United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91 /095
August 1991
&EPA Superfund
Record of Decision:
Carolina Transformer, NC
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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R04-91/095
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Carolina Transformer, NC
First Remedial Action - Final
7. Author(»)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipients Accession No.
5. Report Date
08/29/91
6.
8. PCI forming OrQvuzvtion Rcpt. No.
10. Project/Taskwork UnH No.
1 1. Contract(C) or Grarrt(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The 4.8-acre Carolina Transformer site is a former electrical transformer rebuilding
and repair facility in Fayetteville, Cumberland County, North Carolina. Land use in
the area is predominantly agricultural and residential, with a wooded/swamp-like area
adjacent to the site. The site may overlie as many as three aquifers, of which only
the shallow confined aquifer has been found to be contaminated. From 1967 to 1982,
Carolina Transformer Company rebuilt and repaired electrical transformers onsite.
During site operations, PCB fluids were drained from transformers and improperly
stored and managed. From 1978 to 1982, a number of EPA and State investigations
identified PCB-contaminated soil and ground water. In 1982, the State determined
. that runoff from the site violated surface water quality standards for PCBs. In
1984, EPA began clean-up operations at the site, and removed and disposed of 975 tons
of contaminated soil offsite in a RCRA-permitted landfill. This Record of Decision
(ROD) addresses final remediation of contaminated soil, sediment, debris, and ground
water. The primary contaminants of concern affecting the soil, sediment, debris, and
ground water are VOCs including benzene and toluene; other organics including dioxin
and PCBs; and metals including arsenic, chromium, and lead.
(See Attached Page)
NC
17. Document Analysis a. Descriptors
Record of Decision - Carolina Transformer,
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: VOCs (benzene, toluene), other organics (dioxin, PCBs), metals
(arsenic, chromium, lead)
b. Identifiers/Open-Ended Terms
c, COSATI Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
104
22. Price
(See ANS-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department ol Commerce
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EPA/ROD/R04-91/095
Carolina Transformer, NC
First Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site includes excavating and treating onsite soil
and sediment contaminated with PCBs in excess of 1 mg/kg using a solvent extraction
process to separate the organic contaminants and polynuclear aromatic compounds from
the soil and sediment and to lower the solubility and mobility of the inorganic
contaminants; backfilling the excavated area with treated soil; solidifying soil and
sediment that does not meet the RCRA Toxicity Characteristic Rule; demolishing 970
cubic yards of roof and wall material from three onsite buildings and transporting the
debris to an offsite landfill; treating any remaining structural material contaminated
with PCBs in excess of 10 ug/100 cm2 using a solvent washing system; transporting
180 cubic yards of debris and solid waste to an offsite landfill for disposal and/or
treatment; pumping and onsite treatment of contaminated ground water using
precipitation to remove metals and activated carbon adsorption to remove VOCs, followed
by onsite discharge to surface water or offsite discharge to a publicly owned treatment
works (POTW) ,- dewatering sludge generated from the ground water precipitation process,
followed by offsite disposal; conducting ground water monitoring; and establishing a
contingency remedy for ground water remediation, which includes ground water
engineering controls, ARAR waivers, institutional controls, continued monitoring of
specified wells, and periodic reevaluation of remedial technologies if it is determined
that certain portions of the aquifer cannot be restored to their beneficial uses. The
estimated present worth cost for this remedial action is $10,474,500, with an O&M cost
of $78,100 for years 0-1 and $17,400 for yeras 2-30.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil/sediment clean-up goals are
based on carcinogenic risk and EPA guidelines, and include dioxin 1.2 x 10~4
(carcinogenic risk) and total PCS 1 mg/kg (EPA guidelines). Chemical-specific ground
water clean-up goals are based on SDWA MCLGs, EPA guidance, and State standards, and
include benzene 1 ug/1 (State), chromium 50 ug/1 (MCLG), lead 15 ug/1 (EPA guidance),
PCB-1260 0.1 ug/1 (State), and toluene 1,000 ug/1 (State).
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Remedial Alternative Selection
Site Ito>Tg and I^y-**1 i rm
Carolina Transformer Site
Fayetteville, Cumberland County, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedial action for the
Carolina Transformer Site in Fayetteville, North Carolina. The
remedy was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by Superfund Amendments and Reauthorization Act of 1986
(SARA.) , and to the extent practicable, the National Oil and
Substances Pollution Contingency Plan (NCP) . This decision document
explains the factual and legal basis for selecting the remedy for the
site.
The State of North Carolina concurs with the selected remedy. The
information supporting this remedial action decision is contained in
the administrative record for this site.
Assessment of the Site
Actual or threatened releases of hazardous substances from this site,
if not addressed by implementing the response action selected in this
Record cf Decision (ROD), may present an imminent and substantial
endangezmer.t to public health, welfare, or the environment.
Description of the Selected Remedy
The remedy selected by EPA will be the final action for the site.
This action will address the remediation cf the contaminated
groundwater, soil, and sediments on and off -site The remedy will
also address the remaining waste materials present at the site.
The major components of the selected remedy include:
Excavation of the contaminated soil/sediment and use of a
solvent extraction process to separate organic contaminants
such as PCS, Dioxin /furans, volatile organ irs, and
polynuclear aromatic compounds from the soil and sediments.
The process will convert inorganic contaminants such as lead
and uutyer to lower solubility hydroxides thereby reducing
their nobility. TCLP will be run on the treated soil and
sediment prior to the return to its original location to
determine if it meets RCRA Toxicity Characteristic Rule.
Soil and sediments not meeting the Toxicity Rule will be
solidified. The contaminant rich waste stream will be
transported off site for treatsnent.
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C~\'
-^ Demolition of the roofs and walls of the three on-site
O buildings. The debris will be crushed and transported to an
CD off-site landfill. If the remaining slabs are found to be
contaminated they will be treated with a solvent washing
system to extract the PCBs.
'•^ Removal of the debris and solid waste from the site, which
will be transported to an off-site landfill for disposal
u° and/or treatment in accordance with RCRA 40 CFR 264 Subpart
0 and 40CFR 761 (a)(4)..
Installation of groundwater extraction wells in conjunction
with a two component treatment system to remove the metals
and organic contaminants. Additional monitoring wells will
be installed into the lower aquifer to confirm its status.
If it is found to be contaminated, the groundwater treatment
system mention above will be expanded to address the
contamination of the lower aquifer.
The treated groundwater will be discharged to the
Fayetteville Publicly Owned Treatment Works (POTW), or the
unnamed tributary to the Cape Fear River.
Statutory Determinations
The selected remedy is protective cf human health and the environment
and complies with Federal and State requirements that are legally
applicable or relevant and appropriate to the remedial action. This
remedy utilized permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal elerrer.t.
Since this remedy will result in hazardous substances remaining
on-site above health based levels, a review will be conducted within
five years after commencement of remedial action to insure the remedy
continues to provide adequate protection of human health and the
environment.
|Greer C. Tidwell Date
EPA Regional Administrator
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The Carolina Transformer Site was proposed for inclusion or. the
O National Priorities List (K?L) in July 1587. The Site has beer.
O the subject of a Remedial Investigation (Ri) and Feasibility
CD Study (FS) performed by the United States Environmental
Protection Agency (E?A). The RI, which was completed in
September 1990, consisted cf a four phase investigation that
fully characterized the presence and extent of contamination en
^ and off site by evaluating the sediments, surface water,
groundwater, surface and subsurface soils. The Feasibility study
L-'") (FS) develops and analyzes potential alternatives for remediation
at the site and was issued to the public in draft form in March
1990 .
1.1 Site Location and Description
The Carolina Transformer site is located in Cumberland
County, North Carolina, approximately one mile northeast cf
Fayetteville and north of the intersection of U.S. Highway
3C1 and River Road (Figure 1.0). The approximate r.ap
coordinates are latitv.de 35 03' 08" N and lonritude 78 5C'
C7" A.
The Site consists of approximately 4.8 acres of relatively
flat terrain and is bounded en the north by a
v.-ocded/swar.p-like area vhich is adjacent to an agricultural
field and numerous hcr.es; on the west by a dirt road which
orcvides access to tvc hor.es ; to the south bv Middle ~.caz,
Larry's Sausage Cor.par.y dr.d lundy Packing Ccrr.par.y; dr.d to
the east bv e.r. acar.dc.-.ed hor.e site and ar. arricultural
site are = foundation and a
tf.s-aris the front and r.rrtheast portion cf the crtrerty
Figure 1.1 shows the locations cf these buildings. 7.-.=
western ccrticr. of the site is relatively ooen. Muor. cf the
area around the foundation and buildings has beer, pavei with
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0001
•• V-/
I .Mr
l
USGS. VANOER. NC (198A)
FIGURE l.o
SliriCX>!lO
CAJIOl INA ll»AMr,l ONMt »
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DRAINACF. Oil CM
LARRY'S
SAUSAGE
CAROLINA
1RANSFORMER
UN Fttll
I INCH * 160 FT.
CAROt INA
FAYETTEV1LLE
NOUIH LWUM.INA
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2 . C Site Histcrv and Er.f crcer.ent Activities
2 .1 Site Historv
\O Carolina Transformer Company (CTC) conducted an electrical
CD transformer rebuilding and repair business from 1957 to 1982
O (Bussey, 1985). Che first indication of business operations
O on the site was the presence of two large buildings"deoicted
in the 1S57 quadrangle nap. According to a February 1?35,
Dun and Bradstreet printout, CTC was founded in 1958. The
first parcel of the site was deeded to CTC from Lizzie
^ Talbot KcDaniel on February 7, 1959. CTC was incorporated
May 6, 1959; however, 1965 was the first year the Cumberland
Lr) County Tax Office records indicate property of the business
was identified for tax purposes. In 1967, CTC sold 4.75
acres of their property to R. L. Konbarrier.
Durinc an interview on May 23, 1985, Mr. Thomas Stevens,
North"Carolina Department of Environmental Management
(NCDEM), indicated that at one time CTC was one of the
larcest firms of its type in the U.S., having clients
throughout the southeastern U.S. and along the east coast.
At no time during that period did CTC apparently operate as
a PC3 storage and disposal site for owners of PCS
transformers cr FCB articles. However, it appears that as
part of their transformer repair and rebuilding operations,
?C3 fluids were drained frcr. transformers and not properly
stored and mar.ared .
In 1:~9, E?A conducted soil sar.pling at the sire. Testing
revealed that aicut cr.e and a half acres of the site vere
cor.tar.ir.ated vitr. ?CEs 'Hatcher, 1934;. According tc the
^crtr. Carolina Secretarv cf State's Corporate 2iv_sicr.
records, in 1 = 79, Mr. Kenneth Strcthers started a r.ev
t.r=.r.= fcrr--er company called Faytrancc, which was Iccc.ed in
~c.".*— ~*"e".* 1 ^ "c *i"*"^'~ Cc.*"c" ~ra. In 15S5 FavTrancc vss sr.ut
df..— and dissclvsd.
Acccrdinc to E?A records, CTC relocated and changed its name
to Faytranco, Inc. in April 1982. On August 13, 1934, I?A
started cleanup operations at the site, and approximately
1,COC tons of contaminated soil were removed. Contamination
over 50 pom of ?C3s, however, still exists at the site
(Matcher," 1984).
According to a deed dated November 29,'1984, the entire site
was sold to Cumberland Electrical Repair, Inc. by CTC
through Mr. Pearson and Mr. Miller. A deed, dated April 15,
1985, indicates that Cumberland Electrical Repair, Inc.
operated at the site for only about four and one half months"
before being ordered by the courts to return the oropertv to
CTC.
2-1
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2 . 2 Er.f orcemer.t Activities
^ After a highly publicized case in North Carolina concerning
^ roadside dumping of PCS oil in July 1978, residents living
near Carolina Transformer became concerned about oossible*
ground water contamination from spills at the site. Samples
taken by EPA in 1978 and 1979 revealed contamination of soil
on the site by PC3s and chlorobenzene (a PC3 carrier
^ compound). PCS carrier compounds were also found in a
shallow residential drinking water well about 250 feet west
u~) of the site; this residence was later placed on the
Fayetteville water system. Sampling also revealed trace
contamination in Carolina Transformer's deep industrial
well. The State attempted to have Carolina Transformer
correct the contaminated soil problem at the site, to no
avail.
In March 1982, sampling by the State determined that run-off
from the site violated, surface-water quality standards for
PCSs. In 1984, EPA made efforts to have Carolina
Transformer clean up the site. When the efforts failed, EPA
issued a CSRC1A section 106 Administrative Order requiring
the company to remove and properly dispose of the
contaminated soil. After the company refused, EPA, using
CZ~.m-. emergency funds, began to clean up the site in August
lrE~. During the removal action, EPA excavated 975 tons of
contaminated soil and transported it to a hazardous waste
2-2
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Hir-.l-chl of Cgrnr.ur.-Vy rar^icicdricr.
°P. 1 Suratarv of Community Participation
0 A Community Relations Plan for the Carolina Transferee:
° Site was finalized in June 1989. A RI/FS Fact Sheet
was also prepared at that time. The Remedial
Investigation (RI) ar.d Feasibility Study (FS) reports
_ along with the Proposed Plan were released to the
public on March 29", 1991. All of these documents as
Lr} well as the Administrative Record were made availibie
to the public via the Cumberland County Library.
The U.S. Environmental Protection Agency held a public
coirjnent period from y.zrch 29, 1991 through April 30,
1991 for parties interested in commenting on"the
Proposed Plan and RI/FS Reports. The public meeting
providing the results of the RI/FS and presentation of
the proposed plan was held on April 17, 1991.
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4.0 Scope and Role Of Operable Unit within Site Stra
4.1 The remedy selected by EPA for the Carolina Transformer
C\ Site will be the first and final action proposed for
CD this site. The selected remedy is protective of human
O health and the environment and complies with Federal
° and State requirements that are legally applicable or
relevant and appropriate to the remedial action. This
action utilizes a permanent solution and will address
^ all contamination present at the site.
u-} The action selected will address the remediation of the
contaminated groundwater, soil, and sediments on and
off site The Remedy will address the remaining debris
located in the on site buildings. The major components
of the selected remedy include:
Excavation of the contaminated soil/sediment, which
will be treated using .'a solvent extraction process to
separate organic contaminants such as FCB,
Dioxin/furans, volatile organics, and polynuclear
aromatic compounds from the soil and sediments. The
process will convert inorganic contaminants such as
lead and copper to lower solubility hydroxides thereby
reducing their mobility. TCLP will be run on the
treated sell and sediment prior to its return to its
original location tc determine if it meets the RCRA
Toxicity Characteristic Rule. Soil and sediments not
meeting the Toxicity Rule will be solidified. The
contaminant rich waste strear. will be transported
off-site fcr treatment.
Demolition cf the roofs and walls of the three on-site
buildings. The debris will be crushed ana transported
tc an cff-site landfill. If the remaining slabs are
found to be contaminated they will be treated with a
solvent washing system to extract the PCBs.
Removal of the debris and solid waste from the site,
which will be transported to an off-site landfill for
disposal and/or treatment in accordance with RCRA 40
CFR 264 Subpart 0 and 40CFR 761 (a)(4).
Installation of groundwater extraction wells in
conjunction with a two component treatment system to
remove the metals and organic contaminants. Additional
monitoring wells will be installed into the lower
aquifer to confirm its status. If it is found to be
contaminated, the groundwater treatment system mention
above will be expanded to address the contamination of
the lower aquifer.
The treated groundwater to the Fayetteville Publicly
Owned Treatment Works (POTW), or the unnamed tributary
to the Cape Fear River.
4-1
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5.0 Summary of Site Character's*icg
Q.1 Topography and Surface Drainage
^ The site consists of approximately 4.8 acres of relatively
° flat terrain. The area surrounding the site is generally
low-lying and swamp-like in character. The site itself is
situated at the headwaters of an unnamed tributary which
flows from the west corner of the site less than two miles
to the Cape Fear River. Other drainage ditches flow along
LJ-J Middle Road, west to the Cape Fear River and east to Locks
Creek. (Fig. 5.1)
5.2 Site Geology
The Site is located in the Coastal Plain physiographic
province of North Carolina. The main stratigraphic unit in
the vicinity of the site is the Tuscoloosa Formation which
is of Alluvial origin and Upper Cretaceous in age. The
materials comprising the Tuscoloosa Formation were derived
from crystalline rocks such as granities, gneisses, and
schiscts which compose the adjacent Piedmont physiographic
province. The soils formed from these crystalline materials
consist of brown to tan, fine to coarse-grained sands;, tan,
silty sands; clayey sands; sandy clays; and grey to blue
sandy clays.
The surficial sells at the site consist of the Wickham
Series ar.d the Roanoke Series. Wickhair. Series soils cover
r.ost of the former facility area. These are well-drained
scils that fcrr.ed ir. ioar.y luvial sediments or. terraced of
the Cape Fear River ar.d its nvajor tributaries. The loamy
horizcr. is typically 4C to 60 inches thick ar.d is underlain
by sandy alluvial sedir.er.ts. These are poorly drained soils
that formed ir. stratified clayey sediments or. terraces of
the Cape Fear River and its ir.ajor tributaries. The loamy
and clayey horizons are generally 40 to 60 inches thick and
overlie the stratified sediments deposited by the river.
5.3 Site Hydrology
The Carolina Transformer Site may be underlain by as many as
three aquifers. The alluvial deposits where sand and gravel
are present could provide large yields to wells. Available
information indicates that the alluvial aquifers are not
presently used for water supply in the area. The sands and
clays of the Cape Fear and Middendorf Formation serve as
aquifers in the Fayetteville area. Wells completed within
these formations can be screened over a large interval which
could cover sands and intervening clays. The sands provide
much higher yield and are the most productive aquifers in
the region. The bedrock possesses fracture permeability and
is utilized for industrial supplies. A similar such well
was used by Larry's Sausage Company, located adjacent to the
5-1
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7000
APPROXIMATE SCALE
0 ISOO 7000
Mil DRMINNCI l''\l II UN
(MKIII INM lMnu',1 OI4MI 14
I «Y| I II Vll | I . Ml 1141M LAUOLINR
I ICIIIM •, |
I IN II Ml
I Inch - '000 »»
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0012
Tacie 5.2
Ccn:arr,inants anfl Media 01 Concern
Media
Contaminant
Aluminum
Barium
Cofcau
Copper
Leai
Manganese
Mercury
NicKe'
G- ,-^wa.0.
»—
T
__
7
X
X
__
7
X
T
X
X
—
X
-
Soil
—
X
X
X
X
X
X
X
—
—
—
—
—
—
X
S*cex >' .
X
X
X
X,
v - -_T ,- ,
.~~~~ X.1^"!-2-----
r~=S
-.cx-ns/furans
/».
X.
X
c
C
-
X
c
c
X
X.
X
X
X
X
c
c
X f
NOTE. T - Ncr--Carc:P.cser.;c
C » Carciroje'ic P.s«. >'E-C€
X - Oeteciec a; e'eva'ec ieve' ccr-.:ar«3 to Oackgrounfl but does not oosa a
to hurrar ^-60 :• v ire environment.
-- • Not 26:ac:ec .•- e e^atec 'eve's comparec to oaci<3'oun<3.
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N~,
r_ site. This well is 303 feet deep and is completed into tr.<>
O bedrock from 12 feet to the total depth. Mr. J. D. Parker,
o President of the Carolina Sand and Gravel Company/ Inc.,
indicated, during a conversation on June 22, 1989, that
exploration borings near the site, to the south and
northwest, showed a thick clay lens starting at
ON approximately 20 feet below land surface (BLS) and extending
down to at least 50 feet BLS. Copies of the exploration
Lr) boring logs were later .provided to EPA.
The shallow aquifer, located at a depth of five to eight
feet below ground surface, is flowing through a fine to
coarse sandy layer which varies in thickness from six to 13
feet. The shallow ground water appears to flow in a
northeasterly .direction. The grey to blue-grey clay located
under the upper sand layer is very tough and dry (observed
from samples), indicating that the clay is a very good
confining layer separating the shallow aquifer from the
deeper aquifers.
5.4 Summary of Nature and Extent of Contamination
This section provides a summary of contamination found at
the Carolina Transformer Site by media. This sections also
outlines the approximate locations of the contamination
found. The Remedial Investigation Report (August 1990)
gives a more detail account of contamination found at the
site. (Table 5.4 lists the contaminants and media of
concern)
5.4.1 Grcundwater
The results of the E?A field investigations at the Carciir.a
Transformer site indicates that contamination has occurred
within the shallow aquifer beneath the site and that the
contamination is contained within the site boundaries. The
investigation included installation and sampling of 11
temporary ("sand point") and five permanent monitoring wells
in the surficial aquifer in and around the site. Five
potable water wells located to the north and east of the
site were also sampled.
PCB 1260 was detected in groundwater samples that were
obtained from temporary wells located in the center and
•outh western sections of the site. PCB concentrations
detected were 52 ug/1 and 25 ug/1. PCBs were not detected
around the perimeter of the site or in the potable water
trails.
Purgeable organic compounds were detected at low
concentrations (10 ug/1) in samples obtained from temporary
wells located in the center, southwestern, and northeastern
sections of the site. Detected were benzene, chlorobenzene,
carbon disulfide, methyl ethyl ketone and toluene. Again,
5-2
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^ purgeable organic compounds were not detected beyona tne
IT perimeter of the site. The groundwater sample from
Q monitoring well KW-04 contained 10.OJ ug/1
1,1,1,-trichloroethane and other chlorinated solvents at
concentrations of 2,4J to 42 ug/1. (The numerical values
accompanied by a "J" indicates the quantitative value of
CN the compound is an estimate.) Bis(2-ethylehexyl)phthalate
was detected at relatively high concentrations (920J ug/1)
i_n in a sample from a well located in the center of the site.
This extractable organic compound was also detected at low
levels in a well located in the northeastern section of the
site. The down gradient monitoring well indicated higher
extractable organic content than the upgradient well but the
total value of extractables was less than 26J ug/1. The
sources of these extractables were probably industrial
chemicals used during the active phase of the site. With
the cessation of operations and the removal of accumulated
petroleum products from the site, extractable organic
sources are extremely limited. Phenol was detected in low
concentrations (3.7J ug/1) in a temporary well on the north
western "perimeter of the site. This was the only compound
detected at elevated concentrations in the groundwater
beyond the perimeter of the site.
