data would indicate. Likewise, for data from outcrops located outside the MGFZ,

N/NE

- striking Group 2 Joints are relatively more prevalent than the bulk outcrop data would indicate (Ref. 53, p.15).

Joints , foliation, and lithologic contacts measured in downhole surveys

. The population of more than 8,700 structures (j oints, foliation, and lithologic contacts ) measured in the ei ght wells logged by the USGS, along with available

fracture orientations from four CTS of Asheville wells , documents a dominant orientation of subsu rface structures that

trends to the N/NE , striking from 0 o to 30 o , parallel to the N/NE strike of geologic features in the area. This dominance is clearly indicated in Figure 5 of the USGS report (Ref. 78, pp. 8, 18)

. This dominant N/NE strike orientatio n is shared by the set of surface outcrop features described above as Group 2 Joints (Ref. 57, p. 8 ).

A majority of the structures measured in the downhole surveys are parallel to foliation and compositional layering, have predominantly N/NE

- trending str ikes, have shallow dips, and dominate the statistics whereas surface outcrops mapped by

the NCGS provide a relatively better sample of more steeply dipping features. With the exception of the rare steep cliff face or high road cut, outcrops provide relati vely less opportunity to count and measure flat

- lying features (Refs. 53, pp.

14

- 17; 78, p. 4; 57, pp. 20, 21 ). For example, a subset of these shallow

- dipping fractures, foliations and bedding planes is known to represent open fractures (Ref

. 78, p. 10). Also, vertical boreholes tap shallow

- dipping features much more frequently than they tap steeply dipping features (Ref. 7 8, p. 4 ) . Recognizing both of the observations above, the USGS categorized a total of 272 steeply dipping fractures delineated from the wells into the same surface joint groups defined by the NCGS for surface outcrop data

. From the eight wells logged by the USGS, the dominant strike azimuth for steeply dipping fracture s measured in the wells fall within the 25 o & 205 o category

, which parallels N/NE regional foliation as described by the NCGS (2010) (Ref s . 57, p. 8 ; 78, p. 18 ). From this same set of 272 steeply

- dipping fractures, secondary joint groups delineated in the wells were a) 175 o & 355 o , also parallel to regional foliation str ike, and b) 115 o & 295 o

, parallel to the Mills Gap Fault Zone orientation as described by the NCGS (2010) ( Ref s . 57, p. 8 ; 78, p. 10 )

.

Hydraulic Connection to Distant Receptors

A fractu re system exists in bedrock at the site that allows the hydraulic connection of distant drinking water wells and allows distant (0.673 miles) contaminant transport from the CTS facility (Refs. 53, pp. 17

- 18; 78, pp. 23, 24). Evidence for hydraulic connection between the CTS facility and ground water located toward the E/SE was found in highly contaminated ground water on an adjacent property at depths of up to 187.5 feet (35,000 ppb TCE) and in the high concentrations in a well located 1,260 feet to the E/SE of the CTS facility (1,000 ppb TCE (Well 1) (Ref. 53, p. 14). Evidence for hydraulic connection between the CTS facility and ground water located toward the N/NE was found as TCE (found at depths up to 698 feet) (Refs. 53, pp. 17 , 1 8; 83, p. 17) detected in private supply wells in the Oaks Subdivision, located 0.673 miles to the northeast, and found in a private supply well on Chapel Hill Church Road (CHR) (Ref. 53, p. 14).

In August 2009, the CHR well was taken offline and the TCE concentrations decreased rapidly (Ref s

. 53 , p. 14 ; 83, p.

17 ). The TCE concentration was 1,400 ppb TCE in August, 2009, then decreased to 430 ppb TCE in October, 2009, and

was 74 ppb during the last sampling event in June, 2010 ( Ref. 53 , p. 14 ). Once t he pumping of the CHR well ceased in August, 2009, higher concentrations of contaminant s were no longer being pulled into the well (Ref. 53 , p. 14). During the packer testing of the interval at 480 feet in March, 2010, the concentration maximum was 19 ppb TCE (Ref. 53 , p. 14). The fracture providing water to the CHR well is large and the well production is around 60 gallons per minute (Ref.

53 , p. 14). The varying concentrations of TCE detected in the CHR well through these events are consistent with a TCE source that is distant from the well itself, and that traveled to the well via deep fractures in bedrock (Ref. 53, p. 17)

.

Wells within the Oaks subdivision show a pattern of increasing TCE concentration with depth, with the deepest packer

intervals tested contain ing the highest concentrations ( Ref. 53 , pp. 14

, 15). The TCE contaminant distribution in the Oaks Wells increases with depth ( Ref. 53 , p. 15). This indicates a component of deep flow of TCE

- contaminated ground

water into the Oaks wells. Two wells, a n artesian well, Well 1

, and AW

- 4, have a vertical flow direction that is up w ard. In these two wells, TCE c ontamination is found in both shallow and deep packer intervals

, consistent with upward flow transporting deep contamination into the shallow zone ( Refs. 53 , pp. 1 7

- 23 ; 78

, pp. 26

- 34)

. O rientations of bedrock joints, foliati ons and lithologic contacts and of water

- producing fractures not only provide for hydraulic connectionGround Water Migration Pathway Description

36 between the CTS property and the Oaks Subdivision, but also provide a hydraulic connection between the Oaks wells ( Ref. 53 , p. 17

- 23 ). Cross sections sh ow subsurface features encountered in the individual wells, plus geologic

discontinuities (joints, foliations and lithologic contacts) projected onto the cross sections from nearby surface exposures

. The cross sections do not represent all types and orient ations of discontinuities (joints, foliations and lithologic contacts) present ( Ref. 53 , p p . 16

- 17). The wells in the Oaks Subdivision are low yielding wells with low flow/low stress sampling flow rates that ranged from 0.5 to 0.04 gallons per minute (Ref

. 53 , p. 14). The pattern of TCE concentrations detected in various packer intervals in wells in the Oaks Subdivision is consistent with a TCE source that is distant from the wells themselves, and that traveled to the wells via deep fractures in bedrock ( Refs. 53, p. 22; 83, p. 17).

In the area of the CTS p roperty, Well 11B and Well 1, a secondary set of W/NW

- E/SE striking structural features associated with the MGFZ, are present that could facilitate transport in that direction (Ref. 53 , p. 22)

.

Numer ous N/NE striking joints and foliation parting fractures together form a pathway of interconnected features for contaminated ground water

, documented to occur in bedrock fractures beneath and near the CTS property, to flow toward

wells located on Chapel Hi ll Church Road and in the Oaks subdivision (Ref s

. 53 , p p . 4, 17

- 23 ; 78, pp. 23, 24)

.

Within the Oaks Subdivision

, the subsurface borehole geophysics have determined that all water bearing features are low

angle foliation parallel. These water bearing f eatures provide for interconnection between the Oaks Subdivision wells. (Ref s . 53, p. 23 ; 7 8 , p. 4 ).

SUMMARY OF AQUIFER(S) BEING EVALUATED

Aquifer

No. A quifer Name Is Aquifer Interconnected with Upper Aquifer within 2 miles? (Y/N/NA) Is Aquife r Continuous within 4

-

mile TDL? (Y/N) Is Aquifer Karst? (Y/N)

1 Regolith/Fractured Bedrock NA Y NGround Water Migration Pathway

– Likelihood of Release

37 3.1 LIKELIHOOD OF RELEASE

3.1.1 OBSERVED RELEASE

Aquifer Being Evaluated: Regolith/Fractured Bedrock

Direct Observation

An observed release by direct observation has not been documented.

Chemical Analysis The ground water samples listed below are from sampling events conducted by EPA (REAC), NCDENR, and/or Oneida Total Integrated Enterprises ( OTIE ) (formerly TN&A) from 1999 through 2009 (Refs . 28, pp. 1

- 21; 31, pp. 1

- 36; 39, pp.

1

- 457; 40, pp. 1

- 18; 43, pp. 1

- 44; 44, pp. 1

- 699; 49, pp. 1

- 947). Monitoring wells at or near CTS and target areas were sampled in many cases to determine the presence or absence of contamination, and determine ground water flow

direction. Many of the sampling events consisted of sampling of a single monitoring well , and in all cases, a n event

specific background well was not designated

. All p rivate well samples were collected within a 1

- mile radial distance

from the source (Ref. 3). Like monitoring wells, b ackground private well samples were not designated during the sampling investigations.

TCE is a non

- ubiquitous man

- made substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref. 10, p. 1 ). The absence of TCE concentrations (non

- detect) in the samples below show that TCE is a locally non

- ubiquitous substance apart from the ground water

contamination being scored (see Fi gure 4)

. Therefore , release samples were compared to a background level of zero.

As indicated by multiple sampling investigations, numerous ground water samples collected from the CTS area indicate

no evidence of TCE (or breakdown products) contamination (Refs. 28, pp. 1

- 21; 31, pp. 1

- 36; 39, pp. 1

- 457; 40, pp. 1

- 18; 43, pp. 1

- 44; 44, pp. 1

- 699; 49, pp. 1

- 947)

. Cis

- 1,2

- DCE and trans

- 1,2

- DCE are degradation products of TCE (Ref. 61, p. 4).

