United States
          Environmental Protection
          Agency
Off ice of
Emergency and
Remedial Response
PB93-964004
EPA/ROD/R04-92/111
September 1992
v°/EPA    Superfund
          Record of Decision:
          JFD Electronics Channel
          Master, NC

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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All supptemental material is, however. contained in the administrative record
for this site.
<"

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50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R04-92/111
4. TI1Ie and ~
SUPERFUND RECORD OF DECISION
JFD Electronics Channel Master, NC
Third Remedial Action - Final
7. Author(a)
1 ~
3. A8dplenl'a Acceulon No.
5. Report Date
09/10/92
6.
8. P8rf0rmlng Organlz8tion Rap«. No.
-
8. Flerformlng OrgaJnlza1lon Nama and Addreu
10. ProjactlTulUWork Unit No.
11. ContnIct(C) or Grant(G) No.
(C)
1 ~ SponaorIng Organization Name and Adch8a
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(G)
13. Type of R8pOr1& Period Covered
Agency
800/000
14.
15. Supplementuy No,"
PB93-964004
16. Abatract (Urnt: 200 worda)
The 13.09-acre JFD Electronics Channel Master site is a former television antenna
production and satellite assembly system facility in Oxford, Granville County, North
Carolina. Two onsite buildings are used by two companies as distribution centers.
Land use in the area is predominantly residential and business. Fishing Creek lies
1.7 miles south of the site and receives runoff and drainage from the facility. An
estimated 164 people per square mile use municipal water as their drinking water
supply. From 1961 to 1979, JFD Electronics used the site to manufacture television
antennas. From 1964 to 1965, an unlined lagoon, with a liquid capacity of 800,000 to
1,000,000 gallons, received wastewater from a chromate conversion process and a
copper/nickel electroplating process. From 1980 to 1984, Channel Master owned the site
and produced satellite systems, antennas, amplifiers, and boosters. Organic solvents
were reportedly used onsite to clean tools and antenna elements prior to sending them
offsite for electroplating. A 1987 state inspection detected VOCs and metals in the
lagoon sludge, adjacent soil, and ground water. In 1987, Channel Master excavated and
disposed of 17,000 cubic yards of contaminated sludge/soil at a permitted waste
disposal facility. In addition, 2,000 cubic yards of VOC-contaminated soil was
(See Attached Page)
17. Document An8Iy8Ia L D88cr1ptora
Record of Decision - JFD Electronics Channel Master, NC
Third Remedial Action - Final
Contaminated Media: soil, sludge, gw
Key Contaminants VOCs (benzene, PCE, TCE,), metals (antimony, chromium, nickel)
b. Identifler8l0pen-Ended Terma
Co COSA 11 ReIdIGroup
18. Availability Statement
18. SecurIty Cia.. (nda Report)

None

20. SecurIty Cia.. (ThIs Page)
Nnnp
21. No. of Pages

120
I
tt PrIce
(See ANSl-Z38.18)
See Instrucbons on Reveme
4-77)
(Formet1y NTls.35)
Department of Commerce

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EPA/ROD/R04-92/111
JFD Electronics Channel Masters, NC
Third Remedial Action - Final
Abstract (Continued)
excavated and thermally treated onsite. In 1988, Channel Master excavated and disposed
of two fuel oil tanks and one concrete waste oil tank. An EPA investigation in 1989
concluded that contaminated soil and ground water still existed at the site. This ROD
addresses the contaminated soil/sludge and ground water as a final remedy. The primary
contaminants of concern affecting the soil, sludge, and ground water are VOCs, including
benzene, PCE, and TCE; and metals, including chromium, nickel and antimony.
The selected remedial action for this site includes excavating an estimated 3,000 cubic
yards of soil/sludge, treating the soil/sludge onsite using oxidation-reduction;
stabilizing the treated soil/sludge and backfilling and capping the stabilized material
onsite with a RCRA-approved or non-RCRA cap pending results of a treatability study;
extracting and treating contaminated ground water onsite using alkaline chlorination to
remove cyanide and VOCs, precipitation/filtration to remove metals, and air stripping and
carbon adsorption to remove VOCs, followed by onsite or offsite discharge to a POTW or as
surface water to Fishing Creek. The total present worth cost for this remedial action is
$6,392,000, which includes a total O&M cost of $2,804,000 over a period of at least five
years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil/sludge clean-up goals are based
on health-based levels and include chromium 310 mg/kg; nickel 1,110 mg/kg; and antimony
25 mg/kg. Chemical-specific ground water clean-up goals are based upon health-based
levels, and include; benzene 5 ug/l; 1,2-dichloroethane 0.038 ug/l; 1,1-dich1oroethene
7 ug/l; 1,2-dichloroethene 70 ug/l, PCE 0.7 ug/l, 1,1,1-TCA 200 ug/l; TCE 2.8 ug/l; vinyl
chloride 0.015 ug/l; barium 1,000 ug/l; chromium 50 ug/l; copper 1,000 ug/l; lead 20
ug/l; nickel 100 ug/l; zinc 500 ug/l; and cyanide 154 ug/l.

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1-.-
RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
JFD ELECTRONICS/CHANNEL MASTER SITE
OXFORD, GRANVILLE COUNTY
NORTH CAROLINA
PREPARED BY:
u.s. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA. GEORGIA

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,-
DECLARATION
FOR
THE RECORD OF DECISION
SITE NAME AND LOCATION
JFD Electronics/Channel Master
Oxford, Granvilie County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the JFD Electronics/Channel Master Superfund Site (the
"Site") in Granville County, North Carolina, chosen in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 and, to
the extent praticable, the National Contingency Plan. This
decision is based on the administrative record file for this
Site.
The State of North Carolina conditionally concurs with the
selected remedy. State comments on the ROD, as well as EPA's
responses to those comments, can be found in Appendix A of
this document.
DESCRIPTION OF THE SITE
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response
action selected in this Record of Decision, may present an
imminent and substantial endangerment to public health,
welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This remedial action addresses the soil, sludge, and
groundwater contamination at the Site. The major threat is
the contaminated groundwater migrating off-site.

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The major components of the selected remedy include:
GROUNDWATER
Extraction of groundwater from the Site in the
overburden/fractured bedrock aquifer that is
contaminated above Maximum Contaminant Levels
North Carolina Groundwater Standards;
or the
On-site treatment of extracted groundwater via
alkaline chlorination, precipitation/filtration, air
stripping, and carbon adsorption to reduce
contaminants to either MCLs or State Standards,
whichever are most protective;
Discharge of treated groundwater to the local
Publicly Owned Treatment Works (POTW) or a nearby
surface water pathway. The discharge location will
be determined in the Remedial Design phase; and
Continued monitoring for contaminants in
groundwater.
SLUDGE/SOIL
Excavation of on-site contaminated sludge and soil;
On-site treatment of contaminated sludge and soil
using "reduction-oxidation and stabilization until
the LDRs or treatability variance treatment levels
established for the metals of concern have been met;
On-site disposal, or backfilling, of the treated
sludge/soil into the excavated area;

Placing a cap over the treated sludge and soil to:
1) minimize the potential for adverse health risks
due to direct contact with residual
contamination;
2) impede the infiltration of any residual
contamination into the groundwater aquifer; and
3) minimize the possibility for surface water runoff
from the area of contamination.
ADDITIONAL SAMPLING AND MONITORING
The installation of additional monitoring wells will be
required during the RD to further characterize the nature and
extent of groundwater contamination.

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In order to establish a broader data base on groundwater
quality, additional groundwater samples will be collected and
analyzed for TCL/TAL constituents. In order to maintain a
level of protection for the residential well owners living
immediately downgradient from the Site, samples will be
collected and analyzed every four months prior to
Lmplementation of the remedial action.
Additional surface water and sedLment samples shall be
collected and analyzed during the RD from the surface water
pathways located adjacent to and downgradient of the Site to
confirm and verify that these pathways are not being
adversely impacted by the Site.
STATUTORY DETERMINATIONS
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. The Land
Disposal Restrictions (LDRs) are applicable or relevant and
appropriate for the treatment of the sludge and soil at this
Site because the sludge is a RCRA listed hazardous waste. A
Treatability Variance will be used to comply with the LDRs.
This remedy utilizes permanent solutions and alternative
treatment technology to the maximum extent practicable, and
satisfies the ~tatutory 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 on-site 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.
~rn~
~Greer c. Tidwell
Regional Administrator
9 -It) -~2.
Date

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SECTION
TABLE OP COHTBHTS
I.
SITE NAME, LOCATION AND DESCRIPTION. .
. . . . .
A.
B.
C.
D.
E.
F.
G.
H.
Introduction. . . . . . . . . . . . . . . .
Site Description. . . . . . . . . . . . . .
Topography. . . . . . . . . . . . . . . . . .
Geology/Hydrogeology. . . . . . . . . . . . .
Surface Water ................
Meteorology. . . . . . . . . . . . . . . . .
Demography and Land Use. . . . . . . . . . . .
Utilities ..................
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION

IV. SCOPE AND ROLE OF RESPONSE ACTION
WITHIN SITE STRATEGY. . . . .
A.
B.
. . . . .
Site History. . . . . . . . . . .
Enforcement Activities. . . . . .
. . . . . .
. . .
. . .
. . . . . .
. . . . . .
. . . .
V. SUMMARY OF SITE CHARACTERISTICS.
A.
B.
C.
. . . . . . . . . .
Groundwater Investigation. . . . .
Sludge/Soil Investigation. . . . .
Surface Water/Sediment Investigation
......9

. . . . . . 18

. . . . . 36
. . . .
. . . . .
. . . 42
VI. SUMMARY OP SITE RISKS
A.
B.
C.
D.
E.
. . .
Contaminants of Concern. . . . . . . . . . . . 42
Exposure Assessment. . . . . . . . . . . . . . 42
Toxicity Assessment. . . . . . . . . . . . . . 53
Carcinogens. . . . . . . . . . . . . . . . . 53
Noncarcinogens . . . . . . . . . . . . .. . 53
Risk Characterization. . . . . . . . . . . . . 54
Environmental (Ecological) Risk. . . . . . . . 54
PAGE NO.
1
1
1
1
3
3
4
4
4
5
5
7
8
8
9

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SECTION
TABLE OF CONTENTS (CORT' D)
PAGE NO.
VII. APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) . . . . . . . . . . . . .
A.
B. '
C.
. . 58
Action-Specific ARARs . . . . . . . . . . . . . 59
.Location-Specific ARARs . . . . . . . . . . . . 61
Chemical-Specific ARARs . . . . . . . . . . . . 62
To be Considered Materials (TBCs) .... 64
Sludge/Soil Cleanup Le~els ...... . 64
VIII. DESCRIPTION OF ALTERNATIVES
A.
B.
. . . .
69
. . . . . . .
Remedial Alternatives to Address
Groundwater Contamination. . . . . . . . . .
1. No Action. . . . . . . . . . . . . . . . .
2. Institutional Actions. . . . . . . . . . .
3. Collection/Treatment/Disposal. . . . . . .
4. Collection/Treatment/Disposal. . . .
5. Collection/Treatment/Disposal. . . . . . .

Remedial Alternatives to Address
Sludge/Soil Contamination. . .
1. No Action. . . . . . . . . .
2. Institutional Controls. . .
3. Excavation/Off-Site Disposal
4. Excavation/Treatment/On-Site
5. Excavation/Treatment/On-Site
69
69
74
74
76
79
. . . . . .. 80

. . . . . .. 81

. . . . . . . . 81

. . . . . . . . 81

Disposal. .. 82
Disposal. .. 83
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. .
Threshold Criteria. . . . . . . . . . . . . .
Primary Balancing Criteria. . . . . . . . . .
Modifying Criteria. . . . . . . . . . . . . .
A.
85
85
85
86
GROUNDWATER REMEDIATION. . . . . . . . . . . . 88
Overall Protection. . . . . . . . . . . .. 88
Compliance with ARARs .. . . . . . . . . . . 88
Long-term Effectiveness and Permanence.. 89
Reduction of Toxicity, Mobility, or Volume 89
Short-term Effectiveness. . . . . . . .. 89
Implementability . . . . . . . . . . . .. 89

Cost. . . . . . . . . . . . . . . . . .. 90
State Acceptance. . . . . . . . . . . . . . . 90
Community Acceptance. . . . . . . . . . . . . 90

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SECTION
B.
TABLE OF CONTENTS (CONT' D)
PAGE NO.

SLUDGE/SOIL REMEDIATION. . . . . . . . . . . . 91
Overall Protection. . . . . . . . . . . . . 91
Compliance with ARARs . . . . . . . . . .. . 91
Long-term Effectiveness and Permanence.. 92
Reduction of Toxicity, Mobility, or Volume 92
Short-term Effectiveness. . . . . . . . . . . 92
Implementability . . . . . . . . . '. . . . . . 92
Cost ~ . . . . . . . . . . . . . . . . . . . . 92
State Acceptance. . . . . . . . . . . . .. 93
Community Acceptance. . . . . . . . . . . . . 93
X. THE SELECTED REMEDY. . . . . . .
. . .
. . . . . . . 94
A.
B.
Groundwater Remediation. . . . . . . . . . . . 94
Sludge/Soil Remediation. . . . . . . . . . . . 98
Treatment Levels.. ...... ..... 99
Treatability Study. . . . . . . . . . . . 101
Additional Data Requirements/Monitor
Existing Conditions. . . . . . . . . . . .101
XI. STATUTORY DETERMINATIONS. . . . . . . . . . . .. 103
XII.EXPLANATION OF SIGNIFICANT DIFFERENCE. . . . . . . 104

APPENDICES.
APPENDIX A - STATE COMMENTS ON ROD
- EPA RESPONSES TO STATE COMMENTS

APPENDIX B - RESPONSIVENESS SUMMARY

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FIGURE
1
2
3
4
5
6
7
8
LIST OF FIGURES
PAGE NO.
Site Base Map. . . . . . . . . . . . . .. 2
Potential Onsite Contamination Areas. . .. 6
Groundwater Sample Locations. . . . .. .. 10
Borehole Location Map. . . . . . .. . . . . . . 19
Soil GC Resu~ts-Parking Lot Area. . . . . .. 28
Soil Sample Locations-Sludge Drying Bed Area. .29
Surface water/Sediment Sampling Locations.. 38
Sludge/Soil to be Remediated . . . . . . .. 66

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TABLE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

16
17
18
19
20
21
LIST OF TABLES
Selected Groundwater Analytical Results -
Volatiles and Semi-Volatiles. . . . .
Selected Groundwater Analytical Results -
Monitoring Wells. . . . . . . . . . .
Selected Groundwater Analytical Results -
Re"sidential Wells. .........
Selected Groundwater Results -
Temporary Wells. . . . . . . . . .
Selected Soil Sample Results -
Background Locations. . . . . . . . .
Selected Soil Sample Results -
Borehole CMBB12 . . . . . . . . . . . .
Selected Soil Sample Results -
Former Lagoon Area .. . . . . . . . . .
Selected Soil Sample Results -
Borehole CMBB04 . . . . . . . . . . . .
Selected Soil Sample Results -
Distribution of Nickel, Chromium, Copper. .
Selected Soil Sample Results -
Sludge Drying Bed Area. . . . . . . .
Sludge Sample TCLP Results. . . . . . . . .
Select~d Sample Results
Surface water/Sediment. . . . . . . .
Chemicals of Potential Concern
for Sludge/Soil/Sediment". . . . . . .
Chemicals of Potential Concern
for Groundwater/Surface water. . . . .
Exposure Parameters for Current and Future.
Land Use. . . . . . . . . . . . . . .
Contaminants of Concern. . . . . . . . . .
Summary of Carcinogenic and Non-
carcinogenic Risks. . . . . . . . . .
Groundwater Remediation Levels. . . . . . .
Soil Remediation Levels. . . . . . . . . .
Preliminary Screening of Alternatives. . .
Summary of Cleanup Alternatives. . . . . .
PAGE NO.
11
13
15
16
20
21
22
25
26

30
37
40
43
45

46
55
56
65
68
70
87

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-1-
DECISION SUMMARY
I. SI'l'B HAMB, LOCATION AND DESCRIPTION
A.
Introduction
The JFD Electronics/Channel Master Site (the Site) is located
at 620 West Industry Drive, Oxford, Granville County, North
Carolina. The Site is located approximately 2 miles
southwest of Oxford. From 1961-1979, JFD Electronics owned
and operated various manufacturing processes primarily
associated with the production of television antennas. From
1980 through 1984, Channel Master owned the property and
assembled satellite systems at the Site. All
manufacturing/assembly operations at the Site ceased in 1984;
Channel Master moved its operations to their Smithfield,
North Carolina facility..
B.
Site Description
The Site is located on a 13.09-acre parcel of property.
property is bordered to the north by pine Tree Road, to
west by Industry Drive, to the south by a railroad line
by Southern Railroad, and to the east by a residential
development. Refer to Figure 1.

The main building at the Site is currently being utilized by
Hamilton/Avnet Electronics as a warehouse distribution
center. A smaller building located on-site is currently
being used by the Bandag Corporation as a distribution
warehouse.
The
the
owned
C.
TODoaraDhv
The Site is situated in the piedmont physiographic province
in north-central North Carolina. The Piedmont physiographic
province surrounding the Site is characterized by a broad,
relatively level highland, with ground surface elevations
on-site ranging from 448 to 478 feet above mean sea level.

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                              OUNNCl MASTED vT!
                         '»•:•:•:•:•:•: MAIN WHOINC :•:•:•:•:•?:
                                                                                                          FENCE LINE
                                                                                                          WUlNAtt CKEI
                                                                                                                IWE
                                                                                                          TREE LINE
                                                                                                          lUlLHOAO
203IS  BASEMAPI.OGN 3/20/92
                                                        FIGURE  1
                                                      Base Map
                                               Channel Master Site

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-3-
D.
Geoloav/Hvdroaeoloav
The Site lies within the geologic belt known as the Carolina
Slate Belt. The Carolina Slate Belt generally consists of
crystalline basement rocks of unknown age overlain by a
volcanogenic sequence of late Precambrian to early Paleozoic
age. Most of these rocks near the surface have weathered
into a layer of "overburden", generally ranging in thickness
from 55 to 60 feet at the Site. This layer consists of
weathered bedrock, saprolite, residual soils, and to a lesser
extent, alluvium.
Groundwater at the Site occurs in an unconfined-to-
semiconfined aquifer consisting of overburden hydraulically
interconnected with underlying bedrock. Approximate depth to
groundwater generally ranges from 7 to 11 feet below land
surface. The saturated thickness in the overburden portion
of the aquifer is 40 to 50 feet. During the wetter periods
of the year, groundwater may intersect the ground surface at
specific locations of the drainage ditch located along the
southern border of the Site.