High concentrations of barium, chromium, copper and nickel
were detected in the groundwater from wells in the center of
the site. Pesticides were not detected in groundwater from
ar.y cf the wells sar.pied.
The data for lead levels in the shallow aquifer were
insufficient to determine the source of lead or whe-the'r the
level is elevated over background. The results from the 11
temporary wells indicated lead levels were below detection
limits. The results from the five permanent monitoring
wells indicated lead level ranging from 18 ug/1 to 19C
ug/1. This latter set of data indicated approximately equal
lead levels in upgradient and down-gradient wells. Based on
this body of data, it is uncertain whether lead levels in
groundwater are associated with current or previous
conditions at the site.
5.4.2 Surface Water
The investigation conducted by EPA has also revealed PCB
contamination in the surface water contained in the drainage
ditch which runs through the site and into a wooded area
southwest of the site. PCB was also found to be present in
the surface water contained in the low-lying marsh located
to the north and west of the site. PCB 1260 contamination
range from 2.8 ug/1 to 12 ug/1. Concentrations of copper
were elevated in these samples and a single extractable
organic compound, bis (2-ethylhexyl) phthalate, was also
found.
5-3
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U i
O
Samples collected from Locks Creek, up- and down-gradient
contained no detectable concentrations of PCBs, pesticides,
O extractable organic compounds, or volatile organic
compounds. Samples taken contained similar metals at
equivalent concentrations.
^ For extended periods of time there is no standing surface
^ water on site or in the intermittent stream. This minimizes
the effects on human health and the environment from this
media. Considering that surface water contamination is the
result of contact with contaminated soils, structures, and
debris the remediation of these other media will eliminate
the necessity for a separate remediation of surface waters.
5.4.3 Soil/Sediment
The site investigations conducted by the EPA have documented
that the soils and sediments throughout the western and
southern portions of the site contain moderate to high
levels of PCS compounds. In Figure 5.4 the extent of
contamination is illustrated graphically. Since all
electrical transformers, condensers, and storage tanks have
either been removed from the site or drained, the current
and primary source of this contamination is the on-site
soil. Composite soil/debris samples taken from the main
building, maintenance building, and burn building have been
deterrr.ined to contain FCE compounds at levels as high as
2200 rr.illigra-T.s per kiiogran (mg/kg) . Therefore, residual
sclids in these buildings must also be considered as sources
of PCEs. Wipe sar.pies taken from the interior walls.-, of the
main building and burn building detected PCS at
concentrations ranging from <1 ug/100 cm2 to 5.6 ug/100
cr/. However all sar.pies taken are within Toxic Substance
Ccntrcl Act (TSCA; PCB spill Policy limits.
Lir.ited sampling fcr dicxins/furans confirmed these
contaminants to be present in the on-site soil, off-site
soil, sediments, and building-soil/debris. The highest soil
levels [470 to 550 nanograms per kilogram (ng/kg) toxic
equivalent (TEQ)] were found in the on-site soil west of the
main building and east of the raised foundation.
Concentrations as high as 220J ng/kg TEQ were found in the
sediments along the drainage ditch which receives runoff
from this area. However, the highest levels measured, up to
19,OOOJ ng/kg TEQ, were found in soil/debris samples taken
from the buildings or. site. Pesticides were found in only
occasional samples at measurable levels. These may be
residuals from pest control efforts when the facility was
active.
Extractable organic compounds were detected in a number of
on-site and off-site soil and sediment samples, however, few
specific compounds were consistently detected around the
site.
5-4
-------
0' lo 2" IIEIOW CHAPC
XZ-^^VKi
KXXXX1 5< i« '
II I I I I I 11 »0« I" 5»0 PPm
| 06 I ».4l
t 04 I 0« I 3-9 I
" "—«—-«— M
i icimr s.i
r,oii /'-IDIMINI ceo iLvn
-------
Again the sources of these extractabies were probably
•industrial chemicals used during the active phase of the
^ site. With the cessation of operations and the removal of
accumulated petroleum products from the site, extractable
organic sources are extremely limited.
The most frequently detected purgeable organic compound at
the site was toluene. Toluene was detected in on-site and
ex off-site soil samples generally at levels of 5 to 10 ug/kg.
Toluene was also detected in sediment samples at levels of
i_o 1200J and 2400 ug/kg and in a soil/debris sample at a level
of 230 ug/kg. Toluene was probably used at the active
facility as a solvent with the contamination resulting from
spills or waste disposal practices.
Chlorobenzene 'and dichlorobenzene were detected in on-site
and off-site soil and sediment samples. Concentrations were
generally less than 50 ug/kg but one sediment sample
contained over 750J ug/kg of dichlorobenzene and 48J ug/kg
chlorobenzene. The higher soil sample concentrations were
found off-site along the drainage ditch which carries
surface runoff from the southern portion of the site. The
sources of chlorobenzene and dichlorobenzene were probable
spills of transformer oil which occurred during the active
phase of the facility since chlorobenzene compounds are
frequently used as PCS carriers in transformer.oil.
The sclver.t trichlcroethylene and tetrachloroethylene were
found in a few on-site soil samples at 1J to 4J ug/kg and in
a few off-site soil samples at 5.2 ug/kg to 18J ug/kg. ,•
These contaminants probably resulted from operation ~of the
site since they are net present in the surrounding
upgradier.t wells.
Concentrations cf inorganics, with the exception of copper,
were generally consistent with background values. The
background level cf copper in the soil typically ranged from
less than 1 mg/kg to slightly, above 3 mg/kg. The levels of
copper found in on-site soil were as high as 2800 mg/kg near
the burn building. The copper level in the soil/debris
sample from this building was 130,OOOJ mg/kg. The burning
of wire and electrical equipment may have spread copper.
High levels of copper containing particulates cover much of
the site. High levels of copper were found in soil/debris
samples taken in all of the on-site buildings. Other
inorganics such as mercury and arsenic were detected at
•l«vated levels in a few soil and sediment samples.
5-5
-------
5 9 0018
6 .1 Contaminants of Concern
A baseline risk assessment was performed to evaluate the
potential risks to human health and the environment from.
exposure to the site contaminants of concern. The contaminated
media of concern are: or.site and off site soils, sediments,
groundwater and surface water. Onsite building debris and
solid waste is also a media of concern. Table 6-1 provides the
site contaminants of concern along with the exposure point
concentrations. This concentration represents the upper 95
percent confidence limit of the arithmetic mean.
6.2 Exposure Assessment
The following potential exposure scenarios were evaluated in
the risk assessment:
c Current exposure of onsite .trespassers to contaminants in
soil through incidental ingestion and dermal contact, and
in surface'water and sediment through dermal contact.
* Current exposure of offsite residents to contaminants in
soil through incidental ir.cesticn and dermal contact, and
ir. surface water ant sedir.er.t through dermal contact.
Zxccsure throuch ir.resticr. cf carder, produce growr. ir.
ccr.~2j~.ir.ated scil was else evaluated.
Future exposure cf cr.site residents tc contaminants ir.
crcur.cv2-.er through ir.resticr., direct contact, and
*'/~^. -s^/j ^ —. ,*,~ *.» s — .' — — .... e~ .' «^ ^ —^ * ^ x•»-/•
~ _ » •.. f
ir.cesticr. and cerral contact.
Future expcsure of onsite residents to contaminants ir.
carder, orcduce throurr. incesticr. cf oroduce—e^ovr. ir.
contaminated soil.
In addition to the above scenarios, three additional
assessments were conducted tc assess highly contaminated areas.
" Current exposure of offsite residents to an offsite area
with high levels of contaminated- soil on either side cf the
drainage way immediately south cf the site.
8 Current exposure of onsite trespassers to highly
contaminated debris in one of tr.e site buildings.
Future exposure by onsite residents to groundwater fror
onsite well number 44.
-------
i,. i
Cont.imin.int (ZxpoMiro Point, Concentration
CD
-o
^^
OO
Contnmlnanl
Inorganic lilomnnis
Aluminum
Aisonlc
Barium
Cadmium
Chromium
Coball
Coppor
Lead
Manganoso
Mercury
Nickel
Slronllum
Titanium
Vanadium
Yllldum
Zinc
PesHckte/PCB
PCS- 1248
PCB-1254
PCB-1260
Extraclabla Organtcs
1 .2.4-Trtchtofoberuene
Bls(2-ethylhflxyl)phlhalale
Soil'
Onsllo
mg/kg
—
—
29
2.2
88
05
2.100
160
100
—
--
--
—
—
—
91
ug/kg
16.000
43.000
650.000
ug/kg
2.5
Ollsllo
mo/kg
--
22
74
--
84
.1.1
4G
30
300
003
--
14
300
•
74
56
ug/kg
--
--
1.600
ug/kg
--
._
Snillmonl
Onr.llo
my/k()
1 1 .000
:>(f
2-4
IS
4 ?.
?.f>00
'.IS
1(10
--
•i :i
11
--
3?
CG
73
up/kg
9.B
9?
140
ug/kg
--
--
Ollsllo
ii)(l/k()
" ;>/i6o6
--
110
4.r>
29
5 >
;,no
ISO
<>s
'.V?
ir>
--
r.i
ii. G
2C.O
ug/kg
220
Ifi
4.400
ug/kg
--
--
Ciroundwaior
Onr.ilo
U!l/'
3.100.000
--
1 1) .000
--
?.noo
ft/0
;',!ioo
1/0
^4.000
0.34
1700
.1 .400
O.SOO
4,!)00
1 .SOO
3.5110
UO'I
--
--
SI
ug/i
5 0
f.1
Ollsllo
ug/l
n;,o.ooo
--
2,300
--
840
2SO
3!>0
150
13.000
.40
S?0
740
5.JOO
2.000
490
1.000
ug/l
--
--
16
ug/l
50
50
Surl.ico Walor
Onsilo
ug/l
--
--
--
--
--
--
130
--
440
--
--
--
50
--
--
76
ug/l
--
--
52
ug/l
--
25
Ollsllo
ug/l
--
--
--
--
--
130
--
400
--
--
--
12
--
--
160
ug/l
--
--
12
ug/l
--
100
* Hoi Spot *
Woll 44
ug/:
3.100.000\
.-
19.000
--
2.900
670
3.000
--
6.900
--
1.200
1.400
--
4.900
1.500
3.500
ug/l
--
--
52
ug/I
--
--
Soil .
mg/kg
.-
--
46
--
--
OS
O.'j
11
f,f,
.OS
--
--
--
--
--
05
uo/kg
--
--
280
ug/kg
--
--
Debris
mo/kg
16.000
77
550
9.0
130
21
1 30.000
;<,o
1 ..TOO
2S
r>r,
31
--
1.000
«IU"><1
2.200
ugll>Q
--
-•
* Tin- hot spot tit-rioted In (he (.ihlr is t .•(.( <••.,•„< .,i i v,- ,.l ,,||-..;|rc I'CB soil «>iu.imln.n ion
NOTI:
I. Tho v.-ilm-s (l.-noti-d for ..||-sil.' •..un|.l. .,,, ,,,,'i' i,u ,-.,„,•;..!.• ,-,„„ ,.nt , ,lt j ,,„ ;,n,| w,.ri. ,„,, |,n ••n,l,.,|
I " i i' |> t i' si • 111 11. i (• k )•i 11111111 i 11111 • i • 111 i . 11 j,. 11 . .
-------
T.-ihln <>. I (command)
C<>Mt;iinm;ml Kxpusuio Point Conconlration
-o
o
oo
ggzn
oo
5i c:
Is
3
Conl.imin.int
I'lifflnahln OcQantcs
1.2-l)ichloioban/ene
1.3-l)ichlnfobanzene
1 .4-|)ichloiobanzane
lion/one
Caibon Olsulllde
Chlorobnn/ene
Moihyl F.lhyl Kelone
T otrachiuf obenzena
1 okione
Trlchlornbnnzeno
Dloxlns/fufans
"~Sor
Onsilo
ug/kg
--
--
--
25
--
2.5
--
0.5
62
2.0
nfl/kf)
750
•
Ollsilo
iilnl roncorilLillon lor Ilii:. cool.iinln.ini
SlKllllllllll
Onsilii
fiOO
OIKIIO
H.li
( ilOIIIH
I"
') 0
;• a
it
l!l
/ r.
,.
wnlor
Ollsilo
n"(i'
~ '?.'.,
?s
"^
Sin lace Water
Onsilo
"U"
--
--
--
14
--I |
".:._.
--
--
-"°"-:-
Ollsilo
~!"-lr;
:::.
--
.in
:.:..
--
--«0?_
Mot r,()oi
Well 44
_"»''_
-"-".-
2.8
67
20
:.:_
.
--
ug/l
Soil
22~~
--
44
--
--
--
~—
05
nn/k()
Dobiis
_«o!M._
--
.-
.-
.-
... _ _. "/
.. .. ?no
"(|/kr)
ri.ooo
CD
CD
ro
CD
-------
«—The potentially exposed populations for current scenarios were
CMconsidered to be current offsite residents, both children and
Oadults and current teenage trespassers. The potential future
Opopulations that were evaluated were children and adult onsite
residents.
The exposure frequency for the residential scenarios was daily
^exposure or 365 cays per year. The trespasser exposure
^ frequency was assumed to be one day per week or 52 days per
^year. The exposure duration for the adult and child resident
was 39 and 5 years respectively. The exposure duration for the
trespasser was for 30 years.
The soil ingestion rate was assumed to be 200 mg/day for
children six years and.under and 100 mg/day for individuals
over six years, ^he skin surface area for dermal contact was
8620 cm. , 7000 cm2 and 3160 cm2 for adults, teenagers and
children, respectively. The groundwater consumption rate was 2
L/day for adults and 1.4 L/day for children. The inhalation
rate was assumed to be 0.6 nr/hr for all groups. The
vegetable consumption rate was assumed to be b.201 kg/day.
6 . 3 Tcy.r'.citv Assessment
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group fcr estimating excess lifetime
c2.-.cer risks associated with exposure to potentially
cc.roinorer.ir. chemicals . C?Fs , which are expressed in units cf
(me ''kg-dsy; ~~, are multiplied by the estimated intake cf a
coter.tial carcinocen, in mc/kc-dav, to orovide an uccer-bcund
estimate cf tr^e excess 1; fetif.e csncer risk associated vltl~
exccsurs at that intake level. The term "ucoer bound ' reflect?
the conservative estimate of the risk calculated fror the Z~:.
risk highly unlikely. Car.cer potency factors are derived frrr
the results cf human etidemlclocical studies or chronic animal
bicassays to which ar.imal-to-humar. extrapolation and
uncertalntv factors have been accliec. The CPFs fcr the site
contar.inc.nts of concern are contained in Table 6-2.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from
exposure to chemicals exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates
of lifetime daily exposure levels for humans, including
sensitive individuals. Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested
from contaminated drinking water) can be compared to the RfD.
RfDs are derived from human epidemiological studies or anim.al
.studies to which uncertainty factors have been applied (e.g.,
to account for the use of animal data to predict effects on
humans). These uncertainty factors help ensure that the RfDs
will not underestimate the potential for adverse
noncarcinogenic effects to occur. The RfDs for the site
contaminants of concern are contained in Table 5-2.
6-2
-------
0022
TABLE 6.2
TOXICITY VALUES
-""•'-*•*
Cv:c- 2.$jtfia»
FACTOR
HC
i '. OE-C: :isis
Si.0°5
FACTOR
«
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8»iZ«-t 2.9E-02 1 |lR:S i 2.9E-02 !
T«tr»cr:i:::>«'..->«i«
S !£-C2
•. .OE-C2 IHEAST/1S.S
Tolu*n« i i 2 06-01
Chicro5«r:»n«
1 .3-DieftiOfoe«nz«n» !
V4-Di:^3S"
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VT.' .- i
i.-: 2 : = -:•. .r£>S*
; i : • | i SE-C- 5C:-C£ '=. S
ti.x. .,,..... . -=->; :=! s
A.-3C- ~-'::- 7 7£_;< IIP s
A.-X- c--i::: i 77=^>c : IIRS
A/seic---;'; ; 77E^c : HH.S
A.-3C- :'-'.24« . 77 = ^>C , iiRiS
Aj3cr-c--125-! • 7 7£«OC ;iRiS
A/3cr:s'--25C ! 7 7£-OC | ilR:S
2.3.7. 6-*»:-4-C;D | 1 sg.05 HEAST
1.2 3.7.8-se--.t-CC3 i
V2 34.7.g-H»*«-CDC 6.2E«03 IRIS
1.2.3 487. l-H«pu-COO
Oett-COO
2.3.7.«-T»u»-COD
V2.3.7.(^MW-COC ;
1.2.3.4.7.»-Hra-CDO 9.2E-03 ! ii°'S
1.2.3.4.e.7.»-H«pU-COF I
Ocit-COF ; !
i i
•• 30E-C* n£ts*
; ,
i
i BE-C-. ,:R'S
:
t
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l.SE^S HEAST
6.2E«03 IRIS
B.2E-C3 [IRIS __,
| i
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NC-SS:
IRIS - IN-ESSATE RESEARCH INRDHMATiON SYSTEM
HEAST - HEALTH EFFECTS ASSESSMENT SUMM AflY T A3-.SS (3RD QUARTER. FY 1990)
RC - REeE==NCc 5OSE
POOR QUALITY
ORIGINAL
-------
recuire CPFs ar.c
rbed doses rather
O extrapolated
6 . 4 Risk Characterization
Os
Excess lifetime cancer risks are determined by multiplying the
u"* intake level with the cancer potency factor. These risks "are
probabilites that are generally expressed in scientific
notation (e.g., 1 x 10~5 or 1E-6)." AT. excess lifetime cancer
risk of 1x10 indicates that, as a plausible upper bound, an
individual has a one in a 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 a
site. The Agency considers individual excess cancer risk in
the range of'lO"* to 10"° as protective; however the 10"°
risk level is generally used as the point of departure for
setting cleanup levels of Superfund sites.
Potential concern for noncarcir.ocenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived
from the contaminant concentratior. in a given medium to the
cor.tarr.ir.ar.t ' s reference cose). By adding the KQs for all
cc7.tsT7.ir.2r.ts within a medium cr across all media to which a
civer. ccculaticr. rr.cv reascr.ablv be excosed, the hazard index
{HI car. be cer.erst.ei. The HI crevices a useful reference
ocint fcr caucrinc the cctsr.tisl £ icr.if icance of ir.ulticle
ccr.tamir.2nt exposures within s. sir.cle medium cr across rr.ec.is.
r * s '•"! leve" ^ c **" s*1 * copulations exceeds tu°
~~v
f the E?A scceotsble risk ranee. ?cr
current cnsite trespassers, the lifetime excess cancer ris>. IE
E.6 x 1C~~ primarily fro- contact with ?C3s in site soils,
surface water ar.c sediments . A hot spot scenario fcr
trespasser contact with site debris produced an unacceptable
risk level of l.c x 1C'-3, primarily from ingesticn and dermal
contact with ?CBs and dioxir./furans . Fcr current adult off sit€
residents, the lifetime excess cancer risk is 1.6 x 10" ,
while current off site child residents have a risk of 5.7 x
13" / prim.arily from dermal contact with PC3s in sediment.
For hypothetical future scenarios the cumulative lifetime
excess cancer risk is 2.6 x 10"^ fcr adult onsite residents
and 1.4 x 10"2 for child onsite residents. The risks are
primarily related to exposure to PZBs in groundwater, surface
soil, sediments and produce crown in contaminated soil. The
risks associated with exposure to croundwater from well number
44 are 2.3 x 1C"2 for adults anc 1\3 x 1C"2 for children.
These risk levels reflect exposure via ingestion and dermal
contact with PCHs and inhalation of benzene.
6-3
-------
5 9
D-T.IV
0^1 ~* /.
0^1 a* 70" is
..£-w.. ... .«r.-4. c
l/-C'c-'c'cce-.:s-€
Te::ccK.':orc5:'e'=
Toiue-e
•^.•t-Tricr-crcie-ze-e
Tr:c".ic-cetMe-.e
Bis(2-e^.y:~exyOpr-.:ra'a:e
PCEs
. Dieisrin
f — :..ic.,r->nc ^^PO^
R!D
•E-3
7E-2
5E-*
5E-3
1E-1
2E--s
2E-2
TE-2
2E- "
5E-2
• C.-
2E-2
9E-2
—
"*. E- 2
2E-'
**C 1
iE-2
7E-2
2E-2
5E-5
un/M_
Absorption
SF Faetor(a)
0.2
2E-0 1.0
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
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7.7E«C 0.5
1.6E.1 O.S
V5E-5 C.S
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1E-3
1E-2
1E-4
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2E-2
6E-5
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4E-2
4E-2
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7E-2
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6E-3
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—
— (d)
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3.CE-2
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1.4E-2
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1.SE«1
3.2E«1
3.0E.5
(a) Basetf on USEPA HEAs ana ATSDR doeuners
fr) Dermal Ria • Oral RIO X Absorption Far.or
(c) Dermal SF - Oral SF/Absorption Factor
CT Derma! extrapolation of Arsenic inappropriate d-je to localized effects
POOR QUAUTV
ORIGINAL
-------
oj The His for all current scenarios are below the level of.
O concern (1.0). The His for all future scenarios are all above
O i.o. Future adult and child onsite residents have KIs of 60
and 2CO respectively. The main HI contributors are ir.etals
(bariurt, chror.iun, nickel, vanadium, manganese) and bis
(2-ethylhexyl) phthalate. Exposure to groundwater fror. well
cs r.ur±>er~44 results in a r.oncarcinogenic HI of 200 for adults and
TOO for children, again due to r.etais and a significant
L° contribution to risk from chlorober.zene being inhaled in the
showering scenario.
Lead was evaluated using the lead Uptake/Siokinetic (UBK) Model
developed by SPA. The model predicts that 68 percent of the
children (age C-7 years) exposed to lead at the site exposure
ooint concentrations would have blood lead levels above the EPA
benchmark level of 10 Ug Pb/di. The major contributor to this
•oredic^ed percentage is the groundwater lead exposure point
concentration of 170 ug/1. -This concentration also exceeds the
EPA action level of 15 ug/1. There is some discrepancy
concerning the groundwater lead' concentrations since lead was
net detected in any of the onsite Phase 1 temporary wells but
was detected in the onsite Phase 3 permanent monitor wells .
