PB99-964010
EPA541-R99-050
1999
EPA Superfimd
Record of Decision:
Aberdeen Pesticide Dumps OU 5
Aberdeen, NC
6/4/1999
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RECORD OF DECISION
ABERDEEN PESTICIDE DUMPS SITE
OPERABLE UNIT 5
Mclver Dump and Route 211 Areas
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA, GEORGIA
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RECORD OF DECISION
ABERDEEN PESTICIDE DUMPS SITE
OPERABLE UNIT 5
Mclver Dump and Route 211 Areas
June 1999
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA, GEORGIA
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TABLE OF CONTENTS
Description Page
DECLARATION FOR THE RECORD OF DECISION i
DECISION SUMMARY 1
1.0 SITE NAME, LOCATION, AND DESCRIPTION 1
1.1 Mclver Dump Area 1
1.2 Route 211 Area , 3
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
3.0 COMMUNITY PARTICIPATION HIGHLIGHTS 4
4.0 SCOPE AND ROLE OF RESPONSE ACTION 4
5.0 SUMMARY OF SITE CHARACTERISTICS 5
5.1 Topography and Surface Drainage 5
5.1.1 Mclver Dump Area 5
5.1.2 Route 211 Area 5
5.2 Geology . 8
5.2.1 Mclver Dump Area 8
5.2.2 Route 211 Area 8
5.3 Hydrogeology 9
5.3.1 Mclver Dump Area 9
5.3.2 Route 211 Area 11
5.4 Nature and Extent of Contamination Overview 15
5.4.1 Mclver Dump Area 15
5.4.1.1 Groundwater 15
5.4.1.2 Surface Water and Sediments 16
5.4.2 Route 211 Area 16
5.4.2.1 Groundwater 16
5.4.2.2 Surface water and Sediments . . . 19
6.0 SUMMARY OF SITE RISKS 21
6.1 Data Evaluation 21
6.2 Chemicals of Concern 21
6.3 Exposure Assessment 27
6.4 Toxicity Assessment 30
6.5 Risk Characterization 31
6.5.1 Mclver Dump Area 34
6.5.2 Route 211 Area 34
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TABLE OF CONTENTS
Description
Page
7.0 REMEDIATION OBJECTIVES ......................
7. 1 Mclver Dump Area ......... ............... ....... 4n
7.2 Route 21 1 Area ........... ............... ......................... 40
7.3 Clean up Goals for Mclver Dump and Route 21 1 Areas . . . ......... ....... 41
8.0 DESCRIPTION OF REMEDIAL ALTERNATIVES
8. 1 Mclver Dump Area ................... ........................ 41
8.1.1 Alternative 1 ............. '..... .................. ......... 41
8.1.2 Alternative 2 ............. '.'.'.'.'.'.'.'.'.'.'.'. ...................... 43
8.1.2.1 Description of Alternative 2 Components ......... ..... 43
8. 1.2.2 Other Features of Alternative 2 ............ '.'.'.'.'.'.'.'. 44
8.1.2.3 Expected Outcomes of Alternative 2 44
8.1.3 Alternative 3 ........................... .................. 44
8.1.3.1 Description of Alternative 3 Components ....... ['.'.'. ...... 45
8.1.3.2 Other Features of Alternative 3 ............ ." . . ........ 46
8.1.3.3 Expected Outcomes of Alternative 3 47
8.1.4 Alternative 4 ......................... ............... 4?
8.1.4.1 Description of Alternative 4 Components ....... ......... 47
8.1.4.2 Other Features of Alternative 4 ........... '.'.'.'.'.'.'.'.'. 52
8.1.4.3 Expected Outcomes of Alternative 4 ........ ''<?
8.2 Route 211 Area ................ .................... *
8.2.1 Alternative 1 ....... .... ...................................
8.2.2 Alternative 2 .......... .............. ...................... 57
8.2.2.1 Description of Alternative 2 Componenets ........ ...... 57
8.2.2.2 Other Features of Alternative 2 ............. . . ..... 59
8.2.2.3 Expected Outcomes of Alternative 2 ........ so
8.2.3 Alternative 3 ..................... .................... *
8.2.3.1 Description of Alternative 3 Components ...... ....... 59
8.2.3.2 Other Features of Alternative 3 ............ ....... ..... 61
8.2.3.3 Expected Outcomes of Alternative 3 ..... <9
8.2.4 Alternative4 ................... " " ................ ฃ
8.2.4.1 Description of Alternative 4 Components ..... ........ 62
8.2.4.2 Other Features of Alternative 4 ........... ..." ......... 65
8.2.4.3 Expected Outcomes of Alternative 4 ....... ....... ...... 65
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 6o
9.1 Threshold Criteria ..................... .............. *
9.1.1 Overall Protection of Human Health and the Environment ......... " 69
9.1.2 Compliance with Applicable or Relevant and Appropriate Requirements '
M
(ARARs)
9.2 Primary Balancing Criteria
9.2.1 Long-Term Effectiveness and Permanence
'
70
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TABLE OF CONTENTS
Description Page
9.2.2 Reduction of Contaminant Toxicity, Mobility, and Volume 71
9.2.3 Short-Term Effectiveness 71
9.2.4 Implementability 72
9.2.5 Cost 73
9.3 Modifying Criteria 74
9.3.1 State Acceptance 74
9.3.2 Community Acceptance 74
10.0 THE SELECTED REMEDY 74
10.1 Description of the Selected Remedy 74
10.1.1 Mclver Dump Area 74
10.1.1.1 Description of the Selected Remedy 75
10.1.1.2 Other Features of the Selected Remedy 76
10.1.1.3 Expected Outcomes of the Selected Remedy 76
10.1.2 Route 211 Area 76
10.1.2.1 Description of the Selected Remedy 77
10.1.2.2 Other Features of the Selected Remedy 79
10.1.2.3 Expected Outcomes of the Selected Remedy 79
11.0 STATUTORY DETERMINATIONS 79
11.1 Overall Protection of Human Health and the Environment 80
11.2 Compliance with Applicable or Relevant and Appropriate Requirements 80
11.3 Cost Effectiveness 81
11.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable 81
11.5 Preference for Treatment as a Principal Element 82
11.6 Five-Year Review Requirement 82
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - STATE CONCURRENCE
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LIST OF FIGURES
Description Page
Figure 1 - Mclver Dump and Route 211 Areas Location Map 2
Figure 2 - Topography and Surface Drainage Mclver Dump Area 6
Figure 3 - Topography and Surface Drainage Route 211 Area 7
Figure 4 - Sample Locations and Analytical Test Results Mclver Dump Area 10
Figure 5 - Sample Locations and Analytical Test Results Surficial Aquifer Route 211 Area ... 13
Figure 6 - Sample Locations and Analytical Test Results Upper portion of the
Upper Black Creek Aquifer Route 211 Area . : 14
Figure 7 - Sample Locations and Analytical Test Results Lower portion of the
Upper Black Creek Aquifer Route 211 Area 18
Figure 8 - Sample Locations and Analytical Test Results Lower Black Creek Aquifer
Route 211 Area 20
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LIST OF TABLES
Description Page
Table 1 - Chemicals of Concern Mclver Dump Area 22
Table 2 - Chemicals of Concern Route 211 Area 23
Table 3 - RME Concentrations for Chemicals of Concern Mclver Dump Area ..24
Table 4 - RME Concentrations for Chemicals of Concern Surficial Aquifer
Route 211 Area 25
Table 5 - RME Concentrations for Chemicals of Concern Upper and
Lower Black Creek Aquifers Route 211 Area 26
Table 6 - Site Conceptual Model Mclver Dump Area . . 28
Table 7 - Site Conceptual Model Route 211 Area 29
Table 8 - Cancer Slope Factors Chemicals of Concern 32
Table 9 - Reference Doses Chemicals of Concern 33
Table 10 - Summary of Cancer and Non-cancer Risks Current Use Scenario
Mclver Dump Area 35
Table 11 - Summary of Cancer and Non-cancer Risks Future Use Scenario
Mclver Dump Area 36
Table 12 - Summary of Cancer and Non-cancer Risks Future Use Scenario
Surficial Aquifer Route 211 Area 38
Table 13 - Summary of Cancer and Non-cancer Risks Future Use Scenario
Upper and Lower Black Creek Aquifers Route 211 Area 39
Table 14 - Clean up Goals for Mclver Dump and Route 211 Areas 41
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Aberdeen Pesticide Dumps Site
Operable Unit Five (OU5)
EPA ID # -NCD980843346
Groundwater at Route 211 and Mclver Dump Areas
Moore County, Aberdeen, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedy for OU5 (groundwater) at the Mclver
Dump and Route 211 Areas of the Aberdeen Pesticide Dumps Site (the Site) in Aberdeen, North
Carolina, which was chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfimd Amendments
and Reauthorization Act of 1986 (SARA), and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the
Administrative Record for OU5.
The State of North Carolina concurs with the selected remedy.
Assessment of the Site
The response action selected in this Record of Decision (ROD) is necessary to protect the public
health or welfare or the environment from actual or threatened releases of hazardous substances
into the environment.
Description of the Selected Remedy
The major components of the selected remedy for OU5 are:
Mclver Dump Area
Monitoring of natural attenuation in groundwater, surface water and sediments;
Phytoremediation to enhance natural attenuation processes;
Area reconnaissance; and
Alternative water supply/well head treatment if future potential receptors are identified.
Route 211 Area
Groundwater extraction from "source area groundwater" in the Surficial aquifer;
Treatment of groundwater via carbon adsorption;
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Discharge of treated groundwater via re-injection infiltration galleries;
Monitoring of the extraction, treatment and discharge systems;
Monitoring of natural attenuation in all aquifers;
Area reconnaissance;
Alternative water supply/well head treatment if future potential receptors are identified.
Statutory Determinations
The selected remedy is protective of human health and the environment, complies with Federal
and State requirements that are applicable or relevant and appropriate to this remedial action, is
cost-effective, and utilizes permanent solutions and alternative treatment technologies to the
extent practicable. This remedy also satisfies to the extent practicable the statutory preference for
treatment as a principal element of the remedy. Because this remedy will result in hazardous
substances remaining on-site above health-based levels for a relatively long period of time, a
review will be conducted within five years after initiation of the remedial action and every five
years thereafter until remediation goals are achieved, to ensure that the remedy continues to
provide adequate protection to human health and the environment.
Data Certification Checklist
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the administrative record for this site.
Chemicals of concern (COCs) and their respective range of concentrations
Baseline risks represented by the COCs
Cleanup levels established for COCs and the basis for the levels
Current and future groundwater use assumptions used in the baseline risk assessment and ROD
Groundwater use that will be available at the site as a result of the selected remedy
Estimated capital, operation and maintenance (O&M), and total present worth costs; and the
number of years over which the remedy cost estimates are projected
Decisive factors that led to selecting the remedy
Richard D. Green
Director
Waste Management Division
Date
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Aberdeen OU5
Pagel
RECORD OF DECISION
DECISION SUMMARY
INTRODUCTION
The Aberdeen Pesticides Dumps Site (the Site) encompasses approximately 10.57 square miles of
mostly rural property spread over five non-contiguous areas. The five non-contiguous areas
comprising the Site are identified as the Farm Chemicals Area, the Twin Sites Area, the Fairway
Six Area, the Mclver Dump Area and the Route 211 Area.
The subject of this Record of Decision (ROD) is Operable Unit 5 (OU5); which is EPA's
designation to address groundwater, surface water, and sediment media at the Mclver Dump and
Route 211 Areas.
1.0 SITE NAME. LOCATION. AND DESCRIPTION
Aberdeen Pesticide Dumps Site
EPA ID Number - NCD980843346
Operable Unit Five (OU5)
Groundwater at Mclver and Route 211 Areas
Aberdeen, Moore County, North Carolina
1.1 Mclver Dump Area
The Mclver Dump Area (Figure 1) is located approximately 0.5 miles north of the junction of
SRI 112 (Roseland Road) and SRI 106, west of the town of Aberdeen in Moore County. The
Mclver Dump Area formerly consisted of two subareas, area B and area C, and a soil stockpile.
Materials, some of which contained pesticides, were discovered at both areas B and C. At area B,
pesticides were removed in 1985 by EPA and disposed at the GSX facility located in Pinewood,
South Carolina. In 1989 at area C, approximately 3,200 cubic yards of materials and soils were
removed by an EPA Emergency Response Team and stockpiled on an impermeable liner located
near area C. In late 1997, the potentially responsible parties (PRPs) excavated soils containing
pesticide residuals from both areas B and C (approximately 12,828 tons). The excavated soils and
the soils stockpile were transported to a thermal desorption unit for treatment. Treated soils were
returned to the Mclver Dump Area and used for clean fill. As a result of these remedial activities
under separate RODs, known sources of pesticides have been removed from the Mclver Dump
Area and, therefore, no future impacts to groundwater and/or surface water are anticipated.
Additionally, significant erosion control measures have been constructed at the Mclver Dump
Area to control drainage to Patterson Branch, a stream to the north of the former source areas.
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ROD
Aberdeen OU5
Topsoil has been place over the area, which has been seeded and fertilized to promote growth of
stabilizing vegetation.
1.2 Route 211 Area
The Route 211 Area (Figure 1) is located approximately 1,000 feet southwest of highway Route
211 East and adjacent to the Aberdeen & Rockfish Railroad. It is approximately one mile east of
the Town of Aberdeen. The Route 211 Area formerly contained an old sand mining basin
approximately 80 feet across and 8 to 20 feet deep. Materials, some of which contained
pesticides, were discovered in a waste pile on the southwest slope of the pit. In 1986,
approximately 100 cubic yards of pesticides and associated soil were removed by EPA and
disposed at the GSX facility in Pinewood, South Carolina. In 1989, approximately 200 cubic
yards of similar material was discovered by EPA and subsequently removed, placed in the
stockpile at the Mclver Dump Area, and later treated by thermal desorption. In late 1997, the
PRPs excavated and transported additional soils containing pesticides to a thermal desorption unit
for treatment (approximately 3,464 tons). Treated soils were then returned to the Route 211
Area for use as clean fill and the entire pit at the area was filled. Following regrading of the
Route 211 Area, pinestraw was applied to prevent erosion and stabilize the soil. Surface runoff in
the immediate vicinity of the Route 211 Area flows away from the former source area. All the
soil remediation work described above was performed under a separate ROD.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 Site History and Enforcement Activities
The main PRPs identified for the Mclver Dump and the Route 211 Areas are Novartis Crop
Protection, Inc. (formerly Ciba-Geigy Corporation), and Olin Corporation. During their operation
of a pesticide formulation plant on Route 211 (the Geigy Chemical Plant) east of the Town of
Aberdeen, corporate predecessors to the PRPs used the Mclver Dump and Route 211 Areas for
disposal of wastes from that plant. These wastes contained pesticide and pesticide constituents.
On March 31, 1989, pursuant to Section 105 of CERCLA, 42 U.S.C. ง 9605, EPA placed the
Site on the National Priorities List, set forth at 40 C.F.R. Part 300. The Mclver Dump and Route
211 Areas are two of the five non-contiguous areas comprising the Site.
In response to a release or substantial threat of release of hazardous substances at or from the
Site, EPA commenced on June 30, 1987, a Remedial Investigation and Feasibility Study (RI/FS)
for the Site, including the Mclver Dump and Route 211 Areas. EPA completed its initial
Remedial Investigation (RI) at the Site on April 12, 1991. During that investigation, EPA
determined that the surface water, groundwater, and sediments at the Site required further
investigation. EPA designated the groundwater at all five Areas as Operable Unit Three (OU3).
EPA conducted further investigation of OU3 and completed a Feasibility Study concerning OU3
on May 3, 1993. During that study, EPA determined that further investigation of the
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ROD
Aberdeen OUS
Page 4
groundwater at the Mclver Dump and Route 211 Areas was necessary. EPA designated the
groundwater at those two Areas as OUS.
Effective March 21, 1994, the PRPs entered into an Administrative Order on Consent (AOC) with
EPA concerning performance of the RI/FS for OUS. On September 16, 1997, EPA issued an
interim action ROD for the Route 211 Area to start pumping and treating groundwater containing
the highest concentrations of pesticides.
3.0 COMMUNITY PARTICIPATION HIGHLIGHTS
Pursuant to CERCLA ง113(k)(2)(B)(i-v) and ง117, the RI/FS Report and the Proposed Plan for
OUS were made available to the public in January 1999. These documents can be found in the
Administrative Record file and the information repository maintained at the EPA Docket Room in
Region 4 and at the Aberdeen Town Hall in Aberdeen, North Carolina. In addition, the Proposed
Plan fact sheet was mailed to individuals on the Site's mailing list on January 14, 1999.
The notice of the availability of these documents and notification of the Proposed Plan Public
Meeting was announced in The Faveteville Observer Times and The Pilot on January 18, 1999.
A public comment period was held from January 18, 1999 through February 17, 1999. In
addition, a public meeting was held on February 4, 1999, at the Aberdeen Fire Station. At this
meeting, representatives from EPA answered questions about the site and the remedial
alternatives for the action under consideration. EPA's responses to the comments received during
the comment period, including those raised during the public meeting, are included in the
Responsiveness Summary, which is part of this ROD. The Responsiveness Summary also
incorporates a transcript of the Proposed Plan public meeting.
4.0 SCOPE AND ROLE OF RESPONSE ACTION
As at many superfund sites, the problems at the Aberdeen Pesticide Dumps Site are complex. As
a result, the cleanup efforts at this Site were organized into several Operable Units (OUs).
OU1 & 4 Soil at all areas (Twin sites, Fairway six, Farm Chemical, Mclver Dump
and Route 211). ROD signed on 9/3 0/91.
OU2 Renamed as OU4
OU3 Groundwater at Twin sites, Fairway Six and Farm Chemical areas. ROD
signed on 10/7/93
OUS Groundwater, surface water and sediment at Mclver and Route 211 Areas.
An interim ROD for the Route 211 Area was signed on September 16,
1997. This interim action addresses the highest concentrations of
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ROD
Aberdeen OU5
PageS
pesticides in groundwater (source area groundwater) using a pump and
treat system.
OU 5, the subject of this ROD and the final response action for OU5 addresses groundwater,
sediments and surface water at the Mclver Dump and Route 211 Areas. The interim action for
the Route 211 Area is part of the selected remedy for OU5 described in this ROD.
5.0 SUMMARY OF SITE CHARACTERISTICS
The Aberdeen Pesticides Dumps site encompasses approximately 10.57 square miles of mostly
rural property spread over five non-contiguous areas. The subject of this ROD is OU 5, EPA's
designation for groundwater, sediment and surface water media at the Mclver Dump and Route
211 Areas. Therefore, site characteristics for only those two areas will be discussed in this
section.
5.1 Topography and Surface Drainage
5.1.1 Mclver Dump Area
The Mclver Dump Area is located in a rural area of Moore County, the vicinity of which is
partially wooded and partially cleared for agricultural purposes. Topography and surface drainage
at the Mclver Dump Area is illustrated on Figure 2. The topography at the Mclver Dump Area
has been modified since the soils from areas B and C have been excavated and treated. Significant
erosion control measures have been constructed at the Mclver Area to direct drainage at the
Mclver Dump Area away from Patterson Branch. The Mclver Dump Area has been seeded and
fertilized to promote growth of stabilizing vegetation.
5.1.2 Route 211 Area
The topography of the Route 211 Area is generally flat with depressions and hills created from
historic sand mining operations. Topography and surface drainage at the Route 211 Area is
illustrated on Figure 3. Prior to soils removal, the Route 211 Area comprised a small sand
mining depression. Since the source soils have been removed, the depression has been filled in
with clean fill. Following regrading of the Route 211 Area, pinestraw mulch was applied to
prevent erosion and stabilize the soil. Surface runoff in the immediate vicinity of the Route 211
Area flows away from the former source area. The nearest surface water body is a localized area
containing intermittent ponded water to the southeast of the Route 211 Area. This surface water
body is the result of drainage originating topographically upslope of the Route 211 Area. The next
surface water feature is an intermittent creek approximately 500 feet southeast of the route 211
Area. This creek, known as Bull Branch, flows south-southwest intermittently for approximately
0.8 miles until it becomes a perennial stream. Along this intermittent stream are two man-made
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TOPOGRAPHY AND SURFACE DRAINAGE
MclVER DUMP AREA
ABERDEEN PESnClOE OUUPS SITE
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TOPOGRAPHY AND SURFACE DRAINAGE
ROUTE 211 AREA
ABERDEEN PESTICIDE DUMPS SITE
MOOBE COUNTY. NORTH CAROLINA
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ROD
Aberdeen OU5
Page 8
ponds approximately 800 feet and one-half mile from the Route 211 Area. This stream continues
to flow southward for approximately 3.3 miles, where it enters Quewhiffle Creek.
5.2 Geology
5.2.1 Mclver Dump Area
The geologic formations encountered beneath the Mclver Dump Area during the RI include the
Middendorf and Cape Fear Formations. These formations overlie the basement rocks of the
Carolina Slate Belt. The upper portion of the Middendorf Formation is only partially present
beneath the Mclver Dump Area due to erosion. Along the upland portion of the Mclver Dump
Area, beneath the former soil stockpile and underlying former area B, the upper portion of the
Middendorf Formation is present. Formation materials are comprised of pink to purple to red to
white well graded sand to poorly graded sand. Beneath the upland area, a silty clay was
encountered beneath the upper Middendorf sand. The low permeability unit was gray, moist to
dry, and very dense. Perched water was encountered above this low permeability unit.
Beneath a portion of former area B and all of former area C, the geology is comprised of the
lower Middendorf Formation. Formation materials are comprised of pink to purple to red to white
well graded sand to poorly graded sand. An intermediate bed of silty clay ranging in thickness
from 1.5 to 3.5 feet was encountered within this sand. '
At the base of the Middendorf Formation is the Cape Fear Formation. The Cape Fear Formation
was encountered beneath the entire Mclver Dump Area and is comprised of gray silty clay.
5.2.2 Route 211 Area
The geologic formations encountered beneath the Route 211 Area during the RI include the
Pinehurst Formation, the Middendorf Formation and the Cape Fear Formation. The Pinehurst
Formation ranges in thickness from 5.5 to 50 feet and is comprised of brown, tan, red and gray
fine to coarse sand with varying amounts of interstitial silt and clay.
At the base of the Pinehurst Formation is a silty, clayey sand, or sandy clay unit which includes
humic materials such as wood, grass, peat, and other plant debris at some locations. Where
present, this unit varies in thickness from approximately 2.5 to 9 feet.
The top of the Middendorf Formation is typically marked by a light gray to white, dense, brittle
silty clay, commonly overlain by a layer of pink to purple sand or fine gravel. Where present, this
low permeability unit ranges in thickness from approximately 1 to 22 feet.
Beneath the silty clay, the upper portion of the Middendorf is comprised of pink to purple to red
to white well graded sand to poorly graded sand with varying amounts of interstitial silt and clay.
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ROD
Aberdeen OU5
Page 9
This water bearing upper sand ranges in thickness from approximately 9 to 47 feet. This sand is
underlain by a second gray to white to yellowish brown, dense, brittle silty clay. This clay, termed
the "middle clay", was encountered at thicknesses ranging from approximately 1 to 17 feet.
Underlying the middle clay is the lower portion of the upper Middendorf Formation. This water
bearing sand is comprised of white to yellow to very pale brown well graded sand to poorly
graded sand to clayey sand with varying amounts of interstitial silt and clay. This unit ranges in
thickness from approximately 14.5 to 45 feet.
Separating the upper and lower Middendorf Formation is a low permeability clay. This light gray
clay ranged in thickness from less than 1 foot to 36 feet.
Underlying this low permeability unit is the Lower Middendorf sand. This sand was encountered
at all deep drilling locations and ranges in thickness from 21 to 70 feet. This unit was comprised
of poorly graded sand to well graded sand to clayey sand with varying amounts of silt and clay.
The base of this unit was typically marked by a bed of purple well graded gravel with sand.
At the base of the Middendorf Formation, the light gray silty clay of the Cape Fear Formation was
encountered. This low permeability clay was encountered at all deep drilling locations.
5.3 Hydrogeology
5.3.1 Mclver Dump Area
The aquifer penetrated during this investigation was the Black Creek Aquifer, which is comprised
of permeable sections of the Middendorf Formation. Groundwater in the Upper and Lower Black
Creek Aquifers can occur under perched or water table conditions, with an unsaturated portion of
the aquifer above the water surface. Within the Lower Black Creek Aquifer, beneath former
areas B and C, is a thin but continuous clay layer that acts as a local confining unit. This clay
layer separates the Lower Black Creek Aquifer into an upper and lower portion. The upper
portion of the Lower Black Creek Aquifer is unconfmed. The lower portion of the Lower Black
Creek Aquifer is under confined conditions adjacent to Patterson Branch.
Lower Black Creek Aquifer (upper and lower portions)
Figure 4 shows the monitoring well locations at the Mclver Dump Area. The average
groundwater gradient in the upper portion of the Lower Black Creek Aquifer is 0.02 ft/ft.
Hydraulic conductivity values range from 2.73 x 10'2 cm/sec to 3.44 x 10'3 cm/sec. Groundwater
in the upper portion of the Lower Black Creek Aquifer is moving at an average velocity of 325
feet per year.
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FIGURE 4
BHC ISOMER ANALYTICAL TEST RESULTS
UPPER PORTION OF LOWER BLACK CREEK AQUIFER
MclVER DUMP AREA
BEROEEN PESTICIDE DUMPS SHE
_MCORE COUNflf, NORTH f
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Aberdeen OU5
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The average groundwater gradient in the lower portion of the Lower Black Creek Aquifer is
0.008 ft/ft. Hydraulic conductivity values range from 3.82 x 10"4 cm/sec to 2.03 x 10'3 cm/sec.
Groundwater in the lower portion of the Lower Black Creek Aquifer is moving at an average
velocity of 343 feet per year.
In the upper portion of the Lower Black Creek Aquifer, the principal direction for groundwater
flow is toward the north-northeast, perpendicular to Patterson Branch. However, the lower
portion of the Lower Black Creek Aquifer exhibits a more regional north-easterly groundwater
flow direction.
There is a difference in the potentiometric surface levels between the upper and lower portions of
the Lower Black Creek Aquifer. In the upper portion, unsaturated conditions exist; but in the
lower portion, all locations within the investigation were fully confined. South of former area B,
near monitoring well 04-MW-01 and the former soil stockpile, the potentiometric surface in the
upper portion is higher than the potentiometric surface in the lower portion. Beneath the former
areas B and C and adjacent to Patterson Branch, this condition is reversed, and the potentiometric
surface in the lower portion of the Lower Black Creek Aquifer is above the potentiometric
surface in the upper portion. The vertical head difference reaches a maximum along Patterson
Branch where the vertical gradient is approximately 2.6 feet in the upward direction. In addition,
monitoring well"MC-MW-04D is under artesian conditions, with the potentiometric surface
approximately 2 feet above ground surface. This head reversal indicates that a strong upward
vertical gradient is occurring and that groundwater discharge to Patterson Branch is occurring.
Results of the FLONET model conducted during the RI indicate that Patterson Branch acts as a
discharge boundary for groundwater flow in the upper portion of the Lower Black Creek Aquifer.
In addition, an upward hydraulic gradient exists between the lower and upper portions of the
Lower Black Creek Aquifer between the former source areas and Patterson Branch except for a
very limited upgradient portion of the former area B where there is a slight downward vertical
gradient.
After reviewing the all lithologic and hydraulic data collected from the Mclver Dump Area, values
for transmissivity and storativity for the lower portion of the Lower Black Creek Aquifer were
found to range from 191 to 706 ft2/day and 7.29 x 10'5 to 1.16 x 10"4, respectively.
5.3.2 Route 211 Area
The three aquifers penetrated during this investigation were the Surficial Aquifer, comprised of
the sediments of the Pinehurst Formation, the Upper Black Creek Aquifer, comprised of the sands
of the upper portion of the Middendorf Formation, and the Lower Black Creek Aquifer,
comprised of the sands of the lower portion of the Middendorf Formation. The Upper Black.
Creek Aquifer is separated into an upper and lower portion by an intermediate clay with the
exception of location RT-TW-17DD.
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Aberdeen OU5
Page 12
Groundwater in the Surficial Aquifer is perched with an unsaturated section above the
groundwater surface. Groundwater in the upper portion of the Upper Black Creek Aquifer can
occur under water table conditions, with an unsaturated section above the groundwater surface.
However, the upper portion of the Upper Black Creek Aquifer is locally confined downgradient
of the former source area by the overlying low permeability unit. The lower portion of the Upper
Black Creek Aquifer is under confined conditions with the exception of location RT-TW-17DD
where the middle clay is not present. The Lower Black Creek Aquifer is under confined
conditions.
Surficial Aquifer
In the Surficial Aquifer, the principal direction for groundwater flow is toward the southwest.
The average hydraulic gradient in the Surficial Aquifer is 0.01 ft/ft. Hydraulic conductivity values
in the Surficial Aquifer range from 1.11 x 10'2 cm/sec to 6.2 x 10 * cm/sec. Groundwater in the
Surficial Aquifer is moving at an average velocity of approximately 632 feet per year.
Monitoring wells screened in the Surficial Aquifer are shown on Figure 5.
Upper Portion Upper Black Creek Aquifer
The principal direction of groundwater flow in the upper portion of the Upper Black Creek
Aquifer is toward the east-southeast, a variance of greater than 90 degrees from the flow direction
in the Surficial Aquifer. The average hydraulic gradient in the upper portion of the Upper Black
Creek Aquifer is 0.01 ft/ft. Hydraulic conductivity values in the upper portion of the Upper Black
Creek Aquifer range from 6.09 x 10"4 cm/sec to 2.54 x 10'3 cm/sec. Groundwater in the upper
portion of the Upper Black Creek Aquifer is moving at an average velocity of 235 feet per year.
A downward vertical gradient exists between the perched Surficial Aquifer and the upper portion
of the Upper Black Creek Aquifer. The difference in the groundwater surface between the two
Aquifers ranges from approximately 26 feet to 32 feet. Monitoring wells screened in the upper
portion of the Upper Black Creek Aquifer are shown on Figure 6. The absence of the Surficial
Aquifer and the thinning Upper Black Creek confining unit along the western perimeter of the
study area indicates potential hydraulic interconnection between the Surficial Aquifer and the
upper portion of the Upper Black Creek Aquifer.
Lower Portion of the Upper Black Creek
The groundwater flow direction in the lower portion of the Upper Black Creek Aquifer is toward
the south-southeast. The average hydraulic gradient is 0.0056 ft/ft across the study area. The
vertical gradient between the upper and lower portions of the Upper Black Creek Aquifer is
downward, with a head difference of approximately 3 feet. Hydraulic conductivity values in the
lower portion of the Upper Black Creek Aquifer range from 8.64 x W* cm/sec to 1.3 x 10'3
cm/sec. Groundwater in the lower portion of the Upper Black Creek Aquifer is moving at an
average velocity of 32 feet per year.