All samples collected during the ground water sampling events were analyzed for VOCs using contract laboratory program ( CLP ) , NC Division of Water Quality, or SESD laboratories (Refs. 28 , p. 4

- 5; 25 , pp. 3

- 18; 31 , p. 19 ; 39 , p. 384 ; 40 , p. 1 ; 43 , p . 1 ; 44 , p . 1 ; 49 , pp. 1, 3 ; 51 , p. 16 ). Samples were collected in a ccordance with the REAC Quality Assurance Project Plan (QAPP), NCDENR Standard Operating Procedures (SOPs), or EPA Environmental Investigations Standard Operating Procedures Quality Assurance Manual ( EISOPQAM ) and later the SESD Field Branches Quality Syst em and Technical Procedures (FBQSTP) , respectively (Refs. 39 , p. 4; 62 , pp. 1

- 63 ). QA/QC information is provided in References 28

, 25

, 31

, 43

, 44

, 51

, and 49

.

Sample locations are identified in Figure s 3 and 4.

Sample ID Date
Collected Hazardous
S ubstance Concentration (μg/L) TQL, RL
, QL, MDL, MRL (μg/L) References

9G1465 7/30/1999 TCE 0.25 U 0.25 28 , pp. 6, 7

9G1466 7/30/1999 TCE 0.25 U 0.25 28 , pp. 8, 9

PW1 5/23/2000 Cis

- 1,2

- DCE 1 U 1 31 , pp. 1, 21

TCE 1 U 1 31 , pp. 1, 21

PW2 5/23/2000 Ci s

- 1,2

- DCE 1 UJ 1 31 , pp. 3, 22

TCE 1 UJ 1 31 , pp. 3, 22

CTS

- 016

- PW 11/27/2007 Cis

- 1,2

- DCE BQL 1.0 39 , pp. 42, 82, 83, 280

TCE BQL 1.0 39 , pp. 42, 82, 83, 280Ground Water Migration Pathway

– Likelihood of Release

38 Sample ID Date

Collected Hazardous
S ubstance Concentration (μg/L) TQL, RL
, QL, MDL, MRL (μg/L) References

CTS

- 018

- PW 11/27/2007 Cis

- 1,2

- DCE BQL 1.0 39 , pp. 41, 84, 85, 280

TCE BQL 1.0 39 , pp. 4 1, 84, 85, 280

CTS

- 030

- PW 11/27/2007 Cis

- 1,2

- DCE BQL 1.0 39 , pp. 47, 104, 105, 279

TCE BQL 1.0 39 , pp. 47, 104, 105, 279

CTS

- 031

- PW 11/27/2007 Cis

- 1,2

- DCE BQL 1.0 39 , pp. 47, 106, 107, 279

TCE BQL 1.0 39 , pp. 47, 106, 107, 279

CTS

- 075

- PW 11/28/20 07 Cis

- 1,2

- DCE BQL 1.0 39 , pp. 48, 180, 181, 284

TCE BQL 1.0 39 , pp. 48, 180, 181, 284

MG

- PW

- 01 06/26/2008 TCE 0.20U 0.20 43 , pp. 7, 34, 38

MG

- PW

- 05 06/26/2008 TCE 0.20U 0.20 43 , pp. 12, 34, 39

MG

- PW

- 06 06/26/2008 TCE 0.20U 0.20 43 , pp. 13, 34, 40

M G

- SSI

- 01 9/15/2008 Cis

- 1,2

- DCE 0.50U 0.50 44 , pp. 321, 322, 661, 683

TCE 0.50U 0.50 44 , pp. 321, 322, 661, 683

MG

- SSI

- 02 9/16/2008 Cis

- 1,2

- DCE 0.50U 0.50 44 , pp. 323, 324, 661, 683

TCE 0.50U 0.50 44 , pp. 323, 324, 661, 683

MG

- SSI

- 03 9/16/2008 Cis

- 1 ,2

- DCE 0.50U 0.50 44 , pp. 325, 326, 661, 683

TCE 0.50U 0.50 44 , pp. 325, 326, 661, 683

MG

- SSI

- 04 9/16/2008 Cis

- 1,2

- DCE 0.50U 0.50 44 , pp. 327, 328, 661, 684

TCE 0.50U 0.50 44 , pp. 327, 328, 661, 684

MG

- GMP4

- 23 10/29/2009 Cis

- 1,2

- DCE 0.50U 0.50 49

, pp. 57, 711, 923

TCE 0.50U 0.50 49 , pp. 57, 711, 923

MG

- GMP4

- 61 10/27/2009 Cis

- 1,2

- DCE 0.50U 0.50 49 , pp. 66, 71 2, 930

TCE 0.50U 0.50 49 , pp. 66, 713, 930

Notes: μg/L

- Micrograms per l iter

DCE

- Dichloroeth ene/dichloroeth ylene

GMP 4

- Ground Water Monitoring Program 4 th Quarter

J

- Estimated value

MG

- Mills Gap

MDL

- Method Detection Limit

MRL

- Minimum Reporting Limit

PW

- Potable well QL

- Quantitation Limit

RL

- Reporti ng Limit

SSI

- Special Studies Investigation

TCE

- Trichloroethylene/trichloroethylene TQL

- Target Quantita t ion Limit

U

- Constituent analyzed for but not detected

Monitoring Well Samples The investigation s below detail ground water samples collected from monitoring well s near CTS with elevated levels of TCE and/or its breakdown products

.

- 200 4 Site Investigation (MACTEC)

In June 2004

, MACTEC collected a ground water sample from a temporary monitoring w ell installed by MACTEC (Ref.

7 , p. 7). Lab analysis and data validation procedures were completed to achieve Level 4 data quality objectives (DQO) for water (Ref. 7 , p. 7). The sample was submitted to Shealy Environmental Services, Inc.

, for TCL VOCs an alysis by

EPA Method 8260B (Ref. 7 , p. 275). QA/QC information is provided in Reference 7

. TCE is a non

- ubiquitous man

made substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during ma nufacture or use (Ref. 10 , p. 1 ). Additionally, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated

. S ee FigureGround Water Migration Pathway

– Likelihood of Release

39 3 of this Documentation Record for sample locations.

Sample

ID Total Depth (feet bgs ) Depth to Water (feet bgs ) Sample Location Date Sampled References

TW

- 1 13.75 4.75 Adjacent to, and upgradient of, Spring

02 6/23/2004 7 , p p

. 22, 43, 51, 80 , 275, 286

Notes: bgs

- Below ground surfa ce ID

- Identification

TW

- Temporary well μg/L

- Micrograms per liter

Sample ID Hazardous Substance Concentration ( μg/L ) PQL ( μg/L ) References

TW

- 1 TCE 2,500 500 7 , p p . 80 , 275, 286

Notes:

ID

- Identification PQL

- Practical Quantitation Limit

TCE

- Trichloroethene/trichloroethylene

T W

- Temporary well μg/L

- Micrograms per liter

- 2008 Potable Well, Subsurface Soil
, and Ground Water Sampling ( TN&A )

In December 2007, TN&A collected ground water sam ples from monitoring wells located near the CTS property (Ref.

39 , pp. 6

- 8). Sampling activities were performed in accordance with the EPA SESD Region 4 EISOPQAM (Ref. 39 , p. 4). Samples were submitted to SGS Environmental Services, Inc.

, for TCL VOCs an alysis by EPA Method 8260B (Ref.

39 , p. 384). QA/QC information is provided in Reference 39

. TCE is a non

- ubiquitous man

- made substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref. 10 , p. 1 ). Cis

- 1,2

- DCE and vinyl chloride are degradation product s of TCE (Ref. 61 , p. 4). Additionally, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated

. S ee Figure 3 of this Documentation Record for sample

locations.

Sample ID Total Depth (feet bgs) Depth to Water (feet bgs ) - Location Date Sampled References

CTS

- 001

- MW 11.65 5 East of CTS facility 12/11/2007 39 , pp . 14, 18, 384, 451 , 455

MGGC

- GW

- 01 35.00 23.59 North of the CTS building; On CTS property 12/13/2007 42 , pp. 22, 27, 29, 57, 271, 272

, 428

MGGC

- GW

- 03 9.80 1.50 East of main CTS building 12/14/2007 42 , pp. 22, 27, 29, 59, 60, 257, 258, 426

Notes: bgs

- Below ground surface

ID

- Identification

GW

- Ground water

M W

- Monitoring wellGround Water Migration Pathway

– Likelihood of Release

40 Sample ID Hazardous Substance Concentration ( μg/L ) QL ( μg/L ) References

CTS

- 001

- MW TCE 4,800 400* 39 , pp. 14, 384, 451

MGGC

- GW

- 01 TCE 1,5 00 100 42 , pp. 22, 27, 29, 57, 272, 428

Cis

- 1,2

- DCE 130 25 42 , pp. 22, 27, 29, 57, 272, 428 Vinyl Chloride 48 25 42 , pp. 22, 27, 29, 57, 272, 428

MGGC

- GW

- 03 TCE 22 5 42 , pp. 22, 27, 29, 59, 60, 258, 426

Notes:

*

- Quantitation Limit

DCE

- Dichloroethene /dichloroethylene

GW

- Ground water

ID

- Identification

MRL

- Method Reporting Limit

MW

- Monitoring well QL

- Quantitation Limit

TCE

- Trichloroethene ( trichloroethyl ene) μg/ L

- Micrograms per liter

- January 2008 Temporary Monitoring Well Sampling (TN&A and ERT) In January 2008, TN&A , with the assistance of ERT, collected ground water samples from temporary monitoring wells installed by ER T at the CTS property (Ref. 42 , p. 11). Sampling activities were performed in accordance with the EPA SESD Region 4 EISOPQAM (Ref. 42 , p. 5). Samples were submitted to the SESD Regional Laboratory for TCL VOCs analysis by EPA Method 8260B (Ref. 42 , p p . 2 7, 74, 198

- 199, 438). QA/QC information is provided in Reference 42

. TCE is a non

- ubiquitous man

- made substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TC E (Ref. 61 , p. 4). Additionally, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being evaluate d

. See Figure 3 of

this Documentation Record for sample locations.

