HRS DOCUMENTATION RECORD COVER SHEET

Name of Facility: CTS of Asheville, Inc.

EPA ID No. NCD003149556 

Contact Persons

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

Carolyn Callihan, Remedial Project Manager

(404) 562-8913

Jennifer 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 yields a score above the National Priorities List (NPL) cutoff value of 28.50. Contamination is 

documented in private drinking water wells. The surface water migration, air migration, and soil exposure pathways do 

not contribute significantly to the overall HRS score for the CTS site. 
1

HRS DOCUMENTATION RECORD

Name of Facility: CTS of Asheville, Inc.

EPA Region: 4 Date Prepared: March 2011 

Street Address of Facility*: 235 Mills Gap Road 

City, County, State, Zip: Asheville, Buncombe County, North 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 (Refs. 42 p. 6; Figure 4) 

The Global Positioning System (GPS) coordinates were collected from the easternmost building on the CTS property,

specifically the northeastern corner of the building. 

*The street address, coordinates, and contaminant locations presented in this Hazard Ranking System (HRS) 

documentation record identify the general area in 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 Priorities List (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 "deposited, 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 Water Pathway 97.28

Soil Exposure Pathway Not Scored

Surface Water Pathway Not Scored

HRS SCORE 48.64
2

WORKSHEET FOR COMPUTING HRS SCORE

 S S2 

1. Ground Water Migration Pathway Score (Sgw)

 (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 Water to Surface Water Migration Component

(from Table 4-25, line 28)

 NS NS 

2c. Surface Water Migration Pathway Score (Ssw)

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

 NS NS 

3. Soil Exposure Pathway Score (Ss)

(from Table 5-1, line 22)

 NS NS 

4. Air Migration Pathway Score (Sa)

(from Table 6-1, line 12)

 NS NS 

5. Total of Sgw2 + Ssw2 + Ss

2 + Sa2 9463.3984

6. HRS Score

Divide the value on line 5 by 4 and take the square root

 48.64 

NS - Not Scored

Reference 1, Table 3-1
3

GROUND 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 Precipitation 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. Toxicity/Mobility a 10,000

5. Hazardous Waste Quantity a 100

6. Waste Characteristics 100 32

Targets:

7. Nearest Well 50 50

8. Population:

8a. Level I Concentrations b 260

8b. Level II Concentrations b 0

8c. Potential Contamination b 146

8d. Population (lines 8a + 8b + 8c) b 406

9. Resources 5 0

10. Wellhead Protection Area 20 0

11. Targets (lines 7 + 8d + 9 + 10) b 456

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 (Sgw), (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

Do not round to nearest integer.
!(

CTS of Asheville, Inc.

82°28'0"W

82°28'0"W

82°28'30"W

82°28'30"W

82°29'0"W

82°29'0"W

82°29'30"W

82°29'30"W

82°30'0"W

82°30'0"W

82°30'30"W

82°30'30"W

82°31'0"W

82°31'0"W

82°31'30"W

82°31'30"W

82°32'0"W

82°32'0"W

82°32'30"W

82°32'30"W

35°31'0"N35°30'30"N35°30'0"N35°29'30"N35°29'0"N35°28'30"N35°28'0"N
Plating Area

Warehouse

Offices

Hazardous

Storage Area

Waste Pit

Main Plant

Dry

Room

Paint Curing Area
&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

&3

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A@

AA@@

A@

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!<

!<

&3

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!<

!<

BH-30ABH-30B

BH-30C

CTS-001-MW

MGGC-GW-01

MGGC-GW-03

MGGC-GW-17

TW-1

MW-4

MW-5

MW-7

MW-7A

MW-11B

MW-11A

MW-11

BH-13B

BH-14B

BH-15B

BH-16B

BH-17B

BH-18B

BH-19ABH-19BBH-19C

BH-20ABH-20BBH-20C

BH-21BBH-21C

BH-22ABH-22B

BH-22C

BH-23ABH-23B

BH-25BBH-25C

BH-26ABH-26B

BH-28B

BH-29B

BH-29C

BH-32A

BH-34B

Aerial By: Digital Globe
%, %,

%, %,

%,

%,

%,

%,

%,

%,

%,

%, %, %,

%, %,

*#*# *# *#

*#

*# *#

1/4 Mile Radius1/2 Mile Radius

1 Mile Radius

MW-PW-04MG-SSI-29CTS-019-PWSW-DW-01MG-PT-01A/-01B/-01C

MG-PW-03MG-SSI-34MG-PT-03A/-03B/-03C

MG-PW-15

MG-GMP4-09

9G1464PW9CTS-001-PWMG-SSI-119MG-PT-04A/-04B/-04CMG-PT-05A

MG-PT-02A/-02B/-02C

9G12979G1298

Latitude: 35° 29' 35.07" North Longitude: 82° 30' 21.43" West

9G1465PW2 9G1466

PW1

MG-GMP4-23

CTS-016-PW

CTS-018-PW

CTS-030-PW

CTS-031-PW

CTS-075-PW

MG-SSI-02

MG-PW-01

MG-SSI-02

MG-PW-05

MG-PW-06

MG-SSI-01

MG-GMP4-61

MG-SSI-04

.
8

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.]

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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 Carolina. 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 Miolen, OTIE. Project 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 Analysis 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 Remedial Investigation. 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 Services. 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. EPA, Superfund Technology Support Center for Ground Water. Ground Water Issue: TCE Removal from 

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 Corporation. 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 003149556. 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: Non-compliance documentation for CTS of Asheville, 

Inc. August 17, 2010. 20 pages. 

16. Amanda Miolen, OTIE. Project Note to File. Subject: Classification 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, Environmental 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, NUS Corporation. Letter with Attachments to A.R. Hanke, Waste 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 Greenberg, 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 pages.

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 site. 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. Fred 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 Rice, 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. 

Facsimile 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 20, 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. 36 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 Analysis 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 Plan, 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 & Associates, Inc. (TN&A). Letter with Attachments to David Dorian, OnScene 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-Scene 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: Subsurface Soil and Groundwater Sampling Report, Revision 1, Mills Gap, EPA ID No. A4P5. April 

23, 2008. 440 pages.