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Aberdeen OU5
Page 15
Lower Black Creek Aquifer
The groundwater flow direction in the Lower Black Creek Aquifer is primarily toward the south.
The average hydraulic gradient is 0.0045 ft/ft. The vertical gradient between the lower portion of
the Upper Black Creek Aquifer and the Lower Black Creek Aquifer is downward, with a head
difference of up to approximately 4.5 feet. Hydraulic conductivity values range from 1.24 x 10'3
cm/sec to 4.04 x 10"3 cm/sec. Groundwater in the Lower Black Creek Aquifer is moving at an
average velocity of 346 feet per year.
5.4 Nature and Extent of Contamination Overview
5.4.1 Mclver Dump Area
5.4.1.1 Groundwater
The RI at the Mclver Dump Area was conducted in multiple phases from November 1994 to
October 1995. The following summarizes the findings of the investigation conducted during
Phases I, II, III, IV, IVb, and IVc.
Groundwater samples from the Mclver Dump Area were analyzed for Target Compound List
(TCL) pesticides and Ferbam. The pesticides detected most frequently at the Mclver Dump Area
were the Benzenehexachloride (BHC) isomers, 4,4-dichlorodiphenyldichloroethane (4,4-DDD),
and dieldrin. The following sections provide a description of pesticides detected in groundwater
samples collected from the upper and lower portions of the Lower Black Creek Aquifer.
Upper Portion of the Lower Black Creek Aquifer
The pesticides most frequently detected in the upper portion of the Lower Black Creek Aquifer
were the four BHC isomers (alpha, beta, delta, and gamma), 4,4'-DDD, and dieldrin.
Concentrations of each compound generally decreased with depth at locations where samples
were collected from different depths within the aquifer. Several additional pesticides were
detected in groundwater, however, at random locations and at concentrations lower than those of
the most frequently detected pesticides. As a result of groundwater discharge to Patterson
Branch, the northern downgradient extent of pesticides in groundwater originating from the
former source areas (areas B and C) is Patterson Branch.
The concentrations of the four BHC isomers in the monitoring wells (Figure 4) indicate that
pesticides detected in groundwater originated from the former source areas (areas B and C), and
have migrated hydraulically downgradient to the discharge point at Patterson Branch. The close
proximity of the former source areas to Patterson Branch and the strong upward vertical gradient
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ROD
Aberdeen OU5
Page 16
adjacent to Patterson Branch has resulted in localized groundwater impact that is limited in aerial
extent and in depth.
Lower Portion of the Lower Black Creek Aquifer
The pesticides most frequently detected in the lower portion of the Lower Black Creek Aquifer
were the four BHC isomers. Concentrations of these compounds were lower than those detected
in the upper portion of the Lower Black Creek Aquifer. A few additional compounds were also
randomly detected in ground water at low concentrations.
Pesticides detected in groundwater in the lower portion of the Lower Black Creek Aquifer are
localized and exhibit no significant trends. Pesticide compounds were primarily detected beneath
and downgradient of former source area B and within a small area hydraulically downgradient of
former source area C. The low concentrations of pesticides in groundwater that are limited in
areal extent indicates that limited impact has occurred to the lower portion of the Lower Black
Creek Aquifer.
5.4.1.2 Surface Water and Sediments
Surface water and sediments were sampled and analyzed from Patterson Branch during the RI.
Results show that concentrations of pesticides in surface water are below the North Carolina
Surface Water Standards. The four BHC isomers, 4,4'-DDD, 4,4'-DDT and 4,4'-DDE were
detected in the sediments in Patterson Branch.
5.4.2 Route 211 Area
5.4.2.1 Groundwater
The RI at the Route 211 Area was conducted in multiple phases from November 1994 to October
1996. The following summarizes the findings of investigation conducted during Phases I, Ha, lib,
III, IVa, IVb, IVc, V, and VI. In addition, a Downgradient Receptors Study was conducted,
which consisted of sampling and analysis of 21 private wells.
All groundwater samples for the Route 211 Area were analyzed for TCL pesticides. Some of the
samples collected from monitoring wells were also analyzed for Ferban, Sevin, Guthion and
Parathion.
Surficial Aquifer
The most frequently detected pesticides in the Surficial Aquifer were alpha-BHC, beta-BHC, and
delta-BHC. These compounds exhibit a decreasing trend downgradient of the former source
area. The highest concentrations of pesticides were detected directly downgradient of the former
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Aberdeen OU5
Page 17
source area. Pesticide concentrations in monitoring wells located south of the Aberdeen and
Rockfish Railroad (ARR) were an order of magnitude less than those detected near the source.
Concentrations of these compounds decrease hydraulically downgradient.
Other pesticides detected with moderate frequency were gamma-BHC, 4,4'-DDD, 4,4'-DDE, and
Dieldrin. These compounds exhibit no notable trend and were randomly detected at various
concentrations. Several other pesticides compounds were detected in groundwater, albeit at
random locations and relatively lower concentrations than the BHC isomers. These compounds
include 4,4'-DDT, endosulfan I, endosulfan II, endosulfan sulfate, endrin, endrin aldehyde,
heptachlor, and toxaphene. ' ,
The extent of pesticides has been sufficiently defined in the Surficial Aquifer. This definition is
based on the known location and extent of the former source area, analytical test results of
downgradient groundwater samples, and the absence of Surficial Aquifer groundwater along the
western perimeter of the study area. Figure 5 illustrates the concentrations of the four BHC
isomers in the monitoring wells of the Surficial Aquifer.
Upper Portion of the Upper Black Creek Aquifer
The most frequently detected pesticides in the upper portion of the Upper Black Creek Aquifer
were the four BHC isomers. These compounds were consistently detected at decreasing
concentrations hydraulically downgradient of the pesticide migration pathway. Other pesticides
detected in groundwater include 4,4'-DDT, 4,4'-DDE, 4,4'-DDD, dieldrin, endosulfan I,
endosulfan II, endosulfan sulfate, endrin, endrin aldehyde, and toxaphene. These compounds
exhibited no notable trends and were detected at lower concentrations than the BHC isomers.
The extent of pesticides has been sufficiently defined in the upper portion of the Upper Black
Creek Aquifer. Figure 6 illustrates the concentrations of the four BHC isomers in the monitoring
wells of the upper portion of the Upper Black Creek Aquifer.
Lower Portion of the Upper Black Creek Aquifer
Of the groundwater samples collected during the Phase V RI, no pesticides were detected in the
upgradient well RT-TW-17DD. The four BHC isomers were detected at various concentrations
in monitoring wells RT-TW-12DD, RT-TW-19DD, RT-TW-18DD, in the USGS well USGS-05-
02, and in Hydropunch sample RT-HP-03DD (Figure 7).
During the Downgradient Receptor Study, seven of the thirteen private water wells sampled
which are potentially withdrawing water from the lower portion of the Upper Black Creek
Aquifer did not contain pesticides at or above method detection limits. However, the four BHC
isomers were detected in six wells in the low part per billion range. None of the six wells with
detectable concentrations of pesticides are being used as a source of drinking water.
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FIGURE 7
BHC-ISOMER ANALYTICAL TEST RESULTS
LOWER PORTION OF THE UPPER BLACK CREEK AQUIFER
ROUTE 211 AREA
AOEM1KNPESTODE OUMM SITE
- 18 -
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Aberdeen OU5
Page 19
Of the groundwater samples collected during the Phase VI RI, no pesticides were detected in the
sidegradient wells RT-TW-20DD and RT-TW-23DD. Monitoring well RT-TW-21DD and RT-
TW-22DD contained detectable concentrations of alpha-BHC and gamma-BHC, however, in the
low part per trillion range.
Based upon the results of the Phase V RI, the Downgradient Receptor Study, and the Phase VI
RI, the extent of pesticides has been sufficiently defined in the lower portion of the Upper Black
Creek Aquifer. Detectable concentrations of pesticides are consistent with the groundwater flow
direction. Concentrations of the BHC isomers increase downgradient of upgradient monitoring
well RT-TW-17DD. Concentrations then decrease further downgradient from monitoring well
RT-TW-19DD. Figure 7 illustrates the concentrations of the four BHC isomers in the
monitoring wells of the lower portions of the Upper Black Creek Aquifer.
Lower Black Creek Aquifer
Of the groundwater samples collected during the Phase V RI, no TCL pesticides were detected in
upgradient well RT-TW-17L or in sidegradient well USGS-05-01. The four BHC isomers were
detected in monitoring wells RT-TW-18L and RT-TW-19L. No other TCL pesticides were
detected in wells sampled during Phase V.
During the Downgradient Receptor Study, ten of the eleven water wells sampled which are
potentially withdrawing water from the Lower Black Creek Aquifer did not contain pesticides at
or above method detection limits. The four BHC isomers were detected in only one well
potentially withdrawing water from the Lower Black Creek Aquifer (concentrations of alpha-
BHC at 0.023 pg/l, beta-BHC at 0.018 jigfl, delta-BHC at 0.02 ^g/1, and gamma-BHC at 0.047
One or more of the BHC-isomers were detected in each of the monitoring wells installed during
the Phase VI RI in the part per trillion range. Endosulfan I and DDD were also detected in
monitoring well RT-TW-22L at concentrations in the part per trillion range.
Sidegradient wells RT-TW-20L and RT-TW-22L and downgradient well RT-TW-21L sufficiently
define the extent of pesticides in the Lower Black Creek Aquifer. Figure 8 presents the
concentrations of the four BHC isomers in the monitoring wells of the Lower Black Creek
aquifer.
5.4.2.2 Surface water and Sediments
The surface water sampling effort was conducted by EPA during the initial remedial investigation
for the Site. The closest surface water body to the area is the head waters of Bull branch, and
intermittent tributary to Quewhiffle Creek, which originates about 0. 1 mile south of the area.
Surface water and sediments were sampled and no pesticides, PCB, or VOCs were detected.
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BHC-ISOMER ANALYTICAL TEST RESULTS
LOWER BLACK CREEK AQUIFER
ROUTE 211 AREA
ABCTOCCT FESTIDOE CXJMP4 SIT^
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Aberdeen OU5
Page 21
6.0 SUMMARY OF SITE RISKS
The baseline risk assessment (BRA) estimates what risks OU5 poses if no actions were taken. It
provides the basis for taking action and identifies the contaminants and exposure pathways that
need to be addressed by the remedial action. This section of the ROD summarizes the results of
the BRA for OU5.
6.1 Data Evaluation
Data used to prepared the BRA was obtained from the RI report. The RI included the collection
of surface water, sediment and groundwater samples from locations comprising the Mclver Dump
and Route 211 Areas. All available data collected between November 1994 and November 1996
was used in the analysis. For the purpose of the BRA, the remedial investigation data was
segregated into two groups: the Mclver Dump Area and Route 211 Area. The data was also
separated by aquifers and low permeability units (designated as upper and lower portions of the
aquifer) within each of these two areas to reflect potential exposure conditions. At the Mclver
Dump Area, the upper and lower portions of the Lower Black Creek Aquifer were evaluated. At
the Route 211 Area, the Surficial Aquifer, upper portion of the Upper Black Creek Aquifer, lower
portion of the Upper Black Creek Aquifer and Lower Black Creek Aquifer were considered.
These designations were made to more accurately represent the potential risks associated with
these two distinct geographical areas.
6.2 Chemicals of Concern
The Chemical of Concern (COCs) for groundwater at the Mclver Dump and Route 211 Areas are
presented on Table 1 and 2 respectively. The table also includes the range of detected
concentrations each COC.
Reasonable maximum exposure (RME) point concentrations for groundwater, and surface water
were calculated. For groundwater, the arithmetic average of all wells with detected
concentrations for each COC was used to evaluate each aquifer based on the specified groupings.
The RME concentrations for groundwater at the Mclver Dump Area are presented in Table 3 for
the upper portion of the Lower Black Creek Aquifer and the lower portion of the Lower Black
Creek Aquifer. The RME for groundwater at the Route 211 Area are presented in Table 4 for
the Surficial Aquifer and the source area well (RT-MW04). Table 5 presents the RME
concentrations for the upper portion of the Upper Black Creek, the lower portion of the Upper
Black Creek, and the Lower Black Creek Aquifers at Route 211 Area.
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Table 1
Chemicals of Concern
Mclver Dump Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Chemical of
Concern
ALPHA-BHC
BETA-BHC
GAMMA-BHC
DELTA-BHC
Groundwater (a)
Upper Portion of
Lower Black Creek
Aquifer (b)
Min Max
0.0051 10.5
0.0094 1.4
0.028 0.115
0.047 1.7
Lower Portion of
Lower Black Creek
Aquifer (c)
Min Max
0.011 0.015
0.0049 0.039
0.0015 0.02
0.013 0.03
Surface Water
0.033 0.045
0.088 0.1
0.0016 0.0048
0.16 0.2
Sediment
ซ
~
..
Minimum / maximum detected concentration above the sample quantitation limit.
Units are ug/L.
-- = Not a COG for this medium
(a) Results based on phase I, II, IVb, and IVc data. Background well is 04-MW-01
(b) Samples include MC-MW-03, 04,05, 06, 07, and 08
(c) Wells 04-MW-02; MC-MW-04D and 05D.
22
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Table 2
Chemicals of Concern
Route 211 Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Chemical of
Concern
ALPHA-BHC
BETA-BHC
GAMMA-BHC
DELTA-BHC
Surficial Aquifer (a)
Min Max
0.00075 2.8
0.0069 58
0.047 0.089
0.028 205
Upper Portion of
Upper Black Creek
Aquifer (b)
Min Max
0.0049 1.25
0.003 1.1
0.0028 0.22
0.0013 4.75
Lower Portion of Upper
Black Creek Aquifer (c)
Min Max
0.0079 2.5
0.009 1.2
0.0016 2.1
0.019 3
Lower Black Creek
Aquifer (d)
Min Max
0.0014 0.21
0.002 0.045
0.024 0.16
00017 014
Minimum / maximum detected concentration above the sample quantitation limit.
ND - Not detected
Units are pg/L
(a) Results based on phases I, II, III, and IV data. Samples include 05-MW-01, 02,03; RT-MW-04, 05,07, 08, 09,10.
Background well is RT-MW-06. Wells 05-MW-01 and 05-MW-02 are upgradient of the source area.
(b) Samples include RT-TW-01D, 02D, 05D, 08D, 09D, 12D, 13D, 14D, 16D, 22D, and 23D.
(c) Samples include RT-TW-8DD, 12DD, 17DD, 18DD, 19DD, 20DD, 21DD, 22DD, and 23DD; GS-05-2; PRW-13,16,17, 25,
26,27,34,45,46, 48,50,54 and 58.
(d) Samples include RT-TW-13L, 17L, 18L, 19L, 20L, 21L, 22L; GS-05-1; PRW-23,37-1,37-2,12-1,12-2,42,44,57, 81, 84,
86; and MVW-12.
23
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Table 3
Reasonable Maximum Exposure Concentrations for
ChemicaSs of Concern
Mclver Dump Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Chemical of Concern
ALPHA-BHC
BETA-BHC
GAMMA-BHC
DELTA-BHC
Upper Portion of Lower Black
Creek (a)
RME Concentration (ug/L)
Number of
Wells
4
4
4
4
Concentration
2.73
0.66
0.06
0.54
Lower Portion of Lower Black
Creek (b)
RME Concentration (ug/L)
Number of
Wells
3
3
3
3
Concentration
0.0088
0.019
0.0069
0 014
RME: Reasonable Maximum Exposure Concentration
(a) Wells MC-MW-04, 05, 06, 07.
(b) Wells 04-MW-02; MC-MW-04D, 05D.
24
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Table 4
Reasonable Maximum Exposure Concentrations for
Chemicals of Concern in Surficial Aquifer Groundwater
Route 211 Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Chemical of
Concern
ALPHA-BHC
BETA-BHC
GAMMA-BHC
DELTA-BHC
Surficial Aquifer (a)
RME Concentration (ug/L)
Number of
Wells
5
5.
5
5
Concentration
0.26
0.93
0.039
3.4
Source Area Well (b)
RME Concentration (ug/L)
Number of
Wells
1
1
1
1
Concentration
2.8
58
NO
205
RME: Reasonable Maximum Exposure Concentration
(a) Wells RT-MW-05, 07, 08, 09, and 10.
(b) Well RT-MW-04.
ND - Not detected
25
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Tables
Reasonable Maximum Exposure Concentrations for
Chemicals of Concern in Upper and Lower Black Creek Aquifer Groundwater
Route 211 Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Chemical of
wonc&rn
ALPHA-BHC
BETA-BHC
GAMMA-BHC
DELTA-BHC
Upper Portion of
Upper Black Creek Aquifer
RME Concentration (ug/L)
Number of
Wells
9
9
9
9
Concentration
(a)
0.19
0.28
0.03
1.3
Lower Portion of Upper Black Creek Aquifer
RME Concentration (ug/L)
Number
of Wells
4
4
4
4
North of
MUW-13
(b)
1.1
0.41
0.81
1.2
Number
of Wells
8
8
8
8
South of
MUW-13
(c)
0.12
0.12
0.067
0.18
Lower Black Creek Aquifer
RME Concentration (ug/L)
Number
of Wells
2
2
2
2
m^mm^^mmm
North of
MUW-13
(d)
0.19
0.042
0.16
0.12
Number
of Wells
4
4
4
4
South of
MUW-13
(e)
0.012
0.007
0.02
0.006
RME: Reasonable Maximum Exposure Concentration
(a) Wells RT-TW-01D, 02D, 05D, 08D. 09D, 12D, 14D, 22D and 23D.
(b) Wells RT-TW-12DD, 18DD, and 19DD; GS-05-02.
(c) Wells PRW-16,17, 25, 27, 50, 54; RT-TW-21DD and 22DD.
(d) Wells RT-TW-18L and 19L.
(e) Wells RT-TW-20L, 21L, 22L; PRW-23.
26
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Aberdeen OU5
Page 27
6.3 Exposure Assessment
A conceptual site model incorporates information on the potential chemical sources, affected
media, release mechanisms, potential exposure pathways, and known human and/or ecological
receptors to identify complete exposure pathways. A pathway is considered complete if: (1) there
is a source or chemical release from a source; (2) there is an exposure point where human or
ecological contact can occur; and (3) there is a route of exposure (oral, dermal, or inhalation)
through which the chemical may be taken into the body.
The contamination at the Mclver Dump Area is allegedly due to the disposal of materials
containing pesticides and pesticide residues more than 30 years ago. Contaminants released from
this material and retained by the soil serve as a reservoir for continued release. Groundwater may
be impacted through the leaching action of infiltrating rain water. Surface water and sediment in
streams within the drainage basin may be impacted by erosion or solubilization of soil-bound
contaminants or by an aquifer connection to the stream. The conceptual site model for the
Mclver Dump Area is presented in Table 6.
The contamination at the Route 211 Area is allegedly due to the disposal of materials, some of
which contained pesticides. Surface water impacts at the Route 211 Area are not expected
because the nearest surface water body (a small man-made pond approximately 800 feet
southwest) is separated from the area of concern by a small topographic rise. Groundwater may
be impacted by the same release mechanisms as the Mclver Dump Area. The conceptual site
model for the Route 211 Area is shown in Table 1.
Based on these models, the media available for human contact are:
(I). Groundwater. Potential receptors are future site residents.
(2). Surface water and sediment in Patterson Branch. Patterson Branch is accessible to
juvenile visitors and future residents at the Mclver Dump Area. It is assumed that
these receptors may wade in the stream and be exposed to contaminants in both
surface water and sediment; and
Potentially significant exposure routes are:
(1). Groundwater: Ingestion of groundwater and inhalation of Volatile Organic
Chemicals (VOCs) (if present) released from groundwater while showering.
Because no VOCs were selected as COPCs, the inhalation of VOCs while
showering is considered to be an incomplete pathway and therefore, was not
evaluated. Dermal contact with water during household water use was not
considered a significant exposure pathway; and
-------
Sources
Land Disposal
of Pesticide-
Containing
Materials
NA Not applicable
Primary
Release /
Transport
Mechanism
Leaching
Surface
Erosion
Affected
Medium
Groundwater
Surface Water
in Creek
Sediment
in Creek
Table 6
Site Conceptual Model
Mclver Dump Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Exposure Point
On-and-Off-site
Off-site
Off-site
Land Use
Future
Current
Future
Current
Future
Exposure
Route
Ingestion
Inhalation of VOCs
^"^^"^^^^i
Ingestion
Dermal Contact
Ingestion
Dermal Contact
^"""^l^^-
Ingestion
Dermal Contact
Ingestion
Dermal Contact
Child and
Adult Resident
Child and
Adult Resident
-^^^^^MM^^.
Child Visitor
Child Visitor
Child and
Adult Resident
Child Visitor
Child Visitor
Child and
Adult Resident
YES
NO
YES
YES
NO
NO
28
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Table 7
Site Conceptual Model
Route 211 Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Sources
Land Disposal
of Pesticide-
Containing
Materials
Primary
Release /
Transport
Mechanism
Leaching
Affected
Medium
Groundwater
Exposure Point
On-and Off-site
Land Use
Future
Exposure
Route
Ingestion
Inhalation of VOCs
Receptor
Child and
Adult
Resident
Child and
Adult
Resident
Pathway
Evaluated?
Yes
No
29
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Aberdeen OU5
(2). Surface water: Inadvertent ingestion and dermal contact with surface water in
Patterson Branch. Contact with sediment, because it is nearly always covered by
water, was not evaluated.
6.4 Toxicity Assessment
Toxicity assessment is a two-step process whereby the potential hazards associated with
route-specific exposure to a given chemical are (1) identified by reviewing relevant human and
animal studies; and (2) quantified through analysis of dose-response relationships.
Toxicity values are used in the baseline evaluation to determine both carcinogenic and
non-carcinogenic risks associated with each chemical of concern and route of exposure Toxicitv
values that are used in this assessment include:
reference dose values (RfDs) for non-carcinogenic effects
cancer slope factors (CSFs) for carcinogenic effects
RfDs have been developed to indicate the potential for adverse health effects from exposure to
chemicals exhibiting non-carcinogenic (systemic) effects. RfDs are ideally based on studies where
either animal or human populations were exposed to a given compound by a given route of
exposure for the major portion of the life span (referred to as a chronic study) The RfD is
derived by determining dose-specific effect levels from all the available quantitative studies and
applying uncertainty factors to the most appropriate effect level to determine an RfD for humans
The RfD represents a threshold for toxicity. RfDs are derived such that human lifetime exposure
to a given chemical via a given route at a dose at or below the RfD should not result in adverse
health effects, even for the most sensitive members of the population.
CSFs are route-specific values derived only for compounds that have been shown to cause an
increased incidence of tumors in either human or animal studies. The CSF is an upper
bound estimate of the probability of a response per unit intake of a chemical over a lifetime and is
determined by low-dose extrapolation from human or animal studies. When an animal study is
used, the final CSF has been adjusted to account for extrapolation of animal data to humans If
h! finl TO"? *t deriV!-the ?F W6re conducted for less thaซ *e life span of the test organism,
the final CSF has been adjusted to reflect risk associated with lifetime exposure.
The RfDs and CSFs used in this assessment were primarily obtained from USEPA's IRIS
ncSTr S^eฃIUeS fฐr a 8iVen comPฐund and route of exposure were listed in IRIS, then
USEPA s
nc e ,
USEPA s HEAST was consulted. USEPA's Office of Pesticide Programs (OPP) recently
derived an RfD for gamma-BHC based on a newly available chronic rat study and this value was
kilJv ff S ?lT eSSmenu' ThC Samma-BHC Rฎ on ^ was not used because it is based on
kidney effects that occur through a biological mechanism that is not relevant to humans (ซ-2u-
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Aberdeen OU5
Page 31
globulin accumulation. Tables 8 and 9 summarize the toxicity values for carcinogenic and non-
carcinogenic COCs, respectively.
6.5 Risk Characterization
The final step of the baseline risk assessment is the risk characterization. Human intakes for each
exposure pathway are integrated with reference toxicity values to characterize risk. Carcinogenic
and non-carcinogenic effects are estimated separately.
To characterize the overall potential for non-carcinogenic effects associated with exposure to
multiple chemicals, the Hazard Index (HI) approach is used. This approach assumes that
simultaneous subthreshold chronic exposures to multiple chemicals that affect the same target
organ are additive and could result in an adverse health effect. The HI is calculated as follows:
Hazard Index = ADDj/RfD, + ADD2/RfD2 +...ADDi/RฃDi
where:
ADD; = Average Daily Dose (ADD) for the i* toxicant
RfDj = Reference Dose for the i* toxicant
The term ADD/RfDj is referred to as the Hazard Quotient (HQ).
Calculation of an HI in excess of unity indicates the potential for adverse health effects. Indices
greater than one will be generated anytime intake for any of the chemicals of potential concern
exceeds its RfD. However, given a sufficient number of chemicals under consideration, it is also
possible to generate an HI greater than one even if none of the individual chemical intakes
exceeds its respective RfD.
Carcinogenic risk is expressed as a probability of developing cancer as a result of lifetime
exposure. For a given chemical and route of exposure, excess lifetime cancer risk is calculated as
follows:
Risk = Lifetime Average Daily Dose (LADD) x Carcinogenic Slope Factor (CSF)
These risks are probabilities that are generally expressed in scientific notation (i.e., IxW6
or 1E-6). An incremental lifetime cancer risk of 1 x 10"6 indicates that, as a plausible upper-
bound, an individual has a one-in-one-million chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under the specific exposure
conditions at the site. For exposures to multiple carcinogens, it is assumed that the risk
associated with multiple exposures is equivalent to the sum of their individual risks.
-------
Table 8
Cancer Slope Factors, Tumor Sites and USEPA Cancer Classifications for
Chemicals of Concern
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Chemical of
Concern
ALPHA-BHC
BETA-BHC
GAMMA-BHC
DELTA-BHC
Cancer Slope Factor
CSFo
6.3E+00 i
1.8E+00 i
1.3E+00 h
NA
ABSeff (a)
97.4%
90.7%
99.4%
91.9%
CSFd (b)
6.5E+00
2.0E+00
1.3E+00
NA
ซ
Turn
I^WM
I
L
L
Liver
Liver
Liver
NA
EPA Class:
A - Human Carcinogen
B- Probable Human Carcinogen
C- Possible Human Carcinogen
D- Not classifiable as a human carcinogen
EPA
Class
E^^aB
B2
B2-C
D
h- HEAST
NA - Not Applicable (no data)
CSFo- Cancer Slope Factor (oral), (mg/kg/day)-1
CSFd-Absorbed Cancer Slope Factor (dermal), (mg/kg/day)-1
ABSeff-Absorption efficiency: chemical-specfic
(a) Chemical-specific oral absorption efficiencies obtained from ATSDR (1994) for the BHC isomers
(b) Absorbed cancer slope factor used to assess dermal risks was calculated by dividing the oral cancer slope factor by the chemical-specific oral absorption
32
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Table 9
Reference Doses and Target Sites for
Chemicals of Concern
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Chemical of
Concern
ALPHA-BHC
BETA-BHC
GAMMA-BHC
DELTA-BHC
Reference Dose
RfDo
NA
NA
4.7E-03 (c)
4.7E-03 (d)
ABSeff
(a)
NA
NA
99.4%
91.9%
RfDd {b)
NA
NA
4.7E-03
4.3E-03
Target Sites/Effects
NA
NA
Liver
Liver
Sources:
i - IRIS
(a)
(b)
(c)
(d)
RfDo - Reference Dose (oral), (mg/kg/day)
ABSeff - Absorption efficiency: chemical-specific
RfDd - Absorbed Reference Dose (dermal), (mg/kg/day)
NA - Not Applicable (no data)
Chemical-specific oral absorption efficiencies obtained from ATSDR (1994) for the BHC isomers.
Absorbed Rf D used to assess dermal risks was calculated by multiplying the oral Rf D by the chemical-
specific oral absorption efficiency factor.
Rf D recommended by USEPA Office of Pesticide Programs (OPP) based on a no-observed effect level
of 0.47 mg/kg/day for liver effects in a chronic rat study (Life Science Research 1989).
The RfD for gamma-BHC was used to assess delta-BHC.
33
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6.5.1 Mclver Dump Area
Current Use
Currently complete exposure routes pertinent to OU 5 at the Mclver Dump Area include:
inadvertent ingestion of surface water
dermal contact with surface water
Potential receptors are site visitors. Estimated total risks associated with these exposure routes
are summarized m Table 10. The estimate is based on exposure to the BHC isomers.
The sum of risks associated with currently complete exposure routes is 1 x 10'8 for the site visitor
Non-cancer effects are not expected for the site visitor based on a total HI of substantially less
than one (0.00001) for combined exposure through incidental ingestion and dermal contact with
surface water.
Future Use
Future risks pertinent to OU 5 (groundwater and surface water) at the Mclver Dump Area
consider the development of groundwater resources within the contaminant plume for residents
potential receptors in the future use scenario also include the previously discussed site visitors
Estimated total risks associated with these exposure routes are summarized in Table 11.
The excess lifetime cancer risks associated with future exposure routes range from 5 x 10'9 for a
site visitor that could incidentally ingest stream water from Pattersons Branch to 3 x 10"4 for a
hfetime resident that could ingest groundwater for 30 years from the upper portion of the Lower
Black Creek Aquifer. The predicted excess lifetime cancer risk estimate for adult and lifetime
residents are due primarily to the ingestion of groundwater from the upper portioi of the Lower
Black Creek Aquifer for 24 and 30 years, respectively. For the child resident, the predicted
excess cancer nsks are between the 1x10- tolxlO"6 risk range and below the same range for the
site visitor. BHC isomers are the most significant contaminants in terms of cancer risk in this
future use scenario.
As shown on Table 11, non-cancer effects are not expected for child, adult, and lifetime residents
or site visitors.
6.5.2 Route 211 Area
Current Use
-------
Table 10
Summary of Cancer and Noncancer Risks by Exposure Route
Current Use Scenario
Mclver Dump Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Medium
Stream
Water
Exposure Route
Inadvertent
Ingestion
Dermal Contact
TOTAL CURRENT RISK
Site Visitor
Cancer
5E-9
8E-9
1E-8
HI
0.000003
0.000005
0.00001
HI Hazard Index (noncancer risk)
NA Not Applicable
35
-------
Medium
Stream Water
Groundwater
Upper Portion
of Lower
Black Creek {b)
Lower Portion
of Lower
Black Creek (a)
Table 11
Summary of Cancer and Noncancer Risks by Exposure Route
Future Use Scenario
Mclver Dump Area
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Stream Water Dermal Contact
Exposure
Route
Inadvertent
Ingestion
digestion
Ingestion
Child Resident
Cancer
9E-9
1E-8
1E-4
5E-7
(a) Wells 04-MW-02; MC-MW-04D and 05D.
