PB99-964017
EPA541-R99-079
1999
EPA Superfund
Record of Decision:
Battery Tech (Duracell-Lexington) OU 1
Lexington, NC
9/30/1999
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DURACELL BATTERY TECH SITE
RECORD OF DECISION
OPERABLE UNIT ONE
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 1999
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TABLE OF CONTENTS
Description Page
DECLARATION FOR THE RECORD OF DECISION ii
DECISION SUMMARY 1
1.0 SITE NAME AND LOCATION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES . .. 1
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
5.2 Geology and Soils 6
5.3 Hydrogeology 7
6.0 NATURE AND EXTENT OF CONTAMINATION REVIEW 8
6.1 Soil Sample Results 9
6.2 Surface Water and Sediment Sample Results 27
6.3 Summary of Ecological Assessment .. 36
6.4 Fate and Transport of COCs .37
6.5 Development of Soil Remediation Levels 39
6.6 Current and Future Site and Resource Use 41
7.0 SUMMARY OF SITE RISKS 43
7.1 Summary of Human Health Risk Assessment 43
7.1.1 Identification of Chemicals of Concern 44
7.1.2 Exposure Assessment 44
7.1.3 Toxicity Assessment 47
7.1.4 Risk Characterization 48
7.2 Summary of Ecological Risk Assessment 48
7.3 Current and Potential Future Site and Resource Use 55
8.0 REMEDIAL ACTION OBJECTIVES 56
9.0 DESCRIPTION OF REMEDIAL ALTERNATIVES 58
9.1 Alternative 1 58
9.2 Alternative 2 58
9.3 Alternative 3 59
9.4 Alternative 5 59
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TABLE OF CONTENTS
Description Page
10.0 CRITERIA FOR EVALUATING REMEDIAL ALTERNATIVES 60
10.1 Overall Protection of Human Health and the Environment 60
10.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) 60
10.3 Long-Term Effectiveness and Permanence 61
10.4 Reduction of Contaminant Toxicity, Mobility, and Volume 61
10.5 Short-Term Effectiveness .61
10.6 Implementability .... 61
10.7 Cost ,,,[ [[[[[......... 61
10.8 State Acceptance 61
10.9 Community Acceptance 61
11.0 COMPARISON OF THE ALTERNATIVES 61
12.0 THE SELECTED REMEDY 72
13.0 STATUTORY DETERMINATIONS 80
APPENDDC A-RESPONSIVENESS SUMMARY 82
APPENDDC B - STATE CONCURRENCE LETTER 84
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TABLE OF CONTENTS
Description
Page
LIST OF FIGURES
FIGURE DESCRIPTION
1 Site Diagram with Areas of Concern 3
2 Sample Locations in southern Site area 13
3 Sample Locations in northern Site area 16
4 Sample Locations in Former Solvent Disposal area . 19
5 Surface water and Sediment Sample Locations in Nearby Tributaries 29
6 Surface water and Sediment Sample Locations in Abbotts Creek
and High Rock Lake 30
7 Mercury Concentrations at Sediment Sampling Locations 33
8 Mercury Concentrations at Abbotts Creek and Pounder Creek
Sediment Sampling Locations 34
9 Modeled Source Areas for Soil Remediation 42
10 Conceptual Model for the Site 46
LIST OF TABLES
TABLE DESCRIPTION
1 Summary of Remedial Investigation Samples 10
2 Summary of Inorganic Constituents in southern Site area 12
3 Summary of Inorganic Constituents in northern Site area 14
4 Summary of Inorganic Constituents in Former Plant #2 area . 17
5 Summary of Inorganic Constituents in Former Solvent Disposal area 18
6 Summary of Organic Compounds in Former Solvent Disposal area 20
7 Summary of Inorganic Constituents in Former Cleaning Operations area 22
8 Summary of Inorganic Constituents in Sump areas 23
9 Summary of Organic Compounds in Sump areas .. 24
10 Summary of Inorganic Constituents in Off-Site Soils Located
0 to 400 Feet From northern Site area 25
11 Summary of Inorganic Constituents in Off-Site Soils Located 400 to 800 Feet
from northern Site area 26
12 Summary of Inorganic Constituents in Off-Site Soils Located 800 to V* mile
from northern Site area .. 27
13 Summary of Inorganic Constituents in Off-Site Soils Located
from northern Site area 27
14 Summary of Inorganic Constituents in Surface water Samples 28
1.5 Summary of Inorganic Constituents in Sediment Samples 35
16 Summary of Inorganic Constituents Beneath Geomembrane 36
17 Risk Summary of Chemicals of Concern 49
18 Comparative Analysis of Alternatives 63
19 Summary of Federal and State ARARs 67
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TABLE OF CONTENTS
Description Page
LIST OF TABLES (CONT.)
TABLE DESCRIPTION
20 Estimated Costs for Alternative 5 76
21 Summary of Remediation Levels for Soil and Sediment 78
22 Description of Source Areas to be Remediated 80
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Duracell Battery Tech Site
Operable Unit One (OU1)
EPA ID # -NCD 000 648 402
To Address Soil and Sediment Contamination, and Ecological Concerns
Lexington, Davidson County, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedy for Operable Unit One (OU1) to address
contaminated soil and sediment, and ecological concerns at the Duracell Battery Tech Site (the
Site) in Lexington, Davidson County, North Carolina. This remedy was chosen in accordance
with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). Selection of the remedy in this decision document is supported by the
information contained in the Administrative Record for OU1.
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 OU1 are:
• In-Situ Stabilization/Solidification of Contaminated Soil in the Former Plant #2 Area,
followed by Capping of the Former Plant #2 Area;
• In-Situ Chemical Oxidation of Contaminated Soil in the Former Solvent Disposal Area,
followed by Capping of the Former Solvent Disposal Area;
Selective Excavation and Off-Site Disposal of Contaminated Soil in the Building #4 Area
and the Northern Site Area, and contaminated soils and sediments located outside the
facility fence line;
• Capping of other areas located within the facility fence line for ecological concerns; and
• Long-term monitoring of site-related contamination in soil, sediments, and ecological
receptors;
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
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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 an indefinite 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 information listed below 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 ranges of concentrations
•*• Baseline risks represented by the COCs
* Cleanup levels established for COCs and the basis for the levels
* 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
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Duracell Battery Tech OUI
DECISION SUMMARY
The Duracell Battery Tech facility encompasses approximately 26.5 acres in a light
industrial/commercial area of Lexington. The subject of this Record of Decision (ROD) is
Operable Unit One (OUI); which is EPA's designation to address contaminated soil, sediment, and
ecological concerns associated with past operations at the Site.
1.0 SITE NAME AND LOCATION
Duracell Battery Tech Site
EPA ID Number - NCD 000 648 402
Operable Unit One (OUI)
Lexington, Davidson County, North Carolina
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Duracell site is located at 305 New Highway 64 East in Lexington, Davidson County, North
Carolina. The 26.5-acre Site is an active facility that began operating in the 1950's. Previous
owners/operators of the Site, including P.R. Mallory and Duracell, manufactured mercuric oxide
batteries, as well as dry cells for commercial and industrial use. Over the years, several plant
operations have been added to the Site to expand production.
Over the years various types of batteries have been produced at the Site; the following substances
were used in the battery production:
* mercuric oxide powder
* cadmium oxide powder
* silver oxide powder
* manganese dioxide oxide powder
* manganese dioxide
* graphite
* zinc
if elemental mercury
* potassium hydroxide
* lithium metal
* ethylene glycol dimethylether
The Duracell facility currently consists of three main buildings; Plant #1, Plant #3, and Building #4.
Plant #1 is the battery cell assembly operation where chemicals are mixed and placed into
containers to make batteries. Plant #2 was the building where mercuric oxide was formulated from
1977 to 1986. Mercury reclamation operations also took place on the east side of Plant #2 from
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Duracell Banety Tech OU1
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1977 to 1986. A small wastewater treatment system consisting of two concrete-lined sumps was
also in operation at Plant#2 prior to installation of the Memtek treatment system at Building #4.
Plant #2 was demolished and removed from the Site in 1995. Plant #3 was purchased in 1976 and
is utilized for testing, packaging, and shipping and receiving. Building #4 was built in 1981 to
house the mercury reclamation furnace; this building is now used to store hazardous waste and
house the wastewater Memtek pretreatment system. Figure 1 shows the Site and the on-site areas
of concern.
Site Operations over the years resulted in extensive mercury contamination in the soil and
groundwater at the Site. One source of mercury contamination in the soil involved the past
operations in the area of Plant#2. Another source of mercury contamination involved spillage
while transporting the mercuric oxide from Plant #2 to Plant #1. Leaching of the mercury from the
soil to the groundwater resulted in mercury groundwater contamination. Mercury is present in the
on-site groundwater at levels significantly higher than both State and Federal drinking water
standards.
Runoff from the Site over the years has also resulted in elevated levels of mercury in the sediment
of the surface water pathways draining the Site, including the unnamed tributary of Fritz Branch,
Leonards Creek, and Abbotts Creek southward to High Rock Lake. A 1981 fish tissue study
conducted in Abbotts Creek and High Rock Lake revealed levels of mercury in excess of one part-
per-million. Since these levels of mercury in fish are considered unsafe for human consumption, a
fish advisory was placed on portions of Abbotts Creek and High Rock lake in June 1981. In 1992,
the measured levels of mercury in the fish decreased below the one-per-million level, and the fish
advisory was lifted. Since that time, mercury concentrations in fish have continued to decline and
NCDENR has determined that Abbotts Creek is now fully supporting its designated uses.
Volatile organic compounds such as acetone, methylene chloride, trichloroethene,
tetrachloroethene, 1,1,1-trichloroethane, and 1,1,2-trichloroethane were used over the years as
solvents to clean tools, dyes, presses, watch battery cells, etc. The solvents were routinely
disposed of in an unlined pit located between Building #4 and Plant #1 from the early 1960s until
the early 1970s. As a result, the soil in the area of the former disposal pit contains volatile organic
compounds. On-site groundwater became contaminated as the volatile organic compounds
migrated from the soil in the disposal pit downward into groundwater. Volatile organic compound
contamination exists in the on-site groundwater at levels in excess of State and Federal drinking
water standards.
4»
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FENCE UNE
DUUCO1 PRDPERTT UNE
MXMCEMT PROPERTY UNE
700|
Environmental
Resources
pnw Maitugomcnt.
ON-SITE POTENTIAL AREAS OF CONCERN
DURACELL U.S.A.
LEXINGTON. NORTH CAROLINA
1
.15
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Duraoell Banery Tech OU1
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The Site is not currently on the National Priorities List (NPL). However, an Administrative Order
of Consent was signed between EPA and Duracell in 1995 to perform the RI/FS. Duracell agreed
to conduct the RI/FS, and will incur all appropriate costs associated with the RI/FS as outlined in
the Administrative Order. Although the Duracell Battery Tech Site is not on the NPL, the NPL-
equivalent site is being addressed in a manner consistent with the National Contingency Plan
(NCP).
3.0 COMMUNITY PARTICIPATION HIGHLIGHTS
Pursuant to CERCLA §113(k)(2)(B)(i-v) and §117, the RI/FS Report and the Proposed Plan for
OU1 were made available to the public in July 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 Davidson County Public Library, 602 South Main Street, Lexington, North
Carolina. In addition, the Proposed Plan fact sheet was mailed to individuals on the Site's mailing
list on July 22, 1999.
The notice of the availability of these documents and notification of the Proposed Plan Public
Meeting was announced in The Dispatch in July 1999. A 30-day public comment period was held
fromJuly23, 1999 through August 23,1999. In addition, a public meeting was held on July 29,
1999, at the Agricultural Center in Lexington. At this meeting, representatives from EPA
answered questions about the Site and the remedial alternatives for the action under consideration.
EPA's responses to comments received during the 30-day 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
Due to its complexity, the Site has been organized into two Operable Units. The objective of
Operable Unit One is to address site-related soil and sediment contamination, and to implement a
monitoring program for ecological receptors. Operable Unit Two will address site-related
groundwater contamination. It is anticipated that the Operable Unit Two Remedial Investigation
activities will be completed in Fall 1999. A separate Operable Unit Two RI Report, Baseline Risk
Assessment, and Feasibility Study will be developed to evaluate the risk associated with the
groundwater contamination, and to evaluate alternatives for addressing the groundwater
contamination. The Operable Unit Two Remedy will be selected during calendar year 2000 to
address the site-related groundwater contamination.
The primary objective of conducting the Operable Unit One Remedial Investigation was to
determine the nature and extent of site-related soil and sediment contamination, and to conduct an
ecological assessment to evaluate the potential impacts to ecological receptors. This information
was used to support the development of the Operable Unit One Baseline Risk Assessment (BRA)
and the Feasibility Study (FS).
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Duracell Battery Tech OU1
5.0 SUMMARY OF SITE CHARACTERISTICS
The Duracell Battery Tech site encompasses approximately 26.5 acres in an area characterized as
light industriaVcornmercial. The subject of this ROD is OU1, EPA's designation for addressing
soil and sediment contamination, as well as ecological concerns. Therefore, Site characteristics for
the soil, sediment, and ecological concerns will be discussed in this section. Groundwater concerns
will be addressed with Operable Unit Two (OU2).
5.1 Topography and Surface Drainage
This section presents information concerning the physical characteristics of the study area,
including regional and site-specific surface features, surface water, geology, soils, hydrogeology,
climate, land use, and ecology. This information was drawn from observations and data collected
during the Phase 1, Phase 2, and Phase 3 field investigations for OU1, as well as from previous
studies, state and federal databases, and published sources.
The Site is located in central Davidson County, North Carolina. Davidson County is situated in the
west-central part of North Carolina. Lexington is the Davidson County seat. The county is
bounded on the north by Forsyth County, on the east by Guilford and Randolph Counties, on the
south by Montgomery County, and on the west by Rowan and Davie Counties. Davidson County
is separated from the last-named counties by the Yadkin River. The County encompasses an
approximate 567-square mile area.
Davidson County is a plateau, dissected by numerous streams, which have cut deep, narrow
valleys. The surface of the county is rolling to steeply rolling, and the lowlands along the streams
constitute the only level areas. Some of the interstream areas are gently rolling or undulating. In
the southern half of the county, the topography becomes semi-mountainous in the vicinity of Cid,
Denton, Jackson Hill, Bain, Newsom, and High Rock. Among the more prominent of the semi-
mountainous areas Flat Swamp, Three Hat, Rich, Wild Cat, Grist, and Bald Mountains. The
higher elevations occur in the northern end of the county and the lower in the southwestern part,
along the Yadkin River below High Rock Lake.
The Site is located in the Abbotts Creek drainage basin of eastern Lexington. The topography is
rolling in the eastern portion near the Site. The ground surface at the Site exhibits a slope towards
Fritz Branch, with elevations varying from 760 feet mean sea level (MSL) at the Site to 640 feet
MSL at Fritz Branch. Davidson County falls within the Yadkin-Pee Dee River basin. Numerous
small tributaries drain central North Carolina and discharge to the Yadkin River. The Abbotts
Creek watershed encompasses approximately one-third of Davidson County and empties into the
Yadkin River at High Rock Lake. The Yadkin River at High Rock lake, under the North Carolina
Administration Code (NCAC) Section 15A.2B.0309, is classified as Class WS-IV waters. Class
WS-IV waters are protected as water supplies, which are generally in moderately to highly,
developed watersheds. In addition, these waters must be suitable for all Class C uses. Class C
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Duracell Battery Tech OUI
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fireshwaters are protected for secondary recreation, fishing and aquatic life propagation and
survival.
Storm water runoff from the northern portion of the Site drains generally to the north/northeast
into three unnamed tributaries. One tributary drains into Fritz Branch. Fritz Branch is a small
perennial flow stream which flows from west to east and terminates in Leonards Creek
approximately 2,000 feet upstream of Abbotts Creek. The second tributary, also drains to
Leonards Creek about 500 feet upstream of Abbotts Creek and is an intermittent stream which can
go dry during extended periods of low rainfall. The third northern tributary drains eastward from
Plant #3 to Leonards Creek near the confluence with Abbotts Creek. Runoff from the southern
portion of Site drains to the south/southwest to an unnamed tributary of Abbotts Creek. Abbotts
Creek drains into High Rock Lake approximately 8.5 miles downstream from the Site. Both
Leonards Creek and Abbotts Creek are classified as Class C waters.
The headwaters of Leonards Creek originate several miles due north of the Duracell facility.
Approximately two miles north of the facility, Leonards Creek travels through City lake, a 30-acre
lake. The land use in the Leonards Creek watershed is primarily rural including forested areas,
pastureland and crop land. Fritz Branch, which enters from the west, drains a more urban area on
the northeast side of Lexington. The substrate in Leonards Creek is very sandy and vegetation
cover is primarily deciduous hardwoods, however, shrubs and herbaceous growth is abundant also.
Numerous snags and dead fall are found near Abbotts Creek. Because of the beaver activity,
numerous long pools are found in the channel. Upstream of the beaver activity the creek has small
pools and riffles and exposed sand bars.
Abbotts Creek originates northeast of the Duracell facility in a watershed parallels to Leonards
Creek. Rich Fork and Hamby Creek make confluence with Abbotts Creek approximately 1.5 miles
northeast of the Site resulting in a third order stream. The Abbotts Creek drainage is highly
forested and includes some areas of agriculture - primarily pastureland. Wetlands are also common
in the watershed and as a result Abbotts Creek is dark in color with tannins during most of the year
as the pH is generally below 6.0. The substrate in Abbotts Creek is very sandy upstream of
Leonards Creek, then becomes more rocky downstream as gradient increases. From its confluence
with Leonards Creek, Abbotts Creek flows about eight miles to the impounded waters of Abbotts
Creek Arm of High Rock Lake. The impounded waters of High Rock Lake begin to affect
Abbotts Creek about 2.5 to 3.0 miles downstream of Leonards Creek where it becomes slow and
deep and can be navigated by boat. The City of Lexington discharges to Abbotts Creek
downstream of Leonards Creek.