43. Ryan Stubbs, Project Manager, TN&A. Letter with Attachments to David Dorian, On-Scene Coordinator, EPA. 

Subject: Potable Well Sampling Letter Report, 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). 

November 20, 2008. 699 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 Callihan, Remedial Project 

Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 0, 1st Quarter 2009,

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

47. Ryan Stubbs, Project Manager, OTIE-TN&A. Letter with Attachments to Carolyn Callihan, Remedial Project 

Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 1, 2nd Quarter 2009,

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

48. Ryan Stubbs, Project Manager, OTIE. Letter with Attachments to Carolyn Callihan, Remedial Project 

Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 0, 3rd Quarter 2009,

Mills Gap Assessment. September 25, 2009. 550 pages. 

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, 4th Quarter 2009,

Mills Gap Assessment. February 1, 2010. 947 pages. 

50. Ryan Stubbs, Project Manager, OTIE. Letter with Attachments to Carolyn Callihan, Remedial Project 

Manager, EPA. Subject: Quarterly Drinking Water Well Sampling Letter Report, Revision 0, 5th Quarter 

February 2010, Mills Gap Assessment. July 21, 2010. 1,281 pages. 

51. Ken Woodruff, Project Leader, Lockheed Martin-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 and 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 Report. 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, 2011. 25 pages.

54. John T. Hack. Physiographic Divisions and Differential Uplift in the Piedmont and Blue Ridge. Geological 

Survey Professional 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 of 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 Report 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. Lockheed 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 

Reports. August 17, 2010. 196 pages. 

64. Environmental Data Resources, Inc. (EDR). The EDR Radius AtlasTM with GeoCheck®. Mills Gap: 274 Mills 

Gap Road, Asheville, NC 28803. Inquiry Number: 2355026.2s. November 3, 2008. 724 pages. 

65. James L. Cummins, Senior Vice President, Administration, CTS Corporation. Letter with Enclosures 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. Project 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 Project 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: Western North Carolina Regional Air Quality Agency

(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 Population 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 Specialist, OTIE. Project Note to File. Subject: Private well locations – Identification and 

Analysis 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 Miolen, OTIE. Project Note to File. Subject: Access Authorization forms for residences participating 

in the CTS of Asheville, Inc. sampling events. September 28, 2010. 361 pages. 

75. Becky Robinson. Declaration. Subject: Number of Full-time Residents 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 Logging Data 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, Pechiney 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 Report, 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. December 2, 2010. 1 page.

83. David Edgerton, Lockheed 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 the CTS 

property, specifically the northeastern corner of the building, are 35° 29' 35.07" North latitude, 82° 30' 21.43" West 

longitude (Figures 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 search to date (Ref. 6, pp. 2-3). A large, 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 an

8.65-acre parcel of level ground surrounded by a 6-foot, chain-linked fence topped with barbed wire (Refs. 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 southwest (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 Corporation (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 manufacturing (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 hearing 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, and 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

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

p. 6). Trichloroethene (TCE) was used in the process to clean and/or degrease metal objects prior to electroplating (Ref. 

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

p. 6). Between 1953 and 1980, wastes that could not be reclaimed from the electroplating 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 facility 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 drainage conduit lined with acid brick led from the plating area to a 2-foot by 2-

foot sump that drained to the Hazardous Waste Treatment Plant (HWTP) located south of the plating room(Ref. 9, p. 6). 

At the HWTP, the plating residues were reportedly removed, bagged, and disposed of by a CTS contractor (Ref. 9, p. 6). 

Several storage tanks were formerly located 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 associated pumps and piping, were located near the northwest corner of the building (Ref. 

9, p. 6). The ASTs and USTs have reportedly been removed by CTS personnel (Ref. 9, pp. 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 sources 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 Corporation 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 (Refs. 12, pp. 

1-5; 13, pp. 1-2). Information on the application included EPA 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 Management Branch (SHWMB) conducted a 

RCRA compliance inspection at CTS and found that no written schedule was available for inspection of safety and 
15

emergency equipment or security devices (Ref. 15, p. 16). CTS was notified of the violation on February 15, 1982 (Ref. 

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

On April 19, 1982, SHWMB accepted CTS’srequest 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 were 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 treatment 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. 11). 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, pp. 13, 14). The request was approved by SHWMB on 

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, Part B, permit application (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 the CTS facility and found noncompliance 

in several areas including the accumulation time of hazardous waste at the facility (Ref. 15, pp. 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, North Carolina Department of Human Resources (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 application, CTS sold all plating and process equipment to Arden 

Electroplating, Inc., on December 2, 1985; subsequently, the only hazardous waste generated by CTS was oil, acetone, 

and freon (Ref. 16, p. 8). On January 31, 1986, SHWMB accepted CTS’srequest 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 Site Assessment at the former 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 assessed the actual and potential environmental liabilities associated with the property (Ref. 

9, p. 5). During the evaluation, Law collected 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 associated 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 gravel 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 also stored in the tank, and oil staining was observed on the gravel pad and on the asphalt service road 
16

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 staining was observed 

by Law personnel along the base of the plant wall (Ref. 9, p. 14). Hazardous materials were formerly stored in a fenced 

area directly south of the facility (Ref. 9, p. 15). A 20-by-20-foot asphalt pad surrounded by a steel fence remained in 

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 area, 

compressor room, boiler room, hazardous storage area, the warehouse, and Hazard Waste Treatment pit were assessed 

during the 1987 investigation (Ref. 9, pp. 16-20). Details of the findings are discussed in the paragraphs below.

Plating operations were 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). Approximately one-third of the floor space is concrete, the other two-thirds is composed of acidresistant brick and masonry concrete (Ref. 9, p. 16). A 1-foot wide, acid brick-lined drainage spillway divides the room 

(Ref. 9, p. 16). Several small chemical storage areas were within the plating room, including 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 entered the plating area from the dye room and passed

beneath the concrete pad (Ref. 9, p. 17). An area where acid spilled from the tank and emptied into the drainage spillway 

was located west of the concrete pad (Ref. 9, p. 17). The concrete was dissolved in this area exposing the underlying soil 

(Ref. 9, p. 17). Acid brick was not utilized in the construction of the spillway in this 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 in the 

sump (Ref. 9, p. 17). 