(b) Wells MC-MW-04, 05, 06, and 07.
NE= Not evaluated
NC= Not calculated
HI = Hazard Index (noncancer risk)
HI
0.00001
0.00001
0.02
0.0003
Adult Resident
Cancer
8E-9
1E-8
2E-4
9E-7
36
HI
0.000002
0.01
0.0001
Lifetime Resident
(6-yr + 24-yr)
Cancer
2E-8
0.000003 2E-8 0.00001
3E-4
1E-6
HI
0.000003
0.01
0.0002
Site Visitor
Cancer
5E-9
8E-9
NE
NE
HI
0.000003
0.00001
NE
NE
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There are no currently complete exposure routes pertinent to OU 5 (groundwater) at the Route
211 Area.
Future Use
Future risks pertinent to OU 5 (groundwater) at the Route 211 Area consider the development of
groundwater resources within the contaminant plume for residential use. Potential receptors in
the future use scenario include site residents. Risks associated with the Surficial, upper portion of
Upper Black Creek, the lower portion of Upper Black Creek and Lower Black Creek Aquifers are
presented separately. Estimated total risks associated with these exposure routes are summarized
in Tables 12 and 13.
Surficial Aquifer
In the Surficial Aquifer at the Route 211 Area, the cancer risks range from 2 x lO'5 to 5 x 10'5 for
a child and lifetime resident, respectively. Risks associated with ingestion of groundwater from
the source area well (RT-MW-04) in the Surficial Aquifer are higher (up to 2 x 10'3). BHC
isomers are the most significant contaminants in terms of potential cancer effects.
It is possible that future child and lifetime residents could experience adverse noncarcinogenic
effects following chronic ingestion of groundwater from the source area well (RT-MW-04) at
Route 211 as indicated by hazard indices that slightly exceed one.
Upper Portion of the Upper Black Creek Aquifer
In the upper portion of the Upper Black Creek Aquifer the cancer risks range from 1 x 1(T5 for a
child resident to 3 x 10'5 for a lifetime resident exposed continuously for 30 years. BHC isomers
are the most significant contaminants in terms of potential cancer effects.
Noncancer effects are not expected for child, adult, and lifetime residents based on hazard indices
that are less than one.
Lower Portion of the Upper Black Creek Aquifer
The cancer risks in the Lower potion of the Upper Black Creek Aquifer range from 6 x 10^ to 1
x 1CT4 for a child and lifetime resident, respectively that could ingest groundwater from this
aquifer. The BHC isomers are the most significant contaminants in terms of potential .cancer
effects.
Noncancer effects are not expected for child, adult, and lifetime residents based on hazard indices
less than one.
-------
Tall .
Summary of Cancer and Noncancer Risks by Exposure Route
Future Use Scenario
Route 211 Area Surficiai Aquifer
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Medium
Groundwater
Exposure
Route
Ingestion
Location
Surficiai
Aquifer (a)
Source Area
Well (b)
HI = Hazard Index (noncancer risk)
(a) Wells RT-MW-05.07,08, 09 and 10
(b) Well RT-MW-04
Child Resident
Cancer
2E-5
7E-4
HI
0.05
Adult Resident
Cancer
3E-5
1E-3
HI
0.02
Lifetime Resident
(6-yr + 24-yr)
Cancer
5E-5
2E-3
HI
0.03
38
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Tab. j
Summary of Cancer and Noncancer Risks by Exposure Route
Future Use Scenario
Route 211 Area Upper and Lower Black Creek Aquifers
Aberdeen Pesticide Dumps Site
Aberdeen, North Carolina
Medium
Groundwater
Upper portion of Upper
Black Creek (a)
Exposure
Route
Ingestion
Child Resident
Cancer
HI
Adult Resident
Cancer
HI
1E-5
0.02
2E-5
0.01
Lifetime Resident
(6-yr + 24-yr)
Cancer
HI
3E-5
0.01
Lower portion of Upper Black Creek
NorthofMUW-13(b)
SouthofMUW-13(c)
Lower Black Creek
North of MUW-13 (d)
SouthofMUW-13(e)
Ingestion
Ingestion
Ingestion
Ingestion
5E-5
6E-6
0.03
0.003
8E-5
1E-5
0.01
0.001
1E-4
2E-5
0.02
0.002
8E-6
6E-7
0.004
0.0004
1E-5
1E-6
0.002
0.0004
2E-5
2E-6
0.002
00002
HI Hazard Index (nortcancer risk)
(a) Wells RT-TW-01D, 02D, 05D, 08D, 09D. 12D, 14D, 22D and 23D.
(b) Wells RT-TW-12DD, 18DD, 19DD; and GS-05-02.
(c) Wells PRW-16,17, 25. 27, 50, and 54; RT-TW-21DD and 22DD.
(d) Wells RT-TW-18L and 19L
(e) Wells RT-TW-20L, 21L, and 22L; and PRW-23.
39
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Lower Black Creek Aquifer
In this aquifer cancer risks range from 6 x 10'7 to 2 x Iff* for a child and lifetime resident
respectively. BHC isomers are the most significant chemicals in terms of potential cancer effects.
bsTtrnonf6018 "* "* eXP6Cted **" ^ "^ ^ Hfetime residents based on hazard indices
7.0 REMEDIATION OBJECTIVES
)A|- t +-rป i rr\r^ i i <*iซu /^.ppi upriaie i\.equirements
, ine laentllieu UUUS. and the nntenftal pvnnctiro muta *,! .- * j- i
I ARAl?o\ +l*a. Z A 4.'C J /-ซ/--v/-< t ซ "rr" "fซ ซu.ป.^ *xซ*uuii 1,111^1113
nhST ldjntlซed COCs, and the potential exposure route and receptors, remedial action
objectives were developed for the Mclver Dump and the Route 211 Areas.
7.1 Mclver Dump Area
Protect human health by preventing the ingestion of groundwater with COCs
concentrations exceeding established Federal and State ARARs, having potential
carcinogens in excess of a total lifetime cancer risk of 1 x 10'6, or having a HI greater than
l tor non-carcinogens.
Protect human health and the environment by restoring groundwater at the Mclver Dump
Area to concentrations below to the clean up goals described below.
Protect the environment by preventing future potential impact to Patterson Branch.
7.2 Route 211 Area
Protect human health by preventing the ingestion of groundwater with COCs
concentrates exceeding established Federal and State ARARs, having potential
carcinogens in excess of a total lifetime cancer risk of 1 x 10*. or having a HI greater than
1 for non-carcinogens.
Protect human health and the environment by restoring groundwater at the Route 211
Area to concentrations below the clean up goals described below for the chemicals of
concern.
Protect the environment by preventing future potential impact to downgradient surface
waer
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7.3 Clean up Goals for Mclver Dump and Route 211 Areas
Table 14 shows the applicable groundwater clean up goals in parts per billion (ppb) for the
chemicals of concern for both Mclver Dump and Route 211 Areas.
Table 14
Chemicals of Concern (COCs)
Alpha -BHC
Beta -BHC
Delta - BHC
Gamma - BHC
Groundwater Clean-up Goal
0.02
0.10
70.0
0.20
Basis
Risk - Based
Risk - Based
Risk - Based
MCLs/NCGQS
MCLs - Maximum Contaminant Levels
NCGQS- North Carolina Groundwater Quality Standards
8.0 DESCRIPTION OF REMEDIAL ALTERNATIVES
The following section provides a summary of the alternatives developed in the Feasibility Study
(FS) report for the clean-up of groundwater at Mclver and Route 211 Areas.
8.1 Mclver Dump Area
8.1.1 Alternative 1: No Action
The No Action alternative is required to be evaluated at every site to establish a baseline for
comparison. No further groundwater activities would be conducted at the Mclver Dump Area
under this alternative. Because this alternative does not entail contaminant removal, a review of
the remedy would be conducted every five years in accordance with CERCLA. Costs included on
this alternative are associated with the five year review which would include sampling and analysis
for the COCs and preparation of the five year review report.
Estimated total present worth costs for the No Action alternative is $160,000. This cost includes
a remedy review every 5 years for a 10 year period. There are no operation and maintenance
costs associated with this alternative. A detailed cost estimate for Alternative 1 is provided in
Table 15. Costs are rounded to two significant figures.
-------
Table 15
Alternative 1
Mclver Dump Area
REMEDY REVIEW
Every 5 Years, $100,000
Calculation of Present Worth Factors (PWF) at 7% interest and 4% inflation:
Year PWF
5 0.8626
10 0.7441
Total: 1.6067
REMEDY REVIEW. PRESENT WORTH COST f 10 years. i=7%. e=4%); $160.000
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8.1.2 Alternative 2: Continued Groundwater/Surface Water/Sediments Monitoring,
Phytoremediation, Area Reconnaissance, and Alternative Water Supply/Well Head Treatment
if Future Potential Receptors are identified
8.1.2.1 Description of Alternative 2 Components
Monitor Natural Attenuation
Monitoring would be used to verify that natural aquifer processes are reducing contaminant
concentrations to acceptable levels by intrinsic remediation; to determining the concentration,
distribution, and migration of the COCs in groundwater/surface water and sediments, and to '
verify that the clean up goals are achieved during remedial action. Additionally, monitoring
would be used as a mechanism by which future receptors within the migration pathway of COCs
are identified and addressed, if necessary. Monitoring would also be used to maintain exposure
control within the defined remedial action objectives. After source removal and construction of
erosion control measures already finished under a separate ROD, pesticide concentrations will
naturally decrease.
Monitoring would involve periodic (short and long-term) sampling and analysis of ground water/
surface water/sediments.
Phytoremediation
Phytoremediation is an innovative in-situ technology for the remediation of pesticide in
groundwater. Phytoremediation would be used to enhance the natural attenuation processes by
the use of vegetation to treat in-place contaminated groundwater. The Mclver Dump Area is
favorable for the use of phytoremediation as a remedial technology because of the shallow water
table which would allow tree roots to get in contact with contaminated groundwater, proximity of
the source area to the groundwater discharge area, and absence of current groundwater use.
Additionally, phytoremediation offers some hydraulic control through transpiration, thereby
limiting the migration of pesticides.
Area Reconnaissance
Area reconnaissance would be used to determine whether properties at the area are for sale,
purchased, or being leased. This would be accomplished by reconnoitering the Mclver Dump
Area and reviewing property records. Town development plans would be reviewed to determine
any future development strategies for the Mclver Dump Area. Additionally, residential well
surveys have been conducted at the Mclver Dump Area. Through area reconnaissance, the
residential well surveys would be verified and updated. Area reconnaissance is an effective means
of controlling exposure as defined in the remedial action objectives. The area reconnaissance
program would be in place until clean up goals are achieved.
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Alternative Water Supply/ Well Head Treatment
Currently, there are no receptors of impacted groundwater. However, if potential receptors are
identified in the future, an alternative water supply or well head treatment will be used to prevent
exposure. This option would be available for any potential receptor until clean up goals are
achieved.
Remedy Review
A remedy review would be performed every 5 years until clean up goals are achieved to determine
the effectiveness of the remedy to protect human health and/or the environment. As a result of
this review, if needed, additional site remediation or modifications to the remedy would be
performed.
8.1.2.2 Other Features of Alternative 2
Groundwater clean up goals for the COCs would be achieved by natural attenuation
(since source soils were removed in 1997) and/or via phytoremediation.
The time frame to achieve clean up goals under Alternative 2 is estimated to be 1 0 years.
The estimated total present worth cost for Alternative 2 is $450,000. This cost includes
periodic monitoring of groundwater and Patterson Branch, the enhancement of the Mclver
Dump Area through the planting of trees or other plant life (phytoremediation) and a
remedy review every 5 years for a 10 year period to determine the effectiveness of the
alternative to protect human health and/or the environment. A detailed cost estimate for
Alternative 2 IS provided in Table 16. Costs are rounded to two significant figures.
8.1.2.3 Expected Outcomes of Alternative 2
tea (estimated time frame of 1ฐ y^rs), groundwater should
be available to drink without having to treat to remove pesticides.
ww, - v Groundwater Recovery of the Highest Concentrations of
Pesticide Residuals using Extraction Wells and/or Interceptor Trenches, Treatment by Carbon
Adsorption, Discharge of Treated Groundwater via Surface Water or Rejection (Infiltration
Gallenesanjection Wells), Continued Groundvater/Surface Water Monitoring, Area
~
-------
Table 16
Alternative 2
Mclver Dump Area
Item
DIRECT CAPITAL COSTS
Pbytoretnediation
Administrative Fees
Unit Cost Units Quantity Total Cost
vegetation planting
$32
$10,000
tree
LS
1,250
1
INDIRECTCAPITAL COSTS
Health and Safety @ 5% of Direct Capital Costs (DCC)
Bonds & Insurance @ 5% of DCC
Contingency @ 20% of DCC
ANNUAL OPERATING AND MAINTENANCE COSTS
MONITORING
Sampling - First 5 Years:
Quarterly Sampling (Labor + Supplies)
Quarterly Sampling (Pesticide Analyses)
Quarterly QA/QC Samples
Annual Sampling (Pesticide Analyses)
Validation and Report Preparation
Sampling - Years 5-10:
Annual Sampling (Labor + Supplies)
Annual Sampling (Analyses)
Annual QA/QC Samples
Validation and Report Preparation
REMEDY REVIEW
TOTAL CAPITAL COSTS:
$100,000 Every 5 Years
Present Worth Cost (see B.l-1, FWB=1.60):
TOTAL O&M COSTS:
$40,000
$10.000
$50,000
$2400
$2,500
$10.000
$15,000
$65,000
2 days, 1 night + equipment $4,700 3 MO
4 groundwater samples $620 3 MO
2 water samples $310 3 MO
2 surf, water, 2 sed., 3 QA/QC $1,115 YR
$3,600 3 MO
Present Worth (n=5 yrs, i=7%, e=4%, PWF=4.58):
2 days, 1 night + equip. $4,700 YR
4 gw, 2 sw, 2 sed. samples $1,260 YR
4 water, 1 sediment sample $785 YR
$3,600 LS
Present Worth (n=5-10, i=7%, e=4%, PWF=3.95):
4
4
4
1
4
-
1
1
1
1
$18,800
$2,480
$1,240
$1,115
$14.400
$38,035
$174,200
$4,700
$1,260
$785
$3.600
$10,345
$40,863
TOTAL PRESENT WORTH COST
$160,000
$380,000
$445.000
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8.1.3.1 Description of Alternative 3 Components
Groundwater Extraction and Treatment Components
Groundwater containing the highest concentrations of pesticides, "hot spots"(> 0 1 ppb)
would be extracted using extraction wells or interceptor trenches.
Extracted groundwater would be treated using carbon adsorption.
Treated groundwater would be discharged via surface water or a re-injection method.
Monitoring Natural Attenuation - same as Alternative 2.
Area Reconnaissance - Same as Alternative 2
Alternative Water Supply/ Well Head Treatment - Same as Alternative 2.
Remedy Revieiv - Same as Alternative 2
8.1.3.2 Other Features of Alternatives
Groundwater clean up goals would be achieved by removing the highest concentrations of
pesticides using extraction wells and/or interception trenches, and by natural attenuation
on tne rest of the plume (since source soils were removed in 1997).
Due to the groundwater flow velocity, the hydraulic gradient near the surface water body
and the limited discharge distance to the creek, increasing the gradient through extraction
would not significantly decrease the time frame to achieve clean up goals. The time frame
to achieve clean up goals under Alternative 3 is estimated to be 10 years.
For cost estimate purposes, interceptor trenches were assumed as the groundwater
recovery method. Total present worth costs were estimated for Alternative 3 with two
different discharge options: discharge to surface water and infiltration galleries The
estimated total cost is $1,500,000 discharging to surface water and $1 200 000
d^chargmg to an infiltration gallery. The groundwater recovery method and discharge
option would be determined during remedial design. Costs include the construction of
interceptor trenches to collect the highest concentrations of pesticides, a carbon
adsorption treatment system, and the respective discharge option. Operation and
maintenance costs include power consumption, a site operator, carbon replacement
sampling, and a remedy review every 5 years for a 10 year period. Detailed cost estimates
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for Alternative 3 are provided in Tables 17a and 17b. Costs are rounded to two
significant figures.
8.1.3.3 Expected Outcomes of Alternative 3
After clean up goals are achieved (estimated time frame of 10 years), groundwater should
be available to drink without having to treat to remove pesticides.
8.1.4 Alternative 4: Groundwater Recovery of Pesticide Residuals Exceeding Clean
up Goals using Extraction Wells and/or Interceptor Trenches, Treatment by Carbon
Adsorption, Discharge of Treated Groundwater via Surface Water or Reinjection (Infiltration
Galleries/Injection Wells), Continued Groundwater/Surface Water Monitoring, Area
Reconnaissance, and Alternative Water Supply/Well Head Treatment should Future Potential
Receptors be identified
8.1.4.1 Description of Alternative 4 Components
Ground\vater Extraction and Treatment Components
Groundwater containing pesticides above clean up goals would be extracted using
extraction wells or interceptor trenches.
Extracted groundwater would be treated using carbon adsorption.
Treated groundwater would be discharged via surface water or a re-injection method.
Monitoring of the Extraction, treatment and discharge systems until clean up goals are
achieved.
Monitoring Program
A monitoring would be implemented as a mechanism by which future receptors within the
migration pathway of COCs are identified and addressed, if necessary. Monitoring would also be
used to maintain exposure control within the defined remedial action objectives.
Monitoring would involve periodic (short and long-term) sampling and analysis of groundwater/
surface water/sediments.
Area Reconnaissance - Same as Alternative 2
Alternative Water Supply/ Well Head Treatment - Same as Alternative 2.
-------
Table 17 a
Alternative 3 with Discharge to Surface Water
Mclver Dump Area
Item Basis of Cost
PIRECT CAPITAL COSTS
MOBILIZATION/DEMOBILIZATION
ADMINISTRATIVE FEES (Easement, Private Property Access)
COMMUNITY RELATIONS ASSISTANCE
EXTRACTION SYSTEM- Interceptor Trench
Effluent Pipe
Effluent Pipe Trenching, Backfill
Interceptor Trench Trenching, Backfill
Aggregate
Drainage Fabric
Gallery Pipe
Power Pole and Cable
Unit Cost Units Quantity Total Cost
2inchPVC
5 ft deep by 2 ft wide
Underground Electrical (wire, conduit, trenching, backfill)
4 inch perforated PVC
1 Pole per 200 feet
Extraction Pumps (installed)
10 GPM, 1/3 HP pumps
TREATMENT SYSTEM- Carbon Adsorption
Carbon Units (installed, piping and carbon included) 1000 Ib carbon units
Filter, installed
Site Prep, Foundation, Electrical 15 ft x 15 ft
Treatment Building 15 ft x 15 ft
pH Adjustment System (tank, metering pump, electrical, manhole)
DISCHARGE SYSTEM- Surface Water Discharge
Obtain NPDES Permit
Effluent Pipe 2 inch PVC
Effluent Pipe Trenching, Backfill
Flow Meter (Omega), installed
Force Main Pump, installed 20 GPM, 1 HP
INDIRECT CAPITAL COSTS
REMEDIAL DESIGN
Health and Safety @ 5% of Direct Capital Costs (DCQ
Bonds & Insurance @ 5% of DCC
Contingency @ 20% of DCC
Eng. & Const Mgmt @ 15% of DCC
Prime Contractor Ovrhd & Prft @ 10% of DCC
ANNUAL OPERATING AND MAPfTENANCE COSTS
MISCELLANEOUS
Power (895 kWhr/mo @ $0.10/kWhr)
Operator
Miscellaneous Repairs
Carbon Replacement (1800 Ibs/yr)
Caustic Addition
Total Pump HP = 2.0
60hrs/MO
$5,000
$20,000
$20,000
LS
LS
LS
1 .
1
1
$5,000
$20.000
$20,000
$4.70
-$2.83
$4.81
$24
$1
$3.87
$2.000
$18
$1,425
FT
FT
FT
CY
SF
FT
EA
FT
EA
1.100
1.100
240
70
2.700
240
2
1.100
3
$5.170
$3.113
$1,154
$1.680
$2.700
$929
$4,000
$19,800
$4.275
$42,821
$7,950
$4,000
$20
$30
$15,000
$15,000
$4.70
$2.83
$660
$1,980
$140,000
EA
EA
SF
SF
LS
LS
FT
FT
EA
EA
LS
2
1
225
225
1
-
1
125
125
1
1
1
$15,900
$4,0(X)|
$4400*
$6.750
$15.000
$46,150
$15,000
$588
$354
$660
$1.980
$18,581
$140.000
$7,628
$7,628
$30,510
$22.883
$15.255
$223,904
TOTAL CAPITAL COSTS:
$380,000
$110 MO.
$3300 MO
$10,000 YR
$1.20 LB
$2,000 YR
12
12
1
1,800
1
yrs, i=7%, e=4%. PWF=8.53):
$1,320
$39,600
$10,0001
$2,160 ^
$2.000
$55,080
$469,832
-48-
-------
Table 17a(cont.)
Ahernative 3 with Discharge to Surface Water
Mclver Dump Area
Item
MONITORING
Sampling - First 5 Years:
Quarterly Sampling (Labor + Supplies)
Quarterly Sampling (Pesticide Analyses)
Quarterly QA/QC Samples
Annual Sampling (Pesticide Analyses)
Treatment System Sampling (Analyses)
Treatment System Sampling (labor + supplies)
Validation and Report Preparation
Sampling - Years 5-10:
Annual Sampling (Labor + Supplies)
Annual Sampling (Analyses)
Annual QA/QC Samples
Treatment System Sampling (Analyses)
Treatment System Sampling (Labor + Supplies)
Validation and Report Preparation
NEW PUMPS - as needed
Basis of Cost
Unit Cost Units Quantity Total Cost
TOTAL PRESENT WORTH COST
2 days, 1 night + equipment $4,700 3 MO
4 groundwater samples $620 3 MO
2 water samples $310 3 MO
2 surf, water, 2 sed.. 3 QA/QC $1,115 YR
3 water samples, I QA/QC $620 WK
1 day + equipment $500 WK
$3,600 3 MO
4
4
4
1
52
48
4
Present Worth (n=5 yrs, i=7%, e=4%. PWF=4.58):
2 days, 1 night + equip. $4,700 YR
4 gw, 2 sw, 2 sed samples $1.260 YR
4 water, 1 sediment sample $785 YR
3 water samples, 1 QA/QC $620 Bi-Mo
1 day + equipment $500 Bi-Mo
$3,600 LS
1
1
1
24
23
1
Present Worth (n=5-10, i=7%, e=4%. PWF=3.95):
Extraction Well Pumps $1,425 EA
Force Main $1.980 EA
3
1
Present Worth (n=5&10. i=7%, e=4%, PWF=1.60)
TOTAL O&M COSTS:
$18,800
$2,480
$1,240
$1.115
$32,240
$24,000
$14.400
$94,275
$431,780
$4.700
$1,260
$785
$14,880
$11400
$3.600
$36,725
$145.064
$4,275
$1.980
$6,255
$10,008
$1,100,000
$1.500.000
-49-
-------
Table 17b
Alternative 3 with Discharge via Infiltration Galleries
Mclver Dump Area
Basis of Cost
Unit Cost Units Quantity Total Cost
DIRECT CAPITAL COSTS
MOBILIZATION/DEMOBILIZATION
ADMINISTRATIVE FEES (Easement, Private Property Access)
COMMUNITY RELATIONS ASSISTANCE
EXTRACTION SYSTEM- Interceptor Trench
Effluent Pipe
Effluent Pipe Trenching, Backfill
Interceptor Trench Trenching. Backfill
Aggregate
Drainage Fabric
Gallery Pipe
Power Pole and Cable
Underground Electrical (wire, conduit, trenching, backfill)
Extraction Pumps (installed)
2 inch PVC
5 ft deep by 2 ft wide
4 inch perforated PVC
1 Pole per 200 feet
10 GPM, 1/3 HP pumps
TREATMENT SYSTEM- Carbon Adsorption
Carbon Units (installed, piping and carbon included) .
Filter, installed
Site Prep. Foundation, Electrical
Treatment Building
DISCHARGE SYSTEM- Infiltration Gallery
Obtain Permit/Percolation Testing
Effluent Pipe
Effluent Pipe Trenching, Backfill
Gallery Trenching, Backfill (50% Redundancy)
Aggregate
Drainage Fabric
Gallery Pipe
Pump, installed
INDIRECT CAPITAL COSTS
REMEDIAL DESIGN
Health and Safety @ 5% of Direct Capital Costs (DCC)
Bonds & Insurance @ 5% of DCC
Contingency @ 20% of DCC
Eog. & Const Mgmt. @ 15% of DCC
Prime Contractor Ovrhd&Prftฎ 10%ofDCC
ANNUAL OPERATING AND MAINTENANCE COSTS
MISCELLANEOUS
Power (1080 kWhr/mo @ $0.1fl/kWhr)
Operator
Miscellaneous Repairs
Carbon Replacement (1200 Ibs/yr)
1000 Ib carbon units
ISftxlSft
ISftxlSft
2 inch PVC
3 ft deep by 2 ft wide
4 inch perforated PVC
30 GPM, 1 HP
$5,000
520,000
$20,000
$4.70
$2.83
$4.81
S24
SI
$3.87
$2,000
$18
$1,425
$7,950
$4,000
$20
$30
$25,000
$4.70
$2.83
$6.14
$24
$1
$3.87
S1.980
$140,000
LS
LS
LS
FT
FT
FT
CY
SF
FT
EA
FT
EA
EA
EA
SF
SF
LS
FT
FT
FT
CY
SF
FT
EA
LS
1
1
1
1,100
1,100
240
70
2,700
240
2
1,100
3
2
1
225
225
1
400
400
800
ISO
8,800
800
1
1
$5,000
$20,000
$20,000
$5,170
$3,1 13
$1,154
$1,680
$2.700
$929
$4.000
$19,800
$4.275
$42,821
$15,900
$4,000
$4,500
$6.750
$31.150
$25.000
$1.880
$1,132
$4,912
$4,320
$8,800
$3,096
$1.980
$51,120
$140.000
$8,505
$8405
$34,018
$25414
$17.009
$233450
TOTAL CAPITAL COSTS:
total pump HP = 2.0
SOhrs/MO
$108
$2,750
$8,000
$1.20
MO.
MO
YR
LB
12
12
1
1,800
Present Worth (n=10 yrs, i=7%. e=4%, PWF=8.53):
$400,000
$1,296
$33,000
$8,000
S2.160
$44,456
$379,210
-50-
-------
Table 17b(cont.)
Alternative 3 with Discharge via Infiltration Galleries
Mclver Damp Area
Item
MONITORING
Sampling - First 5 Years:
Quarterly Sampling (Labor + Supplies)
Quarterly Sampling (Pesticide Analyses)
Quarterly QA/QC Samples
Annual Sampling (Pesticide Analyses)
Treatment System Monitoring (Analyses)
Treatment System Monitoring (Labor + Supplies)
Validation and Report Preparation
Sampling Years 5-10:
Annual Sampling (Labor + Supplies)
Annual Sampling (Analyses)
Annual QA/QC Samples
Treatment System Monitoring (Pesticide Analyses)
Treatment System Monitoring (Labor + Supplies)
Validation and Report Preparation
NEW PUMPS - as needed
REMEDY REVIEW
TOTAL PRESENT WORTH COST
Basis of Cost
Unit Cost Units Quantity Total Cost
2 days, 1 night + equipment
4 groundwater samples
2 water samples
2 water, 2sed.,3QA/QC
2 water samples, 1 QA/QC
1 day + equipment
$4,700 3 MO
$620 3 MO
$310 3 MO
$1,115 YR
$465 MO
$500 MO
$3,600 3 MO
4
4
4
1
12
8
4
Present Worth (n=5 yrs, i=7%, e=4%, PWF=4.58):
2 days. 1 night + equip.
4 gw, 2 sw, 2 sed samples
4 water, 1 sed.
2 water samples, 1 QA/QC
1 day + equipment
$4.700 YR
$1.260 YR
$785 YR
$465 MO
$500 MO
$3,600 LS
1
1
1
12
11
1
Present Worth (n=5-10, i=7%, e=4%, PWF=3.95)
Extraction Well Pumps
Force Main
$1,425 EA
$1,980 EA
2
1
Present Worth (n=5&10, i=7%, e=4%, PWr=1.60)
$ 100,000 every 5 years
Present Worth (see B.l-1. PWP=1.60):
TOTAL O&M COSTS:
$18.800
$2,480
$1,240
$1,115
$5480
$4,000
$14.400
$47,615
$218,077
$4,700
$1.260
$785
$5,580
$5400
$3.600
$21,425
$84,629
$2,850
$1.980
$4.830
$7,728
$100,000
$160,000
$800,000
$1.200.000
-51-
-------
ROD
Aberdeen OU5
Page 52
Remedy Revi&v - Same as Alternative 2
8.1.4.2 Other Features of Alternative 4
Groundwater clean up goals would be achieved by removing pesticides above clean up
goals using extraction wells and/or interception trenches.
flnHt r ul flฐW VelOCky' the hydraulic Sradient ^ar the surface water body
and the limited discharge distance to the creek, increasing the gradient through extraction
would not significantly decrease the time frame to achieve clean up goals. The time frame
to achieve clean up goals under Alternative 4 is estimated to be 10 years.
For cost estimate purposes, interceptor trenches were assumed as the groundwater
recovery method. Total present worth costs for Alternative 4 were estimated using two
cos't is'S oonnnn ^^ "J"1* W&ter aฐd infiltration ซalleries' The estimated total
cost is $2,000 000 with the surface water discharge option and $1,600 000 with an
infiltration gallery. Actual discharge options (and recovery options) would be determined
during remedial design. Costs include the same parameters as with Alterative 3
However, because groundwater extraction rates are higher, extraction, treatment and
discharge systems are more costly. Detailed cost estimates for Alternative 4 are provided
in Tables 18a and 18b. Costs are rounded to two significant figures.