Uncertainties associated with the risk characterization include
derivation of exposure point concentrations, intake
uncertainties and the tcxicity values which were used to
evaluate the risk. Another ir.ccrtar.t uncertainty stems frcrr.
the fa-— that the risk cclculaiicns for derrval exposure assure
a dirert and consistent relationship between the oral toxicity
values ar.d the extrapolated dermal value. A final uncertainty
involves the ciscret-sr.cv cf t'r.9 onsits croundwater data for
Ised zetvesr. Phases 1 ar.d 2
T.~.-= si~= habitat consists cf four tvoes: wooceci area, wetlands,
agrioul-ural ar.d grassy area. >:o special nanacenent, pressr*/e
areas or -£.rks are located at the site- and threatened or
endangered species have not beer, documented at the site. Many
areas onsite and in the drainage ditch along the north boundary
cf the site either lack vegetation or had less growth than
adjacent areas.
Surface water concentrations cf several chemicals (copper,
zinc, toluene, PCS) were above ar-bient water quality criteria.
However, these cher.icais were detected in surface water sanples
fror. locations which dici not retain water throughout the year.
For this reason, these areas -»y not be able to sustain aquatic
ecosystems
-------
,„,, --e----al« "f concern 'lead, benzene, chlercber.zer.e,
'T 7«"co"-'~" sediment ar.d surface water at the site have t.-.e
°poteAt~a'l for'toxic'effects and bioaccumulation which may cause
potent a some species via the food chain. This _s a
conce*-" 'or PCBs which ir.ay have adverse effects on
n^acuatic species, terrestrial anir.als, birds, plants,
and reotiles which frequer.t the site.
LD
-------
7.0 Description of Alternatives
CM
This section outlines the alternatives that were considered to
remediate the following media: groundwater, soil/sediment,
structures, and debris/solid waste. The alternatives are presented
and organized by media and are described separately, however the
final remedy will be a combination of the alternatives listed. The
alternatives decribed in this section are listed below.
Groundwater Alternatives
G-l No Action
G-2 Deed Restriction
G-3 Metals Removal/Air Stripping/
Adsorption/Discharge
G-4 Metals Removal
Adsorption/Disc'harge
G-5 Adorption/Discharge
G-6 Metals Removal/UV
Oxidation/Discharge
Soil/Satiitn«»nt Alternatives
S/S-1 Ko Action
S/S-2 Fence/Deed
Restriction
S/S-2 Excavation for
Offsite Landfill
S/S-4 Excavation for Onsite
Incineration
S/S-5 Excavation for Onsite
Chemical Dechlorination
S/S-6 Excavation for Onsite
Solvent Extraction
Structures Alternatives
S-l No Action
S-2 Fer.cir.c
£-3 Partial Eercliticr.
£-4 Cor.plete Demolition
Debris/Solid Wastes Alternative
D-l No Action
D-2 Fencing
D-3 Cffs -9 Disposal
Ground-water
Alternative G-l: >;c Action. The "no action" alternative
would net. involve any remedial action, and the site would
be left in its present condition. Funds would not be
expended for monitoring, control, or cleanup of the
contaminated structures. This alternative, which is
required by the NCP and SARA, is a baseline to which the
effectiveness of other alternatives is compared.
Alternative G-2; Deed Restrictions. This alternative
would consist of placing restrictions on the deeds of the
site and adjacent properties which would prohibit the use
of water from the shallow aquifer and the construction of
any new wells into the shallow aquifer. Monitoring of the
existing groundwater wells should be continued on a
quarterly basis. The sole effect of this alternative is
to eliminate all direct contact with groundwater from the
shallow aquifer. The prohibition against all use of
groundwater from this aquifer, including noncontact
cooling and noneatable crop irrigation, would be
implemented to eliminate exposure to fish, water fowl, and
other environmental populations. Acceptance of deed
7-1
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S Q P H ^D restrictions by offsite property owners would be
07 UU^o voluntary. State and local governmental agencies would be
responsible for enforcement of any deed restrictions.
Alternative G-3; Metals Removal/Air Stripping/Adsorption.
This alternative involves groundwater extraction using
wells followed by treatment to remove both metal
contaminants and organic contaminants. This alternative
would consist of a groundwater extraction system and three
treatment components. The groundwater extraction system
included for this alternative is common for all
alternatives that withdraw groundwater for treatment.
The groundwater extraction technique chosen for detailed
evaluation is the multiple well point system. This system
would consist of approximately 23 to 25 well points located
in a line along the western and northern site boundaries.
The RI indicated the hydraulic gradient of the surficial
aquifer slopes to the northwest. A line of extraction well
points on these boundaries would intercept groundwater
migrating from the site.
The well points would be constructed of 2-inch PVC casings
which would be screened only in their lower one to two
feet. The well points would be installed to the top of the
clay layer which underlies the site at an assumed average
depth of 9.5 feet below grade.
The individual wells would be connected by insulated PVC
headers installed above ground on blocks. A regulation
valve r.ust be installed on each well's connection to the
header to control flow fror. the well. This prevents some
wells frorr. experiencing excessive drawdown of the
groundwater level compared to other wells on the header. A
r.ir.imuzr. of two headers would be used; one serving the well
points along the northern site boundary, the other serving
well points along the western boundary. More than one
header might be used along.each boundary if required by the
hydraulics of the system.
The headers would be connected to a single, above-grade
pump which would pump the groundwater to the treatment
components.
The first treatment component would consist of a skid
mounted, packaged, electrochemical metal removal system.
This system would consist of a reaction tank, clarifier,
•ludge thickening and dewatering equipment, multi-media
filter, chemical storage and feed equipment, and controls.
The filter would ensure that precipitant fines do not leave
this process. The sludge, which contains the metal ions
removed from the groundwater, would be dewatered by a 15
cu.ft. capacity filter press. The filler backwash and
recovered water would be returned to the head of the
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precipitation system. The dewatered sludge, estimated to be
30 percent solids, would be disposed of in an offsite RCRA
landfill.
Following the metals removal system, the groundwater would
enter a packed-bed air stripping unit. Volatile organics
(e.g., benzene, chlorobenzene, toluene, and carbon
disulfide) would be stripped from the aqueous stream and
captured in activated carbon filters on the vent. When the
activated carbon is spent, it is replaced with fresh sorbant
and the spent material is sent to an offsite recovery
facility. The organics are ultimately incinerated during
sorbant recovery.
The final component is an activated carbon absorption system
to remove non-volatile and semi-volatile organics including
dichlorobenzene, 1,2,4-trichlorobenzene, and
bis(2-ethylhexyl)phthalate. When the activated carbon is
spent, it is replaced and the spent material is sent offsite
for recovery or disposal. If the activated carbon is
recovered, the organics are ultimately incinerated. If the
carbon is not recovered, the organics are ultimately
disposed of in a landfill along with the carbon.
Two discharge options have been developed for this
alternative, varying on the discharge point for the treated
groundwater. Alternative G-3A is based on discharge to the
unnamed tributary to the Cape Fear River. Alternative G-3B
is based cr. discharge tc the POTW.
Alternative G-4 : Metals Rer.oval/Adsorption. This
alternative is the same as G-3 except air stripping is not
used to rerr.ove volatiles. The activated carbon usage rate
will be higher for this alternative. Alternative G-4A is
based or. discharge to surface waters; Alternative G-4B en
discharge to the POTW.
Alternative G-5; Adsorption. This alternative (Figure 4-5)
involves groundwater extraction using the well point system
followed by treatment to remove organic contaminants. Some
metal concentrations would be reduced by activated carbon
adsorption. Treated water would be discharged to the Cape
Fear River Tributary. Only spent carbon is generated for
disposal offsite.
Discharge to the POTW was not considered in conjunction wit}
this alternative for two principal reasons. First, the
Fayetteville POTW is a biological treatment facility and
would not -rovide significant removal of inorganics from th«
wastestream. Secondly, the City of Fayetteville is engaged
in an extensive landfarm program for disposal of the POTW
sludges. For this reason, the City has stated it could not
accept the discharge from the Carolina Transformer
groundwater remediation system unless metal removal was
provided.
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59 0 0 '• 0 Alternative s-fi. Metals Removal/UV o^ru^r. This
alternative is similar to G-4 except uv oxidation instead
of activated carbon adsorption is used to remove organic
contaminants. Metal sludge requires disposal offsite.
Alternatives G-6A and G-6B are based on the same discharge
options as developed for Alternatives G-3 and G-4
r
Alternative G-7; UV Oxidation. This alternative is
similar to G-5 except UV oxidation is used to remove
organics. No residual waste requires disposal offsite.
As in Alternative G-5, the only discharge considered is to
the tributary of the Cape Fear River. The reasons for this
decision were presented in Section 4.2.1.5.
7.2 Soil/Sediment
• Alternative S/S-1; Ko Action. The "no action" alternative
would not involve any remedial action, and the site would
be left in its present condition. Funds would not be
expended for monitoring, control, or cleanup of the
contaminated soil/sediment. This alternative, which is
required by the NCP and SARA, is a baseline to which the
effectiveness of other alternatives is compared.
Alternative S/S-2; Fence/Deed Restrictions. This
alternative would involve the construction of a chain-link
fence, approximately 6 feet high to surround the
ccr.tar.inated-areas on site that are not currently fenced.
The site is currently partially fenced. Approximately
1,100 feet of additional fencing would be required to
completely surround the site. Warning signs would be
displayed or. the fences to alert the public of potential
hazards. The fence would be effective in restricting
access and preventing exposure to the contaminated
soil/sediment on site. The fence and deed restrictions
would not be effective at restricting access or preventing
exposure to offsite soil/sediment such as that present in
the offsite portion of the watershed. It would not reduce
the volume of contaminated soil/sediment on site.
Future uses of the property would also be restricted by the
application of deed restrictions. State and local agencies
would be responsible for the implementation and enforcement
of such restrictions.
This alternative, though lacking in effectiveness, serves
as a minimal action alternative for comparison against
other alternatives.
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Alternative S/S-3; gyeavation fqy Offsite Landfill. This
alternative involves the excavation of contaminated coil
for disposal in an offsite landfill. Soil with a PCS
concentration of less than 50 ppm (mg/kg) could be disposed
of in a RCRA landfill such' as the one located at Pinewood,
South Carolina. Soil with a PCB concentration greater than
50 ppm must be disposed of in a TSCA landfill such as the
one located at Emelle, Alabama. Where necessary, native
soil will be used to return the surface contours to
approximately the existing elevations to ensure adequate
site drainage. No backfill would be placed in drainage
ways if adequate drainage could be maintained without it.
All fill soil and disturbed areas would be revegetated with
native grasses to control soil erosion. Because the soil
would be remediated to the extent that onsite activities
would pose no health risk, additional fencing would not be
required.
Two options have been developed for this alternative,
varying on the PCB concentration used to determine the
extent of excavation.
Alternative S/S-3A involves the excavation of all onsite
and offsite soil/sediment with a PCB concentration of
greater than 1 ppro. It is estimated that Alternative
S/S-3A would require excavation of 15,345 cubic yards (CY)
cf ccr.tar.inat.ed soil/sediment with a PCB content of greater
rhan 1 pprr.. Of this total approximately one-half (7630 CY)
have a PCB content of less than 50 ppm and could be ,
disposed cf in a RCRA landfill. The remainder (7715 CY)
have a PCB content of 50 ppir. or greater and must be
transported to a TSCA certified landfill.- Returning the
non-drainage way areas to the existing elevations would
require 5780 CY cf fill material.
Alternative S/S-3B is similar to the first alternative with
the exception that onsite excavation would be limited to
soil/sediment with a PCB concentration greater than 10
ppm. All onsite soil/sediment with a PCB concentration of
greater than 1 ppm (including the unexoavated areas) would
be covered with a minimum of 10 inches of clean soil. More
cover material may be required for some areas to maintain
adequate site drainage. Offsite contaminated soil/sediment
occurs primarily in the storm water drainage ways where it
would be difficult to ensure the maintenance of 10 inches
of cover over soil/sediment exceeding 1 ppm. Therefore,
offsite soil/sediment would be remediated to a level of 1
ppm as in Alternative S/S-3A. This alternative would
require approximately 1575 CY less excavation than
Alternative S/S-3A. Approximately 6055 CY would be
transported to a RCRA landfill and 7715 CY would be
transported to a TSCA landfill.
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r
9 Q052
Alternative S/S-4! gyegvation for Onsite Incineration.
This alternative involves the excavation of contaminated
soil/sediment followed by onsite incineration and
redeposition in the original locations. The onsite
incinerator would be a mobile type capable of achieving
99.9999 percent PCB destruction. At this level of
destruction it may be possible to return the treated
•oil/sediment to its original location. However, while
incineration will result in a high degree of organic
destruction, disposal of incineration residuals in a secure
landfill may be necessary because of the elevated
concentration of copper and lead in the onsite and offsite
soil/sediments. A pilot test of the incinerator and
additional soil testing to determine the extent of onsite
copper and 'lead contamination would be required to
determine whether the treated soil/sediment could be
returned to its original location or would require disposal
in a landfill meeting RCRA standards or nonhazardous design
standards. For purposes of this FS, it is assumed that the
treated soil/sediment would be non-hazardous and could be
disposed of by returning the soil to its original location.
The same two options developed for Alternative S/S-3 will
be considered for the onsite incineration alternative.
Alternative S/S-4A would excavate and incinerate all onsite
and offsite soil/sediment which has a PCB content of
greater than 1 ppr.. The treated soil/sediment would then
be returned to its original location. The treated areas
would be graded, compacted, and seeded to control, erosion.
No additional access controls would be required either on
site cr off site.
Alternative S/S-4B would excavate and treat the same volume
of offsite soil/sediment but would excavate only the
portion of onsite soil/sediment which exceeds 10 ppm. The
treated soil/sediment would be returned to its original
location. Onsite soil/sediment with a PCB content between
1 ppm and 10 ppm would be covered with 10 inches of clean
soil. This soil could be either treated soil/sediment from
the incineration unit or soil from an offsite source.
Alternative S/S-4A would require 15,345 CY of excavation
and no additional backfill material. Alternative S/S-4B
would require 13,770 CY of excavation. It is assumed that
the 5780 CY of cover material required would be supplied
by the treated soil/sediment.
Alternative sys-5; Onsite Chemical Dechlorination. This
alternative is very similar to Alternative S/S-4 except
that the excavated soil would be chemically treated to
dechlorinate chlorinated hydrocarbons such as PCBs to
produce a nonhazardous material. In the chemical
dechlorination process, contaminated soil/sediment and an
alkaline chemical reagent solution would be mixed in a
batch reactor to form a slurry.
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9 0033
The slurry is then heated and the reagent reacts with
chlorinated hydrocarbons in the soil/8edioent to remove the
chlorine atoms and convert them to inorganic chlorides.
The soil/sediment and reagent solution are separated in a
centrifuge or filter. Additional reagent is added to the
recovered solution and the solution is recycled. The
treated soil/sediment is dewatered and washed to remove the
residual reagent solution. The wash water is also
recycled.
The dechlorination system does not remove inorganic
contaminants such as copper and lead; however, some amount
of removal of soluble compounds would be achieved in the
soil washing process.
Pilot testing of the dechlorination process would be
required to determine the reagent chemical consumption
rates, optimum process parameters, and effect on inorganic
contaminants. It is-assumed based on previous tests on
similar media and organic contaminants that the treated
soil/sediment would be nonhazardous and could either be
returned to its original location or disposed of in a
non-hazardous material landfill. Disposal in a RCRA
landfill would be required only if the treated
soil/sediment remained hazardous due to leachate from
inorganic contaminants. This would be established by
conducting TCL? analyses or/ the treated soil/sediment. For
comparison with the other soil/sediment remediation
alternatives, it is assumed that the treated soil/sediment
will be returned to its original location.
As in the two previous soil/sediment remediatior.
alternatives, two options will be considered for
Alternative S/S-5. Alternative S/S-5A would excavate and
chemically dechiorinate all soil/sediment which has a PCB
content of greater than 1 ppn; Alternative S/S-55 all'
soil/sediment with a PCB content greater than 10 ppr.. The
quantities of soil/sediment to be excavated and
dechlorinated Vould be the same as in the parallel options
in the onsite incineration alternative.
Alternative S/S-6: Onsite Solvent Extraction. Alternative
S/S-6 uses a solvent extraction process to separate organic
contaminants such as PCB, dioxin/furans, volatile organics,
and polynuclear aromatic compounds from soil and sediment.
The process produces a treated soil/sediment and a
contaminant-rich waste stream which would be incinerated
off site. This alternative is similar to Alternative
S/S-5 in that the contaminated soil/sediment is excavated
and chemically treated on site. In this alternative,
however, the organic contamination in the media is
concentrated in a separate waste stream rather than
detoxified by dechlorination.
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In a typical solvent extraction system applicab-e t.c
contaminated soil/sediment, the soil/sediment is first
screened, then placed in a batch washer-dryer. In the
washer-dryer, the solvent is added and the media and
solvent are mixed. The organic contaminants are removed
from the soil/sediment into the solvent fluid. The solvent
is decanted from the mixer and sent to the solvent recovery
system. For highly contaminated media and high removal
rates, multiple solvent extraction steps may be necessary.
After decantation of the solvent, the soil/sediment media
is then dried by the introduction of steam into the
washer-dryer. Any remaining solvent is volatilized and
collected for reuse. The treated soil/sediment can then be
handled using normal earth moving equipment.
Leaving the washer-dryer, the solvent solution contains
both the water and organic contaminants that were in the
treated media. A centrifuge or vacuum filter may be
required to achieve additional liquid/solid separation.
The solids would be-returned to the washer-dryer. The
solvent solution is'then heated to above 60 C which results
in a very good separation of the solvent containing the
organic contaminants and the water which was originally in
the soil. Both the water and solvent streams are then sent
to steam strippers which recover the TEA for reuse in the
extraction step. The recovered contaminant stream is
placed in storage tanks for shipment to offsite
incineration facilities. The water stream may be suitable
fcr direct discharge or may be used for dust, control on the
treated media. The relatively low moisture content of the
scil/sediment is expected to generate very little-• wa'ter for
disposal, therefore, costs will be based on use cf this
flow fcr moisture control in the treated media.
The entire extraction process takes place at alkaline
conditions which promote the formation of metal
hydroxides. Therefore, conversion of inorganic
contaminants such as lead and copper to lower solubility
hydroxides may also be achieved in this process. These
hydroxides would be retained in the treated soil/sediment.
The solvent extraction process is capable of achieving PCB
and dioxin/furan removal efficiencies of over 99 percent.
Since the process efficiencies varies with the type of soil
and contaminant, a pilot test is required to establish the
number of extraction steps, solvent requirements, and
effectiveness of the process. Such tests are also required
to determine whether the treated soil/sediment can be
returned to its original location or must be disposed of in
a landfill. For comparison with the other soil/sediment
remediation alternatives, it is assumed that the treated
soil/sediment would be returned to its original location.
7-8
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As in the previous soil/sediment remediation alternatives,
two options will be considered for Alternative S/S-6.
Alternative S/S-6A would excavate and treat all
soil/sediment which has a PCB content of greater than 1
ppm; Alternative S/S-6B all soil/sediment with a PCB
content greater than 10 ppm. The quantities of
soil/sediment to be excavated and treated would be the
•ame as in the parallel options in the other soil/sediment
remediation alternatives. The same quantity of backfill
and landfill cover required by the previous alternatives
would be required by these options also.
7.3 Structures
Wipe samples from the three onsite buildings determined
that the walls of these structures exhibit surface PCB
contamination at levels below the TSCA requirements for
high-contact, non-restricted access surfaces.
Contamination levels of the floors of these structures and
of the raised concrete platform are unknown but, based on
debris samples, they could exceed TSCA imposed levels.
The structural integrity of the three onsite buildings is
not known.
Alternative S-l; No Action. The "no action" alternative
would not involve any remedial action and the site
structures would be left, in place in their present
conditior.. Funds would not be expended for the monitoring
or maintenance of the structures. This alternative is a
baseline to which the other alternatives are compared.
Alternative S-2: Fencing.. This alternative would involve
the construction of a 6-foot high, chain link fer -e tc
surround the portions of the site that are not currently
fenced. This alternative is identical to Alternative
S/S-2 described earlier.
Alternative S-3: Partial Demolition. In this
alternative, the roofs and walls of the three onsite
buildings would be demolished using heavy equipment and
hand tools. The demolition debris would be crushed or
shredded if appropriate to reduce the size of debris prior
to transportation to offsite landfills. The total quantity
of demolition debris generated by the roofs and walls of
these structures would be approximately 970 CY. The floor
•labs and the raised concrete platform would be left in
place. Because the extent of possible PCB contamination
of the floor slab surfaces is unknown, two options have
been developed for this alternative.
Alternative S-3A is based on the assumption that
additional wipe sampling of the floor slabs determines
7-9
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that the PCB contamination is below the TSCA cleanup
requirement for high-contact,.outdoor «urfaces in an
industrial area, 10 ug/100 cm. In this case, no
additional treatment of the structure slabs would be
required.
Alternative S-3B assumes that the wipe sampling indicates
that specific areas of the floors are contaminated with
PCBs at levels above 10 ug/100 cm2. As a basis for
estimation of cost, it is assumed that the contaminated
area consists of all of the floor area in the burn and
maintenance buildings, the one-half of floor of the main
building (excludes the office area), and one-half of the
raised concrete platform. This would result in a total
area to be .treated of 21,350 square feet (SF). These
areas would be treated using a solvent washing system to
extract the FCBs from the concrete. The used solvent and
rinse water would be vacuumed from the floor and drummed.
The drummed waste would be transported to an offsite
licensed incinerator:.
Alternative S-4t Complete Demolition. This alternative
involves complete demolition of all three onsite buildings
and the raised concrete platform. The demolition would
include, as applicable, roofs, walls, floor slabs, and
foundations. The demolition would be accomplished using
heavy equipment and hand tools. As in Alternative S-3,
the debris would be crushed or shredded, as appropriate,
to reduce the size of the material prior to being
transported off site for disposal. The nor.hazardpus
demolition debris would be disposed of in the Cumberland
County Landfill. This alternative would generate a total
of 2,195 CY of demolition material. Because the decree of
floor slab contamination has not .been determined, two
options have been developed for this alternative.