Sample ID Total De pth (f

eet bgs ) Depth to Water (feet bgs ) Sample Location Date Sampled References

MGGC

- GW

- 17 21.50 7.32 East of main CTS building 01/16/2008 42 , pp. 22, 27, 29, 74 , 197

- 199,

438

Notes: Bgs

- Below ground surface

ID

- Identification

Sample ID Hazardous Substance Concentration ( μg/L ) MRL ( μg/L ) References

MGGC

- GW

- 17 TCE 13 0.5 42 , pp. 27, 74, 199, 438

Cis

- 1,2

- DCE 0.85 0.5 42 , pp. 27, 74, 198, 438

Notes:

DCE

- Dichloroethene/dichloroethylene

GW

- Ground water

MRL

- Minimum Reporting Limit

TCE

- Trichloroethene/trichloroethylene μg/L

- Micrograms per literGround Water Migration Pathway

– Likelihood of Release

41 - 2009 Phase I Remedial Investigation (MACTEC) As part o f the Phase I RI, MACTEC collected ground water samples from monitoring wells periodically from August 2008 through July 2009 at the CTS property (Ref. 8 , p. 9 ). The monitoring wells were purged using low

- flow purging techniques, in accordance with the EP A guidance, Low

- Flow Groundwater Sampling Procedures (Ref. 8 , p. 15). During the first two phases, samples were analyzed for VOCs, SVOCs, HSL metals, and cyanide (Ref. 8 , pp. 9, 10). Samples were analyzed for VOCs in the third phase (Ref. 8 , p. 10). MAC TEC conducted a Level II Data Quality Evaluation of the laboratory data (Ref. 8 , p. 17). Samples collected during the event were submitted to Prism Laboratories, Inc. (Ref. 8

, p. 16). QA/QC information is provided in Reference 8

. TCE is a non

- ubiquitous manmade substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TC E (Ref. 61 , p. 4). Additiona lly, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated

. Se e Figure 3 of this Documentation Record for sample locations.

- October 2008

Sample ID Total Depth (feet bgs ) Depth to

Water (feet bgs ) Sample Location Date Sampled References

MW

- 4 24.8 24.19 Approximately 100

feet north of CTS building 10/09/2008 8 , pp. 50, 53, 73, 200, 201,

222

MW

- 5 26.7 20.44 Approximately 250

feet north of CTS

bu ilding 10/10/2008 8 , pp. 50, 53, 73, 207, 208,

222

Notes: bgs

- Below ground surface

ID

- Identification

Sample ID Hazardous
Substance Concentration ( μ g/L) MDL ( μg/L ) References

MW

- 4 Cis

- 1,2

- DCE 100 0.12 8 , pp. 73, 200, 222

PCE 2.2 0.17 8 , pp. 73, 201, 222

TCE 250 1.9 8 , pp. 73, 201, 222

MW

- 5 Cis

- 1,2

- DCE 12 1.2 8 , pp. 73, 207, 222

TCE 4,500 19 8 , pp. 73, 208, 222

Notes:

DCE

- Dichloroethene/dichloroethylene

ID

- Identification

M D L

- Method Detection L imit

MW

- Moni toring well

TCE

- Trichloroethene/trichloroethylene μg/L

- Micrograms per liter

- March 2009

Sample ID Total Depth (feet) Screened

Interval (feet bgs) Depth to

Water (feet) Sample Location Date Sampled R eferences

MW

- 7 30.4 20.4

- 29.8 22.85 Approximately 250 feet north of CTS building 3/13/2009 8 , pp. 50, 52 , 73, 308, 325

MW

- 7A 71. 5 66.8

- 71.3 22.61 Approximately 250 feet north of CTS building 3/13/2009 8 , pp. 50, 52 , 73, 312, 325Ground Water Migration Pathway

– Likelihood of Release

42 Sample ID Total Depth (feet) Screened

Interval (feet bgs) Depth to

Water (feet) Sample Location Date Sampled R eferences

MW

- 11 13.1 3.1

- 12.5 0.58 Approximately 600 feet

east of CTS building ; Near creek 3/12/2009 8 , pp. 50, 52 , 73, 288, 325

MW

- 11A 45. 9 41.1

- 45.7

- 0.81 Approximately 600 feet

east of CTS building ; Near creek 3/12/2009 8 , pp. 50, 52 , 73, 292, 325

Notes:

ID

- Identification

MW

- Mon itoring well

Sample ID Hazardous
Substance Concentration ( μg/L ) MDL ( μg/L ) References

MW

- 7 TCE 3,700 2.9 8 , pp. 73, 308, 325

MW

- 7A TCE 35,000 29 8 , pp. 73, 312, 325

MW

- 11 TCE 6.4 0.073 8 , pp. 73, 288, 325

MW

- 11A TCE 73 0.073 8 , pp. 7 3, 292, 325

Notes:

ID

- Identification

MDL

- Method Detection Limit

MW

- Monitoring well

TCE

- Trichloroethene/trichloroethylene μg/L

- Micrograms per liter

- July 2009

Sample ID Total Depth (fee t) Screened

Interval (feet bgs) Depth to

Water ( toc in feet ) Sample Location Date Sampled References

MW

- 11B 188.0 185.5

- 187.4

- 17.32 Approximately 600 feet

east of CTS building ; Near creek 7 / 7 /2009 8 , pp. 50, 52 , 73, 349, 350

Notes: bgs

- below grou nd surface

ID

- Identification

MW

- Monitoring Well

toc

- Top of casing

Sample ID Hazardous
Substance Concentration ( μg/L ) MDL ( μg/L ) References

MW

- 11B Cis

- 1,2

- DCE 1,900 2.2 8 , pp. 73, 349, 363

MW

- 11B TCE 35,000 29 8 , pp. 73, 350, 363

Notes:

DC E

- Dichloroethene/dichloroethylene

ID

- Identification

MDL

- Method Detection Limit

MW

- Monitoring well

TCE

- Trichloroethene/trichloroethylene μg/L

- Micrograms per literGround Water Migration Pathway

– Likelihood of Release

43 Private Well Samples The investigation s below detail ground water samples collected from private wells near CTS with elevated levels of TCE and/or its breakdown products

. Samples are located on Figure 4.

Contaminated Drinking Water Samples

- July 1999 Ground Water Sampling (NCDENR) In July 1999, NCDENR DWQ

, Groundwater Section collected ground water samples from private residential wells and springs in the CTS area (Ref s

. 25, p p . 1 , 3 ; 28 , p. 1). Samples were collected according to NCDENR SOPs

. The

s amples below w ere submitted to the NCDENR DWQ Laboratory for several analys e s including TCL VOCs (Ref s

. 28

, pp. 4, 5 ; 25 , pp. 3

- 18 ). QA/QC information is provided in Reference 28 and 25

. TCE is a non

- ubiquitous man

- made substance, and contamination of land, air, surfa ce water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TCE (Ref. 61 , p. 4). Additionally, non

- detectable levels of TCE and degradation product s have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated

. Se e Figure 4 of this Documentation Record f or sample

locations.

Sample ID Hazardous
Substance Concentration ( μg/L ) TQL ( μg/L ) References

9G146 4 TCE 170 M 100 28 , pp. 4, 5 ; 24 , p. 6

9G1297 TCE 21,000 M 2,500 25 , pp. 1, 2, 9

- 11

9G1298 TCE 15,000 M 2,500 25 , pp. 1, 2, 14

- 16

Cis

- 1,2

- DCE 370 62 25 , pp. 1, 2, 14

- 16

Notes: μg/L

- Micrograms per liter TQL

- Target Quantitation Limi t
PW

- Potable well

M

- GC/MS analysis performance

DCE

- Dichloroethene/dichloroethylene

TCE

- Trichloroethene/trichloroethylene

- May 2000 Ground W ater Sampling (NCDENR) In May 2000, NCDENR collected ground water samples from p rivate residential wells in the CTS area (Ref. 31 , pp. 1

- 36 ). Samples were collected according to NCDENR SOPs

. Samples were submitted t o PDP for TCL VOCs analysis (Ref. 31 , p. 19 ). QA/QC informatio n is provided in Reference 31

. TCE is a non

- ubiquitous man

- made substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref. 10 , p. 1 ). Cis

- 1,2

- DCE is a degradation product of TCE (Ref. 61 , p. 4 ). Additionally, non

- d etectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated . See Figure 4 of this Documentation Record for sample locations

.