8.1.4.3 Expected Outcomes of Alternative 4
vahtn achTd
-------
Table 18a
Alternative 4 with Discharge via Surface Water
Mclver Dump Area
Item Basis of Cost
DIRECT CAPITAL COSTS
MOBUJZATION/DEMOBILIZATION
ADMINISTRATIVE FEES (Easement, Private Property Access)
COMMUNITY RELATIONS ASSISTANCE
4inchPVC
5 ft deep by 2 ft wide
EXTRACTION SYSTEM- Interceptor Trenches
Effluent Pipe
Effluent Pipe Trenching, Backfill
Interceptor Trench Trenching, Backfill
Aggregate
Drainage Fabric
Gallery Pipe 4 inch perforated PVC
Power Pole and Cable 1 Pole per 200 ft
Underground Electrical (wire, conduit, disconnect, installation)
Extraction Pumps, installed 40 GPM, 1/2 HP pumps
TREATMENT SYSTEM- Carbon Adsorption
Carbon Units (installed, piping and carbon included) 1000 Ib units
Equalization Tank, Pumps, Filter (installed)
Site Prep, Foundation, Electrical 30 ft x 25 ft
Treatment Building 30 ft x 25 ft
pH Adjustment System (tanks, metering pump, electrical, manhole)
DISCHARGE SYSTEM- Surface Water Discharge
Obtain NPDES Permit
Effluent Pipe 4 inch PVC
Effluent Pipe Trenching, Backfill
Flow Meter, installed
Force Main Pump, installed 120 GPM, 2 HP
INDIRECT CAPITAL COSTS
REMEDIAL DESIGN
Health and Safety @ 5% of Direct Capital Costs (DCC)
Bonds & Insurance @ 5% of DCC
Contingency @ 20% of DCC
Eng. & Const Mgmt @ 15% of DCC
Prime Contractor Ovrhd & Prft @ 10% of DCC
ANNUAL OPERATING AND MAINTENANCE COSTS
Unit Cost Units
$5,000
$20,000
$20,000
$8.60
$2.83
$4.81
$24
$1
$3.87
$2,000
$18
$1,500
$7,942
$15,500
$20
$30
$20,000
$15,000
$8.60
$2.83
$1,650
$2,901
LS
LS
LS
FT
FT
FT
CY
SF
FT
EA
FT
EA
EA
LS
SF
SF
LS
LS
FT
FT
EA
EA
1
1
1
1,100
1,100
1,150
340
12,650
1.150
2
1,100
6
6
1
750
750
1
1
125
125
1
1
$185.000 LS
TOTAL CAPITAL COSTS:
Total Cost
$5,080
$20,000
$20.000
$9,460
$3.113
$5,532
$8,160
$12,650
$4.451
$4,000
$19,800
$9.000
$76,165
$47,652
$15.500
$15.000
$22,500
$20.000
$120,652
$15,000
$1,075
$354
$1.650
$2.901
$20,980
$185,000
$13,140
$13,140
$52,559
$39,420
$26.280
$329,538
$590,000
MISCELLANEOUS
Power (2686kWhr/mo @ $0.10/kWbr)
Operator
Miscellaneous Repairs
Carbon Replacement (4480 Ibs/yr)
Caustic Addition
Total Pump HP = 5
70hrs/MO
$269
$3,850
$12,000
$1.20
$4,000
MO.
MO
YR
LB
YR
12
12
1
4.480
1
Present Worth (n=10 yrs, i=7%, e=4%, PWF=8.53):
$3.228
$46,200
$12.000
$5376
$4.000
$70.804
$603,958
-53-
-------
Table 18a(cont.)
Alternative 4 with Discharge via Surface Water
Mclver Dump Area
Basis or Cost
Unit Cost Units Quantity Total Corf
MONITORING
Sampling - Hist 5 Years:
Quarterly Sampling (Labor + Supplies)
Quarterly Sampling (Pesticide Analyses)
Annual Sampling (Pesticide Analyses)
Treatment System Monitoring (Analyses)
Treatment System Monitoring (Labor + Supplies)
Validation and Report Preparation
Sampling -Years 5-10:
Annual Sampling (Labor ป Supplies)
Annual Sampling (Analyses)
Treatment System Monitoring (Analyses)
Treatment System Monitoring (Labor + Supplies)
Validation and Report Preparation
2 days, 1 night + equipment
4 gw samples. 2 QA/QC
2 water, 2 seU, 3 QA/QC
3 water samples/MO, 1 QA/QC
I day + equipment
$4,700 3 MO
$620 3 MO
$1,115 YR
S620 WK
S500 WK
$3,600 3 MO
4
4
1
52
48
4
Present Worth (n=5 yrs, i=7%, e=496, PWF=4.58):
2'days, 1 night + equip.
4 gw, 2 sw, 2 sed samples, 5 QA/QC
3 water samples, 1 QA/QC
1 day + equipment
$4.700 YR
$2,045 YR
$620 Bi-Mo
$500 Bi-Mo
$3,600 LS
I
1
24
23
1
Present Worth (n=5-10, i=7%, e=4%, PWF=3.95):
NEW PUMPS- as needed
Extraction Well Pumps
Force Main & Treatment Pumps
$1,500 EA
$3.000 EA
3
2
Present Worth (n=5&10, 1=7%, e=4%, PWF=1.60)
REMEDY REVIEW
$100,000 every 5 years
-
Present Worth (see B.l-1, PWF=1.60):
$18,800
$2.480
$1,115
$32,240
$24,000
$14.400
$93.035
$426.100
$4,700
$2,045
$14,880
$11,500
$3.600
$36,725
$145.064
$4,500
$6.000
$10.500
$16,800
$100,000
$160.000
TOTAL O&M COSTS:
TOTAL PRESENT WORTH COST
$1,400,000
$2.000.000
-54-
-------
Table 18b
Alternative 4 with Discharge via Infiltration Gallery
Mclver Dump Area
Item Basis of Cost
DIRECT CAPITAL COSTS
MOBnJZATION/DEMOBELJZATION
ADMINISTRATIVE FEES (Easement, Private Property Access)
COMMUNITY RELATIONS ASSISTANCE
Unit Cost Units Quantity Total Cost
EXTRACTION SYSTEM- Interceptor Trenches
Effluent Pipe
Effluent Pipe Trenching, Backfilling
Interceptor Trench Trenching, Backfilling
Aggregate
Drainage Fabric
Gallery Pipe
Power Pole and Cable
4 inch PVC
5 ft deep by 2 ft wide
4 inch perforated PVC
1 Pole per 200 ft
Underground Electrical (wire, conduit, disconnect, installation)
Extraction Pumps, installed
TREATMENT SYSTEM- Carbon Adsorption
Carbon Units (installed, piping and carbon included)
Equalization Tank, Pumps, Filter (installed)
Site Prep, Foundation, Electrical
Treatment Building
DISCHARGE SYSTEM- Infiltration Gallery
Obtain Permit/Percolation Testing
Effluent Pipe
Effluent Pipe Trenching, Backfilling
Gallery Trenching, Backfilling (50% Redundancy)
Aggregate
Drainage Fabric
Gallery Pipe
Pump, installed
INDIRECT CAPITAL COSTS
REMEDIAL DESIGN
Health and Safety @> 5% of Direct Capital Costs (DCC)
Bonds & Insurance @ 5% of DCC
Contingency @ 20% of DCC
Eng. & Const. Mgmt @ 15% of DCC
Prime Contractor Overhead & Prft @ 10% DCC
20 GPM pumps, 1/2 HP
1000 Ib units
30ftx25ft
30ftx25ft
4 inch PVC
3 ft deep by 2 ft wide
4 inch perforated PVC
120 GPM, 2 HP
$5,000
$20,000
$20.000
$8.60
$2.83
$4.81
$24
$1
$3.87
$2,000
$18
$1400
$7,942
$15,500
$20
$30
$25,000
$8.60
$2.83
$2.83
$24
$1
$3.87
$2,901
LS
LS
LS
FT
FT
FT
CY
SF
FT
EA
FT
EA
EA
LS
SF
SF
LS
FT
FT
FT
CY
SF
FT
EA
1
1
1
1,100
1,100
1,150
340
12,650
1,150
2
1.100
. 6
6
1
750
750
1
400
400
2,250
350
24,750
2.250
1
$175,000 LS
TOTAL CAPITAL COSTS:
$9,460
$3,113
$5^32
$8,160
$12,650
$4,451
$4,000
$19,800
$9.000
$76.165
$47,652
$15400
$15,000
$22.500
$100,652
$25,000
$3,440
$1,132
$6,368
$8,400
$24,750
$8,708
$2.901
$80,698
$175.000
$15,126
$15,126
$60403
$45^77
$30.252
$341483
$640,000
-55-
-------
Item
Table 18b(cont.)
Alternative 4 with Discharge via Infiltration Gallery
Mclver Dump Area
Basis of Cost
Units
ANNUAL OPERATING AND MAINTENANCE COSTS
MISCELLANEOUS
Power (2686 kWhr/mo @ $0.10/kWhr)
Operator
Miscellaneous Repairs
Carbon Replacement (4480 Ibs/yr)
MONITORING
Sampling - First 5 Years:
Quarterly Sampling (Labor + Supplies)
Quarterly Sampling (Analyses)
Annual Sampling (Pesticide Analyses)
Treatment System Monitoring (Analyses)
Treatment System Monitoring (Labor + Supplies)
Validation and Report Preparation
Sampling - Years 5-10:
Annual Sampling (Labor+Supplies)
Annual Sampling (Analyses)
Treatment System Monitoring (Analyses)
Treatment System Monitoring (Labor + Supplies)
Validation and Report Preparation
NEW PUMPS . as needed
REMEDY REVIEW
TOTAL PRESENT WORTH COST
s
Total Pump HP = 5 $269 MO. 12 "
60bours/MO $3.300 MO 12
$10,000 YR 1
$1.20 LB 4,480
Present Worth (n=10 yrs, i=7%, e=4%, PWF=8.53):
2 days, 1 night + equip. $4,700 3 MO 4
4gwsamples,2QA/QC $930 3 MO 4
2 water. 2 sediment, 3 QA/QC $1,115 YR I
2 water samples, 1 QA/QC $465 MO 12
1 day + equipment $500 MO . 8
$3,600 3 MO 4
Present Worth (n=5 yrs, i=7%, e=4%, PWF=4.58):
2 days, 1 night + equip. $4,700 YR 1
4gw,2sw,2sed,5QA/QC $2,045 YR 1
2 water samples, 1 QA/QC $465 MO 12
1 day + equipment $500 MO 11
$3.600 LS 1
Present Worth (n=5-10, i=7%, e=4%, PWF=3.95)
Extraction Well Pumps $1,500 EA 3
Discharge & Treatment Pumps $3.000 EA 2
Present Worth (n=5&10, i=7%, e=4%, PWF=1.60)
$100,000 every 5 years
Present Worth (see B.l-1. PWB=1.60):
TOTAL O&M COSTS:
$3.228
$39,600
$10,000
$5.376
$58,204
$496,480
$18,800
$3,720
$1,115
$5,580
$4,000
$14.400
$47,615
$218,077
$4,700
$2,045
$5,580
$5,500
$3.600
$21.425
$84,629
$4400
$6.000
$10400
$16,800
$100,000
$160,000
$1,000,000
$1.600.000
-56-
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associated with this alternative. A detailed cost estimate for Alternative 1 is provided in Table
19. Costs are rounded to two significant figures.
8.2.2 Alternative 2: Continued Groundwater Monitoring, Area Reconnaissance, and
Well Head Treatment or Alternative Water Supply, if Future Potential Receptors are identified
8.2.2.1 Description of Alternative 2 Components
Monitor Natural Attenuation
Groundwater monitoring would be used to verify that natural aquifer processes are reducing
contaminant concentrations to acceptable levels by intrinsic remediation in the Surficial aquifer,
upper portion of the Upper Black Creek Aquifer, lower portion of the Upper Black Creek
Aquifer, and Lower Black Creek Aquifer; to determining the concentration, distribution, and
migration of the COCs in groundwater, and to verify that the clean up goals are achieved during
remedial action. Additionally, monitoring would be used as a mechanism by which future
receptors within the migration pathway of COCs are identified and addressed, if necessary.
Monitoring would be used to maintain exposure control within the defined remedial action
objectives.
The monitoring program would consist of sampling and analysis of monitoring wells in all aquifers
in the pathway of impacted groundwater migration. The existing monitoring well network and
potential new monitoring wells placed at strategic locations would serve as "trigger" mechanism
wells. Statistical increases of pesticide concentrations above acceptable exposure levels
determined through trend analysis would "trigger" an evaluation of potential receptors in the
migration pathway of the groundwater. Should an exposure pathway exist, a well head treatment
system would be installed or an alternative water supply would be provided to the receptors. A
monitoring program under Alternative 2 would be established for groundwater in all aquifers with
existing monitoring wells and proposed monitoring wells. The monitoring program would include
monitoring of municipal well #13. Other details of the monitoring program would be developed
during remedial design.
Area Reconnaissance
Area reconnaissance would be used to determine whether properties at the area are for sale,
purchased, or being leased. This would be accomplished by reconnoitering the Route 211 Area
and reviewing property records. Town development plans would be reviewed to determine any
future development strategies for the route 211 Area. Additionally, residential well surveys have
been conducted at the Route 211 Area. Through area reconnaissance, the residential well surveys
would be verified and updated. Area reconnaissance is an effective means of controlling exposure
as defined in the remedial action objectives. The area reconnaissance program would be in place
until clean up goals are achieved.
-------
Table 19
Alternative 1
Route 211 Area
REMEDY REVIEWEvery 5 Years, $100,000
Calculation of Present Worth Factors (PWF) at 7% interest and 4% inflation:
Year PWF
5
10
15
20
25
30
Total:
Remedy Review, Present Worth Cost (30 years, i=7%, e=4%):
TOTAL PRESENT WORTH COST;
0.8626
0.7441
0.6419
0.5537
0.4776
0.4120
3.6919
$369,000
$370.000
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Alternative Water Supply/ Well Head Treatment
Currently, there are no receptors of impacted groundwater. However, if potential receptors are
identified in the future, an alternative water supply or well head treatment would be used to
prevent exposure. This option would be available for any potential receptor until clean up goals
are achieved.
Remedy Review
A remedy review would be performed every 5 years until clean up goals are achieved to determine
the effectiveness of the remedy to protect human health and/or the environment. As a result of
this review, if needed, additional site remediation or modifications to the remedy would be
performed.
8.2.2.2 Other Features of Alternative 2
Groundwater clean up goals for the COCs would be achieved by natural attenuation.
The time frame to achieve the clean up under Alternative 2 was not estimated. However,
without mitigating the migration of source area groundwater, the time frame to achieve
the clean up goals could be expected to be greater than alternatives 3 and 4.
The estimated total present worth cost for Alternative 2 is $ 1,400,000. Costs include
installation of additional monitoring wells, area reconnaissance, periodic sampling, and
remedy review. A detailed cost estimate for Alternative 2 is provided in Table 20. Costs
are rounded to two significant figures.
8.2.2.3 Expected Outcomes of Alternative 2
After clean up goals are achieved, groundwater should be available to drink without
having to treat to remove pesticides.
8.2.3 Alternative 3: Groundwater Recovery from the Source Area Groundwater
Using Extraction Wells, Treatment by Carbon Adsorption, and Discharge of Treated
Groundwater via Reinjection (Infiltration Galleries/Injection Wells), Continued Groundwater
Monitoring of the Surficial, Upper Black Creek and Lower Black Creek aquifers, Area
Reconnaissance, and Contingency Controls with Well Head Treatment or Alternative Water
Supply if Future Potential Receptors are identified.
8.2.3.1 Description of Alternative 3 Components
-------
Table 20
Alternative 2
Route 211 Area
Basis of Cost
Unit Cost Units
DIRECT CAPITAL COSTS
ADMINISTRATIVE FEES
COMMUNITY RELATIONS ASSISTANCE
MUNICIPAL WATER SUPPLY CONNECTIONS
MONITORING WELLS INSTALLATION
Mobilization/Demobilization
Decontamination Pad
Equipment Decontamination
Drilling and Materials 4 we]]s
Split Spoon Samples Every 5 ft
Well Development 15 hrs per well
Installation Oversight Geologist
INDIRECT CAPITAL COSTS
Health and Safety @ 5% of Direct Capital Costs (DCC)
Bonds & Insurance @ 5% of DCC
Contingency @ 20% of DCC
Eng. & Const. Mgmt. @ 15% of DCC
Prime Contractor Ovrhd & Prft @ 10% of DCC
ANNUAL OPERATING AND MAINTENANCE COSTS
SITE RECONNAISSANCE
MONITORING
Sampling - Pint 5 Years:
Quarterly Sampling (Labor+Supplies)
Quarterly Sampling (Pesticide Analyses)
Validation and Report Preparation
Sampling -Years 5-30:
Annual Sampling (Labor + Supplies)
Annual Sampling (Analyses)
Validation and Report Preparation
REMEDY REVIEW
TOTAL PRESENT WORTH COST
Quantity
Total Cost
$30.000
$20,000
$175,000
$2,000
$350
$120
$80
$20
$120
$1,000
LS
LS
LS
EA
EA
HR
LF
EA
HR
Day
1
1
1
1
4
8
469
94
60
6
*
.
$30,000
$20,000
$175,000
$2,000
$1,400
$960
$37,520
$1.880
$7,200
$6.000
$56.960
$14,098
$14,098
$56392
$42,294
$28.196
$155,078
TOTAL CAPITAL COSTS:
8 hrs (during sampling event) $400 YR 1
Present Worth (n=30, i=7%, e=4%, PWF=19.60)
5days,4nts+eqmp. $10,000 3 MO 4
23 gw samples, 6 QA/QC $4,495 3 MO 4
$4^00 3 MO 4
Present Worth (n=5 yrs, i=7%, e=4%. PWF=4.58)
5days.4nts+equip. $10,000 YR 1
23 gw samples. 6 QA/QC $4,495 YR 1
$4300 LS 1
Present Worth (h=5-30, i=7%, e=4%, PWF=15.02)
$100,000 every 5 years
Present Worth (See B.2-1 , PWF=3.69):
TOTAL O&M COSTS:
i
$400
$7.840
$40,000
$17,980
$17,2Q9
$75.180
$344.324
$10,000
$4.495
$4.300
$18.795
$282301
$100,000
$369,000
$1,000,000
$1.400.000
$440,000
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Groundwater Extraction and Treatment
Groundwater underlying the former disposal area referred to as "Source Area
groundwater" in the Surficial Aquifer, which poses the most significant risk at the Route
211 Area, would be extracted using extraction wells. .
Extracted groundwater would be treated using carbon adsorption.
Treated groundwater would be discharged via re-injection (infiltration galleries/injection
wells).
Monitoring of the extraction, treatment and discharge systems until clean up goals are
achieved.
Monitor Natural Attenuation - Same as Alternative 2
Area Reconnaissance - Same as Alternative 2
Alternative Water Supply/ Well Head Treatment - Same as Alternative 2.
Remedy Review - Same as Alternative 2
8.2.3.2 Other Features of Alternative 3
Groundwater clean up goals would be achieved by removing the Source Area
groundwater from the Surficial Aquifer using extraction wells; and by intrinsic remediation
in the rest of the plume and aquifers.
Through the removal of pesticide residuals and extraction of Source Area groundwater
from the Surficial Aquifer, pesticide concentrations would continue to reduce in all
aquifers.
The estimated time frame to achieve the clean up goal in the various aquifers ranges from
0 to less than 30 years for gamma BHC (Lindane); from less than 5 to 90 years for alpha
BHC; from less than 5 to 90 years for beta BHC ; and from 0 to less than 5 years for delta
BHC.
Costs for this alternative assumed the use of an infiltration gallery as the discharge
method. The estimated total present worth cost for Alternative 3 is $2,600,000. Costs
associated with this alternative include continued monitoring and periodic Area
reconnaissance. Additional costs above that of Alternative 2 include well-head
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components for the existing pumping well, a carbon adsorption treatment system and a
reiryection system. Operating and maintenance costs associated with this alternative
include power, a site operator, carbon replacement, and sampling of the treatment system
A detailed cost est.mate for Alternative 3 is provided in Table 21 Costs are rounded to
two significant figures.
8.2.3.3 Expected Outcomes of Alternatives
After clean up goals are achieved , groundwater should be available to drink without
having to treat to remove pesticides.
8.2.4 Alternative 4: Groundwater Recovery from the Source Area Groundwater the
upper and lover portions of the Upper Black Creek Aquifer, and the Lower sLck Creek
rustng ^traction Wells, Treatment by Carbon
er vta remjection (Infiltration Galleries/Injection Wells) from the Source Area
MonA - ' rouner
Monitor ng, A Reconnaissance, and Exposure Controls with Well Head Treatment or
Alternative Water Supply if any Future Potential Receptors are identified.
8.2.4.1 Description of Alternative 4 Components
Groundwater Extraction and Treatment
Groundwater containing pesticides above clean up goals would be extracted from all
aquifers using extraction wells.
Extracted groundwater would be treated using carbon adsorption.
wn^T11^^1"' eXtraCted frฐm the source area groundwater (Surficial Aquifer)
would be discharged via re-injection (infiltration galleries/injection wells).
via surface
eXtraCtiฐn' treatment and discharge svstems u^il clean up goals are
Monitoring Program
mtheTa1h^t?f imnaS 7"" "T^ ^^ ^ ^^ of monitoring wells in all aquifers
the pathway of impacted groundwater migration. The existing monitoring well network and
-------
Table 21
Alternative 3
Route 211 Area
2inchPVC
Basis of Cost
DIRECT CAPITAL COSTS
ADMINISTRATIVE FEES
COMMUNITY RELATIONS ASSISTANCE
MUNICIPAL WATER SUPPLY CONNECTIONS
MONITORING WELL INSTALLATIONS
Mobilization/Demobilization
Decontamination Pad
Equipment Decontamination
Drilling and Materials 4 Wel]s
Split Spoon Samples Every 5 ft
Well Development ' 15 hours per weU
installation Oversight Geologist
EXTRACTION SYSTEM-Existing WeU
Effluent Pipe
Effluent Pipe Trenching, Backfill
Electrical (wire, conduit, disconnect, installation)
Pump (submersible) 4 g^ 1/3 up
Well-head Equipment (including controller and valves, installed)
Up-Gradient Monitoring Well
TREATMENT SYSTEM- Carbon Adsorption
Carbon Units (piping and carbon included)
Filter
Site Prep, Foundation 15 ft x 15 ft
Treatment Building 15 ft x 15 ft
Electrical Installation (wire, disconnect, fixtures, etc.)
DISCHARGE SYSTEM- Infiltration Gallery
Obtain Permit
Effluent Pipe
Effluent Pipe Trenching, Backfilling
Gallery Trenching, Backfilling
Aggregate
Drainage Fabric
Gallery Pipe
Distribution Pump, installed
Unit Cost Units Quantity Total Cost
190 Ib unit, installed
linchPVC
3 ft deep by 2 ft wide
2 inch perforated PVC
5 GPM pump, 1/2 HP
ELECTRICAL DISTRIBUTION
Power Pole and Cable 1 poie per 200 ft
Underground Service (wire, conduit, trenching. & backfill)
$50,000
$20,000
$175,000
$2,000
$350
$120
$80
$20
$120
$1,000
$4.70
$2.83
$200
$1,200
$3400
$12,000
$1,324
$3.000
$10
$30
.$10,000
$25,000
$2.71
$2.83
$6.14
$24
$1
$2.65
$1,800
$2,000
$18
LS
LS
LS
EA
EA
HR
LF
EA
HR
Day
FT
FT
LS
EA
EA
LS
LS
LS
SF
SF
LS
LS
FT
FT
FT
CY
SF
FT
EA
EA
FT
1
1
1
1
4
8
469
94
60
6
25
25
1
1
1
1
2
1
225
225
1
1
500
500
120
45
1,080
120
1
4
960
$50,090
$20,000
$175,000
$2,000
$1,400
$960
$37420
$1,880
$7,200
$6.000
$56,960
$118
$71
$500
$1,200
$3400
$12.000
$17.388
$2.648
$3,000
$2,250
$6,750
$10-000
$24,648
$25,000
$1,355
$1.415
$737
$1,080
$1,080
$318
$1.800
$32,785
$8,000
$17.280
$25,280
-63-
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Table 21 (cont.)
Alternative 3
Route 211 Area
Item
INDIRECT CAPITAL COSTS
REMEDIAL DESIGN
Health and Safety & 5% of Direct Capital Costs (DCC)
Bonds & Insurance ฉ5% of DCC
Contingency @ 20% of DCC
Eng. & Const. Mgmt. @ 15% of DCC
Prime Contractor Ovrhd&Prft@ 10% of DCC
Basis of Cost
Unit Cost Units Quantity
$75.000 LS 1
TOTAL CAPITAL COSTS:
Total Cost
$75,000
$20.103
$20.103
$80,412
$60,309
$40.206
$296.134
$700,000
ANNUAL OPERATING AND MAINTENANCE COSTS
MEOEXLANEOUS
Power (536 fcWhr/mo @ $0.1Q/kWhr)
Operator
Carbon Replacement (74 Ib/yr)
Total Pump HP =1 $53.60 MO 12
50hrs/MO $2,750 MO 12
$1.20 YR 100
Site Reconaissance (8 hours, completed during sampling event) $400 YR 1
Miscellaneous Repairs
MONITORING
Sampling - Hist 5 Years:
Quarterly Sampling (Labor 4- Supplies)
Quarterly Sampling (Pesticide Analyses)
Treatment System Monitoring
Validation and Report Preparation
Sampling - Years 5-30:
Annual Sampling (Labor + Supplies)
Annual Sampling (Analyses)
Treatment System Monitoring
Validation and Report Preparation
NEW PUMPS - as needed
$8,000 YR ' 1
Present Worth (n=30, i=7%, e=4%, PWF=1 9.60):
5aays,4nts + equip. $10,000 3 MO 4
23 gw samples. 6 QA/QC $4,495 3 MO 4
6gwsamp!es,2QA/QC $1,240 3 MO 4 -
$4,300 3 MO 4
Present Worth (n=5 yrs, i=7%, e=4%, PWF=4.58)
5 days, 4 nts -i- equip. $10,000 YR 1
23 gw samples, 6 QA/QC $4.495 YR 1
6 gw samples, 2 QA/QC $1,240 YR 1
$4,300 LS 1
Present Worth (n=5-30, i=7%, e=4%, PWB=15.02)
Extraction and Distribution Pumps $1,800 EA 2
Present Worth (n=10&20, i=7%, e=4*. PWF=1.29)
INFILTRATION GALLERY REINSTALLATTON AT 15 YEARS '$3,215 LS 1
REMEDY REVIEW
Present Worth (n=15.i=7%,e=4%,PWF=0.64)
$100,000 every 5 years
Present Worth (n=30, i=7%, n=4%, PWF=3.69):
$643
$33,000
S120
$400
$8.000
$42,163
$826399
$40,000
$17,980
$4,960
$17.200
$80,140
$367,041
$10,000
$4,495
$1,240
$4.300
$20.035
$300,926
$3,600
$4,644
$3.215
$2,058
$100.000
$369,000
TOTAL O&M COSTS:
TOTAL PRESENT WORTH COST
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potential new monitoring wells placed at strategic locations would serve as "trigger" mechanism
wells. Statistical increases of pesticide concentrations above acceptable exposure levels
determined through trend analysis would "trigger" an evaluation of potential receptors in the
migration pathway of the groundwater. Should an exposure pathway exist, a well head treatment
system would be installed or an alternative water supply would be provided to the receptors. A
monitoring program under Alternative 2 would be established for groundwater in all aquifers with
existing monitoring wells and proposed monitoring wells. Details of the monitoring program
would be developed during remedial design.
Area Reconnaissance - Same as Alternative 2
Alternative Water Supply/ Well Head Treatment - Same as Alternative 2.
Remedy Review - Same as Alternative 2
8.2.4.2 Other Features of Alternative 4
Groundwater clean up goals would be achieved by removing pesticides above clean up
goals using extraction wells.
A large treatment building to accommodate 4-10,000 Ibs. carbon vessels would be
needed. The treatment building would need to be centrally located and thousands of feet
of pipeline would be necessary for the extraction and treatment system.
An approximately 3.6 mile discharge pipeline to Quewhiffle Creek would be required and
numerous easements and property access agreements would be needed for the disturbance
of approximately 250 acres of private property.
The estimated time to achieve the clean up goal in the various aquifers ranges from 0 to
less than 20 years for gamma BHC (Lindane); from less than 5 to 55 years for alpha BHC;
from less than 5 to 55 years for beta BHC; and from 0 to less than 5 years for delta BHC.
The estimated total present worth cost for Alternative 4 is $15,200,000. Capital costs
include 22 extraction wells that would be installed as part of the groundwater extraction
system. The extraction flow rate generated by these wells would require large treatment
and discharge systems. A detailed cost estimate for Alternative 4 is provided in Table 22.
8.2.4.3 Expected Outcomes of Alternative 4
After clean up goals are achieved , groundwater should be available to drink without
having to treat to remove pesticides.
-------
Table 22
Alternative 4
Route 211 Area
- Basis of Cost
DIRECT CAPITAL COSTS
ADMINISTRATIVE EEES
COMMUNITY RELATIONS ASSISTANCE
MUNICIPAL WATER SUPPLY CONNECTIONS
PRE-DESIGN FIELD ASSESSMENT
MONITORING WELL INSTALLATIONS (4)
Mobilization/Demobilization
Decontamination Pad
Equipment Decontamination
Drilling and Materials 4 wejjs
Split Spoon Samples Every 5 ft
Well Development 15 hours per well
Installation Oversight Geologist
EXTRACTION SYSTEM - Extraction Wells (21)
Mobilization/Demobilization
Effluent Pipe (upper and lower UBC) 2inchPVC
Effluent Pipe (LBC) 4inchPVC
Effluent Pipe Trenching and Backfilling
Decontamination Pad
Equipment Decontamination
Drilling tad Materials
Split Spoon Samples
Well Development
Installation Oversight Geologists and Equipment
Underground Electrical (wire, conduit, disconnect, installation)
Pumps (submersible, installed in upper UBC) 30 GPM, 1/2 HP each
Pumps (submersible, installed in lower UBC) 30GPM.1 l/2HPeach
Pumps (submersible, installed in LBQ 80 GPM^ 5 HP each
Well Head Equip, (controller, valves, electrical, etc.. installed)
SURHCIAL AQUIFER EXTRACTION SYSTEM see Alternative 3 costs
TREATMENT SYSTEM- Carbon Adsorption
Mobilization/Demobilization
Instrumentation and Controls
Upgrade Accessibility and Roads
Carbon Units (piping and carbon included) 10,000 Ib units, installed
Equalization Tank (10,000-gaL, above-ground, steel)
Unit Cost
Units
Quantity Total Cost
3 hours per well
2110-inch diameter wells
Every 5 ft
15 hrs per well
Carbon Feed Pumps
HI to-
Piping and Valves (not otherwise included)
Site Prep, Foundation, Electrical. Security
Treatment Building
SURFIOAL AQUIFER TREATMENT SYSTEM
1.200 gpm
backwashingsand
10-inch steel .
40ftx80ft
40ftx80ft
see Alternative 3 costs
$450,000
$175,000
$175,000
$750,000
$2,000
$350
$120
$80
$20
$120
$1.000
$25,000
$4.70
$6.20
$2.83
$350
$120
$170
$20
$120
$6.000
$18
$750
$750
$2^50
$12,420
$17388
$20,000
$20,000
$50,000
$120,000
$8^00
$8300
$20,000
$60
$80
$30
$24,648
LS
LS
LS
LS
LS
EA
HR
LF
EA
HR
Day
LS
FT
FT
FT
EA
HR
LF
EA
HR
Wdl
FT
EA
EA
EA
EA
LS
LS
LS
LS
EA
EA
EA
EA
LF
SF
SF
LS
1
1
1
1
1
4
8
469
94
60
6
1
5,760
4,520
, 10,280
21
63
2388 .