Site soils are classified as Appling loamy sands and
Appling-Urban land complex. Appling loam soils are
characterized as well-drained soils on nearly level to
strongly sloping piedmont uplands (e.g., sandy loam, clay.
clay loam, sandy clays). Urban land complex soils at the
Site are the result of both construction and former cleanup
activites undertaken by the owners/operators of the facility.
E.
Surface Water
Surface water drainage and flow patterns on the Site are
generally controlled by grading and several man-made drainage
ditches. Runoff and drainage from the main building, the
parking areas south of the main building, and the former
lagoon and treatment tank area, generally flow southward and
are collected by the drainage ditch flowing along the
southern border of the property. Runoff and drainage on the
eastern portion of the Site generally flow into a drainage
ditch that borders the eastern edge of the Site. The two
drainage dit~hes converge near the southeastern corner of the
Site and flow southward approximately 1.75 miles to Fishing
Creek.

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-4-
Potentiometric data indicates that groundwater generally
flows to the southeast from the Site, then turns eastward in
the vicinity of the Southern Railroad right-of-way. This
flow pattern is consistent with the topographic slope and the
direction of intermittent stream flow in the area.
F.
Meteoroloqy
Granville County has a
winters and hot~ humid
average between 42 and
July. Yearly rainfall
averages between 44 to
relatively moderate climate, with mild
summers. Seasonal temperatures
440 in January to 78 and 800 in
across this portion of the piedmont
48 inches.
The average wind speed throughout the Piedmont is 9 miles per
hour. Winds generally blow from a 'south/southwesterly
direction.
G.
DemoqraDhv and Land Use
The Site is located in an industrial park. Land use to the
Site's immediate west, northwest, and southwest is primarily
industrial/light manufacturing and storage. Residential
areas are located east and southeast of the
Site. The average population density in Granville County,
North Carolina,' according to preliminary 1990 census data, is
72.2 persons per square mile. This density increases to 164
persons per square mile in the city of Oxford.

The downtown area of Oxford lies approximately 2 miles
northeast of the Site. The projected population of the city
by 1995 is estimated to be 42,425.
B.
Utilities
Electrici~y, telephone, natural gas, and city water are
available at the Site. Granville County sewage connection is
available at the Site.

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-5-
II.
SITE HISTORY AIm ENPORCBMBIIT ACTIVITIBS
A. Site History

From 1961 to 1979, JFD Electronics (a subsidiary of Unimax
Corporation) manufactured television antennas at the Site. An
unlined lagoon was built from 1964 to 1965 to dispose of
wastewater generated from a chromate conversion process and a
copper/nickel electroplating process. The lagoon reportedly
held from 800,000 to 1,000,000 gallons of sludge during its
operation. In October 1979, Channel Master Satellite
Systems, Inc. (a subsidiary of Avnet Inc.) began leasing the
Site. Channel Master bought the Site in 1980 and used it to
produce satellite systems from 1980 to 1984. Indoor and
outdoor antennas, amplifiers, and boosters were also
assembled on-site during this time period. Organic solvents
were reportedly used on-site for cleaning tools and the
antenna elements prior to sending them off-site for
electroplating.
Reported sources of contamination at the Site included the
sludge lagoon and eleven sludge drying beds, an unconfirmed
number of underground storage tanks, soils contaminated with
volatile organic compounds (VOCs) associated with a leaking
waste oil tank; and several other areas associated with
disposal practices of cleaning solvents. Refer to Figure 2.

The North Carolina Department of Human Resources - CERCLA
unit (NCDHR-CERCLA) (now called the North Carolina Department
of Environment, Health, and Natural Resources or NCDEBNR)
conducted a site inspection on February 23, 1987. Analyses
of the lagoon sludge and adjacent soils revealed the presence
of chromium, lead, arsenic, cyanide, and VOCs. Sampling of
the groundwater revealed the presence of dichloroethane,
trichloroethene, tetrachloroethene, and xylene.
Channel Master initiated cleanup activities at the Site in
June 1987 under the supervision of the NCDBR-CERCLA unit.
These activities included excavating approximately 17,000
cubic yards of contaminated sludge/soil and disposing of it
in a permitted waste disposal facility. Approximately 2,000
cubic yards of VOC-contaminated soil were also excavated and
thermally treated to destroy the VOCs. In July 1988, Channel
Master excavated and disposed of two fuel oil tanks and one
concrete waste oil tank.

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                                                                                                                 POTENTIAL (AST
                                                                                                                 UST MCA
 CONCRETE
 PA*
  fOWCR
  IN-CROUHO
  CQHCRtlt HASTE
  Oil IANK
  (1)11 SURVET NAP)

       I' CONCMK PIPE
fMHCR VOC CONTAMINATED
DRAINAGE AMA IS I ME IIM)
  roRNER SCRAP MEIAL
  IRAllEI PAW IMC ARIA IS I ME IHtl
               OXFORD PRINTING
                                                                                      roncR SNAUO*
                                                                                      OVAL PIT
                                                                                      (IKS AERIAL PHOTO)
                                                                                                                   SlUOCt DRTINC AREA
                                                                                                                   (IKS ACRIAl PHOTO I
                                                                                                                       LEGEND
                                                                                                                                             f
                                                                                                                         POTENTIAL USTS

                                                                                                                         FENCE UNE

                                                                                                                         CREEK

                                                                                                                         nOPERTT UNE

                                                                                                                         RAILROAD

                                                                                                                         PILE Of VOC-CONTAHINATEO
                                                                                                                          SOIL PRIOR TO TREATMENT
                                                                                                                         II SlUOCt DRYING IEOS
              SCALE IN UET
20315 flCNI-i.OCN 1/20/92
                                                                 FIGURE  2
                                                                                 i
                                       Potential Onsite Contamination Areas
                                                     Channel Master Site

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-7-
Site visits were conducted by representatives of the Agency
for Toxic Substances and Disease Registry (ATSDR) in March
1989 and later by EPA in September 1989. Based on these
inspections and on information collected since 1988, both EPA
and ATSDR concluded that contamination still existed at the
Site which warranted further investigation. Site
contamination included soils contaminated with VOCs,
groundwater contaminated with VOCs, and metal-contaminated
sludge/soil associated with the sludge drying beds.
B. Enforcement Activities
The JFD Electronics/Channel Master Superfund Site was
proposed for the National Prioriti~s List (NPL) in June 1988
and was finalized on the list in October 1989.
f"'"
On April 25, 1989, EPA sent special notice letters to:

1. Unimax Corporation (JFD's parent
corporation)
2. Channel Master
3. Granville Industrial Developers
The letters requested that these potentially responsible
partieu (PRPs) 'conduct a Remedial Investigation and
Feasibility Study (RI/FS) at the Site. The notice letters
also informed the PRPs of their liability for past costs.
The PRPs declined to perform the RI/FS. On November 8, 1989,
EPA sent a letter to the PRPs informing them of EPA's
decision to conduct a fund-lead RI/FS at the Site.

-------
-8-
III. HIGHLIGHTS OF COMMUHI'l'Y PARTICIPATION
Pursuant to Section 113(K)(2)~B)(i-v) and 117 of CERCLA, the
Community Relations Plan and the RI/FS Reports were released
to the public. The Proposed Plan for the Site was released
to the public for comment on April 9, 1992. These documents
were made available to the public in the Administrative
Record located in both the Information Repository maintained
at the EPA Docket Room in Region IV and at the Richard H.
Thorton Public Library in Oxford, North Carolina. The notice
of availability of these documents was published in the
Oxford Ledaer and the Durham Herald Sun newspapers on April
9, 1992. A public comment period was held from April 9, 1992
to May 8, 1992. A request for an extension of the public
comment period was made. In addition, a public meeting was
held on April 16, 1992. At this meeting, representatives
from EPA answered questions about problems at the Site and
the remedial alternatives under consideration. EPA extended
the public comment period until June 8, 1992.
Other community relations activities included issuance of a
fact sheet on the RI/FS process as well as a pUblic meeting
on the RI/FS in January 1990. EPA also issued a fact sheet
to the public on the results of the RI in February 1992 and a
Proposed Plan fact sheet in March 1992.
IV. SCOPB AND ROLE OF RESPONSB ACTION WITHIN SITE STRATEGY
The purpose of the remedial action presented in this ROD is
to reduce future risks at this Site. This remedial action
will remove the threat posed by contaminated groundwater and
sludge/soil at the Site. Remediating the groundwater will
prevent further migration of contaminants from the Site, as
well as restoring the groundwater to its beneficial use. The
remedial action for the sludge/soil will prevent the
contaminants from adversely impacting the groundwater and.
will decrease the direct contact threat associated with Site
sludge/soils. The remedial action will also reduce the
possibility of Site contaminants adversely impacting surface
water and sediment resulting from groundwater discharge or
surface water runoff.

-------
-9-
v. SUMMARY OF SITE CBARACTBRISTICS
The purpose of the RI at the Site was to characterize the
nature and extent of groundwater, sludge/soil, and surface
water/sediment contamination.
A.
Groundwater Investiaation
The groundwater,investigation was conducted in two phases;
phase I was conducted in January-February 1991 and phase II
was conducted in September-November 1991. Refer to Figure 3
for groundwater sample locations. In the first phase, a
hydrocone sampling device was utilized to collect 34 samples
from 19 locations on-site. . Samples were collected at depths
ranging from 15 to 24 feet below land surface. The hydrocone
sampling instrument was used both as a field screening device
to qualify the existence of the volatile organic compounds
(VOCs) at the Site, and a means of determining where to
locate the permanent monitoring wells during phase I.

Thirty-four hydrocone samples were analyzed on-site with a
BNU Model 311 Gas Chromatograph (GC); GC analyses were for
the three VOCs trichloroethene (TCE), 1,2-dichloroethene
(1,2-OCE), and tetrachloroethylene (PCE) since these VOCs had
been identified in the groundwater during previous studies.
The results of 'the GC analyses indicated that VOCs were
present in the groundwater from the parking lot south of the
main building, to the former lagoon area, and migrating
off-site to the southeast. Total concentrations of TCE,
1,2-DCE, and PCE, as measured by the GC, ranged from 98,000
micrograms per liter (ug/l) in the parking lot area south of
the main building (BCOl) to 31,000 ug/l at the facility
boundary near the former lagoon location (BC02). Other
hydrocone sample locations (background and those in the
eastern half of the Site) indicated lower total VOC
concentratioDs.
Based on the GC results, certain hydrocone samples described
in the previous paragraph were selected to be analyzed
through EPA's Contract Laboratory Program (CLP) in order to
quantify the extent of contamination. The analytical
parameters for those samples included field parameters (pB,
temperature, specific conductance), Target Compound List
(TeL) volatiles, semivolatiles, and pesticides, as well as
Target Analyte List (TAL) metals. Total concentrations of
TCE, 1,2-DCE, and PCE in four of the hydrocone samples from
the parking lot area south of the main building ranged from
364,410 ug/l to 697 ug/l. The remaining three samples
(background and those in the eastern hal~ of the Site)
indicated lower VOC concentrations. Table 1 shows .analytical
results from six on-site hydrocone locations.

-------
SI
g
         LEGEND

    —•-•-   fENCE LINE
    	   CREEI
    —	   PROPERTY LINE
    -*-*-   RAILROAD
     A    MONITORING *Ll LOCATION

     &    HYOROCONt SAMPLING LOCATION
^
 6
                                                                                                                           I
                                                                                                                           l-»
                                                                                                                           O
TEMPORARY NELL

TEMPORARY WELL KITH
 PIEZOMETER

TREE LINE
                                                                                      CNTK2I
      200
-.. ._  . .1..
 SCALE  IN FELT
                                                                                                                      100
   WUIS-4.0CN 3/20/92
                                                    FIGURE 3
                                      Groundwater Sample Locations
                                             Channel Master Site

-------
TABLE 1

SELECTED GROUNDWATER ANALYTICAL RESULTS
VOLATILES AND SEMI-VOLATILES, (ug/l)
CONTAMINANT CMHCOI2I CMHC0321 CMHCIOIS CMHCOSIS CMHCI024 CMHCIIIS CMHCI3IS
I, I , I-Trichloroethane 2901 NO 2J NO IJ NO NO
Benzene ND ND 2J NO NO. NO NO
1,1,2- Trichloroethane 150 NO NO NO NO NO NO
1.I-Oichloroethane NO NO 28 NO 1 NO NO
1,1-0ichloroethene 150 5. 17 NO 4J NO NO
1,2-Dichloroethane NO NO 2J ND NO NO NO
1 ,2-Dichloroethene 210J 15 630 ND 540 NO NO
Toluene 10 NO NO NO ND NO NO
Acetone 96 ND 86 NO ND ND ND
Xylenes 20 ND ND NO NO ND NO
Carbon Tetrachloride 220J NO NO NO NO NO NO
Ethy I Benzene 2J NO NO NO NO NO NO
Methyl Butyl Ketone 370J ND ND ND NO NO ND
Methylene Chloride 810J NO ND NO NO NO NO
T etrach loroethene 4200J 2400J NO NO NO NO 6J
Trichloroethene 360,000 11,000 100 NO 97 87 NO
Vinyl Chloride ND NO 6J ND 3J NO NO
I
.-
.-
,
J = Estimated Value
N () = Not Detected

-------
r
-12-
The last two numbers in the sample designation refer to the
depth at which the sample was collected. Based on the
results of the hydrocone sampling, five permanent monitoring
wells were installed on-site (CMMW01-CMMW05) during phase I.
Four of the wells were completed at depths ranging from 45 to
55 feet below land surface, including the upgradient well,
and the fifth well was completed at 35 feet. During phase I,
samples were collected from each of the five monitoring wells
on-site as well ,as from three off-site residential wells.
Refer to Figure 3 for the phase I and II groundwater sample
locations on or adjacent to the Site. The residential well
samples were collected along Highway 15 approximately quarter
of a mile east of the Site. Total concentrations of TCE,
1,2-DCE, and PCE in four of the wells ranged from 6,550 ug/l
to 925 ug/l. The upgradient well, CMMW01, did not contain
any VOCs. The metals chromium, copper, and nickel were also
detected in the monitoring wells at concentrations ranging
from 120-33 ug/l, 220-33 ug/l, and 91-29 ug/l, respectively.
Refer to Table 2.
Sample analyses from the three residential wells (CMPW01,
Finch well; CMPW02, Hightower well; and CMPW03, Knott well)
did not indicate any TCL VOCs or SVOCs/pesticides during
phase I. All of the wells (sampled at the tap) revealed
elevated levels of copper, most likely due to the copper
pipes used for-the delivery system. Cyanide was detected in
CMPW01 at 6.6 ug/l. No other Site-related metals were
detected in any of the wells. Refer to Table 3.

Based on the results of the first phase of groundwater
sampling performed in January-February 1991, EPA conducted a
second phase of groundwater sampling in September-November
1991. A total of thirty temporary wells were installed in
the shallow portion of the aquifer. Three of the temporary
wells were installed on-site and twenty-seven were installed
at locations south of the railroad tracks. Refer to Figure 3
for these locations. Six samples (CMTWOl, CMTW02, CMTW03,
CMTW08, CMTW24, AND CMTWBH17, 20-ft depth) were analyzed.
through the CLP for confirmation of the field screening
data. Refer to Table 4.
In addition to the temporary wells, three permanent
monitoring wells were installed at locations south of the
railroad tracks in the intermediate-deep portion of the
aquifer (depths ranging from 56 to 78 feet below land
surface). Four residential wells were also sampled during
phase 2.

-------
TABLE 2
SELECTED GROUNDWATER ANALYTICAL
MONITORING WELLS, (ug/l)
RESULTS
 CMMWO. CMMWOJ CMMWOJ CMMW04 CMMW05 CMSMEOI CMMW0611 CMMW0711 CMMWOSII
CONTAMINANT 2"19. "2519. 2n19. 9125". 2nl9. '12519. 218". '12519. 2n". 9/26/'. 2/519. .00J6/'1 .0/J6". . 0/2'''.
   (I)  (J)  (3)  (4)     
1,1 DichlorOelhene    \J      SJ    
        2J  .-    
I ,I Dichloroelhane             
1,2 Dichloroethane    41 250 100 7S 76 I SOl  340  3.4J 3.6J 
T etrachloroethene   890 1200 2700 1800 2S0 330 2100 2400  77 4S 
T richloroelhene   4300 3800 3600 3800 600 1200 3600 3800  14J 26 
1,1,2 Trichloroethane      IJ    2J    
1,1,1 Trichloroelhane          3J    
Vinyl Chloride      SJ        
1,2,3 Trichloropropane              \.JJ
2-Nilrophenol   4J           
Phenol   S4      SS     
---              
-              
Unidentified TIC.          4/100  1120J 1/40J 1/20J
Alpha BIIC       .OS2       
Phlhalales              
I
I-'
'f

-------
TABLE 2 ( cant. )
 CMMWOI CMMWOZ CMMWOJ CMMWI4 CMMW05 CMSMEO' CMMW06" CMMW01" CMMW08"
CONTAMINANT ZI6/91 "Z5"1 2n"l "25/" 2n"l "25"1 2/8/91 '/25/91 zm" '/2"" 2/5/" 10/2'''' 10/2"" 10/26/91
   (I)  (2)  (])  (4)     
Naphthalene              
Aluminum 4900 240 7C1OOO 1100 26000 220 13000 400 3600 9700 64000 9400 1300 100
Arsenic ND ND ND ND ND ND NO NO NO NO NO NO NO NO
8a 88 33 510 41 290 70 140 90 89 110 620 53 57 34
Be NO ND NO NO NO NO ND NO NO NO NO ND NO ND
Cd NO ND NO NO NO NO ND NO ND NO ND NO NO NO
Cr 33 NO \20 ND 31 NO \3 NO NO 29 35 38 50 NO
Co NO ND 7\ NO NO(40) ND 2\ 9J ND \35 5S 14 NO NO
Cu NO ND 220 ND 65 NO 33 NO ND 31 38 22 10 II
fib ND ND 15 NO 6 ND ND NO 5 ND 25 ND NO ND
Ug NO ND NO ND NO ND ND NO ND NO ND ND NO ND
Ni ND ND 91 NO 70 ND ND NO ND 29 71 42 NO(20) NO
Zn ND ND 360 NO 150 ND 64 NO 44 76 4S0 52 NO ND
CN NO ND NO ND NO NO 800 1100 ND ND NO NO NO ND
I
"""
t
J = Estimated value
ND ( ) = Not detected; ( ) = detection limits
NA = Not analyzed
J N = Estimated value, presumed present.