5.2 Geology and Soils
The soil survey of Davidson County, North Carolina (USDA, 1994) reports that the soil in the
county is generally weathered felsic, intermediate, and mafic crystalline rocks or from fine-grained
metamorphic rocks. The crystalline rocks are primarily in the northern and northwestern parts of
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Duracell Battery Tech OU1
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the county. The fine-grained metamorphic rocks are in the southern and southeastern parts of the
county. The felsic rocks are mostly granite, gneiss, or schist. Soils that are formed in material
weathered from this type of rock are acidic. The mafic rocks are mostly gabbro. Soils that formed
in material weathered from this type of rock are slightly acidic to mildly alkaline. Large areas of
the county are underlain by intermediate rocks, such as diorite, or have a mixture of felsic and
mafic rocks. The fine-grained metamorphic rocks are slate-like rocks that are dominantly argillite.
Soils formed in material weathered from these rocks are acidic. Soil textures vary depending on
the mineralogy or the parent material (e.g. the schists produce micaceous silts while gneiss or
intrusives produce silty or sandy clays).
The soils beneath the Site generally consists of weathered bedrock or saprolite, which is composed
of predominantly silty clays to clayey silts. Based on prior investigative efforts, two distinct soil
types were noted to be present in the shallow subsurface beneath the Site. The uppermost soil
zone encountered at the Site is a medium consistency, multicolored (red, orange, yellow, brown,
gray, and green) silty clay. The silty fraction in this zone ranged from approximately 30% near the
base. Some medium- to fine-grained sand was present in this zone. This uppermost zone was
found to extend from the ground surface to a depth of approximately five to ten feet below ground
level (BGL).
Davidson County is in the center of the Piedmont physiographic province. Davidson County is on
the boundary between two major geologic belts, the Charlotte Belt to the north and the Carolina
Slate Belt to the south. The Charlotte Belt is characterized by both felsic and mafic igneous rocks.
The felsic rocks are primarily granite, and the mafic rocks are primarily gabbro. The Carolina Slate
Belt includes various types of volcanic and sedimentary rocks, such as mudstones, and mixtures, of
volcanic debris. The felsic volcanic rocks are very resistant to weathering and underlie the more
prominent topographic features. The sedimentary rocks consist of such rocks as mudstones and
siltstones that have been physically and chemically altered by metamorphism to a more indurated
slate. Much of the sedimentary rock is intermediate in hardness and is classified as argillite.
The fractured bedrock at the Site consists primarily of the felsic intrusive complex on the west of
the facility and intermediate intrusive rocks on the east side of the facility. Alluvium is found to the
north of the facility along the unnamed tributaries, and consists of dark brown, gray to white
unconsolidated sand, silt, and clay, occasionally containing subrounded to well-rounded pebbles
and cobbles.
5.3 Hydrogeology
Groundwater in the general vicinity of the Site exists within two zones. The first or uppermost,
water-bearing zone is within the silty clay residual saprolite soils overlying felsic igneous bedrock.
The second, or lower, water-bearing zone is within the underlying igneous bedrock where the
occurrence such as fractures, joints, and foliations. Due to gradational changes from weathered
saprolite to competent bedrock, ground water in the uppermost water-bearing zone is expected to
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Duracell Battery Tech OU1
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show preferential movement along relic structures. Ground water in the saprolite is usually found
under unconfined conditions or semi-confined conditions with ground water flow generally
conforming to surface topography. Depth to bedrock has been found to range from about 12 feet
to much as approximately 50 feet below land surface. Depth to ground water in this upper-bearing
zone typically ranges from 10 to 25 feet below land surface depending on the location at the Site
and the time of year. Due to the low permeability of the fine-grained materials comprising the
uppermost water-bearing zone, ground water yields to wells tapping this zone are very small and
typically not sufficient for water supply purposes.
Ground water in the lower water-bearing zone in bedrock is typically under semi-confined or
confined conditions with flow direction being controlled by the presence and orientation of
secondary openings. Depth to ground water in the bedrock zone varies considerably due to the
random distribution of secondary openings. Overall ground water movement will be from areas of
higher hydraulic head (higher elevations) towards areas of lower hydraulic head (lower elevations
or stream valleys). Ground water yields from the bedrock are typically higher than the upper zone
above bedrock with yields high enough to sustain private water supplies. Private wells tapping the
bedrock aquifer are present in the general vicinity of the Site; however, private supply wells were
not found which tap the shallower saprolite zone.
6.0 NATURE AND EXTENT OF CONTAMINATION OVERVIEW
This section provides a summary of findings associated with the investigative activities conducted
as part of this RI. The initial phase of the Remedial Investigation fieldwork was initiated in
January 1996 and was completed in November 1996. Two additional phases of fieldwork were
conducted from March 1997-January 1998, and from February-March 1998. The various
environmental media sampled as part of the Operable Unit 1 RI included: 1) background soils, 2)
soils within the facility fence line, 2) soils outside the facility fence line, 3) sump residuals, 4)
surface water, 5) sediment, and 6) ecological receptors. The various environmental media samples
were analyzed for a wide range of analytical parameters including:
•A: six site-specific inorganic compounds including cadmium, chromium, manganese, mercury,
silver, and zinc;
* target analyte list (TAL) inorganic compounds;
* target compound list (TCL) organic compounds which included volatile organic
compounds, semi-volatile organic compounds, and pesticides/poly-chlorinated biphenyls
(PCBs);and
if Chlorinated dioxins and furans (soils only).
A summary of the number of samples collected from the various environmental media as part of
the Operable Unit 1 RI sampling activities and the number of associated duplicate samples for each
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Duracell Baltey Tech GUI
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media are presented in Table 1. To establish background concentrations of various inorganic and
organic constituents, background samples of each sampling media were collected at locations
distant from the Site so as to not be impacted by releases from the facility, yet near enough to the
Site to be representative of local conditions
6.1 Soil Sample Results
Background soils were collected from 23 separate locations in the vicinity of the Site. At 17 of the
locations, soil samples were collected from the surface only, whereas at six of the sampling
locations samples were collected from the surface and at depth (7-8 feet below ground surface).
The deeper soils were considered to be more representative of naturally occurring background
conditions since they would not be subject to backfilling, leaching due to rainfall infiltration,
runoff, or deposition of other naturally occurring and anthropogenic material from remote areas.
Certain inorganic constituents exhibit a fairly wide range of background concentrations. The wide
range in the reported concentrations of many of these inorganics is due to the natural distribution
of these compounds in the environment, which is related to the lithologies of the varied geologic
source materials of the soils.
A total of 861 surface and subsurface soil samples were collected during the Remedial
Investigation to determine the presence and extent of inorganic and organic constituents of
concern in soils both inside and outside the facility fence line. More limited analyses of other
compounds, including TAL inorganics, TCL VOCs, TCL SVOCs, and TCL pesticides/PCBs, were
performed to assess the potential that other constituents might be present at concentrations of
concern (see RI report for locations).
For purposes of this RI report, the soil sampling activities inside the facility fence line have been
segregated according to current or former uses of specific areas. These areas include: 1) southern
Site Area; 2) Northern Site area; 3) Former Plant #2 Area; 4) Former Solvent Disposal Area;
5) Former Cleaning Operations Area; 6) Former underground storage tank (UST) Areas; and 7)
Sump Areas. Refer again to Figure 1.
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DuraceU Battery Tech OU1
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4ft
TABLE 1
NUMBER OF SAMPLES COLLECTED FROM VARIOUS MEDIA AND ASSOCIATED ANALYTICAL
PARAMETERS
Duracell U.S.A.
Lexington, North Carolina
Media
Soon
(Field)
(Background)
^i^3S*dfifceia» <$*e;|;y
(field)
(Background)
!*.% Sttzfac«u>Valer Ji
(Field)
Constituents
*.-. - . ST £••••• • 'I.;: .-*-. K •x.s, *r .. .'.
SfLP Site-Specific Inorganics!
SPLPTCLVoUtQes
SFLP TCL SemiVblatiles
TCLPVolaHles
TCLPSeraEVoIables
Site-Specific Inorganics (ex. Hg)
HK
TAL Inorganics
TCL Volatile*
TCLSemivolataes
Pesticides «nd PCB's
Chlorinated Dioxins and Fuians
Site-Specific Inorganics
T AL Inorganics
TCL Volatile*
TCL Semivolatiles
PejticidesandFCB1*
K^KS^SS?^s®^t!i*4fe*^!^,.!^'.':^.^.' '.:•> '.-
Site-Specific Inorganics (ex. Hg)
Hg
TAL Inorganic*
TCLVoUtfles
TCL SemivoUtile*
PMUddes and PCB's
TALInorganici and Site-Specific Inorganic*
TAL Inorganics
TCLVoUUle*
TCL Semivolatiles
PesUcida and FCB'i
^ii's-.tiu:'.^^* K-K-"'* ' '*.••»> 'i$a:&ii> »?'->* ^S- ?s.!^
Sita-Specific Inorgania (ex. Hg)
Hg
TAL Inorganic*
TCL Volatile*
TCL Semi volatile*
Pesticide* and PCB's
Dissolved Hg
Number
of
Samples
35
W
2
35
8
2
738
963
55
327
90
77
7
29
24
24
24
23
£ ? .*":•• S&;.
114
116
10
10
17
9
9
2
2
2
2
'*< «-%.v
62
64
9
11
9
9
3
Number of
Duplicate!
1
1
0
4
1
71
84
26
4
3
0
3
2
2
2
2
ww;*-:S&?jfe
9
10
1
2
3
1
1
0
1
1
1
-"»•: S«' *: ^
6
7
2
3
2
2
1
Number of
Triplicate!
«' . • •' *
3
1
1
3
1
1
3
3
0
2
1
0
0
0
0
0
0
0
£te?:g5,%^%. fv 4-<
0
0
0
0
0
0
0
0
0
0
0
r**r."$ffc -..-, ,,. .5.
0
0
0
0
0
a
a
4»
-------
ROD
Duracell Battery Tech OU1
Page 11
TABLE 1
NUMBER OF SAMPLES COLLECTED FROM VARIOUS MEDIA AND ASSOCIATED ANALYTICAL
PARAMETERS
Lexington, North Carolina
Media
Surface Water (cont'd.)
(Background)
.S-jS:" :' : St onnwater
i^^SiuapJLiiQeudir^--*;.
*a:.Sttmp;Sedimcnl»^;.;::
~S;%lifEepIoJislcal;8^iti
(BioHc)
Amphibian
Carbicula
Fish
Small Mamip»l
Phase I Earthworms
Terrestrial Plants
Phase n Earthworms
(Sediment*)2
Amphibian
Corbicula
(Soils)1
Small Mammal
Phase I Earthworms
Constituents
. ,--;f.---v**.:-' : .:•••; ••'. - . -, , .: ; y.. **.•>•-•.:?• £.•>-• ? .-..->.. >>-^.r-Yf;;-'.. ;
ite-Spedfic Inorganics
' AL Inorganics
TCLVolatiles
"CL Semivolatiles
Pesticides and PCB's
t~ ^."S-, -• > ! jj % -
Site-Specific Inorganics
"AL Inorganics
TCLVolatiles
TCL Semivolatiles
Pesticides and PCBs
^^;^^gii^ySi:s«.B^SlfeKl^5Si^P^3;i
Site-Specific Inorganics
"ALInorRanics
rCLVolatiles
[CL Semivolatiles
'esticidei and PCBs
Site-Specific Inorganics
PAL Inorganics
TCLVolatiles
rCL Semivolatiles
Pesticides and PCBs
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
Site-Specific Inorganics
(lumber
of
> ample*
,;:• •;«;>,<: ;;:;:
6
4
4
4
4
4
4
4
4
4
:8¥:;s*
l
l
1
1
1
s:;s;;o^!
4
4
4
j
^
.;-:::---W\;<;'<'
>• f1:^ •:'••'•:.••*:
14
24
178
69
8
j
2
13
15
25
lumber of
duplicates
::v.:v :;?-:'^c?::r:
0
0
0
0
0
1
1
1
1
1
.;'*i'^":^-rSS5X
0
0
0
0
0
S5"r:;^SSTijv'£S:
1
1
1
1
1
f^!x^':;&:$
0
•
t
o
1
0
0
Number of
Triplicates
;:.-'-:;r",Vi-:- .'• •; •
0
0
0
0
0
0
0
0
0
0
..s?:V«!^':.i^:-v;.f '. ':rrr
0
0
0
0
0
ISl^^i!::-;';
0
0
0
0
0
-SHS.pl^S;^;^;
0
0
0
0
0
0
1 Site-Specific Inorganics - include Cadmium, Chromium, Manganese, Mercury, Silver, and Zinc
1 Ecological sediments/soils are also included in the previously listed soils and sediments.
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Duracell Battery Tech OU1
Page 12
The southern Site area includes the area of the Site extending southward from the approximate
southern extent of the Former Solvent Disposal Area to the southern property boundary. Both
Plant #1 and Plant #3 are located in this area. This area also includes the Former Cleaning
Operations Area located immediately north of Plant #1, the sumps located on the west side of
Plant #1, and the two former UST areas. However, since these four areas were believed to be
potential sources of constituents of concern, they are discussed separately from the southern Site
area.
Soils samples from the southern Site area were analyzed for the full range of inorganic and
organic constituents. A total of 112 soil samples were analyzed for the six site-specific
inorganics. Ten soil samples also were analyzed for the remaining TAL inorganic constituents.
Figure 2 shows the soil sample locations in the southern Site area. The concentration ranges and
locations of the maximum detected concentrations, are presented in Table 2.
Table 2 - Summary of Inorganic Constituents In southern Site Area
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
BDLtoZO
0.81 to 343
69 to 14,000
BDL to 6.8
BDL
3.9 to 255
Location of
Maximum
Concentration
DUR-SB-130-1
DUR-SB- 132-6
DUR-SB-131-1
DUR-SB-127-1
Not Applicable
DUR-SB-127-21
The highest manganese value, 14,000 ppm, detected in surface soil sample DUR-SB-131-1, is
located immediately west of Plant #3. This elevated level of manganese is most likely due to a very
localized release of manganese powder, since 16 additional soil samples collected from this area as
part of an investigation associated with a Plant #3 expansion had levels of manganese ranging from
236 to 1,810 ppm.
A total of 31 soil samples from the southern Site area were analyzed for TCL VOCs. Halogenated
VOCs were detected in only one soil sample (SB-127) located north of Plant #1. The reported
concentrations were each less than 10 ppb. Acetone was detected in 21 of the 31 soil samples with
a maximum concentration of 380 ppb.
-------
• PHASE I 0-12 IN. SAUPUNO GOO NODE • PHASE 1 0-30 FT. SAUPUNO GRtO NOOE
A PHASE t 0-1 . FT. SAUPUNG GOO NOOE B p^ff j fmua UST BORING
PHASE I AND 1 0-JO FT. SOIL BORING g p,^ } 500. BORING
ISO
Environmental
Resources
Management
SOIL SAMPLE LOCATIONS IN SOUTHERN PORTION OF SITE
DURACELL U.S.A.
LEXINGTON. NORTH CAROLINA
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Duracell Battery Tech OU1
Page 14
Twelve soil samples from the southern Site area were analyzed for TCL SVOCs. Both PAHs and
phthalate esters were detected in these samples. The phthalate ester, di-n-butyl phthalate
(DNBP), detected in four samples, was the only compound reported at a concentration greater
than 1,000 ppb. Ten soil samples from the southern Site area were analyzed for TCL pesticides and
PCBs. No pesticides or PCB were detected in any of the ten soil samples.
The northern Site Area includes all Site property north of Plant #1, excluding the Former
Solvent Disposal Area and the Former Plant #2 Area. The northern Site area includes
Building #4, the existing wastewater treatment system, a paved parking area, and grass-covered
areas. Since the sumps associated with Building #4 were believed to be a local source of
constituents of concern, these are discussed separately from the northern Site area.
Soil samples from the northern Site area were analyzed for the full range of inorganic and organic
constituents. RI sampling was initially conducted during the Phase IRI in 1996. As part of the
Phase n investigation, samples were collected during 1997 in order to better delineate mercury
concentrations, primarily in the vicinity of former Plant #2. Additional soil samples also were
collected to assess SVOC concentrations in the northeast quadrant of the area and VOC
concentrations at selected locations. Limited sampling for site-specific constituents was
performed in this area during the 1998 Phase III investigation.
A total of 185 soil samples for the northern Site area were analyzed for the six site-specific
inorganics. An additional 88 samples were analyzed only for mercury. Twenty-five samples also
were analyzed for the remaining TAL inorganic constituents. Figure 3 shows the soil sample
locations in the Norhera Site. The concentration ranges and locations of the maximum
concentrations, are presented in Table 3.
Table 3 - Summary of Inorganic Constituents in northern Site Area
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
BDLto2.5
BDLTO134
32.6 to 3,810
BDLto673
BDLto40
4.9 to 899
Location Of
Maximum
Concentration
DUR-SB-247-1
DUR-SB-196-3
DUR-SB-194-3
DUR-SB-247-1
DUR-SB-214-6
DUR-SB-214-6
A total of 35 soil samples from the northern Site area were analyzed for TCL VOCs.
Halogenated VOCs were detected in 11 of the 35 soil samples at concentrations below 100 ppb.
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Duracell Battery Tech OUI
Page 15
Non-halogenated VOCs were detected in 16 of the soil samples. Acetone was reported in 13 of
the 35 soil samples. Thirty-one soil samples from the northern Site area were analyzed for TCL
SVOCs. PAHs were detected in ten soil samples that primarily were located in the eastern half
of the northern property. The area in which these elevated PAH concentrations were detected
historically has received runoff from areas from which PAHs would be released (i.e. stormwater
runoff from asphalt paved areas and building roof areas).
Phthalate esters also were detected in six soil samples. The phthalate ester, DNBP, was detected
in four samples. This was the only phthalate ester reported at a concentration greater than 1,000
ppb. Two other phthalate esters were reported once each at lower concentrations.
Twenty-six soil samples were analyzed for TCL pesticides and PCBs. No PCBs were detected in
any sample from the northern Site area. Endrin was the only pesticide detected with a
concentration of 2 ppb in a single soil sample (DUR-SB-176-2Z).
Three soil samples from the northern Site area were analyzed for chlorinated dibenzo-p-dioxins
(CDDs) and chlorinated dibenzofurans (CDFs). No tetra-, penta-, and hexachlorinated CDDs or
CDFs were detected in any of the samples; however, low concentrations of hepta- and
octachlorinated CDDs and CDFs were detected.
The former Plant #2 area is located in the northwest corner of the northern portion of the
Duracell property. Plant #2 was formerly used to store, process, and reclaim mercury. Soils
samples from this area were analyzed for the full range of inorganic and organic constituents.