Alternative S-4A is based on the PCB contamination of the
floor slabs being less than 10 ug/100 cm2 allowing
disposal of all slab material as nonhazardous wastes in a
non-RCRA landfill. If isolated areas of surface
contamination are detected through additional wipe
testing, these areas would be removed from the slab by
pneumatic or mechanical abrasive equipment. The removed
material would be collected and drummed for disposal as
hazardous waste. For purposes of developing costs,
Alternative S-4A will assume a total of 2,000 SF of floor
Area exceeds the TSCA requirements of 50 ppm and must be
removed prior to general demolition. Assuming that 1 inch
of material would be removed, 6 CY of hazardous material
would be drummed.
Alternative S-4B assumes that PCB contamination of floor
slabs is wide spread and, therefore, removal of
contaminated material separate from the bulk of the floor
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, " •; •=-£- is iiprar^^cd.. in tr.is a-s-ernacive, tne s-acs would
u o/ be treated by the solvent wash technique to remove the PCBs
from the concrete. The used solvent and rinse water would
be vacuumed and drummed for offsite incineration.
Following the solvent wash, the slabs would be broken up
and transported as non-hazardous material to the Cumberland
County Landfill. As in Alternative S-3B, it is assumed
that 21,350 SF of floor slab would be treated by the
solvent wash equipment.
7.4 Debris/Solid Wastes
Alternative Dnl t No Action. The "no action" alternative
would not involve any remedial action to collect, control,
or remove debris or solid wastes from the site. This
alternative, is a baseline to which the other alternatives
are compared.
Alternative D-2t Fencing. This alternative is identical
to Alternative S/S-2, described earlier.
Alternative D-3; Offsite Disposal. This alternative would
transport all debris and solid waste from the site for
disposal in offsite landfills. Solids processing such as
crushing and compaction or the cutting of large items such
as tanks into more manageable sizes would be performed
where necessary prior to transportation. If the material
is nor.hazardous, it would be transported to the Cumberland
County Landfill, a ncn-RCRA facility. If the debris
contains more than 50 ppm of PCBs, it would be transported
to a TSCA landfill. If the debris contains less than 50
ppc PCBs, but would be otherwise considered hazardous (e.g.
failed EPA's TCLP leachate test), it would be transported
to a RCRA landfill.
As discussed in Section 3.3.4, PCBs were not detected in
any of the large electrical transformers on site and were
detected in only one of the partially buried tanks on
site. These items would be cut up and disposed of as
non-hazardous materials. The one partially buried tank
which did contain measurable quantities of PCBs (72 ppm
total PCBs) would be drained and the drummed liquid would
be sent to an offsite incinerator as required by TSCA.
This tank would then be handled in the same manner as the
other tanks. The tanks and drained transformers have
potential value as scrap material, but this option will not
be considered in developing costs. The empty 55-gallon
drums, ceramic insulators, and wooden pallets would also be
non-hazardous materials and would be disposed of in the
sanitary landfill. It is estimated that a total of 160 CY
(80 tons) of solid waste and debris would be transported to
the Cumberland County Landfill.
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c <"• n n "* 0 Tests on the dirt scraped from the floors of the taree
0 -i J U 0 u onsite buildings indicated that this material has a
•ubstantial degree of PCS contamination. This material
would be removed from the building floors, drummed, and
transported to a TSCA landfill- The existing Rl-derived
wastes which have been temporarily stored on site would
also be drummed and transported to the RCRA landfill. The
total volume of hazardous material transported to the RCRA
landfill would be approximately 20 CY (10 tons). An equal
amount is assumed to be transported to the TSCA landfill.
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8*0 s^pmarv of Comparative Analysis
This section presents a detailed evaluation of the alternatives
described in Section 7. Each alternative is evaluated, using the
following nine criteria. The results of the evaluation of each
alternative is then compared and the alternative that best meet the
requirements of the nine criteria is identified.
Protection of Human Health and the Environment - Determines
whether each alternative meets the requirement that it be
protective of human health and the environment. This criterion is
of key importance. While the remedy selected may on occasion seek
a waiver of a given ARAR, the remedy selected must be protective
of human health and the environment.
Compliance With ARARs - This evaluation is used to determine how
each alternative complies with federal and state (ARARs) as
defined in CERCLA Section 121. A presentation of chemical and
location specific ARARs is contained in Section 10.
Action-specific ARARs are summarized in Appendix A.
Lona-Tenn Effectiveness and Permanence - Addresses the results of
a remedial action in terms of the risk remaining at the site after
response objectives have been met. The primary focus of this
evaluation is the effectiveness of the controls that will be
applied to manage risk posed by treatment residuals or untreated
wastes.
Reduction of Toxicity, Mobility, and Volume - Addresses .-the
statutory preference for selecting remedial actions that employ
treatment technologies that permanently and significantly reduce
toxicity, mobility, and volume of a hazardous substance as their
principal element. This preference is satisfied when treatment is
used to reduce the principal threats at the site through
destruction of toxic contaminants, irreversible reduction in
contaminant mobility, or reduction of total volume of contaminated
media.
Short-term Effectiveness - Addresses the impacts of the
alternative during the construction and implementation phase until
remedial response objectives have been met. Alternatives are
evaluated with respect to their effects on human health and the
environment during implementation of the remedial action and until
protection is achieved.
Implementabilitv - Addresses the technical and administrative
feasibility of implementing an alternative and the availability cf
various services and materials required during its implementation.
Cost - The cost estimates provide an order-of-magnitude evaluation
for comparison of alternatives. Capital cost, annual cost, a
present worth analysis, and a cost sensitivity analysis (where
appropriate) are part of this evaluation.
8-1
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•*- State acceptance - EPA requests state comments and concurrence
O for consideration in final selection.
o
Community acceptance - EPA considers input from the affected
community and considers and responds to all coomments received
prior to the final selection of a remedial action (long term
^ cleanup).
LO 8.1 Groundwater Alternatives
8.1.1 Alternative G-l; No Action
Protection of Human Health and the Environment. Since no
remedial action would be taken, this alternative would not
provide any increase in the protection of human health or the
environment:
The risk assessment conducted for this site determined that
there are currently no significant carcinogenic or
non-carcinogenic risks posed to existing human population by
groundwater due to two factors: contaminated groundwater has
not migrated offsite, and there are no local onsite or
offsite withdrawals from the shallow aquifer.
The "no action" alternative would not be protective of future
onsite residents who might use the shallow aquifer for
domestic uses. Such persons would be exposed to groundwater
posing a non-carcinogenic hazard index greater than 1 and a
carcinogenic risk of greater than 10 . .. '
The "nc action" alternative would also not be protective cf
future offsite residents should contaminated groundwater
migrate fror. the site and wells be constructed to use the
shallow aquifer.
Compliance with ARARs. This alternative would net result in
returning the quality of the onsite, shallow aquifer
groundwater to a level which would meet the Safe Drinking
Water Standards.
Long-Term Effectiveness and Permanence. Because remedial
actions would not occur, this alternative would not provide
any long-term effectiveness or permanence. The long term
risks due to contaminated groundwater would be unchanged.
Reduction of Toxicitv, Mobility* and Vol'*me. This
alternative would have no effect on the toxicity, mobility,
or volume of contaminated groundwater beyond natural
attenuation effects due to dilution and natural biological
degradation of some organic compounds. The potential for
dilution of contaminants is dependent on the degree of
cross-media contamination that occurs due to contact with
contaminated soil/sediment.
8-2
-------
O Short-Term Effectiveness. Because no site activities
O would occur, there would be no effect on the community.
There would be no construction or operation related
impacts to the environment.
^ Implementabilitv. This criterion is not applicable to a
,_--) "no action" alternative.
Cost. This alternative would not incur any costs.
8.1.2 Alternative G-2t Deed Restrictions
Protection of Human Health and the Environment. This
alternative 'does not offer any increase in the protection
of the environment; however it does provide substantial
protection to human health. If implemented and strictly
complied with, deed restrictions which prohibit
installation of wells in the shallow aquifer would
eliminate human contact with contaminated groundwater.
Compliance With ARARs. Same as Alternative G-l: No
Action.
Long-Term Effectiveness and Permanence. This alternative
would be effective at preventing human exposure to
contaminated groundwater for as long as local property
owners abide by the deed restrictions. It is possible
that at some future date additional groundwater testing
will indicate that contaminants no longer exceed Safe
Drinking Water Act Standards. However, unless such a
reduction in contaminant levels occurs, the deed
restrictions must, be considered permanent. Sampling cf
the existing groundwater monitoring wells would continue
for an indefinate period.
Reduction in Toxicity. Mobility, and Volume. Same as
Alternative G-l: No Action.
Short-Tenn Effectiveness. Because this alternative would
involve only institutional steps, there would be no
construction phase that might affect the community. Since
no one in the area is currently using water from the
shallow aquifer, there would be no exposure to
contaminated groundwater during the interval until the
deed restrictions are put in place. The implementation
period would be six months to one year depending on the
degree of community acceptance this alternative receives.
Implementability. The implementability of deed
restrictions is considered the ability to attach the
required restriction to the property deeds for the
Carolina Transformer site and adjacent property which
might be effected, and the ability to enforce such
restrictions once attached.
8-3
-------
The attachment of deed restrictions to the Carolina
Transformer site deed can be assumed to be agreeable to
the current property owner and, therefore, readily
implemented. Voluntary acceptance of similar restrictions
by the owners of adjacent property is questionable. These
owners would be relinquishing a potentially valuable
property right (access to a shallow aquifer) for little or
no gain. Such a restriction on their deed would be
expected to result in some reduction in the commercial
value of their property.
Even if acceptable to current owners of the site and
adjacent properties, enforcement of such restrictions
would be difficult. The procedures for issuing a state
groundwater withdrawal permit do not require documentation
that no deed restrictions against withdrawals from
specific aquifers exist. Future owners could choose to
ignore or be unaware of the existence of the
restrictions. The restrictions could also be lost during
future property transfers.
For the above" reasons, the implementability of this
alternative is considered is low compared to other
alternatives.
Costs. The costs for implementation of this alternative
consist of the cost to purchase agreements to accept deed
restrictions froir. adjacent property owners and the
attorney and court costs to amend the affected pro^per'ty
deeds. It is very difficult to accurately estimate the
cost to purchase deed restriction agreements. Although no
one is currently using this aquifer, property owners may
be extremely reluctant to give up such a property right
without a financial inducement to do so. Also, since the
contaminated groundwater has not been shown to have left
the site, it is difficult to determine which property
owners would be affected.
For these reasons, a cost estimate for this alternative is
based on rough assumptions and may not meet the desired
degree of accuracy, +50 percent to -30 percent. Assuming
that there are five property owners in addition to the
Carolina Transformer site owner and that each owner would
agree to accept $10,000 (including all attorney fees) in
return for the deed restriction, this alternative would
have a cost of $50,000. There would be no annual fees
incurred by this alternative.
8.1.3 Alternative G-3; Metals Removal/Air Stripping/
Adsorption
Protection of Human Health and the Environment. The risks
to future users of groundwater associated with ingestion,
inhalation, and dermal contact with contaminants in the
8-4
-------
_ ,-, ^ t 7
9 OUT 5
shallow aquifer groundwater would be reduced by this
pump-and-treat alternative. The operation of the
groundwater extraction and treatment system would continue
until the groundwater meets the remedial goals. The
treatment system would remove both metals and organics to
an extent at which discharge of the treated groundwater to
the unnamed tributary to the Cape Fear River
(Alternative G-3A) or the Fayetteville POTW (Alternative
G-3B) would be possible.
Compliance With ARARs. The remedial goals for groundwater
remediation are based, in part, in meeting the MCLGs or
MCLs and the North Carolina Groundwater Standards.
Operation of the Alternative G-3 equipment would be
continued until the groundwater attains these limits.
If discharged to the tributary of the Cape Fear River, the
treated water from the process would not cause violation
of any ambient water .quality standard. If discharged to
the POTW, the effluent would meet the City's standards for
discharge to the sewer system. The activated carbon
filters on the air stripper offgas would ensure the air
discharge meets all emission standards from this source.
Long-Term Effectiveness and Permanence. This alternative
would be effective at achieving a high degree of
permanenance in remediating the existing volume of
contaminated groundwater. The long-term effectiveness and
permanence of this alternative is dependent upon the
removal of contaminated soil/sediment to eliminate
continued cross-media contamination. Assuming the
contaminated soil/sediment is also removed, there should
be no need for continued operation of the extraction and
treatment system once the remedial goals are met.
Sampling of the existing monitoring wells would continue
for an indefinite period after achievement of the remedial
goals to confirm the permanence of the action.
Reduction of the Toxicity, Mobility, and Volume. This
alternative would be effective at reducing the mobility
and volume of both organic and inorganic groundwater
contaminants.
The organic contaminants would be ultimately concentrated
in the activated carbon sorbant without change in their
toxicity. The fate of these contaminants would be linked
to that of the spent sorbant. If the sorbant is thermally
recycled, the organics would be destroyed during
regeneration or in a separate afterburner. If the spent
sorbant is landfilled rather than recycled, the toxicity
of the contaminants would not be reduced but their
mobility in the general environment would be minimized.
Inorganic contaminants removed from the groundwater would
be concentrated in the sludge generated by the
8-5
-------
precipitation process. Except for contaminants such as
chromium which may be converted to a less toxic valence
state, the toxicity of inorganic contaminants would not be
reduced by the treatment system. At the low
concentrations present in the sludge, recovery of metals
would not be economically feasible. Disposal in an
appropriate landfill would minimize the mobility of
inorganics in the general environment.
Short-Term Effectiveness. Short-term risks to human
health and the environment during the implementation and
operation phases of Alternative G-3 would be limited.
Some increase in ambient air concentrations of volatile
organic contaminants which escape the air stripper's
activated carbon absorption system would be experienced
but at levels which meet emission limits and cause no
threat to human health or the environment. Similarly,
organic and inorganic contaminants will be present at much
reduced levels in the effluent from the treatment system.
Whether discharged to the Cape Fear River's tributary or
to the POTW, this effluent would increase the total
quantity of these contaminants in surface waters. The low
concentrations present in the effluent would provide no
significant human health or environmental effects.
Implementabilitv. The installation techniques and
treatment technologies used in Alternative G-3 are well
understood and have been successfully implemented at other
sites on similar media and contaminants. The process'
equipment consists of standard groundwater treatment
systems and would require no special designs. Pilot plant
testing would be required to obtain optimum process
kinetics and equipment sizing. Such testing would
optimize chemical utilization, air stripper air-to-fluid
ratios, and activated carbon type among other design
factors.
The treatment facility could be mounted on several
equipment skids to minimize construction related
problems. The treatment facility must be manned for both
operation and maintenance considerations. With sufficient
groundwater equalization storage, the groundwater
extraction system could operate continuously while the
treatment system could operate on a 40-hour/week basis.
Coats. The detailed capital cost estimates for
Alternatives G-3A and G-3B are presented in Tables 8-1 and
8-2, respectively. The capital costs of both systems
include installation of the groundwater extraction system
(wells), storage tanks for groundwater and chemicals, the
various treatment components, and sludge dewatering and
storage equipment. Alternative G-3A includes the cost of
a discharge line to the Cape Fear River's tributary.
Alternative G-3B includes the cost of a pipeline to the
existing sewer left station adjacent to the site.
8-6
-------
00,5
Annual operation and maintenance (O&M) costs associated
with these alternatives include costs for electric power,
chemicals, activated carbon replacement, maintenance
parts, sludge disposal, and labor. Because of the lack of
physical data on the shallow aquifer, there is
considerable uncertainty over how long the treatment
system must operate to achieve the remediation goals.
For purposes of comparative costs, it is assumed that the
system would operate for 10 years, and that chemical and
activated carbon consumption drop off by 10 percent each
year over that period (i.e., 10 percent of first year's
consumption used in the tenth year). Power, maintenance,
and labor requirements are assumed to remain constant over
this period. The first year O&M costs for Alternatives
G-3A and G-3B are presented in Tables 8-1 and 8-2,
respectively.
The 10-year present worth costs of Alternatives G-3A and
G-3B are $878,500 and $949,700 respectively.
8.1.4 Alternative G-4; Metals Removal/Adsorption
Protection of Human Health and the Environment. This
alternative would provide approximately the same degree of
protection cf huir.an health and environment as Alternative
G-3.
i
Compliance With ARAHs. Operation of the groundwater
extraction and treatment system would be continued until
the groundwater attains the MCLGs or MCLs set by the Safe
Drinking Water Ac- and/or the North Carolina Drinking
Water Standards. In Alternative G-4A, the effluent froir.
the treatment systeir. would comply with the City's
standards for discharge to the sewer system. In
Alternative G-4B, the discharge to the Cape Fear tributary
would not cause violations of ambient water quality
standards.
Lonq-Term Effectiveness and Permanence. This alternative
would provide the same degree of long-term effectiveness
and permanence as Alternative G-3.
Reduction of Toxicitv, Mobility, and Volume. This
alternative would provide the same reduction in the
toxicity, mobility, and volume of groundwater contaminants
as Alternative G-3.
Short-Tenn Effectiveness. The short-term risks associated
with this alternative would be similar to Alternative G-3
except that without an air stripper, there would be no
increase in ambient air concentrations of volatile
organics. These compounds would be removed in the
groundwater activated carbon adsorption system.
8-7
-------
9 0046
Implementahllitv. The implementability of this
alternative would be similar to that of Alternative G-3.
Costs. The detailed capital cost estimates for
Alternative G-4A and G-4B are presented in Tables 8-3 and
8-4, respectively. The capital cost categories are
identical to Alternative G-3 except for the deletion of
the air stripper and its associated equipment. It is
assumed that the activated carbon adsorption equipment
would be the same size as the equipment in Alternative
G-3. The elimination of the air stripper would increase
the organic load on the adsorption equipment. The cost
estimate assumes that this increased loading would be
accommodated by more frequent activated carbon replacement
rather than'by larger units.
Annual O&M costs associated with Alternatives G-4A and
G-4B include the same categories as their respective
Alternative G-3 options and are also presented in Tables
5-3 and 5-4. The principal difference between the G-4
option and G-3 the option is the lower power costs
reflecting the deletion of the air stripper and the higher
activated carbon replacement costs.
The present worth costs of Alternatives G-4A and G-4B
based on 10 years of operation are $830,500 and $898,800,
respectively.
8.1.5 Alternative G-5; Adsorption . '
Protection of Human Health and the Environment. The
discharge of groundwater to the Cape Fear River tributary
without treatment for metals removal would result ir. some
degree of elevated hazard risk to human health due to
potential dermal contact by offsite persons during
wading. The chronic and lifetime hazard index posed by
the untreated metals in the discharge would be 0.04 and
0.003, respectively. A hazard risk of 1.0 or greater is
considered to be significant.
The metals content in the discharge would exceed the North
Carolina Ambient Water Quality Standards as discussed in
the following section; therefore, some degree of elevated
threat to the aquatic environment would occur until the
discharge reaches the Cape Fear River.
Compliance With ARARs. As in the previous two
alternatives, this alternative would continue operation
until the groundwater attains the Safe Drinking Water Act
MCLGs and MCLs. Without metals removal, the treated
groundwater would exceed the North Carolina Ambient Water
Quality Standards for barium, total chromium, copper,
lead, manganese, nickel, and zinc at the point of
discharge. The effluent would be discharged to the
normally dry drainage stream leaving the site and the
8-8
-------
/~, /"• ^ 4 *"
9 Cut/
stream would not meet Ambient Water Quality Standards
until it confluence with the Cape Fear River in
approximately one-half mile. At a flow rate of only 10
gpm, the mixing zone required to achieve the standards
would be very small even during low flow conditions.
Long-Term Effectiveness and Permanence. This alternative
would provide the same degree of long-term effectiveness
and permanence as the previous two alternatives.
Reduction in Toxicitv, Mobility, and Volume. Organic
contaminants would be concentrated in the activated carbon
media. As in the previous two alternatives, these
contaminants would be destroyed if the activated carbon
were recycled. If disposed of without recycling, mobility
and volume would be reduced without change to the
contaminants toxicity.
This alternative uses dilution by the remainder of the
POTW influent to reduce the toxicity of inorganic
contaminants. The secondary treatment provided by the
POTW would not provide significant removal of inorganics.
However, the levels of inorganic would also not adversely
affect the POTW's operations. This alternative would
increase the mobility and volume of inorganic
contaminants .
Short-Tenr, Effectiveness. This alternative would have few
short term impacts during implementation. This
alternative requires minimal supervision and generates
only spent activated carbon as a waste material.
Implementahilitv. Activated carbon adsorption utilizes
standard modules and can be quickly implemented.
Costs. The detailed capital and annual O&M costs
estimates for Alternative G-5 are presented in Table 8-5.
The activated carbon adsorption equipment would be the
same as in the two previous alternatives. The present
worth of this alternative is $435,000.
8.1.6 Alternative G-6; Metals Removal/UV Oxidation
Protection of Human Health and the Environment.
Alternative G-6 provides the same level of protection of
human health and the environment as Alternatives G-3 and
G-4. The hazards due to both metals and organics would be
reduced by this alternative.
Compliance with ARARs. This alternative offers the same
degree of compliance with ARARs as Alternatives G-3 and
G-4.
Long-Term Effectiveness and Permanence. The long-term
8-9
-------
effectiveness and permanence of this alternative would be
the same as Alternatives G-3, G-4, and 6-5.
Reduction in Toxicitv. Mobility, and Volume. The metals
removal process for this alternative would be identical to
the process used in Alternatives G-3 and G-4 and would
offer the same reduction in the mobility and volume of
inorganic contaminants.
The UV oxidation process would convert the organic
contaminants to less hazardous materials. This would
result in the reduction of organic contaminant toxicity
and volume. The process does not produce any hazardous
byproducts which would require additional handling or
storage.
Short-Term Effectiveness. The metal removal and UV
oxidation equipment would be modular, skid mounted systems
which would minimize -'effects on human health and the
environment during implementation and operation. Organic
and inorganic contaminants would be present at much
reduced levels in the discharge from the treatment
system. Whether discharged to the Cape Fear River
tributary (Alternative G-6A) or the POTW (Alternative
G-6B), this effluent would ultimately increase the total
quantity of these contaminants in surface waters. The low
concentrations present in the effluent would present no
significant human health or environmental effects. As in
all alternatives providing metal removal, metal oxide'
sludges must be transported from the site to a chemical
waste landfill.
