United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-93/155
September 1993
NexEPA Superfund
Record of Decision:
FCX (Washington Plant), NC
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4.
50272.101
REPORT DOCUMENT A TJON
PAGE
TItle and Subtltkl
SUPERFUND RECORD OF DECISION
FCX (Washington Plant), NC
First Remedial Action - Final
Author(.)
11. REPORT NO.
EPA/ROD/R04-93/155
2
3. R8c1pi8nt'. Acuulan No.
&
Report D8I8
09/15/93 .
&
7.
8.
P8rtannlng 0rpnIat1on Rapt. No.
9.
P8rformlng Organization Name and Acid...
10
PnIiect T88k/Wark Unit No.
11. ContI8Ct(C) or Gnnt(G) No.
(C)
(G)
12. ~ng Organization Name and AcId...
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report .. PwIocI Cov8Nd
Agency
800/800
14.
15. Su~Nat-
PB94-965044
16. Ab8t1'llCl (Umll: 200 words)
The 12-acre FCX (Washington Plant) site is an inactive farm supply distribution center
located in washington, Beaufort County, North Carolina. Land use in the area is mixed
light industrial, commercial, residential, and agricultural. The site overlies seven
aquifers, including a surficial/water table aquifer and six deeper semi-confined to
confined aquifers. The local population obtains its potable water supply from either
public water supply wells or private wells. From 1945 to 1985, the Farmers Cooperative
Exchange (FCX) site was used as a farm supply distribution center that repackaged and
sold pesticides, herbicides, and tObacco-treating chemicals. The site contains five
source areas of contamination related to improper pesticide handling and disposal
practices. From 1960 to 1981, FCX buried an unknown amount of chemical waste contained
in plastic containers and paper bags in an onsite landfill, located in source area 5
(southwest of the former FCX warehouse). Since mid-1986, several site investigations,
conducted by Federal, State, and local agencies, revealed the presence of elevated
concentrations of VOCs, other organics (primarily pesticides), and metals. As part of
a removal action between 1989 and 1990, EPA excavated, consolidated, and stockpiled
onsite 3,000 yd3 of contaminated soil from source area 5, and 49 yd3 from source
(See Attached Page)
17. Document AnalysIs L DeacrfptOl'8 .
Record of Decision - FCX (Washington Plant), NC
First Remedial Action - Final
Contaminated Medium: gwJ
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (PAHs, pesticides),
metals (lead)
b.
Idenllfi8ra1Open
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EPA/ROD/R04-93/155
FCX (Washington Plant), NC
First Remedial Action - Final
Abstract (Continued)
area 2. In 1990, in response to a report that the cover of the stockpiled soil was torn,
EPA constructed a temporary containment berm around the stockpiled soil and repaired the
torn liner. Later in 1990, analyses of ground water samples revealed elevated levels of
pesticides, volatile organics, semi-volatile organics, and metals primarily in source
areas 4 and 5. Between 1990 and 1992, EPA conducted a time-critical removal of the
contaminated soil, as OU2. The removal action included excavating and consolidating
onsite 2,200 yd3 of pesticide-contaminated soil and debris and 13,600 yd3 of contaminated
soil; and bagging 3,110 yd3 of the existing stockpile and placing it in an onsite
warehouse for storage. This removal action is expected to address all soil/source
contamination to the point that no further remediation is required. This ROD addresses
the ground water contamination, as OU1, and provides a final remedy for the site. The
primary contaminants of concern affecting the ground water are VOCs, including benzene,
toluene, and xylenes; other organics, including PARs and pesticides; and metals, including
lead.
The selected remedial action for this site includes extracting and treating contaminated
ground water onsite using air stripping to remove VOCs, precipitation and ion exchange to
remove metals, and carbon adsorption to remove organics, followed by discharge of the
treated effluent to surface wateri disposing of the residual sludge generated from the
metals precipitation process and any spent carbon offsite at a RCRA landfill; conducting
long-term ground water monitoring; and implementing institutional controls. Providing
contingency measures including, at a minimum, a combination of containment technologies
and institutional controls, will be implemented if the selected remedy cannot meet the
specified performance standards. The estimated present worth cost for this remedial
action is $12,482,892, which includes an estimated present worth O&M cost of $9,115,079
for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Ground water will be restored to beneficial use based on the more stringent of Federal
MCLs, State standards, and risk-based levels. However, the average background
concentration was selected as the remediation level, if it exceeded the most conservative
level. Chemical-specific goals for ground water include aldrin 0.01 ug/l; alpha-SHC 0.014
ug/l; benzene lug/I; beryllium 1 ug/l; beta-BHC 0.047 ug/l; bis (2-ethylhexyl) phthalate
4 ug/l; carbazole 4.3 ug/l; chlordane 0.027 ug/li chlorobenzene 100 ug/l; chloroform 0.19
ug/li chromium 50 ug/l; 1,2-DCA 0.38 ug/l; 4,4-DDD 0.02 ug/l; 4,4-DDE 0.02 ug/l; 4,4-DDT
0.02 ug/li 1,2-dichloropropane 0.56 ug/li dieldrin 0.02 ug/l; endrin 0.20 ug/l; gamma-BHC
0.0265 ug/l; heptachlor 0.076 ug/l; heptachlor epoxide 0.038 ug/l; lead 15 ug/l; manganese
697 ug/l.;mercury 1.1 ug/l; nickel 100 ug/l; pentachlorophenol 1 ug/l; toluene 1,000 ug/l;
toxaphene 1 ug/li and total xylenes 400 ug/l.
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RECORD OF DECISION
FOR
FCX, INC. SUPERFUND SITE
WASHINGTON, BEAUFORT COUNTY,
NORTH CAROLINA
~ED sr-41"~
. ft .
i ~./1 ~
\~.1
'L PRCf{#
September 15, 1993
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"'.RT.R OF COItXISlt~
DECISIOR StOOIARy
I . SI'l'E RAIlE. IaOCATIOR ARD DESCRIP'.rIOB .
A. Introduction. .
B. Site Descrintion .
C. Demoaranhy and Land Use
D. Geoloav
E. Hydroaeoloav .
F. Climate/Meteoroloav
II.
.
SI'l'E ms'l'ORY ARD BBPORCERMER'l' ~:IVI:~IBS
A. Site Historv .
B. Summary of Previous Investiaations .
C. Enforcement Activities'
IV.
III. BIGRLIGR'.rS OF COIIIIOHITY PARTICIPATIOR .
V.
VI.
VII.
SCOPB AIm
STRADGY
ROLE
OF
RBSPOBSE
AC'l'IOB
WImDI
STJIIIO.~ OF SI'l'E l!ImR.~RIftICS .
A. Soil Investiaation .
B. Groundwater Investiaation
C. Surface Water Investiaation
.
.
StJIIIIARY 01' SID RISKS .
A. Contaminants of Concern
B. EX'DOsure Assessment
C. Toxicitv Assessment. .
D. Risk Characterization.
E. Environmental Assessment.
P. Conclusions
.
.
.
.
.
.
.
.
.
.
.
.
SID
.
APPLICABLE OR RELEVAlft' .AIm APPROPlUAft RBOUIPRIfRNTS
(.ARDs) . . . . . .
A. Action-SDecific ARARs ..
B. Location-SDecific ARARs
C. Chemical-SDecific ARARs
.
-. ..
~".
-
1-1
1-1
1-1
1-1
1-6
1-7
1-8
1-9
. 2-1
. 2-1
. 2-1
. 2-3
. 3-1
. 4-1
. 5-1
. 5-1
. 5-3
. 5-9
. 6-1
. 6-1
. 6-1
. 6-3
. 6-6
. 6-7
6-11
. 7-1
. 7-1
. 7-1
. 7-2
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'l'&RLR OF CONTENT (continued)
VIII. REMEDIAL AC'J.'ION OBJECTIVES. . . . . . . . . . .
A. Groundwater. . . . . . . . . . . . . . . . .
B. Extent of Contamination Above Remediation
IX.
X.
XI.
Levels. . . . . . . . . . . . .
. . . . . . .
. 8-1
. 8-1
. 8-1
DBSCRIPTION OF AL~IVES . . . . . . . . . . . . 9-1
A. Remedial Alternatives to Address Groundwater
Contamination. . . . . . . . . . . . . . . . . 9-1
SUJlMARY OF COMPARATIVE ANALYSIS OF AL'l'ERRATIVES .
A. Groundwater Remediation. . . . . . . . . . .
'l'BB SELECTED REllBDY ..............
A. Groundwater Remediation. . . . '. . . . . . .
B. Extraction and Performance Standards. . . . .
APPEImU I
RESPONSIVENESS SUlDlARY
... --.. ........--........- ..---.----.-..-..-.--.---
- .-....- - -....- .--. .
10-1
10-4
11-1
11-1
11-3
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Record of Decision
FOt WUhin!r"-OD Groundwater Contalll1_~1oD Site
June 1993
SectJ.OI: :
DECISION SUDARY
I.
SI'.rE NAME. IaOCATION AND DESCRIPTION
.A. Introduction
The FCX Washington Site (hereinafter referred to as the "FCX Site"
or the "site") is defined as an area located on the western edge of
Washington, North Carolina, in which soil, sediment, surface water,
and groundwater are contaminated by multiple sources.. Previous
investigations have indicated that the former Farmers Cooperative
Exchange (FCX) Inc. facility, comprised of seven tracts of land, is
one of the major sources of concern. This facility acted as a farm
supply distribution center which repackaged and sold pesticides,
herbicides, and tobacco treating chemicals from 1945 to 1985.
Five source areas of contamination related to these pesticide
handling and disposal practices have since been identified in this
area.
B. Site DescriDtion
The FCX Site is located approximately 1.5 miles northwest of and
within the city limits of Washinqton, North Carolina,. in west
central Beaufort County (see Figure 1-1). The site covers
approximately 12 acres and is bounded on the northeast by the
intersection of Grimes Road (SR 1402) and Whispering Pine Road (SR
1404), Mount Pleasant Canal to the east, wetlands leading to
Kennedy Creek and Tar River to the south and -southwest, and
agricultural land to the west-northwest (see Figure 1-2). A site
features map showing the approxLmate locations and limits of the
warehouse, main chemical burial trench, blending buildinq, and
known features is provided in Figure 1-3.
Source area 1 is located between Grimes Road and the farmland,
approximately 230 yards north-northwest of the former FCX
warehouse, and is comprised primarily of several small to medium
office/storage buildings and silos/tanks associated with the W.B.
Gerard & Sons Inc. fertilizer and hardware company located at 425
Grimes Road. This source area is located on relatively flat
terrain which has a gradual slope to the south and southwest. In
addition, a man-made drainaqe ditch, located parallel and south of
Grimes Road borders this source area to the northeast. This man-
made drainage ditch also borders both source areas 2 and 3 to the
1-1
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.
..
NORTH
CAROLINA
8EAUF"ORT COUNTY
/
FCX WASHINGTON
SITE
COli FEDERAL ARCS IV
SITE LOCATION MAP
FCX WASHINGTON SITE
WASHINGTON, NOA1H CAROUNA
FIGURE NO.
1.1
1-2
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Record ot D8c181cm
Fet waatUDgUm 1iIro1m4Va~ CoD'ta81I1&Ucm 81~
Jane 1993
D8c~.Ucm
DECLARATION FOR THE RECORD OF DECISION.
SITE RAIlE ARD I.QCMIIOB
FCX WASHINGTON SITE WASHINGTON,
BEAUFORT COUNTY, NORTH CAROLINA
STA.'rEIIEIft OF BASIS AIm PURPOSE
This decision document presents the selected remedial action for
the FCX Washington Si te in Washington, Beaufort County, North
Carolina, chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA) and, to the extent practicable, the National Contingency
Plan (NCP). This decision is based on the administrative record
file for this Site.
The State of North Carolina concurs with the selected remedy.
- ASSESSIIBlft' OP !mE SITE
. .
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial-
endangerment to public health, welfare, or the environment.
DESCIUPfiOli OF ~ SBLBC'RD REHBDY
This remedy addresses the principle threat
groundwater emanating from beneath the Site.
The major components of the selected remedy include:
of
contaminated
GROmmwATER
Extraction of groundwater at the Site that is
contAminated above Maximum Contaminated Levels or the
Borth Carolina Groundwater Standards, whichever is more
protectiveJ
Onsite treatment of extracted groundwater
stripping J carbon adsorption; precipitation;
exchange~
via air
and ion
Discharge treated groundwater to surface water'-
- -
o. . ~. .. ". .
- -
.-
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Jtscard ot Dec1aion
FCC Waa.IU.DgUm Qro1Dldw.~ CODtaaiDaUon Site
JUDe 1993
DecJ.aratioD
STA'rU'l'ORY DEftRKIRATIOHS
The selected remedy is protective of human health and the
environment, complies with federal and state requirements that are
legally applicable or relevant and. appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technology to the maximum
extent practicable, and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element. Since this remedy may result in
hazardous substances remaining onsite above health based levels, a
review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
~rY1~
Patrick M. Tobin
Acting Regional Administrator
~/~flg
Date
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SCALE .", ;-::S
LEGEND
'ARlllAND
- ... - Si..RFACE WATER ::HANN(L
~ ~ WE11..ANDS
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COM FEDERAL ARCS iv
AREA FEATURES MAP
FCX WASHINGTON SITE
WASHINGTON, NORTH CAAO~
1-3
FIGURE NO.
1-2
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LEGEND
CHARLIE TOM'S
RESTAURANT"
OYSTER BAR
(Fonner Blenoing
Building)
t
-N-
~
200 0 200
SCALE iN FE~
FARMLAND
-x- FENCE
~ ~EEUNE
--- SURf'ACE WATER
---- SOURCE AR::A
BOUNfWN'
SOURCE AR::A
CECIL CAMPBElL
TRUCKING CO.
(r: onner r:CX
worenouse)
,.
AP?~IMATE AREA
Of' M MAIN CHEMICAL.
3URW,: TRENCH
COM FEDERAL ARCS IV
SITE FEATURES MAP
FCX WASHINGTON SITE
WASHINGTON, NOFmt (:AROUNA
FIGURE NO. I
1-3
1:-/,
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Record of Decision
FCX waatUIIg<;on Gro1mc1waUr CoutalUJiatj,ou Sj,U
June 1993
sec':.~O:1 1
northeast. Surface water in this ditch flows in a
southeasterly direction prior to its confluence with the Mt.
Pleasant Canal northwest of the Cleon Lathan residence (source area
3) .
The deed search conducted as part of a PRP search indicates that
source area 1 once belonged to FCX (Techlaw, 1988). Current
operations at this source area by W. B. Gerard & Sons Inc. includes
the distribution of agro-chemicals.