-------
 CMPWOI CMPW02 CMPOJ  CMPW04
 (Finch Wen) (liiahtower Wen) (Knott Well) (Brooks Wen)
CONTAMINANT 1/11/91 9/26/91 1/11/91 9/26/91 1/11/91 9/26/9' 9126191
Volatiles ND ND ND ND ND ND ND
     ..  
Semi-Volatiles ND ND ND ND ND ND ND
Herachlor Erollide NO NO NO NO ND ND .015
Anenic NO ND NO ND ND ND NO
Barium 7S 63 42 38 43 48 2S
Beryllium ND ND ND ND ND NO NO
Cadmium NO NO ND ND ND ND ND
Chromium NO ND ND ND ND ND ND
Cobal. ND ND ND NO ND ND ND
Copper 180J 180 310J 430 71J 89 280
Lead ND ND ND ND ND ND ND
. Mercury NO ND ND ND ND NO ND
Nickel NO NO NO NO NO NO NO
Zinc ND 14 ND 3.8 ND 12 II
Cyanide 6.6 NA NO NA ND NA NA
TABLE 3

SELECTED GROUNDWATER ANALYTICAL RESULTS
RESIDENTIAL WELLS, (ug/1)
I
~
'('
ND = Nol O~lecled
NA = Nol Analyzed For

-------
TABLE 4
 SELECTED GROUNDWATER RESULTS   
 TEMPORARY WELLS, (ug/l)    
 CMTWOI CMTW02 CMTW03 CMTW08  CMTW24 CMTWBH 1720
CllmAMINAm 9116/91 9/16/91 9116/91 10/1/91  10/7/91 9/30/91
Beryllium 80J 9J 87J ND - 50 ND
Cadmium ND ND ND ND  ND 14J
Chromium 640J 260J 1400J 89  1300 250
Cobalt 720J 240J 1500J 26  1200 460
Copper 1900 250 2600 49  4400 ND
Lead 240 30 270 ND  ND(400) J2
Mercury .4 ND .93 ND  ND ND
Nickel 540 280 1500 58  870 350
Zinc 2900 820 4000 59  3900 2600
Cyanitle ND ND ND ND  ND ND
I
~
cr
=
. estimated value
not detected
tIelection limits

peak average
J
ND( )
()
A

-------
TABLE 4 ( cant. )
 SELECTED GROUNDWATER RESULTS  
 TEMPORARY WELLS, (ug/l)   
.       
 CM1WOI CMTW02 CMTWOJ CMTW08 CMTW24 CMTWBHI720
CONTAMINANT 9116191 9116/91 9116/91 lom91 10/7/91 9/30191
I ,I ,I-Trichloroethane  409AJ    ."  
1,I,2-Trichloroethane 84      
1,1- Dich loroethane 410J      
1,2-Dichloroethene 2900 1000 92 9.7J 43J 6J
I,I-Dichloroethene 1200AJ  3J   
1,2-Dichloroethane II  10   
Tetrachloroethene 11000 13 1700 130 300 55
Trichlornethene 90000 46 3300 26J 3SJ 13
Vinyl Chloride 170 1400     
Chloroform 30      
Benzene 6J IJ     
Ethyl benzene 18      
Toluene 570AJ 2J     
Unidentitied TICs  31900J     
Aluminum 580000 120000 920000 31000 860000 640000
Arsenic ND ND ND ND ND(300) ND
Barium 7100 2000 12000 220 4300 1800
t
.-
....
t

-------
-18-
GC analyses from the temporary wells indicated total VOC
concentrations of TCE, 1,2-DCE, and PCE generally decreased
as distance increased away from the parking lot south of the
main building.' One on-site well (CMTW01) indicated 281,100
ug/l VOCs while off-site VOC concentrations ranged from 1,630
ug/l to none detected.
B.
Sludqe/Soil Investiqation
The sludge/soil investigation was conducted in two phases.
Surface and subsurface soils were analyzed for TAL metals,
cyanide, TCL VOCs, SVOCs, and PCBs/Pesticides. During phase
I, samples were collected from a background location, the
parking lot area, the former lagoon area, and the sludge
drying bed area as shown in Figure 4. A total of 82 soil
samples were collected from 12 boreholes (CMBBOI through
CMBB12) at 5-foot intervals to a depth of 40 feet below land
surface. Tables 5-9 show selected analytical results for
soil samples collected from the boreholes.

TCL VOCs were found primarily in three of the boreholes
located in the parking lot area (CMBB10, CMBB13, and
CMBB16). The largest concentration of VOCs found in the soil
occurred at 5 to 7 feet below land surface in CMBBIO (11,200
ug/kg). SVOCs'(primarily PABs) and pesticide compounds were
detected in the upper portions of boreholes CMBB05, CMBB09,
CMBB10, CMBB12, and CMBB16.
Several boreholes indicated elevated levels of chromium,
copper, and nickel down to 40 feet. Analytical results for
phase I sludge samples CMSPG4A and CMSPE3A indicated elevated
levels of chromium (24,000 mg/kg), nickel (11,000 mg/kg),
zinc (2,000 mg/kg), copper (1,600 mg/kg), and cyanide (40J
mg/kg).
Based on the phase I sludge/soil analytical results,
additional samples were collected during phase II from the
parking lot area (see Figure 6), the former lagoon area,
(Figure 5), and the sludge drying bed area (see Figure 7 and
Table 10). Eight subsurface soil samples (CMCPOI through
CMCP08) were collected from the parking lot area south of the
main building at depths from 6 to 10 feet below land surface
and analyzed on-site with the GC to investigate the possible
presence of residual VOC contamination. GC analytical
results revealed elevated VOC levels in 5 boreholes, with a
~ximum TCE concentration of 17,000 ug/kg in sample CMCP02.

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            fWCE UK


            C«£«

                 I ME


            RMl*OM


            WE LIME
            CHANNEL KASTEd MRMOLE
            «m NUMC*
                                                                                                                                  to
                                                                                                                                  I
           SCALE IN FEET
20315  BCBH2.DGN 3/20/92
                                                           FIGURE 4


                                                   BOREHOLE LOCATION MAP

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TABLB 5
SBLBCTBD SOIL SAMPLB RESULTS
BACKGROUND LOCATION, (mg/kg)
 CMBH0301 CMBII030S CMBH0310 CMBII031S CMBII0320 
CONTAMINANT 0-2 IT 5-7 IT 10-12 IT 15-17 Ff- 20-22 IT AVERAGE'
Arsenic NO NO NO NO NO NO
Barium 47 220 130 160 130 137.4
Beryllium NO NO NO NO NO NO
Cadmium NO NO NO NO NO NO
Chromium 6J 6.4J 9.8J 8.4J 6.8J 7.48
Cobalt 4.9 20 12 15 14 13.18
Copper NO 17 NO 13 ND(4) 15
Lead 14 1.8 2.1 1.4 1.7 4.2
Mercury NO NO NO NO ND NO
Nickel 3.6 12 10 10 9 8.92
Zinc ND(20) 75J 65J 74J 74J 72
Cyanide NO NO NO NO NO NO
I
N
cp
, Average does not include NDs
J = Value is estimated
ND( ) - Not Detected. () Detection Limit

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TABLB 6

SBLBCTBD SOIL SAMPLB RESULTS
BOREHOLB CMBH12, (mg/kg)
 CMB11I101' CMBIII105 CMBIII110 CMBI1I115J CMBIII110 CMBIIIU5 CMBIII230J CMBIII1J5 CMBIII140
CONTAMINANT 0-1 FI' 5-7 FI' 10-11 FI' 15-17 FI' 10-11 FI' 15-17 FI' 30-31.5 FI' 35-37 FI' 40-41 FI'
Arsenic ND ND ND ND ND ND ND NO NO
.         
Barium 93 35 57 220 94 60 180 100 62
Beryllium ND ND ND ND ND ND ND NO ND
Cadmium ND ND ND ND ND ND ND NO ND
-         
Chromium 48 10 5.9 15 12 10 14 21 22
Cobalt 16 ND ND 23 ND ND 15 13 12
Copper 63 6.1 ND(7) ND(5) ND(lO) ND(4) ND(20) ND(20) 22
Lead 17J 4.7J 4.4J 4.1J 2.4J 2.3J 3J 1.9J 3.2J
Mercury NO ND ND ND ND NO ND ND ND
Nickel 41 ND(2) NO(9) 12 ND(8) 8 15 12 14
Zinc 69 ND(9) 38 61 43 40 64 56 60
'Cyanide ND ND ND ND ND ND ND NO ND
I
N
....
I
. I The following organics were detected: Ethylmethylbenzene (IOJN uglkg); Napthalene (84J uglkg); and Tetramethylbenzene (300JN uglkg).
'. . . 1 ': Methyl propane was detected at 30JN uglkg.

) Methyl Ethyl Ketone was detected at 54 uglkg and Tetrahydrofuran at 20JN uglkg.
ND( ) = Not Detected. () is detection limit.
J = estimated value

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TABLE 7
SELECTED SOIL SAMPLE RESULTS
FORMER LAGOON AREA, (mg/kg)
 Units CMBII06 CMBH05 CMBII05 CMBII15 CMBH I' CMBIIOI CMBIIOI CMBII04"
CONTAMINANT  0-1 rt 0-1 ft 5-7 rt 0-1 ft 5-7 rt 0-1 ft 5-7 ft 0-1 ft
Anthracene ,.IIkS ND ND ., NO NA 130J NO NO NO
      " .  
Acenaphthene  NO NO NO NA 11 OJ  NO NO NO
Benzo(a) anthracene  ND 260J NO NA 450 NO NO NO
Benzo (a and/or k)  NO 390J NO NA 680J NO NO NO
nuoranthene         
Benzo (a) pyrene  NO 170J NO NA 220J NO NO NO
Benzo (ghi) perylene  NO 130J NO NA NO NO NO NO
Chrysene  NO 240J NO NA 430J NO NO NO
Fluoranthene  NO 550 NO NA 2300 NO NO 69J
Fluorene  NO NO NO NA 53J NO NO NO
Indeno (1.2.3-cd) pyrene  NO 11 OJ  NO NA NO NO NO NO
Phenanthrene  NO 64J NO NA 680J NO NO NO
Pyrene  NO 560 NO NA 1200J 43J NO 56J
Benzyl Butyl Phthalate  NO NO NO NA 811 NO NO NO
4.4-000 ,.g/kg NO NO .711 NA NO NO NO NO
4.4-00E  NO NO NO NO NO NO 0.54J NO
Endrin  NO NO NO NA .96J NO NO NO
Endosulfan Sulfate  NO NO NO NA 3.0J NO NO NO
4-4-DOT  NO ND ND NA 2.7J ND ND ND
Heptachlurepoxide  ND .44J ND NA ND ND ND ND
I
N
N
I

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TABLB 7 (cant.)

SBLBCTED SOIL SAMPLE RESULTS
PORMER LAGOON AREA, (mg/kg)
I
, .
I
 Vni.. CMBII06 CMBH05 CMBH05 CMBHt5 CMBHt' CMBHO. CMBHO. CMBH041)
CONTAMINANT  0-1 rt 0-1 n 5-7 rt 0-1 rt 5-7 rt 0-1 fa 5-7 rt 0-1 n
(ElhyloKiranyl) Elhanone ullt, ND ND ND ND 800JN - -ND ND ND
Anlhracenedione  ND ND ND ND IOOJN ND ND ND
Benzonuorene  ND ND ND ND IOOJN ND ND ND
Chlorodinuorobulanone  ND ND ND ND 600JN ND ND ND
Cyclobul8phenanlhrene  ND ND ND NO 600JN NO NO NO
Cyclopenl8phenanlhrenone  . ND ND ND NO 1000N NO ND ND
Cyclopenl8phenanlhrene  NO 200JN ND ND ND ND NO ND
Melhyl Anlhracene  NO NO ND ND 300JN NO NO ND
(2 isomers)         
Melhyl Pyrene  ND ND ND ND 300JN ND ND ND
Phenylnaphlhalene  ND ND ND ND 200JN ND ND ND
Benzonuoroanlhene  ND 300JN ND ND ND ND ND ND
(nol B or K)         
Benzonaphlhoruran  ND 80JN ND ND ND ND ND ND
Hexadecanoic Acid  ND 200JN ND ND ND ND ND ND
I
N
If
I)TICs were Cyclobutanediylbisbenzene 900JN ug/kg; Ethylmethylbenzene 700JN ug/kg; and Propylbenzene 400JN ug/kg.
Unidentified - First figure indicates number of compounds; second total concentration.
J = Estimated value
ND ( ) = Not detected; ( ) = detection limits
NA = Not analyzed
IN = Estimated value, presumed present.

-------
TABLE 7 ( cant. )

SELECTED SOIL SAMPLB RESULTS
PORMER LAGOON AREA, (mg/kg)
 Vni.. CMBH06 CMBH05 CMBH05 CMBHt5 CMBHt6 CMBtlOt CMBItOt CMBII041)
CONTAMINANT  0-1 rt 0-1 ft 5-' rt 0-2 rt 5-' rt 0-2 ft 5-7 rt 0-1 ft
Beta BHC  ND ND ND NA ND ... NO .7J NO
Arodar 1254  NO NO ND NA ND NO NO 25J
Unidentified  NO 4/4000J 3/2000J NA 3/3000J 11500J NO 14/10000
Arsenic mglkg NO NO ND NA 2.4J 2.5J ND 2.9
Barium  140 52 43 NA 68 64 140 79
Beryllium  ND ND ND NA .70 ND ND ND
Cadmium  NO NO NO NA 2.6 NO NO ND
Chromium  17 25J 15J NA 790 23J 21J 100J
Cobalt  16 II 4 NA NO (9) 12 47 17
Copper  32 16 9.7 NA . 150 17 25 46
Lead  9J 9.1 12 NA 16J 6.1 5.5 40
Mercury  ND NO NO NA ND ND NO NO
Nickel  8.4 10 NO (2.9) NA 310 8.2 11 54
Zinc  27J 27J NO (20) NA 140 24J 50J 64J
Cyanide  ND NO ND NA 26J ND NO 35J
I
N
~
I

-------
TABLB 8

SBLBCTBD SOIL SAMPLB RESULTS
BOREHOLB CMBH04
CONTAMINANT CMBH40t CMBH405 CMBH4tO CMBH415  CMBH420 CMBH430
Aluminum 19000 13000 7400 7200  t 6000 21000
Arsenic 2.9 NO' NO NO ., NO NO
Barium 79 130 67 61  270 280
Beryllium NO NO NO NO  NO NO
Cadmium NO NO NO NO  ND 1.1
  ___n --- -    
Calcium 2200 2300 NO NO  9600 11000
Chromium 100J 29J 21 19  31 59
Cohalt 17 26 12 II  30 30
Copper 46 19 31 21  87 63J
Imn 28000 22000 21000 20000  34000 30000
Lead 40 8.5 1.11 1.3J  I. 7J 1.3
Magnesium 2000 2500 4400 4700  13000 14000
Manganese 420 330 340J 3001  18001 1600
Mc:rcury NO NO NO NO  NO NO
Nickel 54 II 9.2 8.7  22 31
POlassium 710 290 NO (210) NO (220)  NO (300) 320
Sodium NO (820) NO (250) NO (340) NO (340)  NO (420) 240
Vanadium 89 72 621 511  83J 67
Zinc 641 NO (30) 38J 411  88J 79J
I
N
VI
I
ND ( ) = Not detected. () indicates detection limits.
J = estimated value

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TABLE 9

SELECTED SOIL SAMPLE RESULTS
DISTRIBUTION OF CHROMIUM, COPPER, AND NICKEL, (mg/kg)
             -   
        . BOREHOLES       
Deplh (feel) I 2 3 4' 5 6 7 8 9 10 II 12 13 14 15 16
Chromium:                
0  29  100        .48    
5                790
10               110 110
15                
20               110 
25       34         
30    59           97 
35                
40     230          82 
C()pp~r                
0    46     70   63    
5  31       41       150
10    31     41      44 37
15      37   57 51      
20    87     43 36   49  55 47
25     59  47   36      
30    63          36  
35                
40     47          45 
45             82   
50       32       32  
I
N
f

-------
TABLE 9 (cont.)
        BOREHOLES       
Depth (feet) I 2 3 4 5 6 7 8 9 10 II 12 13 14 15 16
Nickel                
0    54        41    
5                370
10               39 71
15                
20               53 
25                
30               35 
35                
40     110          39 
I
N
....,
I

-------
.
LEGEND
CMCP04
~
i
~
=>
~
...,... .
........ .
...,...... .
........... ..
.............. .
'...'."....'.0.
.,'.'.'."."'." .