Implementabilitv. UV oxidation is a demonstrated
technique for destruction of organic compounds in water;
however, a pilot plant study would be required to optimize
the process factors and equipment sizing. Such testing
would optimize chemical utilization, power consumption,
and oxidation tank detention times among other factors.
UV oxidation equipment is available from several qualified
manufactures who would be capable of conducting the pilot
test and furnishing the required equipment.
Costs. The detailed capital cost estimates for
Alternatives G-6A and G-6B are presented in Tables 8-6 and
8-7, respectively. The costs for metal removal are
identical to those developed for the previous alternatives
using this process. The costs for the hydrogen peroxide
storage tank and metering equipment and the UV light
reactor tank.
Annual O&M costs associated with these alternatives
include the costs of chemicals, power, maintenance parts,
sludge disposal, and labor. The first year O&M costs are
presented in Tables 8-6 and 8-7. The present worth of the
two Alternative G-6 options are $993,300 and $1,055,500.
8-10
-------
U U T '
8.1.7 Alternative G-7; uv
Protection of Human Health and the Enviynnment. This
alternative would provide a degree of protection of human
health and the environment equivalent to Alternative G-5:
Absorption.
Compliance with ARARs. This alternative would provide the
same compliance with ARARs as Alternative G-5. Without
metals precipitation, metal levels in the treated effluent
would be above Ambient Hater Quality Standards until after
a mixing zone in the Cape Fear River.
Long-Term Effectiveness and Permanence. This alternative
provides the same degree of long-term effectiveness and
permanence as the six earlier alternatives.
Reduction in Toxicitv, Mobility, and Volume. Organic
contaminants would be destroyed, eliminating their
toxicity and volume. -' Inorganic contaminants would be
unaffected but the combination of these contaminants with
the remainder of the POTW influent wastes would provide
dilution to reduce the groundwater flow's toxicity. The
POTW would provide no significant removal of inorganic
contaminants.
Shcrt-Ten?. Effectiveness. This alternative would have few
short term impacts on the public health or the environment
during implementation and operation. The alternative
generates no sludges and requires only minimal.
supervision.
Ir.slementabilitv. The UV oxidation system is a
demonstrated technique, however; this alternative would
require pilot testing to optimize oxidation tank detention
time, chemical dosages, and other process variables.
Costs. Detailed capital and annual O&M costs of
Alternative G-7 are presented in Table 8-8. These costs
are identical to Alternative G-6: Metal Removal/UV
Oxidation with the deletion of the metal removal and
sludge handling equipment.
The present worth of this alternative is $590,600.
8.2 Soil/Sediment Alternatives
8.2.1 Alternative S/S-1; No Action
Protection of Human Health and the Environment. Since
remedial action would not be initiated, this alternative
would not provide any increased protection to human health
or the environment. Specifically, the non-carcinogenic
hazard index would be greater than 1 for future onsite
residents and carcinogenic risk would be greater than 1 x
10~b for all populations evaluated in the Risk
8-11
-------
U050
Assessment Report. Also concern for PCB exposure by
terrestrial animals, birds, and plants would not be
reduced.
Compliance with ARARs. The "no action" alternative would
not meet ARARs; specifically, TSCA regulations for cleanup
and disposal of PCB spills. Violations of state water
quality standards in the periodic surface waters leaving
the site would be expected to occur due to cross-media
contamination. Cross-medial contamination of groundwater
would also be expected to continue resulting in
contaminant concentrations exceeding Safe Drinking Water
Standards.
Loncr-Term Effectiveness and Permanence. Because remedial
actions would not occur, the existing risks at the site
would remain. Since site controls would not be
implemented, the criterion addressing the adequacy and
reliability of controls is not applicable to the
alternative.
Reduction of Toxicity. Mobility, and Volume... Since
remedial activities would not occur, there would not be a
reduction in the toxicity, mobility, or volume of
contaminants at the site. The existing type and quantity
of hazardous material would remain onsite. Cross-media
contamination of groundwater, surface water, and sediment
would continue to occur.
Short-Term Effectiveness. Because site activities would
not occur, protection of workers and the community would
not be required. Environmental impacts due to
construction or implementation would not be encountered
since there would be no activities performed at the site.
Impleroentabilitv. This criterion is not applicable
because remedial activities would not occur. Services and
materials and the activities normally needed to coordinate
with other agencies would not be necessary.
Cost. There would be no costs incurred since remedial
activities would not be performed.
8.2.2 Alternative S/S-2; Fence/Deed Restrictions
Protection of Human Health and the Environment. Risks
associated with dermal contact with or ingestion of onsite
contaminated soil/sediment would be controlled by these
access and use restrictions. Security fencing with
warning signs would reduce (but not eliminate) the
possibility of site trespassers coming into contact with
contaminated onsite media. The use restrictions would
prevent the type of long-duration contact associated with
residential development. This alternative would not be
effective at protecting human health or the environment
8-12
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NCAC-IO 101 OU3?(|i)
NC;AC to lui uo.i/ition
Si«it> ii«*uM i«uiil«tiui* lot cunliuktiun tourcci
MirtuliHinu tw)tniiHn«iitt
i,«Hiiil i«
-------
I .il)lt; A L' (continued)
Action Gi>eciliC-AUARs
ooil/Sedirnenl
Standard. Requirement,
Criteria, or Limitation
North Carolina (continued)
Citiiliun
QSNC-II3A b7
Description
MmiOaiuiy nuiiUnU lui •lontiii cuntigl in •!••* ol
•»c*v*liun
Alturnatives
S/S-I
—
b/S-2
—
S/S-3
A. RA
S/S-4
A.RA
SK-t,
A.RA
s;s^>
A.RA
A - A|i|ilica|jtolvi|lil«>nl«lil
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1UC - Tob»cunHd»i«d
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cccc
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o_
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Table A-3
Action Specilic-ARARs
Stiuctures and Debris/Solid Wastes
1VNIOIUO
:• nvno uood
Standard. Requirement.
Criteria, or Limitation
Federal
FtaaouccaConavcvatton and Racow««y Act
MantttcaHon ol Majwdoua Wa«a*
Tia«Bnanl of Haiaidou* Waata* in • Unit
RaqulianianU lot Ganaiallon . Stwaga.
TiaaBnant. and Dlipoaal ol Ha/atdoua Wana
TuKlc SubatancaaConliol Act
Subpart Q - PCB Spill Cleanup Policy
Gubput 0 - Stoiaga and Oi*po««l
1 1
North Carolina
North Ctiolln* Solid end H*/«idou» Wait*
Managomwil Act
Citation
40 use s«ct i euw •) M«)
4OCFR26I
40CFH ?«4 1
40CfH2«S4(M>
uiilatliilaniliialwj malarial.
IntliioKioi i«<|uli«
-------
' I")
• D
U; A 3 (coniuuiud)
Action Specilic-AMARs
tiiics and Debt is/Solid Wastes
Standard, Requirement.
Criteria, or Limitation
North Carolina (continued)
Nmth Caiollna Huanlou* W**l* Management
Rul**
Cll.ltlOII
NCAC-IO-lul- OOJV »< MM)
NCAC-IO-IO» UOJ2(c)
NCAC 10 IOF (Hi:U(>|)
Ocsciiption
( .,^M«.J.,,I.|U,MWM^.
%l«iul«iI>III:II|>I*|nupi1«i<» «inl i«4«v«iii
A - A|iplit«bl»i»»4uinMiioii(
AH -
OO
ccoc
8°
a.
-------
off the site. As discussed in the Risk Assessment Report,
significant carcinogenic risks are presented by exposure
to offsite contaminated soil/sediment.
This alternative would not prevent the additional
migration of hazardous substances into the surface water,
offsite sediments, or underlying groundwater aquifer.
Compliance with ARARs._ This alternative would have the
same lack of compliance with state and federal ARARs as
Alternative S/S-1 No Action.
Long-Term Effectiveness and Permanence. The long-term
effectiveness of this alternative depends upon the
enforcement 'and maintenance provided. Primary site access
restriction would be maintained by the security fence
around the site. This fence would be required
indefinitely to prevent access. Periodic repair or
replacement of the fence would be necessary. The deed
restrictions would prohibit land uses that could disturb
and/or cause exposure to hazardous substances contained in
the soil/sediment. The deed restrictions would be
required indefinitely and must follow through any future
property transfers. The restriction must be maintained
indefinitely unless future testing determines the
contamination has been naturally attenuated to safe levels
or a future remedial action is undertaken.
This alternative has no long-term effectiveness for
offsite soil/sediment such as that found along the surface
water drainage ditch to the south of the site.
Reduction of Toxicitv, Mobility, and Volume., Since
remedial activities would not occur, there would be no
reduction in the toxicity, mobility, or volume of
soil/sediment contaminants at the site. The existing type
and quantity of hazardous material would remain onsite
undergoing only natural attenuation or migration offsite
through cross-media contamination (e.g., the transport of
soil as sediment to offsite watersheds).
Short-Term Effectiveness. The minimal intrusive
activities involved with installing a peripheral fence
around the site would result in very slight environmental
impacts to workers or the community. Since the fence
would be installed beyond the zone of contaminated
soil/sediment in most cases, simple measures to limit
worker contact with soil/sediment during construction
would be sufficient. The alternative would result in no
additional exposure by the community at large.
Implementability. The installation of a peripheral fence
at the site can be easily implemented. The fence would be
of standard industrial fencing material which is readily
available and involves no special materials. A fence for
the offsite portion of the waterway which contains
8-13
-------
5 9 0059
contaminated soil/sediment would be very difficult to
implement due to factors such as multiple land ownership,
the strong potential for flood damage during heavy rains,
and very difficult construction and maintenance
requirements. Fencing along the offsite waterway is not
included in the development of costs for this alternative.
Deed restrictions are legally implementable for the site
but for offsite property would require either voluntary
compliance by the property owners or condemnation of the
property. In Addition, past experience with waste
disposal sites has demonstrated that deed restrictions may
be ignored by.future landowners or not included as a deed
requirement during property transfers. There is currently
no governmental agency responsible for tracking and
enforcement of such deed restrictions.
Cost. The estimated capital and annual costs of
implementing Alternative S/S-2 are presented in Table 8-9.
The capital costs include the required fencing materials
and warning signs and the legal costs of instituting deed
restrictions on the site only. The annual costs include
fence maintenance, site mowing, and weekly security visits
to confirm the fence integrity. The annual costs to ensure
compliance with the deed restrictions have been estimated.
The 30-year present worth of this alternative would be
$172,000.
No sensitivity analysis was performed for this
alternative.
8.2.3 Alternative S/S-3i Excavation for Offs_ite Landfill
Protection of Hunan Health and the Environment. This
alternative would protect the local community and the
environment by eliminating all contact with soils and
sediments which have a PCB content of over 1 ppm. This
alternative would also eliminate cross-media contamination
of surface water and greatly reduce contamination of the
surficial aquifer groundwater.
The disposal of contaminated soil/sediment in a RCRA or
TSCA landfill, as appropriate to its PCB content, will
prevent future exposure to site contaminants.
Compliance with ARARs. This alternative would comply with
TSCA regulations (40 CFR 761.6) relating to the treatment
and disposal of PCB-contaminated media since all media
with a PCB level of greater than 50 ppm would be .disposed
of in a TSCA-certified landfill. The PCB Spill Policy (a
policy to be considered) requires that a 10-inch layer of
clean soil be placed over any area where PCB-Contaminated
(10 ppm or more) media is excavated. Both of these
alternative options meet this requirement.
8-14
-------
0060 Off Bite transport of contaminated soil /sediment would be
governed by DOT regulations. The proposed landfill
facilities meet the requirements for a RCRA or TSCA
disposal facility, as applicable.
Long-Term Effectiveness and Permanence. The excavation
and removal of the contaminated media from the site and
offsite drainage area would permanently reduce the
residual risk to the local community and the environment.
It would also reduce the potential for cross-media
contamination of surface water, sediment, and
groundwater. Alternative S/S-3A would have greater
effectiveness and permanence since it would remove soil in
the 1 ppm to 10 ppm PCB range which the other option would
not.
Disposal of contaminated soil/sediment in a RCRA or TSCA
landfill is considered to be a permanent disposal method.
Properly designed, sited, and operated, such landfills
would permanently isolate the contaminants from the
general environment.
Alternative S/S-3B would have somewhat lower long-term
effectiveness and permanence than Alternative S/S-3A
because it does not remove the portion of onsite
soil/sediment containing between 1 and 10 ppm PCB.
Although both alternatives meet the PCB Spill Policy, the
potential for continued cros.s-media contamination of
groundwater is greater for the S/S-3B option.
s
Alternative S/S-3B also would place more reliance or.
maintaining the vegetative ground cover than would
Alternative S/S-3A. The 10-inch clean soil cover must be
maintained over soil cover exceeding 1 ppm PCB in order to
provide the required degree of protection of human health.
In general, both of the two above points would apply to
all of the soil/sediment remedial alternatives' "A" and
"B" options.
Reduction of Toxicitv, Mobility, and Volume. Landfill
disposal reduces the mobility of soil/sediment
contaminants but does not effect their toxicity or volume.
Alternative S/S-3A would provide a higher degree of
reduction in pollutant mobility than would S/S-3B because
it removes the portion of the onsite soil containing
between 1 and 10 ppm PCB. This factor would apply to all
of the soil/sediment alternatives' "A" and "B" options.
Short-Term Effectiveness. The principal short term
impacts of implementation of this alternative are due to
the excavation of the contaminated media and the placement
of backfill soil. These activities would result in
8-15
-------
Ci 0 6 ^ increases in ambier.t noise levels, winosiown dust, A.~.C
' soil erosion. These impacts would be mitigated by
limiting the hours of operation, coil moisture control,
erosion control measures, and reatablishing vegetative
cover. The excavation work would be staged and
coordinated with the backfill and seeding activities to
minimize the potential for dusting and erosion.
There would be some risk of exposure to contaminants
during the transport of soil/sediment to the offsite
landfills as a result of dust losses or accidents. The
trailers would be covered and all applicable RCRA and DOT
regulations would be followed. The transport would also
result in unavoidable increases in local truck traffic in
the site area. This effect would be minor given the close
proximity of major roads (Business Route 95) to the site.
Implementabilitv. The excavation, transport, and landfill
disposal of soil are established processes and numerous
contractors would be available to perform the work. Clean
backfill soil is readily available in the area.
A significant potential problem with the transport of
contaminated soil/sediment to offsite RCRA and TSCA
landfills is the current problems with shipments of
hazardous waste from North Carolina to South Carolina or
to Alabama. Both of these states have attempted to tax,
prohibit, or otherwise regulate shipments of hazardous
ir.ateriais to the landfills located in their states.
Cost. The estimated capital and annual cost of
Alternatives S/S-3A ana S/S-3B are presented in Tables
5-10 and 8-11, respectively. Because the exposure risk
due to contact with onsite soil would be eliminated, this
alternative does not include costs for additional
fencing. Periodic mowing and visits by security personnel
would occur, however. The total present worth of
Alternatives S/S-3A and S/S-3B would be $9,228,800 and
$8,463,600, respectively.
8.2.4 Alternative S/S-4: Excavation for Onsite Incineration
Protection of Human Health and the Environment. This
alternative would provide generally the same degree of
protection to human health and the environment as
Alternative S/S-3. All contact with soils or sediments
containing over 1 ppc PCBs would be eliminated. Because
incineration would not eliminate or reduce the inorganic
content of the media, some elevated risk due to ingestion
and dermal contact with inorganics would remain. This risk
would not exceed a chronic hazard quotient of 1 or a
carcinogenic risk index of greater than 10~b for any
affected onsite or offsite population.
POOR QUALITY
ORIGINAL
-------
.------*. i-e requirement* of the Nationa
Ambient Axr Quality Standards (NAAQS) and the National
Emission Standards for Hazardous Air Pollutants (NBSHAP
are relevant and appropriate to this alternative and woi
be complied with by installing air emission control
devices on the incinerator and controlling the release c
fugitive dust and volatile emissions during excavation a
material handling. Incineration of the soil/sediment
would meet the requirements in 40 CFR 761.60 and 761.70.
Compliance with TSCA PCS regulations (40 CFR 761.60 to
761.70} would be achieved by following the treatment,
storage, and disposal requirements for PCBs based on the
form and concentration. Regulations pertaining to
thermal destruction, soil handling, or gaseous waste
treatment, and NESHAP guidelines would be followed throut
the use of air emission control devices at the site.
Since this is a CERCLA site, a National Pollutant
Discharge Elimination System (NPOES) permit is not
required for onsite activities; however, the requirements
WOPId be followed if the scrubber water from the
incinerator is to be treated onsite and discharged to a
local stream. If the scrubber water is discharged to the
Fayetteville wastewater treatment facilities, the
wastewater would be treated as required to meet the city
pretreatment requirements. RCRA Subpart 0 regulations
relating to incinerators would be relevant and
appropriate; however, the more stringent TSCA regulations
would be followed. Applicable OSHA requirements would be
met by following appropriate site safety activities
described in the contractor's Health and Safety Plan. The
North Carolina Hazardous Waste Management Act would be
followed whenever their requirements are more stringent
than the corresponding federal requirements.
Lonq-Tenr. Effectiveness and Permanence. The incineration
of contaminated soil/sediment would permanently eliminate
the hazards associated with organic contaminants such as
PCfi, and dioxin/furans. Removal efficiencies in excess of
99.9 percent of all organic contaminants would be
achieved.
As discussed earlier, this alternative does not eliminate
inorganic contaminants. In fact, incineration may convert
inorganic contaminants to more soluble compounds. This
•tudy assumes that the incinerated aedia would pass the
BPA's toxicity characteristic leachate procedure (TCLP)
and could be replaced in its original offsite and onsite
locations. If this assumption proves to be incorrect, the
treated media would be trucked to an offsite RCRA landfill
and replaced with clean backfill.
8-17
POOR QUALITY
ORIGINAL
-------
U C 0
Alternative S/S-4A would provide greater effectiveness and
permanence since this option would treat onsite
soil/sediment in the 1 ppm to 10 ppm PCS range which
Alternative S/S-4B would not. Continued compliance with
the EPA PCS Guidance would be possible only if the 10-inch
soil cover over media in this range were maintained.
Annual maintenance activities at the site would include
periodic site visits, maintenance of vegetation cover, and
groundwater monitoring. A 5-year review would be required
to ensure the effectiveness of the alternative in
protecting the public health and the environment.
Reduction of Toxicitv. Mobility, and Volume. Incineration
would greatly reduce the toxicity, mobility, and volume of
PCBs, dioxin/furans, and other organic soil/sediment
contaminants. Thermal destruction of PCBs is an
irreversible process with a destruction and removal
efficiency exceeding 99.9999 percent and, therefore, the
alternative would satisfy the statutory preference for
treatment as a principal element of a remedial action.
The effectiveness of this incineration alternative to
destroy organics would have to be tested during the trial
burn. Inorganic contaminants (e.g., copper) may form more
oxidized compounds, but would not be destroyed. The
tcxicity and mobility of these oxidized compounds may be
greater or less than the original inorganic compounds in
the soil /sediment..
Short-Term Effectiveness. The short-term effectiveness of
this alternative would be similar to Alternative S/S-3
with the additional considerations related to emissions
fror. onsite incineration. The same steps to control site
access, fugitive dust emissions, and surface runoff would
be taken. In addition, incinerator exhaust emissions
would be monitored during all site activities to ensure
the effectiveness of incineration emission controls. Even
with the stringent controls placed on incinerator
emissions, combustion by-products and products of
incomplete combustion could be introduced into the
environment.
The short-term risks of this alternative to workers would
be potential exposure to contaminated soil/sediment during
excavation and material handling. There would also be a
risk of worker exposure to inorganic contaminants with
toxic characteristics during soil replacement. These risks
would be minimized by compliance with the OSHA
requirements and guidelines for hazardous waste site
activities.
8-18
-------
Since incineration is a complex industrial operation,
there is always the risk of accidents. Risks associated
with incineration include:
Incomplete destruction of organic contaminants resulting
in the release of toxic or hazardous vapors and
particulates.
Malfunction of the incinerator resulting in fire or
explosion.
Air pollution control equipment malfunction resulting in
release of toxic or hazardous vapors or solids.
Accidental releases due to improper operation.
The threat from these possibilities would be minimized by
following proper operation, maintenance, and safety
procedures.
The time required to implement and complete this remedial
process would be substantial. Depending on which
incineration technology is used, incinerator fabrication
time may be needed and the alternative implementation
could take an additional 8 to 9 months. Since incinerator
feed rates are a function of moisture content and
coinbustibility, increased moisture content or low
combustibility could decrease the throughput to the
incinerator, thus increasing the time necessary to
complete the remediation.
Irr.sler.er.tabilitv. The excavation, thermal treatment, and
replacement soil/sediment are established practices and
contractors that specialize in this type of work are
readily available. Transportation and setup of the mobile
incinerator are also proven operations, but could be time
consuming. Coordination between site activities may be
difficult due to the limited size of the site.
The use of a transportable incinerator to destroy organic
contaminants is a proven and reliable technology.
Inorganic contaminants would not be destroyed as discussed
previously. O&M requirements for a mobile incinerator are
fairly extensive, but would normally be the responsibility
of the incinerator owner/operator.
Complex operating procedures would require fully trained
operating personnel. Detailed and careful monitoring of
the incineration processes would be required. Laboratory
analyses of the incinerated residue would be required to
ensure that the organic contaminants were being
effectively destroyed. Additionally, samples from
8-19
-------
excavated soxi/ sediment would oe taxen to coniirs tr*at tr.e
59 0065 contaminated surf ace/sediment is removed to acceptable
levels.
A major consideration in evaluating the impl«mentability
of an onsite incinerator is the location of a waste
incinerator on a relatively small site and in such close
proximity to a food processing facility, Larry's Sausage.
A very high degree of stack emission controls would be
required to ensure that operation of the incinerator met
all ARAR's.
Costs. The estimated capital and annual costs for
Alternatives S/S-4A and S/S-4B are presented in Tables
8-12 and 8-13 respectively. A major assumption in the
development of this alternative's cost is the assumption
that the treated soil/sediment could be placed back in its
original location. The total present worths of
Alternatives S/S-4A and S/S-4B are $18,019,300 and
$16,301,200, respectively.