Other rooms in the building included 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 starting at the northwest corner of the paint 

curing room led to the plating area (Ref. 9, p. 18). Several air compressor engines were located in a large room in the 

southern portion of the plant building (Ref. 9, p. 18). Oils used for lubrication were present in the drip collection pans 

(Ref. 9, p. 18). The boiler room was centrally located in the rear of the facility (Ref. 9, p. 19). The boiler had a one inch 

thick insulation coating of asbestos material that had 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 shipping 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 observed 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 used in manufacturing processes were stocked in this area prior to use (Ref. 9, p. 

19). A large waste pit was 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 was covered 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 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 were 
17

present throughout the 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 request 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 facility (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 facility and surrounding area (Ref. 13, p. 1). 

Based on targets and NUS’s findings, an SSI, Phase II, was recommended for CTS (Ref. 13, p. 3). 

On April 20, 1990, EPA documented a phone 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 water 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 (Refs. 21, pp. 1, 7; 22, p. 1). The 

Study 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 investigation (Ref. 21, pp. 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 water samples (Ref. 21, p. 6). Vinyl 

chloride, TCE, and 1,2-dichloroethene (1,2-DCE) were detected at concentrations of 47micrograms per kilogram (μg/kg), 

50 μg/kg and 330 μg/kg, respectively, in a surface water sample (Ref. 21, pp. 27, 33). Vinyl chloride (84 μg/kg) and 1,2-

DCE (29 to 1,100 μg/kg) were detected in sediment samples(Ref. 21, pp. 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 North Carolina Department of Environment and Natural Resources (NCDENR), Division of Water 

Quality (DWQ), was contacted regarding an oily leachate in a ditch on a property adjacent to CTS (Ref. 24, p. 6). At that 

time, NCDENR personnel collected samples from the ditch leachate and from two springs on the neighboring properties 

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

constituents were detected in a leachate sample (Refs. 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 (Refs. 24, p. 6; 26, pp. 3, 22; 27, p. 

3; 25, p. 16). The spring was used as a potable water 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 (Refs. 24, p. 6; 26, p. 3; 27, p. 2; 25, p. 11). At the time 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 (Refs. 24, p. 6; 27, p. 1). The residents currently obtain water 

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

On July 28, 1999, the NCDENR DWQ identified nine drinking water wells within 0.25-mile of CTS and subsequently 

sampled those wells for volatile organic compounds (VOCs) (Refs. 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) (Refs. 

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 (Refs. 24, p. 6; 28, pp. 6-

21). The NCDENR advised the residents not to use their well for drinking water (Ref. 24, p. 6). The NCDENR 

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, Inc., (CMC) was issued an emergency delivery order from EPA to coordinate actions needed 

to connect four residences to city or county water and to supply potable water as needed (Ref. 29, pp. 3-5, 6, 18). CMC 

responded to the emergency on August 21, 1999 (Refs. 29, pp. 10, 18; 30, p. 1). CMC provided the affected residences 

with potable water until a contracted plumber could begin installation of the city water lines to the residences (Ref. 29, p. 

18). On August 23, 1999, CMC received an additional delivery order to excavate contaminated soil from an impacted

creek near the CTS property (Ref. 29, p. 19). Soils were excavated, loaded into a dump truck, and transported off site for 
18

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 affected 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 November 11, 1999, 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, pp. 8, 10). The sampling locations were determined based on 

suspected areas of contamination, previous site investigations, and potential migration pathways (Ref. 4, pp. 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, pp. 8, 9). TCE and PCE were detected in surface and subsurface 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 well, sample PW9,

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

On August 14, 2000, through August 17, 2000, under EPA’s Response Engineering and Analytical Contract (REAC), 

Lockheed Martin conducted spring and sump sampling and a geophysical investigation with the EPA Environmental 

Response Team (ERT) (Ref. 32, pp. 1-3). Two springs located on the adjacent property, east of the CTS property, were 

sampled for VOCs, base neutral and acid extractables (BNAs), pesticides and polychlorinated 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). 

Approximately 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, pp. 3, 5, 27, 71). Cis-1,2-dichloroethene (cis-1,2-DCE) was present in both the upper spring and lower spring at 

concentrations of 330 μg/L and 400 μg/L, respectively (Ref. 32, pp. 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 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 soil 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 soil 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, was present 

beneath the CTS building (Ref. 33, p. 1). A direct 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, 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 900 μg/kg (30 to 31 feet bgsin 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 Management 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). During the site 
19

reconnaissance, it 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, pp. 2, 16-

17). There was a detectable 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, pp. 4, 9, 11). Surface water samples collected from 275/277 Mills Gap Road included four spring samples and 

one stream sample (Ref. 24, p. 9). Ground water samples were collected from each of the eight residential wells (Ref. 24, 

p. 9). In all surface water samples, TCE was present in concentrations above the National Primary Drinking Water 

Standards Maximum Contaminant Level (NPDWS MCL) of 5 μg/L (Ref. 24, pp. 13, 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, pp. 13, 18). Ground water samples did not exceed method detection limits for VOCs collected from 

the residential wells (Ref. 24, pp. 15, 22). 

From June 21, 2004 through July 1, 2004, MACTEC Engineering and Consulting, Inc., (MACTEC), on behalf of CTS 

Corporation and Mills Gap Road Associates, conducted sampling activities pursuant to an Administrative Order on 

Consent (AOC) for removal action between EPA, CTS Corporation, and the Mills Gap Road Associates (Refs. 7, pp. 2, 

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

objectives of the event (Ref. 35, pp. 1-83). Activities included collecting continuous soil samples from 28 boreholes 

drilled using direct push technology; three of which were developed into temporary piezometers and one was completed 

as a temporary monitoring well (Ref. 7, pp. 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 an SVE pilot test (Ref. 7, pp. 6, 20). A total of 54 

soil samples were collected and analyzed (Ref. 7, pp. 7, 20). Water samples were collected from five spring sampling 

locations previously identified and from the temporary well installed by MACTEC (Ref. 7, pp. 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 collected 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 September 

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 documented 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, pp. 1, 

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

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, pp. 16, 372). TN & Associates, Inc., (TN&A) on 

behalf of EPA, assisted 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 concentrations in surface water ranged from 1.31 to 18,000 μg/L (Refs. 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 (Refs. 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 (Refs. 38, p. 9; 39, pp. 206, 208, 210, 286, 389, 391). 
20

As part of the November 2007, sampling event, property owners with a well located within a one-mile radius of the 

property 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 from 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 (Refs. 40, p. 2; 41, p. 4). The well was re-sampled on December 14, 2007; three 

samples (two field samples plus duplicate) were collected from this location (Ref. 40, pp. 2-3, 5, 10-18). The analytical 

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

pp. 3, 10-18). Results for cis-1,2-DCE ranged from 9.65 to 9.95 μg/L (Ref. 40, pp. 3, 10-18). 