Source area 2 is located between Grimes Road and the farmland
located 115 yards north-northwest of the former FCX warehouse. '!'he
significant site features of source area 2 include a large
warehouse building and a gravel parking lot associated with the
Charlie Tom's Restaurant & Oyster Bar (the former FCX blending
building). A surface water drainage ditch originates in the
southwest corner of source area 2, and water in this ditch flows in
a southeasterly direction parallel to the southwest property line
and the abandoned Seaboard Coastline Railroad Spur. This drainage
ditch discharges into Mt. Pleasant Canal near the Cleon Lathan
residence.
Source area 3 is located between Grimes Road and the farmland
located west of the former FCX warehouse and 50 yards north-
northeast of this warehouse. Mount Pleasant Canal forms the
eastern border of source area 3. The significant site features of
this source area include a large warehouse building located in the
northern portion of the source area, and the Cleon Lathan residence
located" in the southern portion of the source area, adjacent to the
Mt. Pleasant Canal. At the time of the RI field investigation,
residents occupied the large warehouse. Several small
depressions/drainage ditches are also located in the center of
source area 3 which divert surface water runoff northeast towards
the drainage ditch parallel to Gr imes Road. Source area 3 also
contains a former loading dock (concrete ramp), several concrete
grain silo support pads located south of and adjacent to the large
warehouse building, and a secondary access road parallel to the
abandoned Seaboard Coastline Railroad Spur. The access road
connects the southwest corner of source area 2 (Charlie Tom's
parking lot) with the paved entrance road to the Cecil Campbell
Trucking Company (old FCX warehouse). .
Source area" 4 is located between source area 3 and source area 5.
It consists of the Cecil Campbell Trucking Company warehouse (the
old FCX warehouse), a paved entrance and parking lot located south
of the warehouse, existing grain storage silos, a former
1-5
-------
Record ot Decision
FCX WaahiDqt.o:1 Groundwater Con~tion 51 te
June 1993
5ec:'::l.or. ::.
grain storage silo, concrete support pads on the southwest corner
of the warehouse, and secondary access roads that surround the
warehouse to the north, west, and south. The Mt. Pleasant Canal
borders source area 4 to the southeast. Water in a small surface
drainage ditch originating at the former silo concrete support pad
flows in a southeasterly direction between source areas 4 and 5,
and discharges into Mt. Pleasant Canal near the waste stockpile
( source area 5). In the southern part of source area 4 is a
monitor well (WMW-1) which is located adjacent to the warehouse.
This well was ins~alled by Westinghouse.
Source area 5 is located south-southeast of source area 4, and
north-northwest of a small agricultural field and the wetlands~
The Mount Pleasant Canal borders source area 5 to the southeast.
Located in this area are the excavated and backfilled main chemical
burial trench, and the fenced contaminated pesticide waste
stockpile. A small concrete block retaining wall and gravel pad
where above ground storage tanks once existed, are located on the
southwest corner of the fenced stockpile area. In the southeast
part of source area 5 are thfee monitor wells (WMW-2, WMW-3, and
WMW-4) which are located along the border between source area 5 and
the small agricultural field. These wells were installed by
Westinghouse.
C. Demoaranhy and Land Use
The city of Washington with an estimated population of 9,075 is
located within a four-mile radius of the site. Additionally, there
are four minor population centers located wi thin a four mile radius
of the site. These population centers include Washington Park
centered three miles southeast of the site, Chocowinity centered
four miles south-southwest of the site, Hootentown centered 3.5
miles east-southeast of the site, and Wharton Station centered 3.9
miles northwest of the site. Washington Park has an estimated
population of 403 and Chocowinity has an estimated population of
624, based on 1990 census results. Demographic information was not
available for Hootentown and Wharton Station which are
unincorporated. .
Current land use around the site is primarily light industrial,
commercial, residential, and agricultural. Agricultural fields
surround the site to the north, west, southeast, and southwest. A
275-acre freshwater wetlands is located further to the south and
southwest of the site. The former abandoned city dump is located
within these wetlands'" Industries in the area include distribution
centers for trucking, agro-chemical, propane, and manufacturing
companies related to the textile industry. Commercial operations
include a restaurant, grocery store, retail lumber and hardware
1-6
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Record of Decision
Fet Waahaqton Grounc1water ConUUllination Site
.June :!.993
Sec!.:.o:: 1
store, day care nursery, barber shop, automobile parts store,
insurance sales office, and a D.O.T. office located on Grimes Road
north of the site.
Residential neighborhoods are interspersed within the light
industrial/commercial areas which line the main roads within a
three-mile radius of the site. Approximately 11,350 residents are
estimated to live within a three-mile radius of the site. As
previously mentioned, two structures including the large warehouse
building and the Cleon Lathan residence located in source area 3
are inhabited.
Recreational areas near the FCX Site include a public sw~ing pool
located on Gr£mes Road and a little league baseball field located
east of the National Spinning Company. Tranters Creek, Kennedy
Creek, Tar River, and Pamlico River are used occasionally for
fishing and swilnming purposes. Kennedy Creek, Tar River, and
pamlico River are classified for secondary recreation, indicating
waters of lower quality (WPB, 1990).
The population in the vicinity of the site obtains its potable
water supply from either public water supply wells or from private
wells. Industrial production wells are also located in the
vicinity of the site.
D. Geoloav
Three distinct lithostratigraphic units were penetrated during the
subsurface investigation. They include the surficial
undifferentiated sed~ents, the Yorktown Formation, and the upper
portion of the Castle Hayne Limestone.
Directly beneath the site lies the surficial undifferentiated
sed~ents which are comprised of unconsolidated sand, silt, and
clayey sand of Quaternary age. For the most part, the dominant
lithology of the surficial unit is a fine to coarse grained quartz
sand. Locally, within stream basins, these deposits have been
chemically and mechanically eroded into alluvium. These alluvial
deposits mantle deeper marine and non-marine sediments along
surface waters. The thickness of surficial sediments underlying
the site ranges from 9 feet at MW~03 to 17 feet at 0-06, and
averages 12.3 feet. In addition to naturally occurring deposits,
there are localized zones where clean soil material was used to
fill low lying or excavated areas at the site.
Below the surficial deposits are the sediments of the Yorktown
Formation. Based on existing well log data, surficial sediments
gradually interfinger with sed~ents of the Yorktown Formation.
1-7
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Record of Decision
FOt WaalUngt.On Groundwater Contamination Site
June :'993
Sec';J.on :.
The contact between these two units was determined from
Ii thological variations observed in split spoon soil samples and is
delineated by a near surface clay unit. This clay marks the tOt> of
the Yorktown Formation and was encountered at depths ranging from
9 to 17 feet bls. The Yorktown Formation underlying the site
consists 0=: a~ upper sandy, shelley, clay; an intermediate
shelley, sand; and a lower sandy clay. The thickness of the upper
sandy, shelley, clay varies from 6 feet at MW-06 to 12 feet at MW-
02. The intermediate shell and sand unit varies in thickness from
16 feet at MW-02 to 28 feet at MW-01. The deeper sandy clay un~t
varies in thickness from 14 feet at MW-14 to 23 feet at MW-08.
Overall, the Yorktown Formation varies from 40 feet at MW-Ol to 42
feet at MW-08.
E. Hydroaeoloav
The FCX Site is underlain by seven aquifers. They include a
surficial (water table) aquifer and six deeper semi-confined to
confined aquifers. A more formal desiqnation of these aquifer
systems in order of increasing depth is as follows:
Surficial/water table
Yorktown aquifer
Castle Hayne aquifer
Beaufort aquifer
Peedee aquifer
Black Creek aquifer
Cape Fear aquifer
The water table or surficial aquifer is. comprised of
undifferentiated surficial sands of recent age. The thickness of
the water table aquifer ranges from 2.0 feet at MW-03 to 8.0 feet
at KW-06, and averages 4.6 feet. Underlying the water table
aquifer is the Yorktown aquifer. The Yorktown aquifer is semi-
confined and is separated from the water table aquifer by the upper
clayey sediments of the Yorktown Formation. This clay is formally
designated as the upper Yorktown semi-confining unit and is
continuous throughout the site area. The thickness of the upper
Yorktown semi-confining unit ranges from 6 'to 12 feet, and averages
9 feet. Below this upper semi-confining unit are the permeable
sediments that compri.se the Yorktown aquifer. These sediments
consist primarily of shells and sand. The saturated thickness of
the Yorktown aquifer ranges from 16 to 27 feet, and averages 23
feet. The base of the. Yorktown aquifer is formed by the clays of
the Yorktown Formation and of the Castle Hayne Limestone. Formally
this clay unit is designated as the Castle Hayne confining unit
(Winner and Coble, 1989). Only the upper portion of the Castle
.
.
.
.
.
.
.
aquifer
"
1-8
-------
Record ot Decision
FOt W8shagton GroW1dw8~ Contam1nat1on 5i Ut
.:une 1993
5e=-:::.0:: ::.
Hayne confining unit was penetrated during the RI subsurface
investigation, and therefore its exact thickness below the FCX Site
is not known. Based on site lithologic data, it is known that the
Castle Eayne confining unit is at least 38 feet thick. The
Yorktown aquifer is the deepest aquifer that was penetrated during
the subsurface investigation.
The deeper aquifer systems underlying the Yorktown aquifer are
important from a hydrogeological perspective. However, they are
unaffected by the site. As a result, these systems are not
discussed in this document. Addi tional information on these
systems is available in the Remedial Investigation report.
F. Climate/Meteoroloqy
The climate is moderate with warm and humid sunnners, and calm
winters. Summers are long and quite warm, with afternoon
temperatures averaging 90 'T. approximately 33% of the midsummer
days, and wi th sea breezes generally occurring around noon to
alleviate the inland heat. During winter, numerous polar air
. masses reach the middle Atlantic Coast causing sharp drops in
temperatures. The temperature, however, rarely falls below
freezing. The average annual teDiperature for the period 1945-1982
is 63 ~ (NOCD, 1986).
Rainfall is generally evenly distributed throughout the year with
the driest weather usually occurring in the spring and the wettest
weather occurring in the summer. Summer rainfall comes principally
from thunderstorms which occur one out of every three to four days
during the swmner. Winter rain is generally a slow, steady rain or
drizzle only lasting one or two days. Seldom is there a winter
without a few flakes of snow. However, several years may pass
without a measurable amount.
1-9
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- ------.
Record of Decision
Fet WaahiDg1:oD Grounciwa'ter Con'tallLiDa'tioD S1'te
June 1993
Section :2
II SITE HISTORY AND ERPORCENMENT ACTIVITIES
A. Site Historv
The FCX facility operated a farm supply distribution center which
repackaged and sold pesticides, herbicides, and tobacco treating
chemicals from 1945 to 1985. From 1960 to 1981, an unknown amount
of chemical waste in plastic containers and paper bags, generated
by FCX, was buried in an on-site landfill located in source area 5,
southwest of the former FCX warehouse (NCDHR, 1987).
Since mid-1986 to date, several site investigations have been
performed at the FCX Site. Sampling studies have been conducted by
local, state, and federal agencies, as well as private consultants
to FCX Inc. and Fred Webb, Inc. These previous site
investigations, however, have been primarily limited to source
areas 2 and 5 of the former FCX facility (see Figure 1-3). In
September 1990, EPA initiated this Remedial Investigation/
Feasibility Study (RIfFS) to address all potential source areas and
associated contamination at the FCX Site.
B. Summary of Previous Investiaations
. In July of 1986, a preliminary assessment of the- FCX Site. was
prepared by the North Carolina Department of Human Resources
(NCDHR). This preliminary assessment indicated that pesticides, in
the form of toxic powder and liquid wastes, were buried on-site,
and a potential for groundwater, soil, and drinking water
contamination existed. The report recommended that a site
investigation be performed.
The FCX Site was inspected by the NCDHR, Solid and Hazardous Waste
Management Branch, on August 26, 1986. Chemical analyses revealed
the presence of aldrin, dieldrin, chlordane, DDT, DDE, DDD,
hexachlorobenzene, carbon disulfide, naphthalene, phenanthrene,
acenaphthylene, fluorene, dibenzofuran, 2-methylnaphthalene, and
mercury at measurable concentrations. No volatile organic, semi-
volatile organic, pesticide, or metal contamination was revealed in
any of the five groundwater samples collected. Ambient air
2-1
-------
Record of Decision
POt Wa8l1ingtC:1 Groundwa~er Ccntam:1.nat,ion Site
June 1993
Sec-::.o:: 2
monitoring during the site inspection using an HNu did not detect
volatile organic compounds (VOCS) above background levels.
In May of 1987, FCX Inc. employed the resources of Rose and
Purcell, Inc., and GSX, Inc., to study the on-site contamination
and clear the chemical warehouse located in source area 4.
Chemical analysis of one soil sample collected by GSX in the
vicinity of the main chemical burial trench revealed the presence
of toxaphene at a concentration of 2400 milligrams/kilogram (mg/kg)
and copper at a concentration of 480 mg/kg, among other
contaminants (McLaughlin, 1987).
August of 1988, EPA Region IV's technical assistance team (TAT)
conducted a site reconnaissance sampling investigation. An
electromagnetic survey (EM-31) and a magnetic survey were used to
identify the boundaries of the chemical burial trenches located in
source area 5 (TAT, 1989). Soil samples collected near the main
chemical burial trench during the 1988 sampling investigation
revealed the presence of elevated concentrations of DDD, DDE, DDT,
Alpha-Chlordane, Gamma-Chlordane, Dieldrin, Phenol, Heptachlor
Methoxychlor.
In January of 1989, EPA conducted a removal action at the site was
initiated in which approximately 3000 cubic yards (cy) of
contaminated soil was excavated from the main chemical burial
trench located in source area 5. The soil was stockpiled wi thin a
secured area in the southern corner of this source area (TAT,
1989).
Additionally, in 1990, TAT collected soil samples from the area
surrounding the for.mer FCX blending building (Charlie Toms
Restaurant & Oyster Bar) located in source area 2 (see Figure 1-5).
Subsequently in late January, an additional 49 cy of contaminated
soil was excavated from the area surrounding the former FCX
blending building. This removed waste was consolrdated with the
previously removed waste located in source area 5 (TAT, 1991).
In association with the 1990 TAT sampling investigation and
subsequent removal action activities at the site, additional soil
sampling in source area 2 revealed the presence of pesticides,
volatile organics, and semi-volatile organics at elevated
concentrations (TAT, 1991).