Sample ID Hazardous Substance Co ncentration ( μg/L ) RL ( μg/L ) References

PW9 Cis

- 1,2

- DCE 28 J 1 31 , pp. 19, 26

TCE 310 J 1 31 , pp. 19, 26

Notes: μg/L

- Micrograms per liter

DCE

- Dichloroethene/dichloroethylene

J

- Estimated Value

PW

- Potable well

RL

- Reporting Limit

TCE

- Trichloroethene/trichloroethylene

- November 2007 In November 2007, TN&A, with the assistance of NCDENR, collected ground water samples from private residential wells in the CTS area (Ref. 39 , pp. 6

- 7). Sampling activities were performed i n accordance with the EPA SESD RegionGround Water Migration Pathway

– Likelihood of Release

44 4 EISOPQAM (Ref. 39 , p. 4). Samples were submitted to SGS Environmental Services, Inc., for TCL VOCs analysis by

EPA Method 82 60B (Ref. 39 , p. 384). QA/QC information is provided in Reference 39

. TCE is a non

- ubiqu itous man

made substances, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TCE (Ref. 61 , p. 4). Ad ditionally, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated

. See Figure 4 of this Documentation Record for sample

locations.

Sample ID Hazard ous Substance Concentration ( μg/L ) QL ( μg/L ) References

CTS

- 019

- PW TCE 57 4 39 , pp. 14, 87, 280

Cis

- 1,2

- DCE 10.2 4 39 , pp. 14, 86, 280

Notes: μg/L

- Micrograms per liter

DCE

- Dichloroethene/dichloroethylene

ID

- Identification QL

- Quantitatio n Limit

PW

- Potable well

TCE

- Trichloroethene/trichloroethylene

- December 2007 Private Well Sampling (TN&A and NCDENR)

In December 2007 , TN&A, w ith the assistance of NCDENR, collected ground water samples from private residential

wells in the C TS area (Ref. 39 , pp. 6

- 7). Sampling activities were performed in accordance with the EPA SESD Region 4 EISOPQAM (Ref. 39 , p. 4). Samples were submitted to SGS Environmental Services, Inc., for TCL VOCs analysis by

EPA Method 8260B (Ref. 39 , p. 384). QA /QC informati on is provided in Reference 39

. TCE is a non

- ubiquitous man

made substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TCE (Ref. 61 , p. 4 ). Additionally, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated

. See Figure 4 of thi s Documentation Record for sample

locations.

Sample ID Hazardous Substance Concentration ( μg/L ) QL ( μg/L ) References

CTS

- 001

- PW TCE 929 100 39 , pp. 14, 376, 451

SW

- DW

- 01 TCE 54.1 0.5 40 , pp. 3, 5, 7, 11

Cis

- 1,2

- DCE 9.65 0.5 40 , pp. 3, 5, 7, 10

Notes: μg/L

- Micrograms per liter

DCE

- Dichloroethene/dichloroethylene

ID

- Identification

PW

- Potable well QL

- Quantitation Limit

TCE

- Trichloroethene/trichloroethylene

- January 2008

In January 2008, TN&A START collected ground water samples from private residential wells (Ref. 39 , p. 8). Sampling

activities were performed in accordance with the EPA SESD EISOPQAM (Ref. 39 , p. 4). Samples were submitted to SGS Environmental Services, In c.
, for TCL VOCs analysis by EPA Method 8260B (Ref. 39 , p. 14, 290, 321). QA/QC information is provided in Reference 39

. TCE is a non

- ubiquitous man

- made substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TCE (Ref. 61 , p. 4 ). Additionally, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being

evaluated . See Figure 4 of this Documentation Record for sample locations.Ground Water Migration Pathway

– Likelihood of Release

45 Sample ID Hazardous Substance Concentration ( μg/L ) QL ( μg/L ) References

CTS

- 081

- PW TCE 4.32 1 39 , pp. 14, 290, 321

Cis

- 1,2

- DC E 1.35 1 39 , pp. 14, 289, 321

Notes: μg/L

- Micrograms per liter

DCE

- Dichloroethene/dichloroethylene

PW

- Potable well QL

- Quantitation Limit

TCE

- Trichloroethene/trichloroethylene

- June 2008 Ground Water Sampling (TN&A) In June 2008, TN&A START collected ground water samples from private residential wells in the CTS area (Ref. 43 , p. 2). Procedures were conducted in accordance with the EPA Region 4 SESD FBQSTP (Ref. 43 , p. 1). Samples were

submitted to TestAmerica for VOCs analysis by EPA Method 524.2 (Ref. 43 , p. 2). QA/QC information is provided in

Reference 43

. TCE is a non

- ubiquitous man

- made substance , and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage du ring manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TC E (Ref. 61 , p. 4 ). Additionally, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water fr om the aquifer being evaluated . See Figure 4 of this Documentation Record for sample locations.

Sample ID Hazardous Substance Concentration ( μg/L ) MD L ( μg/L ) References

MG

- PW

- 03 Cis

- 1,2

- DCE 4.9 0.25 43 , pp. 2, 3, 9, 34, 35 , 39

TCE 20 0.20 43 , pp. 2, 3, 9, 34, 35 , 39

MG

- PW

- 04 Cis

- 1,2

- DCE 10 D 0.50 43 , pp. 2, 3, 11, 26, 34, 35 , 39

TCE 51 D 0.40 43 , pp. 2, 3, 11, 26, 34, 35 , 39

MG

- PW

- 15 Cis

- 1,2

- DCE 2.1 0.25 43 , pp. 2, 3, 22, 34, 35 , 42

TCE 8.8 0.20 43 , pp. 2, 3, 22, 34, 35 , 42

Notes: μg/L

- Micrograms per liter

D

- Surrogate or matrix spike recoveries were not obtained because the extract was diluted for analysis

DCE

- Dichloroethene/dichloroethylene

ID

- Identification

MDL

- Method Detection Limit

MG

- Mills Gap

PW

- Potable well

TCE

- Trichloroethene/trichloroethylene

- September 2008 Ground W ater Sampling (TN&A) In September 2008, TN&A START p ersonnel collected ground water samples from private residential wells in the CTS

area (Ref. 44 , p. 3). Pro cedures were conducted in accordance with the EPA Region 4 SESD FBQSTP (Ref. 44 , p. 1). A total of eighty potable well water samples were submitted to CLP laboratories for TCL VOCs by CLP Statement of Work (SOW) for Multi

- Media, Multi

- Concentration Organi cs Analysis ( SOM01.2 ) and two potable well water samples were submitted to SESD for TCL VOCs by EPA Method 8260 (Ref. 44 , p. 2). QA/QC information is provided in Reference

44

. TCE is a non

- ubiquitous man

- made substance , and contamination of land, air, su rface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TC E (Ref. 61 , p. 4). Additionally, non

- detectable levels of TCE and degradation prod ucts have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated . See Figure 4 ofGround Water Migration Pathway

– Likelihood of Release

46 this Documentation Record for sample locations.

Sample ID Hazardous Substance Concentration ( μg/L ) MRL ( μg/L ) References

M G

- SSI

- 29 TCE 66 2.5 44 , pp. 14, 378, 676, 691

Cis

- 1,2

- DCE 13 0.5 44 , pp. 14, 377, 676, 691

MG

- SSI

- 34 TCE 14 0.5 44 , pp. 16, 388, 677, 694

Cis

- 1,2

- DCE 4.1 0.5 44 , pp. 16, 387, 677, 694

MG

- SSI

- 114 TCE 2.7 0.5 44 , pp. 26, 472, 679, 694

Cis

- 1,2

- DCE 0.84 0.5 44 , pp. 26, 471, 679, 694

MG

- SSI

- 119 TCE 1,100 10 44 , pp. 28, 48, 49, 55, 681, 698

Cis

- 1,2

- DCE 95 1.0 44 , pp. 28, 48, 49, 54, 681, 698

Notes: μg/L

- Micrograms per liter

DCE

- Dichloroethene/dichloroethylene

ID

- Identification

MG

- Mills Gap

MRL

- Minimum Reporting Limit

SSI

- Special Studies Investigation

TCE

- Trichloroethene/trichloroethylene

- April 2009 Gr ound W ater Sampling (REAC) In April 2009, REAC collected ground water samples from private residential well s in the CTS area (Ref. 51 , p. 1, 18, 19). Samples were collected in accordance with the REAC QAPP (Ref. 62 ). S amples were submitted to DataChem Laboratories, Inc.

, for TCL VOCs by CLP SOW SOM01.2 (Ref. 51 , p. 16). QA/QC information is provided in

Refer ence 51

. TCE is a non

- ubiquitous man

- made substance , and contamination of land, air, surface water, and ground water are primarily a result of industrial spillage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of T CE (Ref. 61 , p. 4). Additionally, non

- detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground water from the aquifer being evaluated . See Figure 4 of this Documentation Record for sample loc ations.