From December 12-14, 2007 and from January 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, pp. 10-11). Soil borings were advanced using a direct push drill 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. 11). TCE was not detected in the 

subsurface soil samples (Ref. 42, p. 15). Ground 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 TCE in five 

samples at concentrations ranging from 13 to 1,500 μg/L (Ref. 42, pp. 15-16, 22, 27, 29, 57, 59, 68, 74, 199, 258, 272, 

426, 428, 438). Sample MGGC-GW-01, located approximately 250 feet north of the CTS building on the CTS property,

contained the 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, pp. 15-16, 22, 27, 29, 57, 272, 428).

During the week of June 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 (Refs. 3; 43, pp. 1-2). Fifteen residential wells were 

sampled for VOCs (Ref. 43, pp. 1, 2). The analytical results indicated the presence 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 (Refs. 43, pp. 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, pp. 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 collect 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 installation of eight overburden 

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

Hazardous Substance List (HSL) metals, and cyanide (Ref. 8, pp. 9-10). Soil samples were required to be collected 

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 cyanide (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 wellslocated on the 

CTS property that were sampled for VOCs, SVOCs, 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, and 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 the 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 VOCs (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, 353, 363). 
21

On September 15 to 18, 2008, TN&A collected potable drinking water samples from 72 residences located within a onemile radius of the CTS facility, on behalf of EPA (Ref. 44, pp. 1, 3). A total of 82 potable drinking water samples, 

including nine field duplicates, were collected and submitted for analysis (Ref. 44, pp. 2-3). The analytical results 

indicated the presence of TCE in three potable 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, pp. 3, 14, 16, 

26, 378, 387-388, 471-472, 676-677, 679). PCE was also detected in one sample (Ref. 44, pp. 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, pp. 

28, 49, 54, 681).

On December 1, 2008, TN&A submitted the Quality Assurance 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, analytical results from the sampling eventsindicate the presence of several SVOCs, VOCs and metals; TCE was

not detected in the ground water samples (Refs. 46, p. 4; 47, p. 4; 48, p. 3; 49, p. 3; 50, pp. 4-6). No TCE breakdown 

compounds were detected (Refs. 46, p. 4; 47, p. 4; 48, p. 3; 49, p. 3; 50, pp. 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, pp. 3, 44). PCE was detected in the second quarter sampling, but not above the Method 

Reporting Limit (MRL) (Ref. 47, pp. 4, 24, 188).

In April of 2009, packer testing and private well sampling was conducted by Lockheed Martin Technology ServicesREAC on behalf of the EPA ERT (Ref. 51, pp. 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 sections 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 concentrations 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 concentrations 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 Ecosystem 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 included surface water, sediment, and soil sampling (Ref. 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 concentration 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 VOCs 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 VOCs 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 solids) of ground water 

samples collected from shallow fractures 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, isolation 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 fractures in select wells using the 

packer assemblage and analyzing the samples for VOCs 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 samples 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 VOCs were detected in any of the sediment samples 

collected (Ref. 83, pp. 10, 18, 24). No VOCs were detected in any surface water samples collected from the unnamed 

stream (Ref. 83, pp. 11, 19, 24). Toluene (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 the 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 operations at the CTS facility began in 1952 (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 

metal objects during degreasing (Ref. 7, p. 9). The plating room was centrally located within the back area of the plant 

building (Ref. 9, p. 6). A 1-foot deep drainage conduit lined with acid-brick led from 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 treatment 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, pp. 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, pp. 11, 32). 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 concentrations 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, 1999, Tetra Tech EM, Inc., under EPA’s Superfund Technical 

Assessment and Response Team (START) 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 determined 

based on suspected areas of contamination, previous site investigations, and potential migration pathways (Ref. 4, pp. 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 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, pp. 8-9). TCE and PCE were detected at elevated concentrations in surface and 

subsurface soil and sediment 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 excavation 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 soils, 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 soil 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). 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). 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 
Source 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 feet 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 (Refs. 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). Activities included collecting 

continuous soil samples from 28 boreholes drilled using a direct push; three of which were developed into temporary 

piezometers 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 samples was collected and analyzed (Ref. 7, pp. 7, 20). 

Location of the source, with reference to a map of the facility:

Contaminated soil coversthe majority of the CTS facility property and includes the soil beneath the building. See Figure 

3 of this documentation record for sample locations.

Containment:

Release to ground water: No 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 Water Containment Factor Value: 10

Reference: 1, Section 3.1.2.1, Table 3-2
Source Hazardous Substances

Source No. 1

25

2.4 Waste Characteristics

2.4.1 Hazardous Substances

The investigation detailed below includes 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 collected 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, were 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 designated 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 included collecting continuous soil 

samples using direct push technology (Ref. 7, pp. 6, 19, 48, 49). All samples were submitted to Shealy Environmental 

Services Laboratory for target compound list (TCL) VOC analysis by EPA Method 8260B (Ref. 7, p. 22, 50). All 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 Evaluating 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

BH-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, 

TCE 7.9 ND 7.9 512

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

PCE - Tetrachloroethene (Tetrachloroethylene)

PQL - Practical Quantitation Limit

TCE - Trichloroethene (Trichloroethylene)

μg/kg - Micrograms per kilogram
Source 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 180 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 (Dichloroethylene)

ID - Identification

PQL - Practical Quantitation Limit

PCE - Tetrachloroethene (Tetrachloroethylene)

TCE - Trichloroethene (Trichloroethylene)

μg/kg - Micrograms per kilogram

 

 
Source 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

PCE - Tetrachloroethene (Tetrachloroethylene)

PQL - Practical Quantitation Limit

TCE - Trichloroethene (Trichloroethylene)