In July of 1990, in response to a report that the permalon liner
covering the contaminated soil stockpile was torn, EPA constructed
a temporary containment beJ:Jll around the waste stockpile to prevent
potential contamination runoff, and repaired the torn liner (TAT,
1991). During this .operation, additional buried material located
two feet below ground surface (with a total pesticides
concentration of 103 mglkg) was identified at the northern corner
2-2
-------
Record of Decision
FOt WallhU1~n GroUJldwa<;er ContallliDaUon Site
June 1993
Sec:tior: 2
of the stockpile (TAT, 1991).
In August of 1990, a groundwater sampling investiqation in the
vicinity of the former warehouse and chemical burial trench was
performed by Westinqhouse Environmental and Geotechnical Services,
Inc. for Fred Webb Grain, Inc. Four 2-inch stainless steel wells
were installed in source areas 4 and 5. Analyses of groundwater
samples collected from the Westinghouse wells revealed elevated
levels of endrin, 4,4 DDD.
C. Enforcement Activities
The FCX Site was listed on the National Priority List in March of
1989.
In October and November of 1988, the EPA and the State of North
Carolina joined in legal action to secure the remaining assets of
the bankrupt FCX Corporation prior to their disbursement to the
investors. The proceedings occurred wi thin the Federal Bankruptcy
Court in Raleigh, North Carolina. In July 14, 1992 a Trust
. Aqreement was entered, which provided that FCX could not abandon
the proPerty at the FCX-Washington Site and that a portion of the
remaininq assets were to be divided between the FCX-Washington Site
and the FCX Statesville Site. .The actual allocation for the FCX
Washinqton Site was $1,750,000.00.
In March 30, 1992 the Aqency entered into a consent decree with
Fred Webb Inc. The settlement was for $540,000.00, to be paid over
a five year Period.
. . -
2-3
..
SO"
--..
_. .
-
~
-------
Record ot D8ci8ian
PCX WA8h1DgUcm GroIUIdwatar Ccmt&81Jl&Uan Site
JIID8 1993
S8c:Uan 3
HZGRLIGII'l'S OF COIOIOlUTY PAR'l'ICIPATIQR
III.
Pursuant to CERCLA 5113(K)(2)(B)(i-v) and 5117, the RI/FS Report
and the Proposed Plan for the FCX Washington Site were released to
the public for comment on April 20, 1993. These documents were made
available to the public in the administrative record located in the
information repository maintained at the EPA Docket Room in Region
IV and at the Brown Library in Washington, North Carolina.
The notice of availability for these documents was published in the
Washinaton Dailv News and the Dailv Reflector on April 20, 1993.
A public CODDDent period on the documents was held from April 20,
1993 to June 18, 1993. A copy of the notice was mailed to the
public. In addition, a public meeting was held on May 4, 1993. At
this meeting, representatives from EPA answered questions about
problems at the Site and the remedial alternatives ~der
consideration.
Other cODDDunity relations activities included~
*
Community Relations Plan finalized on February 6, 1991
and a copy was placed in the information r~pository.
*
Issuance of a Fact
September 1991.
Sheet
on
the RI/FS process
in
*
Public meeting on October 3, 1991, to discuss the
superfund process. The meeting was announced by a
display ad that appeared in the newspapers on September
26, 1991
*
Public notice was mailed to citizens infoDling them that
EPA was beginning the second phase of removal activities
at the Site.
*
Issuance of a. Fact Sheet updating the RI/FS activities in
December 1992.
*
Issuance of a Fact Sheet on the Proposed Plan in April
3-1
-------
Record of Decision
FCX waahingt:.on G:oundwater Con~nation 51 te
Ju!!e ~993
Sec-;:.or. J
*
Proposed Plan Public Meeting for the ground water
remediation held on May 4, 1993. The meeting was
announced by display ad on April 20, 1993.
*
Notice mailed to citizens and appeared in area newspaper
on May 17 1993 announcing 30-day extension of public
connner..t period which was extended until midnight June 18,
1993.
~
#..
3-2
-------
Record or D8Ci8i=
POt w..1UDgUm GrCI1UI4v&~ CGD~UOII 81~
JUDe 1993
8ecU0II .
IV. SCOPE .AIm ROLE OF RESPONSB AC'l'IOR WI:1'III:N SITE STRATEGY
The FCX Washington Site has been divided into units or phases,
referred to as "operable units". The operable units (OUs) at this
Site are: .
OU One:
Contaminated ground water.
Residua1 Soi1 Contamination.
OU Two:
This approach was taken because the soil and source contamination
are being addressed via a time-critical removal action that is
presently taking place at the site. This removal action is
expected to address a11 soil/source contamination to the point no
further remediation is required.
4-1
-------
Record of Deci8ion
POt W..h1n~n Groundwater Contam1nation SJ. te
June ~99J
Sec-:.:.or.. 5
V. SUDARY OF SITE CHARACTERISTICS
The Remedial Investigation (RI) at the FCX Washington Site included
the characterization of the following routes of contaminant
migration: soil, groundwater, surface water and sediment
contamination.
A. Soil Investiaation
The Remedial Investigation included a thorough soil
that encompassed the sampling of soils within each
areas identified at the Site. The results of the
were used to facili tate the four stage removal
conducted at the Site.
investigation
of the source
investigation
action being
The actual removal of contaminated soil was conducted in three
stages.
In January of 1990 2,200 cubic yards of pesticide contaminated
soil and debris were excavated and stockpiled on Site.
In January of 1992 EPA excavated an additional 2,000 cubic
yards of contaminated soil and added it to the existing
stockpile.
The third stage of the removal action began fn September of
1992, during which 3,110 cubic yards of the existing stockpile
was bagged and placed in the on-site warehouse for storage,
and an additional 11,600 cubic yards of contaminated soil was
excavated and stockpiled on-site.
The fourth stage will consist of treatment of the contaminated
soils stored on Site.
Assessment of the soils is not given at this time because Site
conditions were altered by the removal action subsequent to the
Remedial Investigation. However, operable unit 2 (OU2 ) will be
implemented upon the completion of the fourth stage of the removal
action. OU2 will give a full accounting of the four stages of the
removal action and a complete assessment of the Site soils post
treatment. .
5-1
....,
. .., --"..
. :::II'P""""'r. . :.0,;.....
. - .,*-. .'
-------
_.
~
-N-
~
200 0 200
SCAI.£ IN FEET
LEGEND
-x- FENCE
---. TREELINE
-- SURFACE WA'fER
8 YONITDR WELL
.:,">.
. COM FEDERAL ARCS IV
MONITOR WELUSTAFF GAUGE LOCATIONS
FCX WASHINGTON SITE
. ,..
. WASHINGTON, NOR'rH CAROLINA
FIGURE NO.
5-1
-------
Record ot Decision
PCX Waahin!JT.clI G:oundwater ContalllinatioD S1u
June ~993
.3ec:::.o:: 5
B. Groundwater Investiaation
Groundwater sampling was conducted at the FCX Site to fully assess
the types and concentrations of contaminants present in the aauifer
system, and to determine the extent and magnitude of groundwater
contamination with regard to each of the source areas identified at
the site.
A total of 18 monitoring wells (9 two-well clusters) were installed
at the approxim~te locations shown in Figure 2-1 to supplement the
4 existing monitoring wells (WMW1 - WMW4) installed by Westinghouse
Environmental and Geotechnical Services, Inc. for Fred Webb, Inc.
in 1990.
Seventeen pesticides were found at concentrations significantly
elevated above background in groundwater at the Site. Pesticides
were not detected in any of the background groundwater samples.
The range of concentrations for the seventeen pesticides found in
groundwater are as follows:
. Aldrin: ND 0.98 JJ.9/l
. E:eptachlor: ND 2.1 JJ.9/l
. Heptachlor epoxide: ND 0.49 p.g/l
. Alpha-BHC: ND 4.1 JJ.9/l
. Beta-BRC: ND 1.7 p.g/l
. Gamma-BRC: ND 8 JJ.9/l
. Delta-BRC: ND 10 p.g/l
. Dieldrin: ND 2.6 p.g/l
. 4,4-DDT: ND 4.6 p.g/l
. 4,4-DDE: ND 0.42 p.g/l
. 4,4-DDD: ND 13 p.g/l
. Endrin: ND 1.2 p.g/l
. Endosulfan sulfate: ND 0.21 p.g/l
. Toxaphene: ND 110 p.g/l
. Gamma-chlordane: ND 1.6 p.g/l
. Alpha-chlordane: ND 0.77 p.g/l
. Endrin ketone: ND 2.9 p.g/l
The estimated areal extent of pesticides in groundwater is shown in
Pigure 5-2.' Most of the significantly elevated pesticides
concentrations in groundwater are limited to source areas 4 and 5.
There is one isolated area within source area 2 (MW3-SH) that shows
significantly elevated concentrations. The distribution of
significantly elevated pesticides concentrations are limited mainly
5-3
-------
LEGEND
,
-N-
I
200 0 200
SCAlE IN FEET
-x- FENCE
~ TREEUNE
-- SURrACE WATER
e MONITOR WEll.
~ ARE'AI.. EXTENT
"'-P IN SURfICIAL ACUFER
~AR£ALEmNT
~ IN YORICAlWG SIGNflCANtly . MWHJP
ELEVATED CONCENIRATIONS
,.
CDM FEDERAL ARCS IV
ESTIMATED EXTENT OF PESTICIDE CONCENTRATIONS
GREATER THAN 2 TIMES BACKGROUND IN GROUNDWATER
FCX WASHINGTON SITE
WASHINGTON. NOR1H QAROUNA
5-4
FIGURE NO.
5-2
-------
Record of Decision
FCX waahirlgt.on Groundwater ContallliDatiOD 5i te
Jcne 1993
,sec-:;.c:: ~
to the upper 25 feet of the surficial aquifer. Only two
pesticides, endosulfan sulfate (0.21 ~/l in MW7-DP) and aldrin
(0 .14 ~/l in MW8-DP) were measured at significantly elevated
concentrations in the Yorktown aquifer.
Seven volatile organics were found at concentrations signi~icantly
elevated above background in groundwater at the site. Volatile
organics were not detected in any of the background groundwater
samples. The range of concentrations for the seven volatile
organics found in groundwater are as follows:
. Chloroform: ND 14 J.l9/l
. 1,2-Dichloroethane: ND 35 jJ.g/l
. 1,2-Dichloropropane: ND 390 J.l9/l
. Benzene: ND 830 .J.l9/l
. Toluen~: ND 2200 J.l9/1
. Chlorobenzene: ND 160 J.l9/l
. Total xylenes: ND 3300 J.l9/l
The estimated areal extent of volatile organics in groundwater is
shown in Figure 5-3. As indicated in this figure, most of the
significantly elevated volatile organics concentrations in
groundwater appear to be limited to source area 5. There is one
isolated area within source area 4 that shows a significantly
elevated concentration. The distribution of significantly
elevated volatile organics concentrations appears to be limited
mainly to the upper 25 feet of the surficial aquifer. Two VOCs,
toluene and chlorobenzene (both at 2 JJ.9/l in MW9-DP) were measured
at significantly elevated concentrations in the Yorktown aquifer.
There were no volatile organics detected in the groundwater samples
.collected from the private wells.
Semi-Volati1e OrGanics
Three semi-volatiles were found at concentrations above background
in groundwater at the site. Semi-volatile organics were not
detected in any of the background groundwater samples. The range
of concentrations .for the semi-volatile organics measured in
groundwater are as follows:
.
.
.
Bis(2-ethylhexyl)phthalate:
Carbazole:
pentachlorophenol:
ND
ND
ND
68
10
78
JJ.CJ/l
JJ.CJ/l
JJ.CJ/l
The estimated areal extent of semi-volatile organics in groundwater
-
..
5-5
...
-------
-
~
-N-
~
200 0 200
SCAI.£ IN FEET
LEGEND
-x- FENCE
--... TREELINE
-- SURFACE WATER
8 MONITOR WElL
~AREALEXTENT
~ IN SURF1CIAL AQUIFER
~AR£ALEXTENT
~ IN ~ ACUFER
UW8-8H HOtUGKrED WELL MWI-..
N>lCATWG SIGNIFICANIlY UW8-DP
El£VA1EI) CONCENIRATIONS
..
eoM FEDEfW. ARCS IV .
ESTIMATED EXTENT OF VOC CONCENTRATIONS
GREATER THAN 2 TIMES BACKGROUND IN GROUNDWATER
FCX WASHINGTON SITE
WASHINGTON, NOR11i CAROUNA
FIGURE NO.
5-3
r:,,,-<~~
-------
LEGEND
~
-N-
I
200 0 200
SCALE IN FEET
-x- FENCE
---. TREEUNE
- SURFACE WATER
. UONITCR WElL
d/>t.AR£ALEXTENT
~ IN SURf1CW. AQUIfER
. ~ AR£AL EXTENT
~ IN 'tDRKTDWN ACUFER
MWIHH tOOHUGHTED WELL
N)1CA1WG SlGNFlCANtLY
£L1VATED CONCENJRA11ONS
~
COli FEDERAL ARCS IV
. ESTIMATED EXTENT OF SEMI-VOLATILE CONCENTRATIONS
GREATER THAN 2 TIMES BACKGROUND IN GROU"DWATER
FCX WASHINGTON SrrE
WASHINGTON, NOR1H CAROLJt.IA
. FIGURE NO.
5-4
;-7
-
-------
Record of Decision
FOt WashJ.ngton Groundwater Contamination Site
.June 1993
.sec~::'o:1 5
is shown in Fi.qure 5-4. As indicated in this figure, significantly
elevated semi-volatile organics concentrations in groundwater
appear to be lLmited to two isolated areas within source area 5.
There is one isolated area within source area 4 that shows an
elevated concentration of semi volitale organics. The distribution
of significantly elevated semi-volatile organics concentrations
appears to be lLmited mainly to the upper 25 feet of the surficial
aquifer. Only one significantly elevated concentration of bis(2-
ethylhexyl)phthalate (68 /41/1 in MW5-DP) was measured in the
Yorktown aquifer.
There were no semi-volatile organics of concern detected in the
groundwater samples collected from the private wells.
Metals
Five metals were found at concentrations significantly elevated
above background in groundwater. These five metals and their range
of concentrations identified in groundwater are as follows:
. Beryllium: ND 21 J.IIJ/1
. Nickel: ND 140 J.IIJ / 1
. Zinc: 15 370 J.l.g/l
. Mercury: ND 2.8 J.IIJ/l
. Manganese: 25 9500 J.IIJ/l
The est~ated extent of metals concentrations qreater than 2 times
background in groundwater is shown in Figure 3-5. As indicated in
this figure, most of the significantly elevated metals
concentrations in qroundwater appear to be l~ited to source areas
4 and 5. There are also two isolated areas within_source areas 1
and 3 that show significantly elevated concentrations. The
. distribution of significantly elevated metals concentrations
appears to be limited mainly to the upper 25 feet of the surficial
aquifer. Only manganese (5900 /41/1 in MW4-DP) was measured at a
significantly elevated concentration in the Yorktown aquifer.