Sample ID Hazardous Substance Concentration ( μg/L ) MRL ( μg/L ) References

MG

- PT

- 03A TCE 11 5.0 51 , pp. 12, 21, 46

MG

- PT

- 02A Cis

- 1,2

- DCE 2.0 0.50 51 , pp. 13, 22, 48

TCE 18 1.0 51 , pp. 13, 23, 48

MG

- PT

- 02B Cis

- 1,2

- DCE 1.8 0.50 51 , pp. 13 , 24, 48

TCE 19 1.0 51 , pp. 13, 25, 48

MG

- PT

- 02C Cis

- 1,2

- DCE 1.9 0.50 51 , pp. 13, 26, 48

TCE 21 1.0 51 , pp. 13, 27, 48

MG

- PT

- 04A Cis

- 1,2

- DCE 82 5.0 51 , pp. 12, 28, 49

TCE 890 50 51 , pp. 12, 29, 49

MG

- PT

- 04B Cis

- 1,2

- DCE 87 5.0 51 , pp. 12, 30, 49

TCE 870 50 51 , pp. 12, 31, 49

MG

- PT

- 04C Cis

- 1,2

- DCE 98 5.0 51 , pp. 12, 32, 49

TCE 990 50 51 , pp. 12, 33, 49

MG

- PT

- 05A Cis

- 1,2

- DCE 91 5.0 51 , pp. 12, 34, 50

TCE 990 50 51 , pp. 12, 35, 50

MG

- PT

- 01A Cis

- 1,2

- DCE 15 0.50 51 , p p . 13, 36

TCE 52 2.5 51 , p p . 13, 37Ground Water Migration Pathway

– Likelihood of Release

47 Sample ID Hazardous Substance Concentration ( μg/L ) MRL ( μg/L ) References

MG

- PT

- 01B Cis

- 1,2

- DCE 18 0.50 51 , p p . 13, 38

TCE 57 2.5 51 , p p . 13, 39

MG

- PT

- 01C Cis

- 1,2

- DCE 17 0.50 51 , p p . 13, 40

TCE 54 2.5 51 , p p . 13, 41

MG

- PT

- 03B TCE 9 0.50 51 , p p

. 1 2, 43

MG

- PT

- 03C Cis

- 1,2

- DCE 1.7 0.50 51 , p p

. 1 2 , 44

TCE 1 8 0.50 51 , p p . 1 2, 45

Notes: μg/L

- Micrograms per liter

DCE

- Dichloroethene/dichloroethylene

ID

- Identification

MG

- Mills Gap

MRL

- Minimum Reporting Limit

PT

- Packer Test

TCE

- Trichloroethene/trichloroe thylene

- October 2009 Ground W ater Sampling (TN&A) In October 2009, TN&A START collected ground water samples from private residential wells in the area of the CTS facility (Ref. 49 , p p . 1 , 2 ). Sampling was conducted in accordance with th e EPA Region 4 Science SESD FBQSTP (Ref.

49 , p. 1). Samples collected were submitted to CLP laboratories for TCL VOCs analysis by CLP SOW SOM01.2 (Ref.

49 , p. 3). QA/QC information is provided in Reference 49

. TCE is a non

- ubiquitous man

- made substance, and contamination of land, air, surface water, and ground water are primarily a result of industrial spi llage during manufacture or use (Ref s

. 10 , p. 1 ; Figure 4 ). Cis

- 1,2

- DCE is a degradation product of TCE (Ref. 61 , p. 4). Additionally, non

detectable levels of TCE and degradation products have been documented in nearby ground water wells drawing ground

water from the aquifer being evaluated . See Figure 4 of this Documentation Record for sample locations.

Sample ID Hazardous Substance Concentration ( μg/L ) MRL ( μg/L ) References

MG

- GMP4

- 09 (Chapel Hill Church Rd) Cis

- 1,2

- DCE 32 20 49 , pp. 3, 8, 10, 20, 44, 46, 696, 887

, 918

TCE 430 20 49 , pp. 3, 8, 10, 20, 44, 46, 696, 887

, 918

Notes: μg/L

- Micrograms per liter

DCE

- Dichloroethene/dichloroethy lene

ID

- Identification

GMP4

- Ground Water Monitoring Program 4 th Quarter

MG

- Mills Gap

MRL

- Minimum Reporting Limit

TCE

- Trichloroethene/trichloroethyleneGround Water Migration Pathway

– Likelihood of Release

48 Attribution:

TCE is a nonflammable, colorless liquid that does not occur naturally in the environment; however, it is often found in ground water and surface water as a result of manufacture, use, and improper disposal (Ref. 10, p. 1). TCE is a halogenated organic compound widely used as an ingredient in industrial cleaning solutions and as a “universal” degreasing agent (Ref. 11, p. 1). Microbial degradation by sequential dehalogenation may produce cis

- 1,2

- DCE; trans

1,2

- DCE; and vinyl chloride (Ref. 61, p. 4). Final reductive dehalogenation of TCE through natural or induced mechanisms over time results in the production of vinyl chloride (Ref. 11, p. 1). TCE is heavier than water; therefore, a spill of sufficient magnitude tends to move downward through the subsurface as a dense nonaqueous phase liquid (DNAPL), u ntil low permeability features in the soil or bedrock impede its progress (Ref. 11, p. 2). Residual saturation may also serve as a source area for contamination and migration of TCE within an aquifer system (Ref. 11, p. 2).

During the operational period of the CTS facility, plating operations and manufacturing processes requiring the chemical rinsing of parts were conducted in the centrally located plating room near the back of the facility (Ref. 9, p. 16). Approximately one

- third of the floor space in t he 80 feet by 28 feet plating room is concrete, the other two

- thirds is composed of acid

- resistant brick and masonry concrete (Ref. 9, p. 16). During the operational period, there were several small chemical storage areas within the plating room, includin g a TCE pit (sump), a sulfuric acid tank, and a sodium hydroxide tank (Ref. 9, p. 16). A 1

- foot wide, acid brick

- lined drainage spillway divides the room (Ref. 9, p. 16). The drainage spillway enters the plating area from the dye room and passes beneath the concrete pad (Ref. 9, p. 17). An area where acid spilled from the sulfuric acid tank and emptied into the drainage spillway is located west of the concrete pad (Ref. 9, p. 17). Acid brick was not utilized in the construction of the spillway in this l ocation, and the concrete was dissolved in this area exposing the underlying soil (Ref. 9, p. 17). The drainage spillway leads to a collection sump in a room south of the plating area (Ref. 9, p. 17). A large waste pit was located near the southwest corn er of the plant building and was formerly used for the treatment of waste waters generated by plant operations (Ref. 9, p. 20). The waste water effluent from the plating and paint curing rooms was treated at this location (Ref. 9, p. 20). The pit was cov ered with steel plates, one of which was hinged to allow access (Ref. 9, p. 20). Waste treating equipment used in and around the pit was removed from the property prior to the assessment (Ref. 9, p. 20). A dye room was located near the southwest

corner o f the plant (Ref. 9, p. 20). Dyes utilized in manufacturing processes were formerly stored and maintained in this area (Ref. 9, p. 20). Dye residues were present throughout the dye room as well as outside the building near the pump assemblies (Ref. 9, p. 20). Wipe samples collected from the plating area, including the TCE sump, indicated elevated levels of TCE, PCE, hexane, and xylene (Ref. 9, pp. 17, 22, 26

- 29). The source of the VOC contamination was inferred to be spills and/or leaks in the plating a nd paint curing areas (Ref. 9, p. 22). No information regarding the specific materials used to construct the TCE sump is available; however, the sump was only approximately 2 to 3 feet deep and information provided during the 1987 investigation by Law Env ironmental for CTS indicates that the building foundation was concrete directly overlying the native soil (Ref. 9, p. 17). Furthermore, poor housekeeping practices were noted in the plating area where sulfuric acid had dissolved the concrete foundation, e xposing the underlying soil (Ref. 9, p. 17).

Between 1953 and 1980, wastes that could not be reclaimed from the electroplating process at CTS were disposed through the city sewer system (Ref. 4, p. 5). After 1980, wastes were stored in drums or tanks on the property prior to transportation and disposal off property or for recycling (Ref. 4, p. 5). After 1980, the facility produced approximately 44,440 pounds of sludge; 8,307 pounds of waste solvents; and 52,800 pounds of other waste organic chemicals annually, stored in drums, and then manifested off site for disposal (Ref s . 4, p. 5 ; 19, p. 4 ). Among the constituents listed at the facility on the RCRA form Part A, was EPA hazard waste code F001, spent halogenated solvents used in degreasing, listing TCE and PCE specifically (Refs. 12, p. 2; 14, p. 1 ; 19, p. 4 ).

As discussed and referenced below, the hazardous substances (TCE, PCE, and cis

- 1,2

- DCE) documented in ground water underlying CTS and in downgradient temporary, monitoring, and private drinkin g water wells are also detected in soil samples collected from CTS . Investigations at CTS that have documented the presence of TCE , PCE and cis

- 1,2

- DCE in the soils and ground water include:

**•** During the 1987 Site Assessment on behalf of CTS, TCE was ele vated in all of the soil borings collected outside the plant building, with values ranging from 6 μg/kg to 380 μg/kg (Ref. 9, pp. 21, 29, 32, 105, 109). TCE and PCE were also detected at elevated concentrations in the plating area (Ref. 9, pp. 22, 29, 32, 91).Ground Water Migration Pathway

– Likelihood of Release

49 **•** From November 9 through 11, 1999, Tetra Tech EM, Inc., under the EPA START contract, collected samples at CTS (Ref. 4, pp. 8, 10). Analytical results indicated TCE and PCE at elevated concentrations in surface soil, subsurface soil, and sediment s amples at concentrations ranging from 29 to 33,000 μg/kg (Ref. 4, pp. 10

- 11,

17

- 18, 20, 34

- 35, 179, 207, 221, 223, 233).