478
315
21
10,280
2
12
7
21
1
1
1
1
2
1
2
1
200
3200
3^00
1
$450,000
$175,000
$175.000
$750,000
$2,000
$1,400
$960
$37.520
$1.880
$7,200
$6.000
$56,960
$25,000
$27,072
$28,024
$29,092
$7.350
$7,560
$405,960
$9,560
$37,800
$126,000
$185,040
$1400
$9,000
$15.750
$260,820
517.388
$1,192,916
$20,000
$20,000
$50,000
$240,000
$8400
$16,600
$20.000
$12,000
$256.000
$96.000
$24.648
$763.748
-66-
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Table 22 (cont.)
Alternative 4
Route 211 Area
Item
DISCHARGE SYSTEM-Surface Water
Obtain NPDES Permit
Mobilization/Demobilization
Effluent Pipe
Effluent Pipe Trenching and Backfilling
Pipe anti-floatation weights for swampy areas
Surface Restoration of Disturbed Areas
Pump Station (duplex submersible pumps)
Casing pipe for road crossings
Road and Driveway Restoration
Force Main Isolation Valves
SURFICIAL AQUIFER DISCHARGE SYSTEM
Basis of Cost
lOinchHDPE
4.5ft
-------
Table 22 (cont.)
Alternative 4
Route 211 Area
Baste of Cost
Item
MONITORING (Continued)
Treatment System and Environmental Sampling - Years 5-30:
Unit Cost Unite
Treatment System Sampling (Labor + Supplies)
Treatment System Sampling (Analyses)
Annual Well Sampling (Labor and Supplies)
Annual \Vell Sampling (Pesticide Analyses)
Annual Surface Water Sampling
Annual Surface Water Study
Validation and Report Preparation
NEW EQUIPMENT - as needed
REMEDY REVIEW
TOTAL PRESENT WORTH COST
9 water, 3 QA/QC
1 day + equipment
12 days. 11 nts + equip.
43 gw samples, 16 QA/QC
10 sw samples, 4 QA/QC
Aquatic Sample Collection
$1,860
$500
$24,000
$12.930
$3,200
$8,200
$17.200
MO
MO
YR
YR
YR
YR
LS
Quantity
12
11
1
1
1
1
1
Present Worth (n=5-30, i=7%. e=4%, PWF=15.02)
Extraction Well Pumps $34,250 LS
Transfer Pump $10,000 EA
Present Worth (n=10&20, i=7%, e=4%, PWR=1.29)
$200,000 every 5 years
Present Worth (n=30, i=7%, e=4%, PWFb3.69):
TOTAL O&M COSTS:
5
4
Total Cost
$22,320
$5,500
$24.000
$12.930
$3.200
$8.200
$17.200
$93350
$1.402.117
$171,250
$40.000
$211^50
$272,513
$200,000
$738.000
$8,100,000
S1S.2OO.OOO
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9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed comparative analysis using the nine evaluation criteria set forth in the NCP was
performed on the remedial alternatives for both the Mclver Dump and Route 211 Areas. The
advantages and disadvantages were compared to identify the alternative with the best balance
among these nine criteria.
9.1 Threshold Criteria
9.1.1 Overall Protection of Human Health and the Environment
Mclver Dump Area
Alternatives 2, 3, and 4 should be relatively equivalent in regards to the overall protection of
human health and the environment. Alternative 1 would not be a protective alternative.
Currently, there are no complete exposure pathways and therefore, no significant risks to human
health. Alternatives 2, 3, and 4 would involve some controls such as monitoring and area
reconnaissance to minimize the potential for future exposure.
Alternative 2 includes the enhancement of phytoremediation at the Mclver Dump Area through
the placement of trees or other plant life in the migration pathway of the pesticides. Alternative 3
includes the recovery of groundwater containing the highest concentrations of pesticides.
Alternative 4 would attempt to recover groundwater containing pesticides exceeding their
respective cleanup goals.
Computer modeling indicates that pesticide concentrations would not increase above current
conditions. Based on the Ecological Risk Assessment, minimal impact is associated with
ecological receptors in Patterson Branch. Additionally, since source soils were removed in 1997,
residual pesticide concentrations will naturally decrease. Alternatives 2, 3, and 4 would each
further limit the potential discharge of residual pesticides into Patterson Branch. Additionally,
each of these alternatives includes establishment of a monitoring program at Patterson Branch to
ensure no significant impact to ecological receptors is maintained in the future.
Because Alternative 1 is not protective of human health and environment, it will be eliminated for
consideration under the remaining eight criteria.
Route 211 Area
All of the alternatives, except the No Action alternative, provide adequate protection of human
health. Alternatives 2, 3, and 4 would each utilize control mechanisms including continued
monitoring and area reconnaissance. Additionally, these alternatives provide exposure controls if
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sfflassr-as
health
9.1.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARsJ
Mclver Dump Area
Route 211 Area
a"nฐd
aquifers ^ ^ "^ WhUe AJtemative 4 would ^action wells in all
9.2 Primary Balancing Criteria
9.2.1 Long-Term Effectiveness and Permanence
Mclver Dump Area
^
Route 211 Area
For Alternatives 2, 3, and 4, potential future receptors would be identified through a
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9.2.2 Reduction of Contaminant Toxicity, Mobility, and Volume
Mclver Dump Area
Alternative 2 would reduce contaminant mobility and volume using phytoremediation.
Alternatives 3 and 4 would reduce the volume and mobility of pesticides using extraction wells
Alternatives 2, 3, and 4 each would address the plume at the Mclver Dump Area and each would
reduce the mobility and volume of pesticides through treatment.
Route 211 Area
Alternative 4 offers the greatest reduction in mobility and volume of impacted groundwater
through extraction and treatment of all impacted groundwater. Alternative 3 would result in the
reduction in mobility and volume of pesticides in the Source Area groundwater through extraction
and treatment of approximately 60% of the pesticide mass in the Surficial Aquifer.
9.2.3 Short-Term Effectiveness
Mclver Dump Area
For construction activities, Alternative 2 poses the least threat to workers, the public, and the
environment followed by Alternatives 3 and 4. Alternative 2 would also require the least amount
of time for implementation of construction activities followed, in ascending order by Alternatives
3, and 4.
The expected time frame to achieve cleanup goals under Alternatives 2, 3, and 4 is the same (10
years).
Route 211 Area
Alternative 2 would require no construction-related activities which could endanger public
communities or remedial workers. Well installations have been successfully conducted during RI
activities. Therefore, implementation of Alternatives 3 and 4 would pose no significant concerns
in regards to protection of public communities or remedial workers.
In terms of the achievement of cleanup goals, Alternative 4 would require the shortest time frame
followed by Alternative 3 and then by Alternatives 2. However, certain aquifers and certain BHC
isomers would require equivalent time frames to achieve the clean up goals under Alternatives 3
and 4. For gamma-BHC (Lindane), Alternatives 3 and 4 would each require from 0 to less than 30
years and from 0 to less than 20 years, respectively, to achieve the cleanup goals in the various
aquifers. For beta-BHC, the time frames to achieve the cleanup goals in the various aquifers for
Alternatives 3 and 4 would be from less than 5 to 90 years and from less than 5 to 55 years
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Page 72
f n6 T6 f meS t0 aChiCVe deanup 8ฐa!s in the various a Cmduded in the FS report), when
Alternative 4 ("PP* Pฐซ ฐf the Upper Black Creek
r ^)(i'e ' 55 yCarS)' the a'Pha-BHCconcentration under
(Lower Black Creek Aquifer) will be reduced to 0.04 ^g/1 This represents a 90ฐ/
aIha"BHC U"der Atemrfve 3 neede'dto meet theTo2
The remaining 35 year difference between these Alternatives (i.e., 90 years versus 55 vears) is the
fr^'^^^
risk range TheSfore h"' H" T f tO * ' * ^ ^ reduCtiฐn)- This is an -tremelylow
nnS A^f' Therefฐre' based uPฐn the above discussion, the ability to achieve the cleanup /oal
under Alternative 3 is generally equivalent to Alternative 4. B
9.2.4 Implementability
Mclver Dump Area
Alternative 2 requires the enhancement of the Mclver Dump Area with trees and other plant life
ฑSv ^A,? lffiCUltieS7ฐ f be a"tic^d for planting frees or other plant fifc^S
ttSl^Sr; ? 4 6aCl!.incluIde en^ineered remediation systems which should be
Sr C^aLe 3 ฑ 4 UnCฐmpllCated- Additionally, excavation of interceptor trenches
under Alternatives 3 and 4 may compromise the existing erosion control measures at the Area.
Route 211 Area
Alternatives 1 and 2 could be easily implemented. Alternatives 3 and 4 require construction of an
extraction treatment, and discharge System(s), all of which would be located on p^aTpronertv
following lists certain aspects of Alternative 4 in regards to the implementability issues.
rate of 935
A large treatment building to accommodate 4-10,000 Ibs. carbon vessels would be needed.
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The treatment building would need to be centrally located. Thousands of feet of pipeline
would be necessary for the extraction and treatment system.
A 3.6 mile discharge pipeline to Quewhiffle Creek would be required.
Potential for spreading groundwater contaminants, other than pesticides, by the large
capture zone created by 22 extraction wells; and need for additional groundwater
investigation to be able to design an efficient treatment system .
A minimum of nine months would be required to obtain a NPDES permit for surface
water discharge, and greater than 2 years would be required for modeling the extraction
system, obtaining access agreements (to approximately 250 acres of property), design of
the system, and development of a monitoring program.
The monitoring program and control measures of Alternatives 2, 3, and 4 would adequately
address the migration of pesticides and prevent future exposure.
9.2.5 Cost
Mclver Dump Area
The total estimated present worth costs for each alternative are listed below:
Alternative 1: $160,000
Alternative 2: $450,000
Alternative 3: $ 1,500,000 (Surface Water) - $ 1,200,000 (Infiltration Galleries)
Alternative 4: $2,000,000 (Surface Water) - $ 1,600,000 (Infiltration Galleries)
The costs for Alternatives 3 and 4 are greater than 2 times the cost for Alternative 2.
Route 211 Area
The total estimated present worth costs for each alternative are listed below:
Alternative 1: $370,000
Alternative 2: $1,400,000
Alternative 3: $2,600,000
Alternative 4: $15,000,000
Alternative 4 would be significantly greater in cost than any of the other alternatives.
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9.3 Modifying Criteria
9.3.1 State Acceptance
EPA and the North Carolina Department of Environment and Natural Resources (NCDENR)
have cooperated throughout the RI/FS process for OU5. NCDENR has participated in the
an" tS ROD6 ^l *"# """** ฐ" "* rf "ป wrioป- "^ ^vetped by EP
thC EPA and NCDENR site project
NCDENR are m agreement on the selected alternatives for both Mclver
refer to the
deVd0pment ฐf aป the reme^ Passes for this OU5
9.3.2 Community Acceptance
omm C0mmunity on the P^PO^ed Plan for this action. Although public
comments indicat
.
no opposition to the preferred alternatives, some local residents
whict ^f ^ *?*?* "" PUbIiC ^
which contains a transcript of the public meeting.
10.0 THE SELECTED REMEDY
Based upon consideration of the CERCLA requirements, the NCP, the analysis of the alternative,
S rnTdv mCnteh ^ "* ***l** *ซ* COmntS> EPA has Selected ^^for^T
^^0^^ฐ"^^ a-uSUlt ฐf thC remedial deS^n and the construction '
processes Changes to the remedy described in this ROD will be documented usine a technical
ฃSSฑII^
ROD amendment, as appropriate depending on the type of change.
10.1 Description of the Selected Remedy
10.1.1 Mclver Dump Area .
The selected remedy for the Mclver Dump Area is:
r*: ' CฐntiAnueiGroun<*"*er/Surface Water/Sediments Monitoring,
'
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Page 75
10.1.1.1 Description of the Selected Remedy
Monitor Natural Attenuation
Monitoring would be used to verify that natural aquifer processes are reducing contaminant
concentrations to acceptable levels by intrinsic remediation; to determining the concentration,
distribution, and migration of the COCs in ground water/surface water and sediments, and to
verify that the clean up goals are achieved during remedial action. Additionally, monitoring
would be used as a mechanism by which future receptors within the migration pathway of COCs
are identified and addressed, if necessary. Monitoring would also be used to maintain exposure
control within the defined remedial action objectives. After source removal and construction of
erosion control measures already finished under a separate ROD, pesticide concentrations will
naturally decrease.
Monitor would involve periodic (short and long-term) sampling and analysis of
groundwater/surface water/sediments.
Phytoremediation
Phytoremediation is an innovative in-situ technology for the remediation of pesticide in
groundwater. Phytoremediation would be used to enhance the natural attenuation processes by
the use of vegetation to treat in-place contaminated groundwater. The Mclver Dump Area is
favorable for the use of phytoremediation as a remedial technology because of the shallow water
table which allows tree roots to get in contact with contaminated groundwater), proximity of the
source area to the groundwater discharge area, and absence of current groundwater use.
Additionally, phytoremediation offers some hydraulic control through transpiration, thereby
limiting the migration of pesticides.
Area Reconnaissance
Area reconnaissance would be used to determine whether properties at the area are for sale,
purchased, or being leased. This would be accomplished by reconnoitering the Mclver Dump
Area and reviewing property records. Town development plans would be reviewed to determine
any future development strategies for the Mclver Dump Area. Additionally, residential well
surveys have been conducted at the Mclver Dump Area. Through area reconnaissance, the
residential well surveys would be verified and updated. Area reconnaissance is an effective means
of controlling exposure as defined in the remedial action objectives. The area reconnaissance
program would be in place until clean up goals are achieved.
Alternative Water Supply/ Well head treatment
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Page 76
Remedy Review
10.1.1.2 Other Features of the Selected Remedy
Pesticides exceeding the clean up goals would be achieved in groundwater by natural
soils were removed in
The time frame to achieve clean up goals under Alternative 2 is estimated to be 10 years
'
10.1.1.3 Expected Outcomes of the Selected Remedy
10.1.2 Route 211 Area
The selected remedy for the Route 2 1 1 Area is-
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Page 77
10.1.2.1 Description of the Selected Remedy
Groundwater Extraction and Treatment Components
Groundwater underlying the former disposal area referred to as "Source Area
groundwater" in the Surficial Aquifer, which poses the most significant risk at the Route
211 Area, would be extracted using extraction wells. .
Extracted groundwater would be treated using carbon adsorption.
Treated groundwater would be discharged via re-injection (infiltration galleries/injection
wells).
Monitoring of the extraction, treatment and discharge systems until clean up goals are
achieved.
Extraction System
The highest groundwater pesticide concentrations will be extracted from the Source area
groundwater from the Surficial Aquifer using one extraction well.
Treatment System
Activated carbon adsorption is considered to be the Best Available Treatment technologies for
removing pesticides from water. All of the pesticides present in the groundwater to be extracted
can be treated using activated carbon absorption. Routine analytical sampling of the influent and
effluent from the canister(s) shall be conducted to determine when the carbon canisters should be
replaced.
Discharge
Treated water will be discharged via an infiltration gallery system. Discharge requirements will be
documented in an infiltration gallery permit. Based on the groundwater modeling, all treated
water can be distributed through the galleries and allowed to infiltrate down through the soils to
the Surficial Aquifer. The infiltration system shall be located upgradient of the extraction system
to form a "closed-loop" system, as required by the State of North Carolina.
Monitor Natural Attenuation
Groundwater monitoring would be used to verify that natural aquifer processes are reducing
contaminant concentrations to acceptable levels by intrinsic remediation in the Surficial Aquifer,
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^^
w be CS ^ identified and addressed> if necessa^M^ng
would be used to mamtam exposure control within the defined remedial action objectives
JS ฐf m0nitori"g wells j" ซป aquifers
m gallon. The existing monitoring well network and
e T ? g WdIS Placed at Strateซic locations would serve as "trigger" mechanism
wells. Statical increases of pesticide concentrations above acceptable exposufe
.<4rea Reconnaissance
Alternative Water Supply/ Well Head Treatment
acW "ed ^ "^ be &VailabIe fฐr ^ Pฐtential recePtor ซซ* clean up goals
Remedy Review
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Page 79
this review, if needed, additional site remediation or modifications to the remedy would be
performed.
10.1.2.2 Other Features of the Selected Remedy
Groundwater clean up goals would be achieved by removing the Source Area
groundwater from the Surficial Aquifer using extraction wells; and by natural attenuation
in the rest of the plume and aquifers.
Through the removal of pesticide residuals and extraction of Source Area groundwater
from the Surficial Aquifer, pesticide concentrations would continue to reduce in all
aquifers.
The estimated time frame to achieve the clean up goal in the various aquifers ranges from
0 to less than 30 years for gamma BHC (Lindane); from less than 5 to 90 years for alpha
BHC; from less than 5 to 90 years for beta BHC ; and from 0 to less than 5 years for delta
BHC.
Costs for this alternative assumed the use of an infiltration gallery as the discharge
method. The estimated total present worth cost for Alternative 3 is $2,600,000 Costs
associated with this alternative include continued monitoring and periodic Area
reconnaissance. Additional costs above that of Alternative 2 include well-head
components for the existing pumping well, a carbon adsorption treatment system and a
reinjection system. Operating and maintenance costs associated with this alternative
include power, a site operator, carbon replacement, and sampling of the treatment system.
A detailed cost estimate for Alternative 3 is provided in Table 21. Costs are rounded to
two significant figures.
10.1.2.3 Expected Outcomes of the Selected Remedy
After clean up goals are achieved , groundwater should be available to drink without
having to treat to remove pesticides.
11.0 STATUTORY DETERMINATIONS
Under CERCLA Section 121, EPA must select remedies that are protective to human health and
the environment, comply with applicable or relevant and appropriate requirements (unless a
statutory waiver is justified), are cost-effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable. In
addition, CERCLA includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous waste as their principal
element. The following sections discuss how this remedy meets these statutory requirements
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11.1 Overall Protection of Human Health and the Environment
Mclver Dump Area
Route 211 Area
21 ' *** prฐtects human health and the environment
11.2 Compliance with Applicable or Relevant and Appropriate Requirements
romulgated under the authnri
.e
ฃRA). These regulations are applicable to the management of
, . x io
hazardous waste, including treatment, storage and disposal
. . 7- :~ . Vm*....r v^iiiciitm^w/v fan-JIM- 0.111 ^KB Po^f m
W3ter q"^'y ฐ"'ena ba.ed on the protection of human health and .he ซ.viฐoll J!
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Safe Drinking Water Act (SDWA1 National Primary Drinking Water Standards (40 CFR Part
141) establishes health-based enforceable standards (maximum contaminants levels (MCLs)).
North Carolina Administrative Code CNCAO Title ISA. Chapter 2. Subchapter 2L. Regulations
governing classifications and water quality standards applicable to groundwater. Promulgated
under the authority of the NC Water and Air Resources Act. These regulations are applicable to
the protection of groundwater in the State of North Carolina.
NCAC Title ISA, 2B. Regulations governing the water quality standards applicable to surface
waters. Promulgated under the authority of the NC Water and Air Resources Act. These
regulations are applicable to the protection of surface waters in the State of North Carolina.
NCAC Title ISA. Chapter 13A. Regulations for the Management of Hazardous Waste
promulgated under the authority of NC Waste Management Act. These regulations are applicable
to the management of hazardous waste in the State of North Carolina.
NCAC Title ISA. Chapter 13B. Regulations for disposal of Solid Waste promulgated under the
authority of the NC Hazardous Waste Commission Act. These regulations are applicable to the
management of solid waste in the State of North Carolina.
11.3 Cost Effectiveness
EPA's selected remedy is cost-effective and represents a reasonable value for the money to be
spent. In making this determination, the following definition was used: "A remedy shall be
cost-effective if its costs are proportional to its overall effectiveness." (40 CFR
300.430(f)(l)(ii)(D). This was accomplished by evaluating the "overall effectiveness" of those
alternatives that satisfied the threshold criteria (i.e., were both protective of human health and the
environment and ARAR compliant). Overall effectiveness was evaluated by assessing three of the
five balancing criteria in combination (long-term effectiveness and permanence; reduction in
toxicity, mobility, and volume through treatment; and short-term effectiveness). Overall
effectiveness was then compared to costs to determine cost effectiveness. The relationship of the
overall effectiveness of this remedial alternative was determined to be proportional to its costs and
hence represent a reasonable value for the money to be spent.
The estimated present worth cost for the Selected Remedy for the Route 211 Area is $2,600,000.
The estimated present worth cost for the Selected Remedy for Mclver Dump Area is $450,000.
11.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
EPA and NCDENR have determined that the selected remedy represents the maximum extent to
which permanent solutions and treatment technologies can be utilized in a cost-effective manner.
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Page 82
and the environment and comply with
offs the SdeCted remedy Provides the best balance
or v K terms of long-term effectless and permanence, reduction of toxicity, mobility
or volume achieved through treatment, short-term effectiveness, implementability and cost whUe
for treatment as a principai
11.5 Preference for Treatment as a Principal Element
l ^ats posed by the OU5 through the use of treatment
USi"g & Carbon adsฐrPtion s^em j" the Route
Vei" Dump *"*> aS We" as> natural attenuation in both
' , treatment as a sigmficant portion of the remedy, the statutory preference for
remedies that employ treatment as a principal element is satisfied.
11.6 Five- Year Review Requirement
SUbstanC6S remaininS on-site above 'evels that allow
wthin r Unrestncted exPฐsure for a long period of time, a review will be conducted
within five years after mmat.on of remedial action, and every five years thereafter until
remed.at,on goals are achieved, to ensure that the remedy continues to provide adequate
protection to human health and the environment.
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APPENDIX A
RESPONSIVENESS SUMMARY
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t 1
* -t
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Responsiveness Summary
OU5 ROD
Pigel
1.0 RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public comment period from January
18, 1999, through February 17, 1999, for interested parties to comment on the Proposed Plan for
the remedial action for Operable Unit 5 (OU5) of the Aberdeen Pesticide Dumps Site in
Aberdeen, North Carolina. OU5 addresses groundwater, surface water and sediment at the
Mclver Dump and Route 211 Areas. The Proposed Plan, included as Attachment A of this
document, provides a summary of the Site's background information leading up to the public
comment period.
EPA held a public meeting at 7:00 p.m. on February 4,1999, at the Aberdeen Fire Station in
Aberdeen, North Carolina to describe EPA's proposed alternatives for OU5. All comments
received by EPA during the public comment period were considered in the selection of the
remedial action for OU5.
\
The Responsiveness Summary provides a summary of citizens' comments and concerns identified
and received during the public comment period, together with EPA's responses to each comment
and/or concern.
This Responsiveness Summary is organized into the following sections and attachments:
1.0 RESPONSIVENESS SUMMARY OVERVIEW: This section outlines the
purpose of the public comment period and the Responsiveness Summary. It also
references the background information leading up to the public comment period.
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This
section provides a brief history of the interests and concerns of the community
related to OU5.
3.0 SUMMARY OF MAJOR QUESTIONS AND CONCERNS RECEIVED
DURING THE PUBLIC COMMENT PERIOD AND EPA'S RESPONSES TO
THESE COMMENTS: This section summarizes the comments received by EPA
during the comment period, including any verbal comments made during the public
meeting on February 4, 1999. EPA's written responses to these comments are
also provided.
ATTACHMENT A: Attachment A contains the Proposed Plan for OU5 which was mailed to the
information repository and to individuals on the Site mailing list on January 14, 1999, and
distributed to the public during the public meeting held on February 4, 1999.
ATTACHMENT B: Attachment B includes the sign-in sheet from the public meeting held on
February 4, 1999, at the Aberdeen Fire Station, Aberdeen, North Carolina.
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OUS ROD
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ATTACHMENT C: Attachment C includes the address and phone number of the information
repository designated for the Aberdeen Pesticide Dumps Site.
*r
ATTACHMENT D: Attachment D includes a copy of the official transcript of the Public Meeting
on the Proposed Plan for OUS.
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT CONCERNS
2.1 Background on Community Involvement
The remedial action Proposed Plan fact sheet was prepared and mailed to citizens on the Site's
mailing list on January 14, 1999, announcing a public comment period from January 17 - February
18, 1999, and a public meeting on February 4th. A transcript of this meeting was prepared by a
court reporter and a copy was placed in the information repository located in the Aberdeen Town
Hall. A display ad appeared in both the Fayetteville Observer Times and The Pilot newspapers
on January 18, 1999 announcing the public comment period, the public meeting, and the location
of the information repository. Also, EPA representatives met with the City Manager to inform
him of the public meeting enabling him to be responsive to his constituents in the event he was
unable to attend the meeting.
4 ,,r.w _ M1W iฅlwIVi ^^^ irvvj Kiuujp miu U1CU
consultant to go over the proposed remedial action and to respond to their concerns.
There has always been an interest by the public in the Aberdeen Pesticide Dumps Site areas and
meetings have been fairly well attended.
3.0 SUMMARY OF MAJOR QUESTIONS AND CONCERNS
3.1 Verbal Comments
The following is a summary of the verbal comments, concerns and questions raised by the
attendees during the public meeting on July 10, 1997, together with EPA's responses.
COMMENT 1: Is phytoremediation the leading remedial technology at the Mclver
Dump Area? ?
RESPONSE: No, the leading remedial technology for the Mclver Dump area will be Natural
Attenuation. Phytoremediation is an innovative in-situ technology and will be used to enhance the
natural attenuation processes by the use of vegetation to treat in-place contaminated groundwater.
The Mclver Dump Area is favorable for the use of phytoremediation as a remedial technology
because of the shallow water table (i.e, allows tree roots to get in contact with contaminated
groundwater), proximity of the source area to the groundwater discharge area, and absence of
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Responsiveness Summary
OUS ROD
Page 3
current groundwater use. Additionally, phytoremediation offers some hydraulic control through
transpiration thereby limiting the migration of pesticides.
COMMENT 2: Would EPA limit the installation of private wells at the Mclver Dump
and Route 211 Areas?
RESPONSE: No, EPA will not limit the installation of wells in the Areas unless the location of a
proposed well will interfere with the operation or efficiency of the pump and treat system already
in place at the Route 211 Area.
EPA will make sure people interested in installing wells at the Mclver Dump and Route 211
Areas are informed that groundwater from these two areas should not be used for drinking water
purposes without appropriate treatment to remove pesticide residuals prior to drinking. EPA will
encourage people to hook up new constructions to city water where available.
COMMENT 3: Would EPA limit the installation of private wells in the Areas to be
used for irrigation purposes?
RESPONSE: No, EPA will not limit the installation of irrigation wells in the Areas unless the
location of a proposed wells will interfere with the operation or efficiency of the pump and treat
system already in place at the Route 211 Area.
COMMENT 4: Would there be any limitations on developing the Mclver Dump or
the Route 211 Areas due to groundwater contamination or the
groundwater remedial activities?
RESPONSE: There will be ho limitations in developing any of the two areas due to groundwater
contamination or the groundwater remedial activities. See response to comment # 2 for any
limitations on the installation of wells.
3.2 Written Comments
The following are written comments submitted by Warner Environmental Management, Inc.,
(TAG consultant) on behalf of MooreFORCE, Inc. EPA's responses to each comment are
included.
Mclver Dump Area
COMMENT 1: ARARs - stick to the stricter NC groundwater standard of 1 x
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Responsiveness Summary
OU5 ROD
Pace 4
RESPONSE: The clean up goals for the contaminants of concern not having a promulgated MCL
or NCGQS are based on calculated risk levels of 1 xlO"6 for carcinogens, or hazard index (HI) of 1
for non-carcinogens.
COMMENT 2 Natural Attenuation is the primary strategy for groundwater remediation, as
phytoremediation is not a proven remediation technique. Rather
phytoremediaiton is the secondary technique being used to possibly enhance
the rate of natural attenuation. This needs to be clearly stated in the ROD.
RESPONSE: The primary strategy for remediation at the Mclver Dump Area is natural
attenuation. Phytoremediation is an innovative in-situ technology and will be used to enhance the
natural attenuation processes by the use of vegetation to treat in-place contaminated groundwater.
Section 10 of the ROD clearly describes the selected remedy.
COMMENT 3: Continued groundwater and surface water monitoring is critical to protect
the community from additional environmental risks.
RESPONSE: EPA recognizes the monitoring program as an important part of the remedy. The
monitoring program will be used to verify that natural aquifer processes are
reducing contaminant concentrations to acceptable levels by natural attenuation; to
determine the concentration, distribution, and migration of the contaminants of
concern (COC) in groundwater/surface water and sediments; and to verify that the
clean up goals are achieved during remedial action. Additionally, monitoring
would be used as a mechanism by which future receptors within the migration
pathway of COCs are identified and addressed, if necessary. The monitoring
program will include periodic (short and long-term) sampling and analysis of
groundwater/surface water/sediments.
Route 211 Area
COMMENT 1 Beyond the primary remediation remedy of "groundwater recovery from the
source area using extraction, treatment by carbon absorption and discharge
of treated groundwater via reinjection", it should be clearly noted that the
secondary technique is "natural attenuation".
RESPONSE: Groundwater containing the highest concentrations of pesticides will be extracted
using extractions wells, treated using carbon adsorption and discharged via infiltration galleries.
This extraction system will extract groundwater from the surficial aquifer only, and will be
operating until the clean up goals are achieved.. Natural attenuation will be the remediation
technique for all the other aquifers. The selected remedy is described in detail in Section 10 of the
ROD.
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PageS
COMMENT 2: ARARs - stick to the stricter NC groundwater standards of 1 x W*.
RESPONSE: The clean up goals for the contaminants of concern not having a promulgated MCL
or NCGQS are based on calculated risk levels of 1 xlO"6 for carcinogens, or hazard index (HI) of 1
for non-carcinogens.
COMMENT 3: The most critical aspect of the selected remedy is protecting the public from
exposure to contaminated groundwater. Therefore, the "area
reconnaissance" portion of the selected remedy must be implemented
vigilantly to prevent the installation of new drinking water wells. It has been
stated that ground level observations would be conducted by those
individuals who would be performing the sampling. However, because of
the growing interest in land development in the area, and the extended time
periods between sampling events, new drinking water wells could be
installed unobserved. Or wells might be installed in areas where there are
no monitoring wells. Given this situation, we strongly recommend that the
"area reconnaissance" include additional methods to prevent new well
installations, such as periodic aerial observation or photography and the
regular review of new building permits.