Soil sampling was initially conducted during the Phase IRI in 1996. As part of the Phase E
investigation conducted in 1997, samples were collected in this area to better delineate mercury
concentrations. Limited sampling for site-specific constituents was also performed during the
1998 Phase El investigation.
A total of 81 soil samples from the former Plant #2 area were analyzed for the six site-specific
inorganics and 136 additional samples were analyzed only for mercury. Ten samples also were
analyzed for the remaining TAL inorganic constituents. Figure 3 shows the soil sample locations
in the former Plant #2 area. The concentration ranges and locations of the maximum
concentrations, are presented in Table 4.
-------
• mut i t-i» R emu* on NCK
A w« i i-i rr. IWPUM we noes
| IHW i *-M n. iMrutt EM MM
a muc i my/a K* tumi
• rxw > ear ««.
B mat x raw* wr
SQI.C m ftn
25 SO 100
Environmental
Resources
Management
SOIL SAMPLE LOCATIONS IN NORTHERN PORTION OF SITE
DURACELL U.S.A.
LEXINGTON, NORTH CAROLINA
"§§
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Duracell Battery Tech OU1
Page 17
Table 4 - Summary of Inorganic Constituents in former Plant #2 Area
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
BDLto2.7
BDLTO197
22.6 to 2,820
BDL to 2,070
BDLto2.4
4.8 to 195
Location of
Maximum Concentration
DUR-SB-208-4
DUR-SB-210-11
DUR-SB-233-1
DUR-SB-208C-1
DUR-SB-208-1
DUR-SB-200-2
Refer again to Figure 3 for the locations of the soil samples in the former Plant #2 area. The higher
concentrations of mercury are distributed generally in two soil depth zones, a shallow zone and a
deep zone. Relatively shallow soils at depths between 0 and 6 ft BGS had reported higher
concentrations of mercury in two small areas. One area is in the immediate vicinity of soil boring
locations SB-208 and SB-208C. The other area is near the southeast corner of the former Plant #2
area in the are of borings SB-197 and SB-197B.
Deeper soils in the vicinity of boring locations SB-198, SB-198A, and SB-209 had reported
mercury concentrations that exceed 10 ppm. These soils ranged in depth from 19 to 31 feet. This
area appears to be localized since the mercury concentrations reported in deep soils in adjoining
borings (SB-197A, SB-198B, SB-188C, SB-199B, SB-199C, and SB-209) were less than 10 ppm.
The only deeper soil reported to contain mercury at a concentration greater than 10 ppm was from
SB-199 at 8 to 9 ft BGS. This location is surrounded on the south, west, and north by borings
with mercury concentrations that were less than 10 ppm.
Fourteen soil samples from the former Plant #2 area were analyzed for TCL VOCs. Halogenated
VOCs were not detected in any of the soil samples. Non-halogenated VOCs were detected in only
three of the 14 soil samples at concentrations less than 20 ppb.
Eleven soil samples from the former Plant #2 area were analyzed for TCL S VOCs. PAHs were
not detected in any soil samples from this area and phthalate esters were detected in three samples.
The compound phenol was detected in one soil sample.
Ten soil samples from the former Plant #2 area were analyzed for TCL pesticides and PCBs. No
pesticides were detected in any soil sample. A single PCB Aroclor was detected at 33 ppb in one
sample.
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Duracell Battery Tech OUI
Page 18
The former solvent disposal area is located in the southern portion of the northern area of the
Site, immediately south of Building #4. Spent solvents reportedly were disposed in this area.
These solvents also may have contained other raw materials used in the production of batteries.
Soils samples from this area were analyzed for the full range of inorganic and organic
constituents. Soil sampling initially was conducted during the Phase IRI in 1996. As part of the
1997 Phase II investigation, samples were collected in the area to better delineate PCB
concentrations. Limited sampling for site-specific inorganics, TCL VOCs, and TCL SVOCs was
performed during the 1998 Phase III investigation.
A total of 197 soil samples were collected in the former solvent disposal area and analyzed for the
six site-specific inorganic constituents. Five samples also were analyzed for the remaining TAL
inorganic constituents. Figure 4 shows the soil sample locations in the former solvent disposal
area. The concentration ranges for the six site-specific inorganic constituents, and the locations of
the maximum concentrations, are presented in Table 5.
Table 5 - Summary of Inorganic Constituents in Former Solvent Pit Area
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
BDL to 3.0
BDL TO 229
43.3 to 3,430
BDL to 5,050
BDL to 33.2
11.1 to 650
Location of
Maximum
Concentration
DUR-SB-284-11
DUR-SB-285-21
DUR-SB-272-11
DUR-SB-277-1
DUR-SB-277-1
DUR-SB-277-1
The highest mercury concentration, 5,050 ppm, was detected in surface soil sample DUR-SB-277
(0-1 ft) located on the east side of the former solvent disposal area. The higher manganese
concentrations, including a detection of 3,430 ppm in sample DUR-SB-272 (11 feet bis), were
detected primarily in the eastern portion of the former solvent disposal area.
-------
PHASE I TEST BORINO LOCATION
PHASE 2 SOUOn Pit BOOK LOCATION
SOU IMfKI
C=Z=E=
0 5 10 30
Environmental
Resources
Management
SOIL SAMPLE LOCATIONS IN FORMER SOLVENT DISPOSAL AREA
DURACELL U.S.A.
LEXINGTON. NORTH CAROLINA
FIGURE
8?
I
og
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Duracell Battery Tech OU1
Page 20
A total of 199 soil samples from the former solvent disposal area were analyzed for TCL VOCs.
The concentration ranges and the locations of the maximum concentrations for inorganic
constituents in the former solvent pit area are presented in Table 6. The locations of soil samples
collected and analyzed for VOCs in the solvent disposal area are shown on Figure 4.
Table 6 - Summary of Organic Compounds in Former Solvent Pit Area
voc
Tetrachloroethene
Trichloroethene
1,1,1 -Trichloroethane
1 , 1 ,2-Trichlorethene
1 ,2-Dichloroethene
1 , 1 -Dichloroethene
1 ,2-Dichloroethane
1,1-Dichloroethane
Methylene Chloride
Carbon tetrachloride
Acetone
Toluene
Concentration
Range (ppb)
BDLto41,000
BDL to 15,000
BDLto91,000
BDL to 510
BDL to 5,600
BDL to 2,400
BDL to 1,100
BDL to 2,900
BDL to 2,100
BDL to 15,000
BDL to 11, 000
BDL to 27,000
Location of
Max. Cone.
DUR-SB-278-11
DUR-SB-293-16
DUR-SB-278-11
DUR-SB-278-21
DUR-SB-293-16
DUR-SB-273-11
DUR-SB-289-11
DUR-SB-293-11
DUR-SB-274-21
DUR-SB-278-11
DUR-SB-270-1
DUR-SB-278-21
The higher concentrations of halogenated VOCs are present in a north-south band extending
across the former solvent disposal area. The highest concentration of total halogenated VOCs
was detected in SB- 278 at 10 to 11 ft BGS (147,000 ppb). The next higher concentration of total
halogenated VOCs was detected in SB-293 at 10-11 ft BGS (51,000 ppb). In addition, samples
from SB-273 (20-21 ft) and SB-274 (20-21 ft) had total halogenated VOC concentrations of
23,200 ppb and 20,400 ppb, respectively. The only other soil boring in which the concentration
of total halogenated VOCs exceeded 10,000 ppb was SB-291 at 15 to 16 ft BGS.
Boring SB-278 is bounded by borings SB-162 and SB-285 to the west, SB-147 and SB-135 to the
south, and SB-295 to the east. Of the 30 soil samples analyzed in these five borings, three
samples had total halogenated VOC concentrations ranging from 1,000 ppb to 4,000 ppb. In
addition, borings SB-279, SB-280, and SB-283 are located approximately 40 feet north of SB-
278. Of the eighteen soil samples analyzed from these borings, two soil samples had total
halogenated VOC concentrations ranging from 1,000 ppb to 2,000 ppb.
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Duracell Battery Tech OU1
Page 21
A total of 86 soil samples were collected in the former solvent disposal area between ground
surface and 6 ft BGS. Twenty-five of those samples had halogenated VOCs concentrations
greater than 100 ppb and only one (SB-278-1) exceeded 1,000 ppb. These data indicate that the
majority of the halogenated VOCs in the former solvent disposal area are present at a depth
greater than six feet.
Six different non-halogenated VOCs were detected above 100 ppb in soils from the former
solvent disposal area. Carbon disulfide was detected in a single sample in a soil boring. Carbon
disulfide was not reported to have been used at the facility. Xylene also was detected in a single
sample. The remaining four non-halogenated VOCs were detected above 100 ppb in 77 samples.
In 56 of these samples, acetone was the only non-halogenated VOC detected above 100 ppb. The
distribution of the non-halogenated VOCs other than acetone (i.e., toluene, 2-butanone (MEK), 4-
methyl-2-pentanone (MBBK)) was similar to the distribution of the halogenated VOCs. Of these
three VOCs, only toluene was reported above 1,000 ppb in four soil borings. All other soil
borings had concentrations less than 300 ppb.
The distribution of acetone did not appear to follow any distinct pattern. Unlike the other VOCs,
acetone frequently was reported at elevated concentrations in samples collected at depths between
ground surface and 6 ft BGS. Eight of the 11 acetone concentrations above 1,000 ppb were
between ground surface and 6 ft BGS.
Four soil samples from the former solvent disposal area were analyzed for TCL SVOCs. SVOCs
were detected in three of these samples. A single PAH (2-methyl naphthalene) was detected in
one soil sample at less than 1,000 ppb. Phthalate esters were detected in three soil samples. The
phthalate ester, DNBP, was detected in the two samples.
A total of four soil samples were initially collected in March 1996 from the former solvent
disposal area and analyzed for TCL pesticides and PCBs. An additional 27 soil samples were
collected from six supplemental borings in the former solvent disposal area in April 1997 for
analyses of pesticides and PCBs. Pesticides were detected in only three soil samples from the
former solvent disposal area. The pesticide methoxychlor was detected in SB-SP5-3 at 41 ppb,
All other pesticide concentrations were less than 6 ppb. PCBs were detected in 12 soil samples.
These data indicate that PCBs are present in very localized areas of the former solvent disposal
area with only two of 29 soil samples having total PCB concentrations greater than Ippm.
The former cleaning operations area is located on the north side of Plant #1, immediately east of
monitoring well DW-1. Five soil borings were drilled in the area of the former cleaning operations
area in order to determine the magnitude and extent of residual volatile organic compounds and
site-specific inorganic constituents in the underlying soils.
In order to characterize the soil in the vicinity of this reported cleaning operation area, 19 discrete
soil samples were collected from five stations and subsequently analyzed for the six site-specific
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Duracell Battery Tech OU1
Page 22
inorganic constituents. The concentration ranges and the locations of the maximum concentrations
for the six site-specific inorganic constituents are identified in Table 7. The VOC 1,1,2-
trichloroethane was the only VOC identified in two soil samples collected from this area at stations
CO1 (DUR-SB-CO1-21 at 2 ppb) and CO4 (DUR-SB-CO4-21 at 2 ppb).
Table 7-Summary of Inorganic Constituents in Former Cleaning Operations Area
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
DDL to 6.2
BDLto39
85.5 to 1240
BDLtol9
BDL to 5.4
20.3 to 369
Location of
Maximum
Concentration
DUR-SB-CO4-1
DUR-SB-C02-1
DUR-SB-CO2-1
DUR-SB-CO3-1
DUR-SB-CO4-1
DUR-SB-CO5-1
The former underground storage areas (USTs) were used in the past for storing fiiel. One of
these areas was a former location of a 550-gal gasoline UST located above 100 feet south of
Building #4. The other area was a former location of a 20,000-gal fuel oil tank located at the
northwest corner of Plant #3. These former UST areas are areas of concern due to the presence of
fuel-related organic compounds in the soil and ground water. For this reason, two soil borings
were drilled at each of two former UST areas. A total of 13 soil samples were collected in two of
these areas to evaluate the magnitude and extent of potential constituents of concern associated
with these former USTs.
The concentrations of lead observed in the soil samples ranged from a minimum of 2.9 ppm at
boring GT1 from a depth of 15 to 16-ft to a maximum of 10.9 ppm at boring GE1 (GT1) at the 7-
ft depth interval. Only two VOCs, methylene chloride and acetone, were detected in the soil
samples collected in the two former UST areas. Methylene chloride was detected in only one soil
sample (DUR-SB-GT2-16) at a concentration of 17 ppb. Acetone was detected in four of the soil
samples collected from the former UST locations. The maximum acetone concentration was
33,000 ppb from boring G1E from the 7-ft depth interval at the former gasoline UST area. Five
soil samples from the former fuel oil UST area were analyzed for SVOCs. Semi-volatile organic
compounds were not detected in any of these five soil samples.
Four wastewater sump areas, located at Building #4 and Plant #1, were previously used at the
facility for storing wastewater generated during the battery manufacturing process. Based on a
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Duracell Battery Tech OU1
Page 23
process sewer assessment conducted during the RI/FS by Metcalf and Eddy, these four wastewater
sumps were found to have potentially released wastewater to the subsurface.
The Plant #1 sumps have been included as part of the Southern Site area for data evaluation
purposes whereas the Building #4 sumps were included as part of the Northern Site area. A total
of five borings were drilled and 28 discrete soil samples were collected in these areas to evaluate
the magnitude and extent of contamination of site-specific parameters in the vicinity of these
sumps.
A total of 28 discrete soil samples were collected from five stations (SUA, SUB, SUC1, SUG2,
and SUD1), and subsequently analyzed for the six site-specific inorganic constituents. Table 8
shows the concentration ranges and locations of the maximum concentrations for the six site-
specific inorganic constituents.
Table 8 - Summary of Inorganic Constituents in Sump Areas
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
BDLtolO.8
BDLtol92
275 to 4,380
BDLto 1,100
BDL to 8.0
5.2 to 2,8 10
Location of
Maximum
Concentration
DUR-SB-SUB-1
DUR-SB-SUA-16
DUR-SB-SUC1-6
DUR-SB-SUA-3
DUR-SB-SUA-3
DUR-SB-SUC1-3
Four of the five highest mercury concentrations and the two highest cadmium concentrations were
detected in samples collected from the borings drilled at sumps SUA and SUB, both located at
Building #4. The two highest manganese concentrations were detected at the two sumps at Plant
#1 (SUC and SUD).
A total of seven halogenated VOCs and three non-halogenated VOCs were detected in the soil
samples collected from the four sump areas. The concentration ranges of the predominant VOCs
and the location of the maximum concentration are shown in Table 9.
The maximum concentrations for these VOCs, as noted above, were found at soil sampling
stations SUB and SUC1. Lower concentrations of these compounds also were found in the soil
samples collected from stations SUA and SUD1.
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Duracell Battery Tech OVl
^____ Page 24
Table 9 - Summary of Organic Compounds in Sump Areas
VOCs
Acetone
1,1,1 -Trichloroethane
Trichloroethene
Xylene
Concentration
Range (ppb)
BDL to 1,300
BDL to 1,600
BDL to 1,700
BDL to 5,500
Locations of
Maximum
Concentration
DUR-SB-SUB-6
DUR-SB-SUB-3
DUR-SB-SUC1-1
DUR-SB-SUB-3
In addition to the four VOCs listed in the above table, six other VOCs were detected at low
frequencies and concentration (BDL to 78 ppb). The majority of VOC detections were in soil
samples collected from the two sumps at Building #4 (SUA and SUB).
PAHs were detected at Station SUA at Building #4 at concentrations ranging from 50 to 120 ppb,
and at Station SUC2 at Plant #1 at concentrations ranging from 2,000 to 20,000 ppb. Two of the
most common phthalate esters, diethyl phthalate and bis (2-ethyt hexyl) phthalate, also were
detected in the soil samples collected from stations SUA, SUB, and SUD1.
A total of 201 surface soil samples were collected outside the facility fence line from properties
surrounding the Duracell property. In addition, 26 surface soil and 6 subsurface soil samples were
collected from 23 background areas some distance away from the Site to establish soil conditions
in nearby areas not affected by the Site.
Off-site soil sampling was conducted to determine the presence and extent of site-related inorganic
constituents and organic compounds in soils located outside the facility fence line. More limited
analyses of other compounds, including TAL inorganics, TCL VOCs, TCL SVOCs, and TCL
pesticides/PCBs, were performed to assess the potential that other constituents might be present.
For purposes of the RI report, the off-site soil sampling activities were segregated into discrete
areas according to proximity to the northern portion of the Site. These areas include: 1) 0 to 400
feet from the northern Site boundary, 2) 400 to 800 feet from the northern Site boundary;
3) 800 feet to '/$ mile from the northern Site boundary; and 4) greater than 54 mile from the
northern Site boundary.
A total of 67 soil samples were collected from 0 to 400 feet from the northern Site area and
analyzed for the full range of inorganic and organic constituents described above. Soil sampling
initially was conducted in this area during the Phase I RI in 1996, with limited follow-up sampling
being conducted as part of Phase H sampling in 1997. Samples were not collected from this area
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Pace 25
as part of the Phase HI RI program. Soils samples were collected from this area as part of both the
soil sampling programs and the ecological investigations.
All samples were analyzed for the six site-specific inorganic constituents, and seven additional
samples were analyzed for mercury only. Five samples also were analyzed for the remaining TAL
inorganic compounds. The concentration ranges and locations of the maximum concentrations of
the site-specific inorganics are identified in Table 10.
Table 10 - Summary of Inorganic Constituents in Off-Site Soils Located from 0-400
Feet From Northern Site Area
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration Range
(ppm)
BDL
4.9 to 93.8
190 to 3,220
BDL to 3 1.4
BDL to 2.1
21.7 to 1,570
Location of
Maximum
Concentration
Not Applicable
DUR-SB-169-1
DUR-SB- 154-1
DUR-SB-D3-9
DUR-SB-D3-9
DUR-SB-156-1
In the case of the manganese, some contribution from Site runoff or airborne emissions is a
possibility. This is most likely in small areas immediately north of the northern Site property
boundary.