**•** On September 12, 2000, REAC completed the excavation of exploratory trenches at CTS (Ref. 32, p. 3). Outside of the former plant building, the REAC investigation did not identify another obvious contamination source (Ref. 24, p. 7). Therefore, the emphasis shifted to locating possible sources directly beneath the building foundation (Ref. 24, p. 7). During the week of May 7, 2001 , REAC personnel conducted a soil boring and sampling event beneath the foundation of the CTS building (Ref. 33, p. 1). Direct push technology was used to advance and sample 10 borings through the concrete floor of the CTS building and two borings outside of the building (Ref. 33, p. 2). TCE was detected in all samples; the highest VOC concentrations were detected in

borehole BH

- 3 from the 32 to 34 foot range, where TCE was detected at 830,000 μg/kg, although, VOC concentrations were generally elevated th roughout the borehole (Ref. 33, pp. 2, 8, 29, 97, 98). The BH

- 3 sample at 32 to 34 feet was collected within the saturated zone beneath the CTS building. The two cores from borehole 12, located outside of the CTS building, exhibited TCE concentrations of 110,000 μg/kg and 140,000 μg/kg at 12 to 16 feet bgs and 16 to 19 feet bgs, respectively (Ref. 33, pp. 2, 12, 29, 31, 97). Samples collected from borings located south of the building exhibited TCE concentrations from 110,000 μg/kg (32 to 38 feet bgs)

to 400,000 μg/kg (20 to 24 feet bgs) (Ref. 33, pp. 27

- 28, 96).

**•** In 2004, MACTEC conducted sampling activities pursuant to an AOC for removal action between EPA, CTS Corporation, and M ills Gap Road Associates (Refs. 7, pp. 6, 9; 34, p. 2). Activities inclu ded collecting continuous soil samples from 28 boreholes drilled using direct push technology; a total of 54 soil samples were collected and analyzed (Ref. 7, pp. 7, 20). The highest values of TCE were detected at elevated concentrations

in locations BH

- 3 4B (440,000 μg/kg), BH

- 20C (240,000 μg/kg), and BH

- 22C (95,000 μg/kg) (Ref. 7, pp. 26,

56

- 57, 62, 354, 474). Sample BH

- 34B was located approximately 25 feet to the south of the CTS building (Ref. 7, p p

. 42, 89 ). Samples BH

- 20C and BH

- 22C were located und erneath the building, east of the building’s center (Ref. 7, p p

. 42, 89)

.

**•** The SVE system operating at the CTS facility since 2006 includes 15 SVE wells located throughout the property (Ref. 37, p. 5, 13). From January 2008 to the present, an estimate d 1,568 pounds of VOCs have been discharged from the SVE system (Ref. 63, pp. 3, 11, 19, 27, 35, 43, 51, 85, 118, 152).

These investigations and the volume of VOCs removed by the SVE system indicate that a significant source of VOCs, including TCE and its breakdown products exists at CTS.

In an attempt to identify the presence of other possible contributors to the TCE ground water contamination, a radial search for businesses within 4 miles of the CTS property was conducted by Environmental Data Reso urces, Inc. (EDR) for EPA (Ref. 64, pp. 1

- 25). EDR searches multiple databases including, but not limited to, federal, state, tribal, local land records, emergency release reports, and EDR proprietary records (Ref. 64, pp. 1

- 25). According to the EDR rad ial report, there are numerous businesses within the 4 mile radius of the CTS property (Ref. 64, pp. 1

- 25). EDR conducted a comprehensive review of RCRA Info, the EPA’s comprehensive information system (Ref. 64, pp. 5

- 7). The review

included several RCRA Info databases including: CERCLIS No Further Remedial Ac tion Planned (CERC

- NFRAP) sites;

RCRA

- Large Quantity Generators (LQG) s ites; RCRA

- Small Q uantity Generators (SQG) sites; Resource Conservation and Recovery Act Conditionally Exempt Small Quantity Gen erators (RCRA

- CESQG) sites ; and RCRA Non

- generator sites (Ref. 64, pp. 5

- 7). EDR additionally reviewed the list of dry cleaners, active and abandoned, that have been entered into the Dry Cleaning Solvent Cleanup Program database (Ref. 64, p. 22). A revie w of the dry cleaners database indicated one dry cleaning site 2. 733 miles northwest of CTS (Ref. 64, pp. 22, 400

- 401).

CTS Corporation submitted an Attribution Report to members of Congress dated September 28, 2009. The report identified multiple busi nesses in the area that CTS deemed “potential” businesses contributing to the source of TCE contamination in the contaminated wells in the area (Ref. 65, pp. 1

- 310). CTS highlighted numerous businesses within their report based on the category of listed h azardous wastes used at the facilities (Ref. 65, pp. 1

- 8).Ground Water Migration Pathway

– Likelihood of Release

50 To follow up on the EDR and the CTS report s , EPA mailed CERCLA 104E information request questionnaires to several businesses/locations (Ref. 66, pp. 1

- 2)

. Of these

, the following businesses are being further investigated by EPA because their operation has or may have used TCE in their process at one point in time , and they are in proximity of the TCE contaminated ground water . The three locations that are currently being investigated by EPA to determine if they may have contributed to the TCE contamination in ground water are:

**•** Pechiney Plastic Packaging, Inc

. Pechiney Plastics Packaging, Inc. (now Amcor Flexibles, Inc.) , an Alcan Company, is located at 3055 Sweeten Creek Road, 0.951 miles nor thwest of the CTS property (Ref s . 64, p p . 5, 11

- 12, 73

- 87 ; 79, p. 2 ). In 1989

, twelve USTs were removed by Chase Packaging, a former owner of the facility (Ref. 79, pp. 2, 4681) . The

USTs c ontained gasoline, fuel oil, n

- propyl acetate, heptane, ethyl ac etate , ethyl alcohol, toluene and methyl

ethyl ketone (MEK) (Ref. 79, p. 4681)

. No chlorinated solvents were kept in the USTs and Alcan has no records of TCE or PCE ever being used in their processes (Ref. 79, p. 12). G round water sampling at the

facilit y indicated trace levels of PCE and TCE in monitoring wells in the area of the former USTs (Ref. 79, p. Appendix J, pp. 4710

- 4711, 4715, 4903, 4905, 4932

- 4933)

. T race levels of VOC s had been detected in soil samples on the property prior to Alcan ownershi p (Ref. 79, p. 4681). Ground water flow at this facility is toward the west, away from the area of the contaminated residential wells in the Oaks Subdivision (Ref. 79, pp. 4691, 4715). EPA plans to conduct further investigation at this facility to determ ine the presence or absence of

contamination.

**•** Conner Motors

Conner M otors is located at 270 Mills Gap Road, 0.023 miles east of the CTS property (Ref. 64, pp. 6, 12, 58

- 60). Connor Motors reported that they were a conditionally exempt small quantity gene rator of halogenated solvent waste, including PCE and TCE (Ref. 64, p. 58

- 60). However, n o evidence exists that Connor Motors

has released PCE or TCE to the environment or contributed to the ground water contamination being scored in

this HRS documentatio n record. EPA plans to conduct further investigation at this location to determine the presence or absence of contamination at the facility

.

**•** Sheet Metal Restoration Sheet Metal Restoration operated at 60 Pinners Cove Road (formerly 39 Pinners Cove Road) from December
11, 2006 to December 10, 2008 (Ref. 80, p. 1). From 2003 until 2009, the owner operated a sandblasting
business on the property and utilized urea, aluminum oxide

, and walnut shells to sandblast fiberglass and sheet
metal (Ref. 80, p. 1). A ccording to the current property owner, the previous owner operated a spray paint booth

in one of the on

- site buildings; however, this operation has not been verified to date (Ref. 80, p. 1). There is no
evidence that Sheet Metal Restoration or the previo us property owner released TCE to the environment or
contributed to the ground water contamination being scored in this HRS documentation record. EPA is
currently requesting information from the previous property owner.

The following conclusions (Ref . 53, p. 21

- 22) are presented based on the data collected:

1. Ground water with up to 35,000 ug/L TCE exists in fractured bedrock beneath and near the CTS plant at

187.5 feet ( ’ ) below ground surface. Private wells up to 698’, within the Oaks Subdivision, have higher concentrations (at depth) of TCE which is consistent with a deeper flow path from a distant source, and that traveled to the wells via deep fractures in bedrock ( Ref. 53, p. 22)

. 2. The main flow paths in fractured rocks are along joints, fracture s, shear zones, faults and other (geologic) discontinuities ( Ref. 53, p. 22 ).

3. The contaminant distribution in the Oaks Subdivision w ells in which borehole geophysics and packer testing were performed showed increasing TCE concentrations with depth indica ting a possible deep migration pathway from a distant source (Ref. 53, p. 22)

. 4. Surficial geologic mapping and subsurface borehole measurements document the existence of

a. numerous W

- NW and E

- SE striking joints and foliation parting fractures (within the MG FZ) that together form a pathway of interconnected features for contaminated g round water, knownGround Water Migration Pathway

– Likelihood of Release

51 to occur in bedrock fractures near the CTS plant, to flow toward MW

- 11B on the adjoining residential property and Concord Road (Ref. 53, pp. 22

- 23)

. b. numerous N /NE striking joints and foliation parting fractures that together form a pathway of interconnected features for contaminated ground water, known to occur in bedrock fractures near the CTS plant, to flow toward wells located on Chapel Hill Church Road and i n the Oaks

Subdivision (Ref. 53, p. 23)

.

c. low angle, foliation parallel water bearing features within the Oaks Subdivision wells that provide for interconnection between the Oaks Subdivision wells (Ref. 53, p. 23)

. d. orientation data collected from surface ou tcrops and from borehole surveys are biased to count steeply dipping features and to count shallow dipping features, respectively. Also, a majority of the available orientation data for surface outcrops in the site area were collected from

locations with in the MGFZ, and are also biased in that respect. The two sets of orientation data are not inconsistent with one another, but rather are compl i mentary, and together support the

above conclusions (Ref. 53, p. 23)

.