Two of the private wells sampled during the field investigation
(PWOl and PW03) contained significantly elevated concentrations of
zinc. The source of the zinc concentrations remain unknown. For
this reason, the private well analytical data was not used in this
study to help - estimate the extent of metals contamination in
groundwater.
5-8
-------
Record of Decision
POt Waah1nq""..on G:owu:1vater ConUlll1nat1on 51 te
June ~993
Sec':.:l.c:: 5
c. Surface Water Investiaation
Samples of surface water were to be collected both on-site and off-
site to determine and evaluate surface water contaminant migration
pathways and the extent and magnitude of surface water
contamination with regard to each of the source areas identified at
the site. . Surface water is only present on site during rainfall
events. There was no surface water at any of the nine sample
locations at the time of sampling. Because the presence of surface
water is seasonal and corresponds to rainfall events, the
remediation of on-site surface water will be addressed through the
selected treatment remedy for soils/sediments.
To assess the surface water condition in the wetlands, the "pore-
hole" method was used to collect three surface water samples. This
method involved digging an approximate 2-foot deep hole at the
sample location, letting water seep into the hole, and filling the
sample bottles directly from the hole. The surface water sampling
locations are shown in Pigure 5-6. Surface water samples were
collected at the three wetlands locations (SW07, SW08, and SW09).
None of the seventeen pesticides identified on-site were detected
in the three surface water samples collected in the wetlands.
Based on these findings it was determined that pesticides
contamination is not a problem in the surface water of the wetlands
near the site. The only volatile organic detected in the wetlands
was toluene, which was detected at one location (SW09) at a
concentration of 5 ~/l.
No semi volatiles were detected in the samples collected in the
wetlands. Semi-volatile organics contamination is not a problem in
the wetlanc.s at the site.
Four metals were detected in surface water samples collected in the
wetlands. The range of concentrations for these four metals
identified in surface water are as follows: .
.
.
.
.
Lead:
Zinc:
Mercury:
Manganese:
8
24
ND
160
35
62
0.31
1400
~/l
IPJ/l
IPJ/I
IPJ/l
5-9
-------
~
-N-
I
200 0 200
SCAlE IN FEET
LEGEND
-x- FtNCE
~ TRmINE
-- SURFACE WATER
.. MONITOR WEll.
~ARtALEXTENT
~ IN SURF1CIAl AQUFER
~ARtALEXTENT
~ IN YORKTOWN AQUFER
IM8-8H HGHlDf1EI) WELL MWl-SH
1NDICAt1NG SlGNFICAN1l Y UWB-DP
ELEVA1ED CONCENTRA11ONS
f'
COli FEDERAL ARCS IV
ESTIMATED EXTENT OF METAL CONCENTRATIONS
GREATER THAN 2 TIMES BACKGROUND IN GROUNDWATER
FCX WASHINGTON SITE
WASHINGTO", NORTH CAROLINA
.1)-1 0
FIGURE NO.
5-5
-------
(I)
C
:II
~
n
m
~
!!~ ~
III ~
~zll~ I
VI G) ,..
I "'!I ~
:: nO U) f;J
~= ~ ;:
i~ ~
r-
o
~
:t
o
Z
fD
'r \ ~
0\ i1I
z
p
500
...........,
LEGEND
~
~
1
o
SCAlE IN fEET
500
.
..
-...
... ..
-...
... -
-... ........
... - ...
------ SOURCE AR£A
BOUNDARY
SOURCE AREA
.. - ~ WETlANDS
SAMPlE lOCATION
SEDIMENT SAMPLE
SURfACE WATER SAMPLE
18
SD
SW
...
..
...
DUMP
- *
...
-... ...
..
-... ...-..,1...-...
... - .. - {.' ... ...
.. -
. -
-------
JI8COzd of Dec1.8Um
PC[ v..II1Dgtoa ~..........ter ~ Bite
J- 1993
SectiOD 6
VI.
SUMMARY OF SITE RISKS
The FCX Washington Site is releasing contaminants into the
environment. The Baseline Risk Assessment Report presents the
results of a comprehensive risk assessment that addresses the
potential threats to public health and the environment posed by the
Site under current and future conditions, assuming that no remedial
actions take place, and that no restrictions are placed on future
use of the Site. The Baseline Risk Assessment being sununarized in
this section considered the Site risks associated' 'with the
groundwater only. The Site risks associated with the soils and air
pathways will be presented in OU2.
The Baseline Risk Assessment Report consists of the following
sections: identification of chemicals of potent~al concern;
toxicity assessment; human exposure assessment, risk
characterization; and environmental assessment. All sections are
summarized below.
A. Contaminants of Concern
Data collected during the RI was reviewed and evaluated to
determine the contaminants of concern at the Site which are most
likely to pose risks to the public health. These contaminants were
chosen for each environmental media sampled.
Once these contaminants of concern were identified, exposure
concentrations in each media were estimated. - Exposure point
concentratior-s were calculated for groundwater using the lesser of
the 95 'percent upper confidence 1 :.mit concentration or the maximum
detected value as the reasonable maximum exposure (RME) point
concentration. Exposure point concentrations for groundwater are
shown in Table 6-1.
B .EXDOSure Assessment
The exposure assessment evaluates and identifies complete pathways
of exposure to human population on or near the Site. Current and
future exposure scen~ios include ingestion of groundwater; and
inhalation of volatiles evolved from groundwater during household
water use. Further detail and mathematical calculations can be
reviewed in the Baseline Risk Assessment. Table 6-2 provides the
exposure assumptions that were used in the BRA.
6-1
-------
Table 6-l
Summary of Reasonable Maximum Exposure Concentrations for Contaminants of Concern
Shallow and Deep Aquifers
FCX Washington Site
Washington, North Carolina
--
-.
---- .....
...... -----------
UCL or Maximum (ug/l)
COC
Shallow
Deep
---
-............----
BERYlLIUM
CHROMIUM III
NICKEL
lEAD
ZINC
MERC~Y
MANGANESE
CHLOROFORM
1,2-DICHLOROETHANE
1,2-DICHLOROPROPANE
BENZENE
TOllJ:NE
CHLOROBENZENE
TOTAL XYLENES
ALDRIN
HEPTACH.OR
HEPTACI-LOR EPOXIDE
ALPHA-BHC
BETA-SHC
GAMMA-BHC (UNDANE)
DELTA-BHC
DIELDRIN
4,4-ooT (P,P-DDT)
4,4-DOE (P,P-DDE)
4,4-DOD (P,P-DDO)
ENORIN
ENDOSULFAN SUlFATE
TOXAPHENE
GAMMA-CHlORDANE
ALPHA-CHLORDANE
ENCRIN KETONE
BIS(2-~ PHTtWATE
PENTACH..OROPHENOL
CARBAZOLE
3
49
55
77
241
0.22
5900
ND
12
6
ND
2
42
5
0.40
ND
NO
1.5
0.4
4.3
8.3
0.5
0.4 '
NO
7
0.3
0.21
NO
NO
NO
0.9
19
28
NO
21
56
140
64
157
1.6
9500
14
ND
336
317
1868
11
3300
0.17
0.9
0.416
1.08
0.94
0.42
3.9
2.6
4.6
0.42
4.1
1.05
0.14
82.8
1.33
0.77
1.6
NO
NO
6
cae Contaminant d Conoem
NO Not Detected
6-2
-------
JI8card o~ Deci.81aa
ft:% ~ ~--"-'t8r ~UaD Site
JUDe 1993
Sectiou 6
TABLE 6-2
I EXPOSURE ASSUMPTIONS I
Child Adult Adult
Resident Resident Worker
Body Weight (kg) 16 70 70
Exposure 350 350 250 I
Frequency
(days/year)
Exposure Duration 6 30 25
(years)
Ingestion Rate 2 2 1
(GW) (liters/day)
Inhalation Rate 16 15
(m3 /day)
c. Toxicitv Assessment
Under current EPA guidelines, the likelihood of adverse effects
occurring in humans from carcinogens and noncarcinogens are
considered separately. These are discussed below. 'rabIes 6-3 and
6-4 summarize the carcinogenic and noncarcinogenic toxicity
criteria for the contaminants of concern.
Cancer slope factors (CSFs ) have been developed by EPA for
estimating excess lifet~e cancer risk associated with exposure to
potentially carcinogenic chemicals. CSFs, which are expressed in
units of (mg/Kg-day)-1, are multiplied by the estimated intake dose
of a potential carcinogen, in mg/kg-day, to provide an upperbound
est~ate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upperbound" reflects the
conservative estimate of the risks calculated from the slope
factor. Use of this approach makes underestLmation of the actual
cancer risk highly unlikely. Cancer potency factors are derived
from the results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied.
Reference Doses (RfDs) have been developed by EPA for indication of
the potential for adverse health effects from exposure to chemicals
6-3
-------
6-3
Cane.r 810p. Faclor., lumor 611.. and EPA Canc.r CI...lllcaliana 10, Conlamlnan18 01 Coneern
R:X W..hlnglon 8118 ,
W..hlnglon, Norlh Cuollna
------------------------------------------------------------------------------------------------------------.-~-----_._------
cae
Tumor 81...
)
,"r81 InhalaUon Or'" 1nhe18IIon
------------------------------------._-----~-_._-----.----------------------------~----------------------_.---------------
EPA
CI..,1Ic1dlDn
CBF(mgJlcgJday.-1
BERVWUM ".IE+OO (2. '.4E+OO (2)
CHROMllat 811 NA NA
NICKEL NA 1.7E+OO (2)
~~ NA NA
ZINC NA NA
MERCURY NA 'NA
MANGANEBE NA NA
CHLOROFORM 8.1E-01 (2. '.IE-02 (2)
1.2-DICHLOROETHANE 8.1E-02 (2) 8.IE-02 (2)
1.2-DICHLOROPRDPANE '.8E-02 (21 NA
BENZENE 2.8E-02 (2) a.SE-02 (2)
TOWENE NA NA
CHLORDBfNZENE NA NA
TOTALXYLENE8 NA NA
ALDRIN UE+OI (21 1.1EtOI (21
HEPTACHlOR 4.IE+OO (2. UEtOO (2)
HEPTACHlOREPOXIDE 8.1Etoo (21 81EtOO (21
AlPHA-BHC 8.3E+00 (2) 83E tOO (21
BETA-BHC UEtoo (21 lIE tOO (21
GAMMA-BHe (UNDANE) UE+oo (21 NA
DELTA-BHe NA NA
DleWRlN f,CiE+O' (2' UE tOI (2'
",..'-ODT (P.P'-OOl} 3.4E-OI (21 3.4E-01 (21
4.4'-DOE (P,P'-DDE) 1.4E-OI (21 NA
4.4'-DOD (P,P'-DDD. 2.4E-OI 121 NA
ENQRlN NA NA
ENDOSUlfAN SUlfATE ~ NA
TOXAPHENE 1.1 E +00 (2) ... E +00 (2)
GAMMA-CHLORDANE UE+oo (2) UE+oo (21
ALPHA-CfWflJANE 8.IE+00 (21 UEtoo (2)
ENDRIN k£1ONE NA NA
BIS(a-ETHYlHEXYl) PHTHALATE 1.4E-02 (21 NA
8ENZOCAI.c,N1'HMCE~ 1.3E+00 (21 6.1E+00 (21
CHRYBENE' " ' 1.3S+oo (2) '.8E+00 (a)
BENZOIBIJOR I<)fLUOfW4fHENE 1.IE+00 (2) "'E+oo (2)
BENZO-A-PYRSNE: .~).. ',I:' ,: ',7.IE+00 (2) '.8E+00 (21
ItI)EtG (U,a-CD) PYRENE ' , '.IE+oo (2) 8.8E+OO (2)
DIBENZDMANTHRAC~ ' ' '.IE+oo (2) '.8E+00 (2)
PENI'ACHLOAOPtENOL' I, 8.IE-01 (2J . NA
CARBAZOLE '.OE-O' (2) NA
2.I,7,8mMCHLbRODlBEmoolOXiN UE+CII (I) UE+OI (3)
To'lIlumOr8
NA
NA
NA
NA
NA
NA
UWIf
CI,clJlaloJy .y.tern
Uver
Blood
NA
NA
NA
UWf
Uver
Uver
Uver
Uver
Uv.r
NA
Uw,
UV8f
Uv.r
Uvar
NA
NA
UWf
Uver
Uver
NA
UWIf
NA
NA
NA
BIom8ch
NA
NA
u........ 8"'"
UVIr
RNpIrIllorr 'pl8m,"
----------------~~--------------_.--------_._--------------------------------
(21 IRlB, 1 qlll2
(SI HEAST,I882
. "
, .
"
"
Lung
NA
Aaapfraloly ay.lam
UV8f
NAI
NA
NA
UV8f
CIrClllalory ,pi....
NA
Blood
NA
NA
NA
Uver
Uver
Uvw
Uver
Uver
Uver
NA
Uwr
Uvw
Uver
NA
NA
NA
UV8f
Uver
Uvw
NA
NA
NA
NA
NA
RMplrlllofy trllCt
NA ' I
NA
NA
NA
................. ..
... .-----------
82
D
A
B2
D
D
D
B2
B2
8a
A
o
o
o
82
82
82
82
sa
82
D
82
8a
82
82
D
D
II
82
82
D
B2
8a
82
82
sa
8a
II
II.
~II
II
...;t'
I
\D
"
--------------
c;og CcarII8dwII..Conoam
AD ........ DaM
NA NIIAptllk1ll1e
-------
6-4 .
IIn'OIOIlCO 1I1I1I1In. IRlllol :llIoa, ftlld (;onOd..,C. h",.I. lor Conlamlnanl. 01 Conc.1A
FCX W8.I.nglotl 911.
W...hlnololl, NOfIl. Carolina
... ---- --------------------- ----- ---.-.....,--..- ....
... - - '- - - ...--- -- ------..--------------.-- - - - -------------------------------.-_._------
coc
Rlf) (molleo/day.
T arg., SIt..