A total of 16 soil samples were analyzed for TAL VOCs. Acetone was reported above the
detection limit in two of the 13 samples. No other VOCs were reported above detection limits in
these soil samples. Six soil samples were analyzed for TAL SVOCs within 0 to 400 feet from the
northern Site area.. The phthalate ester, DNBP, was detected in three samples at a maximum
concentration of 2,300 ppb. No other SVOCs were detected. Four soil samples were analyzed for
TCL pesticides and PCBs. No pesticides or PCB were detected in any soil sample from this area.
Therefore, pesticides and PCBs are not considered to be a concern in this area.
Four soil samples from off-site locations were analyzed for CDDs and CDFs. No tetra-, penta-,
and hexachlorinated CDDs, or any CDFs were detected in any off-site soil samples; however, low
concentrations of hepta- and octachlorinated CDDs were identified.
A total of 76 soil samples were collected from the area located 400 to 800 feet from the Northern
Site area, and analyzed for the six site-specific inorganic constituents. Soil sampling initially was
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Rage 26
conducted in this area during the Phase IRI in 1996, with limited follow-up sampling being
conducted as part of Phase II sampling in 1997. Soil samples were collected from this area as part
of both the soil sampling programs and the ecological investigations.
Seventy-two soil samples were analyzed for the six site-specific inorganic constituents and an
additional four samples were analyzed for mercury only. No samples were analyzed for the
remaining TAL inorganic constituents. The concentration ranges and locations of the maximum
concentrations of the site-specific inorganic constituents are identified in Table 11.
Table 11 - Summary of Inorganic Constituents From 400 to 800 Feet Within the
Northern Site Area
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
BDLto2.7
3.1 to 219
197 to 4,280
0.12 to 29.6
BDLto4.6
17.1 to 1,080
Location of
Maximum
Concentration
DUR- OS-57-1
DUR-OS-76-1
DUR-OS-89-1
DUR-SB-251-1
DUR-SB-263-1
DUR-OS-56-1
A total of 42 soils samples were collected from the off-site area located 800 Feet to V2 Mile Area
from Northern Site area as part of both the Phase II RI soil sampling program and the ecological
investigations. Thirty-eight soil samples were analyzed for the six site-specific inorganics and a
single sample (DUR-SB-102-2Z) was analyzed for TAL inorganics. The concentration ranges
and locations of the maximum concentrations of the site-specific inorganic constituents are
identified in Table 12. A single soil sample (DUR-SB-102-2Z) was analyzed for TCL VOCs and
SVOCs. The only VOC detected was acetone at 290 ppb. No SVOCs were detected in this
sample.
A total of 16 soil samples were collected from this off-site area and analyzed for the six site-
specific inorganics as part of the Phase II RI soil sampling program. Soil samples from this off-
site area were analyzed only for the six site-specific inorganic constituents. The concentration
ranges and locations of the maximum concentrations of the site-specific inorganic constituents are
identified in Table 13.
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Table 12 - Summary of Inorganic Constituents Located from 800 Feet to 1/2 Mile
From Northern Site Area .
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
DDL to 1.0
4.5 to 91.7
281 to 2,240
BDL to 13.1
BDLtoO.48
17.4 to 184
Location of
Maximum
Concentration
DUR-OS-41-1
DUR-OS-13-1
DUR-OS-13-1
DUR-OS-16-1
DUR-OS-50-1
DUR-OS-41-1
Table 13 - Summary of Inorganic Constituents in Off-Site Soil 800 Feet to '/z Mile
From Northern Site Area
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration Range
(ppm)
BDL to 0.83
6.1 to 81. 9
225 to 1,250
BDL to 0.76
BDL to 0.35
24.0 to 204
Location of
Maximum
Concentration
DUR-OS-44-1
DUR-OS-53-1
DUR-SB-OS-53
DUR-OS-44-1
DUR-OS-34-1
DUR-OS-40-1
6.2 Surface Water and Sediment Sample Results
A total of 71 surface water samples were collected from 33 different locations including the
unnamed tributaries located to the north, south, and east of the Site, Leonards Creek, Abbotts
Creek, and High Rock Lake. The surface water sampling was conducted to determine whether
contaminants of concern are present in the surface water of the unnamed tributary northeast of
former Plant #2, the unnamed tributary east of Plant #3, the unnamed tributary north of Plant #3,
the unnamed tributaries south of Plant #1, Fritz Branch, Leonards Creek, Abbotts Creek, and the
Abbotts Creek Arm of High Rock Lake. The surface water samples were analyzed for the six site-
specific inorganic constituents, as well as the lull range of TAL inorganic and TCL organic
compounds. The surface water data also were used to evaluate local ground water discharge to
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the upper reaches of the unnamed tributaries draining the Site. See Figures 5 and 6 for the surface
water and sediment sample locations. In addition, six surface water samples were collected from
three background locations to establish surface water conditions in areas not affected by the Site.
To establish background concentrations of various TAL inorganic and TCL organic constituents, a
total of six samples were collected from three background stations (SW-10, SW-16, and SW-25)
at locations distant from the Site so as to not be impacted by releases from the facility, yet near
enough to the Site to be representative of local conditions. Variations in detected concentrations
of the inorganic constituents are attributable to the natural distribution of these constituents in the
environment. Arsenic, beryllium, selenium, and thallium were not detected in any of the
background surface water samples. VOCs, SVOCs, pesticides, and PCBs were not detected in
any of the background surface water samples. Samples for inorganic compounds in surface water
were collected from 33 stations during the Phase I and Phase II sampling events, totaling 71
samples. Nine samples were analyzed for TAL inorganic constituents. The concentration ranges
and locations of the maximum concentrations of the site-specific inorganic constituents are
identified below in Table 14.
Table 14 - Summary of Inorganic Constituents in Surface Water Samples
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppb)
BDL to 5.5
BDLto21.5
10.8 to 14,500
BDL to 56.9
BDL
BDL to 784
Location of Maximum
Concentration
DUR-SW-32
DUR-SW-32
DUR-SW-32
DUR-SW-32
Not applicable
DUR-SW-32
The maximum concentrations for each of these inorganic constituents were found in the surface
water sample collected on July 16, 1996 at Station 32, located on the unnamed tributary northeast
of former Plant #2.
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SURFACE WATER AND SEDIMENT SAMPLING LOCATIONS
FOR TRIBUTARIES DRAINING SITE
DURACELL U.S.A.
LEXINGTON. NORTH CAROLINA
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OFF-SITE SURFACE WATER
AND SEDIMENT SAMPLING LOCATIONS
Environmental
Resources
Management
DURACELL U.S.A.
LEXINGTON. NORTH CAROLINA
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Higher mercury concentrations were reported in the surface water samples collected during July
1996 from stations SW-31 (10.6 ppb) and SW-32 (56.9 ppb), both located in the unnamed
tributary northeast of former Plant #2. These samples also revealed elevated total suspended solids
(TSS) concentrations greater than 9,000 ppm
Mercury also was detected in the surface water samples collected from station SW-33 (5.8 ppb)
and from stations SW-22 (0.68 ppb), SW-24 (0.35 ppb), and SW-27 (1.7 ppb) during the April
1996 sampling event.
A total of 11 surface water samples were collected from nine stations during the Phase I and Phase
II sampling events and analyzed for organic compounds. A total of four samples also were
collected from two background stations (SW-16 and SW-25). The analytical results for volatile
organic compounds at the background stations were below detection limits.
A total of 11 VOCs were detected in samples collected from non-background stations. The
maximum concentrations for these organic compounds were found at surface water sampling
stations SW-33 and SW-34 located immediately south and southwest of the Site, respectively.
Station SW-33 is located at the head of the unnamed tributary south of Plant #1. Station SW-34
is located at the head of the unnamed tributary southwest of Plant #1. Lower concentrations of
VOCs were reported at other stations including SW-2, SW-9, SW-17, and SW-36.
Chlorinated VOCs were detected at only two surface water stations (SW-33 and SW-36). These
VOCs are potentially related to the Site via the shallow ground water system. The presence of
vinyl chloride in a surface water sample collected from Station SW-33 located south of the Site
may be a result of the degradation of halogenated VOCs used at the facility, including PCE and
TCE, to vinyl chloride. Acetone was detected in surface water samples from five stations (SW-2,
SW-9, SW-17, SW-33, and SW-34) at concentrations of 67 ppb and less. The exact source of the
acetone is unknown. Toluene, ethyl benzene, and total xylene also were detected at
concentrations ranginf from 2 to 9 ppb at a single surface water station, SW-2, located on the
Abbotts Creek Arm of High Rock Lake. These compounds are typical to gasoline and their
presence is most likely due to releases from boat motors in High Rock Lake or cars from the
nearby highway bridge.
A total of eleven surface water samples were collected from five stations during the Phase I and
Phase II sampling events and analyzed for semi-volatile organic compounds. A total of four
samples also were collected from two background stations (SW-16 and SW-25). Analytical
results for semi-volatile organic compounds at the background stations were below detection
limits.
The only SVOC detected at three of the five non-background stations was bis (2-ethyl hexyl)
phthalate (DEHP) at concentrations ranging from non-detect to 57 ppb. The highest concentration
was detected at Station SW-3 7 located on the southern unnamed tributary to Abbotts Creek,
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Duracell Battery Tech OU1
upstream of the confluence with the unnamed tributary south of Plant #1. Low concentrations of
DEHP also were found in the surface water samples collected from Stations SW-2, located on the
Abbotts Creek Arm of High Rock Lake, and SW-33, located on the unnamed tributary south of
Plant #1. The exact source of the DEHP is not known.
A total of nine samples were collected from five stations during the Phase I and Phase II sampling
events and analyzed for pesticides and PCBs. A total of four samples also were collected from
two background stations (SW-16 and SW-25). Analytical results for pesticides and PCBs at the
background stations were below detection limits. Neither pesticides nor PCBs were detected in
any of the surface water samples. Therefore, pesticides and PCBs are not considered to be an
issue in the surface water in the vicinity of the Site.
A total of 117 sediment samples were collected from 70 stations during the Phase I and Phase II
sampling events and analyzed for inorganic constituents. Figures 7 and 8 show the mercury
concentrations at each sediment sample location collected along the tributaries draining the Site, as
well as Abbotts Creek and into High Rock Lake. These locations included the unnamed tributary
northeast of former Plant #2, the unnamed tributary east of Plant #3, the unnamed tributary north
of Plant #3, the unnamed tributaries south of Plant #1, Fritz Branch, Leonards Creek, Abbotts
Creek, and the Abbotts Creek Arm of High Rock Lake. This includes 21 sediment samples
collected as part of the ecological sampling program for amphibians and Corbicula. A total of nine
samples were collected from three background stations (SW-10, SW-16, and SW-25). Eleven
sediment samples were analyzed for TAL inorganic constituents. The concentration ranges and the
locations of the maximum concentrations of the site-specific inorganic constituents are identified
below in Table 15.
The highest mercury concentration was detected in a sediment sample collected from station SD-
67 (365 ppm), located in the unnamed tributary northeast of former Plant #2. The source of the
mercury in the sediments is most likely runoff from the areas of concern located inside the facility
fence line (i.e., former Plant #2 area, northern site area, and Building #4 sump area). Lower
concentrations of mercury were detected in the sediments sampled from other stations along this
unnamed tributary, as well as from Stations SD-33 (1.8 ppm) and SD-22 (2.2 ppm). Station SD-
33 was located at the head of the small unnamed tributary located south of Plant #1. Station SD-22
was in the unnamed tributary located north of Plant #3. Station SD-14, located in Abbotts Creek,
had an initial Phase I mercury concentration of 11.8 ppm. Station SD-14 is downstream of the
Site, the Old Lexington Landfill, and the Old Wastewater Treatment Plant. Mercury was not
detected above 0.22 ppm in 11 subsequent sediment samples collected at Station SD-14, as well as
downstream and upstream of Station SD-14.
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Page 34
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Brent-wood. Tennessee
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Table 15 - Summary of Inorganic Constituents in Sediment Samples
Inorganic
Constituents
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
Concentration
Range (ppm)
BDLto7.9
6.1 to 152
114 to 9,440
BDL to 365
BDLtoS.O
11. 5 to 140
Location of
Maximum
Concentration
DUR-SD-17-3
DUR-SD-19
DUR-SD-47
DUR-SD-67
DUR-SD-6
DUR-SD-67
A total of 10 sediment samples were collected from ten stations during the Phase I and Phase II
sampling events and analyzed for VOCs. Two samples also were collected from two background
stations (SW-16 and SW-25). A total of nine VOCs were detected in the sediment samples. The
higher concentrations for these organic compounds were found at sediment sampling stations SD-
2, SD-33, and SD-36. Station SD-2 is located along the Abbotts Creek Arm of High Rock Lake
(impounded), while Stations SD-33 and SD-36 are located along the unnamed tributary south of
Plant #1. Lower concentrations of VOCs were detected in the sediments collected from stations
SD-9, SD-17, andSD-26.
Chlorinated VOCs were detected in only two sediment samples which were collected from
Stations SD-33 and SD-36. The presence of chlorinated VOCs at these locations is most likely
attributable to the discharge of shallow ground water containing VOCs to this surface stream.
A geomembrane was placed into the upper reached of the unnamed tributary following the 1994
sediment removal activities conducted by Duracell. In order to investigate the presence of residual
inorganic constituents beneath the geomembrane, sediment samples were collected from beneath
the geomembrane. Seven samples were collected and analyzed for the site-specific inorganic
constituents. These locations were selected based on historical data which indicated concentrations
of mercury in the sediment at these locations. The concentration ranges and locations of the
maximum concentrations of the site-specific inorganic constituents are identified below in Table
16.
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Table 16- Summary of Inorganic Constituents beneath Geomembrane
Inorganic
Constituents
Concentration
Range (ppm)
Location of
Maximum
Concentrations
Cadmium
Chromium
Manganese
Mercury
Silver
Zinc
BDLtoO.59
5.8 to 12.4
505 to 968
0.74 to 45.3
BDLtoO.69
54.8 to 92.9
DUR-SS-03
DUR-SS-01
DUR-SS-01
DUR-SS-03
DUR-SS-03
DUR-SS-04
These data indicate that residual concentrations of mercury are present at certain locations beneath
the geomembrane in the unnamed tributary. The material is not directly accessible for exposure or
transport in the environment.
6.3 Summary of the Ecological Assessment
A Phase I screening-level ecological assessment and a Phase II ecological assessment were
conducted to evaluate the potential ecological impacts related to the Site. Numerous samples were
collected and analyzed as part of this effort. The key objectives of these ecological assessments
included:
• determining if habitats of any federally listed Threatened or Endangered (T & E) species
have been adversely impacted by site-related contamination;
• determining if bioaccumulation of site-related contaminants has occurred in benthic macro-
invertebrates, such as the freshwater mussels called Corbicula, living in streams near the
site;
• determining if bioaccumulation of site-related contaminants has occurred in fish living in
Abbott Creek and High Rock Lake. A total of 187 fish samples were collected and
analyzed for this effort; and
• determining if uptake and bioaccumulation of site-related contaminants has occurred in
terrestrial organisms living near the site, including shrews, mice, and earthworms, as well as
higher order predators in the food chain.
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The study area consisted primarily of two ecozones: 1) terrestrial off-site ecozone and 2)
aquatic/riparian ecozone. The Tier I screening-level ecological risk assessment identified certain
organisms (representatives of different feeding groups in the terrestrial and aquatic ecozones in the
vicinity of the Site) which could potentially be impacted due to the presence of site-related
constituents, particularly mercury. Based on the results of the Phase I screening-level ecological
assessment, the decision was made to conduct a Phase II ecological risk assessment.
The Phase II ecological sampling was intended primarily to fill data needs in the ecological
database that has been used for the screening level and ecological risk analyses. The Phase II
sampling included a study of the target off-site ecozones to estimate habitat suitability and
abundance. Specifically, observations were made of target species (and others in the same
niches/feeding guilds), tracks, scats, cover types, nest sites, nesting habitat, and other observations,
following the data collection and input data procedures of the United States Fish & Wildlife
Service (USFWS) and the Habitat Evaluation Procedure (HEP) model. The HEP protocols were
selected in order to follow a well-understood and repeatable methodology at this stage, realizing
that the data needs of any Tier II analyses would not be fully defined at the time of the Phase II
field work.
6.4 Fate and Transport of COCs
The constituents present in the soil (gas, aqueous, or sorbed onto the solid phase) are subjected to
physical, biological, and chemical reactions which directly influence the persistence and
migration of the constituents. The site-related constituents of potential concern (COPCs) include
the following inorganic constituents (mercury, manganese, zinc, silver, cadmium, chromium, and
lithium), and volatile organic compounds (tetrachloroethene, carbon tetrachloride, methylene
chloride, trichloroethene, 1,1-dichloroethene, trans- 1,2-dichloroethene, 1,1-dichloroethane, 1,2-
dichloroethane, 1,1,1 -trichloroethane, 1,1,2-trichloroethane, acetone, chloroform), toluene,
xylene, PCBs, and polynuclear aromatic hydrocarbons (PAHs).
Based on the areas of concern identified above, pathways of migration include air, surface water
runoff, surface water, and ground water. The air pathway includes transport of surface soil
particles that might contain inorganic and organic constituents of concern to on-site and off-site
areas. In addition, VOC vapor emissions from the surface soils in the vicinity of the former solvent
disposal area would be transported via the air pathway.
The surface water runoff pathway includes the transport of constituents of concern entrained in
soil, and, to a lesser extent, the transport of dissolved constituents of concern in the water phase.
This pathway of migration leads predominantly to a series of unnamed tributary streams draining to
the north/northeast of the Site and to a minor extent to the south. The surface water pathway
continues the transport of suspended sediment and dissolved constituents of concern downstream
from these unnamed tributaries to Leonards Creek, Abbotts Creek, and High Rock Lake.
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Uptake of various constituents of concern by aquatic and terrestrial plants and organisms also can
occur. This uptake and subsequent bioaccumulation occurs through the local ecosystem based on
the dominant species comprising the food web in the area. Bioaccumulation of certain constituents
of concern such as mercury can occur which can have an impact on various plants and organisms.
Mercury is typically present in the soils in the metallic state as a hydroxide and chloride. Based on
the relatively low concentrations of mercury that leached from the soils as part of the SPLP tests,
the concentration of mercuric chloride, a high solubility species of mercury, is considered to be
low. Mercury present in the soils is expected to methylate at a very slow rate, if at all.
Mercury present in sediments is primarily derived from mercury bound to soil that is transferred via
runoff; therefore, the species initially present will be similar to the species present in the parent soil.