Electroplating operations have been condu cted at the CTS property since 1952 (Ref. 7

, p. 9) . As referenced above, TCE and other solvents have been tied to CTS operations since 19 80 , and have been detected in soils and ground water at the facility since 19 87. These solvents are highly mobile and persistent in ground water, and can travel through the faults/joints/fractures present in the Mills Gap area (Ref. 11, p. 2) . In addition to being detected in both shallow and deeper ground water at the CTS facility, the same VOCs have been detected in m onitoring, temporary, a nd/or private drinking water wells as far out as the Oaks Subdivision 0.673 miles northeast of the CTS facility

. These findings and the site specific geological data support the conclusion that the ground water contamination being s cored is at least partially

attributable to CTS

.

Hazardous Substances Released:

cis

- 1,2

- DCE

PCE

TCE Vinyl Chloride

Ground W ater Observed Release Factor Value: 550Ground Water Migration Pathway

– Waste Characteristics

52 3 .2 WASTE CHARACTERISTICS

3.2.1 TOXICITY/MOBILITY

Hazardous
Substance So urce No. Toxicity

Factor

Value Mobility

Factor

Value Toxicity/Mobility Does Hazardous
Substance Meet Observed Release by

chemical analysis? (Y/N) Reference s

PCE 1 100 1 100 Y 1, Table 3

- 9; 2,

p. BI

- 10

TCE 1 10,000 1 10,000 Y 1, Table 3

- 9; 2,

p. BI

- 11

Cis

- 1,2

- DCE 1 100 1 100 Y 1, Table 3

- 9; 2,

p

. BI

- 5

Vinyl

Chloride O.R. * 10,000 1 10,000 Y 1, Table 3

- 9; 2,

p. BI

- 12

Notes:

**•** O.R.

– Meets observed release criteria. Vinyl chloride is a degradation product of TCE ( Ref. 11, p. 1 )

Toxicity/Mo bility Factor Value: 10,000 (Ref. 1, Table 3

- 9)Ground Water Migration Pathway

– Waste Characteristics

53 3.2.2 HAZARDOUS WASTE QUANTITY

Source No. Source Type Hazardous Waste Quantity

1 Contaminated Soil 1.29

SUM = 1.29

Sum of Values: 1.29

Hazardous constit uent quantity information is incomplete and drinking water targets from the ground water migration pathway are subject to Level I concentrations; therefore a hazardous waste quantity factor value of 100 is assigned (Refs. 1, Section

2.4.2.2 and Table 2

- 6; 70 ).

Hazardous Waste Quantity Factor Value: 100 (Ref. 1, Section 2.4.2.2 and Table 2

- 6)

3.2.3 WASTE CHARACTERISTICS FACTOR CATEGORY VALUE

Toxicity/Mobility Factor Valu e: 10,000 Hazardous Waste Quantity Factor Value: 10 0

Toxicity/Mobility Fac tor V alue (10

, 0 00 ) X Hazardous Waste Quantity Factor Value (10 0 ) = 1

, 00 0 ,000

Waste Characteristics Factor Categ ory Value: 32 (Ref. 1, Table 2

- 7)Ground Water Migration Pathway

– Targets

54 3.3 TARGETS

Residents within a 4

- mile radius of the CTS source obtain drinking water from a combi nation of private and community wells and municipal water sources (Refs. 70 , pp. 1

- 42 ; 71 , pp. 1

- 11 ). The City of Asheville provides drinking water to a portion of the population within the 4

- mile radius; the source of water is surface water intakes ( Refs . 13, p. 2; 21, p. 14)

.

Three community wells were identified within the 4

- mile radius of the source , Homestead Mobile Village and two wells at

Christ School (Ref. 71 , pp. 1

- 11 ). The community well at Homestead Mobile Village maintains 39 connections

, serves a population of 77 people

, and is located 1. 5 miles east from the source (Refs. 3; 71 , pp. 1, 2, 4, 5).

The Christ School maintains two community wells that are located 1. 9 miles and 2. 2 miles from S ource 1 (Ref s . 3; 71 , pp. 1, 3, 7, 8, 10 ; 82, p. 1 ). A total of 33 connections and 249 persons are served by two Christ School community well s

. The two wells are completed at 600 feet below land surface are pumped in 12

- hour cycles to fill a 50,000 gallon tank to avoid depleting the water table; th erefore , the population per well was apportioned as follows: 33 connections ÷ 2 wells = 16.5

connections per well and 249 persons ÷ 2 wells = 124.5 persons per well (Ref s

. 71 , pp. 1

- 11 ; 82, p. 1 ). Therefore, 16.5 connections and 124.5 persons are served b y the community well located within the 1

- 2 mile radial ring and 16.5 connections and 124.5 persons are served by the community well located within the 2

- 3 mile radial ring (Ref s

. 71 , pp. 1, 3, 7, 8, 10 ; 82, p.

1 )

.

A total of 4,390 private wells were ide ntified within a 4

- mile radius of the source (Ref s

. 70 , pp. 1

- 7 ; 72 , pp. 1, 2 ). A total of 128 private wells were identified within one radial mile of the source during a comprehensive drinking water well survey (Ref.

70 , pp. 1

- 7 ). Outside the one

- mile radius, the number of private wells was determined by a house count after subtracting out the service area for the municipal water supply

, and only counting those parcels that have a maintained structure and are not served by a community well (Ref. 72 , pp. 1

- 2) . A total of 4

, 262 private wells were counted within the 1 to 4 mile radii (Ref.

72 , pp. 1, 2 ). Using the Buncombe County average persons per household of 2.33, a total 10,228.7 persons obtain drinking water from private wells within the 4

- mile rad ius (4,390 private wells x 2.33 persons per household = 10,228.7 persons) (Refs.

70 , pp. 1

- 7 ; 72 ; 73 , p. 1 ).

Access forms, phone logs, and/or affidavits are available for more specific persons per household at certain addresses within 1

mile of the CTS source (Refs. 74, pp. 1

- 361, 75, pp. 1, 2). S even private wells with Level I concentrations of TCE were

identified within the 1

- mile radius of the CTS property and are distributed as follows: from 0

- to 0.25

- mile, 1 well; from 0.25

- to 0.50

- mile, 2 wells ; and from 0.50

- to 1

- mile, 4 wells (Ref. 3) . A total of 26 persons obtain drinking water from these Level I wells (Refs. 70 , pp. 1

- 7). No private wells with Level II concentrations were identified. Sample information is listed in