RESPONSE: EPA recognizes the importance of the "area reconnaissance" portion of the remedy
and will make sure that an effective strategy to prevent drinking of contaminated groundwater is
developed during the remedial design. At this point, details of the area reconnaissance strategy are
not final. EPA will consider the given recommendations, such as aerial observation and new
building permits review, as options when developing the complete area reconnaissance strategy
during the remedial design.
COMMENT 4: Another important portion of the selected remedy, the "contingency
controls with well head treatment or alternative water supply if future
potential receptors are identified", must be designed to immediately respond
when groundwater data indicate a potential exceedence of NC groundwater
standards.
RESPONSE: EPA recognizes the importance of the "contingency controls with well head
treatment or alternative water supply if future potential receptors are identified" portion of the
remedy and will make sure that an effective strategy that prevent drinking of contaminated
groundwater is developed during the remedial design.
COMMENT 5: Because of the complexities of the aquifer formations under this site, and
the widespread diffusion of contaminants down gradient from the source
area, the groundwater monitoring scheme for the surficial, Upper Black
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OU5 ROD
Pปge6
Creek and Lower Black Creek aquifers must be designed to adequately
protect the community in the long run i.e, until all groundwater meets NC
groundwater standards.
RESPONSE: The selected remedy will be designed in a manner that protects human health and
the environment until the clean up goals are achieved. Additionally, a remedy review would be
performed every 5 years until clean up goals are achieved to confirm the effectiveness of the
remedy to protect human health and/or the environment. As a result of this review, if needed,
additional site remediation or modifications to the remedy would be performed.
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ATTACHMENT A
PROPOSED PLAN FACT SHEET
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PROPOSED PLAN
ABERDEEN PESTICIDES DUMP SITE
OPERABLE UNIT 5 - GROUNDWATER
Mclver Dump and Route 211 Areas
January, 1999
INTRODUCTION
This Proposed Plan feet sheet has been prepared by the U.S. Environmental Protection Agency - Region 4 (EPA) to
propose a cleanup plan to address groundwater contamination at the Mclver Dump and Route 211 areas, Operable Unit
# 5 (OU5), of the Aberdeen Pesticide Dumps Site in Moore County, Aberdeen, North Carolina. As the lead Agency,
EPA has worked in conjunction with the North Carolina Department of Environment and Natural Resources (NCDENR)
to direct and oversee all remedial activities performed by the Potentially Responsible Parties (PRPs) at the Site.
In accordance with Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act, SARA 1986, EPA is publishing
this Proposed Plan to provide an opportunity for public review and comment on cleanup options under consideration for
A final remedy for OU5 will be selected only after the public comment period has ended and all the information submitted
to EPA during this period has been considered. EPA, in consultation with NCDENR, may modify the preferred
alternative or select another response action presented in this plan and in the Remedial Investigation Feasibility Study
(RI/FS) reports based on new information and/or public comments. Therefore, the public is encouraged to review and
comment on all alternatives identified in this plan.
OU5 deals only with groundwater at both Mclver Dump and Route 211 areas. Therefore, all information presented in
this proposed plan is only relevant to groundwater at those two areas.
THIS PROPOSED PLAN:
1. Includes a brief history of the two areas addressed by
OU5 and a summary of the findings of OU5
investigations;
2. Presents the alternatives for OU5 considered by EPA;
3. Outlines the criteria used by EPA to recommend the
alternatives for OU5;
4. Provides a summary of the analysis of alternatives;
5. Presents EPA's rationale for its preliminary selection
of the preferred alternative; and
6. Explains the opportunities for the public to comment
on the remedial alternatives.
PROPOSED PLAN PUBLIC
MEETING
WHEN: February 4,1999
TIME: 7:00 PM
WHERE:
ABERDEEN FIRE STATION
Highway 1 and Peach Street
Aberdeen, North Carolina
30-DAY PUBLIC COMMENT
PERIOD
January 18 - February 17,1999
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This document summarizes information that is
explained in more detail in the Remedial
Investigation and Feasibility Study Reports
(RI/FS) for OU5 and other documents contained in
the Information Repository/Administrative Record for
this Site.
SCOPE AND ROLE OF PROPOSED
REMEDIAL ACTION
The Aberdeen Pesticide Dumps Site was divided into
different Operable Units (OUs) in order to address
contamination in the different media and areas. The
remedial alternatives described in this document deal
with OUS only (groundwater contamination at the
Mclver Dump and Route 211 areas). Other media
and/or areas are being addressed under other OUs.
An interim Record of Decision (ROD) for the Route
211 area was signed on September 16, 1997. This
interim action addressed, through a pump and treat
system, the highest concentrations of pesticides in
groundwater at the Route 211 area. This interim
action is part of EPA's preferred alternative for the
Route 211 area described on this proposed plan.
MCIVER DUMP AREA SITE BACKGROUND
Site History
The Mclver Dump Area (Figure 1) is located
approximately 0.5 miles north of the junction of
SRI 112 (Roseland Road) and SRI 106, west of
Aberdeen. The Mclver Dump Area formerly consisted
of two subareas, area B and area C, and a soil
stockpile. Materials, some of which contained
pesticides, were discovered at both areas B and C. At
area B, pesticides were removed in 1985 by EPA and
disposed at the GSX facility located in Pinewood,
South Carolina. In 1989 at area C, approximately
3,200 cubic yards of materials and soils were removed
by an EPAEmergency Response Teamand stockpiled
on an impermeable liner located near area C. In late
1997, soils containing pesticide residuals were
excavated from both areas B and C (approximately
12,828 tons). The excavated soils and the soils
stockpile were transported to a thermal desorption
unit for treatment. Treated soils were returned to the
Mclver Dump Area and used for clean fill. As a
result of these remedial activities (all conducted as
part of a separate OU), known sources of pesticides
have been removed from the Area and, therefore, no
future impacts to groundwater and/or surface water
are anticipated. Additionally, significant erosion
control measures have been constructed at the Area
to control drainage to Patterson Branch, a stream to
the north of the former source areas. Topsofl has
been place over the Area, which has been seeded and
fertilized to promote growth of stabilizing vegetation.
Remedial Investigation Summary
The groundwater Remedial Investigation (RI) at the
Mclver Dump Area was conducted in multiple phases
from November 1994 to October 1995. The
following summarizes the investigative activities
conducted:
8 Monitoring Wells Installed;
27 Direct Push Samples Collected; and
5 Surface Water/5 Sediment Samples Collected
from Patterson Branch.
Waterbearing areas below the land surface are known
as aquifers. The only aquifer penetrated during this
investigation at the Mclver area was the Lower Black
Creek Aquifer. Within the Lower Black Creek
Aquifer is a thin but continuous clay layer that acts as
a local confining unit. This clay layer separates the
Lower Black Creek Aquifer into an upper and lower
portion. The only impacted portion of the aquifer at
the Mclver Dump Area is the upper portion of the
Lower Black Creek Aquifer. The principal direction
for groundwater flow is toward the north-northeast
perpendicular to Patterson Branch.
Nature and Extent of Contamination
Based on the investigation, no one is being exposed
to contaminated groundwater in the Mclver area.
The pesticides considered chemicals of concern
(COCs) at the Mclver Dump area are alpha- and beta-
benzenehexachloride (BHC). Concentrations of each
compound generally decreased with depth at locations
where samples were collected from different depths
within the aquifer. The concentrations of the two
BHC isomers in the monitoring wells (Figure 2)
indicate that pesticides detected in groundwater
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originated from the former source areas (areas B and
Q, and have migrated downgradient to Patterson
Branch.
Surface water and sediments were sampled and
analyzed from Patterson Branch during the RI.
Results show that concentrations of pesticides in
surface water are below the North Carolina Surface
Water Standards. Figure 2 shows the locations of the
surface water and sediment samples collected.
The only pesticide detected at the Mclver area having
a promulgated Federal or State groundwater quality
standard for the protection of groundwater is gamma-
BHC also known as Lindane. Lindane does not
exceed the promulgated Federal and State standard of
0.2 parts per billion (ppb) in any of the groundwater
samples collected from the monitoring wells in the
area.
ROUTE 211 AREA SITE BACKGROUND
Site History
The Route 211 Area (Figure 1) is located
approximately 1,000 feet southwest ofhighwayRoute
211 East and adjacent to the Aberdeen & Rockfish
Railroad. It is approximately one mile east of the
Town of Aberdeen. The Area formerly contained an
old sand mining basin approximately 80 feet across
and 8 to 20 feet deep. Materials, some of which
contained pesticides, were discovered in a waste pile
on the southwest slope of the pit. In 1986,
approximately 100 cubic yards of pesticides and
associated soil were removed by EPA and disposed at
the GSX facility in Pinewood, South Carolina. In
1989, approximately 200 cubic yards of similar
material was discovered by EPA and subsequently
removed, placed in the stockpile at the Mclver Dump
Area, and later treated by thermal desorption. In late
1997, additional soils containing residual pesticides
were excavated and transported to a thermal
desorption unit for treatment (approximately 3,464
tons). Treated soils were then returned to the Area
for use as clean fill and the entire pit at the Area was
filled. Following regrading of the Area, pinestraw
was applied to prevent erosion and stabilize the soil.
Surface runoff in the immediate vicinity of the Area
flows away from the former source area. All the soil
remediation work described above was performed
under a different operable unit. '
Remedial Investigation Summary
The groundwater RI at the Route 211 Area was
conducted in multiple phases fromNovember 1994 to
October 1996. The following summarizes the
investigative activities:
37 Monitoring Wells Installed;
35 Direct Push Samples Collected; and
2 HydroPunch Samples Collected.
In addition, a Downgradient Receptor Study was
conducted, which consisted of the sampling and
analysis of 21 private wells.
The three aquifers characterized during this
investigation were the Surficial Aquifer, the Upper
Black Creek Aquifer, and the Lower Black Creek
Aquifer. The investigation indicates that the Upper
Black Creek Aquifer is separated into an upper and
lower portion by an intermediate clay layer with the
exception of one sample location upgradient of the
source area. Figure 3 depicts the aquifers associated
with the Route 211 Area.
The principal directions for groundwater flow in the
different aquifers are:
toward the southwest in the Surficial Aquifer;
toward the east-southeast in the upper portion of
the Upper Black Creek Aquifer;
toward the south-southeast in the lower portion
of the Upper Black Creek Aquifer, and
toward the south in the Lower'Black Creek
Aquifer.
Nature and Extent of Contamination
Based on the investigation, no one is drinking
contaminated groundwater from any aquifer in the
Route 211 study area.
Source Area Groundwater/Surficial Aauifer
The groundwater underlying the former source area
is referred to as "Source Area Groundwater", which
is a small portion of the Surficial Aquifer. The
Source Area Groundwater is currently being
remediated as part of the Interim Remedial Action for
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Jj.
Approximate Elevation (Feet MSL)
' ~ a a a ซ: *!] a a a a
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the Route 211 Area in 1997. This interim action is Results of the analysis indicated the presence of the
described in the Interim Action Record of Decision BHC isomers. The property owner was notified of
(ROD) issued on September 1997. the analytical results, the well was immediately
equipped with a carbon treatment unit until the
Forthe remaining portion of the Surficial Aquifer, the residence was hooked to theTown of Aberdeen water
pesticides determined to be contaminants of concern supply system. During the Downgradient Receptor
(COCs) were alpha-BHC, beta-BHC, and delta- Study, seven of the thirteen private water wells
BHC. Endrin aldehyde was also determined to be a sampled which are potentially withdrawing water
COC; however, the pesticide was not detected in from the lower portion of the Upper Black Creek
subsequent sampling events. The BHC isomers Aquifer did not contain pesticides at or above method
exhibit a decreasing trend downgradient of the former detection limits. However, four BHC isomers were
source area. Pesticide concentrations in monitoring detected in six of the same thirteen wells in the low
wells located south of the Aberdeen and Rockfish parts per billion range. None of the six wells with
Railroad were considerably less than those detected detectable concentrations of pesticides are being used
near the source. Concentrations of these compounds as a source of drinking water. Based on these
decrease as they move downgradient fromthe source, activities and this investigation, no one is drinking
Figure 4 illustrates the concentrations of the BHC contaminated groundwater from this aquifer.
isomers in the monitoring wells of the Surficial
Aquifer. Detectable concentrations of pesticides are consistent
with the groundwater flow direction and a Route 211
Upper Portion of the Upper Black Creek Aauifer contaminant source. Concentrations of the BHC
The pesticides determined to be COCs in the upper isomers increase downgradient of monitoring well
portion of the Upper Black Creek Aquifer are alpha- RT-TW-17DD. Concentrations then decrease further
and beta-BHC These compounds were consistently downgradient from monitoring well RT-TW-19DD.
detected at decreasing concentrations downgradient Figure 6 illustrates the concentrations of the BHC
of the pesticide source area. Figure 5 illustrates the isomers in the monitoring wells of the lower portion
concentrations of the BHC isomers in the monitoring ' of the Upper Black Creek Aquifer.
wells of the upper portion of the Upper Black Creek
Aqซปfer- Lower Black Creek Aauifer
The only pesticide determined to be a contaminant of
Lower Portion of the Upper Black Creek Aauifer concern (COC) in the Lower Black Creek Aquifer is
The pesticides determined to be. contaminants of alpha-BHC.
concern (COCs) in the lower portion of the Upper
Black Creek Aquifer are alpha-, beta-, and gamma- During the Downgradient Receptor Study, ten of the
BHC (Lindane). eleven water wells sampled which are potentially
withdrawing water from the Lower Black Creek
The only pesticide detected at the Route 211 Area Aquifer did not contain pesticides at or above method
having a promulgated Federal or State groundwater detection limits. BHC isomers were detected in only
quality standard is gamma-BHC (also known as one well potentially withdrawing water from the
Lindane). Lindane was detected above the Federal Lower Black Creek Aquifer; however, the
and State standard of 0.2 ppb in 2 of the 58 concentrations detected do not pose a significant risk
monitoring wells installed in the Route 211 Area, to human health. As a precautionary measure, this
These two wells are both screened in the lower private well was immediately equipped with carbon
portion of the Upper Black Creek Aquifer. treatment units to remove the minor concentrations of
pesticides. Based on these activities and this
Prior to the Downgradient Receptor Study, a water investigation, no one is drinking contaminated
supply well located at a private residence near RT- groundwater from this aquifer.
TW-19DD was sampled and analyzed for pesticides.
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FIGURE 4
SAMPLE LOCATIONS AND
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SURFICIAL AQUIFER
ROUTE 211 AREA
ABCROCCN PCSItClOE DUMPS SIIE
Moour COUNIY, NOHIII CAHCM.INA
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Figure 7 presents the concentrations of the^BHC
isomers in the monitoring wells of the Lower Black
Creek Aquifer.
SUMMARY OF SITE RISKS
As part of the Remedial Investigation/Feasibility
Study (RI/FS) process, EPA analyzed and estimated
any existing(current) and potential(future) human
health and/or environmental problems that could
result if the OU5 contamination is not addressed.
This analysis is called a Baseline Risk Assessment
(BRA). In conducting this assessment, EPA focused
on the human health effects that could result from
direct exposure to contaminated groundwater in the
Route 211 and Mclver Areas.
Based on the investigation, no one is drinking
contaminated groundwater from the Mclver or the
Route 211 Area. Therefore, there is no current risk
to human health and the environment in any of the
two areas due to the ingestion of groundwater.
Future/potential risk might exist due to the ingestion
of contaminated groundwater from the Lower Black
Creek Aquifer at the Mclver Area. At the Route 211
Area, future/potential risk might exist mainly due to
ingestion of contaminated groundwater from the
source area well. Future/potential risk might also
exist due to the ingestion of groundwater from the
other aquifers within the plume.
For more detailed information about risk calculations
for OU5, please refer to the BRA report available for
review at the repository.
REMEDIAL ACTION OBJECTIVES (RAOs)
Remedial action objectives or clean up goals were
developed based on the results of the Baseline Risk
Assessment (BRA) and the examination of potential
Applicable or Relevant and Appropriate
Requirements (ARARs). ARARs for groundwater
include Maximum Contaminants Levels (MCLs) and
North Carolina Groundwater Quality Standards
(NCGQS).
The following are the applicable groundwater clean
up goals in parts per billion (ppb) for the chemicals of:
concern in both Mclver and Route 211 Areas. ! !
Chemicals of
Concern fCOCs^
Alpha -BHC
Beta -BHC
Delta-BHC
Groundwater
Clean-up Goat
0.02 ppb
0.10 ppb
70.00 ppb
Risk-based
Risk-based
Risk-based
Gamma-BHC(Lindane) 0.20ppb MCLs/NCGQS
SUMMARY OF ALTERNATIVES
The following section provides a summary of the
alternatives developed in the Feasibility Study (FS)
report for the clean-up of groundwater at Mclver and
Route 211 Areas.
MOVER AREA
Alternative 1: No Action
The No Action alternative is required to be evaluated
at every site to establish a baseline for comparison.
No further groundwater activities will be conducted
at the Mclver Dump Area under this alternative.
Because this alternative does not entail contaminant
removal, a review of the remedy would be conducted
every five years in accordance with the Superfund
law. Costs included on this alternative are associated
with the five year review which would include
sampling and analysis for the contaminants of concern
(COCs) and preparation of the five year review
report.
The estimated cost of this alternative is $160,000.
Alternative 2: Phytoremediation, Continued
Goundwater/Surface Water/Sediments
Monitoring, Area Reconnaissance, and
Contingency Well Head Treatment if Future
Potential Receptors are identified
Alternative 2 proposes phytoremediation, an
innovative technology for the remediation of pesticide
in groundwater. Phytoremediation is the use of
vegetation to treat in-place contaminated
groundwater. The Mclver Dump Area is favorable
for the use of phytoremediation as a remedial
technology because of the shallow water table (i.e,
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HOURS >7 . .,
PESnODE ANAIYT1CAL TEซrK9UII
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allows tree roots to get in contact with contaminated
groundwater), proximity of the source area to the
groundwater discharge area, and absence of current
groundwater use. Additionally, phytoremediation
offers some hydraulic control through transpiration
thereby limiting the migration of pesticides.
Following source removal and construction of erosion
control measures already finished under another
operable unit, pesticide concentrations will naturally
decrease. Under Alternative 2, the reduction in
pesticide concentrations will be monitored in both
groundwater and Patterson Branch. Exposure control
under Alternative 2 would be maintained through
monitoring and area reconnaissance, and well head
treatment should future potential receptors be
identified.
Monitoring will involve periodic (short and long-
term) sampling and analysis of groundwater/surface
water/sediments to determine if contaminants have
degraded or migrated. Monitoring will also be used
as a verification mechanism to confirm predicted
contaminant transport pathways, concentrations and
time frames, and to evaluate potential contingencies
should unanticipated contaminant trends or migration
pathways occur.
Area reconnaissance will consist of periodic
reconnoitering of specific areas to determine whether
properties overlying impacted groundwater are for
sale or have been purchased. Potential future
development of property areas will be determined in
order to control future exposures.
Alternative Water Supply/ Well head treatment -
Currently, there are no receptors of impacted
groundwater. However, if potential receptors are
identified in the future, an alternate water supply or
well head treatment will be used to prevent exposure.
This alternative will also include a review after the
first five years to determine the effectiveness of the
alternative to protect human health and/or the
environment. As a result of this review, EPA will
determine if additional site remediation or
modifications to the alternative are required. The
estimated time to achieve the clean up goal and cost
of this Alternative 2 is 10 years and $450,000
respectively.
Alternative 3: Groundwater Recovery of the
Highest Concentrations of Pesticide Residuals
using Extraction Wells and/or Interceptor
Trenches, Treatment by Carbon Adsorption,
Discharge of Treated Groundwater via
Surface Water or Reinfection (Infiltration
Galleries/Injection Wells), Continued
Groundwater/Surface Water Monitoring,
Area Reconnaissance, and Well Head
Treatment should Future Potential Receptors
be identified
Under Alternative 3, groundwater containing the
highest concentrations of residual pesticides will be
extracted using extraction wells or interceptor
trenches. Extracted groundwater will be treated using
carbon adsorption, and treated groundwater will be
discharged via surface water or a re-injection method.
As in Alternative 2, exposure controls would be
maintained through monitoring, area reconnaissance
and well head treatment should future potential
receptors be identified.
This alternative will also include a review after the
first five years to determine the effectiveness of the
alternative to protect human health and/or the
environment. As a result of this review, EPA will
determine if additional site remediation or
modifications to the alternative are required. The
estimated time to achieve the clean up goal and cost
of Alternative 3 is 10 years and $1,500,000
respectively.
Alternative 4: Groundwater Recovery of Pesticide
Residuals Exceeding RAOs using Extraction
Wells and/or Interceptor Trenches,
Treatment by Carbon Adsorption, Discharge
of Treated Groundwater via Surface Water
or Reinfection (Infiltration Galleries/Injection
Wells), Continued Groundwater/Surface
Water Monitoring, Area Reconnaissance, and
Well Head Treatment should Future Potential
Receptors be identified
Under Alternative 4, contaminated groundwater
exceeding the remedial action objectives (RAOs) will
be extracted using extraction wells or interceptor
trenches. Extracted groundwater will be treated using
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carbon adsorption, and treated groundwater will be alternative water supply.
discharged via surface water or are-injectionmethod.
During operation of the system, exposure controls Monitoring will involve periodic (short and tone-
would be maintained through monitoring, area term) sampling and analysis of groundwater to
reconnaissanceandwellheadtreatmentshouldfuture determine if contaminants have degraded or mierated
potential receptors be identified as defined in Monitoring will also be used as a verification
Alternative 2. mechanism to confirm predicted contaminant
-.. u .. . . . , J . transport pathways, concentrations and time frames,
This alternative wfll also include a review after the and to evaluate potential contingencies should
first five years to determine the effectiveness of the unanticipated contaminant trends or migration
alternative to protect human health and/or the pathways occur. The monitoring program includes
environment. As a result of this review, EPA wfll monitoring of municipal well #13.
detennine if additional site remediation or
modifications to the alternative are required. The Area reconnaissance will consist of periodic
estimated tune to achieve the clean up goal and cost reconnoitering of specific areas to detennine whether
of Alternative 4 is 10 years and $2,000,000 properties overlying impacted groundwater are for
respectively. sale or have ^en purcnased Potential future
unTTTir 111 A DT- A development of property areas will be determined in
KUU lit 211 AREA order to control future exposures. Residential well
Ai,ป**-ai MA*- surveys will continue to be conducted throughout the
Alternative 1: No Action duration of the remedial action to ensure foreseeable
. receptors are identified and protected.
The No Action alternative is required to be evaluated
at every site to establish a baseline for comparison. Alternative Water Supply/ Well head treatment -
No further groundwater activities will be conducted Currently, there are no receptors of impacted
at the Route 2111 Area under this alternative. Because groundwater. However, if potential receptors are
th,s alternative does not entail contaminant removal, identified in the future, an alternate water supply or
areviewoftheremedywouldbeconductedeveryfive well head treatment will be used to prevent exposure
years in accordance with the Superfund law. Costs
included on this alternative are associated with the The time frame to achieve the clean up under
five year review which would include sampling and Alternative 2 was not estimated. However without
analysis for the contaminants of concern (COCs) and mitigating the migration of contaminated groundwater
preparation of the five year review report. from the source area, the time frame to achieve the
T- .. . ^^ cleanup goals could be expected to be greater than
The estimated cost of Alternative 1 is $370,000. alternatives 3 and 4.
Alternative 2: Continued Groundwater This alternative will also include a review every five
Monitoring, Area Reconnaissance, and Well years to determine the effectiveness of the alternative
Head Treatment or Alternative Water to protect human health and/or the environment. As
rfUPP-fi'rt C Potential RecePtors ซ* a result of the reviews, EPA will determine if
identified additional site remediation or modifications to the
... , . . alternative are required; The estimated cost of
A continued groundwater monitoring program would Alternative 2 is $1,400,000.
be put in place to monitor pesticide concentrations
and migration pathways. If potential future receptors
are identified, they would be protected through the
monitoring program, area reconnaissance, and, if
necessary, through the use of well head treatment or
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Alternative 3: Groundwater Recovery from the
Source Area Groundwater Using Extraction
Wells, Treatment by Carbon Adsorption, and
Discharge of Treated Groundwater via
Reinjection (Infiltration Galleries/Injection
Wells), Continued Groundwater Monitoring
of the Surficial, Upper Black Creek and
Lower Black Creek aquifers, Area
Reconnaissance, and Contingency Controls
with Wen Head Treatment or Alternative
Water Supply if Future Potential Receptors
are identified.
Underthis alternative, the groundwater underlying the
former disposal area referred to as "Source Area
groundwater", which poses the most significant risk
at the Area, would be extracted and treated. Treated
groundwater will be discharged via infiltration
galleries or a reinjection method. Through the
removal of pesticide residuals and extraction of
Source Area groundwater, pesticide concentrations
would continue to reduce in all aquifers. Alternative
3 includes a continued monitoring program to verify
reduction in pesticide concentrations in the Surficial,
Upper Black Creek, and Lower Black Creek aquifers,
including monitor migration pathways. If potential
future receptors are identified, they would be
protected through the monitoring program, area
reconnaissance, and, if necessary, through the use of
well head treatment or alternative water supply. The
monitoring, area reconnaissance and contingency
controls programs (same as in Alternative 2) will be
in-place until the clean up goals are achieved. The
estimated time frame to achieve the clean up goal in
the various aquifers ranges from 0 to less than 30
years for gamma BHC (Lindane); from less than 5 to
90 years for alpha BHC; from less than 5 to 90 years
for beta BHC ; and from 0 to less than 5 years for
delta BHC.
This alternative will also include a review every five
years to determine the effectiveness of the alternative
to protect human health and/or the environment. As
a result of the reviews, EPA will determine if
additional site remediation or modifications to the
alternative are required. The estimated cost of
Alternative 3 is $2,600,000.
Alternative 4: Groundwater Recovery from the
Source Area, the upper and lower portions of
the Upper Black Creek Aquifer, and the
Lower Black Creek Aquifer using Extraction,
Treatment by Carbon Adsorption, Discharge
of Treated .Groundwater via reinjection
(Infiltration Galleries/Injection Wells) from
the Former Source Area and via surface
water from the lower aquifers, Continued
Groundwater Monitoring, Area
Reconnaissance, and Exposure Controls with
Well Head Treatment or Alternative Water
Supply if any Future Potential Receptors are
identified.
Under this alternative, groundwater from aquifers
would be extracted and treated. Alternative 4
includes a continued monitoring program to verify the
reduction in pesticide concentrations, monitor
migration pathways, and evaluate the effectiveness of
the extraction system. If potential future receptors
are identified, they would be protected through the
monitoring program, area reconnaissance, and, if
necessary, through the use of well head treatment or
alternative water supply. The monitoring, area
reconnaissance and contingency controls programs
(same as in Alternative 2 and 3) will be in-place until
the clean up goals are achieved. The estimated time
to achieve the clean up goal in the various aquifers
ranges from 0 to less than 20 years for gamma BHC
(Lindane); from less than 5 to 55 years for alpha
BHC; from less than 5 to 55 years for beta BHC; and
from 0 to less than 5 years for delta BHC.
This alternative will also include a review every five
years to determine the effectiveness of the alternative
to protect human health and/or the environment. As
a result of the reviews, EPA will determine if
additional site remediation or modifications to the
alternative are required. The estimated cost of
Alternative 4 is $15,000,000.
EVALUATION OF ALTERNATIVES
The selection of the preferred alternatives for OU5 is
the result of a comprehensive screening and
evaluation process. The Feasibility Study (FS) report
identified and analyzed appropriate alternatives to
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address groundwater contamination at Mclver Dump
and Route 211 Areas. As stated previously, the FS
report, as well as other documents used relevant to
the site, are available for public review in the
information repository.
EPA uses the following nine criteria to compare all
proposed alternatives:
1. Overall protection of human health and the
environment: EPA assesses the degree to which
each alternative eliminates, reduces, or controls
threats to public health and the environment
through treatment, engineering methods, or
institutional controls.
2. Compliance with Applicable or Relevant and
Appropriate Requirements CARARsV The
alternatives are evaluated for compliance with all
applicable state and federal environmental and
public health laws and requirements that apply or
are relevant and appropriate to the Site
conditions.
3. Short-term effectiveness! The length of time
needed to implement each alternative is
considered, and EPA assesses the risks that may
be posed to workers and nearby residents during
construction and. implementation.
4. Long-term effectiveness: The alternatives are
evaluated based on their ability to maintain
reliable protection of public health and the
environment over time once the cleanup levels
have been met.
5. Reduction of contaminant toxicitv. mobility, and
volume: EPA evaluates each alternative based
on how it reduces (1) the harmful nature of the
contaminants, (2) their ability to move through
the environment, and (3) the volume or amount
of contamination at the Site.
6. Implememabilitv: EPA considers the technical
feasibility (e.g., how difficult the alternative is to
construct and operate) and administrative ease
(e.g., the amount of coordination with other
government agencies that is needed) of a remedy,
including the availability of necessary materials
and services.
7. Cost: The benefits of implementing a particular
remedial alternative are weighed against the cost
of implementation. Costs include the capital (up-
front) cost of implementing an alternative over
the long term, and the net present worth of both
capital and operation and maintenance costs.
8- State Acceptance: EPA requests state comments
on the Remedial Investigation Report, Risk
Assessment, Feasibility Study Report, and
Proposed Plan, and must take into consideration
whether the State concurs with, opposes, or has
no comment on the preferred alternative.
9. Community Acceptance: To ensure that the
public has an adequate opportunity to provide
input, EPA holds a public comment period and
public meeting and considers and responds to all
oral and written comments received from the
community prior to the final selection of a
remedial action.
ANALYSIS OF ALTERNATIVES
(SUMMARY)
MCIVER AREA
Overall Protection of Human Health and the
Environment - Alternatives 2, 3, and 4 should be
relatively equivalent in regards to the overall
protection of human health and the environment.
Alternative 1 would not be a protective alternative.
Currently, there are no complete exposure pathways
and therefore, no significant risks to human health.
Alternatives 2,3, and 4 would involve some controls
such as monitoring and area reconnaissance to
minimize the potential for future exposure.
Alternative 2 includes the enhancement of on-going
phytoremediation at the Area through the
emplacement of trees or other plant life in the
migration pathway of the pesticides. Alternative 3
includes the recovery of groundwater containing the
highest concentrations of pesticides. Alternative 4
which would attempt to recover groundwater
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containing pesticides exceeding their respective
cleanup goals.
Computer modeling indicates that pesticide
concentrations would not increase above current
conditions. Based on the Ecological Risk
Assessment, minimal impact is associated with
ecological receptors in Patterson Branch.
Additionally, since source soils were removed in
1997, residual pesticide concentrations will naturally
decrease. Alternatives 2,3, and 4 would each further
limit the potential discharge of residual pesticides into
Patterson Branch. Additionally, each of these
alternatives includes establishment of a monitoring
program at Patterson Branch to ensure no significant
impact to ecological receptors is maintained in the
future.