",',',',',',',',',',',',',',',',',',',',',',',',',',',',',',',',', CHANNEL MASTER ',',',',',',',',',',',',',',',','"

""'::::::}~:~~{rr~tttttt~r",~~,~,~",~y,~,~,~,,~,~~,",rttttttHtt~~::~::::::::-:-",
,:~~~~~~~~~~)::::::::})rrrrrrrrrrrrrrrrrrrr{H((t~H~~HH~~}::::::::::-,',.
o
80RING lOCATlOII
FENC£ LINE
CREEl
PROPERTY LINE
FOllMER I'IPO.INE
IIOT OUECTEO
:::::
  DEPTH  ClP
 0' 5' 10' 10'
TC£ - - - -
PCE ]8 - J8 -
-..-  
DC[ - - - -
CMCP01
DEPTH
5'
210
22J
I
N
f
10'
550
"
TC£ 1200
Pc[ 2400
DC[
0'
-"'".0
~.,
..~..
CMCP06 ..~..
DEPTH Q.P """--.....
5' 10' 10' ~
12J 250 '\.~""",

.~. " \ ""j
o
CMCPOS
DEPTH
5
10
o
I
100
200
I
TCE
PCE
OCE
SCALE IN FEET
20385
CCRES.DCN 3/20/92
FIGURE 5
South Parking Lot Area
Soil Sample Field GC Results (fl9/k9)
Channel Master Site

-------
. N4900
~I ~I ~I ~I ~I C> C> 
~I ~ 
  +     9
       8
 + +     
+
 BAIIDAG WAREHOUSE         
+          
          I
          N
          f
       3
    J K L M N 0 
   2   LEGEND   
     .  SOIL SAMPLING LOCATION  
 F G H I ~  SLUOGE ORYING PITS (APPROXIMATE I  
     ~ TREE LIME   
 CMSOA01 (PHASE 1)  -..- PROPERTY LIME   
 0  \00 200 -- fENCE LIME   
 I  I I   RAILROAD   
+ +  SCALE IN fEET       
CHAllllEL MASTER
!lAIN IUILDING
N5\OO
+
N5000
TRUTIOT
TAllIS
--
-,./
~-
.-- a A

~~800 ~ +
20385 4C-10.DGN 3/23/92
. FIGURE 6
Soil Samples Collected in the Siudge-Drying Area
Channel Master Site

-------
TAl . 10
SELECTED SOIL SAMPLB RESULTS
SLUDGB DRYING BED AREA
  CMSPA100 CMSP8.. 08..1. 08.... CMSI'CJOO CMSPD.  O8PF.M8 CMSI'C408 CMSPIIUOI CMSPI400 ~ 
ANAL VSIS ANA lYrE  l1li11. uaIq ..,... uaIq ..,... ..,...  ..,... ..,... ..,... uaJIIa .'" 
EXTRACf ABll!' ACENAPHTHYlENI! NO NO NO NO NO IIOJ  NO NO NO ND NO 
OROANICS (SWCI) ANTHRACENE NO NO NO NO NO ~  NO NO NO NO t: 
 BEN2O(A)ANTHRACENE NO NO NO NO NO 490  NO NO NO 441 
 8EN7.0(8 AND/OR IC)Ft.UORANTHBNB NO NO NO NO NO 12110  NO NO NO NO NO 
 BEN7.0(OHI)PERYlENE NO NO NO NO NO )IJO  NO NO NO ND NO 
 BEN7.0.A.PVRENE NO ND NO NO ND '10  NO ND NO ND ND 
.              
 CARBAZOLE NO NO NO NO NO 42  .. NO NO NO ND NO 
 CHRVSENE NO NO NO NO NO 610  NO NO NO /WI NO 
 FLUORANTHENE NO 121 NO NO ND 1100  "OJ II' NO 1001 NO 
 IOENO('.2.3.CD)PVRENI! NO NO NO NO NO 3!10  NO I'll> NO ND NO 
 PHENANTHRENI! NO 411 NO NO NO '10  631 NO NO 411 NO 
 PHENOL NO NO '" NO NO NO  NO NO NO NO NO 
 PYRENE NO .001 NO ND 451 I!IO  1501 9\11 ~ UOJ NO 
MISCELLANEOUS I UNIOENTII'IED COMPOUNO NO NO IiOOJ NO NO NO  NO NO NO 100J NO 
EXTRACf A8LE ) UNIOENTIFIED COMPOUNDS NO NO NO NO 21m! DXIJ  NO NO 10,0001 NO NO 
OROANICS 4 UNIOENTIFIED COMPOUNDS NO NO NO NO NO NO  DXIJ NO NO ND NO 
 6 UNIOENTIFIED COMPOUNDS 1QIJOJ 10001 NO NO NO NO  NO 40001 NO NO NO 
 1 UNIOENTIFIED COMPOUNDS NO NO NO lO0OI NO NO  NO NO NO NO NO I
 ANTHRACENEDIONI! NO NO NO NO NO 10011'1  NO NO    W
  NO NO NO «r
 BENZACEPH.ENTHRYtENB NO NO NO NO NO 60011'1  NO NO NO NO NO 
 BENZALDEHYOI! 60011'1 NO NO NO NO NO  NO NO NO NO NO 
 BENZANTHRACBNONI! NO NO NO NO NO 40011'1  NO NO NO NO NO 
 8ENZ1!Nl!ACETALDEHYOl! 100011'1 NO NO ND NO NO ' ND ND NO NO NO 
 BEN7.0FLUORANTHENI! (NOT 8 OR K) NO NO NO ND NO 10011'1  NO NO NO ND NO 
 BBN7.0FlIJORENE (2 ISOMERS) NO NO NO NO NO DIN  ND NO NO NO NO 
 8EN7.0NAVHTHOTHIOPHENB NO NO ND ND ND 211011'1  ND NO ND NO NO 
 BROMOOIPHENYlETHANONB GIN NO ND NO NO NO  NO NO NO NO NO 
 CHLDROOIFlUOROBU f ANONI! 90011'1 100011'1 60011'1 ND SOOJN ND  DIN NO 211011'1 NO NO 
 OIMETHYLBUTENE NO NO NO NO NO NO  NO GIN NO NO NO 
 ETHYLOXIRANYL£THANONE NO NO NO NO NO NO  100011'1 NO NO NO 400IN 
 HYOROXYNONANONB NO NO 2DOJN NO NO NO  NO NO NO NO NO 
 METHYLANTHRACENB NO NO NO NO NO 10011'1  NO NO NO NO NO 
 METHYL£THYlBENlENE2 DXlIN NO NO NO NO NO  NO NO NO NO NO 
 METHYLPHENANTHRENE NO NO. ND NO NO 10011'1  NO NO NO NO NO 
 METHYLPYRENE (2 ISOMERS) NO NO NO NO NO 40011'1  NO NO NO NO NO 
 MIITHYLTRlrHIONYLENE NO NO NO NO NO SODIN  NO NO NO NO NO 
 rHENYl.li,.HANoNE NO NO :10011'1 NO NO NO  NU NU NO NO NO 
 TErRAIIECANAI. I'll) 30011'1 NO NO ND I'll)  NU I'll) I'll) NO NO 

-------
TABLE 10 (cont.)
SELECTED SOIL SAMPLE RESULTS
SLUDGE DRYING BED AREA
  CMSPAJII CMSPBI. CMSPII28I CMS,.. CMSI'CHI CMSPEIII CMS,... CMSPC408 CMSPlI4.Je8 CMS"'" c.-rq (II m
ANAL VIIS ANALYTE ..,.. ..,.. ..,.. 88Ib 88Ib ..,.. ..,.. ..,.. ..,.. ..,.. ..,..
PESTICIDIWI'CIo 4,4,"Doo (P,P-DDD) ND ND ND ND ND ND ND 2.11 ND ND '~D
 4,4,"008 (P,P-DDE) 0.431 ND ND ND 1.41 ND ND 291 ND ND NO
 4,4,..DDT (P,P-DDT) ND ND NO ND ND ND ND 651 ND ND ND
 AWIUN NO ND NO ND ND ND ND 141 ND ND ND
 ALPHA.cHLORDANB 12 ND ND ND ND ND ND ND 621 ND NO NO
. DIELDIUN ND NO . ND ND NO ND .,.D 311 ND ND ND
 ENDOSlJUIAN I (ALPHA) ND ND ND ND ND U4 ND ND ND ND ND
 ENDRIN 1.61 ND ND ND ND ND ND 4U ND ND ND
 OAWMA-8HC (UNDANE) ND ND NO ND ND ND ND 141 ND ND ND
 OAWMA.cHLORDAN8 12 ND ND ND ND ND ND ND 481 ND ND ND
 HEPACHLOR EPOXiOB NO NO NO NO NO NO NO \11 NO NO NO
 HEP'I'ACHLOR NO NO NO NO NO NO NO 161 NO NO ND
1 - &Ii-..J V.-
. ND - Nell DoI8ctM
N . P........ e..w...c. ", '-- ", M8I8rioI
I
w
...
I

-------
I
TABLJ!: 10 (cont.)

SELECTED SOIL SAMPLE RESULTS
SLUDGE DRYING BED AREA
ANALYSIS TYPE ANALYTE CMSPBJJ6 CMSPG414 CMSPJ7J6 CMSPK6J6 CMSPM7J6 CMSPM9J6 CMSI'QOJ6
  ui/itl ui/itl ul/ltl U&'ltl ui/itl ug/kl ul/lt«
EXTRACTABLE 4-NITROPHENOL J9OJ. .      
      . .  
ORGANICS (SVOCa) DI-N.BUTYLPHTHALA TE 461      
 PYRENE   39J    
MISCELLANEOUS I UNIDENTIFIED COMPOUND  SOOJ   SOOJ 900J 
EXTRACTABLE ETHYLOXIRANYLETHANONE       200JN
ORGANICS NONAMIDE  400JN     
PERCENT  21 14 10 29 24 2S 23
MOISTURE        
J = Estimated Value
ND = Not Dctected
N = Prcsumptive Evidcnce of Prescnce of M.tcrial
,
W
N
,

-------
TABLE 10 (cont.)

SELECTED SOIL SAMPLE RESULTS
SLUDGE DRYING BED AREA
AI'IALYSIS TYPE ANALYm CMSPJSOO SMSPJ700 CMSPJIOO  CMS"'- CMSPKIOO CMSPL700 CMSPUOO CMSI'M700 CMSPMtOO 
  uallia 81/11a 81/11a  8&111a UI/1ia 81/11a 81/11& UI/''' 81/11& 
exTRACfABI.E Bl!Nl.O(A)ANTHRACI!NB 821 1401     1101  511  
OROANICS (SVOCI) BI!NZO(B AND/OIIC)PLUOIAHl'HI!NE 2SOJ 3401     3401  941  
 BI!NZO-A-PYRI!NE  1401         
 CHltYSI!NE 1301 JlOI     1801    
 DI-N-BIfrYLPHTHALA TE S6J          
 FLUORANTHI!NE UOI 2]QJ     2101  681  
 PHENANTHRI!NE  15J     111    
 PVRENE 1801 2SOJ     2801  971  
MISCELLANEOUS I UNIDeNTIFIED COMPOUND   500J   5001  SOOI   
exTRACfABLE 10 UNIDeNTIFIED COMPOUNDS       9000J    
OROANICS II UNIDeNTIFIED COMPOUNDS 10,0001        10,0001  
 2 UNIDeNTIFIED COMPOUNDS     2000J      I
 1 UNIDeNTIFIED COMPOUNDS          10,0001 
 BI!NZOFLUORANTHI!NE (NOT B OR K)  200JN 1000N        
 BENZOFLUORENE  401N         
 BUTANOIC ACID, ETHENYLesTeR        1000N   
 CHLORODIFLUOROBUTANONE        JOOIN   
 ETHYLOXIRANYLETHANONE        900IN   
 METHYLPeNTl!NE        101N   
 OXYBISDIACET A TI!I!THANAL   200IN        
PCB/PesTICIDES 4,4-DDE(P,P-DDI!)         1.8J  
 OAMMA-CHLORDANI!. n          J.I 
 PCB-I260 (AROCLOR 1260)         211N  
PERCeNT I 11 II J I 5 5 II 12 29 J8 
MOISTURE         I 
w
'f
J '" I!sIimaIe4l V llue
NI) = Nal !>elected
N '" Prcsumptin Eviclmce 01 P,..ence or Mlterill

-------
TABLB 10 (cant.)
Grid Oreaaiel Anal,tlcal Da" Summar1 . Siudle Samples
ANALYSIS TYPE ANALYTE CMS~ CMSPF..3A CMSPG4A CMSPOO6S
  ualka ua/kl UI/II, ualli.
EXTRACTABLES BIS(2-ETHYLHEXYL)PHTHALA TE 11,000   4,600
MISCELLANEOUS (TETRAMETHYLBUTYL)PHENOL   3000JN 
EXTRACTABLE 20 UNIDENTIFIED COMPOUNDS 200,0001 -  
ORGANICS 21 UNIDENTIFIED COMPOUNDS ._-   100 ,OO()J
PCB/PESTICIDES PCB-12.54 (AROCHLOR 12.54) 2100 320J 1100 
PERCENT MOISTURE  73 74 68 S9
J = Eslimaled Value
ND = Nol Detecled
N = Presumptive Evidence of Presence of Malerial
I
~
I

-------
-35-
Based on the GC results, four samples (CMCP04, CMCP05,
CMCP06, and CMCP07) were sent for off-site laboratory
analysis through the EPA contract laboratory program (CLP).
CLP analytical results confirmed 250 ug/kg of trichloroethene
and 31 ug/kg of tetrachloroethene in sample CMCP06.

Five boreholes (CMBB13 through CMBB16) were installed at or
near the four corners ~f the former lagoon to investigate the
possible presence of residual inorganic contamination (Refer
to Figure 5). The analytical results did not show a pattern
of metals occurring in the soil; however, one sample (CMBB16,
from 5-7 feet below land surface) contained chromium at 790
milligrams per kilogram (mg/kg). A number of samples
contained polynuclear aromatic hydrocarbons (PABs) and
pesticides above background levels; however, concentrations
did not exceed action levels.
A SO-foot grid was extended over the sludge drying bed area
and the surrounding vicinity to investigate the nature and
extent of metals contamination. A total of 168 surface and
subsurface sludge/soil samples were collected from 46 grid
points at one-foot intervals in the sludge drying bed area.
The samples were analyzed on-site for the presence of
chromium, nickel, copper, and zinc using a BNU X-ray
fluorescence (XRF) analyzer.

Of the 23 surface soil samples collected, 8 samples in the
western half of the grid indicated elevated metals
concentrations. Chromium ranged from 1,350 mg/kg to 6,570
mg/kg (grid points Al and Q1, respectively), and nickel
ranged from 580 mg/kg to 3,010 mg/kg (grid points D2 and B1,
respectively). In the eastern half of the grid, only two
grid points, M7 and N7, indicated elevated metals
concentrations. Chromium was present at 5,410 mg/kg and
23,120 mg/kg, respectively, and nickel was present at 860
mg/kg and 5,920 mg/kg, respectively. Cyanide was detected in
14 out of 20 surface soil samples, and concentrations ranged
from 2.7J mg/kg (grid point J5) to 230J mg/kg (grid points B1
and 1017).
Surface soil SVOC concentrations ranged from 44J ug/kg
benzo-a-anthracene (grid point 14) to 1,200 ug/kg benzo-(b
and/or k)-fluoranthene (grid point E2). The largest number
of SVOCs were found in a sample collected at E2, which
contained 12 identified SVOCs, 10 TICs, and 3 unidentified
compounds. Surface samples from four points (J7, J5, L7, and
14) contained seven, six, six, and five identified SVOCs,
respectively. Samples from the remaining points detected
from one to four identified SVOCs.

-------
,-
I
I
-36-
One SVOC, bis (2-ethylhexyl) phthalate, was detected in two
sludge samples at concentrations of 4,600 ug/kg (sample
CMG3A) and 11,000 ug/kg (sample CMB226S).
One TIC was detected in sludge sample CMSPG3A, and
unidentified SVOC compounds were detected in sludge samples
CMSPB226S and CMSPG436S. Polynuclear Chlorinated Biphenols
(PCBs) were detected in four sludge samples. corresponding to
grid locations ~2 (2.1 mg/kg), E3 (0.32J mg/kg), G4 (1.10
mg/kg), and M7 (0.021 mg/kg). Pesticides were detected in
six surface soil samples.
In the western half of the grid, 66 subsurface soil samples
were collected at 22 sample locations. Three grid points
(points B2, G4, E3) directly overlaid subsurface sludge
drying beds. Sludge was encountered at depths of 26, 36, and
42 inches below land surface below these three grid points,
respectively. Samples were collected at the three locations
to characterize the nature of the sludge. Chromium
concentrations ranged from 100,000 mg/kg to 27,000 mg/kg
(points E3 and G4, respectively), and nickel ranged from an
estimated 36,000 mg/kg to 10,000 mg/kg (points E3 and G4,
respectively). Based on the results of the XRF analyses, 20
samples were sent for CLP analysis for metals, cyanide, TCL
VOCs, TCL SVOCs, and PCBs/Pesticides. CLP analytical results
confirm the XRF analysis, indicating a general pattern of
elevated metals in surface samples in certain grid areas.
Subsurface soil samples from depths below the sludge drying
beds were collected and analyzed both by XRF analysis and CLP
analysis. CLP analysis of seven samples, including samples
collected at depths below the sludge drying beds, did not
indicate elevated metals concentrations.
Two sludge samples were also submitted for toxicity
characteristic leaching procedure (TCLP) analysis. The TCLP
analysis indicated that chromium leaching ranged from 0.29 to
0.71 mg/kg; no other metals leached above their respective
detection limit (See Table 11).
C.
Surface water/Sediment Investiaation
Surface water and sediment samples were collected on two
separate occasions during the RI. The first sampling event
occurred in January 1991 during the wet season. Four surface
water and sediment samples (CMSW01 through CMSW04 and CMSD01
.through-CMSD04, respectively) were collected, one from a
background location (CMSW/SD04), two from locations adjacent
to the Site (CM/SD01 and CM/SD02), and one from a location
downstream from-the Site (CMSW03, CMSD03). See Figure~.