Section 3.3.2.2.Ground Water Migration Pathway

– Targets

55 Level I Concentrations

Sample ID Hazardous
Substance Hazardous
Substance

Concentration ( μg/L ) Benchmark

Concentration ( μ g/L) Benchmark Reference for

Benchmark

9G1464 TCE 170 M 5 MCL 2, p. 31; 24, p. 6; 28, pp. 4, 5; 41 , p. 4

9G1297 TCE 21,000 M 5 MCL 2, p. 31; 25, pp. 1, 2, 9

- 11; 41 , p. 4

9G1298 TCE 15,000 M 5 MCL 2, p. 31; 25, pp. 1, 2, 14

- 16; 41 , p. 4

9G1298 Cis

- 1,2

- DCE 370 70 MCL 2, p. 25 ; 25, pp. 1, 2, 14

- 16

PW9 TCE 310 J 5 MCL 2, p. 31; 31, pp. 19, 26; 41 , p. 4

CTS

- 019

- PW TCE 57 5 MCL 2, p . 31; 39, pp. 14, 87, 280; 41 , p. 4

CTS

- 001

- PW TCE 929 5 MCL 2, p. 31; 39, pp. 14, 376; 451; 41 , p. 4

SW

- DW

- 01 TCE 54.1 5 MCL 2, p. 31; 40, pp. 3, 5, 7, 10; 41 , p. 4

MG

- PW

- 03 TCE 20 5 MCL 2, p. 31; 41 , p. 4 ; 43, pp. 2, 3, 9, 34, 35, 39

MG

- PW

- 04 TCE 51 D 5 MCL 2, p. 31; 41 , p. 4 ; 43, pp. 2, 3, 11, 26, 34, 35, 39

MG

- PW

- 15 TCE 8.8 5 MCL 2, p. 31; 41 , p. 4 ; 43, pp. 2, 3, 22, 34, 35, 42

MG

- SSI

- 29 TCE 66 5 MCL 2, p. 31; 41 , p. 4 ; 44, pp. 14, 378, 676, 691

MG

- SSI

- 34 TCE 14 5 MCL 2, p. 31; 41 , p. 4 ; 44, pp. 16, 388, 677, 694

MG

- SSI

- 119 TCE 1,100 5 MCL 2, p. 31; 41 , p. 4 ; 44, pp. 28, 48, 49, 681, 698

MG

- SSI

- 119 Cis

- 1,2

- DCE 95 70 MCL 2, p. 25 ; 44, pp. 28, 48, 49, 54, 681, 698

MG

- PT

- 03A TCE 11 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 12, 21, 46

MG

- PT

- 02A TCE 18 5 M CL 2, p. 31; 41 , p. 4 ; 51, pp. 13, 23, 48

MG

- PT

- 02B TCE 19 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 13, 25, 48

MG

- PT

- 02C TCE 21 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 13, 27, 48

MG

- PT

- 04A Cis

- 1,2

- DCE 82 70 MCL 2, p. 25 ; 51, pp. 12, 28, 49Ground Water Migration Pathway

– Targets

56 Sample ID Hazardous
Substance Hazardous
Substance

Concentration ( μg/L ) Benchmark

Concentration ( μ g/L) Benchmark Reference for

Benchmark

MG

- PT

- 04A TCE 890 5 MCL 2 , p. 31; 41 , p. 4 ; 51, pp. 12, 29, 49

MG

- PT

- 04B Cis

- 1,2

- DCE 87 70 MCL 2, p. 25 ; 51, pp. 12, 30, 49

MG

- PT

- 04B TCE 870 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 12, 31, 49

MG

- PT

- 04C Cis

- 1,2

- DCE 98 70 MCL 2, p. 25 ; 51, pp. 12, 32, 49

MG

- PT

- 04C TCE 990 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 12, 33, 49

MG

- PT

- 05A Cis

- 1,2

- DCE 91 70 MCL 2, p. 25 ; 51, pp. 12, 34, 50

MG

- PT

- 05A TCE 990 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 12, 35, 50

MG

- PT

- 01A TCE 52 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 13, 37

MG

- PT

- 01B TCE 57 5 MCL 2, p. 31; 41

, p. 4 ; 51, pp. 13, 39

MG

- PT

- 01C TCE 54 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 13, 41

MG

- PT

- 03B TCE 9 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 13, 43

MG

- PT

- 03C TCE 18 5 MCL 2, p. 31; 41 , p. 4 ; 51, pp. 13, 45

MG

- GMP4

- 09 TCE 430 5 MCL 2, p. 31; 41 , p. 4 ; 49, pp. 3, 8 , 10, 20,

44, 46, 696, 887,

918

Notes: μg/L

- Micrograms per liter

D

- Surrogate or matrix spike recoveries were not obtained because the extract was diluted for analysis

DCE

- Dichloroethene/dichloroethylene

ID

- Identification

J

- Estimated value

M

- GC/MS Analysis Performance

MG

- Mills Gap

M C L

- Maximum Contaminant Level

PW

- Potable well

TCE

- Trichloroethene/trichloroethyleneGround Water Migration Pathway

– Targets

57 3.3.1 NEAREST WELL

Well: 275 Mills Gap Road (0

- 0.25 mile from CTS source)

Level of Contamination: Actual (Level I )

Nearest Well Factor Value: 50 (Ref. 1 , Section 3.3.1 )

3.3.2 POPULATION

3.3.2.1 Level of Contamination

3.3.2.2 Level I Concentrations

Sample IDs Aquifer Population References

9G1297 (spring well)

9G1298 (spring wel l) 1 3 Ref s

. 25, pp. 1, 2, 9

- 16; 70

, p. 4 ; 74 , p. 361

9G1464

PW9

CTS

- 001

- PW

MG

- SSI

- 119

MG

- PT

- 04A/

- 04B/

- 04C

MG

- PT

- 05A 1 7 Refs. 24, p. 6; 28, pp. 4, 5; 31, pp. 19, 26; 39, pp. 14, 376, 451; 44, pp. 28, 48, 49, 54

, 681, 698; 51, pp. 12, 28

- 35, 49 , 50 ; 70

, p. 4;

75 , pp. 1, 2

MG

- GMP4

- 09 1 5 Refs. 70

, p. 4; 74 , p. 66

- 69

MW

- PW

- 04

MG

- SSI

- 29

CTS

- 019

- PW

SW

- DW

- 01

MG

- PT

- 01A/

- 01B/

- 01C 1 1 Ref s

. 39, pp. 14, 86, 87, 280; 40, pp. 3, 5, 7, 10, 11; 43, pp. 2, 3, 11, 26, 34, 35, 39; 44, pp. 14, 377, 378, 676, 691; 51, pp . 13, 36

- 41; 70

, p. 4 ; 74 , pp. 355

- 356

MG

- PW

- 03

MG

- SSI

- 34

MG

- PT

- 03A/

- 03B/

- 03C 1 1 Ref s

. 43, pp. 2, 3, 9, 34, 35, 39; 44, pp. 16, 387, 388, 677, 694; 51, pp. 12, 21, 43

- 46;

70

, p. 4 ; 74 , pp. 357

- 358

MG

- PW

- 15 1 6 Ref. 43, pp. 2, 3, 22, 34, 35, 42; 70

, p. 4

MG

- PT

- 02A/

- 02B/

- 02C 1 3 Ref s

. 51, pp. 22

- 27, 48; 70

, p. 4 ; 74 , pp. 359

- 360
Sum of Population Served by Level I Wells: 26 Sum of Population Served by Level I Wells x 10: 260

Level I Concentrations Factor Value: 260 Reference 1, Section 3.3.2.2

3.3.2.3 Level II Concentrations

No Level II concentrations are evaluated in this documentation package.

3.3.2.4 Potential Contamination

T hree community wells exist within 1 to 3 mile s from CTS (Ref s

. 3; 71 , pp. 2, 3, 4, 7) . The community well located at the Homestead Mobile Village serves 39 connections and a population of 77 and is located within the 1 to 2 mile radius (Ref s

. 3;

71 , pp. 1, 2, 4, 5). The two community wells located at the Christ School serve 33 connections and a combined popu lation of

249 . O ne of the Christ School wells is located in the 1 to 2 mile radius and the other is located in the 2 to 3 mile radius (Ref s

. 3; 71 , pp. 1, 3, 7, 8, 10 ; 82, p. 1 ).

A total of 4,390 private wells were identified within a 4

- mile radius of the CTS source area (Refs. 70 , pp. 1

- 7; 72 , pp. 1, 2).

For the one

- mile radius, a total of 128 private wells , including private wells scored in this Documentation Record as subject to Level I concentrations, were identified within one radial mile of the CTS source by a comprehensive drinking water wellGround Water Migration Pathway

– Targets

58 survey (Ref. 70 , pp. 1

- 7 ). Outside the one

- mile radius, the number of private wells was determined as those residents outside

the service area o f municipal water a nd not served by any community well (Ref. 72 , pp. 1, 2). A total of 4,262 private wells

were located between 1

- 4 miles of the property radius (Ref. 72 , pp. 1, 2). Using the Buncombe County average persons per household of 2.33, a total 10,228.7 0 persons obtain drinking water from private wells within the 4

- mile radius (4,390 private wells x 2.33 persons per household = 10,228.7 0 persons) (Refs. 70 , pp. 1

- 7; 72 ; 73 ).

The number of Level I private wells were subtracted from each distance ring and the potential contamination population was

calc ulated using that number. Therefore, the population served by community and private wells in the vicinity of the property

is distributed as follows: 0

- to 0.25

- mile, 2 .33 perso ns ( 1 private well ); 0.25

- to 0.5

- mile, 11.6 5 persons (5 private wells); 0.5

- t o 1

- mile, 2 67.95 persons ( 115 private wells); 1

- to 2

- miles, 2,780.81 persons ( 1,107 private wells; 2 community wells ); 2

- to
3

- miles, 3,272.33 persons ( 1,351 private wells; 1 community well ); 3

- to 4

- miles, 4,203.3 2 persons ( 1,804 private wells ) (Refs. 71 , pp. 1

- 11; 70 , pp. 1

- 42; 73 , pp. 1, 2; 72 , pp. 1, 2; 74 ; 75 ).

Sum of Distance

- Weighted Population Values: 1,456

Sum of Distance

- Weighted Population Values/10: 145.6 , rounded to 146 (Ref. 1, S ection 3.3.2.4)

Potential Contamination Factor Value: 14 6

3.3.3 RESOURCES

G round water resources have not been identified wit hin a 4

- mile radius of the CTS source ; therefore, a value of 0 was assigned for resources

.

Resources Value: 0

Distance Category

(miles) Number

of

Private

Wells Number of Community Wells Population per Distance Ring Distance Weighted Population

Value References

0

- 0.25 1 0 2 .33 4 1,

Table 3

- 12; 3;

71 , pp. 1

- 11;

70 , pp. 1

- 42;

73 , pp. 1, 2;

72 , pp. 1, 2;

74 ; 75 0.25

- 0.5 5 0 11.6 5 (5 private wells x 2.33) 11

0.5

- 1 115 0 2 67.95 (115 wells x 2.33) 52

1

- 2 1,107 2 (1 Homestead well ; 1 Christ School well) 2,780.81 ([ 1

, 107 private wells x 2.33]

+ 77 Homestead + 124.5 Christ School) 294

2

- 3 1,351 1 (Christ School well) 3,272.33 ([1

, 351 private wells x 2.33] + 124.5 Christ

School ) 678

3

- 4 1,804 0 4,203.3 2 (1,804 private wells x 2.33) 417Ground Water Migration Pathway

– Targets

59 3.3.4 WELLHEAD PROTECTION AREA

In North Carolina, community wells are protected under the wellhead protection program, and c ommunity wells are located

within a 4

- mile radius of the CTS property ; however, no source has been documented to lie above or within a wellhead protection area (Ref s

. 71 , p. 1 ; 81, p. 1 ). According to NCDENR’s Wellhead Protection Program, Wellhead Protect ion Areas exist in North Carolina; however, i t is unclear whether a designated wellhead protection area is present at the location of the

contaminated wells cited within this document (Ref s

. 71 , pp. 1

- 11 ; 81, p. 1 ) . The refore, a factor value of 0 was assi gned for wellhead protection area.

Wellhead Protection Area Value: 0