Because Alternative 1 is not protective of human
health and environment, it will be eliminated for
consideration under the remaining eight criteria.
Compliance with ARARs - Alternatives 2,3, and 4
would equally comply with ARARs. Pesticides
exceeding clean up goals would be addressed under
those three alternatives, via phytoremediation in
Alternative 2, and extraction wells in Alternatives 3
and 4.
Long-Term Effectiveness and Permanence -
Alternative 2,3 and 4 wouW reduce pesticide
concentrations until oiean up levels are achieved
Exposure during active remediation under
Alternatives 2, 3, and 4 would be controlled through
continued monitoring and area reconnaissance.
Therefore, Alternatives 2, 3, and 4 are equivalent in
regards to addressing long-term effectiveness and
permanence.
Reduction of Contaminant Toxicitv. Mobility, and
Volume - Alternative 2 would reduce contaminant
mobility and volume using phytoremediation.
Alternatives 3 and 4 would reduce the volume and
mobility of pesticides using extraction wells.
Alternatives 2,3, and 4 each would address the plume
at the Mclver Dump Area and each would reduce the
mobility and volume of pesticides through treatment.
Short-Term Effectiveness - For construction
activities, Alternative 2 poses the least threat to
workers, the public, and the environment followed by
Alternatives 3 and 4. Alternative 2 would also
require the least amount of time for implementation of
construction activities followed, in ascending order,
by Alternatives 3, and 4.
The expected time frame to achieve cleanup goals
under Alternatives 2,3, and 4 is the same (10 years).
Implementabilitv - Alternative 2 requires the
enhancement of the Mclver Dump Area with trees
and other plant life. No significant difficulties would
be anticipated for planting trees or other plant fife
under this alternative. Alternatives 3 and 4 each
include engineered remediation systems which should
be implementable, although not uncomplicated.
Additionally, excavation of interceptor trenches under
Alternatives 3 and 4 may compromise the existing
erosion control measures at the Area.
Cost - The total estimated present worth costs for
each alternative are listed below:
. Alternative 1: $160,000
Alternative 2: $450,000
Alternative 3: $ 1,500,000 (Surface Water) -
S1,200,000 (Infiltration Galleries)
- Alternative 4: $2,000,000 (Surface Water) -
$1,600,000 (Infiltration Galleries)
The costs for Alternatives 3 and 4 are greater than 2
times the cost for Alternative 2.
ROUTE 211 AREA
Overall Protection of Human Health and the
Environment - All of the alternatives, except the No
Action alternative, provide adequate protection of
human health. Alternatives 2, 3, and 4 would each
utilize control mechanisms including continued
monitoring and area reconnaissance. Additionally,
these alternatives provide exposure controls if any
future potential receptors are identified in the
migration pathway of impacted groundwater. The
exposure controls could include installation of well
head treatment systems or providing an alternative
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water supply.
Because Alternative 1 is not protective of human
health and environment, it will be eliminated for
consideration under the remaining eight criteria.
Compliance with ARARs . Alternative 2 may not
achieve the cleanup goals in a reasonable time frame
when compared with the Alternatives 3 and 4. Both
Alternatives 3 and 4 would achieve the cleanup goals.
Therefore, Alternative 3 and 4 would comply with
ARARs. Theprimary difference between Alternatives
3 and 4 would be that Alternative 3 would rely on
natural processes for the remediation of pesticides
outside of the former source area, while Alternative
4 would use extraction wells in all aquifers.
Long-Term Effectiveness and Permanence - For
Alternatives 2, 3, and 4, potential future receptors
would be identified through a comprehensive
monitoring program. The receptors would either be
connected to public water systems or individual
carbon filtration systems would be installed at the
point of use.
Reduction of Toricitv, Mobility or Volume
Through Treatment - Alternative 4 offers the
greatest reduction in mobility and volume of impacted
groundwater through extraction and treatment of all
impacted groundwater. Alternative 3 would result in
the reduction in mobility and volume of pesticides in
the Source Area groundwater through extraction and
treatment of approximately 60% of the pesticide mass
in the Surficial aquifer.
Short-Term Effectiveness - Alternatives 2 would
require no construction-related activities which could
endanger public communities or remedial workers.
Well installations have been successfully conducted
during RI activities. Therefore, implementation of
Alternatives 3 and 4 would pose no significant
concerns in regards to protection of public
communities or remedial workers.
In terms of the achievement of cleanup goals,
Alternative 4 would require the shortest time frame
followed by Alternative 3 and then by Alternatives 2.
However, certain aquifers and certain BHC isomers
would require equivalent time frames to achieve the . j
clean up goals under Alternatives 3 and 4.:For
gamma-BHC (Lindane), Alternatives 3 and 4 would
each require from 0 to less than 30 yปr* and from p_
to. less than 20 years, respectively, to achieve the
cleanup goals in the various aquifers. Forbeta-BHC,
the time frames to achieve the cleanup goals in the
various aquifers for Alternatives 3 and 4 would be
from less than 5 to 90 years and from less than 5 tn
55 years, respectively. The time frames to achieve
cleanup goals in the various aquifers for delta-BHC
would be from 0 to less than S y*r* for both
Alternatives 3 and 4. The range of time frames to
achieve the cleanup goal in the various aquifers for
alpha-BHC for Alternatives 3 and 4 would be from
less than 5 to 90 years and from less than 5. to SS
years, respectively.
Based on the results of the groundwater computer
modeling, (included in the FS report), when the alpha-
BHC concentration under Alternative 4 (upper
portion of the Upper Black Creek Aquifer) reachs the
cleanup goal (0.02 ppb)(i.e., 55 years), the alpha-
BHC concentration under Alternative 3 (Lower Black
Creek Aquifer) will be reduced to 0.04 ngfl. This
represents a 90% reduction in the alpha-BHC
concentration under Alternative 3 needed to meet the
0.02 Aig/1 cleanup goal.
The remaining 35 year difference between these
Alternatives (i.e., 90 years versus 55 years) is the
amount of time that it will take for the concentrations
in the Lower Black Creek Aquifer to go from 0.04
ppb to 0.02 ppb (a 2 x 10* risk to a 1 x 10"fi risk
reduction). This is an extremely low risk range.
Therefore, based upon the above discussion, the
ability to achieve the cleanup goal under Alternative
3 is generally equivalent to Alternative 4.
ImDlementahilitv- Alternatives 1 and 2 could be
easily implemented. Alternatives 3 and 4 require
construction of an extraction, treatment, and
discharge system(s), all of which would be located on
private property. However, Alternative 3 would
consist of an extraction well, a treatment building
accommodating two carbon treatment canisters, and
an infiltration gallery with approval already obtained
from this property owner. Multiple implementability
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concerns are associated with Alternative 4. The The monitoring program and control measures of
following lists certain aspects of Alternative 4 in Alternatives 2,3, and 4 would[adequately address the
regards to the implementability issues. migration of pesticides and prevent future exposure.
Twenty-two extraction wells having a combined Cost- The total estimated present worth costs for
flow rate of 935 gallons per minute (gpm) is each alternative are listed below:
estimated for the alternative.
A large treatment building to accommodate 4- Alternative 1: $370,000
10,000 Ibs. carbon vessels would be needed. Alternative 2: $1,400,000
The treatment building would need to be Alternatives: $2,600,000
centrally located. Thousands of feet of pipeline Alternative 4: $15,000,000
would be necessary for the extraction and
treatment system. Alternative 4 would be significantly greater in cost
A 3.6 mile discharge pipeline to Quewhiffle than any of the other alternatives.
Creek would be required.
Potential for spreading unknown groundwater State Acceptance - The North Carolina Department
contaminants, other than pesticides, in the large of Environment and Natural Resources (NCDENR)
capture zone created by 22 extraction wells. has participated during all the remedial process for
Numerous easements and property access this Site and concurs with EPA's proposed remedial
agreements would be required to obtain access to action for both the Mclver and Route 211 Areas.
approximately 250 acres.
A minimum of nine months would be required to Community Acceptance - Community acceptance
obtain a NPDES permit for surface water will be evaluated after the public comment period and
discharge, and greater than 2 years would be will be described in the Record of Decision for
required for modeling the extraction system, Operable Unit 5.
obtaining access agreements, design of the
system, and development of a monitoring
program.
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EPA'S PREFERRED ALTERNATIVE
After conducting a detailed analysis of all the feasible cleanup alternatives based on tbe criteria described in
the previous sections, EPA is proposing the following cleanup plan to address groundwater contamination at
Mclver and Route 211 Areas. The EPA preferred alternatives are:
MOVER AREA
Alternative 2: Phytoremediation, Continued Groundwater/Surface Water Monitoring, Area
Reconnaissance, and Contingency Well Head Treatment if Future Potential Receptors
are identified
Est. Cost - $450,000
ROUTE 211 AREA
Alternative 3: Groundwater Recovery from the Source Area Groundwater Using Extraction,
Treatment by Carbon Adsorption, and Discharge of Treated Groundwater via
Reinfection (Infiltration Galleries/Injection Wells), Continued Groundwater
Monitoring of the Surficial, Upper Black Creek and Lower Black Creek aquifers,
Area Reconnaissance, and Contingency Controls with Well Head Treatment or
Alternative Water Supply if Future Potential Receptors are identified.
Est Cost - $2,600,000
Based on current information, these alternatives appear to provide the best balance of trade-offs with respect
to the nine criteria that EPA uses to evaluate alternatives. EPA believes the preferred alternatives will satisfy
the statutory requirements of Section 121(b) of CERCLA, 42 USC 9621(b), which provides that the selected
alternatives be protective of human health and the environment, comply with ARARs, be cost effective, and
utilize permanent solutions and treatments to the maximum extent practicable. The selection of the above
alternatives is preliminary and could change in response to public comments.
PUBLIC PARTICIPATION/COMMUNITY RELATIONS
As already stated in this fact sheet, EPA is conducting a 30-day public comment period beginning on January
18, 1999 and extending until midnight February 17, 1999 to receive written comments from citizens
concerning this proposed interim remedial action. There will also be a public meeting at 7:00 p.m. on
February 4th at the Aberdeen Fire Station to receive oral comments. If requested by an individual, a 30-
day extension can be added to the comment period. If you prefer to submit written comments, please mail
them postmarked no later than midnight February 17,1999, to:
Ms. Diane Barrett
Community Involvement Coordinator
North Site Management Branch
U.S.E.P.A., Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-8960
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The Aberdeen Pesticide Dumps Site awarded an EPA Technical Assistance Grant (TAG) to the
MooreFORCE, Inc. organization several years ago. If you are interested in joining this group of concerned
citizens, please contact them at (704)692-7141.
The Aberdeen Community Liaison Panel meets the third Thursday of each month to discuss on-going activities
occurring at the entire Site. The members of the panel consist of area citizens, businessmen, City/County/State
and Federal government officials and representatives of the Potentially Responsible Parties. Citizens are invited
to attend . The meetings begin at 5:30 PM at the Aberdeen Fire Station.
During this 30-day period, the public is invited to review all site-related documents housed at the information
repository located at the Aberdeen Town Hall in Aberdeen, North Carolina and offer comments to EPA either
orally at the public meeting which will be recorded by a court reporter or in written form during this time
period. The actual remedial action could be different from the proposed preferred alternative, depending upon
new information or arguments EPA may receive as a result of public comments.
All comments will be reviewed and a response prepared in making the final determination of the most
appropriate alternative for cleanup/treatment of the Site. EPA's final choice of a remedy will be issued in a
Record of Decision (ROD). A document called a Responsiveness Summary summarizing EPA's response to
all public comments will also be issued with the ROD. Once the ROD is signed by the Regional Administrator
it will become part of the Administrative Record (located in the Town Hall) which contains all documents
used by EPA in making a final determination of the best cleanup/treatment for the Site. Once the ROD has
been approved, EPA will again negotiate with the Potentially Responsible Parties (PRPs) to allow them the
opportunity to design, implement and absorb all costs of the remedy determined in the ROD in accordance with
EPA guidance and protocol. Once an agreement has been reached, the design of the selected remedy will be
developed and implementation of the remedy can begin.
INFORMATION REPOSITORY LOCATION:
Aberdeen Town Hall
115 North Poplar Street
Aberdeen, North Carolina
Phone:(910)944-1115
Hours: Monday - Friday 8:00-5:00
Saturday & Sunday - Closed
FOR MORE INFORMATION PLEASE CONTACT:
Luis E. Flores, Remedial Project Manager or
Ms. Diane Barrett, NC Community Involvement Coordinator
North Site Management Branch
U.S. Environmental Protection Agency, Region IV
61 Forsyth Street, S.W., 11lh Floor
Atlanta, Ga 30303-8960
Toll Free No.: 1-800-435-9233
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Mailing List
If you know of someone that would be interested in receiving a copy of this feet sheet and would like to have
their name placed on the Aberdeen Pesticide Dumps Site mailing list, ask them to complete this form and
return to Diane Barrett at the EPA address previously given. If you have an address change or wish to have
your name removed from this mailing list, please complete this form and return to Diane Barrett.
Thank you for your cooperation.
Name ,...
Address
City, State, Zip Code
Addition.
.Change.
.Deletion.
Region 4
U.S. Environmental Protection Agency
61 Forayth Street, SW
Atlanta, Georgia 30303-3950
North Site Management Branch
Diane Barren, Community Relations Coord.
Luis E. Rores. Remedial Project Manager
Official Business
Penalty for Private Use $300
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ATTACHMENT B
PUBLIC MEETING SIGN-IN SHEET
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%^^ PLAN PUBLIC MEETING
ABERDEEN PESTICIDES DUMP SITE
Operable Unit #5 - Groundwater (Mclver & Route 211 Areas)
Aberdeen, North Carolina
February4,1999
w
x^x
(NOTICE; Duo to the Freedom of Information Act regulations, once
your name and address are provided they become public
- --- Information.)
ADDRESS
PHONE#
i^iJI&.
I Oiifc
P.O.
We-
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ATTACHMENT C
INFORMATION REPOSITORY
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INFORMATION REPOSITORY LOCATION
ABERDEEN TOWN HALL
115 North Poplar Street
Aberdeen, North Carolina
Telephone-(910) 944-1115
Hours: Monday - Friday 8:00 - 5:00
Saturdays and Sundays- Closed
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ATTACHMENT D
PUBLIC MEETING OFFICIAL TRANSCRIPT
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PUBLIC MEETING
ON
PROPOSED PLAN
ABERDEEN PESTICIDES DUMP SITE
OPERABLE UNIT #5 - GROUNDWATER
MCIVER DUMP AND ROUTE 211 AREAS
FEBRUARY 4, 1999
ABERDEEN FIRE STATION
HIGHWAY 1 AND PEACH STREET
ABERDEEN, NORTH CAROLINA
TAKEN BY:
WANDA B. LINDLEY, CVR-CM/NCCR
NOTARY PUBLIC
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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DIANE BARRETT: WE WELCOME EACH AND EVERY ONE
OF YOU HERE TONIGHT. AND I JUST WANT TO RECOGNIZE ANY CITY
OR STATE OR COUNTY OR CONGRESSIONAL OFFICIALS FIRST. RANDY,
WILL YOU STAND?
RANDY MCELVEEN: RANDY MCELVEEN FOR THE NORTH
CAROLINA SUPERFUND, DEPARTMENT OF ENVIRONMENTAL AND NATURAL
RESOURCES.
DIANE BARRETT! THANK YOU. AND WE THANK EACH
AND EVERY ONE OF YOU FOR TAKING TIME OUT OF YOUR BUSY
SCHEDULES TO COME TO THIS MEETING TONIGHT. WE HAVE A LONG,
LONG, LONG, LONG PRESENATION. I BELIEVE EVERYBODY THAT'S
HERE HAS BEEN HERE BEFORE.
SO LUIS FLORES IS THE PROJECT MANAGER FOR OP
UNIT 5 WHICH DEALS WITH GROUNDWATER FOR ROUTE 211 AT THE
MCIVER SITE.
AND THEN BILL OSTEEN DO YOU WANT TO STAND
BILL, PLEASE? HE IS E.P.A.'S GROUNDWATER EXPERT. ANY
QUESTIONS ABOUT GROUNDWATER YOU WANT ASK, YOU MIGHT ASK HIM.
AND CHUCK MIKALIAN BACK THERE IN THE BACK, HE
IS E.P.A.'S ATTORNEY FOR THE SITE. HE CAME ALONG JUST IN
CASE WE HAD ANY LEGAL QUESTIONS. WELCOME HIM, TOO.
THE PURPOSE OF TONIGHT'S MEETING IS FOR E.P.A.
TO PRESENT THE PROPOSED PLAN OF ACTION FOR THE GROUNDWATER
AT MCIVER AND ROUTE 211 AREAS. THESE TWO AREAS ARE CALLED
OP UNIT 5. SINCE THERE ARE FIVE AREAS IN THE ABERDEEN
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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REMEDIAL INVESTIGATION, AND WE SAMPLED FOR SURFACE WATER AND
SEDIMENTS. NONE OF THE SURFACE WATER SAMPLES THAT WERE
COLLECTED EXCEEDED NORTH CAROLINA SURFACE WATER STANDARDS.
SO, BASICALLY, THE IMPACT TO PATTERSON BRANCH IS MINIMAL.
WE ALSO SAMPLED GROUNDWATER AROUND ON THIS
AREA (INDICATING) USING MONITORING WELLS, AND WE FOUND OUT
THAT NONE OF THE CONCENTRATIONS FROM MONITORING WELLS
EXCEEDED ANY DRINKING WATER STANDARDS.
LET ME SHOW YOU WHERE THE SOME OF THOSE
OR WHERE THE SAMPLING POINTS WERE. AS YOU CAN SEE, FOR A
RELATIVELY SMALL AREA THERE ARE A LOT OF SAMPLING POINTS.
THIRTY SAMPLES WERE COLLECTED FROM ABOUT THIRTY-TWO SAMPLING
POINTS. SO AS YOU CAN SEE, FOR A SMALL AREA, THE AREA IS
PRETTY WELL-DEFINED.
SO, IN GENERAL, LOW LEVEL PESTICIDES WERE
DETECTED IN THESE SAMPLES. AND, AS I SAID, NONE OF THEM
EXCEEDED DRINKING WATER STANDARDS. SO BECAUSE THE DRINKING
WATER STANDARDS WERE NOT EXCEEDED IN THIS SITE OR IN THIS
AREA, IN THOSE CASES WE USED BECAUSE THE DRINKING WATER
STANDARDS WERE NOT EXCEEDED, BASICALLY THE CLEAN-UP HERE ON
THIS SITE IS GOING TO BE DRIVEN BY THOSE CONTAMINANTS THAT
DO NOT HAVE A DRINKING WATER STANDARD.
SO FOR CONTAMINANTS THAT HAVE A DRINKING WATER
STANDARD, WE USED THAT DRINKING WATER STANDARD AS THE CLEAN-
UP NUMBER. BUT FOR THOSE CONTAMINANTS THAT WE DO NOT HAVE A
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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DRINKING WATER STANDARD, WE CALCULATE MATHEMATICALLY A
CLEAN-UP NUMBER, AND ALL THAT THOSE CALCULATIONS ARE
BASED ON RISK ASSESSMENT.
SO, BASICALLY, TAKING INTO CONSIDERATION THE
FINDINGS OF THE INVESTIGATION WHICH IN SUMMARY ARE IN
SUMMARY ARE THAT NOBODY IS USING THE GROUNDWATER IN THIS
AREA, THAT THEIR LOW CONCENTRATION OF PESTICIDES, THAT
NONE OF THE SAMPLES EXCEEDED DRINKING WATER STANDARDS, AND
THAT PATTERSON BRANCH IS NOT IMPACTED.
E.P.A. IS PROPOSING THE FOLLOWING PLAN TO
ADDRESS THE GROUNDWATER. BASICALLY, WHAT WE'RE PROPOSING IS
TO USE THE PHYTOREMEDIATION TO ENHANCE THE INTRINSIC
REMEDIATION WHICH IS BASICALLY THE NATURAL PROCESS OF
REMEDIATION THAT THE GROUNDWATER HAS. SO WE'RE WE'RE
PROPOSING PLANTING TREES ALONG PATTERSON BRANCH TO HELP THE
DEGRADATION OF THOSE CONTAMINANTS IN THE GROUNDWATER THE
LOW LEVELS OF CONTAMINANTS.
WE WILL ALSO PUT IN PLACE A MONITORING PROGRAM
FOR GROUNDWATER TO MAKE SURE THAT THE CONCENTRATIONS ARE
DECREASING. AND, ALSO, WE WILL SAMPLE SURFACE WATER AND
SEDIMENT ~ AND SEDIMENTS TO ~ TO MAKE SURE THAT NOTHING
HAS CHANGED AND THAT PATTERSON BRANCH HAS NOT BEEN IMPACTED.
WE WILL ALSO DO AREA RECONNAISSANCE WHICH WILL
CONSIST BASICALLY OF MAKING SURE THAT NOBODY WILL GO TO THE
SITE AND START USING THE GROUNDWATER. IN THIS AREA, THERE'S
WORDSERVICEB, IMC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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THE POTENTIAL FOR SOMEBODY TO GO OVER THERE AND PUT A WELL.
IT'S VERY, VERY SLIM. BUT WE'RE STILL GOING TO HAVE THAT
JUST AS A SECURE MEASURE. IF SOMEBODY GO OVER THERE AN PUT
A WELL OR WANT A WELL THERE, WE WILL MAKE SURE THAT THEY
WILL NOT USE THE GROUNDWATER USING EXPOSURE CONTROLS.
SO, IN SUMMARY, WE WILL USE PHYTOREMEDIATION
TO TAKE CARE OF THOSE LEVEL OF ~ LOW LEVEL OF PESTICIDES
AND TO HELP THE NATURAL ATTENUATION PROCESSES THAT ARE
ALREADY OCCURRING ON THE SITE. WE WILL DO MONITORING TO
MAKE SURE THAT WE KNOW WHERE THE CONCENTRATIONS ARE IN THE
GROUNDWATER AND MONITORING THE SURFACE WATER AND SEDIMENTS
TO MAKE SURE THAT WE KNOW WE'RE ASSURED THAT PATTERSON
BRANCH IS NOT BEING IMPACTED.
THE AREA RECONNAISSANCE ALSO TO MAKE SURE THAT
NOBODY WILL GO OVER THERE AND USE THE GROUNDWATER UNTIL
WE'RE DONE. AND IF SOMEBODY IS EXPOSED, WE WILL MAKE SURE
THAT WE WILL CONTROL THAT EITHER BY PROVIDING A ALTERNATIVE
WATER SUPPLY OR HEAD WELL TREATMENT.
SO THAT'S BASICALLY THE PROPOSED PLAN FOR THE
MCIVER AREA. I GUESS IF NOW IF THERE IS ANY QUESTIONS
REGARDING THE MCIVER AREA AND THE PROPOSED ALTERNATIVE?
DATID SINCLAIR: I HAVE ONE.
LUIS FLORESS YES?
DAVID 8INCLAIR8 I'M DAVID SINCLAIR WITH THE
FAYETTE7ILLE OBSERVER-TIMES. I'M NOT QUITE CLEAR ON YOU
WORDSERVICES, INC.
Post Office BOX 751
Siler City, North Carolina 27344
(800) 266-3248
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WERE TALKING ABOUT IF SOMEONE WERE TO MOVE INTO THAT AREA
AND TRY TO DRILL A WELL, THAT YOU SAY YOU WOULD PREVENT THEM
FROM DOING THAT OR STOP THEM FROM DOING THAT. I WAS A
LITTLE FUZZY ON EXACTLY WHAT YOU WERE TALKING ABOUT IF
SOMEBODY DOES MOVE IN THERE. WHAT WOULD HAPPEN?
LUIS FLORES: WELL, THE AREA OF RECONNAISSANCE
MAY JUST WE'RE JUST GOING TO MAKE SURE THAT NOBODY IS
GOING TO USE THAT GROUNDWATER. I MEAN, THEY CAN MOVE THERE
AND BUILD A HOUSE OR WHATEVER. THEY JUST SHOULD NOT DRINK
THE GROUNDWATER STRAIGHT THE WAY IT COMES FROM THE GROUND.
IF THEY INSIST ON PUTTING A PRIVATE WELL, WE WILL MAKE SURE
THAT THEY WILL NOT DRINK THE WELL JUST STRAIGHT THE WAY IT
COMES FROM THE GROUND.
DAVID SINCLAIR: WOULD YOU PUT SOME KIND OF A
TREATMENT DEVICE ON IT OR
LOIS FLORES: YEAH, PROBABLY A WELL TREATMENT
SYSTEM; MAYBE CARBON.
DAVID WARNER: TONIGHT I'M SPEAKING ON BEHALF
OF MOOREFORCE. HARRY HUBERT COULDN'T MAKE IT TO THE MEETING
TONIGHT AND HE EXPRESSES HIS REGRETS. BUT I'M GOING TO
ATTEMPT TO SPEAK FOR HARRY AND MOOREFORCE ON BEHALF OF THE
COMMUNITY IN RESPONSE TO THE E.P.A. SELECTED ALTERNATIVE TWO
FOR THE MCIVER SITE.
FIRST OF ALL, I GUESS WE WANT TO JUST
REINFORCE THAT WE DON'T TAKE EXCEPTION AT ALL TO THE
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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ALTERATIVE. WE THINK IT'S A REASONABLE ALTERNATIVE AT THIS
POINT IN TIME. WE LIKE THAT THE REGULATORY STANDARD, I.E.
THE CLEAN-UP STANDARD, IS GOING TO BE TO THE NORTH CAROLINA
ONE TO THE TIMES TEN OR MINUS SIX IN TERMS OF RISK.
AND AND WE SUPPORT THAT, AND ~ AND WE'LL VIGILANTLY
WATCH AND LOOK FOR RESULTS TO THAT STANDARD.
AND THAT CONTINUED MONITORING, OF COURSE, OF
THAT SITE IS CRITICAL; BECAUSE THINGS CAN HAPPEN IN THE
FUTURE THAT WE DON'T SEE TODAY ON OTHER SITES. AND SO WE'RE
VERY SUPPORTIVE OF A VERY STRUCTURED AND WELL-DESIGNED
MONITORING PROGRAM AS WELL.
IN THE SHEET THAT WAS CIRCULATED THAT ~ I
GUESS IT'S FROM COMMUNITY RELATIONS THAT HAD THE
ALTERNATIVES OUTLINED SHOWING THAT ALTERNATIVE TWO WAS
SELECTED FOR THE MCIVER AREA AND THE E.P.A. SELECTED '
ALTERATIVE, IT SAYS ALTERNATIVE TWO AND THE FIRST WORD,
IT SAYS PHYTOREMEDIATION, CONTINUED GROUNDWATER/SURFACE
WATER MONITORING, AREA RECONNAISSANCE, AND THE CONTINGENCY
WELL HEAD TREATMENT IF WELLS ARE DRILLED.
WE JUST TAKE EXCEPTION TO THAT AS
PHYTOREMEDIATION IS NOT IN REALITY WHAT WHAT THE LEADING
REMEDIATION TECHNIQUE IS HERE. BUT RATHER IT'S KIND OF ~
IT'S NOT A DO NOTHING ALTERNATIVE, BUT NATURAL ATTENUATION
IS BEING COUNTED ON AS BEING THE PRIMARY MEANS OF
REMEDIATION OF THE CONTAMINANTS ON THE SITE.
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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GRANTED, THAT THE CONTAMINANTS FOUND TODAY ARE
BELOW REGULATORY LEVELS. BUT WE ~ WE TOOK EXCEPTION TO THE
WORD PHYTOREMEDIATION BEING THE LEADING. WE THINK THAT
NATURAL ATTENUATION IS THE INTENDED TRIGGER OF THE
CONTAMINANTS WITH PHYTOREMEDIATION BEING A POSSIBLE ENHANCER
OF THAT PROCESS THROUGH WHATEVER MICRO MICROBIAL ACTIVITY
THAT WILL HAPPEN IN THE TREES AND THAT TYPE OF THING.
SO WE'D LIKE TO RECOMMEND THAT
PHYTOREMEDIATION ISN'T A LEAD REMEDIAL STRATEGY. IT'S A
SECONDARY POSSIBILITY OF ENHANCING THE PRIMARY STRATEGY
WHICH IS NATURAL ATTENUATION OF THE CONTAMINANTS IN THE
GROUNDWATER. SO WE JUST WE WANTED TO GO ON THE RECORD
AND FORMALLY STATE THAT.
AND THEN WE WANTED TO SEE THAT REFLECTED ALSO
IN THE -- EVENTUALLY IN THE RECORD OF DECISION. REALLY IT'S
NATURAL ATTENUATION; PHYTOS COME IN SECONDARY. AND WE JUST
WANTED TO MAKE THAT CLEAR.
AND THAT'S ABOUT ALL WE HAVE TO SAY FOR
MCIVER.
LUIS PLORES* YEAH, WHAT DAVID SAID,
PHYTOREMEDIATION BASICALLY WILL BE USED TO ENHANCE THAT
NATURAL ATTENUATION PROCESSES THAT ARE ALREADY OCCURRING AND
WILL CONTINUE TO OCCUR NOW THAT THE SOURCE - THE SOURCES
HAVE BEEN REMOVED.
ANY OTHER QUESTIONS BEFORE WE GO TO ROUTE 211?
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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1 (NO RESPONSE.)
2 WELL, THE ROUTE 211 AREA IS A LARGER AREA IN
3 COMPARED WITH MCIVER. HERE'S ROUTE 211 ROAD (INDICATING) OR
4 HIGHWAY 211. THIS IS CAROLINA ROAD (INDICATING) . AND THE
5 ROUTE 211 AREA IS RIGHT HERE (INDICATING) . HERE
6 (INDICATING) IS WHERE THE FORMER SOURCE AREA WAS. ALL THAT
7 SOIL CONTAMINATED SOIL HAS BEEN EXCAVATED AND REMOVED AND
8 TREATED. SO IT'S NOT THERE ANYMORE.
9 IN THE MCIVER I'M SORRY. IN THE ROUTE 211
10 AREA WE COLLECTED SAMPLES FROM SEVENTY-NINE SAMPLING POINTS.
11 WE USED MONITORING WELLS. WE USED TEMPORARY SAMPLING POINTS
12 AND PRIVATE WELLS. THE RESULTS FROM THE FROM THAT SAMPLE
13 TELLS US THAT THE HIGHEST CONCENTRATION OF PESTICIDES ARE
14 LOCATED CLOSE TO THE FORMER SOURCE AREA, BASICALLY NORTH OF
15 THE RAILROAD TRACKS. IT ALSO SHOWS THAT AS WE MOVE FURTHER
16 DOWNGRADIENT OR FURTHER AWAY FROM THE FORMER SOURCE AREA,
17 THE CONCENTRATIONS START DECREASING CONSIDERABLY.
18 OF THE SEVENTY-NINE SAMPLING POINTS, DRINKING
19 WATER STANDARDS WERE EXCEEDED ONLY IN TWO OF THEM; THESE TWO
20 HERE (INDICATING) . IN ALL THE OTHER SAMPLING POINTS, NONE
21 OF THEM EXCEEDED DRINKING WATER STANDARDS.
22 ALSO, WITH THE EXCEPTION OF THE SOURCE AREA
23 WHERE THE HIGH CONCENTRATION OF PESTICIDES ARE AND THE TWO
24 SAMPLE POINTS WHERE THE DRINKING WATER STANDARDS WERE
25 EXCEEDED, ALL THE OTHER SAMPLES, ALL THE OTHER RESULTS FROM
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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THE ANALYSIS SHOW THAT THE CONCENTRATIONS ARE WITHIN E.P.A.