-------
-37-
TABLE 11
Sludge Samples TCLP Results
 CMSPG4A CMSPE3A
CONTAMINANT mglL mglL
SILVER ND ND
ARSENIC ND ND
BARIUM ND ND
CADMIUM ND ND
CHROMIUM 0.71 0.29
\  
LEAD ND ND
SELENIUM ND ND
MERCURY NA NA
CN NA8 NA8
VOAs NA8 NA8
EXTRACTABLE ORGANICS NA8 NA8
PESTICIDESIPCB NA8 NA8
8Cannot fail TCLP test based on Scan Analyses
NA = Not analyzed:
i
i
i
ND = Not detected

-------
.
OISVSDI4
SO 511
T« -
PCE -
OCE -
Ct 15 U
Cu 11 IIJ
IIi IS
o
o
I
300
I
SCALE IN HET
600
I
OISW/SOl5
50 511
TCE -
Pc( -
DC( -
C't II
QI -
.i
I
\
'\\,


'-
...,
~,

~.'\
\~
QISOII'-..
SO \
'....
CllSVlSOt4
SO $V
TCE -
PC[ -
OCE -
Cr 22 10
CU 15 I5J
Hi
(J
OISW/SD 11
SO $V
n t2
41 ]I
121 2\
26 ,
11 14J
OISOI\
SO
QlSVSO\2
SO $V
0ISV50 II
 SO 511
Tc( - -
PCE - -
DCE - -
Ct " -
CU 21 TJ
Hi II -
Tc( -
Pc( -
DCE -
Ct 22
CU 50
~lIi II
~t
20m SURFSED4.DCN 1131/92
FIGURE 7
Surface Water (1l9/L) and Sediment
Sampling (mg/kg) CLP Results
Channel Master Site
LEGEND
-)(-
FEliCE LJIIE
CREEl
RAILROAD
TREE LIIIE
PHASE I SURfaCE IIATER
AIIO SAMPLING LOCATIONS
PHASE 1\ SURf ACE IIA TEl
AIIO SED IMEIIT SAMI'lINI: LOCATIONS
PHASE II SEDIMENT SAMPliNG
LOCArtONS INO SURfaCE IIAT£A
AT TIME OF SAMPliNG!
-+--+-+-
"""
.
@
o
SEDIMENT 1lIOII01
SURF ACE IIATER 1 uglll
omvSDn
 SO SII
TCE - -
PCE - -
DCE - -
Ct 4)0 ]1
CU ,.] "J
Ni 1]0 -
I
f
511
"'AIITMEIIT
BUILDINGS
OISD~ C::::::Jt:::::J
50 C:::::J l:::::::J
TCE . ---.......::;:: -..J l:::::::J r--..
~: : ~. . ~~'""---J
Cr ]20 . '""\..,
CU ,)
Ni ,.
2)

-------
                              -39-

In general, metals  data from the  background location indicate
that  sediment  samples  should generally contain less than 25
mg/kg of chromium/  cobalt, copper, lead/ and nickel.  There
is little indication of the  presence of arsenic, cadmium/ and
mercury in the sediment background samples.  VOC and SVOC
results were negative.   Cyanide was found in background
sample CMSWO4  at  6.2 ug/1.   Refer to Table 12 for selected
analytical results.

Barium and zinc, appear  to be naturally occurring at fairly
substantial levels  (100 to 200 mg/kg) in the sediments.
Surface water  samples at all four locations were clean/
except for the water sample  taken from the stagnant pool at
CMSW05, which  contained lead at 53 ug/1.

Sample CMSW/SD02  revealed the presence of VOCs.  It is not
known if the source of  this  contamination is due to
groundwater discharge or from chemicals in the soil gas that
have escaped from the underlying  groundwater plume.
Sample CMSWO3  showed a  slightly elevated concentration of
chromium (31 ug/1), while CMSD03  revealed 12J mg/kg of
cyanide.

The second sampling event included collecting seven surface
water and ten  sediment  samples during the dry season in
September 1991..  Sampling locations included one background
sample (CMSW/SD05)/ two samples adjacent to the Site
(CMSW/SD13/ CMSW/SD14)/  and  the remaining samples
downstream.  Refer to Figure 7.   Sample CMSW/SD13 indicated
the presence of the VOCs 1/2-dichloroethene (91 ug/1)/
trichloroethene (32J ug/1)/  tetrachloroethene (8J ug/1), and
chloroform (4J ug/1); these  results confirm the fact that
VOCs occurred  in  sample CMSW/SD02 collected in January 1991.


Sample CMSW12/  located  immediately downgradient of the Site/
revealed the presence of barium (20 ug/1) and toluene (3J
ug/1)/ while CMSD12 revealed chromium (62 mg/kg), copper (31
mg/kg)/ and nickel  (23  mg/kg) above expected background
levels.  Eight unidentified  SVOCs were measured at a total
concentration  of  7 mg/kg; and one TIC was identified
(bromohexane at 900JN ug/kg).  Samples CMSW/SDO8/ CMSW/SD09/
CMSW/SD10, and CMSW/SDll were collected south of the railroad
tracks.  Samples  CMSW/SD08,  CMSW/SDO9, and CMSW/SD10 revealed
various concentrations  of chromium/ copper/ nickel/ and
cyanide.  No volatiles  were  identified in the four samples;
however/ seven unidentified  SVOCs with a total concentration
of 6 mg/kg were identified in sample CMSD11.  Two pesticides
were identified in  sample CMS009  (4/4-DDO/ 8.5 ug/kg and
4/4-DDE, 2.7J  ug/kg).

-------
----..
MI:TAI S
Nkon8f
0..18...
/lc"'Ii...
C ''''ID'''.
C"......iU8
CuINIt
('''''pcr
I...J
Mfl<"'Y
Nd.1
z,.
OTIlt:R

- ~~~-_.-
VOLATII.ES
I) - Di<1I"'_'"
TcuIC""'-"'''
T,,,,""'''''''''
Chiou"".
1'01.....
TABLE 12
SELECTED SAMPLE RESULTS - BACKGROUND SURFACE WATE~/SEDIMENT
._..-_. - . - .-.- ---- -.---    -..  ------- 
   CMSWII (:MSIJI I CMSWI2 CMSDI2 CMSIJII CMSUI' CMS"" CMSW
   WI.,.I WI.,.I  WI.,.I WI.,.I WI.,.I WI.,.I WI.,.I WI
I'AMINA"T  .... _!"JI~I - .- !'t!: ..". -5'. ~_.. 8I1f'. ..,..
o ._o._....-------~._.. - -. 
  NO ND  NO ND ND ND NO NO
  J7 ZI  ZO Z6 IJ 41 to 90
  ND ..,  NI> .54 .14 .)'1 .68 NO
  ND ND  NI) ND NO ND NO NO
  "0 ZZ  "0 6Z II 140 UO NO
  NO ND  "D ND ND NO "D NO
  ND "  ND II "D 51 ., ND
  "D III  ND UJ 4.5J U 16.1 IJ
  ND UI  ND .59J .111 .19J .14J NO
  ND ..  ND ZJ 1.1J J6 . NO
  ND IJO  NO "I 52 11 "I 41
  NO NO  NO NO .61J I.U UJ ND
    NO   ND NO NO ND NO
.. ..        
  &J   NO     
  W   NO     
  4J   NO     
  NO   11     
,''',, ND   NO     
._0-  -    NO(Z)    
PlllTICIDIIS ND III  ND (J) N0(41 UI NO
  NO II)  NO (1) (J) (4) (5) ND
MrOUNDS NO 11.51  NO WJ.U ''''.,, S(J." Int... --~!>
c:c IN'
11  CMSnl1 (:MSWM CM
I   WI.,.. WI.,.I W
-- ...~'I_- .. .!'tfI~_... . - .
   NI) NI)  
  .. n 41  
 .'  .54   
   NO  
   ND NO  
   II Nn  
   ND NO  
   ND ND  
   IU NO  I
   .115 NO  
   ND ND  
   .1 --2~  I
..   ND ND  I
   NO   
    11  
    II  
    4J  
    -- - 
  ~~ NO  
   (') ND  
 --  1nOJ -  
tit
sn..
I.,.
!!I1~L
-- 
 CMSW.
I WI.,.I
 .8IIL
- -
 NO
 t)
 NO
 NO
 NO
 NO
 NO
 19
 NO
 ZJ
 ZI
- ---
 NO
 --
 ND
 NO
 -~~
 NO
f
UJ
ss
811
NO
811
U
Z'
U
HI)
52
10
11
ocw
IIrc>8OOdicll"'-
~~~~Tlli~ --!!)
!!u -1!l-
~!!I~~!EO CO val
I) TIle ,......., ,....ic... ... de.rclCld: Diclllyl ""~'" (1111"81'1); OJ -.- bulyl '111"'''1' 15J .1I'c). Dc.... II8IIa ......"- .41"", 10 I.' 8l1l'i- 0.. TIC - .,rcled: O_IIIyI....lallOic Arid. &"'IIJIcIU. ('00 JH "II'c).
1) DcI«....1i8iI1 ...acd 11- .41 8II'c 10 1.0 "81'1. 0.. TIC - deleclCld: 1Ir"""'- (tOO IN uII'I)'
. J) TIle '''''''''''' ,....ic...... delecled: Fha..IIIe.. (1001""". 1I....(b"""" ') R,........... (2tII ...,..); ca..,.... (IU uII'I); IIb(Z-&lIyIIIcql)hI""',,, (nOh8l'l); Oi-.-O..IJ!"'III,,,,., (56.1"81'1); .8d 4,4- DOli (I 8J "IILI).
Sea--lile dclali081i8i1a ruacd Ir- .411811'8 10 1.1 811'c. 0.. TIC - delecled: 1Ir"""'- (SOlIN...,..).
. '4) ~""""iIe dclali08li- ruacd 1r-.4I .81'1101.1 811'c. TICa 1"" .re deleclCld.."" 1Ir............ (4OO.IN uII'I); ud Propa_IoI, OiKetate (ZOOIN uII'I).
5) S."""". dclCl
-------
    TABLE 12 (cont.)  
   Selected Analytical Resuns for Background Surface Water and Sediments 
  CMSW01 CMSD01 CMSW04 CMSD04 CMSW05 
  1/9/91 1/9/91 1/9/91 1/9/91 9/16/91 
. . "g,Il mg/kg " m k a  
Metals       
 Arsenic ND ND ND ND ND ND
 Barium 28 57 83 92 220 42
 Beryllium ND ND 'ND ND ND " '.48
 Cadmium ND ND ND ND ND ND
 Chromium ND 16 10 22 ND 11
 Cobalt ND 12 ND 14 ND ND
 Copper 7J 21 15J 15 ND ND
 lead ND 19J 10J 25J 53 13J
 Mercury ND ND ND .25 ND .4J
 Nickel ND 18 ND ND ND ND
 Zinc 810 140 79 77 130 42
Other       
 Cyanide ND ND 6.2 ND ND ND
Volatiles  ND ND ND ND ND ND
Semi .VolatilesJPest ND ND(1) ND ND(2) ND ND (3)
 Fluoranthene      .046J
TICs  ND ND ND ND ND 
 Bromohexane      .7JN
Dlfluorochlorobutanone      .9JN
Unidentified Canpounds (b) ND ND ND ND ND 9/10
" (1) - Detection linlts ranged from .82 mglkg to 4.0 mg/kg
(2) '- Detection linlts ranged from 1.4 mglkg to 6.9 mg/kg
(3) - Detection linlts ranged from .43 mglkg to 1.0 mglkg
(4) - Detection tin Its ranged from .43 mglkg to 1.1 mg/kg
(a) Reported on a dry weight basis. 53% moisture content may bias results upward as a calculation artifact
(b) -1- first number Indicates total number of compounds present; second concentration
NO Not detecled
J ' E slmaled value
IN r sima led value, pr~~urTI~~ P!es!~L--------_..
.------- -------
pdh\cm4 - 8 ...
CMSW14 CMSD14 
9125/91 9/25/91 
l m k 
ND ND 
45 180 
ND 3.1 
ND ND 
8J 15 
ND 31 
11 11 
ND 4J 
ND 1.3J 
ND 15 
430 140 
ND ND ~
  ....
ND ND t
ND ND(4) 
ND ND 
ND
ND

-------
-42-
VI. SUMMARY OP SITH RISKS
The JFD Electronics/Channel Master Site is releasing
contaminants into the environment. The Baseline Risk
Assessment 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 if no remedial action is taken at the
Site. Actual or threatened releases from the Site, if not
addressed, may present an imminent and substantial
endangerment to public health, welfare, or the environment.

The Baseline Risk Assessment consists of the following
sections: identification of chemicals of potential 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 were reviewed and evaluated to
determine the contaminants of concern at the Site which are
most likely to pose risks to public health or the
environment. These contaminants were chosen for each
environmental media sampled. Table 13 shows chemicals of
potential concern for soil/sediment and Table 14 for
groundwater and surface water.
Once these contaminants of concern were identified, exposure
concentrations in each media were estimated. The maximum
concentrations detected were compared to the calculated 95'
confidence level of the arithmetic average of all samples,
and the lower of these values was chosen as the estimated
exposure concentration. Table 15 shows the exposure
parameters u8ed to derive the chronic daily intake.
B.
EXDosure Assessment
The exposure assessment identified potential pathways and
routes for contaminants of concern. TWo overall exposure
conditions were evaluated. The first was the current land
use condition, which considers the Site as it currently
exists.

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,-
-43-
TABLI 13
CBEXICALS OF POTENTIAL CONCERN
FOR SLUDGE/SOIL/SEDIMENT
Sludge Drying Area Soil
Creek
Sediment
.......................-.............
Main Building Area Soil
......................-....
Shallow Int Deep '-""""'-
C1'-3') C5'.12') C15'-52') East South
Surface Shallow Int Deep
CO"-6U) C1'.3') C5'-12') C15'-52')
Organics:     
Acenaphthene     
Acenapthylene  X   
Aldrin  X   
Anthracene  X   
BenzoCa)anthracene  X   X
BenzoCa)pyrene  X   X
BenzoCb and/or k)fluoranthene. X   X
BenzoCg,h,i)perylene X   X
BisC2-ethylhexyl)phthalate  X  
beu-BHC     
g_-BHC  X  X 
Butylbenzylphthalate X   
Carbazole  X   
alpha-Chlordane  X   
,---Chlordane  X   
Chrysene  X   X
4,4-0DD  X   
4,4-0DE  X   X
4,4-00T  X X X X
1,2-0;chlorOithene CtoUl)    X
O;eldrin  X  X 
O;ethylphthalate     
Oi-n-butylphthalate  X X  
Endosulfan I  X   
Endosulfan sulfate     
Endr;n  X   
Fluoranthene  X   X
"l uorene     
Heptachlor  X   
Heptachlor Epoxide  X   X
IndenoC1,2,3-c,d)pyrene X   X
Methoxyc:lor     
Methyl ethyl ketone     
2-Methylnapthalene     X
Napthalene     X
4-Nitrophenol   X  
PCB' 1254    X  X
PCB' 1260   X   
Pentachlorophenol     
Phenanthrene  X   X
Phenol  X   
Pyrene  X X  X
Tetrachloroethene     
Trichloroethene     
Toluene     X
Trichloroethene     .X
.Xylenes Ctotal)     X
S.. footnotes on followh,. P8I8    
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
 X
 X
X 
X 
X 
X 
X 
 X
X
X
X

X
X
X
x
X
X
X
X
X
X
X   
X  X
x  X
x X  X
X   X
 X X 
 X  
X X  

-------
-44-
TABLB 13 (cont.)
CHEMICALS OF PO'l'D'l'IAL COMCERH
FOR SLUDGE/SOIL/SEDIMENT
Sludge Dry;ng Are. So;l
Main Bu;ld;ng Are. So;l
CrHk
Sediment
----..........---........--..........
-....-...............-.....
Surflce Shillow Int Deep
(on.6n) (1'-3') (5'-12') (15'-52')
Shillow Int Deep -...--...---
(1"3') (5'-12') (15"52') Elst South
lnorganics:       
Antimony X X     
Slri"", X    X  
Seryll i"",  X  X   
Caani"", X X  X   
ChrOllli"", X X  )( )( X X
Cobalt    )(   
COJIPer )( )( )( )( )( )( X
CYlnide X X X X  )( X
Lead  X ,"    X
"Inglnese )(  )(  X  X
Nickel X X X )( X X X
Zinc X X X    
X . Selected IS I chemical of potentill concem.     
(a) Chemicals selected in this table Ire potentially rellted to fOnler on.site activity and Ire above
background concentrltion.
. .

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-45-
TABLI 14
CBBKICALS OF PO'l'BN'l'IAL CONCERN
FOR GROUNDWA'l'ER/SURPACE WA'l'ER
ensite Gr~.ter
Offsite Groundw.ter
Creek
Surface Water
-.....------------....--
--.----------..-.--.-..-
..........--...
Shallow Inter. Bedrock
Sh.llow Inter. Bedrock
East
South
Organics:        
Acetone X       
Benzene X       
alpha-BHC     X   
Broaodichloromethane       X 
Carbon Oisulfide       X 
Carbon Tetrachloride X       
Chlorofol'll X      X X
1,1-0ichloroethane X    X   
1,1-0ichloroethene X  X     
1,2-0ichloroethane X       
1,2-0ichloroethene etot.l) X  X X X   X
cis-t,2-0ichloroethene    X X X  
Oiethylphthalate X   X    
Oimethyl phth.late X       
Oi-n-butylphth.late       X 
Ethylbenzene X       
Methyl butyl ketone X       
Methylene Chloride X       
Napthalene X       
2-Nitropnenol   X     
Phenol   X  X   
Tetrachloroethene X  X X X X  X
Trichloroethene X   X X X  X
Toluene X       X
1,t,t-Trichloroethane X  X     
1,t,2-Trichloroethane X  X     
Trichloroethane   X     
Vinyl Chloride X  X     
Xylenes (total) X       
lnorganics:        
BariUII X  X X X   X
Beryl I hili X       
Cacini UII -- - ;  X X   
ChromiUII X  X X X X X 
C~r X  X X    
Cyanide     X   
Lead X   X X   X
Manganese X  X X X X  X
Mercury X       
Mo I ybdenun     X X  
Nickel X   X X   
Vanadillll X  X X X   
Zinc X   X X   
X . Salected - . dM8ical of potential concem.     
ea) Ch..icals ..lected in this tlbla ara potentially r.lated to fOn81r on-sit. activity and 
are above b8cItlnard concentr.tions.      

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-46-
TABLE 15

EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION
OF SURFACE SOIL/SEDIMENT
CURRENT LAND-USE CONDITIONS
Parameters
Facility
Worker
Utility
Worker
Soil Ingestion Rate (mg/day) (a)
Fraction Ingested (dimens;onless) (b)
Exposure Frequency (days/year) (c)
Exposure Duration (years) (d)
Body Weight (kg) (e)
50
1
480
250
25
7
70
70
Period Over Which Risk is Being Estimated (years)
Carcinogenic (f)
Noncarcinogenic
70
25
70
1
(a) Ingestion rate for facility workers is the standard default value for adult soil ingestion in the
workplace based on USEPA (1991a). Ingestion rate for utility workers based on OSWER
Directive 9285.6-03 (USEPA 1991a) for shon-term activities.
(b) A probability of comact factor (FI) of 1 was conservatively used based upon USEPA Region IV
direction.
(c) Value for a facility worker is based on USEPA (1991a) at the request of USEPA Region IV. A
utility worker is assumed to work 30 days over a one-year period.
(d) Value for facility workers based on USEPA (1991a). A utility worker is assumed to conduCt
work at the site over a period of one year.
(e) Standard.default value provided by USEPA (1991a. 1989a).
(f) Based on USEPA (1991a. 1989a) standard assumption for lifetime. This value is used in
calculating exposures for potential carcinogens.