~11 factar
Or.I
I"hala 11011
Orellt
Inhelellon
Or"
Inhelellon
Dermal
- - ------ --- - ---- ---------- -.---------. .;.------ - -.------- ---- --------------------.------------------.------.-------.------
DERVU.IUM 5.OE-03 (2) NA NA NA 100 NA High
CHROMIJM III I.OEtoo (2) NA UWf NA 100 NA HIgh
NICKEL 2.0E-02 (2) NA Mop organa NA 300 NA High
lEAD NA NA Can." R8M)U8 .V'''''''' blood NA NA NA NA
ZINC 3.0E-OI (2) NA Blood NA S NA High
MERCURY 3.0E-04 (2) . NA Cen.al n","ous 5valem NA NA NA NA
MANGANESE (dleIoIV) I.OE-OI (2) I. IE 04 (3) Call. al ".. voua 'Yllem . lung aoo 100 High
MANGANESE (IngnUon 01 we'..) 5.0E-03 (2) NA
CHLOROfORM I. DE -02 (2) NA Ilvet NA NA NA NA
. ,2-DICH: OROETIIANE NA NA NA NA NA NA NA
'.2 -OICtilOROPAOPANI: NA '.IE,'03 (2) N~ NA 300 NA HIgh
BENZENE NA NA NA NA NA NA NA
TOLUENE 2.0E-01 (2) '.'E-.O' (2) U_, kldlle~ Cen'el RerV0U8 .V8I8rn 1000 aoo High
CHLOROBENZENE 2.0E-02 (2) 6.1E-03 (3) LIller Uv8r 1000 10000 High
TOTAL XYLENES 2.0Etoo (2) NA Can"l nefYOU. IV,'.m NA 100 NA High
ALDRIN 3.0E-05 (2) NA Uver NA 1000 NA High
HEPTACHLOR &.OE - 04 (2) NA !.Iller NA SOD NA HIgh
tlEPTACHWR EPOXIDE 1.3E-05 (2) . UA I Iller NA 1000 NA ~Igh
ALPHA-OtiC NA riA NA NA NA NA NA '"
8ETA-SHe NA tlA W\ NA NA NA NA '
-0
GAMMA- DIIC (LINDANE) 3.UE-04 (2) NA I llIef, kld"ev NA 1000 NA High
DELTA-III.~ 3.0E-04 (2) NA NA NA NA NA NA
DIELDRIN $.OE-05 (2) NA Uver NA 100 NA High
4,4'-DD1 IP,P'-UDl) 5.0E-04 (2) NA liver NA 100 NA High
4,4'-00£ (P,P'-DDE) NA NA NA NA NA NA NA
4.4'-000 (P,P'-DDO) NA NA NA NA NA NA NA
ENORIN 3.0E -04 (2) NA Cerllral netyoulayatem.llvw NA 100 NA High
ENDOSULfAN SULfATE &,OE-05 (2) NA I
-------
JI8eard of' Dec:1s:1oD
PC[ _.h4~ c........dI..at:er ~Uaa 811;8
JUDe 1993
Sect:i.- 6
exhibiting noncarcinogenic effects. RfDs, which are expressed in
uni ts of mg/kg-day, are estimates of acceptable lifetime daily
exposure levels for humans, including sensitive individuals.
EstLmated intake dose of chemicals from environmental media can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied. These uncertainty factors help ensure that the RfDs will
not underestimate the potential for adverse noncarcinogenic effects
to occur.
In the case of lead, EPA recommends the use of the Agency's Uptake
Biokinetic model which predicts blood-lead levels for children ages
o . 5-7 years under various exposure scenarios and lead
concentrations.
D. Risk Characterization
The risk characterization step of the baseline risk assessment
process integrates the toxicity and exposure assessments into.
quantitative and qualitative expressions of risk. The output of
this process is a characterization of the Site-related potential
noncarcinogenic and carcinoqenic health effects.
Potential concern for noncarcinoqenic 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 concentration in a given medium to the contaminant's
reference dose. By addinq the HQs for all contaminants within a
medium or across all media to which a given population may be
reasonably exposed, the hazard Index (HI) can be generated.
Calculation of a HI in excess of unity indicates the potential for
adverse health effects. Indices greater than one w:tll be generated
anytLme intake for any of the chemicals of concern exceeds its
Reference Dose (RfD). However, given a sufficient number of
chemicals under consideration, it is also possible to generate a HI
greater than one even if none of the individual chemical intakes
exceeds their respective RfDs.
Carcinoqenic risk is expressed as a probability of developinq
cancer as a result 9f lifetime exposure to a cintaminant
concentration in a given medi.um. Excess lifetime cancer risks are
determined by multiplying the intake level with the cancer. potency
factor. EPA' s acceptable target range for carcinoqenic risk is
one-in-ten-thousand (lE-4) to one-in-one-million (lE-6).
Neither a cancer slope factor nor a reference dose is available for
lead. Instead, blood lead concentrations have been accepted as the
6-6
-------
8IIcard at D8c1aicm
~ ~ GrOaIIdIRa1:er CaIrt.II81JIatilm SU.
JUDe 1993
~..j,OD6
best meas~re of exposure to lead. The EPA has develoDed a
biokinetic/uptake model to assess chronic and nonchronic exPosure
of children to lead. The uptake/biokinetic model estimates total
lead uptake resulting from diet, inhalation, and ingestion of
soil/dust, water, paint, and placental transport to the fetus. The
uptake/biokinetic model calculates the uptake and blood lead levels
for the most sensitive population, children ages 0 to 6 years old.
EPA uses a blood lead level of 10 micrograms per deciliter (ug/dl)
as the benchmark to evaluate lead exposure.
Current use
Ingestion exposure to groundwater obtained from private well one
(PWOl) constitutes the only complete exposure pathway for the
current use scenario. PW01 located in source Area 3, is no longer
used as. a drinking water source. The exposure and risk
calculations were made as a measure of the risks which would be
incurred if the well was used as a drinking water source. Risks to
a child resident due to ingestion of water from PWOl are presented
in Table 6-5. Noncancer health effects are possible based on a
measured HI of 1.12. None of the constituents which were detected
is a carcinogen; therefore I calculation of cancer risk due to
ingestion of water from PWOl is not necessary.
Risks to an adult resident due to ingestion of water from PWOl are
presented in Table 6-5. Noncancer health effects are not expected
based upon a measured HI of 0.27. Calculation of cancer risk is
not applicable.
Future Use
The future use scenario considers the possibility that water supply
wells may be installed in the contaminant plume. - Consumption of
water from the contaminated plume would result in an unacceptable
risk to human health and environment. The shallow (water table)
aquifer and the deep (Yorktown) aquifer are considered separately.
Contaminant Risk
The quantified carcinogenic risk and non-carcinogenic hazard
indices for each aquifer is given in Table 6-6 and Table 6-7.
E. Environmental Assessment
Contact wi th or ing$stion of cont81l\inated surface waters are
possible exposure routes at this site. . The elevated chemical
levels in surface waters indicate that these chemicals may have a
potential ~pact upon terrestrial and aquatic organisms.
6-7
-------
,r
Table 6-5 .
Summary of Cancer and Noncancer Risks by Exposure Route
Current Use Scenario - Private Well
FCX Washington Site
Washington, North Carolina
Exposure Child Resident Adult Resident
Route Cancer HI Cancer HI
Ingestion (water) NA 1.12 ' NA 0.27
Total NA 1.12 NA 0.27
HI Hazard Index (noncancer risk)
..
6-8
-
-------
Table 6-6
Summary of Cancer and Noncancer Risks by Exposure Route
Future Use Scenario - ShaUow Aquifer
FCX Washington Site
Washington. North Carolina
Exposure
RoUte
Chid Resident
Cancer HI
Total
3.3E-03
406.65
Adutt ReSlcent Adult Worker
Cancer HI Cancer HI
3.35-03 57.40 9.8E-CM 20.50
4.5E-04 33.33 2.7E-Q4 23.10
3.aE-03 90.73 1.3E-03 44.30
Ingestion (water)
Inhalabon (VOlatiles)
2.9E-03
4.2E-Q4
251.13
, S5.S2
HI Hazard Index (non cancer risk)
r
6-9
-------
Table 6-7
Summary of Cancer and Noncancer Risks by Exposure Route
Future Use Scenano - Deep Aquifer
FCX Washington Site
Washington. North Carolina
Exposure
;;oUte
Adult Worxer
Cancer HI
Chil~ Resident
Cancer HI
Adutt Resicient
. . Cancer HI
Ingestion (wate~
Inhalation (voiltiJes)
'I2.~
0.;4
Total
5.1E-04
4.5=-05
1 51.42
6.16
5.8E-04
4.8:-05
34.61
1.32
1.7:-04
2.9:-05
2.0:-04
13.30
5.6:-04
~ 51.55
6.3:-04
35.93
HI Hazara in::iex (nonc:ancer risk)
6-10
-------
88ca:I:d or D8ciaioD
~ -_..,,~ ~~ter ~ Ut8
J- 1993
Sec:ticm 6
The results of the ecological sampling in the adjacent wetlands are
discussed in the RI report. Dry conditions at the time of the
sampling limited the scope of the investigation. Based only on one
site sample compared to a background sample, a small Lmpact on the
benthic community in the study area was identified. Fish tissue
analyses indicate that higher. levels of DDD, DDE, and DDT are
present in fish collected from the study site. All of the observed
tissue concentrations ( 0 . 38-0. 48 mg /kg) . are well below the FDA
Action Levels for DDT in fish of 5.0 mg/kg (USEPA, 1980a).
Although species diversity and equitability measurements of the
macroinvertebra~e communities at stream stations downgradient of
the site are generally less than those of the control stream
stations, both benthic communi ties appear to be heal thy in terms of
diversity and indicative of good water quality.
F. Conclusions
Actual or threatened releases of hazardous substances from this
Site if no~ addressed by implementing the response action selected
in this ROD, may present an ~inent and substantial endangerment
to public health, welfare, or the environment.
6-11
-------
Ja8caEd ar -.,,-
ft:![ ~ ~ fig
~ 1993
88cUaI 7
VII. APPLICABLE OR RBLEVAIr.r AND APPROPRIATE REOUIREKEB'.rS (ARARs)
Section 121(d) of CERCLA, as amended by SARA, requires that
remedial actions comply with requirements or standards set forth
under Federal and State environmental laws. The requirements that
must be complied with are those that are applicable or relevant and
appropriate to the (1) potential remedial actions, (2) location,
and (3) media-specific chemicals at the Site.
Applicable requirements are those requirements specific to the
hazardous substance, location, and/or contemplated remedial action,
that are, or will be, related to the Site. These requirements
would have to be met under any circumstance. Relevant and
appropriate requirements are those requirements that address
problems or situations sufficiently similar to those encountered at
the Site, so that their use is well suited to the Site, but for
which the jurisdictional prerequisites have not been met.
This Section examines the cleanup criteria associated with the
contaminants found and the environmental media contaminated.
A. .Action-Soecific ARARs
Action-specific ARABs are technology-based, establishing
performance, design, or other similar action-specific controls or
regulations on activities related to the management of hazardous
substances or pollutants. Potential action-specific ARARs are
presented in Table 7 -1.
B. Location-aoecific ARARs
Location-specific ARABs are design requirements or activity
restrictions based on the qeographical or physical positions of the
Site and its surroundinq area. Potential location-specific ~
are presented in Table 7-2.
Federal classification quidelines for groundwater are as follows:
*Class
I:
Groundwater that is irreplaceable with no
alternative source or is ecologically vital;
A - Groundwater currently used for drinking
water;
*Class II:
7-1
-------
~ a~ _.4-
FCIt "'''4~ ~.81'C8
ohM 1993
88I:U.ca 7
B - Groundwater potentially
drinking water;
available
for
*Class III:
Groundwater not considered Class IIA. State
classification guidelines are based on best
usage (NCAC 2L.0201). Under the State system
the aquifer is considered Class GA
groundwater, existing or potential source of
drinking water supply for humans under the
state system.
C. Chemical-Specific ARARs
Chemical-specific ARABs include 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. Potential chemical-specific ARARs
are listed in 'l'able 7 - 3.
. . ......
7-2
-------
7-1
POTENTIAL ACTION-SPECIFIC ABARe
FCX WASHINGTON SITE
WASHINGTON, NORTH CAROLINA
Standard, Requirelllent, Citation De.odptloa APtliCD1. or
Crlterie, or £11111 taUoa Ral.vaa 'Appropriate
,
PBDBRAL
~ Di.charae to Burface
a er P
Clean Water Act 33 USC 1351-1316
Requlrel uae of Belt Avai1abl. .0 CrR 122 Ua. of beat aval1abl. technol~ Relevent and Approprlat.
Treatment Technology (BA~) economically achievable la raqu racS to
oontrol dlacharg. of toxic pollutanta to
PO'l'W
National Pollutant Dlacharge .0 CrR 122 Uae of beet available technolDgJ Applicable
Bll1111natlon Systelll Perllllt (Subpart C) .conolllloally achievabl. ia requrlacS to
Re\Julatione control dllhoarge or toxic pollutanta
diaaharged to aurraee vatera
Diecharge lIIuat be consiatent wltb .0 erR 122 Diaaharge IIIU.t cOlllply vith BPA-approved Relevaat aad Appropriate
the requirelllenta of e Weter Water Quality Managemant Plan
Quality "ana\Jelllent Plan approved
by BPA
STATB
North Carolina Groundwater NCAC 15A-2L Groundwater luallty .tanoarO., regulate. ApplicD1.
Standarda InjecUon w. 18
Weatawater Dlachar\Je to Surface NCAC 151-28 Regulat.a aurfae. wat.r dlacbarg. ApplicDl.
Watera
North Caroline Air Pollution NCAC 15A-2D Air pollution control air quality and ApplieDI.
Control Requirelllinta BIIIlaaloaa ataadarda
. f
('I')
I
.....
-------
TABLE 7-3
POTENTIAL CHMEICAL-SPECIFIC ARARs
J<'('X WASHINGTON SITE
WASH] ;G'l'ON, NOR,)~H CJ\ROJJINA
'::"'';:,=='~""= -~-=-.....- --.--. -.
Al>pUclible or ,
Rolevant , CODU11ent
--.-- Appropriate.
-bdsed Relevant and The MCL. for organio and
Ic water Appropriate inorganic contaminant.
ontaminant ar. relevant and
appropriate for
groundwat.er at the sit.e
since it i. a potential
drinkng water .ourc.
dopled for Relevant and
human Appropriate
an
Hity and
11 shed Relevant and
t Level Appropriate
e :
ndllrds are
it.eria.
s for the
ply.
e-baaed Not an MAR The secondary HCLs for
ic water inorganic contalliDJJIllta in
maximum groundwater are "t.o be
s) considered" guideline.
ng \/ater Relevant and
at level. Proposed HCLGs for
icipiltecl Appropdllte organic and inorganio
octs contaminants are relov~nt
and appropriate for
groundwater at lhe sit.e
since it Is a pot.ential
drinking water source
--
Sllon,l.lItI, 11"'1"11 ","",nta,
Crjl~rja, or tlmltlltl~ns
~:;'::-':'"':;.: .-:'':'''''':'':''::.-:';:;.;...-~-''.::'::'.;:; .~: :.:: ;..:: .: ~.-.:-=-==::.:~;.::,,;:--.."-'...:.'..'":!.':':''';'''.~:-::::::---;O~::':'-:='::::","~-:-:::':':':.:'':"''~
---------4'>- .--.----..