μg/kg - Micrograms per kilogram

 
Source Hazardous Substances

Source No. 1

28

-Contaminated 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. 56, 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 

PQL - Practical Quantitation Limit

TCE - Trichloroethene (Trichloroethylene)

μg/kg - Micrograms per kilogram

List of Hazardous Substances Associated with Source 1:

TCE

PCE

Cis-1,2-DCE

Additional Supporting Data 

In addition to the 2004 MACTEC data, several investigations conducted at CTS at or within the vicinity of Source 1 

between 1987 and 2010 have further shown the presence of TCE and related VOCs in facility soils (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 calculate 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 Value (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 

contamination. 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 soilsamples that form the 

source area were collected during the 2004 MACTEC investigation (Ref. 7, pp. 1-667). The source area totals 43,859 feet 

square (ft2

) or 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 the 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 ft2 

/34,000 = 1.29

Area Assigned Value: 1.29

Reference: 1, Table 2-5

2.4.2.1.5 Source Hazardous Waste Quantity Value

Source Hazardous Waste Quantity Value: 1.29

Reference: 1, Section 2.4.2.2
Summary of Source Descriptions

30

SUMMARY OF SOURCE DESCRIPTIONS

Source 

No.

Source Hazardous 

Waste Quantity Value

Containment

Ground Water

Surface 

Water Soil

Air 

Gas 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, several storage 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 associated pumps 

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 it 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 

Province of the Appalachian Mountain system (Refs. 53, p. 1; 54). The Blue Ridge Highlands is characterized by a 

complex, irregular pattern of mountain ranges, intermontane basins, and trench valleys (Refs. 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 (Refs. 53, p. 1; 54). Contour levels between 2,300 and 2,400 feet of elevation define the upper surface of 

the basin (Refs. 53, p. 1; 54). It has a jagged, irregular border because intervening ridges from the adjacent highlands 

extend some distance into the basin (Refs. 53, p. 1; 54). Elevations in Buncombe County range from approximately 

1,720 feet above mean sea level to approximately 6,419 feet above mean sea level (Refs. 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 (Refs. 53, p. 1; 54). The mountains were subsequently 

uplifted and eroded to expose the rocks currently present at the surface (Refs. 53, p. 1; 54). The metamorphic rocks that 

comprise the mountains have a well-developed foliation that strikes predominantly northeast-southwest (NE-SW) (Refs. 

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 (Refs. 53, p. 1; 54). The majority of mountain ranges in the area have a northeast (NE) 

alignment generally following the regional strike (Refs. 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 Paleozoic granitic bodies underlie the far southeastern portion of the county and 

Mesoproterozoic meta-igneous units comprise the northwest portion (Refs. 53, p. 1; 56, p. 1). The rocks in the Asheville 

area are typically gneissic metagraywacke, schistose metagraywacke and schist, with lesser amphibolite, ultramafics and 

migmatite (Refs. 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 grade clastic metasediments (Refs. 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 quartztourmaline veins, and lesser zones of fault breccia and gouge (Refs. 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 Oteen (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 (Refs. 53, p. 5; 57, p. 4).

In 2010, the North Carolina Geological Survey (NCGS) mapped the geology of an approximate 4 square mile (mi2

) 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). 

Lithologic contacts and structural features are identified in the geologic map of the area developed by NCGS (Refs. 53, p. 

2; 57, p. 13). 

The NCGS defined three map units in the area based on the relative percentages of lithologies in outcrop: 

metagraywacke, amphibolite, and schistose metagraywacke (Refs. 53, p. 5; 57, p. 4). These lithologic units have 

undergone structural deformation that results in compositional layering, foliation, folds, 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 of 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 features 
Ground Water Migration Pathway Description

32

were identified 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

Regolith and fractured bedrock components comprise one aquifer system beneath the study area (Refs. 53, p. 8; 59). 

Recharge to the aquifer system occurs through 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 foliation- 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 geophysical mapping and data collection (Refs. 53, 

p. 8; 57; 59; 78). High-angle fractures allow water to seep into the rock, serving as recharge conduits (Refs. 53, p. 8; 59).

Discharge may occur along high-angle fractures near streams or other discharge boundaries (Refs. 53, p. 8; 59). Lowangle foliation-parallel partings connect high-angle recharging fractures (Refs. 53, p. 8; 59). Pumping of the private 

wells will alter the natural flow conditions in the area (Refs. 53, p. 8; 59).

Aquifer Components

Ground 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 much 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) the fractures serve as an intricate interconnected network of pipelines that transmit water either to springs or streams or 

to wells (Refs. 53, p. 8; 60).

Regolith Component

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 (Refs. 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 (Refs. 53, p. 8; 57, p. 4). The zone of overburden (i.e., regolith) 

determined from boreholes at the CTS facility ranges in thickness from 28 to 81 feet below ground surface (Refs. 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 weathered bedrock component (Refs. 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. Discontinuity 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, 

Section 3.0.1.2.2; 53, p. 8; 57). The weathered bedrock zone of the regolith exhibits enhanced weathering, mineral 

dissolution and secondary mineral precipitation along bedrock discontinuitiesincluding foliation, compositional layering, 

joints (fractures), and faults (Refs. 53, p. 9; 57, p. 4). Enhanced bedrock weathering, particularly along faults and joints, 

is observed in association with the MGFZ (Refs. 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 volcanics (Refs. 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 (Refs. 53, p. 9; 57, p. 3). Three map units 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 (Refs. 53, p. 9; 57, p. 4). The 
Ground 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 section 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 (Refs. 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 (Refs. 53, p. 9; 78, pp. 

17, 19).

Secondary features documented in bedrock within the MGFZ provide potential flow paths parallel to that zone’s W/NWE/SE trend (Ref. 53, pp. 8, 9). Outside the MGFZ, secondary features documented in bedrock throughout the mapped 

areas provide potential flow paths that are parallel a) to the regional strike of geologic map units, b) to the general strike 

of bedrock foliation, compositional layering and mylonitic foliation, and c) to the strike of quartz-tourmaline veins, all of 

which share a N/NE-S/SW strike (Refs. 53, p. 9; 78, pp. 1, 10). These two general groups of features in the Mills Gap 

Road area have developed and provide ground water flow pathways from the CTS plant property toward the E/SE and 

toward the N/NE for considerable distances (Refs. 53, p. 9). 