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-47-
TABLE 15 (cent.)

EXPOSURE PARAMETERS FOR DERMAL CONTACT
WITH SURFACE SOIUSEDIMENT
CURRENT LAND-USE CONDmONS
  Facility Utility
Parameters  Worker Worker
Skin Surface Area Available for Comact (cm2) (a) 1,960 3,120
Soil to Skin Adherence Factor (mg/cm2) (b) 1.45 1.45
Dermal Absorption Factor (dimensionless) (c)  
Organics '. 0.01 0.01
Inorganics  0.001 0.001
Exposure Frequency (dayS/year) (d) 250 7
Exposure Duration (years) (e) 25 1
Body Weight (kg) (f) 70 70
Period Over Which Risk is Being Estimated (years)  
Carcinogenic (g) 70 70
Noncarcinogenic 25 1
(a) Values based on USEPA (1991a. 1989b). Value for the facility worker is the mean surface area
for hands and forearms. Value for the utility worker is the mean surface area for hands and
arms.
(b) Value based on USEPA (1989a) for commercial potting soil.
(c) Based on Region IV guidance.
(d) Value for facilitY worker based on USEPA (1991a) at the request of USEPA Region IV. A utility
worker is assumed to work 7 days.
(e) Value for facility workers based on USEPA (1991a). A utility worker is assumed to conduct WOI
at the site over a period of one year. .
(f) Standard default value provided by USEPA (1991a. 1989a).
(9) Based on USEPA (1991 a. 1989a) standard assumption for lifetime. This value is used in
calculating exposures for poIentiaJ carcinogens.

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-48-
TABLE 15 (cont.)

EXPOSURE PARAMETERS FOR INCIDENTAL INGESTION
OF SURFACE SOIL/SEDIMENT
FUTURE LAND-USE CONDmONS
Parameters
Residents
Child 
(1-6 years) Adult
200 100
1 
170 170
6 30
15 70
70 70
6 30
Soil Ingestion Rate (mglday) (a)
Fraction Ingested'.(dimensionless) (b)
Exposure Frequency (days/year) (c)
Exposure Duration (years) (d)
Body Weight (kg) (e)
Period Over Which Risk is Being Estimated (years)
Carcinogenic (t)
Noncarcinogenic
(a) Based on USEPA (199180 1989a).
(b) A probability of contact factor (FI) of 1 was conservatively used based upon USEPA Region IV
direction.
(c) Values for adult and child residents are based on 5 days/week during the warmer months. April
through October, and 1 day/week during November through March (USEPA Region IV).
(d) Values based on USEPA (1991a). Adult duration is the national upper-bound time at one
residence ~SEPA 1991 a).
(e) Standard default value provided by USEPA (199180 1989a).
(t) Based on USEPA (199180 19898) standard assumption for lifetime. This value is used in
calculating exposures for potential carcinogens.

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-49-
TABLE 15 (cont.)

EXPOSURE PARAMETERS FOR DERMAL CONTACT
WITH SURFACE SOIUSEDIMENT
FUTURE LAND.USE CONDmONS
Parameters
Residents
Child 
(1-6 years) Adult
3,140 1,960
1.45 1.45
0.01 0.01
0.001 0.001
170 170
6 30
15 70
70 70
6 30
Skin Surface Area Available for Contact (cm2) (a)
Soil to Skin Adherence Factor (mg/cm2) (b)
Dermal AbsorptiQn Factor (dimensionless) (c)
Organics
Inorganics
Exposure Frequency (days/year) (d)
Exposure Duration (years) (e)
Body Weight (kg) (f)
Period Over Which Risk is Being Estimated (years)
Carcinogenic (g)
Noncarcinogenic
(a) Surface area for child residents is based on the recommendation of USEPA Region IV,
assuming hands, arms and legs are uncovered and exposed. Value for the adult resident is
the mean surface area for hands and forearms (USEPA 1991a, 1989b).
(b) Value based on USEPA (1991 a) for commercial potting soil.
(c) Based on Region IV guidance.
(d) Values for child and adult residents are based on 5 days/week during the warmer months.
April through October. and 1 day/Week during November through March (USEPA Region IV).
(e) Values based on USEPA (1991a). Adult duration is the national upper-bound time at one
residence (USEPA 1991a).
(1) Standard default value provided by USEPA (1991a, 1989a).
(g) Based on USEPA (1991a, 1989a) standard assumption for lifetime. This value is used in
calculating exposures for potential carcinogens.

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-s~
TABLE 15 (cant.)

EXPOSURE PARAMETERS FOR DERMAL ABSORPTION OF CHEMICALS
IN SURFACE WATER
FUTURE LAND-USE CONDITIONS
Parameters
Skin Surface Area Available for Contact (cm2) (a)
Dermal Permeab~ity Constant (cm/hr) (b)
Exposure Time (hours/day) (c)
Exposure Frequency (days/year) (d)
Exposure Duration (years) (e)
Average Body Weight Over Exposure Period (kg) (f)
Period Over Which Risk is Being Estimated (years)
Carcinogenic (g)
Noncarcinogenic
Residents
Child 
(1-6 years) Adult
1.721 3.846
8x1 O~ 8x1 O~
4 2
170 170
6 30
15 70
70 70
6 30
(a) Values for child and adult residents are the mean surface areas for hands. lower legs. and feet
(USEPA 1989b).
(b) Based on USEPA (1989a). Assumes all chemicals penetrate the skin at the same rate as
water. It should be noted that there is some uncertail'!tY associated with this value. A more
recent detmal permeability constant for water of 1x10-3 cm/hr (USEPA 1992) could be applied.
This value !jiffers from the permeability constant used in this evaluation (8x1 O~ cm/hr) by a
factor of 1.25. and therefor'.! there is no significant difference between these two constants.
(c) Assumes a child would spend 4 hours per day and an adult would spend 2 hours per day in
creek surface water.
(d) Values for child and adult residents are based on 5 dayS/week during the warmer months, April
through October. and 1 day/week during November through March (USEPA Region IV).
(e) Values based on USEPA (1991a). Value for the adult resident is based on the upper bound
time at one residence (USEPA 1991a).
(f) Standard default value provided by USEPA (199180 1989a).
(g) Based on USEPA (199180 1989a) standard assumption for lifetime. This value is used in
caIcuI8Iing exposures for potential carcinogens.

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-51-
TABLE 15 (cent.)

EXPOSURE PARAMETERS FOR INGESTION
OF GROUNDWATER
FUTURE LAND-USE CONDmONS
Resident
Parameters
Child
(1-6 yrs)

1
Adult
Ingestion Rate (liter/day) (a)

Exposure Fr~uency (dayS/year) (b)

Exposure Duration (years) (c)

Body Weight (kg) (d)

Period Over Which Risk is Being Estimated (years)
Carcinogenic (e)
Noncarcinogenic
350
6
2
350
15
30
70
70
6
70
30
(a) Value for a 1-6 year old resident is based on the recommendation of USEPA Region IV.
Value for adult resident is based on USEPA (1991a).
(b) Values for child and adult residents are based on USEPA (1991a).
(c) Values based upon USEPA (1991a). Value for the adult resident is based on the upper
bound time at one residence (USEPA 1991a).
(d) Standard default value provided by USEPA (1991a. 1989a).
(e) Based on USEPA (19918, 1989a) standard assumption for lifetime. This value is used in
calculating exposures for potential carcinogens.

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-52-
The second was the future land use condition, which evaluates
potential risks that may be associated with any probable
change in Site use assuming no remedial action occurs.

The exposure pathways that were evaluated under current land
use conditions were as follows:
*
Incidental ingestion and dermal absorption of
surface soil/sludge in the sludge drying bed area by
facility workers;

Incidental ingestion and dermal. absorption of
shallow soil/sludge in the sludge drying bed area by
utility workers; and
*
Incidental ingestion and dermal absorption of
shallow soil/sludge in the main building area by
facility workers.

The exposure pathways that were evaluated under future land
use conditons were:
*
*
Incidental ingestion and dermal absorption of
surfa~e soil/sludge in the sludge drying bed area by
child .or adult residents;

Incidental ingestion and dermal absorption of
shallow soil/sludge in the main building area by
child and adult residents;
*
*
Incidental ingestion and dermal absorption of creek
sediment by child and adult residents;

Dermal absorption of creek surface water by child
and adult residents;
*
*
Dermal absorption and inhalation of volatile
chemicals in shallow/intermediate groundwater by
child and adult residents while showering; .

Dermal absorption and inhalation of volatile
chemicals in bedrock groundwater by child and adult
residents while showering;
*
*
Ingestion of shallow/intermediate groundwater by
child and adult residents; and
*
Ingestion of bedrock groundwater by child and adult
residents.

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1-
C.
Toxicity Assessment
-53-
Under current EPA guidelines, the likelihood of adverse
effects to occur in humans from carcinogens and
noncarcinogens are considered separately. These are
discussed below. The toxicity of the contaminants of concer:
are presented in "IRIS" - EPA's Toxicity Data base.
Carcinoaens
EPA uses a weight of evidence system to classify a chemical' I
potential to cause cancer in humans. All evaluated chemical I
fall into one of the following categories:
Group A chemicals
Group B chemicals
B1 chemicals
Group C chemicals
Group D chemicals
Group E chemicals
Noncarcinoaens
- known human carcinogen
- probable human carcinogen
limited human epidemiological
evidence
- possible human carcinogens

- not classified to human
carcinogenicity
- evidence of non-
carcinogenicity in humans
Health criteria for chemicals exhibiting noncarcinogenic
effects are generally developed using verified risk referencI
doses (RfDs) and reference concentrations (RfCs). These are
developed by USBPA's RfD/RfC Work Group or are obtained from
the Agency's IRIS data base or Health Effects Assessment
Summary Table (BEAST). The RfDs, expressed in units of
mg/kg/day, are lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes 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 RfD
will not underestimate the potential for adverse
nonca~cinogenic effects to occur.

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-54-
D. Risk Characterization
Table 16 shows the final contaminants of concern for the
media of concern. To quantitatively assess the risks of
these contaminants from the Site, the chronic daily intakes
(CDIs) were combined with the health effects criteria.
For potential carcinogens, excess lifetime upperbound cancer
risks were obtained by multiplying the estimated CDI for each
chemical by its cancer slope factor. The total upperbound
excess lifetime cancer risk for each pathway was obtained by
summing the ch~cal-specific risk estimates. A cancer risk
level of 1 x 10- represents an upper bound probability of
one in one million that an individual could develop cancer
due to exposure to the potential carcinogen under the
specified exposure conditions.

Potential risks for noncarcinogens are presented as the ratio
of the CDI to the reference dose for each chemical. The sum
of the ratios of all chemicals under consideration is called
the hazard index. The hazard index is useful as a reference
point for gauging that the potential exists for adverse
health effects to occur from the assumed exposure pathways
and durations,. and that remedial action may be warranted for
the Site.
Table 17 summarizes the quantitative estimates of
carcinogenic and noncarcinogenic risk under the current and
future land use scenario for each exposure pathway evaluated
in the risk assessment, respectively.
E. Environmental (Ecoloaical) Risk
Potential ri.k. to environmental receptors at or near the
Site were evaluated based on Site sampling data and a review
of the toxicity of the chemicals of potential concern to
ecological receptors. Use of the Site, particularly the
sludge drying bed area or the main building area, by
terrestrial receptors such as birds and small mammals was
considered unlikely, given the lack of trees or other cover
at the Site. Therefore, the focus of the ecological
assessment was on the intermittent creeks east and south of
the site and the small low-lying area south of the railroad
tracks. Although these creeks do not contain sufficient
water to sustain fish populations, populations of aquatic
insects could occur there.

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-55-
TABLE 16
Contaminants of Concern
Channel Master Site
Medium/ Area
Organics
lnorganics

Barium
Chromium
Copper
Lead
Nickel
Zinc
Cyanide
Groundwater
Benzene
1,2-Dichloroethane
1,l-Dichloroethene
1.2-Dichloroethene
T etrachloroethene
1.1 , I-Trichloroethane
Trichloroethene
Vinyl chloride
Sludge-drying beds/Soil
None
Antimony
Cadmium
Chromium
Copper
Cyanide
Nickel
Zinc

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-56-
TABLE 17
SUMMARY OF TOTAL CARCINOGENIC RISKS
FOR THE CHANNEL MASTER SITE
Cancer Risk
Due to All Chemicals
...........................-.-.--.-.---.-..----.
Area/Pathlilay
Current
Faci! i ty
Worker
Future Chi Id
Resident
Future Adul t
Resident
Sludge Drying Area:
Incidental Ingestion Surface (0"-6") Soil:
Dermal Abso~tion Surface (0"-6") Soil:
Derm.1 Absorption 5/1 Groundwater:
3E-06
2E-06
IIE-06 4E-06
2E-06 1E-06
1E-05 4E-05
1E-02 2E-02
1E-03 1E-03
1E-02 2E-02
Ingestion 5/1 Gr~ater:
Inhalation VOCs 5/1 GroundWater:
TOTAL:
5E-06
Main Building Area:
Incidental Ingestion Shallow (1'-3') Soil:
Denl81 Absorption Shallow (1'.3') Soil
Derm.1 Abso~tion 5/1 GrCU1dw8ter:
2E-06
1E-06
7E-06 4E-06
1E-06 1E-06
1E-05 4E-05
1E-02 2E-02
1E-03 1E-03
1E-02 2E-02
Ingestion S/I Groundlilater:
Inhalation VOCs 5/1 Groundlilater:
TOTAL:
3E-06
East and South Creeks:
TOTAL:
6E-06 3E-06
1E-06 9E-07
4E-08 4E-08
1£-06 4E-06
Incidental IngeStion Creek SediMnt:
Derm.1 Absorption Creek SediMnt:
Dermal Absorption Creek Surface Water:

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-57-
TABLB 17
( cent. )
SUMMARY OF TOTAL NONCARCINOGENIC RISKS
FOR THE CHANNEL MASTER SITE
Noncaneer Risk
Due to All Chemicals
.......-.-......................................
Area/Pathway
Current
Flci l ity
Worker
Future Chi ld
Resident
Future Adult
Resident
Sludge Drying Ar.a:
Incidental Ingestion Surface (oa-68) Soil:
Ingestion S/I GrOll1dwater:
Inhalation VOCs S/I GrOll1dwater:
>1 (a) >1 (b) >1 (c)
2E-01 SE-01 1E-01
 > 1 (d) >1 (e)
 >1 (f) >1 (9)
 ze.01 5E.02
Dennal Absorption Surface (oa.6") Soil:
Del'1ll81 Absorption. S/I GrOll1dwat.r:
Mlin Building Ar.a:
Incidental Ingestion Shallow (1'.3') Soil:
Denial Absorption Shallow (1'-3') Soil
Inhalation VOCs S/I GroundNater:
9E-03 1E-01 1E-02
6E-Q4 3E-03 4E-Q4
 >1 (d) >1 (e)
 >1 (f) >1 (9)
 ze.01 5E.02
DeMl8l Absorption S/I Gr0undw8ter:
Ingestion S/I GroundNater:
East and South Creeks:
Incidental Ingestion Creek Sedi..nt:
Dermal Absorption Creek Sedill8nt:
9E.01
ze-02
1E-01
3E-03
Dermal AbsorptiOn Creek Surface Wat.r:
2E-02
4E-03
(I) The hazlrd index .xceeded one for CNS (2.3) .
(b) The hlzard index .xceeded one for eNS (30), lover body weight (2.5), and blood chemistry (1.9).
(C) The hazard index exceeded one for eNS (3.2).
(d) The hazard index exceeded one for liver (3.6).
(e) The hazard index .xceeded one for liver (2.0).
(f) The hlzard index exceeded one for liver (>3,000), CNS (80), kidney (41), hematology (19),
increased blood pressure (11), lover body weigtlt (4.9), pstrointestinal irritation (4.5),
myelin detr8d8tion (3.0), ln88il (1.3), and total tu.or (1.1).
(9) The hazard index exceeded one for liver (>1,000), CNS (34), kidney (18), hematology (7.9),
incr.U8d blood pressure (4.7), lover body weight (2.1), gastrointestinal irritltion (1.9),
and ~U" d8tr8d8tion (1.2).

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-58-
Ambient water quality criteria are considered inappropriate
for the limited aquatic receptors at this Site, because they
incorporate toxicity data from sensitive fish species such as
trout that would not occur in these creeks. Therefore,
potential impacts to the aquatic receptors at the Site were
evaluated by comparing average and maximum surface water
concentrations with invertebrate aquatic toxicity data.
Potential impacts from exposure to sediment were evaluated by
comparing averaqe and maximum sediment concentrations with
sediment toxicity values.

Based on these comparisons, it is possible that the presence
of elevated levels of sodium in surface water may be
impacting freshwater aquatic life, especially in the creek to
the south of the Site. It is also possible that some
sensitive aquatic invertebrates could be adversely affected
by chromium, nickel, and some PABs present in the sediment at
sample locations such as CMSD06. Limited cover at the Site
limits its value as habitat for terrestrial species. Based
on a qualitative analysis, terrestrial wildlife communities
in the low-lying and wooded areas near the site are not
likely to be significantly impacted.
Additional sampling of the intermittent creeks and the
downstream tri~utary is needed during the Remedial Design to
define the downstream extent of surface water or sediment
contamination. A rapid bioassessment and surface
water/sediment toxicity testing is also needed to determine
if remedial action is warranted.
VII. APPLIOAT.. OR RBLBVAR'l' ARD APPROPIUAD RBQUIRBMBR'l'S

Section l21(D) of CERCLA, as amended by SARA, requires that
remedial actions comply with requirements or standards set
forth under Pederal and State environmental laws. The
applicable or relevant and appropriate requirements (ARARs)
that must be complied with are those that are (A)
action-specific, (B) location-specific, or (C)
chemical-specific at the Site. Thus, ARARs are used to
determine the appropriate extent of Site cleanup, to scope
and formulate remedial action alternatives, and to govern the
implementation and operation of the selected action. "To be
considered" materials (TBCs) are non-promulgated,
non-e~forceable advisories, guidelines, or criteria issued by
federal or state governments (e.g., reference doses and
carcinogenic po~ency factors) that may be useful for
developing remedial action alternatives or for determining
what is protective to human health and the environmen~.