8.2.5 Alternative S/S-5; Excavation for Onsite Chemical
Dechlorination
Protection of Human Health and the Environment. This
alternative would protect human health and the environment
from PCS contamination located at the Carolina Transformer
site by chemically treating the contaminated soil/sediment
and dechlorinating the PCB molecules. The chemical reagent
would be recovered and reused, any wastes would be
incinerated offsite and the treated soil/sediment would be
redeposited onsite. This alternative would have no effect
en inorganic soil contaminants such as copper.
The excavation and treatment of the contaminated
soil/sediment in conformance with the specified cleanup
level (<1 ppzr. for Alternative S/S-5A, or <10 ppn: for
Alternative S/S-5B) would effectively minimize danger to
public health and the environment at the site from PCBs
and other chlorinated hydrocarbons to approximately the
same extent as onsite incineration. Carcinogenic risk
would be reduced to the range of 1 x 10"4 to 1 x
10~ . Non-carcinogenic risk factors due to contact or
ingestion of soil/sediment would not be increased. This
alternative eliminates the primary contaminants of concern
to the other biotic receptors, both plant and animal, as
well.
Compliance with ARARs. The requirements of NAAQS and
NESEAP are relevant and appropriate to this alternative
and would be complied with by implementing air emission
control devices on the dechlorination equipment and
controlling the release of fugitive dust and volatile
emissions during material handling.
8-20
-------
Tr.-s alternative may ^ not ce in compliance with parts of
TSCA chemical-specific and action-specific regulations,
including 40 CFR 761.60, 761.70, and 761.75.
Soil /sediment having PCS concentrations in excess of 50
ppm are specifically required by Part 761.60 (a) (4) to be
disposed in an incinerator (761.70), chemical waste
landfill (761.75), or by equivalent treatment (761.60
(a)). Chemical dechlorination will require pilot
treatment tests to be considered an equivalent treatment
method since limited studies are available that document
its effectiveness and effectiveness may vary with
soil /sediment composition and other factors.
The evaluation of the federal location-specific ARARs
would be similar to the evaluation of the onsite
incineration alternative with the exception that a
pollutant dispersion analysis would not be required since
there is no onsite combustion involved. The same state
ARARs would also apply.
Lono-Term Effectiveness and Permanence. The extent of
residual risk posed by the chlorinated hydrocarbon
contaminated material would be reduced and possibly
eliminated depending on the degree of dechlorination
achieved with the implementation of this alternative. The
destruction cf such organic contaminants at the site would
reduce the long-term risks associated with direct human
contact and inhalation and with cross-media
•contamination. The system is ineffective in removing
inorganic contaminants from soil/sediment media.
The remaining reagent and rinse water would be recycled or
incinerated cffsite and the treated soil/sediment would be
redeposited onsite.
Reduction of Toxicity, Mobility and Volume. Chemical
dechlorination. has been demonstrated to reduce PCB
concentrations in transformer oil to <10 ppm. Full scale
demonstration plants have achieved reductions in soil
media to a residual of less than 2 ppm. Since the PCB and
other chlorinated hydrocarbon contaminants would be
permanently destroyed, chemical dechlorination could
essentially eliminate the toxicity, mobility, and volume
of the contaminants and satisfy the statutory preference
for treatment as a principle element of a remedial
action .
Short-Tenn Ef feetivenesa . Temporary hazards to the
community and the environment during the implementation of
this alternative would include the possibility of release
of and exposure to contaminants transported by surface
runoff, adsorption of airborne dust, or release by
8-21
-------
UUo/ process. The potential for release or exposure via these
routes would be minimized with the use of benns and sumps
to control runoff, nonreactive dust suppressants and wind
screens to prevent fugitive dust emissions, and vehicle
decontamination to prevent spread of contaminants
offsite. Even with the use of emission controls during
implementation of this alternative, some uncontrolled
emissions to the environment can be expected.
Implementabilitv. Handling of contaminated soil/sediment
during chemical dechlorination are established procedures
and contractors that specialize in this type of work are
generally available.
Research on polychlorinated compounds has shown that a
catalyst can be used at room temperature to cause a rapid
reduction reaction where chlorine atoms on the organic
compound are replaced with hydrogen atoms. However, the
process may not completely dechlorinate some organic
chemicals and may produce equally toxic or more toxic
byproducts. A treatability study using site specific
soil/sediment would be required to determine the
dechlorination efficiency, reagent requirements, and
byproducts produced. Such testing would determine if
further remedial action is required to treat the
byproducts produce.
Cost. The detailed capital and annual cost estimates for
Alternative S/S-5A and Alternative S/S-5B are presented in
Table 8-14 and Table 8-15, respectively. The capital
costs associated with implementation include treatability
testing, material handling, chemical dechlorination,
soil/sediment sampling, and site restoration. Included in
the cost of chemical dechlorination is the operating cost
of the dechlorination equipment and disposal of residual
reagent and rinse water offsite by the contractor. Annual
costs associated with this alternative include mowing the
revegetated areas and weekly visits by security
personnel. As in the onsite incineration alternative,
this alternative's costs are based on the assumption that
the treated soil/sediment can be redeposited in its
original location. The total present worth of
Alternatives S/S-5A and S/S-5B are $8,560,900 and
$7,820,800, respectively.
8.2.6 Alternative S/S-6; Excavation for Onsite Solvent
Extraction
Protection of Human Health and the Environment. This
alternative would protect the local community and the
environment by chemically treating the contaminated
soil/sediment containing PCB concentrations above 1 ppm
8-22
-------
0068 (for Alternative S/S-6A; or above 10 ppz ;icr A-tezr.a-ive
uuwu S/S-6B) . The treatment would involve the extraction of
the PCS molecules from the soil. The treated soil would
be redeposited onsite and the solvent residuals would be
transported offsite for recycling or incineration.
Treatment of the soils and removal of the PCB contaminants
would control the risk of direct contact or ingestion of
PCBs in the contaminated soils. Depending upon the
solvent used, this alternative may also be effective for
other organic contaminants such as dioxin/furans. The
treatment system would not reduce risks associated with
cross-media contamination by inorganic contaminants.
Compliance with ARARs. This alternative's compliance with
ARARs would generally be the same as onsite
dechlorination. The concentrated wastes which would be
drummed for offsite incineration must meet RCRA and DOT
regulations for shipment of hazardous materials. This
alternative does not.generate a wastewater stream,
therefore, no discharge to surface waters or the POTW
would be required.
Long-Term Effectiveness and Permanence. The long-term
effectiveness and permanence of this alternative would be
similar to the previous alternative, dechlorination,
except that the organic contaminants would be concentrated
and then incinerated offsite. Residual organic
contamination in the treated soil/sediment would be
similar. The residual risk due to all forms of contact
with onsite and offsite soil/sediment would be reduced.
Reduction of Tcxicity, Mobility, and Volume. The solvent
extraction process achieves reductions in the toxicity and
volume of organic contaminants and in the mobility of
inorganics. The process concentrates the organic
contaminants in a liquid waste stream which is then sent
to an incinerator for destruction. The process has
demonstrated over 99 percent PCB removal from soils and
sediments in demonstration scale projects. Similar
removal efficiencies would be expected for dioxin/furans
and other organics. The soil does retain a residual TEA
content of up to 500 ppm, however, TEA is not toxic and
readily biodegrades. The process does not reduce the
toxicity or volume of inorganic contaminants. It does,
however, convert metals such as mercury, lead, zinc,
chromium, and copper to their lowest solubility states,
thus minimizing their mobility.
8-23
-------
Short-Term Effectiveness. The short-term impacts of the
solvent extraction process would be very similar to
dechlorination. The principle effects would be the result
of excavation and replacement activities, not the solvent
extraction equipment.
Hazardous materials extracted from the soil/sediment would
be transported to an offsite licensed incinerator.
Implementability. As in the two previous alternatives,
the material handling portion of this alternative uses
established practices and contractors that are readily
available. The solvent extraction process must be pilot
tested prior to implementation to confirm removal
efficiencies, number of extraction cycles, solvent
consumption, and other process variables. Such testing
would also confirm whether the treated media is suitable
for replacement or whether it must be landfilled offsite.
Cost. The detailed;capital and annual cost estimates for
Alternatives S/S-6A and S/S-6B are presented in Tables
8-16 and 8-17, respectively. The capital costs included
material handling, pilot plant operation, solvent
extraction, confirmation testing, and site restoration.
Annual costs are limited to periodic site mowing and
security inspections. The total present worths of
Alternatives S/S-6A and S/S-6B are $9,346,000 and
$8,529,800, respectively.
8.3 Structure Alternatives
8.3.1 Alternative S-l: No Action
Protection of Human Health and the Environment. The
Remedial Investigation and Risk Assessment for the
Carolina Transformer site^did not identify any chemical
contamination risks associated with the onsite structures
although the possibility exists that untested surfaces may
contain high levels of PCBs. Physical risks do exist to
trespassers due to the uncertain structural soundness of
the buildings. The integrity of the structures can be
expected to continue to deteriorate, increasing this
risk. The "no action" alternative would not provide any
mitigation of this risk.
The onsite building provides no hazard to the environment
unless undetected high levels of PCS contamination exists
on walls and floors.
Compliance with ARARs. The results of PCB surface
contamination tests indicate that the structure currently
meets the PCB Spill Cleanup Policy for high
8-24
-------
n ,., n ^... - .. ._ «,._. .,_ _
59 OU/u this level, the "no action" alternative would not bring
these areas into compliance.
Long-Term Effectiveness and Permanence. Because remedial
actions would not occur, the existing chemical and
physical risks at the site would remain. Since site
controls would not be implemented, the criterion
addressing the adequacy and reliability of controls is not
applicable to the alternative.
Reduction of Toxicitv. Mobility, and Volume. Since
remedial activities would not occur, there would not be a
reduction in the toxicity, mobility, or volume of
contaminants at the site. If present, the existing type
and quantity of hazardous material would remain on site.
Short-Term Effectiveness. Because site activities would
not occur, protection of workers and the community would
not be required. Environmental impacts due to
construction or implementation would not be encountered
since there would be no activities performed at the site.
Implementability,. This criterion is not applicable
because remedial activities would not occur. Services and
materials and the activities normally needed to coordinate
with other agencies would not be necessary.
Cost. There would be no costs incurred since remedial
activities would not be performed.
8.3.2 Alternative S-2: Fencing
Protection of Kurr.an Health and the Environment. Risks
associated with structurally unsound building and denr.al
contact with potentially contaminated surfaces would be
controlled by access restrictions. Security fencing with
warning signs would reduce (but not eliminate) the
possibility of site trespassers gaining access to the
buildings.
Compliance with ARARs. As described in Section 8.3.1.
this alternative would not meet ARARs related to PCS spill
cleanup if contaminated surfaces exists.
Long-Term Effectiveness and Permanence. The long-term
effectiveness of this alternative depend upon the
enforcement and maintenance provided. The security fence
would be required indefinitely to prevent access.
Periodic repair or replacement of the fence would be
necessary.
Reduction of Toxicitv, Mobility, and Volume. Since
remedial activities would not occur, there would not be a
8-25
-------
0 0 /' "l reduction in the toxicity, mocj-iity, or volume of
structure contaminants at the site. If present, the
existing type and quantity of hazardous material would
remain onsite.
Short-Term Effectiveness. The minimal intrusive
activities involved with installing a peripheral fence
around the site would result in very slight environmental
impacts to workers or the community. Since the fence
would be installed beyond the zone of contamination from
the structures/ simple measures to limit worker contact
with contaminated structures during construction would be
sufficient.
Implementabilitv. The installation of a peripheral fence
at the site can be easily implemented. The fence would be
of standard industrial fencing material which is readily
available and involves no special materials.
Cost. The costs associated with this alternative are
presented in Table 8-18. The total 30-year present worth
of this alternative would be $168/900.
8.3.3 Alternative'S-3; Partial Demolition
Protection of Human Health and the.Environment. By
demolishing all building roofs and walls, this alternative
would eliminate hazards to trespassers due to
deteriorating structural integrity. Solvent treatment of
PCB-contaminated floor surfaces (Alternative S-3B) , if
required, will reduce the potential risks associated with
the remaining floor slabs.
Compliance with ARARs. The demolition of the structures'
roofs and walls will be conducted in accordance with
applicable OSKA worker safety regulations. Alternative
S-3A assumes that the floor slab surfaces currently comply
with PCB Spill Cleanup Policy of 10 ug/100 car. If some
floor areas currently exceed this level. Alternatives S-3B
would achieve this ARAR by solvent washing the areas.
Incineration of the solvent and rinses would be conducted
in an appropriately certified TSCA incinerator.
Non-hazardous demolition debris would be disposed of in a
licensed landfill.
Long-Term Effectiveness and Permanence. Both alternatives
S-3A and S-3B would provide the same degree of long-term
effective reduction in the hazards associated with onsite
structures. Both would be permanent solutions since all
demolition debris (and wastewater if applicable) would be
removed from the site.
8-26
-------
f-
59 U U / Z Reduction of Toxicxtv. Mobility, and Volnmo Thiscategcry
is not applicable for Alternative S-3A since it assumes
that the only hazard presented by the onsite structures is
a physical hazard due to deteriorating structural
soundness, if PCB contamination on floor surfaces
requires treatment, Alternative S-3B, solvent washing
concentrates the contaminant in a solvent and rinse
liquids which would be incinerated. This alternative would
provide destruction of the contaminant.
Short-Term Effectiveness. Short-term risks to the
environment and the local community during site activities
would involve airborne dust during demolition activities
and transport of demolition debris to the landfill. For
Alternative S-3B, there would also be a rick of exposure
to contaminants during offsite transport of solvent and
rinse wastes as a result of an accidental spill. RCRA and
DOT regulations are designed to minimize the danger of
accidental release during transport and reduce the hazards
associated with such;a release should it occur. Site
access would also be restricted during implementation to
prevent accidental exposure to the public. Transport of
demolition debris would result in uncontrollable effects
such as increased traffic in the area of the site which
would lead to increased noise and fugitive dust emissions.
Implementability. The demolition of structures is an
established practice and contractors that perform this
work are readily available. Chemical treatment of the
building slabs is an innovative technology that has been
shown to be effective in extracting PCB molecules as deep
as 1-inch in r.on-earthen surfaces such as concrete slabs.
Implementation of this alternative would require that the
chemical treatment process be demonstrated to provide
treatment of PCB contaminated material to 10 ug/100
cm . The effectiveness of the chemical treatment would
have to be evaluated during demonstration testing.
Cost. The detailed capital and annual cost estimates for
Alternatives S-3A and S-3B are presented in Tables 8-19
and 8-20, respectively. The capital costs associated with
these alternatives include demolition of the roofs and
walls of the structures, chemical treatment of the
building slabs and disposal of the demolition debris and
the waste from the chemical treatment. The annual O&M
cost would include fence maintenance and weekly security
visits. The total present worth of these alternatives is
estimated to be approximately $189,700 and $238,100,
respectively.
8.3.4 Alternative S-4: Complete Demolition
8-27
-------
r p, - 7 Protection of Buman Health and the Envimnmonr . inese
L o / o alternatives provide essentially the case degree of
protection to human health and the environment as partial
demolition alternatives since the floor slabs present no
significant hazards if the PCB level of the slabs meets
the 10 ug/lOOcnr remedial goal.
Compliance with ARARS. Complete demolition of the site
structures will be conducted in accordance with OSHA
worker safety regulations. Spot areas of concrete which
contain excessive PCB contamination would be removed and
landfilled in a TSCA landfill. The remaining demolition
debris will be disposed of in a construction material
landfill meeting state requirements.
Lono-Tenn Effectiveness and Permanence. The demolition
and removal of the structures from the site would
effectively minimize the danger to the public and the
environment in the area of the site. In addition,
placement of the PCB-contaminated material in a secure
landfill would reduce the potential for the migration of
contaminants into the soil and groundwater.
Reduction of Toxicitv, Mobility, and Volume. This
category is not applicable to Alternative S-4A since it
assumes that the only hazard presented by the structures
is a physical one due to deteriorating structural
soundness. If PCB contamination of floor surfaces is
present, the removal and; landfill of this material would
reduce its mobility but would have no effect on the volume
cr toxicity of the contaminated material.
Short-Term Effectiveness. The short term risks to the
environment and the local community wold be essentially
the same as those presented by partial demolition. The
separate removal and disposal of PCB-contaminated concrete
flooring would result in the generation of minor amounts
of fugitive dust which could be contaminated with PCBs.
Dust collection equipment would be used on this equipment
for protection of the general public and demolition
workers.
Implementabilitv. The demolition of structures as well as
offsite transportation and disposal of contaminated
materials would be easily implemented using conventional
construction technologies. These technologies are all
established and proven methods of hazardous waste
remediation.
Cost. The detailed capital and annual cost estimates for
Alternatives S-4A and S-4B are presented in Tables 8-21
and 8-22, respectively. The capital cost categories for
these alternatives are the same as for partial demolition
8-28
-------
_ with tne addition ci esses for bre~v_r.s up tne a^a^s ar.d
59 U U /4 foundations and transporting the additional waste volume
to the landfill. The total present worth of these
alternatives would be $337,900 and $369,700, respectively.
8.5 Debris/Solid Waste Alternatives
8.5.1 Alternative D-l; No Action
Protection of Human Health and the Environment. Since
remedial action would not be initiated, this alternative
would not provide any protection to human health or the
environment. Specifically, the non-carcinogenic hazard
index would be greater than 1 for future onsite residents
and carcinogenic risk would be greater than 1 x 10~6 for
all populations evaluated in the Risk Assessment Report.
Also concern for PCB exposure by terrestrial animals,
birds, and plants would not be reduced.
Compliance with ARARs. The no action alternative would
not meet ARARs; specifically, TSCA regulations for cleanup
and disposal of PCB spills. Violations of state water
quality standards in the periodic surface waters leaving
the site would be expected to occur due to cross-media
contamination. Cross-media contamination of groundwater
would also be expected to continue.
Long-Tern^ Effectiveness and Permanence. Because remedial
actions would not occur, the existing risks at the site
would remain. Since site controls would not be
implemented, the criterion addressing the adequacy and
reliability of controls is not applicable to the
alternative.
Reduction of Toxicityf Mobility, and Volume... Since
remedial activities would not occur, there would not be a
reduction in the toxicity, mobility, or volume of
contaminants at the site. The existing type and quantity
of hazardous material would remain onsite. Cross-media
contamination of groundwater, surface water, and sediment
would continue to occur.
Short-Term Effectiveness. Because site activities would
not occur, protection of workers and the community would
not be required. Environmental impacts due to
construction or implementation would not be encountered
since there would be no activities performed at the site.
Implementabilitv. This criterion is not applicable
because remedial activities would not occur. Services and
materials and the activities normally needed to coordinate
with other agencies would not be necessary.
Cost. There would be no costs incurred since remedial
activities would not be performed.
8-29
-------
8.5.2 Alternative D-2; FeriC^ng
Protection ef Human Health and the Environment. Risks
00/5 associated with dermal contact with or ingestion of onsite
contaminated debris/solid wastes would be controlled by
these access restrictions. Security fencing with warning
signs would reduce (but not eliminate) the possibility of
site trespassers coming into contact with contaminated
onsite media. This alternative would not be effective at
protecting human health or the environment offsite. This
alternative would not prevent the additional migration of
hazardous substances into the surface water, offsite
sediments, or the underlying groundwater aquifer.
Compliance with ARARs. As described in Section 5.4.1.2.
this alternative would not meet state and federal ARARs.
Lona-Term Effectiveness and Permanence. The long-term
effectiveness of this alternative depends on the
enforcement and maintenance provided. Primary site access
restrictions would be maintained by the security fence
around the site. The fence would be required indefinitely
to prevent access. Periodic repair or replacement of the
fence would be necessary.
Reduction of Toxicity, Mobility, and Volume. Since
remedial activities would not occur, there would be no
reduction in the toxicity, mobility, or volume of
debris/solid waste contaminants at the site. The existing
type and quantity of hazardous material would remain
onsite undergoing only natural attenuation or migration
offsite through cross-media contamination.
Short-Term Effectiveness. The minimal intrusive
activities involved with installing a peripheral fence
around the site would result in very slight environmental
impacts to workers or the community. Since the fence
would be installed beyond the zone of contaminated
debris/solid wastes in most cases, simple measures to
limit worker contact with debris/solid waste during
construction would be sufficient. This alternative would
result in no additional exposure by the community at
large.
Implementability. The installation of a peripheral fence
at the site can be easily implemented. The fence would be
of standard industrial fencing material which is readily
available and involves no special materials.
Cost. The costs for this alternative would be identical
to Alternative S-2: Fencing which were presented in Table
8-18.
8-30
-------
59 uu/ c
8.5.3 Alternative D-3; Offsite Landfill
Protection of Human Health and the Environment. This
alternative would provide protection from the hazards
associated with current site conditions by permanently
removing the debris/solid wastes from the site for
disposal in an offsite sanitary landfill, RCRA-permitted
landfill as appropriate. Disposal in a secure hazardous
waste landfill, or TSCA landfill, would eliminate the
threat of direct contact with PCBs and reduce the threat
of potential migration of these contaminants into the soil
and to the >groundwater.
Compliance with ARARs. All debris and solid wastes with a
PCB level of greater than 50 ppm would be transported to a
TSCA facility disposal in compliance with 40CFR 761
(a)(4). If any debris has a HOC exceeding 1000 ppm, it
will be incinerated at the facility in accordance with
RCRA 40 CFR 264 Subpart 0. Liquids if present, would be
drummed and incinerated in accordance with 40 CFR 268.42
(a) (1).
Long-Term Effectiveness and Permanence. The removal of
debris/solid waste from the site would effectively
minimize the danger to the public and the environment in
the area of the site. In addition, placement of
contaminated material in a secure landfill would reduce
the potential for the migration of contaminants into the
croundwater.
The long-term risks associated with offsite disposal would
, be the responsibility of the owner/operator of the
selected hazardous waste facility. Exposure dangers would
be minimized by conformance to RCRA and TSCA regulations
pertaining to leachate control, groundwater monitoring,
and cap maintenance. A long-term residual risk, however,
would be associated with this alternative since
contaminants are contained rather than treated or
destroyed.
Reduction of Toxicity, Mobility, and Volume. Since
disposal in an offsite landfill does not permanently
destroy or treat contaminated material, it would not
directly reduce the toxicity or the volume of the
contaminated material. However, the mobility of the
contaminants would be indirectly reduced through offsite
containment. Landfill disposal is not an irreversible
process and would not comply with the statutory preference
for treatment as a principle element of a remedial action.