I'IIDHRAL
Saf. Drinking Wator Act
National Primary Drjnkng Water
Standards
Safe Drinking Water Act
Primary Maximum Contaminant
Leve1a
Maximum Contam.tnant Level Goals
National Secondary Drinking
Water Stand8J:ds
Mllx.lmnm Contaminant J,uYlJl
00a1s (HCLGs)
Cdltiela
Dnucript.:lon
-----..-
40 USC 300 et. sP.q.
---'-'--'--- ----.---.
40 eFR 142
50 FR 46936
(Nuv01l!bar 13, 1985)
Pub1IcatiQns r.. N2 99-
399, 100
Stat. 642 (1986)
Establishes health
standards for publ
systems (maxImum c
levels)
Primary HCLs are a
the protection of
health but include
analysis of fea8Ib
cost of attainment
EPA has also estab
MaxImum contaminan
Goals (HCLGs). Th
nonenforceable sta
b~sed on health or
The MCLGs are goal
nalion's water sup
Establishes welfar
standards for publ
systems (SecOndarr
contamInated luve
RstablJshes'drJnk1
quality goals set
of 110 known or ant
adv~~6e health eff
-~---- .__4_.____.-"" '-
. -.- --- '.--'--" .__...-.~--_.._..._- --- ----....--
40 CFR 141
42 USC 300
40 C.'R 142
40 eFR J43
..;t"
I.
.....
-'''-
-------
TABLE 7-3
(continued)
I
I(Pl1Cable or c_n~
DeacdpUoD eleva~ .
8~andard, Requiremen~a, CUaUon Appropde"
Criteria, Dr Limitationa
Surface Watel:
Clean Water Act 33 USC 1351-1376
Water Quality Criteria 40 crR 131 Seta criteria for water quality aalevant and Criteria available for
baaad on toxicity to aquatic Appropriata water' fiah ingeaticn,
organiama and human healtb end fi.b conawaCtion
6!!: for huun heelt
CI.an Air Aot 40 USC 1857
National Primary , 40 CrR 50 Set. primary and ..condary air lie levant and Will be relevant and
Secondary Ambient Air atandard. at lavela to protect "ppropda~. appropriate if oD-s1te
Quality Standarde public bealtb and welfare treat88nt unit. are
part of remedial action
National Emmi.aiona 40 CFR &1 Providea 881aa10D atendarda for Relevant and Will be relevant and
Standard. for Razardoua hazardoua air pollu"nta for wbich Appropdate appropriate If on-aite
Air Pollutant. no ambient air Quality atandard treat88nt unit. are
..iata part at r8ll8dial act\OD
Si'ATB
North Carolina 801id , 1301 NCAC
Sazardou. Waate
Management Act
North Carolina Drinking 15A RCAC Chapter 2L Batabliabaa groundwater Relevant and The guideline. for
Water' Groundwater olaaaification and vater quality Appropriate allovable level. of
Standard. .tandard. toxio organio and
. inorganio oontaadnant.
are relevat and
appropriate for
groundwater et the .ite
.inc. it i. potential
driDkiag water .ourc.
un'
I
....
. I
-------
Record ot Decision
FOt W_hiD~n Groundwa<;er Con~DAtion SlUt
June :!.993
Sec':.~c:: 8
VIII. REMEDIAL ACTION OBJECTIVES
A. Groundwater
Based on the results of the RI, the baseline risk assessment and
considering the requirements for risk reduction, risk-based
remediation levels, and the ARARs, the remedial action objectives
specifically developed for groundwater at the site are presented in
Tab1e 8-1. The objectives in establishing the remediation levels
were:
*
Prevent migration of contaminants to surface water that
would result in contamination to levels greater that the
Ambient Water Quality Criteria (AWQC).
*
Control future releases of contaminants to ensure
protection of human health and the environment (SARA
Section 121[d]).
*
permanently and significantly reduce mobility, toxicity,
or volume of characteristic hazardous waste with
treatment (SARA Section 121[d])
The final remediation levels, presented in Table 8-1, were selected
as the most conservative of the federal and state chemical-specific
ARARs, and if a standard did not exist, the risk-based goals.
However, the average background concentration was selected as the
remediation level if it exceeded the most conservative level.
B. Extent of Contamination Above Remediation Levels
The chemical groups found above the remediation levels in
groundwater are pesticides, volatile organics, semi-volatile
organics, and metals. The approximate locations of the contaminant
plumes for each of the chemical groups are shown in Figures 8-1, 8-
2, 8-3, and 8-4, respectively. The total extent of groundwater
contamination is a summation of the contaminant plumes for each of
the four chemical groups. The estimated volumes of groundwater
contamination above remediation levels for each contaminant group
are presented in ~able 8-2. The semi-volatile and volatile
organics contamination extends vertically through the upper 20 and
30 feet, respectively. Pesticides and metals contamination extends
through the upper 40 and 50 feet, respectively.
8-1
~. .
-------
TABLE
8-1
REMEDIAL ACTION OBJECTIVES FOR GROUNDWATER
FCX WASHINGTON SITE
WASHINGTON, NORTH CAROUNA
p~
Aldrin
Heptachlor
Heptachlor epoxide
Alpha-SHe
~-8HC
Gsmma-BHC
Dieldrin
4.4-00T
4.4-ODE
4.4-000
End"n
Toxaphene
Chlordane
0.01
0.078
0.D38
0.014
0.047
0.0265
0.02
0.02
0.Q2
0.Q2
0.20
1.0
0.027
Volatile Orosnic$
Chlorofonn
1,2-Dichloroethane
1.2-Dichbtopropane
Benzene
Toluene
Chiorobenzene
Total xylenes
t
!! Semi- VolatiltJ Of9Snics
I Bis(2-ethylhexyl)phthalate
Pemacnlorgphenol
Carbazole
0.1;
0.38
ooSe
1
1.000
100
400
4
1
4.3
MstaJs
Beryllium
Chromium
N iclcel
Lead
Mercury
[I Manganese
1
50
100
15
1.10
-o~
0_1
Contraet Required Q\8i AibatiJu Unit (1)
NO Groundwater Oualfty Stanc1ards (1SNCAC O2IJ
NO Groundwmer 0\aJity Standards (15NCAC O2U
Based on CSFValue ~pliad to RllsidentialLand Use Scenario
Based an CSFValue Applied to AesideMial Land U8e Scenario
NC Groundwater Quality Standards (15NOAC 021.) I
Contract ReQuired Qua(ditation Li'nit
Contract Aeauired Quaotitation U'nlt .
Contract Aeauired QU8(Ititation unit' , :1
, Contract ReQuired Quandtation unit '\
I' NC G/OundViater QuaUly Standards (1SNCAC 02W
Contract Required Quantitation Li'nit (2)
j NO Groundwater Quality -. (1SNCAC 02LJ I
NC Groundwater Quality Standardl (1SNCAC 02L.)
NO Groundwater Quality Standards (1SNCAC 02U
NO GroundwBtBrOuaJicy SIandarda (1SNCAC o~
NC Grounc:twar Quality Standards (1SNQAC C2t)
Maxinum Contlminlnt Lav8I
M8"inum CoI'It8mInant Level
;
: NC Groundwater ouartty Standards (15NOAC 02U
I . . 1\
I Muimum Contlminant Lev8I II
Maxinum ~ntaminant Level - iI
I Based on CSF Value Applied = Residential Und L's03 Scenario i
I
I Maximum Contaminai'lt Uwal
I NC Grcundwater Qualily Standards (1SNCAC 02W
I Maximum Contaminant Lsvel
I Treatment T~hnlaue Action Level
I NC Groundwater Quality Standards (15NCAC oz..;
: A_-erage Backgrc:.;:-.d Concentration
! (Greater ti'an 15NCAC ~L of SO UQ/O
I,
ii
"
(1) CoI'IIraCt Required QuantitIItion-Lmit exceeded the risk-b88ed concentration.
(2) Contract Required Quamira1iOn unit exceeded the NC Groundwater OualitY Slandard.
. When a '''required standard is set below what can be accurately obtained
in the laboratory. the contract quantitation limit is used.
8-2
-------
,::~
!
o
-"1-
1
~
..
200
SCAIL ;N Fffi
LEGEND
-x- ;-~C£
-. ii1E£UNE
- SURFACE iVA~~
e MONtOR WE\.!.
/"7'). SMU.OW PES:.QES
'<,g ::"'-AMlNATIC...
~ :~ PES"!IC:5
~ :::~TAUlNATIO~
CDII FPC ARCS IV ... . FIGURE NO.
APPROXIMATE AREAL EXTEIfT OF PESTICIDES CONTAMINATION
ABOVE REMEDIATION LEVELS IN GROUNDWATER . 8-i-
FCXWASHINGTONSITE. . . .
WASHINGTON, NOR1H CAROLINA
SL':\
-
'.
-
-.
~
.
..,
'.
:
-
-------
I
SCALE IN tW
~
-N-
~
2::1
o
200
IoIW3-SH
IoIW3-DP
LEGEND
-J(- FENCE
-.. TREEUNE
-- SURFACE WAT£i
8 WONTOR WElL
~ SItAWM VOt.A1U
~ ORCiWCS COXWlNo1lON
CDUFPC ARCS IV
APPROXIMATE AREAL EXTENT OF VOCs CONTAMINATION
ABOVE REMEDIATION LEVELS IN GROUNDWATER
FCX WASHINGTON Sm:-
WASfmfGTON, NOR1H CAROLINA
FIGURE NO.
8-2
.
~-, '
-------
~
-N-
I
J
:J
200
--.
'wW
S~ iN FE:
\IW.3-SH
IoCWJ-OP
LEGEND
-x- 8ICE
-. ~WJNE
- SURFACE WAT£R
e UONTOR lIEU.
~ S-'".ALLOW St\tI-IIOlATI,£
~ ~~...wc:s =~AUM1ION
CDII FPC ARCS IV
APPROXIMATE AREAL EXTENT OF SVOCs CONTAMINATION
ABOVE REMEDIATION LEVELS IN GROUNDWATER
FCX WASHINGTON SITE "
wASHINGTON, NORtH CAROLINA
. I
FIGURE NO.
, 8~3
"- -
-------
~=~
!
.
-N-
i
...
w
200
SCALE 1':1 FEET
LEGEND
-x- "!!iCE
...-.. ~EEUNE
-- SiJRFACE WA~
. WON1aR WELL
~ s;;AWIW uF:TA!.S
'=-' C:'OU'AUlNAno.~
~ 0$1 METAlS
~ :::..rAUINATICH
CDII FPC ARCS IV . .
APPROXIMATE AREAL EXTENT OF METALS CONTAMINATION
ABOVE REMEDIATION LEVELS IN GROUNDWATER"
FCX WASHINGTON SITE .
WASHINGTON, NOImI CAROUNA
FIGURE NO.
. 8-4
_.
.-----
.-
-------
TABLE
8-2
ESTIMATED VOLUMES OF GROUNDWATER ABOVE REMEDIATION LEVELS
FCX WASHINGTON SITE
WASHINGTON, NORm CAROLINA
",",.....,. ....... .," -
- -
Pesticides 147,215 0 - 20 809,683 6,056,429
9,984 20 - 40 54,912 4 10,742
Volatile Organics 66,201 0 - 30 546, 158 4,085,262
Semi-Volatile Organics 22,827 O . 20 125,549 939, 107
Metals 204,920 O . 20 1,127,060 8,430,409
8,786 20 . 50 72,485 542,188
7,806 20 - 40 42,933- 321,139
~
.
Average porosity of 0.275 was assumed when estim"ti1'lg volumes
'"
8-7
-------
JI8ICIIEd or __i-
~-_....~ fL.~ ~ aUe
~ 1993
a.cu.- 9
IX.
DBSCRIPl'IOR OF AL~:IVES
Table 9-1 snmmarizes the technologies considered for remediating
the groundwater contamination, at the FCX Washington Site. The
table also provides the rationale as to why certain technologies
were not retained for f~her consideration after the initial
screening.
A. Remedial Alternatives to Address Groundwater Cont:Amhlation
The following alternatives were developed to address groundwater
contamination at the Site:
Al ternati ve 1: No Action
Alternative 2: Limited Action
Deed recordation
Long-term groundwater monitoring
Alternative 3: Groundwater Extraction/Onsite Treatment
Discharge to Surface Water
The remedial response actions to address groundwater contamination
are discussed below.
Al'terDative 1:
80 .Action
This alternative provides the baseline case for comparing remedial
actions for groundwater and the level of improvement achieved. The
only actions included in this alternative are groundwater sampling
and analysis of the existing welle, and a data review every 5 years
for 30 years. All samples would be collected and analyzed for the
contaminants of concern.
There are no capital costs associated with this alternative.
Operating costs are based on the review of Site conditions every
five years. There would be no maintenance costs. .
Total Capital Costs
Present Worth 0 & H Costs
Total Present Worth Costs
$0
S142.635
$142,635
Al'terDative 2:
Limited Acti.on
9-1
-------
""uble 9-1
I':\' A 1.1 IA'I'ION 01" mUmNI)WA'f~III.ROCI~SS olt'nUNS
FCX WASIIINC;'I'ON snn
WASIIIN(,TON, NOIt1'1I CAIlOLINA
. ;,oundw.I.r Glnlr.1
~ I~'pon.. Actlonl
I No kllon
Rlmedlll T8Chnolog~
P,OCI.. Opllon
I Nolappicable
i --
landusere~lons
InsUlUlonal
I:Oflllols
Use reskldlonl
Monllortng
GrourKttYaler monUOfIng
Removal
~ ::::::::r:~~:~,:",::::t::::::M!.J!ifl::
H eXllaclionJ
Oo.&lIe Dhyslcall
chem~
C8lbon adso.pUon
I ,salmsnl
DIsposal .
(SBI",.tpag.)
i~~::::::~:::::::i:::::::::,!,Rji!:1~1{~~i~~jjii::
,
Ell8cllve and ,eUabIe lor 'ealmanl 01 pesllc:ldea.
DlsplsaI oIlIpInI carbon ..-
Nol as .Uecllve when ...lIuenl concenllallonl are ...
(RIb IInge)
E'JecUve and relable ~r volalile organk;&, Pr.~eaI'
menl may be rlCf*8d. '
E'Jecliv. and relable ~r volalile organics. Pr.keal.
menl may be recpred.