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-59-
A.
Action-Specific ARARs
Action-specific requirements set controls or restrictions on
the design, performance, and other aspects of implementation
of specific remedial activities. A retained alternative mus1
conform with all ARARs unless a statutory waiver is invoked.
The action-spec~fic ARARs pertaining to the Site include:
Resource Conservation and Recovery Act (as amended) (42
U.S.C. 55 6921-6939 (5 3001-3019); 40 C.F.R. Parts 260-71)
Regulates the treatment, storage, and disposal of hazardous
waste from generation through ultimate disposal,

Safe DrinkinQ Water Act (SDWA) Primary Maximum Contaminant
Levels (MCLs), (42 U.S.C. 5 1412 (5 300g-1); 40 C.F.R.
141.11, 141.61) Establishes primary MCLs adopted for the
protection of human health but include an analysis of
feasibility and cost of attainment,
SDWA Secondary Maximum Contaminant Levels (SMCLs), (42 U.S.C.
5 1412 (5 300g~1); 40 C.F.R. 143.3) Establishes unenforceablE
secondary MCLs regulating the aesthetic quality of drinking
water, ,
SDWA Maximum Contaminant Level Goals (MCLGs), (42 U.S.C. 5
1412 (5 300g-1); 40 C.F.R. 141.50) Establishes unenforceable
MCL goals based on health criteria and used for the nation's
water supply,

Clean Water Act (CWA) DischarQe Limitations, (33 U.S.C. 5
1311 (5 301); 40 C.F.R. Parts 122,125, 129, 133, and 136)
Requires the U8e of best available technology economically
achievable to control discharge of toxic pollutants to POTW,
CWA Pretreatment Standards, (33 U.S.C. 5 1317 (5 307); 40
C.F.R. 403.5) Prohibits the unpermitted discharge of dny
pollutants or combinations of pollutants to waters of the
u.S. from any point source,

Department of TransDortation (DOT) Hazardous Materials
TransDortation Act (49 U.S.C. 55 1801-12; 49 C.F.R. Parts
107, 171-179) Regulates the labelling, packaging, placarding
and tran~port of hazardous materials off-site,
. .

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-60-
OccuDational Safety and Health Administration (OSHA) (29
U.S.C. 5 651 et seq.; 29 C.F.R. Parts 1910.120, (.1000
-.1500), and 1926.53, (.650-.653», Occupational safety and
health requirements (1910.120) for hazardous substance
response actions under CERCLA establish safety and health
program requirements that must be implemented in the cleanup
phase of a CERCLA response. These standards govern CERCLA
response actions involving any type of hazardous substance
that may result~ in adverse effects on employee health and
safety. The provisions of 29 C.F.R. 1926.650-.653 are
applicable to any excavation, trenching, and shoring that is
undertaken as part of the construction of trenches, cut-off
walls, etc.,
North Carolina Hazardous Waste Manaqement ReQUlations (NCAC,
Title 15A, Chapter 13A, Sections .0009, .0013), Provides
standards for owners/operators of hazardous waste treatment,
storage, and disposal facilities,

North Carolina Solid Waste DisDosal Requlations (NCAC, Title
15A, Chapter 13B), Provides design, operation, and closure
requirements for solid waste disposal facilities,
North Carolina Groundwater Standards (NCAC, Title 15A,
Subchapter 2L), Establishes groundwater restoration goals and
criteria for termination of restoration activities,
North Carolina Water Qualitv Standards (NCAC, Title 15A,
Subchapter 2B), Establishes effluent limitations, in terms of
both quantity and quality, for point discharges to surface
water bodies,
Wastewater Discharqe to Surface Waters (NCAC, Title 15A,
Subchapter 2&), Regulates surface water discharge and
discharges to POTW,

Clean Air Act lCAA) National Ambient Air Qualitv Standards
(42 U.S.C. 5 109 (5 7409); 40 C.F.R. Part 50), Establishes
emissions standards, monitoring and testing requirements, and
reporting requirements for eight pollutants in air emissions,
CAA New Source Performance Standards (42 U.S.C. 5 7411 (5
111); 40 C.F.R. 60), Establishes standards of performance for
new air emission sources,

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-61-
North Carolina Air Pollution Control Reauirements (NCAC,
Title 15A, Subchapter 2D), Regulates air pollution, air
quality, and emissions standards, and
North Carolina Sedimentation Control Rules (NCAC, Title 15A,
Subchapter 4) Provides requirements for the prevention of
sedimentation pollution.
8.
Location-SDecific ARARs
Location-specific ARARs must consider Federal, State, and
local requirements that reflect the physiological and
environmental characteristics of the Site or the immediate
area. Remedial actions may be restricted or precluded
depending on the location characteristics of the Site and the
resulting requirements.' The location-specific ARARs
pertaining to the Site include:
Classifications and Water Qualitv Standards ADDlicable
Surface Waters of North Carolina (NCAC 15A, Subchapter
Establishes surface water classifications for unnamed
tributary near Site, Fishing Creek, and Tar River,
to the
28)
RCRA Location8 Standards (42 U.S.C. 55 6921-6939 (5
3001-3019; 40-C.F.R. Parts 257, 264.18) A TSD facility must
be designed, constructed, operated, and maintained to avoid
washout along a 100-year floodplain. These requirements have
been adopted by the state of North Carolina, and are covered
in the North Carolina Hazardous Waste Management Regulations,

North Carolina Hazardous Waste ManaQement Regulations (NCAC,
Title 15A, Subchapter 13A, Section .0009) Establishes siting
and design requirements for hazardous waste treatment,
storage, and disposal facilities,
North Carolina Solid Waste Disposal Requlations (NCAC, Title
l5A, Chapter 138, Section .0503) Establishes siting and
desiqn requirements for solid waste disposal sites,

CAA National Ambient Air Oualitv Standards lNAAOSs) (42
U.S.C. 5 7409 (5 109); 40 C.F.R. Part 50) Establishes
emission standards to protect public health and public
welfare,
Fish and Wildlife Coordination Act (16 U.S.C. 661-666),
,Requires actions to protect fish and wildlife from actions
,modifying streams or affecting streams,
. '

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-62-
FloodDlain Manaaement Executive Act, (Executive Order 11988;
40 C.F.R. 6.302), Enforces that actions that are to occur in
a floodplain should avoid adverse effects, minimize potential
harm, restore and preserve natural and beneficial value, and
North Carolina Sedimentation Pollution Control Act (General
Statistics of North Carolina, Chapter 113A, Article 4),
Establishes mandatory standards for control of sedimentation
and erosion in streams and lakes.
C. Chemical-SDecific ARARs

Chemical-specific ARARs are concentration limits in the
environment promulgated by government agencies. Health-based
site-specific levels must be developed for chemicals or media
where such limits do not exist and there is a concern with
their potential health or environmental impacts.. Groundwater
cleanup levels for the Site are Safe Drinking Water Act
Maximum Contaminant Levels (MCLs) or North Carolina water
quality standards, whichever are more protective. These
groundwater levels are shown in Table 18. The potential
chemical-specific ARARs pertaining to the Site include:
SDWA MCLs (42 U.S.C. 5 1412 (5 300g-1); 40 C.F.R. Parts
141.11, 141.61r, Establishes health-based standards for
public water systems, for inorganics and organics,
respectively,
CWA Water Qualitv Criteria (33 U.S.C. 51314(a)(1)(5
304)(a)(1); 40 C.F.R Part 131), Sets criteria for water
quality based on toxicity to aquatic organisms and human
health,
RCRA (42 U.S.C. 55 6921-39 (55 3001-19); 40 C.F.R. Parts
260-271), Regulates the treatment, storage, and disposal of
hazardous waste from generation through ultimate disposal, as
well as the protection of groundwater at solid waste
management units,
CAA National Emissions Standards for Hazardous Air pollutants
(NESBAPS) (42 U.S.C. 5 109 (5 7409); 40 C.F.R. Part 61),
Provides emission standards for hazardous air pollutants for
which no ambient air quality standard exists, and may be
relevant and appropriate if on-site treatment units are part
of the remedial action,

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-63-
CAA National Ambient Air Qualitv Standards (NAAQSs) (42
U.S.C. 5 109 (5 7409); 40 C.F.R. Part SO), Sets primary and
secondary air standards at levels to protect public health
and public welfare, and may be relevant and appropriate if
on-site treatment units are part of the remedial action,
DOT Hazardous Materials TransDortation Act (49 U.S.C. 55
1801-12; 40 C.F~R. Pa~s 107, 171-9), Regulates the labeling,
packaging, placarding, and off-site transportation of
specific hazardous chemicals and wastes,
~ (29 U.S.C. 5 6S1; 29 C.F.R. 1910, Part 120), Sets
on exposure to workers on hazardous site or emergency
responses, sets mimimum health and safety requirements
as personal protection and training, and reporting
requirements,
limits
such
North Carolina Groundwater Standards (NCAC, Title 1SA,
Subchapter 2L, Section .0202), Bstablishes groundwater
classification and water quality standards,
North Carolina Drinkina Water Act (130A NCAC 311-327)
Regulates water systems within the State which supply
drinking water. that affect public health,

North Carolina ComDrehensive Bnvironmental ReSDonse Act (130A
310.1-310.23),
North Carolina Surface Water Qualitv Standards (NCAC, Title
1SA, Subchapter 2B) Bstablishes water quality requirements
applicable to all surface waters of North Carolina which
protect public health and the environment,

North Carolina Air Pollution Control Reauirements (NCAC,
Title 1SA, Subchapter 2D), and
North Carolina Solid and Hazardous Waste Management Act (130A
NCAC) .

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-64-
To be Considered Materials (TBCsI

"To be considered" materials (TBCs) are non-promulgated,
non-enforceable advisories, guidelines, or criteria issued by
federal or state governments that may be useful for
developing remedial action alternatives or for determining
what is protective to human health and the environment.
The following are several examples of TBCs for the Site:
EPA Groundwater Protection Strateqy (EPA 19841, Whose policy
is to protect groundwater for its highest present or
potential beneficial use. This policy will be incorporated
into future regulatory amendments, and

National Oceanic and Atmosheric Administration (NOAA)
ER-L/ER-M Values, Guidelines developed as screening criteria
for sediment to be protective of aquatic life.
Sludqe/Soil CleanuD Levels

There are no promulgated Federal or State standards
applicable to the contaminants in the sludge/soil at the
Site. Cleanup "levels have been calculated based on direct
exposure residential assumptions for contaminatign identified
in the sludge/soil. These levels are at the 10- end of
the protective risk range (risk that one person in one
million people would experience adverse health affects).
These levels were adopted as per OSWER Directive 9355.0-30.
Directive 9355.0-30 states that remedial action is warranted
under CERCLA where the Baseline Risk Assessment indicates
that Site ri.k to an individual exists. It was determined
that the Sit.'. future land use possibilities should include
a residential .cenario where a home with a basement is
constructed. Based on this scenario, the reasonable maximum
exposure for both current and future land use for the Site
indicates that the noncarcinogenic hazard quotient exceeds 1
for chromium, nickel, and antimony in those areas shown in
Figure 8. The total quantity of contaminate~ sludge/soil to
be remediated is estimated to be 3,000 yards.

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                -65-

              TABLE  18
GROUNDWATER REMEDIATION LEVELS (ug/1)
Contaminant
of Concern
Benzene
1 , 2-Dichloroethane
1, 1-Dichloroethene
1 , 2-Dichloroethene
Tetrachloroethene
1,1, 1-Trichloroe thane
Trichloroethene
Vinyl Chloride
Barium
Chromium
Copper
Lead
Nickel
Zinc
Cyanide
Detected Groundwater
Concentrations
1-6
2-11
1-1,200
6-2,900
52-11,000
1-490
46-360,000
3-1,400
53-12,000
8-1,400
19-2,600
30-270
42-1,500
34-4,000
800-1,100
Groundwater
Cleanup Levels
5
0.38
7
70
0.7
200
2.8
0.015
1,000
50
1,000
20
100
500
154

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                                                                                      SLUDGE OBY1NG PITS (APPROXIMATE)


                                                                                      WE* TO IE EXCAVATED TO I FT


                                                                                      AREA TO BE EXCAVATED TO S FT
                                                        SCALE IN FEET
20385 3C-I5.0CN 4/
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-67-
In order to be protective of human health usinq the residential
scenario, it was determined that cleanup levels for sludqe/soil would
be calculated based on direct exposure and would be applied to
sludqe/soil at depth. The health-based sludqe/soil cleanup levels
are identified in Table 19. This table also indicates the ranqe of
detected concentrations for those metals whose hazard index exceeded
1.
The remediation levels are based on direct exposure to contaminated
sludqe/soil via'incidental inqestion and dermal contact. The
followinq equation and exposure assumptions were used to calculate
the remediation or cleanup levels for chromium, nickel, and
antimony. All chromium present is assumed to be in the hexavalent
state.
TBI * AT * BW
EF*ED*[(1/Rfdo*FI*IR*CF)+(1/RfDa*SA*AF*AB*CF)]
where:
RfD~I
IR
TBI - Tarqet Bazard Index - 1
AT ~ Aver. time - 2,190 days (child), 8,760 (adult)
BW ~ Body Weiqht - 15 kq (child), 70 kq (adult)
EF - Exposure Frequency - 350 days/year
ED - "Exposure Duration - 6 yrs. (child); 24 yrs.
(adult)
- Oral Reference Dose (mq/kq-day)
- Fraction Inqested - 1
- Inq. Rate - 200 mq/day (child); 100 mqlday
(adult)
CF - Conversion Factor - 1E-06 kq/mq
Rfda - Adjusted Rfdo (5% oral absorp. eff.)
[mqlkq-day]
SA - Surface are - 3,140 cm2 (child); 3,120 cm2
(adult)
AF - Soil to Skin Adherance Factor - 1 mqlcm2
ABS - Dermal Absorption Factor - 0.001

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,
-68-
TABLE 19
SOIL REMEDIATION LEVELS
, (FOR THOSE AREAS SHOWN IN FIGURE 8)
CONTAMINANT
OF CONCERN
RANGE OF SOIL
CONCENTRATIONS
SOIL
CLEANUP LEVELS
Chromium (Cr.' ) 24-24,000 ppm 310 ppa
Nickel  10-11,000 ppm 1,100 ppm
Antimony  5.6-120 ppm 25 ppm

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I-

I
-69-
VIII. DESCRIPTION OP AL'l'BRHATIVBS
Table 20 summarizes the technologies considered for
remediating the groundwater and sludge/soil contamination,
respectively, at the JFD Electronics/Channel Master Site.
These tables also provide the rationale as to why certain
technologies were not retained for further consideration
after the initial screening.

. .
A.
Remedial Alternatives to Address
Groundwater Contamination
These groundwater alternatives were developed to address
groundwater contamination at the Site:

Alternative 1: No Action
Alternative 2: Alternate Water Supply, Closure of
Private Wells, Deed Restrictions, Monitoring

Alternative 3: Groundwater Extraction, Treatment with
Ultra-violet Radiation-Oxidation, and
Precipitation/Filtration
Alternative' 4: Groundwater Extraction, Treatment with
Alkaline Chlorination, Precipitation/Filtration,
Air Stripping, and Carbon Adsorption

Alternative 5: Groundwater Extraction, Treatment with
Alkaline Chlorination, Ion Exchange, Air
Stripping, and Carbon Adsorption
The remedial response actions to address groundwater
contamination are discussed below.
Alternative 11 Bo Action
No remedial action would be implemented for groundwater
contamination under this alternative. The No Action
alternative would include the posting of warning signs, a
5-year review of the remedy, as well as the initiation of a
public awareness program.
This alternative involves the following costs:
 Total Capital Costs  $170,000
 Total 0' M Costs  5329.000
 Total 'present Worth Costs $499,000