8-31
-------
59 uu / /
Short-Term Effectiveness. The short-term risks associated
with implementation of this alternative would involve
exposure of the public and the environment to contaminants
from migration in airborne dust, surface runoff, or as a
result of an accidental spill during offsite transport.
The potential for contaminant migration could be reduced
through use of nonreactive dust suppressants along with
berms and sumps. RCRA and DOT regulations are designed to
minimize the danger of accidental release during transport
and reduce the hazards associated with such a release,
should it occur. Transport of contaminated material
offsite would result in increased traffic in the area of
the site which would increase noise and fugitive dust
emissions. .Even with the use of emission controls, some
uncontrolled emissions can be expected. All vehicles
would be decontaminated before leaving the site to prevent
the spread of contamination to the local community. A
potential for worker exposure to contaminants, including
volatile PCBs, would.'exist during excavation, material
handling, transport, and landfill placement. Worker risk
would be minimized by compliance with OSHA guidelines and
requirements for hazardous waste site work.
Implementabilitv. Excavation and site restoration, as
well as offsite transport and disposal of contaminated
soil, would be easily implemented using conventional
construction technologies. These technologies are all
established and proven methods of hazardous waste
remediation. Contractors that specialize in this type of
work are readily available.
Cost. The detailed cost estimate for the offsite disposal
alternative is presented in Table 8-23. Capital costs
involved in implementing this alternative would include
material handling, offsite transportation, and disposal.
The total present worth of this alternative would be
$67,600.
8.6 State Acceptance
The State of North Carolina, as represented by the North
Carolina Department of Environmental, Health, and Natural
Resoures, concurs in the selection of Alternatives G-4, S/S-6,
S-3, and D-3 as the preferred Alternative for the Carolina
Transformer Site.
8.7 Community Acceptance
During the public meeting, held on April 17, 1991, the
Fayetteville community had no objections with the selection of
Alternatives G-4, S/S-6, S-3, and D-3 as the preferred
Alternative for the Carolina Transformer Site.
8-32
-------
Tables 8-1 through 8-3 present a summary ranking of each
alternative against the evaluation criteria and each
alternatives present worth cost. Each alternative performance
against the criteria was ranked on a scale of zero to five,
with zero indicating that none of the criteria's requirements
were met and five indicating all of the requirements were met.
8-33
-------
en
13
08
33
Tatile H.I
Homodial Alloinativcs Evaluation Summary
Ginnndwalcr
AlternatK/e
G-1: No Act Ion
G-2: Dead Rttsliicilons
G-3A: Mnials Removal/Air Stripping/
Adsorption/Discharge to River
G-3D: Metals Removal/Air Stripping
Adsotptlon/Dlscharge to POTW
G-4A: Metals Removal/AdsorptlorW
Discharge to River
G-4B: Metals Removal/Adsorption/
Discharge to POTW
6-5: Adsorption/Discharge to River
G-6A: Metals RemovalAJV Oxidation/
Discharge to River
G-6B: Metals Removal/UV Oxidation/
Discharge to POTW
G-7: UV Oxldaticn/Dlscharge to River
Criiuda Rating*
Pioiotilon ol
Human Hoalth
and the
rrivirnniiinnl
0
:i
s
s
!>
S
3
&
6
3
Compliance
With AHAMS
o
(1
fl
!>
" &
3
S
t>
4
1 OIHJ Tofin
l-llnciivcinnss
and
r'orm.monr.o
0
;i
f>
5
!>
'.,
5
S
&
!i
Reduction in
Toxiclly.
Mobility.
and Volume
0
0
5
5
5
5
4
5
5
4
Shori-Term
Effectiveness
NA
5
4
4
5
S
5
S
5
5
Implemeniaullily
NA
4
5
5
5
S
5
S
5
5
Present
Worth
Cost (S)
0
SO .000
878.500
949.700
830.500
898.800
435.000
993.300
1.055 .500
590.600
C
C
-^
VI
• Rating ol 0 indicates complale noncomplianco wiih cntona
Hating ol 5 Indicates complete compliance with
-------
Tahlo 8.2
Rnrnodinl Aliornaiivos I-valuation Summary
O
oo
5} 30
00
Aliornative
S/S- 1 : No Action
S/S-2: Fence/Doed Restrictions
S/S-3A. Excavation tor Ollsile Landlill
(PCBs > 1 ppm)
S/S-3B: Excavation lor Ollslle Landlill
(PCBs > 10 ppm)
S/S 4A: Excavation lor Onslle Incineration
(PCBs > 1 ppm)
S/S-4B: Excavation lor Onslte Incineration
(PCBs > 10 ppm)
S/S-5A: Excavation tor Onsila Chemical
Dechlorlnatlon (PCBs > 1 ppm)
S/S-5B: Excavation lor Onsite Chemical
Dechlorlnatlon (PCBs > 10 ppm)
S/S-6A; excavation lor Onslle Sotvoni
Extraction (PCBs > 1 ppm)
S/S-6B: Excavation lor Onsite Solvent
Extraction {PCBs > 10 ppm)
Criteria Haling"
Protection ol
tinman Hoallh
and iho
Mnvironnmni
0
•f.
5
4
5
4
5
4
'.,
4
Compliance
wiiti AMAH;,
0
o
!•
'.,
4
4
f>
I>
s
;>
1 oni.i lerm
1. iloclivonoss
nnrl
1*1)1 m.llKHH.O
0
'/
S
4
!>
4
5
4
!>
4
rioduclion in
Toxiciiy.1
Mobility,
and Volume
0
0
3
3
5
4
5
4
5
4
Short-Term
Effectiveness
NA.
5
5
5
4
4
5
5
S
S
Implemeniablilly
NA
4
5
5
3
3
5
5
5
5
Present
Worth
Cos) ($)
0
172.000
9.228.800
8.463.600
18.019.300
16.301 .200
8.560.9OO
7.820.800
9.346.000
a.S39.600
O
CO
O
Baling of 0 indicates complete noncompllanco with criteria.
Haling ol 5 indicates complete compliance wiiii (iinin.i
-------
en
vo
Tatilo H.;j
H«:mi!(1i;il Alternatives Evaluation Summary
Gtiuctiircs ar\d Dnhiis/Soltrl Wastes
"Tl
00
v«/
t£—
oo
•gl *•—
5s* r—
1""" Llj
^
Alternative
Slucluros
r>-t: No Action
S-2: Fencing
S-3A: Partial Demolition
S-30: Partial OomolHlon
S 4A Cornploto Dtiinolilkin
S 41) Coniploln Diiiriolltion
ODDiiS/AolUIWasliK.
D I: No Action
D-2: l-'oni.ino
I)- 3: Ollsito Disposal
Protection nl
Human llu.illli
and Mm
(-'nwironinonl
;;
:t
3
4
4
!,
1)
:>
!»
Com ,„,,,
Will) AIIAUS
NA
NA
NA
NA
NA
NA
0
0
S
loin) lonn
1 iliii.livunoss
.UK!
Pomunonco
'.'
II
.1
4
•I
'.,
0
•1
••>
taliny*
Iteduction m
loxicily.
MoDllily.
and Volume
n
0
!,
S
0
0
4
Snort-Term
HltoctK/enoss
NA
h
4
4
3
3
NA
5
3
Implementabtlily
NA
5
b
s
5
5
NA
5
5
Present
Worth
Cost ($)
0
HiB.OOO
\ 00.700
?:HI.
-------
59 0082
9.0 Selected Remedy
EPA has selected combination of the alternatives presented in this
document to serve as the selected remedy for the Carolina Transformer
Site. The selected remedy is protective of human health and the
Environment. Those alternatives EPA has selected to serve as the remedy
for the Carolina Transformer Site are listed below. (Tables 9-1 and 9-2
list the remedial goals that will be met by the selected remedy.) There
may be some changes made to the remedy as a result of the remedial
design and construction process. However, such changes in general
reflect modifications resulting from the engineering design process.
1. Alternative S/S-6; Excavation of the contaminated soil with PCB's in
excess of 1 ppm and,use of a solvent extraction process to separate
organic contaminants such as PCB', dioxin/furans, volatile organics,
and polynuclear aromatic compounds from the soil and sediments. The
process will convert inorganic contaminants such as lead and copper
to lower solubility hydroxides thereby reducing their mobility.
TCLP will be run on the treated soil and sediment prior to its
return to its original location to determine if it meets the RCRA
Toxicity Characteristic Rule. The treated soil and sediment will
also be modeled to assure that its placement will not cause
violation of North Carolina's Groundwater Standards. Soil and
sediments not meeting the Toxicity Rule or which is shown by
modeling to cause future violations of North Carolina's Groundwater
Standards will be solidified. The contaminant rich waste stream
will be transported off site for treatment. Table 9-3 lists the
major components involved and their associated cost.
2. Alternative S-3; Demolition of the roofs and walls of the three
on-site buildings. The debris would be crushed and transported to an
off-site landfill. If the remaining slabs are found to be
contaminated with PCBs in excess of lOug/lOOcnr they will be
treated with a solvent washing system to extract the residual PCBs.
Table 9-4 list the major components and their associated cost.
3. Alternative D-3; The debris and solid waste from the site will be
transported to an off-site landfill for disposal and/or treatment in
accordance with RCRA 40 CFR 264 Subpart 0 and 40CFR 761 (a)(4).
This alternative is designed to reduce the risk associated with
direct contact with materials remaining on site to within the 10"5
carcinogenic risk level and the non-carcinogenic hazardous index of
1. Table 9-5 lists the major components and their associated cost.
4. Alternative G-4; Install groundwater extraction wells and use a two
component treatment system (Metals Removal, Adsorption) to remove
the metals and organic contaminants. The risk to future users of
groundwater associated with ingestion, inhalation, and dermal
contact with contaminants in the groundwater would be reduced by
this pump and treat system. The operation of the system would
continue until the groundwater meets the remediation goals listed in
9-1
-------
Table 9-1. Table 9-6 list the major components and their associated
cost.
The goal of this remedial action is to restore ground water to its
beneficial use, which is a potential potable water source. Based
on information obtained during the remedial investigation and on a
careful analysis of all remedial alternatives, EPA believes the
selected remedy will achieve this goal. It may become apparent,
during implementation or operation of the ground water extraction
system and its modifications, that contaminant levels have ceased to
decline and are remaining constant at levels higher than the
remediation goal over some portion of the contaminated plume. In su
a case, the system performance standards and/or the remedy may be
re-evaluated. >
The selected remedy will include ground water extraction for an
estimated period of 10 years, during which time the system's
performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during
operation. Modifications may include any or all of the following:
a) at individual wells where cleanup goals have been attained,
pumping may be discontinued;
b) alternating pumping at wells to eliminate stagnation points;
c) pulse pumping to allow aquifer equilibration and to allow
adsorbate contaminants to partition into ground water; and
d) installations of additional extraction wells to facilitate o
accelerate cleanup of the contaminant plume.
To ensure that cleanup goals continue to be maintained, the aquifer
will be monitored at those wells where pumping has ceased on an
occurrence of every 5 years following discontinuation of ground wate
extraction.
If it is determined, on the basis of the preceding criteria and the
system performance data, that certain portions of the aquifer cannot
be restored to their beneficial use, all of the following measures
involving long-term management may occur, for an indefinite period o
time, as a modification of the existing system:
a) engineering controls such as physical barriers, or long-term
gradient control provided by low level pumping, as containment
measures;
b) chemical-specific ARARs will be waived for the cleanup of
those portions of the aquifer based on the technical
impracticability of achieving further containment reduction;
c) institutional controls will be provided and maintained to
restrict access to those portions of the aquifer which remain
9-2
-------
as
n P, ,-r ^ above health-based goals, since this aquifer is classified
5 9 UUOHa potential drinking water source;
d) continued monitoring of specified wells; and
e) periodic re-evaluation of remedial technologies for
groundwater restoration.
The decision to invoke any or all of these measures may be made duri
a periodic review of the remedial action, which will occur at
intervals of at least every five years, in accordance with CERCLA
121(c). To ensure State and public involvement in this decision at
this Site, any changes from the remediation goals indentified in thi
ROD will be formalized in either an Explanation of Significant
Difference document or an Amendment to this Record of Decision,
thereby providing an opportunity for State and public.
Monitoring wells will be installed into the lower aquifer to confirm
its status. If it is found''to be contaminated, the groundwater
treatment system mentioned above will be expanded to address the
contamination of the lower aquifer. The protectiveness of the
remediation of the lower aquifer will be identical to that of the
shallow aquifer and meet the same groundwater quality criteria
The treated groundwater will be discharge to the Fayetteville POTW o
the unnamed tributary to the Cape Fear River.
9-3
-------
5 9 0035
Grcundwater Remediation Goals
Contaminant
Aluminum
Barium
Cnrcmium
Cccal:
Ccppe:
Lead
Manganese
Merc'jry
Nickel
Strontium
Tiiar.ljm
va.-.adijm
Y::r urn
Z:r=
E^V-e'Sr-x-— a;*-
^r~r-:T'='"~eT"5
Careen Dis.:':ce
C ~ • i~ -C
:.*-D;c-:cr:ce-;e-e
Maximum
Detecteo
Concentration
ug/l
1,900,000
19.000
2.900
670
3.CCC
. 190
25. COO
0.4
1 .200
1,400
6.700
4900
1.5CO
3.5CO
52
92:
^
- :
V -
21
37
Upgradient
Concentration
Ranqe *
ug/l
1.900-740.000
250-6.000
32-640
ND" -180
25-340
ND-110
270-2.7CO
NC-0.22
ND-160
88-610
320-2.900
50-1,200
20-640
35-3CO
NiQ
NO
i^u- — * . Z
NC
NC
N^
» •
\™ i
_
Remedial
Goal
ug/l
l.OOn
50
1,300
15
50
1
100
615
5.0CO
i
A
C
Selection Eas.s
Lack of R:sk
NCGS
MCLG
Lack of Risk
MCLG
E=A Guiceii-e
sees
SCGS
MCLG
Lack cf P sx
Lack of R.£<
Lack Of =:5K
VCG?
c
• R
'.er sarrpies 16GV, . 19GW, 2iGW, MVt". , ar.d MW2.
ND denotes net detected.
POOR QUALITY
ORIGINAL
-------
SO-./Cc«••':
Contaminant
PCS (total)
Dioxins/Furans
Maxi.T.um
Concentration
Detected
mg/kg
2,100
4.2E-04
Range of
Background
Concentration
mg/kg
ND"
ND
Remedial
Goal Selection Basis
mg/kg
1 (10)*** EPA Guidelines
1.2E-04 Carcinogenic Risk
Soil samples 19SLA. 19SLB. 20SLA and 20SLB
ND denotes not detected.
() Indicates alternative goal.
-------
5 9 OOS7
Aite''a:.ve S/S-6A. Ocsite Solvent E*trac::cr.
Item
Mobiiization/QemoOiiiraticn
i Qua^'ty
1 i
I
Material Handling
Excavation - Onsite
- Olisite
Contirnnation Sampling
Samp'.ing
PCB's
TAL i TCL
Dioxin/Fgrans
Protective Clothing (Level 0) ,
Hauling !o Site - Ors-.'.e
- Olfsiie
i
i 5.76C
9. £65
1
I so
! 50
i 50
i 10
i 20C
£730
! 9.565
!
• Sc'vent Exracticn
Mcc'|.''Ze::cf;Oe.'-:c-!i2a;;on
Feec Sc:' Sar-D r.g
PCB's
;
•
50
: e:
Units
IS
Unit
Cost($)
1 .000.00
i
CY
CY
Events
Analyses
Analyses
Analyses
Sets
CY
CY
US
Events
Analyses
1.37
V37
25.00
120.00
1.050.00
Capital Anruai i
Cost(S) CcsKVYo ;
i.OOC_,
i
7.900 :
13.100
1.300
6.000
52.500
850.00 i 8.500 j_
30.00
6,000 :
1.30 I 7.500 i i
3.10 29.700 '
500.000.00
10.00
120.00
1
500.00C i
600 '
7.200 '•
Treateo Sci: Sa~:""
PCB's
TC'u?
C.Cx r.'C.-s-s
A.- Sa-r..-; i --* ;s s
P-:c: =:a-:
• Lea: -; £:. :.-5".
S: vsr: Ex.'ar. :r
Was-e v.aie- a T-s-s::.-.
Was:e Ma:e- i: -: -e's: ;•
?*:.•- S:: - C-= -5
-C"s:e
G.-ac -3 C:Ti:- :-
H>c-cse9c:-;
lMa!n;er:a-:Ce M:-*.'g
Security
60 .
60
if
j.
* "
2' z~-~.
:• r.:
• "
~ '.'.'.
-. ":C
r :^r
•; 3A£
•16 '•"
• ^
52
Events |
Ana'yses \
Ar=-ysas i
A.-a-yses \
Ar.a yses :
LS
~CrS
~"S
C'-;""S
^ ;
CY
CY
CY '
SY
t
EvenivVr !
V;S:!S,'Yr |
10.00 \
12C.OC !
300.00 !
asocc .
i SCC. 00
-.sc.ooc :c
6.7C
220.CC
20C 00 ,
C sC
i 3C
3 'C '
2.50
C.AC '
!
300.0C :
|
100.X \
600 •
7.200 ;
9.00C .
25.5'DC-
S7.0CO •
•st.coc •
•A4 '00
•* 34=. •::•:
2.COC
A. SCO
T S "^J"
25. "C
36.AC-C
• e ij;.
,
3 :-:c
:.^.-.
; I
iSoDtotal : ~
BiO Cootingencies (i 5%) i
Scooe Contingencies (1 5%) !
Construction Total i
Permitting anc Legai (3%) i
Construction Services (5%) '
Total Implementation I
\
Engineering Design (8°*) i 1
Total Capital i
Total Annual i
Present Worth (30 years of maintenance;':
,,:••• .
6.080. 500 :
8 SCC
912.100 ';
912/00 ;
7.904.700 .
237.100 !
395.200 '.
L_ 8,537.000 :
683.000 ;
9.220.000 .
i 8.2C-
9.346.CC
Ail costs rounceo to the nearest $100.
POOR QUALITY
ORIGINAL
-------
5 9
0088
Item
Mooilization/Demooiiization
Fencing
6-Fi. Fencing
Corner Posts
Corner Braces
Warning Signs
Demolition
Mcbilization/Demooiim'.ion
Main Building
Maintenance Building
Burn Building
Solvent Washing
Washing Equipment
Wasn Solvent
Confirmation Samslirg
PCBs
Quantity
1
VOO
2
4
10
1
880
73
18
1
170-
15
15
Protective Ctotfiir.g (leve1 0) I 3C
Vacjj-". True*
2*
;
Units
US
Ft.
Posts
Braces
Signs
IS
CY
CY
CY
Eacn
Gallon
Samples
Analyses
Sets
Hours
Unit
CostW
1.000.00
15.2S
as. oo
30.00
5.00
1.000.00
5.70
5.70
5.70
4,500.00
54.00
20.00
175.00
30.00
I 99.00
Capital
Cost(S)
i.OOO
16.800
200
100
100
1.000
5.000
400
100
4,500
9,200
300
2.60C
900
2.400
Annual
Cost(VYf)
Tfar.s=ort tc Lanof,". 3"' ! CY
T^-;::" •.: TSCA :--:.-.='s::: - ' : Trucx'.cac
Cs;csa :r. La-c' . ; 9:3 : CY
l"c:.-.e-a:.c-. i.iX , Ga'i—s
: i
'er-.c -; Ma -'.s-c-te '; Ever-.'Yr.
5.35 S.200 '
3.30C.OO i 3.30C i
2.X 1.90C ,
5.8C ; 8.70C' i
i
i.ooc.oo: ;
l.OOC
i 1 i i i
;Ms".e-a-:eMcw.-; i 1C ! Ever-W'. 30C.OC •. ' i
3.00C
Site Sec. ".y ' 52: Visrts.'Vr. ]
! 1
1_
Subtotal
Bid Contingencies (15%)
Scope Contingencies (15%)
Construction Tottl
Permitting and Legal (3%)
Construction Services (5%)
Total implementation
Engineering Design (8%)
Total Cao-'-ai
Total Annual
Present Wortr* (30 years of maintenance)!
-,00.00 : ; 5.20C
1
!
-
63700
9.600
9.600
82.900
2.500
4.100
89.500
7,200
96.700
9.20C
9.20
238.10
All costs rounoeti to the nearest Si 00.
POOR QUALITY
ORIGINAL
-------
5 9
0089
Cess Esi-rr.aie
Alternative D-3: 0"site Disposal ot Oeons/Soiic Wastes
Item
Mooilization/Demooillzaticr,
Material Handling
Laoor
Equipment
Landfill Disposal
Trarsport ;o Landfill
Transport 10 RCRA lanolin
Transport to TSCA landfill
Landfill
RCRA Landfill
TSCA landfill
QuamMy
1
15
15
80
1
1
80
10
10
•
Units
IS
Days
Days
Tons
Truckload
TrucKload
Tons
Tons
Tons
linn
Cost(S)
1.000.00
1.900.00
500.00
5.25
500.00
1.850.00
2.00
210.00
245.00
Capital
Cor.(S)
1.000
28.500
7.500
400
500
1.900
200
2.100
2.500
Annual
Cost(VYr)
| 1
i ! 1 ! i
i !
i • \
1 1
) i 1
l i :
t
i
;
Subtotal
Bio Contingencies (15%)
Scop* Contingencies 05%)
Construction Total
Permitting and Legal (3%)
Construction Sen/ices (5%)
Total Implementation
Engineering Design (8%)
Total Capital
Total Annual
Present Wonh
t
•'>*£'
i
i
t
^
>!"'.*<.- ... ••
'?&..;£'..:..• •-
••• ". '?'•', "
••'••• . *
j
44,600
6,700
6.700
58.000
1.700
2.900
62.600
5.000
67.600
67.5CC
All costs roundee to the nearer* $100.