ACCEPTABLE RISK RANGE OR E.P.A. ACCEPTABLE RANGE OP
CONCENTRATIONS FOR CLEAN-UP.
BUT BECAUSE THE STATE OF NORTH CAROLINA DOES
NOT RECOGNIZE THE RANGE OF CONCENTRATIONS FOR CLEAN-UP, WE
HAVE TO USE WHAT THE STATE OF NORTH CAROLINA RECOGNIZES
WHICH IS THE MOST CONSERVATIVE NUMBER FOR CLEAN-UP OF THAT
RANGE. SO, BASICALLY, WE WILL BE CLEANING TO THE MOST
CONSERVATIVE NUMBER OF THAT RANGE, EVEN THOUGH THAT IN ALL
THIS AREA, CONCENTRATIONS ARE WITHIN E.P.A. ACCEPTABLE RISK
RANGE.
SO LET'S GO BACK TO THIS AREA HERE THAT I SAID
CLOSE TO THE FORMER SOURCE AREA WHERE THE HIGHEST
CONCENTRATION OF PESTICIDES ARE. THAT IS THE AREA OR THE
PART OF THE SITE THAT WE LAST YEAR INSTALLED THAT PUMP AND
TREAT SYSTEM AS PART OF THE INTERIM INTERIM ACTION. WHAT
THAT INTERIM ACTION IS DOING OR HAS BEEN DOING FOR THE LAST
YEAR HERE'S THE RAILROAD TRACKS AGAIN (INDICATING). HERE
(INDICATING) IS WHERE THE HIGH CONCENTRATION OF PESTICIDES
ARE OR WHERE THE FORMER SOURCE WERE WHERE THE
CONTAMINATED SOURCE WERE.
WHAT THE INTERIM ACTION IS DOING IS BASICALLY
CAPTURING ALL THOSE HIGH CONCENTRATIONS OF PESTICIDES THAT
ARE ABOVE E.P.A. ACCEPTABLE RANGE. SO, AS I SAID, ALL THE
CONCENTRATIONS DOWN HERE (INDICATING) ARE EITHER BELOW OR
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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BASICALLY, ON THIS PART OF THE AREA, WE WILL BE WE WILL
LET NATURE TO TAKE CARE OF THE REMEDIATION AND WE WILL BE
MONITORING TO MAKE SURE WE KNOW WHERE EVERYTHING IS.
THE AREA RECONNAISSANCE: TO MAKE SURE NOBODY
PUTS ANY WELLS IN THIS AREA AND DRINK THE WATER. AND IF WE
FIND SOMEBODY THAT ~ THAT DO, WE WILL PROVIDE ALTERNATE
ALTERNATIVE WATER SUPPLY.
SO THAT'S BASICALLY THE PROPOSED ALTERNATIVE
FOR THE ROUTE 211 AREA. ARE THERE ANY QUESTIONS REGARDING
THIS AREA? YES?
PHYLLIS KALK: DID YOU HAVE TO ARE THERE
ANY PEOPLE LIVING CLOSE ENOUGH AROUND THERE THAT YOU HAVE TO
THAT THEY HAVE TO PUT ON ABERDEEN WATER, YOU KNOW,
INSTEAD OF THEIR PRIVATE WELLS? OR IS THERE ANYBODY WHO
LIVED CLOSE ENOUGH TO THAT AREA TO HAVE TO DO THAT? "
LUIS PLORES: THERE THERE'S PEOPLE LIVING
DOWN DOWN HERE (INDICATING) WHERE THE LOW CONCENTRATION
OF PESTICIDES WERE DETECTED.
PHYLLIS KALK: UH-HUH (YES).
LUIS PLORES: THEIR PRIVATE WELLS WERE
SAMPLED. SOME OF THEM WERE BELOW THE CLEAN-UP NUMBERS THAT
WE'RE GOING TO USE. OTHERS WERE SLIGHTLY ABOVE BUT STILL
WITHIN E.P.A. ACCEPTABLE RISK RANGE. BUT THE COMPANIES WENT
AHEAD AND CONNECT ALL OF THEM BUT ONE TO CITY WATER. THAT
THAT HOUSEHOLD THAT IS NOT CONNECTED TO CITY WATER,
WORDSERVICES, INC.
Post Office BOX 751
Siler City, North Carolina 27344
(800) 266-3248
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TREATMENT HEAD TREATMENT SYSTEM WAS INSTALLED IN HIS
WELL. THEY DID NOT WANT TO TAKE CITY WATER.
DAVID SINCLAIR: DO YOU KNOW HOW MANY PEOPLE
WERE HOOKED UP?
LUIS PLORES: I THINK IT WAS LIKE SIX.
DAVID WARNER: WE HAD SOME MEETINGS, IT WAS A
YEAR AGO SEPTEMBER. SO WE TALKED ABOUT THE INTERIM ACTION
AND PUTTING THE EXTRACTION WELL IN AND GOING AHEAD AND DOING
THE CARBON ABSORPTION AND INFILTRATION GALLERY. AND I GUESS
THAT WAS INSTALLED IN JANUARY OR SO OF '98. WE HADN'T HEARD
ANYTHING. I JUST WONDERED WHAT THE DELAY WAS, BECAUSE UNTIL
NOW WE'RE STARTING TO TALK ABOUT A PROPOSED REMEDIAL ACTION.
WHAT WAS THE DELAY?
LUIS PLORESt WELL, WE BASICALLY HAD THE
REMEDIAL INVESTIGATION FINISHED WHEN WE GOT TOGETHER WITH
THE COMPANIES AND DECIDED TO DO THE INTERIM ACTION. THE
FEASIBILITY STUDY THAT WE HAD WAS NOT FINISHED YET. WE WERE
STILL GOING BACK AND FORWARD WITH THE COMPANIES DOING
GROUNDWATER MODELING AND DEVELOPING DIFFERENT ALTERNATIVES.
AND THAT, BASICALLY, WAS WHAT TOOK MOST OF THE TIME.
BUT RECOGNIZING AT THAT TIME THAT WE WERE ~
THAT IT WAS GOING TO TAKE US LONGER TO FINALIZE THAT
FEASIBILITY STUDY REPORT, THAT WAS PROBABLY ONE OF THE
BIGGEST REASONS TO GO AHEAD AND DO THE INTERIM ACTION;
BECAUSE WE KNEW THAT THE REMEDIAL INVESTIGATION WAS
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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FINISHED, WE KNEW WHERE THE CONCENTRATIONS WERE, AND WE KNEW
THAT THE HIGHEST CONCENTRATIONS WERE IN THIS AREA AND THAT
WE COULD DO SOMETHING REAL FAST AND TAKE CARE OF THAT.
. RANDY MCZLVEBN: E.P.A. RANDY MCELVEEN,
NORTH CAROLINA SUPERFUND. E.P.A. ALSO DID SOME INTERNAL
STUDY OF THAT TO MAKE SURE THIS WAS A SITE THAT WAS
APPROPRIATE FOR THE REMEDIATION THAT WAS BEING PROPOSED. IS
THAT NOT CORRECT?
LUIS FLORES: I'M NOT SURE WHAT YOU ~
RANDY MCELVEEN: WAS IT MODELING MAINLY?
LUIS FLORES: YEAH, MODELING EXTENSIVE
GROUNDWATER MODELING WAS CONDUCTED, TOO.
RANDY MCELVEEN: I WAS THINKING THAT THERE WAS
ALSO SOME DISCUSSION WITHIN THE MANAGEMENT ABOUT THE TO
ASSURE THAT THIS THAT THEY DIDN'T NEED SOME OTHER MORE
AGGRESSIVE GROUNDWATER CLEAN-UP PROGRAM.
LUIS FLORES: RIGHT. THERE WAS A LOT OF
DISCUSSION --
RANDY MCELVEEN: (INTERPOSING) WITHIN E.P.A.
AND WITH THE STATE?
LUIS FLORES: WITH THE E.P.A. ABOUT
GROUNDWATER MODELING. WE WANTED TO MAKE SURE THAT BASICALLY
THIS WAS THE BEST THING THAT WE CAN DO TO ADDRESS THIS
THESE AREAS. DAVID?
DAVID WARNER: I'VE GOT MY STATEMENT NOW.
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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I'VE ASKED MY QUESTION, SO I'LL MAKE MY STATEMENT NOW, IF
THAT'S ALL RIGHT.
AGAIN, THIS IS ON BEHALF OF MOOREFORCE
REGARDING THE ROUTE 211 SITE.
COURT REPORTER: SIR, WOULD YOU LIKE TO STATE
YOUR NAME SO IT WILL BE ON THE RECORD?
DAVID WARNER: OH, I'M SORRY. DAVID WARNER
COURT REPORTER: THANK YOU.
DAVID WARNER: CONSULTANT WITH MOOREFORCE
UNDER THE TAG GRANT.
(TO COURT REPORTER) AND I'VE GOT THIS ALL IN
WRITING, BY THE WAY. I'LL SUBMIT IT TO YOU.
THIS IS REALLY KIND OF A TWO-PART PROJECT,
AND THE SOURCE AREA IS ONE AREA AND AND THE INTERIM
ACTION WAS ALLOWED TO GO AHEAD TO GO AHEAD AND HIT 'THE
HIGH CONCENTRATIONS OF GROUNDWATER CONTAMINANTS.
BELOW THE RAILROAD ON THAT DEPICTION WHERE
THOSE OTHER WELLS ARE, WHERE IT SAYS "LOW CONCENTRATION OF
PESTICIDES," REMEMBER THERE WERE TWO TWO SPOTS IN THERE
WHERE THERE WERE SIGNIFICANT CONCENTRATIONS OF PESTICIDES.
AND FOR THOSE OF YOU WHO GOT THE INFORMATION
SHEET ABOUT THE AQUIFER, IT'S A LAYERED AQUIFER AND IT'S
FAIRLY COMPLEX WITH FOUR DIFFERENT WATER UNITS SEPARATED BY
CONFINED CLAY LAYERS.
IT'S A COMPLEX HYDROGEOLOGY ON THE SITE. AND
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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21
1 WHAT WE'VE LEARNED IS THAT THE CONTAMINANTS ARE DIFFUSE DOWN
2 THROUGH A PLUME DOWNGRADIENT FROM THE SOURCE AREA, AND THAT
3 THE STRATEGY IN THE SOURCE AREA WAS TO PUMP AND TREAT. THE
4 STRATEGY BELOW THE GROUND LEVEL IS NATURAL ATTENUATION --
5 I.E. WE'RE GOING TO LET IT GO AND WE'RE GOING TO MONITOR IT.
6 AND WE JUST WANT TO ~ WE THINK THAT SHOULD BE
7 ACKNOWLEDGED AS WELL THAT NATURAL ATTENUATION AGAIN IS A
8 PART OF THE STRATEGY. LET IT GO NATURALLY AS PART OF THE
9 DEAL, WITH THE CONTINGENCIES IN PLACE FOR WELL HEAD
10 TREATMENT OR HOOKING UP TO CITY WATER, OR WHATEVER ELSE IS
11 NEEDED.
12 SO, AGAIN, NATURAL ATTENUATION OUGHT TO BE
13 MENTIONED AS PART OF YOUR STRATEGY FOR THE WHOLE OTHER PART
14 OF THE 211 SITE. AGAIN, WE WANT TO STICK TO THE NORTH
15 CAROLINA GROUNDWATER STANDARDS OF ONE TIMES TEN MINUS'SIX OF
16 RISK.
17 ONE OF THE CRITICAL AREAS, BECAUSE WE HAVE
18 SUCH COMPLEX HYDROGEOLOGY BELOW THE RAILROAD THERE, AND WE
19 HAVE SUCH A WIDELY DIVERSE DISPERSED PLUME OF CONTAMINANTS
20 OVER A FAIRLY BROAD AREA, AREA RECONNAISSANCE AS YOU
21 SUGGESTED IS VERY CRITICAL.
22 AND IN OUR EARLIER DISCUSSIONS, WE WERE TOLD
23 THAT ONE OF THE REGULAR WAYS THIS HAPPENS IS THAT THE FOLKS
24 THAT ARE GOING OUT AND DOING THE SAMPLING OF THE WELLS WILL
25 DO VISUAL OBSERVATIONS OF ANY LAND DISTURBANCES OR
WORDSERVICES, INC.
Post Office BOX 751
Siler City, North Carolina 27344
(800) 266-3248
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DEVELOPMENT THAT ARE GOING ON.
WE WE THINK THAT THAT'S GOOD, BUT IT NEEDS
TO BE A LOT MORE; THAT BECAUSE IT'S SUCH A BROAD AREA, WE
THINK THAT THE AREA RECONNAISSANCE IN THIS CASE NEEDS TO BE
IMPLEMENTED VIGILANTLY TO PREVENT THE INSTALLATION OF NEW
DRINKING WATER WELLS.
THERE'S A GROWING INTEREST IN LAND DEVELOPMENT
ALONG THAT AREA. AND I HAD A CHANCE TO GO WALK THE SITES
AND DRIVE AROUND THIS AFTERNOON A BIT AND GET A FEEL FOR
THAT. AND IN THAT INTERIM PERIOD, THE THE TIME BETWEEN
THE SAMPLING EVENTS THERE'S SOME EXTENDED PERIODS OF TIME
BETWEEN SAMPLING EVENTS, THINGS HAPPEN. AND HAVING THE
FOLKS DOING THE GROUNDWATER SAMPLES LOOKING AROUND IS NOT
GOING TO BE ENOUGH TO EFFECTIVELY RECONNAISSANCE THIS AREA
FOR NEW DEVELOPMENT.
WE'RE SUGGESTING THAT YOU BEEF THAT UP. AND
YOU MENTIONED AERIAL RECONNAISSANCE WHICH YOU BROUGHT UP THE
OTHER DAY. WE THINK THAT'S A GOOD WAY TO DO IT, EITHER
THROUGH AERIAL PHOTOGRAPHY OR OTHER TYPES OF AERIAL
RECONNAISSANCE, BECAUSE IT'S SUCH A BROAD AREA.
AND ANOTHER GOOD WAY TO TAKE A LOOK AT THIS IS
HAVING SOMEONE PERIODICALLY REVIEW THE BUILDING PERMITS FOR
NEW DEVELOPMENT IN THAT WHOLE DOWNGRADIENT AREA. AND THERE
MAY BE SOME OTHER MEANS, IF SOME OTHER THOUGHT IS PUT TO
THAT.
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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BUT THE AREA RECONNAISSANCE CAN'T BE A CASUAL
THING FOR THIS ~ FOR THIS SITE, AGAIN, BECAUSE OF THE
WIDESPREAD DISPERSION OF THE CONTAMINANTS.
AND THEN ON THE OTHER END, THE CONTINGENCY
CONTROLS FOR WELL HEAD TREATMENT OR ALTERNATIVE WATER
SUPPLY. WE WOULD LIKE TO SEE, YOU KNOW, THAT ~ THAT WHOLE
CONTINGENCY MECHANISM DESIGNED TO IMMEDIATELY RESPOND WHEN
WE START SEEING ELEVATED LEVELS OF CONTAMINANTS OR DETECTS
WHERE WE HAVE NOT DETECTS BEFORE; AGAIN, BEING THE
CONSERVATIVE RESPONSE AS IT HAS BEEN PRETTY MUCH THE CASE IN
THE PAST.
AND, AGAIN, WE HAVE A LITTLE BIT OF CONCERN
ABOUT WHERE THE CONTAMINANTS ARE, BECAUSE IT'S SUCH A BROAD
AREA AND THE AQUIFERS ARE STACKED ON EACH OTHER. AND WE'VE
ONLY GOT A LIMITED NUMBER. ALTHOUGH WE HAVE LOTS OF DATA
POINTS, WE STILL ONLY HAVE A LIMITED NUMBER OF DATA POINTS
GIVEN THE THREE DIMENSIONS OF THE GROUNDWATER IN THIS AREA.
AND, AGAIN, CAREFUL IMPLEMENTATION OF THE
GROUNDWATER MONITORING SCHEME FOR THE LONG RUN IS CRITICAL;
MAKING SURE THAT ALL WELLS REGISTERED BETTER THAN CLEAN-UP
LEVELS AT THE END OF THIS WHOLE THING. SO WE WANT TO
REINFORCE THAT. THAT'S REAL IMPORTANT IN SUCH A BROAD AREA
OF DISBURSEMENT.
I APPRECIATE IT. I'LL LEAVE A COPY OF WHAT I
SAID FOR THE REPORTER.
WORDSERVXCES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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LDI8 PLORESS YEAH, WE DEFINITELY RECOGNIZE
THE IMPORTANCE OF ~ OF THE AREA RECONNAISSANCE AND THE
MONITORING IN THE AREA DOWNGRADIENT. WE ARE WE KNOW WE
HAVE TO PUT A LOT OF EFFORT IN COMING UP WITH WITH A GOOD
SYSTEM TO PERFORM THOSE TWO THINGS. AND ALL THAT WILL BE
DECIDED IN THE FUTURE AND WILL BE INCLUDED IN THE REMEDIAL
DESIGN FOR THE FOR THE SITE. BUT WE ARE I'M SORRY?
CLAUDIA MADLEY: CAN YOU BE MORE EXACT ABOUT
HOW BROAD AN AREA THIS IS, BOTH ABOVE THE RAILROAD TRACKS
AND BELOW THE RAILROAD TRACKS, IN TERMS OF ACREAGE OR SQUARE
MILES?
LDIS PLORES: I BELIEVE THAT FROM THE SOURCE
AREA TO TO THE FURTHER TO THE ~ TO THE AREA WHERE WE
HAD NO DETECTS FOR THE DOWNGRADIENT, I THINK IT'S ABOUT A
MILE. IT'S ABOUT A MILE, YEAH, LIKE FROM NORTH TO SOUTH
THIS WAY (INDICATING).
RANDY MCELVEEN: RANDY MCELVEEN FOR THE NORTH
CAROLINA SUPERFUND. I THINK I CAN DID A LITTLE QUICK
CALCULATION ON THAT. IT'S SOMEWHERE AROUND TWO HUNDRED AND
FIFTY ACRES.
LUIS PLORESJ THANK YOU, RANDY.
PHYLLIS KALK: THE WHOLE AREA?
RANDY MCELVEEN: IT'S THE WHOLE AREA.
BILL OSTEEN: I DISAGREE. I GOT TWO FORTY-
NINE.
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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1 RANDY HCELVEEN: TWO FORTY-NINE, OKAY.
2 LOIS FLORES: I HAVE LESS THAN ONE ACRE AT MY
3 HOUSE. THAT'S ALL.
4 FORREST LOCKEY: FORREST LOCKEY. I'M THE
5 LANDOWNER ON 211. I'M JUST WONDERING WHAT LIMITATIONS THERE
6 WILL BE ON DEVELOPING THE AREA. I HAVE ABOUT SIXTY ACRES OF
7 LAND AROUND 211, THE SITE SITS ON. AND I'M JUST WONDERING
8 WHAT LIMITATIONS THAT WOULD MEAN FOR ME AS A LAND DEVELOPER
9 WHEN I AM BUILDING A SMALL INDUSTRIAL PARK THERE; TO BE ABLE
10 TO DRILL WELLS, FORCE THE IRRIGATION IN THAT AREA?
11 LUIS FLORES: ARE YOU TALKING ABOUT LIKE RIGHT
12 ON TOP OF HERE OR IS IT FURTHER UPGRADIENT OR ~
13 FORREST LOCKEY: IT WILL BE AROUND THERE. I'M
14 SURE IT WILL PROBABLY BE SEVERAL YEARS DOWN THE ROAD BEFORE
15 ANYTHING IS DEVELOPED CLOSE TO THAT. BUT JUST WONDERING,
16 ONCE I DO START BUILDING BUILDINGS CLOSE BY, WILL THERE BE A
17 PROBLEM FOR, SAY, DRILLING A WELL FOR THE USE OF IRRIGATION?
18 BECAUSE MOST OF THE BUILDINGS I WILL HAVE ON CITY WATER, BUT
19 I WILL POSSIBLY WANT TO DRILL WELLS FOR IRRIGATION PURPOSES.
20 I'M WONDERING IF THERE WOULD BE ANY LIMITATIONS TO THAT?
21 LUIS FLORES: i REALLY po NOT HAVE AN ANSWER
22 FOR YOU RIGHT NOW REGARDING THAT. I CAN ONLY MAKE AN
23 ASSUMPTION. I THINK IT WILL DEPEND A LOT ON WHERE ~ WHERE
24 ARE YOU TALKING ABOUT PUTTING A WELL? YOU SAID IT'S GOING
25 TO BE USED FOR DRINKING WATER PURPOSES?
WORDSERVICE8, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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FORREST LOCKEY: RIGHT.
LUIS FLORES: SO I DON'T I DON'T HAVE AN
ANSWER. BUT I DON'T SEE WHY IT WOULD BE A PROBLEM. MAYBE
RANDY
RANDY MCELVEEN: YEAH, RANDY MCELVEEN, NORTH
CAROLINA SUPERFUND. I'LL HAVE TO CHECK ON THIS FOR YOU,
FORREST, BUT OBVIOUSLY WE WOULD ENCOURAGE PEOPLE TO USE GOOD
JUDGMENT ANY TIME THEY'RE DOING SOMETHING OUT THERE WITH THE
GROUNDWATER. AND, YOU KNOW, NOTHING TO ~ THERE'S OBVIOUSLY
NO LAW THAT WOULD KEEP YOU FROM USING THAT WATER
FORREST LOCKEYt ALL RIGHT.
RANDY MCELVEEN: IF YOU WANTED TO DO THAT;
I DON'T THINK I'LL DOUBLE CHECK ON THAT. AND ~ BUT WHAT
WE WOULD ENCOURAGE PROBABLY IS THAT YOU HAVE THE WATER
TESTED, YOU KNOW. AND PROBABLY THE GROUNDWATER PEOPLE, THEY
WOULD BE WILLING TO DO THAT. I THINK THEY'VE DONE IT AS
FAR AS YOUR WELL THERE, AND FOR WHATEVER WHEREVER YOU PUT
THE WELL.
AND IF IT EXCEEDS ANY STANDARDS THEN
HOPEFULLY, IT WOULD NOT. AS LONG AS IT DOESN'T EXCEED
STANDARDS, THERE'S NO REASON WHY YOU COULDN'T USE IT. BUT,
YOU KNOW, IT WOULD HAVE TO PROBABLY AT THAT POINT NEED THE
WE WOULD PROBABLY ENCOURAGE THAT IT NEED TO MEET SURFACE
WATER STANDARDS NOW BECAUSE IF YOU PUMP IT OUT AND USE IT IN
A SURFACE WATER BODY OR IF YOU'RE JUST USING IT IN SOME
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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OTHER MANNER, IT WON'T BE ~ THERE WON'T BE ANY EXPOSURE.
IT WOULD PROBABLY BE FINE.
CHUCK MI KALI AN: CHUCK MIKALIAN, E.P.A. I
JUST WANT TO POINT OUT, THE ONLY OTHER POSSIBLE PROBLEM THAT
YOU MIGHT HAVE WITH DEVELOPMENT IS IF YOU CHOSE TO BUILD
RIGHT THERE, ANYTHING WOULD INTERFERE WITH THE OPERATION OR
EFFICIENCY OF THE SYSTEM, WE'D LOOK CLOSELY AT. I WANT TO
MAKE SURE WE'RE CLEAR ON THAT.
FORREST LOCKE Y: OKAY.
LUIS FLORES: ANY OTHER QUESTIONS?
RANDY MCELVEEN: I'LL JUST MAKE A STATEMENT.
RANDY MCELVEEN, DEPARTMENT OF ENVIRONMENTAL AND NATURAL
RESOURCES, SUPERFUND SECTION.
THE STATE OF NORTH CAROLINA HAS WORKED CLOSELY
WITH THE E.P.A. AND THE COMPANIES ON THESE SITES AND WE
AGREE WITH THESE REMEDIES. WE'VE LOOKED CLOSELY AT THEM AND
CAREFULLY.
WE ~ BILL OSTEEN, GROUNDWATER MODELER, HAS
LOOKED AT THESE THINGS, THE MODELS, AND ACTUALLY GONE TO THE
CONTRACTORS' OFFICES AND LOOKED AT AND EVALUATED THESE
MODELS VERY CLOSELY TO MAKE SURE THAT IT'S GIVING US, YOU
KNOW, GOOD DATA. AND WE LOOKED AT THE COMPLEX AQUIFERS, AND
WE FEEL CONFIDENT THAT THIS IS THE BEST REMEDY THAT WE COULD
DO OUT THERE. IT REALLY DOES MAKE SENSE.
AND THERE IS ALSO A LOT OF -- THESE COMPANIES
WORD8ERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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HAVE DONE A LOT OF PUBLIC CONTACT THAT HAVE BEEN VERY GOOD
FOR THIS PROGRAM. PEOPLE ARE VERY WELL AWARE OF THE
SITUATION OUT THERE AND THERE IS NO ONE, AS LUIS HAS SAID,
THAT'S DRINKING THE WATER AT THIS TIME, AND WE'RE GOING TO
DO OUR BEST TO MAKE SURE NOBODY DOES DRINK IT.
AND THERE EVERYONE OUT THERE THAT HAS A
WELL, EVERY RESIDENT OUT THERE HAS BEEN CONTACTED AND THEIR
WELLS HAVE BEEN TESTED AND THEY'VE BEEN BEEN GIVEN A
LETTER THAT TELLS THEM EXACTLY ANY CONCENTRATIONS IF THERE
ARE CONTAMINANTS FROM THE SITE THAT ARE IN THEIR WELL.
SO THAT'S THE STATE'S POSITION. AND I'LL BE
GLAD TO ASK SOME ANSWER ANY QUESTIONS THAT YOU HAVE FOR
US.
. (NO RESPONSE.)
LUIS PLORES: WELL, IF THERE IS NO MORE"
QUESTIONS, THANKS A LOT FOR COMING. WE'LL KEEP YOU POSTED.
02/17/99:SRG
WORDSERVICES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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29
C 6 R TIFICATE
STATE OF NORTH CAROLINA
COUNTY OF CHATHAM
I, WANDA B. LINDLEY, CVR-CM, A NOTARY PUBLIC FOR
THE STATE OF NORTH CAROLINA, DO HEREBY CERTIFY THAT THE
FOREGOING PUBLIC MEETING WAS TAKEN AND REDUCED TO
TYPEWRITING UNDER MY DIRECT SUPERVISION; THAT THE FOREGOING
28 PAGES CONSTITUTE A TRUE AND ACCURATE RECORD OF THE
PROCEEDINGS TO THE BEST OF MY KNOWLEDGE AND BELIEF.
IN WITNESS WHEREOF, I HAVE HEREUNTO SET MY
HAND AND OFFICIAL SEAL ON THIS, THE 9TH DAY OF MARCH, 1999.
WANDA B. LINDLEY, CVR/CM
04-30-2002
ซ ป
WORDSERV1CES, INC.
Post Office Box 751
Siler City, North Carolina 27344
(800) 266-3248
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APPENDIX B
STATE CONCURRENCE
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.JAMESB. HUNTJ
.--GOVMNOfl
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A
NORTH CAROLINA DEPARTMENT OP
ENVIRONMENT AND NATURAL RESOURCES
May 25, 1999 DIVISION OF WASTE MANAGEMENT
Mr. Luis Flores
Remedial Project Manager
US EPA Region IV
61 Forsyth Street, Eleventh Floor
Atlanta, Georgia 30303
RE: State Concurrence with the Draft Record of Decision (ROD)
Aberdeen Pesticide Dumps Site Operable Unit #5, Groundwater
Located in Aberdeen, Moore County, NC
NCD 980 843 346
Dear Mr. Flores:
The State of North Carolina has reviewed the Draft Record of Decision
(ROD) for the groundwater remedy at the Route 211 and Mclver Dump Areas of the
Aberdeen Pesticide Dumps Site, OU#5, dated May 1999 and concurs with the
selected remedy, subject to the following conditions.
1. Remediation of Operable Unit #5 (ground water) will be accomplished
primarily by long-term natural attenuation and ground water monitoring.
Computer modeling of contaminant degradation in the ground water
shows that these natural attenuation processes may have to operate for up
to 90 years before the concentrations of contaminants in the ground water
attenuate to the levels that would allow its unrestricted use. Therefore, the
complete ground water remedy must include controls to prevent human
exposure to the ground water until the remediation is complete. The State
requires that the presence of ground water contamination be recorded on
the property deed of non-residential properties where groundwater will
remain contaminated above performance standards until remediation is
complete. Deed recordation should be in accordance with NCOS 130A-
310.8, Recordation of inactive hazardous substances or waste disposal
sites.
2. State concurrence with this Record of Decision (ROD) and the selected
remedy for the site is based solely on the information contained in the
subject ROD dated May 1999. Should the State receive new or additional
information which significantly affects the conclusions or remedy
selection contained in the ROD, it may modify or withdraw this
concurrence with written notice to EPA Region IV.
3. State concurrence on this Record of Decision (ROD) in no way binds the
State to concur in future decisions or commits the State to participate,
financially or otherwise, in the clean up of the site. The State reserves the
401 OBERLIN ROAD, SUITE ISO, RALEIGH, NC 276OB
PHONE 919-733-4996 FAX 919-715-3605
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER - so% RECYCLED/I o% POST-CONSUMER PAPER
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Mr. Flores
5-25-99
Page 2 of2
right to review, overview, comment, and make independent assessment of
all future work relating to this site.
4. If, after remediation is complete, the total residual risk level exceeds 10"*,
the State may require deed recordation/restriction to document the
presence of residual contamination and possibly limit future use of the
property as specified in NCOS 130A-310.8.
The State of North Carolina appreciates the opportunity to comment on the Draft
Record of Decision for the subject site, and we look forward to working with the EPA
on the final remedy. If you have any questions or comments, please give me a call at,
(919) 733-2801, extension 291.
Sincerely,
rover Nicholson
^mediation Branch Hea
Superfund Section
cc: Phil Vorsatz, NC Remedial Section Chief
Jack Butler, Chief NC Superfund Section
Randy McElveen, NC Superfund Section
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