Planar bedrock discontinuities identified in the study area consist of foliation, mylonitic foliation, veins, joints (fractures), 

and faults (Refs. 53, p. 10; 57, p. 4). These bedrock discontinuities can be grouped into two main categories, ductile 

features or brittle features (Refs. 53, p. 10; 57, p. 4). Ductile features, such as foliations, mylonitic foliations and mineral 

elongation lineations, form when the rock is in a plastic state during metamorphism (Refs. 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 in the crust (Refs. 53, p. 10; 57, p. 4). Quartz and quartz-tourmaline veins show 

evidence of both ductile and brittle deformation (Refs. 53, p. 10; 57, p. 4). 

Foliation. The dominant planar bedrock discontinuity identified is a foliation produced and modified during one or more 

stages of regional, sillimanite-grade metamorphism (Refs. 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 to the rock 

in many exposures (Refs. 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 (Refs. 53, p. 11; 57, 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 of the MGFZ (Refs. 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 NESW strike trend to that of a WNW trend in those areas that are near the MGFZ (Refs. 53, p. 11; 57, p. 5). 

Mylonitic foliations outside of the MGFZ are prevalent and penetrative, and like foliations and compositional layering, 

predominantly strike in the N-NE direction (Refs. 53, p. 11; 57, p. 5). These closely spaced, low to moderately SEdipping mylonitic foliations realign and displace a pre-existing foliation (Refs. 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 (Refs. 53, p. 11; 57, p. 6). Most of these veins strike NNE, dip moderately to steeply to the NW or SE, and for the most part, occupy bedrock discontinuities that crosscut earlier

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

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) (Refs. 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 (Refs. 53, pp. 11-12; 57, p. 6). These veins are intersected and presumably offset by the fractures and 

faults associated with the MGFZ (Refs. 53, p. 12; 57, p. 6).

Faults. Faults of different orientations occur in the study area, but can be divided into two groups (Refs. 53, p. 12; 57, p. 
Ground Water Migration Pathway Description

34

6). Contractional thrust faults that strike N-NW to N-NE (Refs. 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 (Refs. 53; p. 12; 57, p. 6). 

Mills Gap Fault Zone. The WNW-trending 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 (Refs. 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 (Refs. 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 (Refs. 53, p. 12; 57, p. 6). 

The MGFZ can be traced for at least 5,500 feet west of the CTS property (Refs. 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 (Refs. 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 (Refs. 53, p. 12; 57, p. 6). The trends of these short lineaments appear to change from 

WNW orientations to those of an ENE orientation (Refs. 53, p. 12; 57, pp. 6, 7).

Although the MGFZ has not been traced to the ESE beyond the vicinity of Robinson Creek, joints associated with it 

occur beyond the mapped extent of the fault zone (Refs. 53, p. 13; 57, p. 7). Joints that have similar orientations to the 

MGFZ [azimuth 115-295o (+15o)], and the conjugate set [azimuth 85-265o (+15o)] occur beyond the mapped extent of the 

MGFZ (Refs. 53, p. 13; 57, p. 7). 

 

Joints measured in surface outcrops. The population of joints measured in surface outcrop by the NCGS is divided 

into six sets based on orientations (Refs. 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 (Refs. 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 outcropscale faults, n=80 (Refs. 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 (Refs. 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 NNE striking quartz and quartz-tourmaline veins (Refs. 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 with 

the MGFZ, n=37 (Refs. 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 NE-SW- striking bedrock layering and foliation, n=22 (Refs. 53, p. 14; 57, p. 8).

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

61-90o (Refs. 53, p. 14; 57, p. 8). An intermediate number of all joint groups have moderate dip angles that range from 

31-60o, followed by the fewest number of joints with shallow dip angles less than 30o (Refs. 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 geologists visited a relatively larger number of outcrops located within the MGFZ than they did outcrops

located outside the MGFZ (Refs 53, pp. 14, 15; 78, p. 4). As a result, it is useful to consider the statistics for brittle 
Ground 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 (joints, foliation, and lithologic contacts) measured in the eight wells logged by the USGS, along with available 

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

trends to the N/NE, striking from 0o to 30o

, 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 orientation 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 strikes, 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 relatively 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. 78, 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 fractures measured in the wells fall within the 25o & 205o category, which parallels N/NE regional foliation as 

described by the NCGS (2010) (Refs. 57, p. 8; 78, p. 18). From this same set of 272 steeply-dipping fractures, secondary 

joint groups delineated in the wells were a) 175o & 355o

, also parallel to regional foliation strike, and b) 115o & 295o,

 

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

Hydraulic Connection to Distant Receptors

A fracture 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, 18; 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 (Refs. 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 the pumping of the CHR well ceased in 

August, 2009, higher concentrations of contaminants 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 containing 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, an artesian well, Well 1, and AW-4, have a vertical flow direction that is upward.

In these two wells, TCE contamination is found in both shallow and deep packer intervals, consistent with upward flow 

transporting deep contamination into the shallow zone (Refs. 53, pp. 17-23; 78, pp. 26-34). Orientations of bedrock 

joints, foliations and lithologic contacts and of water-producing fractures not only provide for hydraulic connection 
Ground 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 show 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 orientations of discontinuities (joints, foliations and lithologic contacts) 

present (Ref. 53, pp. 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 property, 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). 

Numerous 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 Hill Church Road and in the Oaks subdivision (Refs. 53, pp. 4, 17-23; 78, pp. 23, 24). 

Within the Oaks Subdivision, the subsurface borehole geophysics have determined that all water bearing features are lowangle foliation parallel. These water bearing features provide for interconnection between the Oaks Subdivision wells.

(Refs. 53, p. 23; 78, p. 4). 

 

SUMMARY OF AQUIFER(S) BEING EVALUATED

Aquifer 

No. Aquifer Name

Is Aquifer Interconnected 

with Upper Aquifer 

within 2 miles? (Y/N/NA)

Is Aquifer 

Continuous within 4-

mile TDL? (Y/N)

Is Aquifer 

Karst? (Y/N)

1 Regolith/Fractured Bedrock NA Y N
Ground 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, an eventspecific background well was not designated. All private well samples were collected within a 1-mile radial distance 

from the source (Ref. 3). Like monitoring wells, background 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 Figure 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 accordance 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 System 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 Figures 3 and 4. 