Because the soils at the facility are mineral soils, low organic carbon levels may be restricting
transformation to methyl mercury. If this transformation is occurring, methyl mercury is rapidly
being removed from the aquatic system. Based on the low concentrations of mercury observed in
the aquatic biota, methylation is apparently not occurring at a significant rate, or total mercury
concentrations are sufficiently low that significant bioaccumulation does not occur.
The various VOCs detected at the Site can be classified as halogenated VOCs (HVOCs) and non-
halogenated VOCs (NVOCs). The halogenated volatile organic compounds (HVOCs) identified in
the soil and ground water at the Site have moderate solubilities, high volatilities, low to moderate
partition coefficients, high mobilities, and densities greater than water. As a result, they can be
readily leached from soil into ground water. Once in the subsurface, these HVOCs typically
undergo progressive dehalogenation and degradation.
The Site had concentrations detected above background for various inorganic constituents
including cadmium, chromium, manganese, mercury, silver, and zinc, as well as halogenated and
non-halogenated VOCs, PAHs, phthalate esters, and PCBs.
The soils at the Site do not have a high organic carbon concentration and, therefore, these VOCs
will move relatively rapidly through the soil along with infiltrated water. This mobility is evident in
the former solvent disposal area.
Inorganic constituents are elements and, therefore, will not biodegrade. Inorganic mercury
compounds can undergo a microbiologically-induced transformation to methyl mercury, an
organo-inorganic compound. Methylation of mercury can cause increased bioaccumulation of
mercury in aquatic life. Inorganic and organic constituents present in surface and subsurface soils
can migrate through soils. The inorganic constituents of concern have high K,, values and will
readily sorb onto soil particles. This phenomenon was confirmed by the SPLP testing performed
as part of the RI. Although the inorganic constituents tend to preferentially sorb to soil particles,
some migration in the water phase does occur. The presence of inorganic constituents in the
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ground water demonstrates this transport mechanism With the exception of metallic mercury, the
various inorganic constituents and related inorganic species all have low vapor pressures and,
therefore, movement as a vapor will not be a significant migration pathway through soils.
Transport through soils of the various constituents of concern associated with the Site is limited to
on-site ground water. Surface runoff of soil material is limited to small surface areas immediately
north and northeast of the Site, and to the three small unnamed tributaries to the north/northeast
and the one small unnamed tributary to the south.
Site constituents of concern can enter surface water from other media. Inorganic constituents can
be transported in surface water either as dissolved inorganic constituents, precipitated inorganic
constituents, or inorganic constituents associated with suspended matter. Dissolved inorganic
constituents also can be transported with surface water flow. The concentration of the inorganic
constituents of concern in surface water, except in areas immediately adjacent to the Site, are low.
The low levels of VOCs identified in surface water adjacent to the Site are most likely the result of
ground water discharge to the heads of the small unnamed tributaries. Based on this limited
extent, VOCs entering the surface water are rapidly removed, most likely via volatilization to the
atmosphere.
Inorganic constituents can be transported to sediments via soils entrained in stormwater runoff,
deposition of dust, or transfer of dissolved or precipitated inorganic constituents in surface water
to sediments. Inorganic constituents can be transported with sediments either as bed-flow or
suspended sediments. The sediments would be deposited onto the bottom of the surface water
body when water velocity is reduced to a rate at which bed-flow ceases or suspended matter settles
out. Once sediments settle to the bottom, they can be remobilized as bed-flow or suspended
matter if a sufficient water velocity is reached, or they can be covered by additional sediment and
the constituents buried.
Based on the low concentrations of mercury and VOCs in the near surface soils at the Site,
transport via volatilization and the air pathway is not considered significant. In addition, the
vegetative cover and compact soils at the Site would limit transport via entrainment in wind-blown
dust.
6.5 Development of Soil Remediation Levels
Soil remedial goals for the protection of ground water were derived based on physical and
chemical transport mechanisms at the Site. Although it is possible that the risk assessment for
Operable Unit Two (ground water) will result in site-specific ground water quality criteria for the
Site, for the purposes of this analysis, the ground water cleanup goals for the site-specific
constituents of concern were based on default ground water quality criteria. These criteria were
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taken from the North Carolina Ground Water Quality Standards (NCGWQS) or the EPA
Maximum Contaminant Levels (MCLs).
The soil remedial goals for protection of ground water are not considered to be the maximum
allowable concentrations that can be present in soil in a given area of concern in order to be
protective of ground water quality. Rather these remedial goals represent an average
concentration of a particular constituent of concern in a given area of concern with a specific soil
volume. The total mass of a constituent of concern available for migration to ground water is
controlled by the total surface area and depth of soil through which infiltration occurs, in addition
to the average constituent concentration. Therefore, these soil remedial goals for protection of
ground water are to be used as a guide to reducing the overall risk at each area of concern
associated with migration to ground water.
Hydraulic and solute transport models were constructed to represent Site conditions and to
determine a dilution/attenuation factor from the source areas to the northern Site boundary. Soil
remedial goals were derived from the model results using a soilrwater partitioning equation.
The modeling effort was necessary to establish soil concentrations that would be protective of
ground water in the future as a result of leaching of COCs from the soils at the Site. The methods
evaluated for predicting or determining the mobility of COCs in the soil at the Site include: 1)
simple soil/water partition equations using literature data; 2) simple soil/water partition equations
using site-specific environmental data; 3) complex unsaturated and saturated zone chemical-
equilibrium models; and 4) site-specific leach tests, such as the Synthetic Precipitation Leaching
Procedure (SPLP).
A direct method of testing the mobility of the COCs using on-site soils was considered to be a
more representative and appropriate approach to assessing the site-specific mobility of COCs.
The SPLP, as described in SW-846 Method 1312, was used in making this site-specific
assessment. The 1996 EPA Soil Screening Guidance: User's Guide recognizes the utility of a
leach test in assessing the mobility of COCs in soil and specifically cites the SPLP as the leaching
test appropriate for a contaminated soil scenario.
The calibrated transport models were used to determine soil remedial goals (SRGs) for the
protection of ground water. The SRGs were determined by incorporating the soil-water partition
coefficients, dispersion and dilution during transport, and for the organic compounds, the
degradation rate. This analysis involved a two step process. First, an aquifer mass loading was
determined using WinTran®. Second, that mass loading was converted to a soil concentration
based on the area of the source and the rate of infiltration through the source area. Analytical
results for VOCs in soil were reviewed to evaluate the need for determining site-specific SRGs
for the VOCs in the former solvent disposal area. The VOC data initially were compared to the
EPA soil screening levels (SSLs) for migration to ground water, employing a dilution attenuation
factor of 20 (20DAF) and a fraction organic carbon content (fj of 0.2%. Based on this
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Duracell Batteiy Tech OU1
™--->41
for ^^^^^^^^f^ mercury for each of the four cases and
carbon tetrachJnriHo ™ i c *u™ »eyei tor each, are as follows- tetranM^^u... ,' ""Posai
6.6
in soil and tie con-endnnT. f™ rep°rted tolal constituent
^^^^
the ^£ Sd P"— ^« wou,d occur as a rSul, ^
and tfc land
aild Potenaal ^^ s.te
heatth and
the
water and surface
' ^^^ beneficial
-------
SOUT IN fECl
a^sss
0 55 130 260
MODELED SOURCE AREAS FOR SOIL REMEDIATION
GOAL CALCULATIONS FOR PROTECTION OP GROUND WATER
DU8ACELL U.S.A.
LEXINGTON. NORTH CAROLINA
Environmental
Resources
Management
Z
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7.0 SUMMARY OF SITE RISKS
As part of the RI/FS, EPA conducted a baseline risk assessment (BRA) to determine the current
and future effects of contaminants on human health and the environment if no action were taken to
address the contaminated soil and sediment at the Site. The BRA focused on potential health
effects for both children and adults that could result from current or future direct contact with
contaminated soil or sediment (e.g., children ingesting soil or sediment while playing in the area).
Based on discussions with the Site owners, the facility is currently zoned for industrial use, and will
remain an industrial facility for the foreseeable future. The facility owners have agreed to apply
land use restrictions to their property as part of this remedy to prohibit residential use of the facility
in the future. The BRA also focused on potential effects to ecological receptors that could result
from the direct contact with or bioaccumulation of contaminated soil, surface water, or sediment
(e.g., predatory birds feeding on mice or shrews with elevated levels of mercury, raccoons eating
fresh water mussels, etc.).
7.1 Summary of Human Health Risk Assessment
Exposure scenarios for both current and future land use were evaluated based on an estimate of
Reasonable Maximum Exposure. Under the current land use scenario, current human receptors
near the Site potentially include child or adult residents living near the Site who may incidentally
ingest or come into contact with soil and sediment with elevated levels of mercury. A current
human receptor on-site would be a construction worker coming into contact with on-site soils
contaminated with mercury.
Under the future land use scenario, future human receptors living around the Site potentially
include child or adult residents who incidentally ingest or come into contact with soil and sediment
with elevated levels of mercury. The reasonable future land use scenario for the Duracell facility
will remain industrial, and future land use restrictions will be implemented as part of this remedy to
prohibit the facility from being used for residential purposes. Therefore, the potential for future
child or adult residents living on the facility and incidentally ingesting or coming into contact with
elevated levels of mercury is eliminated. However, a future human receptor on-site would be a
future construction worker coming into contact with elevated levels of mercury in the soil.
The baseline risk assessment focused on the health effects for adult and child residents that could
result from potential exposures both inside and outside the facility fence line, as well as to
construction workers on the facility. The chemicals of concern (COCs) for an exposure scenario
are the chemicals of potential concern (COPCs) that significantly contribute to an exposure
pathway for an identified receptor. The Risk Assessment also adds the risk from all COCs in order
to assess the cumulative risk for each exposure scenario. A COC must have an individual
cumulative carcinogenic risk which exceeds IX10"4 (or one-in-ten-thousand), or a hazard index
(HI) for noncarcinogenic risk (e.g., nervous disorders) of 1.0. A 1X10"4 cumulative carcinogenic
risk level or an HI of 1.0 for noncarcinogenic risk are typically used as "remediation triggers".
No unacceptable carcinogenic risk was identified during the RI from exposures to the COCs.
However, there are several exposure scenarios evaluated in the Risk Assessment with HI values
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greater than 1.0. The HI value greater than 1.0 is primarily due to incidental ingestion of, and
dermal contact with, mercury in soil. The exposure scenarios with HI values greater than 1.0
included future construction workers in the Northern Site area (total HI = 3.0), future on-site adult
residents in the Northern Site area (total HI = 2.0), future on-site child residents (1-6 years of age)
in the Northern Site area (total HI = 15), and future child residents (1-6 years of age) in the
Southern Site area (total ffl = 4.0).
7.1.1 Identification Of Chemicals Of Concern
Based on the history of operations and materials used at the Site, and an evaluation of the
analytical data collected during the Remedial Investigation, the primary chemicals of potential of
concern at the Site in soil include mercury, manganese, PCBs, toluene, xylene, and volatile organic
compounds including tetrachloroethene, trichloroethene, carbon tetrachloride, methylene chloride,
1,2-dichloroethane, acetone, 1,1,1-trichloroethane, trans-1,2-dichloroethene, 1,1-dichloroethane,
1,1,2-trichIoroethane, 1,1 -dichloroethene, and chloroform.
Elevated levels of mercury in soil can be toxic if human beings are exposed through inhalation,
ingestion or dermal contact exposure. Elevated levels of mercury in soil can also cause adverse
impacts to ecological receptors. Mercury can bioaccumulate in living tissue, potentially causing
adverse effects to higher order organisms in the food chain. Elevated levels of mercury in soil is
also a source of groundwater contamination. The elevated levels of manganese and volatile organic
compounds in the soil do not pose a direct contact exposure risk, but are a source of groundwater
contamination at the Site. Although the above constituents were considered to be the primary
constituents of concern associated with the Site, the Remedial Investigation detected other
chemical constituents through sampling and analyses.
7.1.2 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. The conceptual model for the Site is presented
on Figure 10. 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 mercury, manganese, and volatile organic compound contamination in the soil resulted from
past operations at the Site. Soil contamination over the years has resulted in continued releases to
ground water. Groundwater has been impacted by mercury, manganese, and volatile organic
compounds through the leaching action of infiltrating rain water. Surface water and sediment in
nearby surface water pathways have been impacted by mercury due to runoff of soil contamination
from the Site. The potential exists for adverse impacts to terrestrial and aquatic ecological
receptors due to the uptake or the bioaccumulation of mercury.
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Based on these models, the media available for human contact are:
(1). Soil within the facility fence line as well as outside the fence line. The receptors
evaluated in the BRA included future site residents, current and future residents
around the Site, current on-site visitor, and current and future construction workers
at the facility;
(2). Surface water and sediment in the unnamed tributaries are accessible to juvenile and
adult residents living near the facility. It is assumed that these receptors may be
exposed while swimming, wading, or fishing in the stream; and
(3). Fish in Abbotts Creek and High Rock Lake caught by human beings and consumed.
The potentially significant human exposure routes are:
(1). through the inhalation, direct contact, and/or incidental ingestion of contaminated
soil;
(2). through the inhalation of, incidental ingestion of, and/or dermal contact with surface
water and sediment in the unnamed tributary. Direct contact with sediment in the
unnamed tributary may occur since the sediment is not covered by surface water for
much of the year.
(3). through the consumption offish in Abbotts Creek and High Rock Lake due to
levels of mercury in fish fillets.
The media available for ecological uptake and/or bioaccumulation are:
(1) soil located within the facility fence line as well as outside the fence line.
Earthworms were evaluated for the bioaccumulation of mercury, and through the
use of food chain models, the bioaccumulation potential to high-order organisms
(2) surface water and sediment in the unnamed tributary of Fritz Branch. Fresh water
fish and mussels were evaluated for bioaccumulation of mercury, and through the
use of food chain models, the bioaccumulation potential to higher-order organisms
in the food chain including carnivorous and omnivorous mammals, was estimated.
The potentially significant exposure routes to ecological receptors are:
(1) through direct with and/or ingestion of contaminated soil, as well as the ingestion of
lower-order organisms in the food chain; and
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Polrntlil
Ami of
Concern
Primuy
Rtltue
Mtrhanhnu
FIGURE 10
CONCEPTUAL SITE MODEL
DURACELL U.S.A
LEXINGTON, NORTH CAOLINA
Primiry
Medium
Primuy
Migration
Plllwayi
Vtlaaty
Exposure
Palhwtya
I VDClCWlY
s
I
f
i*§8
-------
7.1.3 Toxicity Assessment
~,
* reference dose values (RfDs) for non-carcinogenic eifects
* cancer slope factors (CSFs) for carcinogenic effects
-—•*"»» TV xiu u.j.vniiic CAUtlalirC
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7.1.4 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.
In order 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 sub-threshold 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/RfDi
where: ADD; = Average Daily Dose (ADD) for the i* toxicant
RfDj = Reference Dose for the ilh toxicant
The term ADD/RfD; 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., 1 x lO^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 17 shows a risk summary for the chemicals
of concern. The cumulative, non-carcinogenic hazard indices for the site-related COCs, along
with the exposure point concentrations that trigger the need for remedial action.
7.2 Summary of Ecological Risk Assessment
Previous investigations conducted at the Site between 1980 and 1995 revealed mercury
contamination in the soil around the facility, in sediment along segments of the surface water
pathways around the Site, as well as in fish tissue collected from Abbotts Creek and High Rock
Lake. As a result, a screening ecological assessment was conducted in 1996 as part of the RI to
-------
TABLE 17 - RISK SUMMARY FOR CHEMICALS OF CONCERN
Current Off-Site Receptor
Adult Resident
Exposure Pathway - Incidental Ingestion of Surface Soil + Ingcstion of Fish
Media
Soil
Fish
Chemical
of Concern
Aluminum
Chromium
Iron
Manganese
Mercury
Vanadium
mercury
Exposure Point
Concentration (ppm)
50,500
219
62,000
4,280
53.3
220
0.509
Associated Risk
Carcinogenic Risk
NA
NA
NA
NA
NA
NA
NA
Noncarcinogenic Risk
0.09
0.02
0.4
0.02
0.07
0.06
0.3
Total Noncarcinogenic Risk = 1.0
*SB
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TABLE 17(CONT.) - RISK SUMMARY FOR CHEMICALS OF CONCERN
Current Off-Site Receptor
Child Resident (age 3-6)
Exposure Pathway - Incidental Ingcstion of Surface Soil + Ingestion of Fish
Media
Soil
Fish
Chemical
of Concern
Aluminum
Chromium
Iron
Manganese
Mercury
Vanadium
Mercury
Exposure Point
Concentration (ppm)
50,500
219
62,000
4,280
53.3
220
0.509
Associated Risk
Carcinogenic Risk
NA
NA
NA
NA
NA
NA
NA
Noncarcinogcnic Risk
0.72
0.14
3.0
0.2
0.51
0.45
0.3
Total Noncarcinogenic Risk = 5.0
IB
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TABLE 17 (CONT.) - RISK SUMMARY FOR CHEMICALS OF CONCERN
Future Receptor
On-Site Adult Resident
Exposure Pathway - Incidental Ingestion + Dermal Contact with Surface Soil in Northern Site Area
Media
Soil
Chemical of
Concern
Aluminum
Arsenic
Cadmium
Chromium
Iron
Manganese
mercury
Vanadium
Exposure Point
Concentration (ppm)
48,600
8
10.8
121
71,800
2,820
5,050
172
Associated Risk
Carcinogenic Risk
NA
NA
NA
NA
NA
NA
NA
NA
Noncarcinogenic Risk
0.1
0.02
0.002
0.01
0.3
0.05
1.0
0.03
Total Noncarcinogenic Risk = 2.0
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TABLE 17 (CONT.) - RISK SUMMARY FOR CHEMICALS OF CONCERN
Future Receptor
On-Site Child Resident (age 1-6)
Exposure Pathway - Incidental Ingcstion + Dermal Contact with Surface Soil in Northern Site Area
Media
Soil
Chemical of
Concern
Aluminum
Arsenic
Cadmium
Chromium
Iron
Manganese
Mercury
Vanadium
Exposure Point
Concentration (ppm)
48,600
8
10.8
121
71,800
2,820
5,050
172
Associated Risk
Carcinogenic Risk
NA
NA
NA
NA
NA
NA
NA
NA
Noncarcinogenic Risk
0.69
0.194
0.024
0.13
3
0.2
10
0.4
Total Noncarcinogenic Risk = 15.0
.gs
>So
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TABLE 17(CONT.) - RISK SUMMARY FOR CHEMICALS OF CONCERN
Future Receptor
On-Site Child Resident (age 1 -6)
Exposure Pathway = Incidental Ingcstion of Surface Soil in Southern Site Area
Media
SoQ
Chemical of
Concern
Aluminum
Chromium
iron
Manganese
Mercury
Exposure Point
Concentration (ppm)
37,000
83.4
52,600
14,000
226
Associated Risk
Carcinogenic Risk
NA
NA
NA
NA
NA
Noncarcinogenic Risk
0.53
0.18
2.5
0.26
0.34
Total Noncarcinogenic Risk = 4.0
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TABLE 17(CONT.) - RISK SUMMARY FOR CHEMICALS OF CONCERN
Future Receptor
On-Sitc Construction Worker
Exposure Pathway - Incidental Tngestion and Dermal Contact with Surface and Subsurface Soil in Northern Site Area
Media
Soil
Chemical of
Concern
Aluminum
Arsenic
Cadmium
Chromium
Iron
Manganese
mercury
Vanadium
Exposure point
Concentration (ppm)
(Surface/Subsurface)
48.600/51,800
8/3.3
10,8/10.3
121/267
71,800/62,800
2,820/3,810
5,050/1,910
172/268
Associated Risk
Carcinogenic Risk
NA
NA
NA
NA
NA
NA
NA
NA
Noncarcinogenic Risk
0.1
0.02
0.002
0.01
0.3
0.05
1.0
0.03
Total Noncarcinogenic Risk = 2.0
s?