E.Jectlv. and reUabl8 when used In conjuncllon willi
IIocwlalonlsedknenlalian
Ellec:llv.lor some kIorganica
=:::.~.~~~~
Reliable InCIlf1ec1v8 gtlen prOpel apirallon and
melnlenano8
P:f)+:':~::::HI P,OQ/ss opllon ellmlnaled Irom
',','. '"',','.,,,',',',',' further consIdefaUon
ImplamtnllbUl1V
Redr lmpIemenllllll
RIIIII1 ""lellllnlablt. .......
men.. and auIhorly ..8dad.
R..., knpIemllllabll
RtadIIv knpIemenlabll
ReacIIr ~enlabll
Readir ",-"en1ab18
ReadIJ knpI8mtnIabI8
I,. .. ,I" i :. .'
Rtdr ............
I I ~'I ,. , " .
, ..
R..., ....,..........
I ,
COil
None
Low c:apIIaI, law O&M
Low c:apIIaI,low O&M
HIgh CIpIIaI. low OIM
Low C8flllallI1d 0&"
N
I
Q\
EII.cllvln...
I Does not adJl8V1.emedIaI.J:aon ClbJedlveI
Would be errec:llve In COIfIndIon with other rem8Clal
18c:tInologln, EIIecllvIR8ll cIepend8 on .........-
lion In ... tllure
Would be eUeelveln Iradllng conlamlnanl mlgrBllon Reaclly lmpIemenlabll
and'CllelecUv8f1818 oI.tm8dlal1dlon1
Less "Mable and eleeYvelwn muilimeda Gap is III Requkea 11m. 10 ImpIemtnL Equpn.nII Low AfIIaI,
Impenneable lay.., ptIICIIIIIUIIrvlGll ...., IV""'. mad8rIII O&N
R... ,,8IIIc*In1 on ......Iand use
endlong-l8nn malnlenance
Mosl reliable and electlv. as 80 ~8fmeable tay. Requkeallm.1o Implem.nt ECfllpmenli HIgh r:aplIaI,
perIOIVIeUservlceI rellllW available. moderall aIM
RlCfltes reslrldOOI on ......Iand use
lAd Iong-tenn malnl8RIIRCI
Mar be drrlwll to Inslal
E'Jec:lJveln cxmlalnlng GOntamlnanl pkune, Mull III
Inslaled ... con)tn:1on d CCf 10 prlVena mo&IIdng
J ReUabIe and .Uecllve 'or GOnlalnmeni 01 gJo&nt.val. Readly lmpIemenlabll allhaugh b8sI
bUI mar noI achJev..emedal action objedJv8s IocaIIon lor ulrlClon will need 8D be
pntdelemlNd .
Redy lmfIIemenlabll
HIgh capIIaI and 0&'"
HIgh c:apllal and OIM
ModeI8te r:aplial.
low O&M
HIgh caplal.
rnod8fII8 O&M
low c:apItaI.
, moderIfI O&M
HlghapllllROIM
. I
HIgh apIIaI and 0...
I,', il" '
V.., hIF capI8aI
-------
liroundw".r O.n.,.'
""pon.. Aedon.
R.medlll Tec:hnolo9r
PIOC... Option
low C8fIIIaI and OIM
IlJlsposal
Ohlle
;ii~t ;";'.'; ;':iij~~~i~i~t~~jM~~[t:[!~:~ifi\]i~;~:
.
Tllille 9-t(nm.illued)
~ P,ocell oplion ellmktated
~ "am"""" GOfIIIde,1IIoA
EU.cUv.n...
lmpIt...nllbllllJ
Not Ideal for IocqIIaIn .... Reliable and
elleclN.lnhlgher Il8llbu'lImIedlplClla
."aMabIe. WocAd need IItCOItI8ntktaIed 118110
Sflrar over.
Reliable and elI8liUv'IINIfI proper ope,atlon and
maintenance
Rl8lllylmplem8nl8lll8
local POTW does nul have d&dtarge
cdI8rIa .. peltill8. WI nal8GC1p8
pr8lr8l11d .fllulnl.
PI8'.Un8n1 ,.111 10 mill' NPDES
dlscltarge ImiI8. Recpli NPDES
ptrmll
Reliable and eaeclN.
COl'
HIgh GIpIIIIIRd OIM
"odera~ c:apa.I.
law O&M .
M
I
0\
-------
IIIIcard o~ -1-1011
Pa __M~ G:..O~t:er COII1:a81DatJ.aa 81te
JaDe 1993
sec:uOD 9
described above except that it includes implementation of
institutional controls. The Agency will request that the State
implement deed recordation to control, limit, and monitor
activities onsite.
Total Capital Costs
Present Worth 0 & M Costs
Total Present Worth Costs
$0
$142,635
$142,635
Groundwater Pumping/Onsite Treatment/
Discharge to Surface Water
This alternative includes extraction of the contaminated
groundwater, VOC removal using air stripping, metals removal using
precipitation and ion exchange, carbon adsorption for the removal
of organics, and discharge of the treated effluent to surface
water.
Alternative 3:
Groundwater
required to
adjustments
30 years is
monitoring on at least an annual basis would be
evaluate remediation as it progresses so that timely
can be made, if determined appropriate. A period of
assumed for complete remediation.
If an offsite discharge option is selected the treated effluent
would meet the surface water discharge criteria of the NPDES permit
that would be obtained during the remedial design phase. The
groundwater system will be designed to operate 24 hours per day.
System controls would allow for complete automatic operation with
minimal operator attention. Alarms and switches would be furnished
for fail-safe operation.
For costing purposes, it is assumed that all treatment equip~ent
would be leased. To the extent possible, major equipment would be
furnished skid-mounted and complete with all piping and controls
mounted on structural steel support skids. Also assumed for
costing purposes, that air quality control equipment will be needed
to capture volatile organics released from the air stripper and
that the sludge produced from the metals precipitation process and
spent carbon would be disposed of at a RCRA approved hazardous
waste landfill facility.
Total Capital Costs
Present Worth 0 & K Costs
Total Present Worth Costs
$ 3,367,813
$ 9.115.079
$12,482,892
9-4
I
.
-------
Record at D8c:181cm
PCX W~ QroUDdwatar c:cm~UOI1 SUe
x.
JIIJUt 1993
S8CUcm 10
SUXllARY OP COXPARATIVE ARALYSIS OP ALTERRATIVES
The remedial alternatives to address groundwater. contamination were
evaluated using the nine evaluation criteria as set forth in the
~CP, 40 CFR 5300.430(e)(9). A brief description of each of the
nine evaluation criteria is provided below.
THRESHOLD CRITERIA
2.
1.
Overall Protection of Human Health and the Environment
addresses how an alternative as a whole will protect
human health and the environment. This includes an
assessment of how the public health and the environmental
risks are properly eliminated, reduced, or controlled
through treatment, engineering controls, or controls
placed on the property to restrict access and (future)
development. Deed restrictions are examples of controls
to restrict development.
Camoliance with ADD1icable or Relevant and ADDroDriate
Reauirements (ARARs) addresses whether or not a remedy
complies with all state and federal environmental and
public health laws and requirements that apply or are
relevant and appropriate to the conditions and cleanup
options at a specific site. If an ARAR cannot be met,
the analysis of the alternative must prov~de the grounds
for invoking a statutory waiver.
3.
PlUDRY BALUCIBG CRIBRIA
4.
Lena-term Effectiveness and Permanence refers to the
ability of an alternative to maintain reliable protection
of human health and the environment over time once the
cleanup levels have been met.
Reduction of Toxicitv. Hobility. and Volume are the three
principal measures of the overall performance of an
alternative... The 1986 amendments to the Superfund
statute emphasize that, whenever possible, EPA should
select a remedy that uses a treatment process to
permanently reduce the level of toxicity of contaminants
10-1
-------
R8c0rd ot Dec1don
PCX W~ Qzo1mdwa~ Contall1Da~1on Site
5.
Jane 1993
~1OD 10
at the site~ the spread of contaminants away from the
source of contaminants ~ and the volume, or amount, of
contamination at the Site.
Short-term Effectiveness refers to the likelihood of
adverse ~pacts on human health or the environment that
may be posed during the construction and ~plementation
of an alternative until cleanup levels are achieved.
6.
Implementabilitv refers to the technical and
administrative feasibility of an alternative, including
the availability of materials and services needed to
implement the alternative.
Cost includes the capital (up-front) cost of implementing
an alternative, as well as the cost of operating and
maintaining the alternative over the. long-term, and the
net present worth of both the capital and operation and
maintenance costs.
7.
IIODIFYING CRITERIA
9.
8.
State Acceptance addresses whether, based on its review
of the RIfFS and Proposed Plan, the State concurs with,
opposes, or has no comments on the alternative EPA is
proposing as the remedy for the Site.
Community AcceDtance addresses whether the public concurs
with EPA's proposed plan. Community acceptance of this
proposed plan will be evaluated based on comments
received at the public meetings and during the public
comment period. . _.. - ..... . -. -- -
.These evaluation criteria relate directly to r~quirements in
Section 121 of CERCLA, 42 USC Section 9621, which determine the
overall feasibility and acceptability of the remedy. Threshold
criteria must be satisfied i.n order for a remedy to be eligible for
selection. Primary balancing criteria are used to weigh major
trade-offs between remedies. State and community acceptance are
modifying criteria formally taken into account after public comment
is received on the proposed plan. Table 10-1 provides a Sl1mm~ry of
all the alternati.ves. The evaluation of the potential remedial
alternatives to address groundwater were developed as follows.
10-2
-------
TABLE 10-1
DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES
FCX WASHINTON SITE
WASHINGTON, NORTH CAROLINA
COst Alternative Description of Process Options Employed
.
$142,635 1GW No Action
$142,635 2GW Limited Action
Deed restrictions
Long-term qroundwater monitoring
$12,482,892 I 3GW Pump all contaminated qrounwater by 17
well points
Air stripping
precipitation, flocculation,
clarification, and filtration
Ion exchange
carbon adsorption
Di8charge of treated groundwater to
Kennedy's Creek
Deecl restriction
Long-term groundwater monitoring
10-3
-
-------
lt8eord of Dec18ion
POt Waah1IIgUm CiIrOWIdWater CODtII81DaUon au.
JaDe 1993
S8Ct1OD 10
A.
Groundwater Remediation
The following alternatives were subjected to detailed analysis for
groundwater remediation:
Alternative 1:
No. Action
Al ternati ve 2:
Limited Action
Alternative 3:
Groundwater Pumping/Onsite Treatment
Discharge to Surface Water
Overall Protection of Human Health and the Environment.
Each alternative was evaluated to determine whether it is likely to
effectively mitigate and minimize the long-ter.m risk of har.m to
public health and the environment currently presented at the Site.
Alternative 1 does not eliminate any exposure pathways or reduce
the level of risk. Alternative 2 eliminates some exposure
pathways, with a reduction in the potential risk of groundwater
ingestion and inhalation. The exposure pathways associated with
continued contaminant migration in groundwater and through surface
water discharge would not be eliminated. Alternative 3 eliminates
exposure pathways and it is expected that any potential risk of
ingestion or inhalation would also be greatly reduced as long as
the system is in operation.
ConiriliiuiceWi th -.ARA1iS- -..-. -. -.. --
The no action and the limited action alternatives would not comply
with ARARs. Alternative 3 would attain ARARs at the entire Site.
~ah1es 7-1 tbru 7-3 identifies the regulations pertaining to these
alternatives.
- - . - - ..-
Long-ter.m Effectiveness and Permanence
In Alternatives 1 and 2, contaminant migration through groundwater
and surface water discharge would continue. In Alternative 3,
there would be a ma,rimUJD reduction in pathway exposure risk, and
furthet migration would be eliminated.
10-4
-------
R8CCrd or Decia1an
Fa W&81L1..Dg1:oD GlJ:OUII4va~ COAU81.DaUOD 811:8
JDJle 1993
sec:uOD 10
Reduction of Toxicity. Mobilitv. and Volume
Alternatives 1 and 2 would not reduce the toxicity, mobility, or
volume (T/M/V) of the contami.nants. Alternative 3 provides the
maximum reduction of T IM/v .
Short-term Effectiveness
All of the alternatives can be implemented without significant
risks to the community or on-site workers and without adverse
environmental impacts.
ImDlementability
Alternative 2, requiring deed restrictions presents no
implementability problems. Alternative 3 would require a NPDES
permit if the treated effluent is discharged to KenndyCreek.
If Mount Pleasant Canal is selected for discharge, substantive
compliance will be adequate. .
Cost
Total present worth costs for the groundwater alternatives are
presented in Table 10-1.
. - .. - . ...
10-5
-------
Record of nec~9io~
FCX was!1~~~oc G=ol::c...a~= Con~Con Si1:e
:~ne 1993
Se=~:!.or. ~:
XI.
THE SELEC'l'ED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP,
the detailed analysis of the alternatives and public and sta";e
conunents, ~:?A has selected Alternative 3, groundwater pump and
treat, as the remedy for this Site. At the completion 0= t~is
remedy, the risk associated with this Site has been calculated ~o
be within the accepted risk range determined to be protective of
human health ar.d the environment. The total present worth 0= the
selected remedy is $12,482,892.00. See Tables ll~l for the
detailec cost estLmate.
A.
Groundwater Remediation
Groundwater
cont~~'lated
contaminated
water.
r~~ediation will involve the extraction of the
groundwater at the Site via extraction wells. The
groundwater will be treated and discharged to surface
The treatment will consist of air stripping to remove volatile
organics, precipitation and ion exchange for the removal of metals,
and carbon adsorption to remove organics.
The groundwater system will operate 24 hours per day. System
controls will allow complete automatic operation wi th minimal
operator attention. Long-term monitoring for cleanup verification
purposes and to track contaminant plume migration will be required.
The system is expected to operate 30 years; samples will be
collected from existing wells on a quarterly basis for the first 5
years, a.~d on an annual basis for the following 25 years.
The qroundwater treatment system will also require monitoring and
maintenance. Monitoring of the treatment system will include
periodic sampling of the influent and effluent from the treatment
system and a.~alysis in accordance with the per.mit requirements.
Al though dioxin contamination is not expected, the groundwater will
be sampled for dioxin during Remedial Design stage. If dioxin is
found the selected remedy will be modified to address any dioxin
problem.
11-1
-------
.
Table 11-1
-
li_ii~~~!~liBl~h~':.'
.-
."'..
m:u DESCRIPn:IN
~WA'TER:
'"
UI"IIIIIq,t.:11ON
T.....-rt ~w--.nt&SId
T8IIIpInty FaciIiIi8a
GROUNDWA'TER EXT1W:'nON
SiI8 fIr..-....
w.IIlnI8II8ian
SubnwaiDIe ,.."...