Sample ID Date 

Collected

Hazardous 

Substance

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 Cis-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, 280
Ground Water Migration Pathway – Likelihood of Release

38

Sample ID Date 

Collected

Hazardous 

Substance

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. 41, 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 11/28/2007 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

MG-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, 712, 930

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

Notes: μg/L - Micrograms per liter

DCE - Dichloroethene/dichloroethylene

GMP4 - Ground Water Monitoring Program 4th Quarter

J - Estimated value

MG - Mills Gap

MDL - Method Detection Limit

MRL - Minimum Reporting Limit

PW - Potable well

QL - Quantitation Limit

RL - Reporting Limit

 SSI - Special Studies Investigation

 TCE - Trichloroethylene/trichloroethylene

 TQL - Target Quantitation Limit

 U - Constituent analyzed for but not detected

Monitoring Well Samples

The investigations below detail ground water samples collected from monitoring wells near CTS with elevated levels of 

TCE and/or its breakdown products.

- 2004 Site Investigation (MACTEC) 

In June 2004, MACTEC collected a ground water sample from a temporary monitoring well 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 analysis by 

EPA Method 8260B (Ref. 7, p. 275). QA/QC information is provided in Reference 7. 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. 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. See Figure 
Ground 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, Spring02 6/23/2004 7, pp. 22, 43, 51, 80, 275, 286

Notes:

bgs - Below ground surface

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, pp. 80, 275, 286

Notes:

ID - Identification

PQL - Practical Quantitation Limit

TCE - Trichloroethene/trichloroethylene

TW - 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 samples 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 analysis 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 products 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 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 

MW - Monitoring well

 
Ground 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 1,500 100 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 (trichloroethylene)

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 ERT 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, pp. 27, 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 (Refs. 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 3 of 

this Documentation Record for sample locations.

Sample ID

Total Depth 

(feet 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 liter

 

 
Ground Water Migration Pathway – Likelihood of Release

41

- 2009 Phase I Remedial Investigation (MACTEC)

As part of 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 EPA 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). MACTEC 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 (Refs. 

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 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 

building 10/10/2008

8, pp. 50, 53, 73, 207, 208, 

222 

Notes:

bgs - Below ground surface 

ID - Identification

Sample ID

Hazardous 

Substance Concentration (μg/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

MDL - Method Detection Limit 

MW - Monitoring 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 References

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, 325
Ground Water Migration Pathway – Likelihood of Release

42

Sample ID Total Depth 

(feet)

Screened 

Interval 

(feet bgs)

Depth to 

Water

(feet) Sample Location Date Sampled References

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 - Monitoring 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. 73, 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 

(feet)

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 ground 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:

DCE - Dichloroethene/dichloroethylene 

ID - Identification

MDL - Method Detection Limit 

MW - Monitoring well

 TCE - Trichloroethene/trichloroethylene

 μg/L - Micrograms per liter
Ground Water Migration Pathway – Likelihood of Release

43

Private Well Samples

The investigations 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 (Refs. 25, pp. 1, 3; 28, p. 1). Samples were collected according to NCDENR SOPs. The 

samples below were submitted to the NCDENR DWQ Laboratory for several analyses including TCL VOCs (Refs. 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, surface water, and ground water are primarily a result of industrial spillage 

during manufacture or use (Refs. 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)

TQL

(μg/L) References

9G1464 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 Limit 

PW - Potable well

M - GC/MS analysis performance

DCE - Dichloroethene/dichloroethylene

 TCE - Trichloroethene/trichloroethylene

-May 2000 Ground Water Sampling (NCDENR)

In May 2000, NCDENR collected ground water samples from private residential wells in the CTS area (Ref. 31, pp. 1-

36). Samples were collected according to NCDENR SOPs. Samples were submitted to PDP for TCL VOCs analysis 

(Ref. 31, p. 19). QA/QC information 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-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)

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 in accordance with the EPA SESD Region 
Ground 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 8260B (Ref. 39, p. 384). QA/QC information is provided in Reference 39. TCE is a non-ubiquitous manmade substances, and contamination of land, air, surface water, and ground water are primarily a result of industrial 

spillage during manufacture or use (Refs. 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)

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 - Quantitation Limit 

PW - Potable well

TCE - Trichloroethene/trichloroethylene

-December 2007 Private Well Sampling (TN&A and NCDENR)

In December 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 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 information is provided in Reference 39. 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 (Refs. 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)

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, Inc., 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 (Refs. 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-DCE 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 wellsin 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 during manufacture or use (Refs. 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)

MDL

(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 Water Sampling (TN&A)

In September 2008, TN&A START personnel collected ground water samples from private residential wellsin the CTS 

area (Ref. 44, p. 3). Procedures 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 laboratoriesfor TCL VOCs by CLP Statement of Work 

(SOW) for Multi-Media, Multi-Concentration Organics 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, surface water, and ground water are 

primarily a result of industrial spillage during manufacture or use (Refs. 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 
Ground Water Migration Pathway – Likelihood of Release

46

this Documentation Record for sample locations.

Sample ID Hazardous Substance

Concentration 

(μg/L)

MRL

(μg/L) References

MG-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 Ground Water Sampling (REAC)

In April 2009, REAC collected ground water samples from private residential wells in the CTS area (Ref. 51, p. 1, 18, 

19). Samples were collected in accordance with the REAC QAPP (Ref. 62). Samples were submitted to DataChem 

Laboratories, Inc., for TCL VOCs by CLP SOW SOM01.2 (Ref. 51, p. 16). QA/QC information is provided in 

Reference 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 (Refs. 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-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, pp. 13, 36

TCE 52 2.5 51, pp. 13, 37
Ground 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, pp. 13, 38

TCE 57 2.5 51, pp. 13, 39

MG-PT-01C Cis-1,2-DCE 17 0.50 51, pp. 13, 40

TCE 54 2.5 51, pp. 13, 41

MG-PT-03B TCE 9 0.50 51, pp. 12, 43

MG-PT-03C Cis-1,2-DCE 1.7 0.50 51, pp. 12, 44

TCE 18 0.50 51, pp. 12, 45

Notes:

μg/L - Micrograms per liter

DCE - Dichloroethene/dichloroethylene

ID - Identification

MG - Mills Gap 

MRL - Minimum Reporting Limit

PT - Packer Test

 TCE - Trichloroethene/trichloroethylene

 

-October 2009 Ground Water 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, pp. 1, 2). Sampling was conducted in accordance with the 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 spillage during manufacture 

or use (Refs. 10, p. 1; Figure 4). Cis-1,2-DCE is a degradation product of TCE (Ref. 61, p. 4). Additionally, nondetectable 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/dichloroethylene

ID - Identification

GMP4 - Ground Water Monitoring Program 4th Quarter

MG - Mills Gap

MRL - Minimum Reporting Limit 

 TCE - Trichloroethene/trichloroethylene
Ground 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; trans1,2-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), until 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 the 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, including 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 location, 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 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). The pit was covered 

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 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 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 and 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 Environmental 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, exposing 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 (Refs. 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 drinking 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 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 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 samples 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 throughout 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 Mills Gap Road Associates (Refs. 7, pp. 6, 9; 34, p. 2). Activities included 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-34B (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, pp. 42, 89). Samples BH-20C and BH-22C were located underneath the building, east of the building’s 

center (Ref. 7, pp. 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 estimated 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 Resources, 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 radial 

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 Action Planned (CERC-NFRAP) sites;

RCRA-Large Quantity Generators (LQG) sites; RCRA-Small Quantity Generators (SQG) sites; Resource Conservation 

and Recovery Act Conditionally Exempt Small Quantity Generators (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 review 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 businesses 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 hazardous 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 reports, 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 northwest of the CTS property (Refs. 64, pp. 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 contained gasoline, fuel oil, n-propyl acetate, heptane, ethyl acetate, ethyl alcohol, toluene and methylethyl 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). Ground water sampling at the 

facility 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). Trace levels of VOCs had been detected in soil 

samples on the property prior to Alcan ownership (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 determine the presence or absence of 

contamination.

• Conner Motors

Conner Motors 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 generator of halogenated 

solvent waste, including PCE and TCE (Ref. 64, p. 58-60). However, no 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 documentation 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). According 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 previous 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, fractures, shear zones, faults and other (geologic) 

discontinuities (Ref. 53, p. 22). 

3. The contaminant distribution in the Oaks Subdivision wells in which borehole geophysics and packer 

testing were performed showed increasing TCE concentrations with depth indicating 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 MGFZ) 

that together form a pathway of interconnected features for contaminated ground water, known 
Ground 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 in 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 outcrops 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 within the MGFZ, and are also biased in that respect. The two sets of orientation data 

are not inconsistent with one another, but rather are complimentary, and together support the 

above conclusions (Ref. 53, p. 23).

Electroplating operations have been conducted at the CTS property since 1952 (Ref. 7, p. 9). As referenced above, TCE 

and other solvents have been tied to CTS operations since 1980, and have been detected in soils and ground water at the 

facility since 1987. 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 monitoring, temporary, and/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 scored is at least partially 

attributable to CTS.

Hazardous Substances Released:

cis-1,2-DCE

PCE

TCE

Vinyl Chloride

Ground Water Observed Release Factor Value: 550
Ground Water Migration Pathway – Waste Characteristics

52

3.2 WASTE CHARACTERISTICS

3.2.1 TOXICITY/MOBILITY

Hazardous 

Substance

Source 

No.

Toxicity 

Factor 

Value

Mobility 

Factor 

Value Toxicity/Mobility

Does Hazardous 

Substance Meet 

Observed Release by 

chemical analysis? 

(Y/N) References

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/Mobility 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 constituent 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 Value: 10,000

Hazardous Waste Quantity Factor Value: 100

Toxicity/Mobility Factor Value (10,000) X 

Hazardous Waste Quantity Factor Value (100) = 1,000,000

 

Waste Characteristics Factor Category 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 combination 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 Source 1 (Refs. 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 wells. 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; therefore, 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 (Refs. 71, pp. 1-11; 82, p. 1). Therefore, 16.5 

connections and 124.5 persons are served by 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 (Refs. 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 source (Refs. 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 radius (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). Seven 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 

(μg/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 MCL

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, 49
Ground Water Migration Pathway – Targets

56

Sample ID Hazardous 

Substance

Hazardous

Substance 

Concentration 

(μg/L)

Benchmark 

Concentration 

(μg/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

MCL - Maximum Contaminant Level

PW - Potable well

 TCE - Trichloroethene/trichloroethylene
Ground 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 well) 1 3 Refs. 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

Refs. 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

Refs. 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

Refs. 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

Three community wells exist within 1 to 3 miles from CTS (Refs. 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(Refs. 3;

71, pp. 1, 2, 4, 5). The two community wells located at the Christ School serve 33 connections and a combined population of 

249. One of the Christ School wells islocated in the 1 to 2 mile radius and the other is located in the 2 to 3 mile radius (Refs.

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 well 
Ground 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 of municipal water and 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 10,228.70 persons obtain drinking water from private wells within the 4-mile radius (4,390 private 

wells x 2.33 persons per household = 10,228.70 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 

calculated 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 persons (1 private well); 0.25- to 0.5-mile, 11.65 persons (5 private wells); 0.5-

to 1-mile, 267.95 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, 4,203.32 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, Section 3.3.2.4)

Potential Contamination Factor Value: 146 

3.3.3 RESOURCES

Ground water resources have not been identified within 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

11.65 

(5 private wells x 2.33) 11

0.5 - 1 115 0

267.95

(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

4,203.32

(1,804 private wells x 

2.33) 417
Ground Water Migration Pathway – Targets

59

3.3.4 WELLHEAD PROTECTION AREA

In North Carolina, community wells are protected under the wellhead protection program, and community 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 (Refs. 71, p. 1; 81, p. 1). According to NCDENR’s Wellhead Protection Program, Wellhead Protection Areas 

exist in North Carolina; however, it is unclear whether a designated wellhead protection area is present at the location of the 

contaminated wells cited within this document (Refs. 71, pp. 1-11; 81, p. 1). Therefore, a factor value of 0 was assigned for 

wellhead protection area. 

Wellhead Protection Area Value: 0