I
H
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evaluate the potential for significant ecological impacts. The screening ecological assessment
indicated the potential for adverse impacts to ecological receptors on and around the facility;
therefore, a qualitative ecological assessment was performed at the Site during the RI. No unique
or sensitive habitats were identified at or near the facility.
The qualitative ecological assessment also indicated the potential for adverse impacts to
ecological receptors on and around the facility.
The ecological assessment evaluated the uptake potential of mercury in fish, earthworms, and
freshwater mussels, and through the use of food chain models, predicted the bioaccumulation
potential to higher-order organisms in the food chain including worm-eating birds, worm-eating
mammals, carnivorous birds, aquatic birds and mammals, and omnivorous mammals. Based on
the food chain models, mercury soil contamination inside and outside the facility fence line, as
well as mercury sediment contamination in the unnamed tributary to Fritz Branch, pose an
unacceptable risk to the ecological receptors inside and outside the facility fence line.
7.3 Current and Potential Future Site and Resources Uses
The complete exposure routes pertinent to the contaminated soil and sediment on or around the
Duracell facility for both current and fixture land use include:
* incidental ingestion of, and dermal contact with, mercury and iron in soil in the northern
and southern site areas, by either a current/future industrial worker or construction
worker;
•*• incidental ingestion of, and dermal contact with, mercury in surface soil, by a current site
visitor in the northern and southern site areas;
* incidental ingestion of mercury in fish by a current/future recreational fisher;
* incidental ingestion of mercury in fish by a current off-site adult and child residents, and
ingestion of aluminum, iron, manganese, mercury, and vanadium in off-site surface soil;
* incidental ingestion of mercury and iron in surface and subsurface soil by a future
construction worker in the northern site area;
* incidental ingestion of iron, mercury, and aluminum in surface soil, by the future
construction worker in the southern site area;
* incidental ingestion of, and dermal contact with iron and mercury in surface soil, by a
future adult resident, in the northern site area;
* incidental ingestion of iron and aluminum in surface soil, by an on-site adult resident, in
the southern site area;
* incidental ingestion of, and dermal contact with mercury and iron in surface soil, by an on-
site child resident, in the northern site area; and
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* incidental ingestion of iron, manganese, aluminum, and mercury in surface soil, by an on-
site child resident, in the southern site area.
It should be noted that aluminum, iron, and vanadium are not considered to be related to the
Duracell facility.
8.0 REMEDIAL ACTION OBJECTIVES
The analytical results from the RI/FS indicate the following areas of concern which need to be
addressed during the Operable Unit One Remedial Action at the Duracell Battery Tech Site.
* On-site surface and subsurface soils in the Northern Site area, the former Plant #2 area,
the former solvent pit area, and the Building #4 sump areas, which contain elevated levels
of mercury, manganese, and volatile organic compounds. The elevated levels of mercury,
manganese, and volatile organic compounds in the soil are of concern as a potential source
of groundwater contamination. In order to address the concerns described above, the
levels of mercury, manganese, and volatile organic compounds need to be reduced to the
remediation levels in order to limit their potential as a future source of groundwater
contamination.
* The elevated levels of mercury identified in the Northern Site area soil would also pose a
potential risk to future construction workers working in this area if left in-place. The
levels of mercury need to be addressed in order to be protective of future construction
workers should they work in this area.
•*• Several small areas located outside the Duracell facility fence line contain elevated levels
of mercury. These areas need to be addressed to eliminate the potential for direct contact
exposures with human beings.
* Analytical results from biota samples indicate potential risk due to earthworms exposed to
elevated levels of mercury in soil both inside and outside the facility fence line. Levels of
mercury in the surface soil in certain areas posed unacceptable risk to worm-eating birds,
worm-eating mammals, and high-order organisms in the food chain. The levels of mercury
in the surface soil need to be addressed to be protective of these ecological receptors.
* Analytical results from biota samples collected in nearby streams indicate potential risk to
macro-invertebrates such as Corbicula, as well as to high-order organisms in the food
chain. In order to address this concern, the levels of mercury in nearby stream sediments
need to be reduced to minimize exposure to mercury, and minimize the bioaccumulation of
mercury in the food chain. The potential still exists that surface water runoff from the Site
may transport elevated levels of mercury into nearby streams. Therefore, engineering
controls such as capping or constructing a retention basin need to be implemented to
minimize future runoff of contaminated soil into nearby streams.
Remedial action objectives were developed based on the results of the Baseline Risk Assessment
(BRA), and the examination of Potential Federal and State Applicable or Relevant and
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Duracell Satiety Tech OU1
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Appropn'ate Requirements (ARARs). ARARs are categorized as action-specific, location-
specific, and chemical-specific. Chemical-specific ARARs for contaminated soil and sediment
include prohibitions on the disposal of certain hazardous wastes based on its chemical
composition. Location-specific ARARs address site-specific conditions such as critical habitat
upon which endangered species or threatened species depend, the presence of a wetland, or
historically significant features. Action-specific requirements are controls or restrictions for
particular activities related to the implementation of a remedial alternative.
Remediation levels were established to reduce the levels of mercury, manganese, and volatile
organic compounds in soil both inside and outside the facility fence line, as well as sediment in the
unnamed tributary of Fritz Branch, in order to be protective of human health and the environment.
The objectives of the OU1 Remedial Action were established in order to be protective of facility
workers (construction and non-construction), as well as to current residents living around the
facility and future hypothetical residents living on the facility.
Remediation levels were also established to reduce the potential for future contamination of
groundwater. Mercury was found to have different migration potentials from soil to groundwater
across the facility. As a result, the mercury remediation levels established for protection of
groundwater range from 42 parts per million (ppm) in the former Plant #2 area to 165 parts per
million in the former solvent disposal area. The remedial level for manganese established for soil
inside the facility fence line for protection of groundwater is 3,080 parts per million. The
remediation levels for the primary volatile organic compounds for soil inside the facility fence line
for protection of groundwater are as follows: tetrachloroethene (0.28 ppm), carbon tetrachloride
(0.15 ppm), methylene chloride (0.29 ppm), trichloroethene (0.48 ppm), 1,1-dichloroethene (0.90
ppm), 1,1-dichloroethane (55.4 ppm), trans-1,2-dichloroethene (7.6 ppm),l,2-dichloroethane
(0.02 ppm), 1,1,2-trichloroethene, (0.49 ppm), l,l,l-trichloroethane(40.5 ppm), chloroform
(0.02 ppm), acetone (32.6 ppm), toluene (186 ppm), xylenes (148 ppm), and PCBs (144 ppm).
The remediation levels for the remaining VOCs in the soil can be found in the Feasibility Study.
Remediation levels were established for mercury in surface soil and sediments in order to
minimize any potential adverse impacts to ecological receptors both inside and outside the facility
fence line. Long-term monitoring of the ecological receptors will also be required as part of the
OUl remedy to verify that adverse impacts to ecological receptors do not exist. If the monitoring
indicates that adverse impacts to ecological receptors are occurring, a change or modification to
that portion of the remedy may be warranted at that time.
The mercury remediation level of 10 parts per million (ppm) in the surface soil will be applied to
certain areas outside the facility fence line in order to minimize any adverse impacts to ecological
receptors, yet minimize destruction of existing habitat in those areas (i.e., avoid clear-cutting of
hardwood forests). In other areas located just to the north of the facility fence line where soil
removals have previously taken place and further destruction of habitat is not an issue, a mercury
remediation level of 5 parts per million (ppm) will be applied to provide protection of ecological
receptors. Applying the 5 and 10 ppm remediation levels for soils inside and outside the facility
fence line are not considered to be fully protective based on the biota data results from the OUl
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Remedial Investigation, but is considered to be a well-balanced response action for several
reasons. First, removing mercury in the soil to 3.5 ppm will greatly reduce the volume of mercury
contamination in the soil without destroying wildlife habitat in the area. Secondly, the long-term
monitoring will be implemented to evaluate any potential adverse impacts to ecological receptors
in the area. Likewise, applying a mercury remediation level of 10 parts per million for surface
soils inside the facility fence line is not considered to be fully protective of ecological receptors.
However, the active manufacturing facility is not considered to be prime feeding habitat, and the
areas of concern inside the fence line are limited.
A mercury remediation level of 3.5 parts per million was also established for sediment around the
facility. The 3.5 ppm sediment remediation level is slightly higher than the EPA Region IV Waste
Management Division Sediment Screening Values for mercury in sediment, which range from
0.15 ppm for "low expected effects", to 1.3 ppm for "moderate expected effects." Nevertheless,
the 3.5 ppm sediment remediation level is considered to be a well-balanced response action for
several reasons. First, the volume of mercury contamination will be greatly reduced in the
unnamed tributary, but minimizing the destruction of existing aquatic habitat. Secondly, long-
term monitoring will be implemented to evaluate the potential for adverse impacts to ecological
receptors. If the monitoring indicates that adverse impacts are occurring, a change or
modification to that portion of the remedy may be warranted at that time.
9.0 DESCRIPTION OF REMEDIAL ALTERNATIVES
The following section provides a summary of the alternatives developed in the Feasibility Study
(FS) report to address the soil and sediment contamination, and ecological concerns, associated
with the Site. Alternatives 2,6, and 7 were eliminated in the Feasibility Study for consideration as
potential remedial alternatives for the Operable Unit One Remedial Action. For this reason, the
following alternatives are numbered as alternativesl,3,4,and 5.
9.1 Alternative 1
CERCLA requires that the no action alternative be evaluated at every site to establish a baseline
for comparison. Under this alternative, no further action would be taken at the Site to remove or
control the Site contamination identified during the Remedial Investigation. The cost of the no
action Alternative 1 is $0. A review of the no action remedy would be conducted every five years
in accordance with the requirements of CERCLA. The costs of the five year reviews are
considered a separate expense from the remedy.
9.2 Alternatives
Alternative 3 would involve selective capping, selective soil vapor extraction, excavation/off-site
disposal of off-site soils (protection of human health only), limited action for ecological concerns.
The total present worth costs for Alternative 3 are estimated to be $3,640,000.
This alternative includes capping of certain on-site areas with elevated levels of mercury and
manganese to address human health concerns, reduce the infiltration potential and mobility of the
contaminants in the soil, and cover those areas inside the facility fence line to address ecological
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Duracell Battety Tech OU1
559
groundwa S0 remeaton Boas for protection of
There would be no treatment of off-site soils and sediments for protection of the ecoloeical end
9.3 Alternative 4
Alternative 4 would involve in-situ stabilization/soUdification and capping of on-site soils in situ
means A treatabuity study would be required to ensure the technology achieves SS
remediation levels established for protection of groundwater and humS l^^Lab
study results indicate the technology does not meet the soil remediation levefs °*J , a toa^
remedy for treatmg SO1Is mside the fence Une would be determined during the remSSgn
The In-situ Bioremediation treatment technology would be used to degrade or metabolize the
•tt^ztttttt&zttS.
would be excavated and transported off-site to an appropriate Subtitle C or D faciUty for
treatment and/or disposal. Land use restrictions, environmental enhancements, storm water
controls, and monitoring would be implemented as part of the remedy.
9.4 Alternatives
£ZS£ZS%££ZZ£^^ •?»-• "* •*«*• --
chemical
sediment* T^**I V ' excavation and off-site disposal of off-site soils and
-^ sediments. The total present worth costs for Alternative 5 are estimated to be $5,270,000.
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Page 60
Selective soils within the fence line with elevated inorganic constituents would be excavated and
transported off-site to a disposal facility for treatment and/or disposal. Selective soils within the
facility fence line with elevated inorganic constituents would be treated with In-situ
Stabilization/Solidification to reduce the mobility of the inorganic constituents by chemical and
physical means. A treatability study would be required to ensure that Stabilization/ Solidification
would reduce the levels of inorganic constituents to meet the established remediation levels. If the
treatability study indicates that the technology does not reduce the levels of inorganic
contamination to meet the established remediation levels, an alternate treatment technology would
be selected at that time. Selective capping of soils within the fence line would also be used to
reduce the mobility of the inorganic constituents in the soil, to meet the remedial action objectives
for protection of human health, and address those areas with ecological concerns.
The In-situ Chemical Oxidation technology would be used to address soils within the fence line
with elevated levels of volatile organic compounds. A treatability study would be required to
ensure that Chemical Oxidation can reduce the levels of organic compounds in the soil to meet the
established remediation levels. Access restrictions, environmental enhancements, storm water
controls, and monitoring would also be employed as part of the remedy.
10.0 CRITERIA FOR EVALUATING REMEDIAL ALTERNATIVES
EPA's selection of the preferred alternative for the Operable Unit One Remedial Action at the
Duracell Battery Tech Site, as described in this Record of Decision, is the result of a
comprehensive evaluation and screening process. The Feasibility Study for Operable Unit One
was conducted to identify and analyze the alternatives considered for addressing the
contamination. The Feasibility Study for Operable Unit One describes, in detail, the alternative
considered, as well as the process and criteria EPA used to narrow the list to potential remedial
alternatives to address the Site contamination.
EPA always uses the following nine criteria to evaluate the alternatives identified in the Feasibility
Study. While overall protection of human health and the environment is the primary objective of
the remedial action, the remedial alternative selected for the Site must achieve the best balance
among the evaluation criteria considering the scope and relative degree of the contamination at
the Site.
1.) Overall protection of human health and the environment - EPA assesses the degree to
which each alternative eliminates, reduces, or controls the threats to public health and the
environment through treatment, engineering methods or institutional controls.
2.) Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) -
The alternatives area evaluated for compliance with all State and Federal environmental
public health laws and requirements that apply or are relevant and appropriate to Site
conditions.
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Daracell Batteiy Tech OU1
Page 61
3.) 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 remediation
levels have been met.
4.) Reduction of Contaminant Toxicity. 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; (3) the volume or amount of contamination a the
Site.
5.) 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.
6.) Implementabilitv - 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. Cost includes the capital (up-front) cost of implementing an
alternative over the long-term, and the net present worth cost of both capital and
operation and maintenance costs.
8.) State Acceptance - EPA requests State comments on the documents produced during the
RI/FS, including the Remedial Investigation, Baseline Risk Assessment, Feasibility Study,
and Proposed Plan, and must take into consideration the State's comments on EPA's
preferred alternative.
9.) Community Acceptance - To ensure theat the public has an adequate opportunity to
provide input, EPA holds a public comments period and considers and responds to all
comments received from the community prior to the final selection of a remedy.
11.0 COMPARISON OF THE ALTERNATIVES
The following summary profiles the performance of each alternative in terms of the nine
evaluation criteria noting how it compares to the other alternatives under consideration. Table 18
shows a comparative analysis of the alternatives..
Alternative 1 would not be protective of human health and the environment because no active
remedial action would not address the contamination. As a result, the unacceptable risks outlined
in the "Summary of Site Risks" section described above would not be reduced. Soil
contamination within the fence line would be left in-place as a source of groundwater
contamination, and a potential health threat to facility workers. Soil and sediment contamination
outside the fence line would be left in-place and potentially cause adverse impact to ecological
receptors. By comparison, Alternatives 3, 4, and 5 would provide a combination of remedial
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Duracell Battery Tech GUI
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technologies, access restrictions, environmental enhancements, storm water controls, and long-
term monitoring. These alternatives would therefore reduce soil contamination within the fence
line to be protective of groundwater and facility workers.
Alternative 3 would not be protective of ecological receptors since it would not address the
mercury contamination in the soil and sediment contamination inside and outside the fence line.
Alternatives 4 and 5 would be protective of ecological receptors since the soil and sediment
contamination inside and outside the fence line would be addressed.
A complete summary of the State and Federal ARARs is shown in Table 19. The No Action
Alternative 1 does not comply with the ARARs. By comparison, Alternatives 3, 4, and 5 comply
with the ARARs.
Alternative 1 - the No Action Alternative - would not provide long-term effectiveness because the
contamination would remain at the Site; therefore, the risks associated with the contamination
would remain in place indefinitely. By comparison, Alternatives 3, 4, and 5 would provide long-
term effectiveness because the inorganic soil contamination at the Site would either be excavated
and removed from the Site, or treated with Stabilization/Solidification or Capping. The organic
contamination in the soil would be treated with Soil Vapor Extraction, In-Situ Bioremediation, or
Chemical Oxidation. The contaminated soils and sediments would be addressed for ecological
concerns by capping the areas of concern inside the fence line. Soils and sediments outside the
fence line would be excavated and transported off-site for treatment and/or disposal.
The No Action Alternative 1 would not provide a reduction in the toxicity, mobility, or volume of
any contaminants at the Site. By comparison, Alternatives 3, 4, and 5 would provide reductions
in the mobility of the inorganic contaminants through stabilization/solidification of the
contaminants, the toxicity and volume of the organic contaminants through chemical oxidation.