POOR QUAdJTY
-------
5 9
0090
Tac-a - • -
Cost Estimate
Alternative G-48. Metal flemoval/Ac'sorption
Item
Quantity
MoDiiizanon < i
Grounowater Extraction Sys:e~ I
Extraction EQuipment i 1
Power
Maintenance
LaDcr (2 nr/mo)
Metais Removal System
Pilot Tes-
Package Jin
Enclosure (20 M x 25 tt)
Air BlOwe"
Utility Cor-ect'ons
Cnemicais 4 Power
Maintenance
1.1*0
1
24
1
1
500
i
1
5.256
1
Laser (8 n."wk) - 476
S>uCse Tra^s^or; :o La-.c!< - £
Units
LS
IS
KWHAY
LSA'r
Hr/yr
Test
Unit
SF
Slower
LS
lOOOGai/Yr
LS/Yr
Mf/Yr
Orums/Yr
S'LCQe D^ccsas m Lane!- : 1 ' Ton/Yr
Ac::va:ea Ca-ocr System i
AC: vaiec Ca'ccn Urn : i • Unit
Unit
Cost ($)
i.OOO
140.000
0.07
100
30
5.000
140.000
10
1.500
7.300
0.3S
7.000
30
75
300
Capital : ISt Year Annua
Cost ($) ' Ccs: 'S.V)
i.OOC
i
140.00C
IOC
iOC
1 70C
5.0CO
\ 140.000 ,
5.000 1
1.500 !
7,3oc ;
1 • .80C
i 7.00C
i 12.5C-:
; 40-:
! 30C
4.000 j 4.00C
Ca'cor. Pec'a:e-re-: : OCC LB/Yr ! i.2C
4.3-::
Ma^eiarce i • LS/Yr I
Lac:: (2 -.'"-:! 2* Hr/Yr |
300 I
3C :
i 30C
7C-:
D.sc-a-;e S.s:e~ • i 1
C.sc-a-ce '„ -e :: CC~V. _ -j £: F: |
Se~e- C-a-;e 5.2££ -OCC Ga'/Yr :
3.50 •
1.7C
2f *•
»%
; r . I
Me- ::' -; i
|r':_e-: Sa~:!es ;• :e- ~: '2 Sa~,;:es/Yr ;
E1! .=-• Sa-: =s •' ;«• *« 52 Sar.Qies/Y.- ;
?CSs &i A-a'yses/Yr ;
Me:a s 64 . Aca-yses/Yr ;
P.-;=ar e C-;a- :s 6^ ; Ana'yses.'Yr i
i
25 •
25
65
145 :
125 '
i
2 1*1
"• . 2 Z t
^ ^::
9 2M
= CI'"
: i ! i
! t j
i
. . 1
: 1 • i
; ;
i !
1
SoCtcta;
BiC Contmgencie* (15%)
Scooe Contingencies (15%)
Construction Total
Permitting and Legal (3%) t
Construction Services (5%)
Total Implementation
Engineering Design (8°A)
Tota: Capital
Total 1st Year Annual
Present wortr. (10 years ol oc«ra:ion)
.
i
303. ooc 6C.?:-:
45.50C
45.50C
394 OOC
T.80C
19.70C
425 50C
34 OOC
459 50C
5C.7v:
633. 8C<
Ail costs rounoec to the neares: S'OC
POOR QUALITY
ORIGINAL
-------
<— The U.S. EPA and N.C. Department of Environment, Health and
ON Natural Resources have determined that this remedy is protective
O of human health and the environment, attains ARARs, is cost
O effective, utilizes permanent solutions, alternative treatment
technologies or resource recovery technologies to the maximum.
extent practicable which satisfies the statutory recruiremer.ts of
Section 121 of CERCIA
10.1 Protection of Human Health and the Environment
Based on the risk assessment developed for this site, dermal
contact with and ingestion of the contaminated soil and
sediment, ingestion and inhalation of the contaminated
groundwater, are the identified risks associated with the site.
The selected remedy of solvent extraction in conjunction with
the groundwater extraction and treatment system is protective of
human health and the environment. The alternatives selected
provide a permanent remedy that removes the contaminants from
the associated media and disposes of the reduced contaminated
waste stream off site.
10.2 Compliance with Applicable or Relevant and Appropriate
R.6.C.U i r em e n t s •' ARAR s >
The rer.edy selected will comply with all applicable or relevant
ar.d appropriate chemical-, action-, and location-specific
recuirer.er.ts (ARARs) of Federal ar.d mere stringent State
er.virorrr.ental laws. This Site does not contain California list
Waste ar.d ar.d the residual materials remaining on site will r.ct
ccr.tair. RCRA characteristic waste. The concentrated waste
designated for off site treatment will be drummed and
transported off site per RCRA and DOT regulation.
Chemical Specific ARARs
Chemical specific ARARs includes those laws and
regulations governing the release of materials
possessing certain chemical or physical
characteristics, or containing specified chemical
compounds. These requirements generally set health or
risk-based concentration limits or discharge
limitations in various environmental media for specific
hazardous substances, contaminants and pollutants. The
chemical specific ARARs which set the concentration
limits for the cleanup criteria at this site are listed
below by media.
The ground water cleanup standards for this Site are
set at the most stringent of the following ARARs since
the aquifer is a potential drinking water source: Safe
Drinking Water Act (SDWA); Clean Water Act (CWA); and
North Carolina Water Quality Standards.
-------
5 9 0092
The soil and debris cleanup standards are based on
Guidance on Remedial Actions for Superfund Sites with
PCS Contamination, OSWER Directive No. 9355.4-01.,
Toxic Substance Control Act (TSCA). Table 10-1 gives a
detailed break-down of the governing Chemical-Specific
ARARs.
10.2.2 Location-Specific ARARs
Location-specific ARARs are design requirements or
activity and/or contaminant concentration restrictions
based on the geographical or physical position of the
site and its surrounding area. ( Table 10-2 outlines
the location specific ARARs applicable to the Site.)
10.2.3 Action Specific ARARs
Action Specific ARARs are those ARARs that place
activity-abased requirements on a particular technology
or places condition on dealing with specific
substances. (Table A-l in Appendix A outlines the
Action-Specific ARARS applicable to this Site)
10.3 Cost Effectiveness
The present estimated cost of EPA's selected remedy is
$10,474,200.00. The selected remedy provides a permanent
solution and affords overall effectiveness proportional to its
costs such that the remedy represents a reasonable value for the
money. When the cost and overall effectiveness of the selected
remedy is compared to the other alternatives, the selected
remedy is the most cost effective.
10.4 Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery Technologies
to the Maximum Extent Practicable
The remedy selected meets the statutory requirement of
utiliizing permanent solutions and treatment technologies to the
maximum extent practical. The selected remedy provides the best
balance in terms of long and short term effectiveness,
permanence, implementability, cost, reduction in toxicity,
mobility and volume.
10-2
-------
Tabloid-1
I1..i. nt i.il Olwmical-Specitic ARARs
Ml
Standard. Requirement
Criteria or Limitation
Federal
Sale Drinking Water Act
National Primary
Drinking Water
Standards
Citatjox
40 USC f>ocl. 300
40 CPU Pan MI
National Secondary
Drinking Water
Standards
Maximum Contaminant
Level Goals
40CFRPart 143
Putt. L. No 91-
339, 100 Still
642(19B6)
Description
Applicable/
Relevant and
Appropriate
F :;t;iblir.hes hnalth-basod No/Yes
st.uxl.inls tor public
water systems (maximum
contaminant levels).
F.slablishes wellare-based No/No
standards (or public water
systems (secondary maximum
contaminant levels).
Establishes drinking water No/Yes
qu.ility goals set at levels
of no known or anticipated
e health effect.
Comment
The MCLs lor organic and
inorganic comarninants are
relevant and appropriate tor
groundwater at the site since
it is a potential drinking water
source.
The secondary MCLs lor
inorganic contaminants
in groundwater are *lo
be considered" guidelines.
Proposed MCLGs lor organic
and inorganic contaminants
are relevant and appropriate
lor goundwater potentially
used lor drinking water.
-------
Table | o-l (continued)
Potential Chemical-Specific ARARs
Standard. Requirement
Criteria or Limitation
Federal (continued)
Clean Water Act
Water Quality Criteria
Resource Conservation
and Recovery Act (RCRA).
as amended
RCPA Groundwater
Protection
RCRA SWMU
Requirements
Citation
33 USC Sect.
1251-1370
40CFRPafl 131
42 USC 6905.
6912.6924.6925
40 CFR Par?
40 CFR Part
254 3-4
Description
Applicable/
Relevant and
Appropriate
r.els aiienal lor water
quality hasod on toxicity
to aquatic organisms and '•
human health.
Provides lor groundwater
protection standards.
general monitoring
requirements and technical
requirements.
Provides lor protection
nrnurulwater at solid waste
management unit.
No/Yes
No/Yes
Yes/No
Comment
The AWQC for organic and
inorganic contaminants are
relevant and appropriate.
The RCRA MCLs are relevant
and appropriate lor
groundwater at the site.
May be applicable if
remedial action includes
provisions for an on-site
landfill
-------
cn
Standard. Requirement
Criteria or Limitation
Federal (continued)
Clean Air Act
National Primary and
Secondary Ambient
Air Quality Standards
National Emissions
Standards for Hazardous
Air Pollutants
(NESHAPs)
Toxic Substances Control
Act (TSCA)
Occupational Safety and
Health Administration
Citation
40 DSC Id!./
40 Cm Part '..0
lOCFRPart Ol
15 USC 2601
?9CFR 1910
Part 1?0
Table I o-l(continued)
Potential Chomical-Speciric ARARs
Applicable/
Relevant and
Appropriate
r.i'ts primary and secondary
.111 siandards at levels to
protect public health and-
public wHIare.
Provides emissions standard
for ha/ardous air pollutants
for which no ambient air
quality standard exists.
Rcrjulates disposal ol
waste materials
containing PCB
contamination.
Provides safety rules for
handling specific
chemicals for site
workers during remedial
activities.
No/Yes
No/Yes
TBC
Comment
CD
O
vo
cn
May be relevant or appropnat.
if on-site treatment units
are part ol remedial actions
Maybe relevant or appropriate
if on-site treatment units
are part of remedial actions.
The substantive requirements
for treatment and disposal
of PCB contaminated
are to-be-considered.
Yes/No Health and salcty requirement
are applicable to all potential
remedial actions.
-------
0<
Standard. Requirement
Criteria or Limitation
Federal (continued)
Departmen t ol Trans-
ation (DOT) Hazardous
Materials Transportation
Act
Citation
s ur>c moi
Tahlri o-1 (continued)
Potential Chemical-Specific ARARs
Description
Regulates ofl-site
Ir.ur.portalion of
r.p(!Cihc ha/ardous
chemicals and wastes.
Applicable/
Relevant and
Appropriate
Yes/No
Comment
c>
O
v/
O
Regulations lor transport ol
contaminated media off-site
applicable to potential
activities at the site.
Stale
North Carolina Water
Quality Control
Standards
North Carolina Drinking
Water Act
15ANCAC2I)
130ANCAC
3H-327
Establishes water quality Yes/No
requirements applicable
to all surface waters of
North Carolina which
protect public health and
ihe environment.
Regulates water systems No/Yes
within the State which
supply drinking water
ihat may affect the public
health.
Guidelines tor allowable
levels of toxic organic
and inorganic compounds
in surface water after
a discharge is mixed with
a receiving stream.
Provides the Slate with Ihe
authority needed to assume
primary enforcement
responsibility under the
federal act.
-------
Tabl«. 10-2
Potential location-Specific ARARs
Vl
Standard, Requirement.
Criteria, or Limitation
Federal
Resource Conservation
and Recovery Act (as
amended)
Location
Standards
Fish and Wildlife
Coordination Act
Floodplaln Management
Executive Order
Citation
42 USC 6001
40CFR264 .10(0)
16USC661-G66
Executive Order
11988;40CFR6302
prescription
A TSD facility must be
designed, constructed.
operated, and maintained
to avoid washout.
Actions that are to occur
in lloodplain should avoid
adverse effects, minimize
potential harm, restore and
preserve natural and
beneficial value.
Applicable/
Relevant and
Appropriate
c
C
Vl
No/Yes
Yes/No
Comment
Potential remedial alternatives
within the 100-year tloodplain.
Requirement is relevant and
appropriate.
Remedial actions are to prevent
Incursion ol contaminated ground-
water onto forested floodplain.
-------
Table | o- ^continued)
Potential location-Specific ARARs
Standard. Requirement.
Criteria, or Limitation
Federal (continued)
Wetlands Protection
Citation
Executive Order
11990;40CrR6.
Appendix A.
Endangered Species Act 16 DSC t 531
Clean Water Act
Dredge or Fill
Requirements
(Section 404)
Rivers and Harbors
Actol 1889
Section 10 permit
33 USC Sect. 12
40 CFR 230
33 USC Sect 40:1
Applicable/
Relevant and
''Appropriate
Requites that FPA conduct
activities to avoid, to the
extent possible, the long
and short-term adverse
impacts associated with tho
destruction or modification
o1 wetlands.
Requires action to conserve
endangered species or
threatened species, including
consultation with the
Department ol Interior.
Requires permit lor discharge
ol dredged or till material
into aquatic environment.
Requires permit lor structures
01 work in or atlecting
navigable waters.
Ye s/No
No/No
No/No
No/No
Comment
Remedial actions to impact site ,
directly by stopping incursion
of contaminated groundwater
into wetlands area associated
with Cape Fear River.
No threatened or endangered
species or critical habitats
were identified in or near
the site.
No alternative will be developed
which will discharge dredge
or (ill material into an
aquatic environment.
No alternative involves work that
would aftect a navigable water wa
-------
Standard. Requirement.
Criteria, or Limitation
Federal (continued)
Wilderness Act
National Wildlife
Roluge System
Wild and Scenic
Rivers Act
Citation
16 USC 1311
50CFR3S I
16 usc
50CFR27
16 USC 1271
40CFR
Tahlrio -2(contmued)
Potnnlial Location-Specific ARARs
Oesoription
Area must be administered
in r.ur.h ;i way as will leave
it unimpaired as wilderness
and will preserve it
;r. a
nnstucts activities within
National Wildlife
Prohibits actions that will
have direct adverse effects
on a scenic river.
Applicable/
Relevant and
Appropriate
Comment
cn
vo
O
o
No/No No wilderness areas exist onsite
or adjacent to (he site.
No/No No wildlife refuge areas exist
onsite or adjacent to the silo.
No/No
No scenic river in area.
Coastal Zone Management
Act
16 USC Sect 1151
et.seq.
Conduct activities in manner
consistent with approved
State Management Program.
No/No Area is not in the
coastal zone.
-------
010
APPENDIX A
ACTION-SPECIFIC ARARs
-------
en
vo
tJ
o
33:0
OQ
Table A-1
Action Specific-ARARs
Groundwaicr
o
Standard, Requirement.
Criteria, or Limitation
Federal
R*aouic« Con**»viUon and Racov*iy Act
•dandtcMlon of Ha/aidoui Waat**
Tiewtmant ol Hajardou* Wa*t** In a Unit
Raquiiamanli lo« GeoeiaOon. Slotg*
TfoaBnanl. and f»*po»aj o) Hundoui Wait*
Sal* Drinking W*lw Act
Subpart B - Maximum Contaminant level!
Subpa/t F - Racommandad Maximum .
Coniamlnant L*v*l*
Subpart O - National R*vl**d Primary
Drinking Wat*r Ragulabon*: Maximum
Contaminant Laval*
National Secondary Drinking Wai*i
ReguUtfon.
Citation
40 u'.'f. r.eci iocs «i MM)
40 cm ?n«
40 Gin 7A4 1
4OC(n 24K400
40CFH ?«3
40CFII ?«M
42 USC Sect 3001 *t *W)
40CFR 141 11
40CFR 141 I?
40CFH 141 SO
40CFR 141 «1
4OCFR 141 00
40CFR 14.1 3
Description
ClHfcufir.aiiiM) and identification olhaiaidou*w**tv*.
(Inlet unit ixgiilalinn* lot th* li**tm*nt o(h*/*idou*
wallet
Itulm tnd legulitioni loi *to<*g*. liantpo«tatlon. and
i^ieiiiiix ol ha/aidoui wad* g*n*iator*.
Pnmary MCI t lot organic and inotganlc contaminant*.
Additional MCLi and MCLGi toi oiganic contaminant*.
Revitwl MCI • and MCLGi toi organk and Inmganic
rontammanli
r>«cni<1iif MCLt hx mwgan>c*
Alternatives
G-l
.--
—
—
—
—
—
—
G-J
—
—
—
—
—
—
—
G-3
A
A
A
RA
RA
RA
RA
G-4
A
A
A
RA
RA
RA
RA
G-S
A
A
A
RA
RA
RA
RA
0-«
A
A
A
RA
RA
RA
RA
HI
-------
en
vo
TJ
08
gaza
oo
c:
T;ible A-1 (continued)
Action Specilic-ARARs
Gfoundwaler
O
O
Standard. Requirement.
Criteria, or Limitation
Federal
Raaouica Cona*tv*aon and Raeovafy Act
td*ntllcailon ol Huaidou* Wact**
Ttaalmanl ol Ha/aidou* Wa*la* In a Unit
Raquliamanlc lot Ganarataon. Slotaga.
Ti**tm*nt. and Olapoaal ol Haiaidou* W*«ta
Sato Drinking Waiai Act
Subpart B - Maximum Contaminant Laval*
Subpan f - Racommandad Maximum
Contaminant Laval*
Subpan a - National Ravlaad Primary
Drinking Watw Regulation* Maximum
Conlamtnanl Lavala
N*ttonaJ Secondary Dnnfcing Wctai
Regulator!*
Citation
40 USC Kw.l IAO0 •! •«>
40CFR ?6t
40CIM 7A4 1
40C.IM ?IU> 40O
40CFM 703
40CFK ?IM
42USCS*cl 300t*l*eq
40CFR 141 It
40CFR 141 12
40CFR 141 6O
40CFR 141 01
40CFR 141 00
4OCFR 141 1
Description
(;U«unciiti«n and id»nukcatinn ol h*/*ldotl*«ia*l**
Rul** *nd i •gulatlun* lo« (h* ti**imant ol haxaidou*
w.-..
Kiil*« and <*oul*tion* lot cloiaga. liai^cpoilation, and
opaiaUon nlhaiaidoucwaataganaialofa.
Primary MCI* lot mganlc and motganlc contaminant*.
Additional MCL* and MCLG* lot otganic cunlamlnanl*.
R*vl**<1 MCL* and MCLG* lot otganle and inorganic
contaminant*
r.acnndary MCL* tot inotganlc*
Alternatives
G-1
—
—
—
—
—
—
—
0-2
—
—
_
—
—
—
—
G-3
RA
RA
RA
RA
Q-4
—
RA
RA
RA
RA
O-S
RA
RA
RA
RA
G-e
RA
RA
«A
RA
G-7
RA
R/.
'"
R
-------
-o
08
oo
Table A-1 (continued)
Action Specilic-ARARs
Groundwatcr
CD
—^
CD
Standard. Requirement.
Criteria, or Limitation
Federal (continued)
National Primary tod Secondary Drinking
Watar Regulation*: Synthetic Organic
Chemical* wid Inotganlc Chemical*
Clean Walei Act
NaUonal Poltulanl Dleehaig* Ellmlnaoon
Syctem Permit Regulation*
Twlc SubeUncetContiat Act
Subpejt Q - PCB SpIN ClMmup Policy
OWtMrAct
National EmlMlon 8t«HJanl* tor Huaidou*
Mi Pdluiwtl*
Citation
&S PR 30.170
(July 25. 1000)
33 USC S«cl l?*>l-tl7A
40CFR U2Sp«t1C
IS USC 2001
40CFR76I tJ6
42 USC t«&7alMq
40CFH4I Sohptn A
4OCH1OI S,,l>|)«r1 I f
Doscription
flevlKKl MCI > and MCI.G* Im raganlc and Inmganic
conlamlnatilc
lit* ul l>««l availatila lachnotngy •conomlctlly
ach«(v«hla ICH loxic polluKinu dlichaqiad to a POTW
OlKhaig* muM coo>|ily with EPA appiovwl watai
<|iialily managantanl plan
Olachaiga mud comply with (adatal watai quality
crttoha
Raquliamanli la PCB aplll cleanup.
Ganai d laquliamanla Im •mitnoni of haianloua
poliuianl*
Cmnaton aiandaid* la banian*
Alternatives
G-t
—
—
—
—
—
—
—
G-J
—
—
—
—
—
—
_
G-3
RA
HA'
RA"
RA"
RA
A
A
O-4
RA
RA-
RA"
RA--
RA
--
Q-5
RA
—
RA
RA
RA
—
--
Q-«
HA
RA-
RA"
RA"
RA
—
—
o-r
RA
-
PA
RA
H>
-
-------
Table A-1 (continued)
Action Specilic-ARARs
Groundwater
o
*—
>
c
.. I
Standard. Requirement.
Criteria, or Limitation
North Carolina
North C«oUn« W«tec QuUlly StMxUid*
North CwoUn* Drinking WttM «nd Giound-
W«« SUndMd.
North Cuottn* Drinking WM« Act
WMwfepplM*
North Cwottn* All Potation Conliol L«w
North CwoMn* All PaNuMon Conliol
R«guU*on*
Citation
NGAC-1f>A-?H0704
NCAC-I5A-2B0708
NT.AC-lbA-IB 0711
NCAC-I6A-7HOMO
NCAC-I&-2C 0108
NCAC-I5-2COM3
NCAC-I5-2L0202
GSNC-t 13A-31 1 *4 *«|
NCAC-tO-tOO 1600
GSNC-143 7IB.IMO.
N*,AC li 71) 02OI
NCAC-15 2O 0400
N<:AC -is»2O of>oo
Description
I in •nmi of Mmpllng *« tot •bindonmwil olwdl*
GioundwtlM quility dtndud*
North Caiolln* drinking WMM «l»ndwd«
CU«*Kc*uon ol *li potluKon MUICC*
Ambicnl «i qutfly M«ndwdi
t miifiun contiol M«nd«id«
Alternatives
G-t
—
—
--
—
—
—
—
—
—
-
G-2
—
—
—
—
—
—
—
RA
—
--
G-3
RA-
RA-
RA'
HA'
RA
RA
RA
RA
RA
RA
RA
0-4
RA-
RA-
HA-
HA'
RA
RA
RA
HA
—
—
G-5
RA
RA
RA
RA
RA
RA
RA
RA
—
—
—
Q-»
RA-
RA-
HA-
HA-
RA
RA
RA
R*
_-
—
(
I
,
------- |