Pip8a. VaIw8. 6 FiIiftva
WA'TER TREATMENT' FACILtrV
Sa. fir.,.,....
~
Tr.--. Fac:iIity
Lighting 6 HVN: Spt8m8
WA'TER TREATMENT' PROCESS UNITS
E...... Tank
Ion b:n8nge Unit
Ch8Inic:8J ........... Fac.
..... ........ FaciIiIi88
Ail S..... Una
Car... Ac8m ..... Una
E~1nItaI8tion
TruW8r ,.."...
ConhtP8Ml&"~ r 'I
Piping. V--&~-
FiII8r .....
TREATED WATER DISCHMGE TO SURFACE WA1B
PUIft8II CIn*II8cO
Pipe. Yalw8. &......
MISCS.I.ANEaUS EQWIIENT & SUPPUES
& HEALtH NI/J SAFE1YEaUPIIENT
Sub8a8f - CuiI8I Colt
~ Fee"ftfllCu8llCa8t'
L8CIIt r... Lia8I88 &....... ('" rI CuiI8I Colt t
&M.&_~;" '1"'rlCui8lCa8t'
,....,
,
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Record of Dec~B~on
Fa W"I1::.n~:::: :J:o=c!vat.e: Cont.alllinatioll S1us
':une :!.993
Se:-:io:: ::
B.
Extraction and Perfo~ce Standards
Location of extraction wells a~~ pumping rates will be determined
during the re~ed~al design.
Final discharqe will be to surface water. Discharge ste.~c.ards will
meet the requirements of the NPDES per.mit, which will be defined
during the ~eve:opment of the Remedial Design.
Groundwater shall be treated until the Remediat::..on Ob-iect::..ves
listed in Table g-1 are attained throughout the contaminant plume.
The goal of this remedial action is to restore the groundwater to
its beneficial us~, as defined in Section 6.0. Based on
information obtained during the RI, and the analysis of all
remedial alternatives, EPA and t~e State of North Carolina believe
that the selected remedy may be able to achieve this goal.
Groundwater contamination may be especially persistent in the
immediate v::..cinity of the contaminants' source, where
concentrat::..ons are relatively high. The ability to achieve
remediat:.on levels at all points throuqhout the area of attainment,
or plume, cannot be determined until the extraction system has be~n
~plemented, modified, as necessary, and plume response monitored
over time.
If the selected remedy cannot meet the specified perfoxmance
stand~ds, at ~~y or all of the monitoring points ~~rinq
~plementation, the contingency measures and goals described in
this sect::..on may replace the selected remedy and goals for these
portions of the plume. Such contingency measures will, at a
minimum, prevent further migration of the plume- and include a
combination of containment technologies and institutional controls.
These measures are considered to be protective of human health and
the enviroIment, and are technically practicable under the
corresponding circumstances.
The selected remedy will include groundwater extraction for an
estimated period of 30 years, during which t~e the system's
performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected durinq
operation. I!odifications may include any or all of the following:
a)
at individual wells where remediation levels have been
attained, pumping may be discontinued;
al ternating pumping at wells to eliminate stagnation
b)
11-3
-------
Record of :>ecision
FCX WA.~~~n G=~~cwAter Cc:taminAt~cn Site
c)
d)
June ~993
Sec-:~o::. ::.
points;
pulse pumping to
encourage adsorbed
c;ro~:ldwater;
allow aquifer
contaminants
equilibration
to partition
and
into
installation of additional extraction wells to facilitate
or accelerate cleanup of the contaminant plume.
To ensure that cleanup continues to be maintained, the aquifer will
be moni tored at those wells where pumping has ceased on an
occurrence of at least every 2 years following discontinuation of
groundwater extraction.
If it is determined, on the basis of the preceding criteria and the
system perfc=ma:lce data, that certain portions of the aqui=er
cannot be restored to their beneficial use, all of the following
measures invo:vi:lg long-ter.m manageme~t may occur, for an
indefinite period of time, as a modification of the ex~sting
system: .
periodic reevaluation of
groundwater restoration.
The decision to invoke any or all of these measures may be made
during a periodic review of the remedial action, which will occur
at 5 year intervals in accordance w::'th CERCLA Section 121(c).
a)
b)
c)
d)
e'
,
engineering controls such as physical barriers, or long-
term gradient control provided by low level pumping, as
contaminant measure;
chemical-specific ARAF.s
tl10se portions of t~e
~practicability of
red'.lction;
may be waived for the cleanup of
aquifer based on the techr..ical
achieving further contaminant
insti tutional controls may be provided/maintained to
restrict access to t~ose portions of the aquifer which
r~~~in above remediation levels;
continued monitoring of specified wells; and
remedial
technologies
for
The remedial actions shall comply with all ARARs (See Sections
VII) .
11-4
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RESPOIISJ.VMOSSS ~y
PO WASBIHG'l'OR GROtD1DWATER CONTAlaRA'l'J:OR SIft
WASHDlG'l'OR, HaRm CAROLIBA
Responsiveness Summary OVerview
The Responsiveness Snmmary is the official record of how the Agency
responded to public CODDDents as a part of the decision making
process. The responsiveness snmmary also provides the decision
makers of the lead Agency with the public's views, so that they are
considered in the final decision.
This document is segregated into three components ~ summary of the
cODDDuni ty' s involvement, the Agency's response to CODDDents received
at the proposed plan public meeting and the Agency's response to
written comments received from concern parties during the p~ocess.
Backaround of CODDDunitv Involvement and Concerns
-.
The public concerns regarding this Site have been minimal. This is
probably the result of the Agency's rather extensive cODDDunity
relations efforts, and the fact that the removal action conducted
at the Site removed the primary threat.
Two public meetings were held. The first meeting on October 3,
1991 was the introduction of the Superfund process, and the second
meeting was the proposed plan meeting on May 4, 1993. Several fact
sheets were prepared and distributed through out the process. The
Remedial Investigation (RI) and Feasibility Study (FS) reports
along with the Proposed Plan were released to the public in April
1993. All of these documents as well as the Administrative Record
were made available to the public via the Brown Library, in
Washington, North Carolina. Announcements of each meeting were
advertised in the local newspaper and press releases prepared.
.
Public Meetina Comments
'.rhese are the community concerns that were expressed as a result of
the May 4, 1993 proposed plan public meeting are as follows:
Comments: A gentleman inquired if the FCX declared bankruptcy
in anticipation of the huge cleanup cost associated with the
Site.
Response: We really don't know the reason bankruptcy was
declared. We were made aware of the proceedings at the latter
stage of the process and were able to retain 2.5 million
-------
dollars of their assets, for
Statesville and Washington Sites.
the
cleanup
at
the
FCX
Comments:
What is the total cost of the projected cleanup?
Response: The approximate cost including previously incurred
cost is about $19,000,000.00
Comments: How far has the contamination migrated? and how
many wells are there at the Site to show movement of the
plume?
Response: EPA installed eighteen wells that look at the
surfical and the Yorktown aquifers. The contamination is
still wi.thin the boundary of the Site.
Comments:
What would the future deed'restrictions entail?
Response: The restriction would seek to restrict 'the use of
the groundwater until it was restored to useable condition.
The removal and treatment of the contaminated soil will
restore the soils so that the property can have unrestricted
use.
COJIDDents: Is it safe to eat at Charlie Toms Restaurant given
it's close proximity to the Site?
Response: The pesticides are not especially' -volatile and
require that they be airborne via blowing dust to cause a
problem. However, the cleanup standards selected will render
the Site safe for public use even in the event of airborne
dust. The results of sampling' conducted in the interior of
Charlie Toms Restaurant were within EPA' s acceptable risk
range'~-"'- . .. -- ""." . - - . _. ... .H .
CODDDents: Will the treated groundwater have to- meet a minimum
co~taminant level before it can be discharged.
Response:
Yes.
Comments: When will the groundwater remediation action begin,
and how long will it take?
Response: It will probably be a year to a year and a half
before the remedial action begins, and take anywhere from 15-
30 years to complete.
Comments: Does ,~he Agency anticipate any movement of the
contaminated groundwater in that time?
Response: We anticipate some movement, but the extent of
contamination will be re-evaluated to compensate for any such
movement at the time of remedial action.
-------
Comments: Is there an estimate of the amount of the discharge
for the NPDES permit?
Response:
gallons.
Comments: Thirty three million dollars is a lot of money to
spend on this one small Site. Couldn't the contaminated soil
be diluted by spreading the soil on other farms where people
would be willing to accept the soil, or could these soils be
repackaged with other pesticides? There are probably
unacceptable levels of pesticides on fcu:ms allover the
Washington area.
We estimate it to be approximately 20 million
Response: One major problem with that idea is DDT, DDE and
Lindane are banned pesticides, and legally these things cannot
be done.
Comments:
Aquifer?
Has the. contamination reached the Castle Hayne
Response: The Remedial Investigation did not address the
Castle Haynes. We don't believe the Castle Hayne has been
affected.
Comments: Your slides didn't qive the overall volume of soil
present at the site.
Response: We surveyed the stockpile and counted the bags and
estimated we have 14,700 cubic yards of contaminated soil,
give or take five to ten percent. .
Comments: Who monitors the contractor and evaluates his-.
performance?
Re~ponse:
The on-scene coordinator will perfo~ that duty.
Comments: What will be the limitation on the soils beinq used
for fill material after remediation?
Response: Because of perception the soil won't be sold by the
truckload at the Site. But it will probably be made available
for the city's public works department.
Comments: Given the fact that farmers apply these pesticides
year after year because they lose their strength. How long
would we have to wait for this stuff to become harmless if we
did nothinq? .'
Response: The half-life for chlordane pesticides is eighteen
years, and that half-life depends on several variables such 8S
the presence of oxygen, etc. That does not mean the Site will
be safe enough for people to be in direct contact with the
-------
-.. - ----'-----"--
contaminated soil.
Comments: We were discussing the movement of the groundwater
and you assured us that contamination had not migrated very
far. The Latham residence is very close, how is it impacted?
Response: The groundwater is flowing away from the Latham
residence, however, their well was primarily contaminated with
metals and only one of the seventeen pesticides present on
Si te. The probable source is from the over land flow from the
warehouse along the drainage ditch.
Comments:
What if it doesn't work.
Response: It depends on why it doesn't work, but we would re
bid the job if there is a problem with the unit or the vendor.
If the technology is not adequate another public meeting will
be held and another alternative selected.
Written COIIIIIIents Received Durina the Public COIIIIIIent Period
Comments: There was one letter submitted in response to the
Proposed Plan Public Meeting. Serious concern was expressed
over the amount of money to be spent at this Site, and that
fifteen to twenty million dollars is too much money to spend
to improve one person's risk of developing cancer. The letter
expressed an overall disagreement with the risk assessment
process, and how overall risk is dete%Dli.ned. The author
believes that Alternative 2, limited action would be the best
alternative. The author is also at odds with the decision to
use theJ:mal desorption to address the soil contamination. It
is his belief that the waste can be shipped off-site to a salt
mine "for back fill. . Be is certain. that the" contamination--
won't ever escape from the salt for.mations, and all this can
be done at a considerable cost savings.
Response: Regulatory requirements will not allow the
landfilling of these contaminants outside an approved RCRA.
landfill.
Comments: The Pamlico-Tar River Foundation forwarded a letter
to the Agency in support of the actions taken at the Site.
The letter also expressed conc~rn over the potential threat
posed by the old city dump located in the wetland.s behind the
Site, and the fact that actions taken at the PCX Site don't
encompass the old ci~ dump.
Response: The city dump will have to be considered as
separate site and would have to be proposed for the National
Priority List before EPA could become involved.
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State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street. Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor
Division of Solid Waste Management
Telephone 919 - 733-2801
Jonathan B. Howes, Secretary
September 13, 1993
Mr. Michael Townsend
Remedial prnject Manager
US EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE:
state Concurrence with the Draft
Operable Unit 1, Groundwater FCX
Washington, Beaufort County, NC
NCD 981 475 932
Record of Decision
Washington NPL Site
Dear Mr. Townsend:
. The State of North Carolina has reviewed the Draft Record of
Decision for the FCX Washington Site and concurs with the selected
remedy, subject to the following conditions.
1.
state concurrence on this Draft Record of Decision (ROD)
and the selected remedy for the site is based solely on
the information contained in the Draft Record of Decision
dated June 1993. Should the State receive new or
additional information which significantly affects the
conclusions or remedy selection contained in the ROD, it
may modify or withdraw this concurrence with written
notice to EPA Region IV.
State concurrence on this Draft ROD in no way binds the
state to concur in future decisions or commits the State
to participate, financially or otherwise, intbe clean up
of the site. The state reserves the right to review,
overview, comment, and make independent assessment of all
future work relating to this.site.
2.
p.D. ~ 27W, Raleigh, North Carolina 27611-7687 Telephone 919.733-4984 Fax' 919-733-0513
An Equal Opponuniry Affirmarive ActicJn Emp~
-------
L-
Mr. Townsend
9-13-93
Page 2
3.
4.
If, after remediation is complete, the total residual
risk level exceeds 10-6, the State may require deed
recordation/restriction to document the presence of
residual contamination and possibly limit future use of
the property as specified in NCGS 130A-310.8.
It is our understanding that screening analysis of the
groundwater at the subject site for dioxins/dibenzofurans
will be performed during the remedial design.
If, PCDD's/PCDF's are determined to be present in
groundwater at detectable levels, risk values as shown in
Table 6-6 of the ROD and remedial action objectives for
groundwater as noted in Table 8-1 must be recalculated
and submitted for review. The granular activated carbon
(GAC) system must also be designed based on PCDD's/PCDF's
as contaminants of concern in the groundwater and GAC
unit disposal methods may also change.
The state of North Carolina appreciates the opportunity to
comment on the Draft Record of Decision for the subject site, and
we look forward to working with EPA on the final remedy.
. Since;~ ~~
~ Butler. PE
Environmental Engineering Supervisor
Superfund section
cc:
Randy McElveen, HC Superfund section
Bruce Nicholson, HC Superfund section
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FCX WASHINGTON GROUNDWATER CONTAMINATION SITE
RECORD OF DECISION
CONCURRENCE SIGN-OFF SHEET
~~ 1//73 v: fit? ~
own end Fehn 0 d
RPM Section Chief Branch Chief
~ff1B G';'
q~Atl 1}4 3 t\JL D q /31Cl,3
Adams Bethune
ORC Risks Groundwater
~~
Green Franzmat Tobin
~c ~irector Di~~~i Acting RA
~ \~ A). - ."
1'he State of North Carolina Department of Environment, Health, and
Natural Resources (NCDEBNR) has reviewed this ROD and submitted
comments. These comments have been incorporated and NCDEBNR has
concurred with the selected remedy. -
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