The mobility of the contaminants would be further reduced by capping the areas.
Alternatives 3 and 4 would reduce the toxicity and volume of the volatile organic compound soil
contamination through the use of Soil Vapor Extraction or In-Situ Bioremediation. Alternative 5
would also reduce the toxicity of volatile organic compound contamination in the soil through the
use of the Chemical Oxidation technology. However, Alternatives 3, 4, and 5 would not reduce
the toxicity of the inorganic soil contamination.
Alternatives 4 and 5 would potentially increase the volume of the inorganic contamination
through treatment with stabilization/solidification. Alternative 5 would partially reduce the volume
of the inorganic contamination inside and outside the facility fence line through excavation and
off-site disposal.
Alternative 1 would not have short-term effectiveness because no action would be taken to reduce
the risks from the contamination. By comparison, worker and public exposure would be limited
in Alternatives 3,4, and 5 through the implementation of institutional and engineered controls.
However, greater potential worker and public exposure would increase over the short-term during
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Table 18 Comparative Analysis of Alternatives
Duracell U.S.A., Lexington, North Carolina
Criteria
Alternilivc 1
No Action
Alternative 3
Cap (On-site Soil -
Inorganics), Selective
SVE (On-site Soil-
Organics), Excavate
and Dispose (Off-site
Soils—Human
Health RAOs),
Limited Action (Off-
site Soils and
Sediments—
Ecological RAOs)
Alternative 4
In-situS/S
(On-site Soil-
Inorganics), In-situ
Bio-remediation (On-
site Soil — Organics),
Excavate and Dispose
(Off-site Soil and
Sediments)
Alternative 5
Selective Excavation and Off-site
Landfill, Selective In-situ SIS,
and Selective Capping (On-Site
Soils-Inorganics), In-situ
Chemical Oxidation (On-sile
Soil- Organics), Selective
Removal (Off-Site Soils, and
Sediments)
Threshold Criteria
Overall Protection of
Human Health and
the Environment
Not Protective Protective
Protective
Protective
Compliance with
ARARs
Does not meet Meets all ARARs
ARARs
Meets all ARARs
Meets all ARARs
Bala»ciMg Criteria
Long-Term
Effectiveness and
Permanence
Not effective Effective in isolating
COCs from public
and environmental
receptors. Long-term
reliability would be
high with continued
maintenance. Long-
term environmental
impacts would be
minimal.
Effective in isolating
COCs from public and
environmental
receptors. Greater
long-term reliability
for on-site media than
Alternative 3 due to
stabilization of COCs
followed by capping.
Maintenance
requirement would be
reduced. Long-term
environmental Impacts
Effective in isolating COCs from
public and environmental
receptors. Less residual risk
than in Alternatives 3 and 4 due
to selective removal from the
Site. 1 xing-term environmental
impacts could be substantial
since off-site habitats (including
wetlands) within the prescribed
area could be destroyed or
degraded for 10 (o 50 years.
-81
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Table 18 Comparative Analysis of Alternatives
Duracell U.S.A., Lexington, North Caralina
could be substantial
since off-site habitats
(including wetlands)
within the prescribed
area could be
destroyed or degraded
for 10 to 50 years.
Criteria
Alternative! Alternative 3
No Action Cap (On-site Soil -
Inorganics), Selective SVE
(On-site Soil - Organics),
Excavate and Dispose (Off-
site Soils—Human Health
RAOs), Limited Action (Off-
ale Soils and Sediments—
Ecological RAOs)
Alternative 4
In-sllu Stabilization
/Solidification With Cup
(On-site Soil -
Inorganics), In-situ Bio-
remediation (On-site Soil
— Organics), Excavate
and Dispose (Off-site
Soil and Sediments)
Alternative 5
Selective Excavation and Off-site
Landfill, Selective In-situ SIS,
and Selective Capping (On-Sile
Soils-Inorganics), In-situ
Chemical Oxidation (On-site
Soil- Organics), Selective
Removal (Off-Site Soils, and
Sediments)
Reduction of Toxicity,
Mobility, and Volume
Through Treatment
No treatment. Capping on-sitc media will
No reduction, effectively reduce mobility.
Toxicity and volume will only
be reduced through treatment
of organics (not inorganics).
S/S would effectively
reduce mobility, but would
not reduce toxieity. The
volume could be expected
to increase by 15 to 30
percent. Toxicity and
volume would only be
reduced through treatment
of organics (not
inorganics).
Capping or S/S would effectively
reduce mobility, but would not
reduce toxicity. Toxicity would
only be reduced through treatment
of organics (not inorganics).
Selective excavation would provide
no reduction ofCOC mobility or
toxicity through treatment. The
removed volume would be
relocated without treatment unless
determined to be necessary.
Short-Term
Effectiveness
Not effective Effective. Worker and public
exposure to COCs would be
limited through the
implementation of institutional
Effective. Implementation
would result in limited
exposure to workers.
Short-term off-site
Effective. While protective of
workers and the public,
implementation would result in
greater risk to both. RA would
•if
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Table 18 Comparative Analysis of Alternatives
Duracell U.S.A., Lexington, North Carolina
and engineered controls. Since
the COCs remain in place, no
handling of the COCs is
involved in this alternative.
Short-term environmental
impacts arc minor. Most orT-
sitc habitats would be
protected. Duration of RA
would be approximately six
months for capping and five
years for SVE. Duration of
limited action would be
approximately ten years as
dictated by five-year reviews.
environmental impacts
could be extensive since
off-site habitats (including
wetlands) within the
prescribed area could be
destroyed or degraded for
10 to 50 years. Duration
of RA would be
approximately six months
for S/S, one year for off-
site excavation and 10 to
15 years for bio-
rcuicdiation.
involve substantial waste handling
and transportation. Access
controls, and site-specific Health
and Safety Plan would keep this RA
protective. Short-term
environmental impacts could be
extensive since off-site habitats
(including wetlands) within the
prescribed area could be destroyed
or degraded for 10 to 50 years.
Duration of RA would be
approximately six months for on-
sitc excavation, one year for off-site
excavation, and six months for
chemical oxidation.
Criteria
Alternative 1 Alternatives
No Action Cap (On-site Soil -
Inorganics), Selective SVE
(On-site Soil - Organics),
Excavate and Dispose (Off-
site Soils—Human Health
RAOs), Limited Action (Off-
site Soils and Sediments —
Ecological RAOs)
Alternative 4
In-situ Stabilization
/Solidification With Cap
(On-site Soil-
Inorganics), In-situ Bio-
remediation (On-site Soil
— Organics), Excavate
and Dispose (Off-site
Soil and Sediments)
Alternatives
Selective Excavation and Off-site
Landfill, Selective In-situ S/S,
and Selective Capping (On-Site
Soils-Inorganics), In-situ
Chemical Oxidation (On-site
Soil- Organics), Selective
Removal (Off-Site Soils, and
Sediments)
Implcmcntability
N/A
Feasible. All activities would be
conducted using conventional
and readily available
construction methods,
equipment, and services.
Feasible. The S/S
technologies arc well
demonstrated. Typical
applications require
conventional material
handling equipment that
would be readily available.
Most of the reagents and
Feasible. All activities would be
conducted using conventional and
readily available construction
methods, equipment, and services.
Administrative feasibility would be
moderately difficult because of
logistics of large waste volume.
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Table 18 Comparative Analysis of Alternatives
Duracel! U.S.A., Lexington, North Carolina
additives used would be
widely available and
relatively inexpensive.
Administrative feasibility
would be moderately
difficult because of
logistics of large waste
volume.
Present Worth Cost
No Cost
$3.640.000
SS.370.000
$5,270.000
i
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Table 19 State Chemical Specific ARAKj
Duracell U.SA., Lexington, North Carolina
Standard, Requirement or
Limitation
NORTH CAROUNA HAZARDOUS
WASTE MANAGEMENT •
Identification and Listing of
Hazardous Waste
Citation
Title ISA NCAC
Subchapter 13A
Section 13A.0006
Description
Provides numerical criteria to determine
those solid wastes that are subject to
Alternatives
for which
ARARsar*
Applicable or
Relevant and
Appropriate
3,4,5
Comments
Potentially applicable to remedial
actions involving solid waste removal
Treatment Standards
Graundwater Classification and
Standards
Maximum Contaminant Levels in
Ground Water
Section 13A.0112
Title ISA NCAC
Subchapter 2L
Sections 2L0100,.
0201
and .0202
regulations as hazardous wastes.
Provides numerical treatment standards 3,4,5
for hazardous wastes or hazardous waste
extracts before land disposal is allowed.
Establishes numerical standards for 3,4,5
ground water quality based on best usage.
in the identification of wastes and
application of other action-specific
ARARs
Potentially applicable to remedial
actions involving disposal of
hazardous waste
Soils remaining on-site must be
protective of ground water or surface
water as a potable water supply.
CLASSIFICATIONS AND WATER
QUALITY STANDARDS
APPLICABLE TO SURFACE
_ WATERS OF NORTH CAROLINA
Classification and Water Quality
Standards applicable to Surface
Water and Wetlands in North
Carolina ..._
Tide ISA NCAC
Subchapter 2B
Section 28.0100
and .0200
Establishes a series of numerical standards 3,4,5
for surface water and wetland quality.
Potentially applicable to remediation
of and impacts to surface waters and
wetlands.
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TaWe 19 State aiemiealSpfdflc AMR* (Con fd.)
Dtiratetl tM.A, Lexington, North Carolina
Standard, Requirement, or Citation Description
Limitation
Alternatives
for which
ARARaare
Applicable or
Relevant and
Appropriate
Comments
NORTH CAROLINA AMBIENT
AIR QUALITY CONTROL ACT
Ambient Air Quality Standards
Emissions Control Standards
Control of Toxic Air Pollutants
Title 15ANCAC
Subchapter2Dand2H
SubchaplerZD
Section .0400
Subchapter2D
Section .0500
Subchapter2D
Section .1100
Establishes ambient air quality standards 3,4,5
for sulfur dioxide, total suspended
particulates, PM10, carbon monoxide,
ozone, nitrogen dioxide, etc.
Establishes emission standards for seven 3,4,5
contaminants - benzene, mercury, arsenic,
asbestos, beryllium, vinyl chloride, and
radionuclida.
Establishes air toxic threshold 3.4,5
concentrations.
Potentially applicable if air emission
releases are involved in soil or
sediment treatment/remediation.
Not applicable to remediation
' activities at Site because regulated
activities are not performed at the
Site; however, is relevant and
appropriate to SVE.
Potentially applicable if air emission
releases are involved in soil or
sediment treatment/ remediation.
Must meet substantive requirements.
I
CD
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Table 19 Federal Chemical Specific ARARs
Duracell U.SA., Lexington, North Carolina
Standard, Requirement, or
Limitation
Citation
Description
Alternatives
for which
ARARs are
Applicable or
Relevant and
Appropriate
Comments
RESOURCE
CONSERVATION AND
RECOVERY ACT
Identification and Listing of
Hazardous Waste
Treatment Standards
42 USC 6901
40CFR261
SubpartC
40CFR268
SubpaitD
Provides numerical criteria to 3,4,5
determine those solid wastes that are
subject to and regulated as hazardous
wastes.
Provides numerical treatment 3,4,5
standards for hazardous wastes or
hazardous waste extracts before land
disposal is allowed. ^^
Potentially applicable to
remedial actions involving solid
waste removal in the
identification of wastes and
application of other action-
specific ARARs.
Potentially applicable to
remedial actions involving
disposal of hazardous waste.
SAFE DRINKING WATER 42 USC 300
National Primary Drinking 40 CFR141
Water Standards
National Secondary Drinking 40 CFR 143
Water Standards
Establishes health-based enforceable 1,3,4,5
standards for public water systems
(maximum contaminant levels
(MCLs))
Establishes aesthetic-based, non-
enforceable guidelines for public
water systems (secondary maximum
contaminant levels (SMCLs))
1,3,4,5
Soils remaining on-site must be
protective of ground water or
surface water as a potable water
supply.
Soils remaining on-site must be
protective of ground water or
surface water as a potable water
supply.
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Table 19 Federal Chemical Specific ARARs(Co»t'iJ.)
Duracell USA., Lexington, North Carolina
Standard, Requirement, or Citation
Limitation
Maximum Contaminant Level 40CFR141
Goals
CLEAN WATER ACT
Ambient Water Quality
Criteria (AWQQ
Point Sources
CLEAN AIR ACT
National Primary and
Secondary Ambient Air
Quality Standards
33 USC1251-1376
40CFR131
40 CFR Part 400
42 USC 1857-18571
40 CFR Part 50
Description
Establishes non-enforceable drinking
water quality goals (MCLGs) set at
levels that cause no known or
anticipated adverse health effects
with an adequate margin of safety
without consideration of available
treatment technology or cost.
Alternatives
for which
ARARa are
Applicable or
Relevant and
Appropriate
1,3,4,5
Establishes criteria for water quality
goals set at levels of no known or
anticipated adverse health effects.
Establishes pretreatment
concentrations.
Sets primary and secondary air
standards at levels to protect public
health and public welfare.
3,4,5
3,4,5
3,4,5
Comments
Soils remaining on-site must be
protective of ground water or
surface water as a potable water
supply.
The AWQC for organic and
inorganic constituents are
relevant and appropriate for
remedial actions involving
streams and tributaries.
Potential for any POTW
discharge of surface water and
decontamination water.
Potentially applicable to any
remedial action that releases
regulated pollutants to the air.
Duracetl
P
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Table 19 Federal Chemical Specific ARARs
Duracell U.SA., Lexington, North Carolina
Standard, Requirement, or Citation
Limitation
Description
Alternatives
for which
ARARs are
Applicable or
Relevant and
Appropriate
Comments
National Emission Standards 40CFRPart61
for Hazardous Air Pollutants
FOOD AND DRUG
ADMINISTRATION
Maximum level of methyl
mercury in seafood products
(edible portion)
FDA 1984 (CPG
7108.07)
Establishes emission standards for
seven contaminants - benzene,
mercury, arsenic, asbestos, beryllium,
vinyl chloride, and radionuclides.
Establishes 1.0 gpm as the maximum
concentration in seafood.
3,43 Not applicable to remediation
activities at Site because
regulated activities are not
performed at the Site; however,
is relevant and appropriate to
activities, including SVE.
1,3,4,5 Based on most recent surveys
the mercury body burned in fish
does not exceed the 1.0 ppm
limit
Ii
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Duracell Battery Tech OU1
implementation of Alternative 5 due to the substantial volume of contaminated soil inside the
facility fence line, as well as sediment outside the facility fence line requiring excavation and off-
site transportation.
The ecological habitats on and around the Site would not incur short-term damage if Alternative 3
were selected since there would be no excavation of soils or sediments outside the facility fence
line. The ecological habitats outside the facility fence line would incur short-term damage if
Alternative 4 or 5 were selected since both alternatives involve the excavation of soils and
sediments located both inside and outside the facility fence line. The Implementability criterion
does not apply to Alternative 1. Alternatives 3,4, and 5 are all feasible, and would be conducted
using conventional and readily available construction methods and services. Administratively,
Alternatives 4 and 5 would be moderately difficult to implement due to the large volumes of '
waste.
Since Alternative #1 does not use any type of active or limited remediation, there are no costs
associated with this alternative. The present worth costs for Alternative 3,4 and 5 are
$3,640,000, $5,370,000, and $5,270,000, respectively.
EPA and the North Carolina Department of Environment and Natural Resources (NCDENR)
have participated in the decision-making process throughout the RI/FS process for OU1.
NCDENR has participated in the development of the RI/FS through comment on each of the
various reports developed by EPA, and the Draft ROD and through frequent contact between the
EPA and the NCDENR Site project manager. EPA and NCDENR are in agreement on the
selected remedy. Please refer to the Responsiveness Summary which contains a letter of
concurrence from NCDENR.
EPA solicited input from the community on the Proposed Plan for this action. Although public
comments indicated no opposition to the preferred alternatives, some local residents expressed
some minor concerns during the Proposed Plan public meeting. Please see the Responsiveness
Summary which contains a transcript of the public meeting.
12.0 THE SELECTED REMEDY
After conducting a detailed analysis of all the feasible remedial alternatives based on the criteria
described in the previous sections, EPA selected Alternative 5 as a comprehensive, multi-
component remedy to address soil and sediment contamination, including:
* selective excavation and off-site disposal of soils contaminated with inorganic constituents
(i.e., mercury and manganese) located inside and outside of the facility fence line;
* selective in-situ stabilization/solidification of soils contaminated with inorganic
constituents (i.e., mercury and manganese) in the former Plant #2 area;
* in-situ chemical oxidation of soils contaminated with VOCs (i.e., tetrachloroethene,
trichloroethene, carbon tetrachloride, methylene chloride, 1,1- dichloroethene, 1,1-'
dichloroethane, 1,2-dichloroethane, 1,1,2-trichloroethane, 1,1,1-trichloroethane,'trans-1,2-
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Duracell Battery Tech OU1
dichloroethane, chloroform, acetone), as well as toluene, xylenes, and PCBs in the former
solvent disposal area;
* capping of several areas inside the facility fence line (including the former Plant #2 area
and the former solvent disposal area);
* excavation and off-site disposal of mercury-contaminated sediments located in the upper
2000 feet of the unnamed tributary; and
* land use restrictions, environmental enhancements, storm water controls, and long-term
monitoring.
The remedial action objectives of Alternative 5 are to:
1) reduce levels of inorganic contamination in the soil both inside and outside of the
facility fence line, thereby minimizing the potential risks to current residents living around
the facility, and to future hypothetical residents living on the facility;
2) reduce the levels of inorganic contamination in the soil inside the facility fence line,
thereby minimizing the potential risks to future construction and non-construction workers
at the facility;
3) reduce the levels of organic and inorganic contamination in the soil inside the facility
fence line, thereby minimizing the potential for future ground water contamination;
4) capping of several areas of concern inside the facility fence line, thereby eliminating any
potential risks to humans due to direct contact exposures, minimizing the potential for
future leaching of contaminants from soil into ground water, and minimizing the potential
for future adverse impacts to ecological receptors;
5) reduce the levels of inorganic contamination in the soil and sediment outside the facility
fence line, thereby minimizing the potential for future adverse impacts to ecological
receptors;
6) establishing institutional controls such as future land use restrictions for the areas of
concern at the facility, thereby eliminating the potential risks associated with the facility
being used for residential purposes (more detail will be provided in the Remedial Design);
7) establishing environmental enhancements such as sediment traps to minimize the
potential for future runoff of soil contamination into nearby surface water pathways; and
8) long-term monitoring (including but not limited to monitoring required for the 5-year
reviews) of the areas of concern, as well as ecological receptors, to ensure the long-term
effectiveness of the selected remedy.
Soil remediation levels were established to reduce the levels of mercury, manganese, and VOCs in
soil both inside and outside the facility fence line, as well as sediment in the nearby unnamed
tributary of Fritz Branch. The objectives of the OU1 Remedial Action include protecting current
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and future workers on the facility (construction and non-construction), as well as current residents
living around the facility and future hypothetical residents living on the facility. Mercury was
found to have different migration potential from soil to ground water across the facility. As a
result, the mercury remediation levels established for protection of ground water range from 42
part per million (ppm) in the former Plant #2 area to 165 ppm in the former Solvent Disposal area.
The remediation level for manganese inside the facility fence line for protection of ground water is
3,080 ppm. The remediation levels for the primary volatile organic compounds in the former
solvent disposal area for the protection of ground water are as follows: tetrachloroethene (0.28
ppm), carbon tetrachloride (0.15 ppm), methylene chloride (0.29 ppm), trichloroethene (0.48
ppm), 1,1-dichloroethene (0.90 ppm), 1,1-dicbloroethane (55.4 ppm), 1,2-dichloroethane (0.02
ppm), 1,1,2-trichloroethane (0.49 ppm), 1,1,1-trichloroethane (40.5 ppm), trans-1,2-
dichloroethene (7.6 ppm), chloroform (0.02 ppm), acetone (32.6 ppm), toluene (186 ppm),
xylenes (148 ppm), and PCBs (144 ppm). The remediation levels for any remaining VOCs can be
found in the Feasibility Study.
A remediation level of 10 parts per million (ppm) was established for mercury in surface soil for
certain areas inside and outside the facility fence line in order to minimize any adverse impacts to
ecological receptors, yet minimize destruction of existing habitat in those areas (i.e., avoid clear-
cutting of hardwood forests). In other areas located just to the north of the facility fence line
where soil removals have previously taken place and further destruction of habitat is not an issue,
a mercury remediation level of 5 ppm will be applied to minimize any adverse impacts to
ecological receptors. Applying the 5 and 10 ppm soil remediation levels is considered to be a
well-balanced response action for several reasons. First, selectively removing mercury in the soil
from 5 tolO ppm will greatly reduce the volume of mercury contamination in the soil without
destroying the wildlife habitat in the area. Secondly, the long-term monitoring required as part of
this remedy will be implemented to evaluate any potential adverse impacts to ecological receptors
in the area. If the long-term monitoring indicates that adverse impacts are occurring after the soil
has been removed, additional response action(s) may be warranted at that time in order to
minimize any adverse impacts to ecological receptors.
A mercury remediation level of 3.5 parts per million (ppm) was established for sediment around
the facility. The 3.5 ppm remediation level is slightly higher than the EPA Region IV Waste
Management Division Sediment Screening Values for mercury in sediment, which range from
0.15 ppm for "low expected effects", to 1.3 ppm for "moderate expected effects". Nevertheless,
the 3.5 ppm sediment remediation level is considered to be a well-balanced response action for
several reasons. First, the volume of mercury contamination will be greatly reduced in the upper
2000 feet of the unnamed tributary of Fritz Branch where mercury in sediments was found to
exceed 3.5 ppm, the destruction of existing aquatic habitat will be minimized. If the long-term
monitoring required as part of this remedy indicates that adverse impacts are occurring after the
sediment has been removed, additional response action(s) may be warranted at that time in order
to minimize any adverse impacts to ecological receptors.
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Duracell Battery Tech OU1
Treatability studies will be required to ensure the in-situ solidification/stabilization and the
chemical oxidation remedies will reduce the levels of inorganic and organic constituents in the
soil, respectively, to meet the remediation levels provided in this Record of Decision. Treatment
standards will be established during the remedial design prior to the initiation of each treatability
study. Upon completion of each treatability study, if the treatment standards are met, in-situ
solidification/stabilization and chemical oxidation will be applied full-scale. If the treatment
standards are not attained during the treatability studies, an alternate remedy will be selected at
that time to address the organic and/or inorganic soil contamination.
The total present worth costs for Alternative 5 are estimated to be approximately $5,270,000,
based on capital costs (including contingency costs) of $1,775,000, annual operation and'
maintenance costs and monitoring costs of $20,000 per year for 30 years for the facility property
monitoring costs of $25,000 per year for 2 years for property outside the facility fence line, and a
discount rate of 5%. Table 20 shows the estimated costs for Alternative 5.
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Duracell Batteiy Tech OU1
Paee76
Table 20 - Estimated Costs for Alternative 5
UnttOwt
W
total rnM»t
odi
•m
BIMAN HEALTH
UXBCT COSTS
Sd.rm«&«»v»Uo««jUlrH.po—l«a to • Kit. W»H IUnc
Stomwtkw Contrail
Stladin fltaWltaHMv O«-Sttt
SoildJnarioo/SfcMlutio* (A«JOT, BMch Pk»t Kngwito)
KoUllulfcn o*E^«lp«i«n«
Stommlx CenOob
Ovom OpvnMonfl
Subtotal
lump kuch Uckhix. eonpictoa, «iic.v>hlclo)
- j,h«ll(.ppo«.l«n«>
SkumMMK Conlrab (kkoc cnrcnlihl / kd to UndM
Stotmwtltr Conltoli
OtWl Direct C—to
c Mak / Dmok / SIM Fnp
P>y«ttnt* Piifonunn Bondi
r«tal HMm«n
2
MOO
200
3,375
2
3,900
300
3JOO
1SOO
1
1
1
1
12
1
S10
1
1
1
4
2400
1
1
1
600
750
05
900
(00
600
1
1
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Duracdl Battery Tech OU1
Table 20 (Cont) - Estimated Costs for Alternative 5
WoAIto.
«7
Unit
tTnltCort
(S)
TotJh»«<
Worth Co*
(S)
ECOLOGICAL
Enavat* tut DbpeM (OfMte Sail*)
O«.i*«UKlGnbMxc
EUndflll
GonfimallonSuYiphiK
DbpoMlSutflinc
Puttand Vapor Suppccttlon
SMmwiM Controb
Sukuul (roiuuUd
SdecHtc Op SyttM. (OMih Sail.)
Ckuinc.Stoclcpakl* Ruling
CcofibHc (Twchu* u>k>tav«iii(ht/Bnt^ MmoraMd.)
Dkpoal Ti.~port.Soci to IjuvifiB (Snlninli Only)
Dmtand VaporSuppteMion
StanmralH Conttob
SubloUl (raiudxl)
SubtoUI Dlnrt OM> (H.««n Hulth » EooIngUxl) (tnnd.d)
INDDECT COSTS
CbnrtzKtlonUuMgramt/ FnjKt AdalnMnUon
••MdlilDBfen
WokFUra
Subtoul
ANNUAL 0*M COSTS
CipMilmmmai
SuWolJ (rnNDt Worth)
SHORT TEKM MONTIORINC
OivSiUCAP
Ofl>U>py«n)
Subtotal (TnMM Wortfc)
AlmnMi5ZMK>kdCoM(nMi
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Duracell Ballcry Tech OU1
Rage 78
Table 21 summarizes the remediation levels for the organic and inorganic contaminants in soil and
sediment.
Table 21 - Summary of Remediation Levels for Soil and Sediment
Chemical of
Concern
mercury
manganese
PCBs
carbon tetrachloride
tetrachloroethene
Remediation Level
(ppm) - (Media) -
Location
42 - (soil) - Former
Plant #2 area
165 - (soils) -Former
Solvent Disposal area
+ Building #4 Sump
area
69 - (soil) - Northern
Site area
5 - (soil) - applied in
areas where habitat
destruction is not an
issue
10 - (soil) - applied in
areas where habitat
destruction is an issue
3.5 - (sediment) - in
upper 2000 feet of
unnamed tributary of
Fritz Branch
3080
144
0.15
0.28
Basis for
Remediation Level
protection of ground
water, risk assessment
protection of ground
water, risk assessment
protection of ground
water, risk assessment
ecological risk
assessment
ecological risk
assessment
ecological risk
assessment
protection of ground
water
jrotection of ground
water
jrotection of ground
water
'rotection of ground
water
Risk at
Remediation
Level
ffl < 1.0
ffl<1.0
HK1.0
NA
NA
NA
NA
NA
NA
NA
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Table 21 (Cont.) - SummarvofRem.H{a^» Levels for SoiJ
Chemical of Remediation Level
Concern
trichloroethene F 0.48
methylene chloride I 0.29
1,2-dichloroethane | 0.02
^•^™^»
40.5
protection of ground | NA
water
protection of ground J NA
water
protection of ground J NA
water
protection of ground J NA
water
trichloroethane
trans- 1,2-
dichloroethene
protection of ground |NA
water
1,1 -dichloroethane 55.4
MM^^^B
0.49
••••••
1,1 -dichloroethene | 0.9
——_^___
chloroform 0.02
:—
xylenes | 145
protection of ground J NA
water
1,1,2-trichloro-
ethane
protection of ground j NA
water
protection of ground j NA
water
protection of ground NA
water
protection of ground NA
water
protection of ground NA
water
protection of ground J NA
water
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Duracell Battery Tech OU1
Table 22 - Description of Source Areas to be Remediated
Name of Source Area
Former Plant #2 Area
Former Solvent Disposal
Area
Northern Site Area
Building #4 Sump Area
Sediment in the Unnamed
Tributary
ea
i
osal
ea
med
Size of Source An
5,850
4,900
6,750
900
2,000 linear feet*
Volume of Soil to be
Remediated (yd3) +
(contaminant(s) of concern)
3,690 (mercury)
1,720 (mercury, manganese,
andVOCs)
1,570 (mercury, manganese)
1,410 (mercury)
700-900 (mercury)
Alternative 5 should reduce the risk within a reasonable time frame and provide for long-term
reliability of the remedy. Alternative 5 also allows the property to be used for the reasonably
anticipated future land use. Therefore, based on current information, Alternative 5 appears to
£? A 'Jv balance With respect to the nine criteria that EPA uses to evaluate alternatives
S6leCted altemative wiu satisfV the statutory requirements of Section 121(b) of
USC 962 l(b).
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 the environment. As a result of these
5-year reviews, if needed, additional site remediation or modifications to the remedy would be
performed. y
13.0 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
reduce the volume, toxicity, or mobility of hazardous waste as their principal element The
following sections discuss how this remedy meets these statutory requirements.
EPA's selected remedy for Operable Unit One at the Duracell Battery Tech Site protects human
health and the environment through:
* reducing the potential of non-cancer risks to current residents living around the facility
future hypothetical residents living on the facility, and future construction and non- '
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Duiacell Battery Tech OU1
Page 81
construction workers on the facility (non-carcinogenic risk levels reduced below a hazard
index value of 1.0);
* reducing the potential for future ground water contamination resulting from the leaching
of contaminants from soil to ground water; and
* reducing the potential of potential adverse impacts to ecological receptors both on and
around the facility.
The selected remedy shall be in full compliance with all applicable or relevant and appropriate
requirements (ARARs). The estimated present worth cost for the Selected Remedy is
$5,270,000. 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(i)(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.
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.
Of those alternatives that are protective of human health and the environment and comply with
ARARs, EPA and NCDENR have determined that the selected remedy provides the best balance
of trade-offs in terms of long-term effectiveness and permanence, reduction of toxicity, mobility,
or volume achieved through treatment, short-term effectiveness, implementability and cost, while
also considering the statutory preference for treatment as a principal element and considering
State and community acceptance.
The selected OU1 remedy addresses principal threats posed through the use of in-situ
solidification/stabilization to treat soil in the former Plant #2 area contaminated with mercury and
manganese, and in-situ chemical oxidation to treat soil in the former solvent disposal area
contaminated with VOCs. By utilizing treatment as a significant portion of the remedy, the
statutory preference for remedies that employ treatment as a principal element is satisfied.
Because this remedy will result in hazardous substances remaining on-site above levels that allow
for unlimited use and unrestricted exposure for a long period of time, a review will be conducted
within five years after initiation of 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.
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APPENDIX A - RESPONSIVENESS SUMMARY
EPA received a total of two letters from the general public during the thirty-day comment period.
As the Remedial Project Manager for the Duracell Battery Tech site, I am providing the following
responses to the comments provided in those two letters.
Comment #1 - Mr. David Kinney sent a letter to EPA-Region IV dated August 23, 1999, in
which he expressed concerns about eating vegetables from his garden. He also asked if his
property is contaminated?
EPA Response - No samples have been collected and analyzed from your property during the
Remedial Investigation. For this reason, I can not tell you whether the soil on your property is
contaminated as a result of historical releases from the Duracell facility, or any other facility
located upstream in the Lexington area. For the same reason, I can not determine if the vegetables
from your garden are safe to eat. However, based on the sample results from the Remedial
Investigation, there is no reason to believe that your property has been impacted by the Duracell
facility.
Comment #2 - The letter sent to EPA-Region IV from Yadkin, Inc., dated August 20 ,1999 in
which Mr. Gene Ellis stated his concerns regarding the 3.5 parts per million remediation level for
sediment. Mr. Ellis would like to know whether a lower sediment remediation level was
considered, as well as what remedial objective for mercury in sediments would be "fully
protective" of ecological receptors and what the associated costs are for this objective.
EPA Response - Before deciding on the sediment remediation level, EPA and the North Carolina
Department of Environment and Natural Resources (NCDENR) evaluated the feasibility of
applying a lower sediment remediation level, including how much sediment removal would be
required, the potential impacts of the removal on the ecosystem, and the costs associated with the
removal. The evaluation indicated that selecting a sediment remediation level lower than 3.5 ppm
would require removing a much larger volume of sediment from the unnamed tributary of Fritz
Branch to High Rock Lake, including the isolated occurrences of mercury mentioned in your
letter. Implementing a massive sediment removal could potentially re-suspend isolated
occurrences of mercury, and potentially destroy existing aquatic habitat over large areas.
EPA-Region IV does not consider the 3.5 ppm sediment remediation level to be "fully protective"
because it is slightly higher than the EPA Region IV Waste Management Division Sediment
Screening Values for mercury in sediment, which range from 0.15 ppm for "low expected effects"
to 1.3 ppm for moderate expected effects". However, EPA and the NCDENR believe the 3.5
ppm sediment remediation level is a well-balanced response action for several reasons. The
Remedial Investigation indicates the majority of the mercury is located in the upper 2000 feet of
the unnamed tributary of Fritz Branch. Implementing the 3.5 ppm remediation level will greatly
reduce the amount of mercury in the unnamed tributary, while minimizing the destruction of
existing aquatic habitat and the amount of re-suspended sediment. The long-term monitoring
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Duracell Battery Tech OU1
;83
remedy wiu be **"•" to evaluate the potential for
inne°rd°f ecis™
action
SZ
renSy
nen°rdH°f ?ecis™Mcl"des co^°^ ««* as silt curtains as part of the sediment removal
n in order to minimize the potential for re-suspension of sediments. While EPA can not
0068 regafdin8 P?tCntiaI ftture- fl°°ding events' long-term monitoring of soil and
^ '' °&^ ^^^ ^ b& required to ensure the effectiveness of the
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Duracell Battery Tech OU1
Page 84
APPENDIX B - STATE CONCURRENCE LETTER
HCDENR
JAMZIB.KVNT.M.
COVXHMOIt
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DivnioN OF WATTE MANAGEMENT
September 20,1999
Mr. Ken Mallary
Remedial Project Manager
US EPA Region IV
61 Forsyth Street, Eleventh Floor
Atlanta, GA 30303
McDcvrrr
tun
Dear Mr. Mallary:
'
ft :-.-'.
•I'-
RE: State Concurrence with the Draft Record of Decision (ROD)
Duracell-Lexington Site, OUffl, Soil
NCD000648402
Lexington, Davidson County, North Carolina
The State of North Carolina has reviewed the Draft Record of Decision
(ROD) for the soil remedy at the Duracell-Lexington Site, OU#1, dated August 1999
and concurs with the selected remedy, subject to the following conditions.
1. Human Health Risks from remediation of Operable Unit #1 (Soil) at the Duracell-
Lexington Site will be accomplished to protect potential future residents off-site
and for an industrial worker on-sile. Therefore, the on-site soil remedy will
require deed covenants/restrictions to preclude potential human exposure to site
contaminants of concern (COCs) during future construction/development at the
Duracell-Lexington Facility.
2. The State, in agreement with the EPA, has many concerns about the use of In-situ
solidification/stabilization (SIS) of mercury in the deeper more highly
contaminated areas of the former Plant #2 area of the Site. The use of in-situ SIS
in the former Plant #2 area hinges on further research into its applicability for use
with mercury contamination in soils and an acceptable and successful Treatability
Study and Pilot Test.
3. 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
August 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.
4. 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 right to review.
AN iQUALOPPOMTUHITV/AFrillMATlVB ACTION
4O1 OHHLIN ROAD, •UITK ISO, RALKIOH, NC £7*OS
PHONB *1»-7JJ-4fi*« FAX ft! ft-71 B-3«OB
PLDrER • 9O% HICYCLID/10% POIT-CONIUKIft PAPKfl
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Duracell Battery Tech OU1
Page 85
Mr. Mallary
9-20-99
Page 2 of 2
overview, comment, and make independent assessment of all future work related
to this site.
5. If, after remediation is complete, the total residual risk level exceeds ID"*, 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
NCGS 130A-310.8.
6. If the groundwater concentrations in the Pump and Treat remedy do not show
improvements consistent with an effective source removal /control it will be
documented that the source removal/control in this area was ineffective. This will
eliminate the possibility of any future impracticability waiver since the NCAC 2L
Groundwater Standards require effective source removal or control in order to
implement a technical impracticability waiver for any contaminant source.
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,
/Grover Nicholson
Remediation Branch rfead
Superfund Section
cc: Phil Vorsatz,NC Remedial Section Chief
Jack Butler, Chief NC Superfund Section
Randy McElveen, NC Superfund Section
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