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Q8N.IIAL     PIIOC888    
".UON" AcnON ftCHNOLOQY   OPTION  DI""IPTION INITIAL ""alNiNG CO...NTe 
I NO ACTION   NONE   NOT APPLICABlE I- No rnadlal .ctln. Rltalnad II requlrld .. C£RCLA. 
  , ACCESS   DEED RESTRICTIONS I- All dlldllar PIOPlllr wNhln IICIItntlaly aanllmln.1Id ...... _IdlnWdI rlllrlctlonl on 1111... 01 Palanlllllr applicable. 
  RESTRICTIONS   ground". .nd lutull WIll drlilno. 
  AlTERNATE WATER I r CITY WATER ~ EJltllllan 01 0Xf0ld cIIy WI. 11l1li, louthWlnl,1Iang Hwy. 1510 mldllICII downglldllnl 01 contaminant Pallnlllily applicable. 
IINSTlTlITlDIW. ~   plume; IncUl. mandalllllal I8ldlntlln IIrvIcI.1I III conlllClld with city Wlllr. 
 ACTIONS  SUPPLY [1 NEW (D£EPER)   Nolapplcabla dUiIo ,,"1nCI oIlractUlld RICIIequN_lh.1 doll no! hIvI 
    WULS i- lntIalllllon 01-. uncontamlllllad ...11 (Individual or JoInt) lor "'"ad ",!dInll. .ny blnll"to mlcal (down..nI) mlIJdlon. 
  ~  t- SAll'LINGI i'" COlactlon .nd .naJyall 01 orounchnt. .nd IUrta Wli. Ampl. (from dlldlllrga'''"11o manNor  
  MONITORING AIW. VIIS conttnued _ment II1dgrounchntll qUIIIy IrIndi. PoIInllllly applicable. 
    r RCRA.TYPE CAP I- Multlmadll cap with low pallllllblilly. drain.. and wglllthtlarwt dulgnad 10 rlduOf Nolapplcabla; .ppllclllon UlUIIy IImllad 10 IOUrOf .,.1; 11IIII1CI1IIt In controlling 
    InIlltraIIonIWrllcaI_mll'll 01 contarnlnantl Into graundWltlr. grlllllllln. contamlnanl mlgllilon. 
  -t CAPPING U     
    , NON-RCRA CAP I- II'" or mulillynd 1011. ell" aneIIor IIMmel'll (COIICIIII. .pllal) cap dIIlgnad 10 rlduOf Not appIlcabll; UlUlIy Imlld 10 lOuru .,1.; IlIIIfactlvl In controlling 
    lnIUtr.tlanMrtlcal_mn 01 contamlnantllntograundWlllr. orounchnt. contaminant mlgrallon. 
      SLIlUtY WALLS .. ConItNctIon 011 wrtUllow ~meablllr IayIr thIough ..vallon 01 trlllell and ,*"Ilno with IOI~ Nol appIIcablllo IlICIulld loct lqull"; holtlOf\llly aantlnuOUl conIlnlno IIyIr 
I CONTAINMENT J- -t II£RTICAlIlARRIERS    IIInIOnb I"'" mlxtutl; mlnlmlnl groundWIIIl contaminant mlgrallon abowIl ....lIlIno c:onI1nlno II,.. nllllld lor Ilull'J WIIIIiIJ (bllow contamlnaled lOfII) II no! "lIInt. 
 GROUT CURTAIN I- ConIINciIon III . wrtlcallow ~meabilly 1ayIr. thraugh htgIt-pIt8UII InJICIlan 01 graul ~ ~ IpIC8d Not appIlcabll 10 IIIclUted roct .qull"; horllOf\tal cxlnflnlng IaJII II no! lIIIIanl. 
      bcnholll; mlnlmlal OlOuildwal8r contamlnanl mlOlllIon IbcM a ....latlng c:onIlnlno IIJIr. 
  ~ GRADIENT CONTROLS PUMPINGIINJECTION I- COntrol 01 OlOundwalat flow and IXIntamlnant tranaport IIIlng pumplno andJor InJlClIon WIlli. Nol appIicabll; InJection ..ohlbl1ed "lIdl rlOulJllDnl: ufl1Cl1on ..III would 
  IIQulr1 handling 01 aanlamlnaled groundwatll. 
        W"II and pumpa InItaIad wlhln ilia limN. ollila COI8mlnant pluml (or Immadlllily downgradlant) 10  I
    ~ EXTRACTION WElLS I- wllhdraw c:onIamlllltad grounchnt-; allO HMllo modlly hJdllullc OIIdlanta. Pal8ntlallr applcable. 
  -t EXTRACTION 11{ INTERCEPTOR t- A gravtl- or 1Ind-1HIId coIllctlon Itancll with parforalld plpaln III.; InItruplt OlOundWllIt now II1d  I
   Pallntlally applicable.
    DRAINS COIMJII a dlachlIOI point; Il1o .Mllo modlly ¥raullc Oradlant..  
      DEEP INJECTION ... InJlClIon oIllllractad groundwallr Inlo dIIp eqular ~nn IaoIIIId 110m lhallow equNa". Not appIicabll dill 10 Ibllnca III confining 1ayI" In 'licturad rodllQunll; In 
  ~ ONSITE OISCHARGE     addNlan.llall prohlbl11 In)ldlon oI...ln. 
I COlLECTION I  INFILTRATION  PIIcoIIIIan (1IChatgI1 01 unIt.1Id groundWItar Ullno graval- or lind-iliad Itancll. and low II1II11111 Not appIlcabll; would r.ulln IIChargl 01 IXInllmlnatld wit- Into lQunll and 
I DlsatARGE (     GALlE'" - dllltllullan ~am. c:onIaminatad 101. 
      ADJAaNT STREAM I- DIachIIOI 01 unltaalad graundwal8r 10 !nIItmNllnlllrllm lOutII 01 lb. PoIIntlallr applcable. 
  ~ OFfSITE DISCHARGE ~ POTW I- Dllellarga III UIItIaIId grounClWlllt to OXtord anqatratmal'll plant a.... ~a along Pilla Tr. PoIlntlally applcable. 
  Road. 
      OFFSITE DISPOSAL I- COIICIId graundWll8r .. haulad "lint truclllor dlallOlll.1 ""llr8tmllllltclJIy lleanlld to hand.. Not appIicabll dUilo high ¥OIume III groundwll. IIIaI mUll III 
      organic and inorganic WIIIn. Iranapot\8d. 
  i BiOlOGICAl. ~ BIODEGRADATION J- InJlClIon ...11 UIId 10 InJICI CIIII)'OIn and.'ol nulrtanll bIIow ..lIr tabla to IIIhlnCl maolllal Not appIicabll dill to anllOllOpic. hatllOQll1I018 aQuNar IXIndnlant and elllorlnalad 
  TREATMENT dIc:omPC8Nlon 01 organic contamlnantl. allphallc contamlnanta. 
I IN SITU r -tCHEMICAl TR~ CHEMICAl  InJICIIDn WIlli UIId 10 InJICI elllIIIIcaI oxldanlt bIIow ..IIr tabla to oxldla contamlnanta: alto Ulad 10 Not appIicabll dUiIo anllOllOpic. llalllOQll1I018 aQunll condNIant. 
TREATMENT OXIDATION  tnhanca bIoIogll:al actNIIy.  
  -t PHYSICAl TREATMENT VAPOR EXTRACTION t- A VIGIum II appilld 10 unsaturalld lOfIIand dlWll8r1d portlona ollila l8Iuralld lOfII; VlPOII .,a Nol appIlcIIIIlI dUi to anlIOIropic. hatlloganlOl8 aQuNlr condnlont 8nd elllorlnalld 
  coIIICIad on .urtaca In vapor.pIIa. calbon adIolfl\lon or alllar IJIIlm. allphallc contamlnantl. 
-.J
C
t 53 14\17
TABLE 20

Preliminary Identification and Screening of Technologies and
Remedial Process Options for Groundwater

-------
-        
       - 
OINIIiAL        
1118PON8I        
ACTION TlCHNOLOQY Pllool.. Ol'1'ION D1801I1I'1'ION INITIAL 801I1ININO COMMINT. 
   J-{ EXTJW:1IOI WEllS  WI" 1111 .."'" -'111 1- _-Id ,"ancI8IIw. PalontiIlIW l"a'lI. 
 ---4 EXTMC110I     
   8UBSURF.\CE DIWIIS  A .-~ o'.""'1od nlt""'...a wiIII,...1d ...1. ""11"""" --,..... III --of ,"unchnI. 1111 PallIIIIolIW l"a'lI. 
    co.., 10 ditcllorvo point. . 
    8Dl.WIT EXTJW:TIOII ~ ..... co_inInIIfro.. '"'..... tin,.. collllCt'" llIaIIII, 1m....11 liqlil'. 811I0Il... co-inInII .... I PallIIIiIlIW l"a'lI. 
    .,'111111". 
    CAR801 AOIOIIPI1DII  AI- d....... olpllco fro.. ,",undwIhr ....Id..1d COMO; _1IoIIiI.. IIMIon..rf8co 8IDICIIo. ....... - PallIIIIotv l"a'lI. 
     II1II iItomoI,oN ,.... eI.ldinlld CO".. 
    AlIWTWIITIUPPIIIII  wc.... ..1IIIMd .,.,,.... I""" " "'l1li of I~" _. PaIontiIlIW l"a'lI. 
    Fl.YMTIOI  RuiIo 81 ...-1II:n8h 1"1Ing mid.""'. collctoo "......... .1IIt. POIIIIIiIIIW l"a'lI. 
 rl PHYSICAl. 1R£ATII£IT t-     
    1I1CIIOFIl11lAtIDI  E1IICIM lor..... inorpnlco (..... . ".;,....lIIm,. PalontiIlIW l"a'lI. 
    AM" CIIIIOIII ~ fillorillg co_i.... ,",I"""tin... -to....... ..."'.-. ,...1.. ".'hIn _lie -.. 01 diIoolold PoIIlllloIIW l"a'lI. 
    co_inIIII;""" __Id..... .18ft. 
    1IOlB:UUII.MI  .,....1coI1r,raMM c.,...... ......... ... nlCltollld lor ..."... ., .."..;.. ... of ...,IIIIon, 0'181.. I.. ..,ablolll, III"'''' o,lIIIt......-. _1"'- (would "'Iii.. 
     fCn..IMo......"'" -III lIinIW lor _. dnoIo,...... 0I......,.afic .....,. 
    R.OTA1I0I ~ .....,iI. of 1.""'.1ido IftI.. -..0,,, I"""'"". .......... Ii, II 'Ig' ,......; -. 01_, Po,..tillIW l"a'lI. 
    10 ..., ....,.,...... IIIII-ill-, clllmw CIIIIII Ii, "'''''10 rioo, cony..'inI ,.rtidoI... lhorn. 
    £VAPOIIAtIDI  Diuolilld..-.... 81 co........ ., diotI...... 1Id- ....... of - "'lulling dIollOlll. I.. ..,ablo duo III ,...nco III co..-.... ... low hoi.-, poil'" I
OOlLs:nol    WIIIK81101  A co...inoIiI. of cIIomiCII 0IiI18r.. W ligll,IIIdIor.... 81"'" III ...1co1lW olidia o",,-ie co"'poundl in -,. PoIIIIIiIIlW l"a'lI. I
1RfA1III£1T -      
    101 EXCIIAIIGE  Diuolilld ...... .......... willi... co_-.. onil.. -"", coiono III.. I ,,"hIIi: Mil; .......... ... PotontilllW I"abll. 
IJ8OINI8E H CMEIlCAl.1R£A1III£1T ~   ...... chIlIIicaIW........III'" -..  
   AI... II _II ond ..,..., .1IIt ., _liming"" into 10111 ,.... ... III nil ..'11; l18'ft1y-inducld  
    PIIECIfIItA 1101  ............. ...... .,.-iII "... inIoIO.. .... PotIIIIIotv ."a'" 
    ALUUIE  0ridIIiI1 II""""". _II. .~. oPtIIIIutII.", ell...... _,..ndo. IIot ..ill colllidoriftg IN -_ue.."", 01_, (ond lilt ti... 
    Cll.0III1A1IOI  ,.....11, _iie -III). 
    ACnVA1tDIWD8£  1Iic.... 81 _II"""" ..... ----III. _lie II _iie ............... .1IIcII_, or PoIIIIIiIIlW ."IieUII. 
     IIIidIIId lid. 
 -IIIOUIIIICALTllEANmt- RXBlIED IYI1DII  CI-.IoDd ",...., II....,.., _lid III ....... II1II..,.. wIIldIlI.-"''''''' 111'__; IIot ..ill coll8idlrl88 IN -_uo ....... 01_, (ond lilt tinll 
  ........,....... -~. hi... II, _lie -III). 
    8III8CIRPY101  .."... of ..., ..... 01 C8II...I11"" ........ .......111... _. PotIIIIIoIIW 1,,1ieU1I. 
 Y lMtRlIAI. TIIEA'nItlT ..... WET AIR IIXI~TIOI  All"''''''' ollilllilft of 0IpI& co_inun""'" ........- ond ,""M. Po."iIIy op~1I 
    IlllALLOIIIIJECIIOI  IlIjICIiII of hIIod 1fOU"'" ...Il1o "',""""'..r. .. ..., 10..... 10, ,lIdionl Po."iIIy ..pIicoIlI. 
     colllnll 
 rl 01811 OIIaWI6t II~~:-  1'IruIIIiD. (rIChugo' 01IIIIIIII groundwlhr."",,~ orllftll.Mld III'" ond 1Dw-,- dillrilution ...-"'. PotI"iIIy ",-,11 
 --     Po."iIIy ..pIicobll. 
    ADJM:EIT I1REAII  Point diIcIIIf9I 01..... '''U~,.. m...1nt",.1I8II (ullllllMd"tllllllry) .... 01 lilt. 
 Y Of AIm Dl8CHAAGE   GroUlldwllt, (IrIItId 0"') iI ditcllorvod 10 OIIord _"II_",,1Int vii -, ,.. ... Pill T- Raid. Polllllilly oppWIIlI 
    POTW  
..,J
~
1535407.1
TABLE 20
(CONT. )

-------
 Q...   .....DIAL   HOC...  ...CIIIPTIOM  
       OPTIOM  INlnAL 8C....NINa CO...NT. 
I NO ACTION        No r.lllldialldion. Rllalntd II requilld br CERCLA. 
      I OEED RESTRICTIONS  R.lrlctlonl pbad on prOlltrly dttd to prMnt IuIUIi building or Cltlltr IInd UI. on or 118r Pcllntlally IllClllcabli. 
       IIudgt-drylng btdI. 
   r-I ACCESS RESTRICTION I--      
      ~ FENCING AND SIGNS  flail conllrudld IIOIInd lludgt drying btdIlnd IIIOCIIIId 1118 wfth COnIImmttd tOIl. PcllntllJly eppllctbll. 
I INSTITUTIONAl ACTiONt-      
   I-[ MONITORING  I SAMPlING AND  Periodic II/IIplklg 011l1li11:8 10111. tUrta -III (rUn-oII). and tldlmenllo Idtntlly Ulfllnlllutur. rtltl8.  
    1 ANAl VSIS I PIIIInlIlIIy Ippllctbll. 
      ~ ReM.TYPE CAP  CGwtllludg. dryklg btdIlnd conllmNlId 101 wfth mul~mtdll RCRA.1ypt tip 10 "'trld kltltrllion. tllmlnll. I'otlntlilly IppllclbIt. 
        IIIIfac:8 IXpoIur... 
   -f CAPPING I--      
       NOfI.RCRA CNI  CGwtllludg. drying btdIand contamklalld IOI..h mul~mtdll RCRA-Iypt tip 10 raid kllltrtlion. tllmllIII. I'ollntlilly IppllclbIt. 
        IUIftct IXpoIUItI. 
       SlURAV WAll  Contlrucllon 011 VtIIk:aI ptlm.bllly btrrlar Ullng I tr.nd! btdI.tllld wfth 8OI~btntonl. lIurry mil; rlllrlcll NcllppllcIbIt given abunet 01 horl1Dnlll 
         . glllUnd_ltllIow. contlnlng laytr into whlcha~rry wafl mUll bt I
         Uytd.
I CONTAINMENT J-        NcllppllcIbIt given Ibunet 01 Ilol11011111 I
   ~ VERTICAl BARRIER ..-  SHEET PLiNG  Contlludlon aI a YtIIIcaJ ptlmallllIIy btrrllr Uling drlvtn allttl pin; IIIIrlcll groundwalll now btn.lh contIning laytr Into which IhIII pili mUll bt 
   I   corumlnlltd l1li. Uytd. 
      ~ GROUT CURTAIN I ConIIrudion 011 VtIlIcaJ ptlmaIIIllly IIytr br Injtdlng groul .. hlgll pr..UII kilo dot8Iy 8IIIC8d borlllOltt; NclIOOIlcabl. klllldurid rocl< equl8ll. 
       IIIIIIcII grouncIwIlII. 
   -f HORIZONTAl BARRIER I .lOCl( DISPlACEIIENT  Construction ala !Iud btrrltr 1l0000d Ind btnlllh 1h.1Io. m.. 01 mntamln8l1d IOIllnd wdgtlwatlt; baIIorn NclIOOIcablt dill to Pellntlll lor dlrnlgt to 
    btrrlll lI'ormed ." IIIgII ........ ~Ion allturry; penntlll btrrltr II awry Wli. 1111"" bulldklg laundltlonl. 
    EXCAVATION I I SlUDGElSUll  MtcIIInIcaI-1 ala,"", drying bid ... and contamlnaltd tOil IIIlng CXIIMnttonal conllrucllon PcllntllJly eppllctbll. 
    r I EJCAVATION ' equlprnanl. 
I REMOVAl         NoIlOOIcablt dill 10 limned lilt 01 ani Ind 
I  r- -r ONSITE DISPOSAl ..- ~ ONSITE lANOFl.l  A tptClillly contIruclld 0III1tt dlillOl8l Cllil d.igntd wlh 111111. 'klll_. and ather dtalgn Itdurn IXlllllattnt Ibtllood tor contlnuld CIOmmlrtlll ual atlh. all. 
DISPOSAl  with IPlllcablt .8. "Oulallonl. 
   -r Off SITE DISPOSAL  : OFFSITE TSO FACILITY  EJaVtIId mal.rtallIllIl\tPOIIld 10 ptrmltttd TSO IIdlty lor IJ.trnlnl (. 1INdtd'lnd dlloollL Patanllally IllClllcablt. 
~
~
IU"'"
TABLE 20 (CONT.)

Identification and Preliminary Screening of Remedial Technologies and
Process Options for Sludge.Drying Beds and Soils

-------
GINIUL   1t'.IDIA~..  "OCI..  DlteltlPYlON  
a_~     INITIAL ICII..NING CO..'NT' 
 r--I or.AVAt1OI  I SlUOGL1IOI.or.AVAt1OII  ....... -'II""""""" ....... coll8..iIhI...... _..81 coll8llllCliollhdln., "'*"'1oIy .8Iic8" 
     OtElllCAl fXTMCT10II I PIoc- UIId II""" .iI....1IIdge ..0...,11:.. _I,1nd ""1I:uIIto tOIiIII, ..,.,Iie....III, Il1o '_m .. inorvInll: CWO'" 
        ond m...", 
      lOll WASHIIIG I lolC", 01 co"m~ "'m III .iI., miring .., "18CIIng IOIIIIID ....,., co.....l- "am .1Id ID III'" ',...:  
       lot .,Iie"" III'''''''', 
REMOVAl      lOll R.USHlIU  PIoc_., whid!, .""11111 .Mlln ..lnjoolld InID .. ond tIIon ........... 80 colochd . till ..Mat it --, ..,.,111:""111, Il1o I_m .. CWOnidol 
TAEATlEIIT I-- ~ PIIY!IICAlIOtEIIICAl I--  lOW tDlPERA1URE    
      1IIBIIIAlITAIP  PIoc-., whidt VOCo.. IIIfIIIIIIJ dOIo"''''m co_il8Od ..., lot ."Iie... III' Il1o ._m .. cwonideo 0' mill.. 
DlSPOBAI. ""         
      OIE8ICAl 001II\1I0Il  HtaardD.. com...... "'111' ndlriDHIid8iooI ,- II tIIIIor dII'.., Of -" Il1o com,...", II 0 100. "-do.. "'*"'1oIr .,8Iic8" ... III "'.""'" 01 cp"'. 
       ..rm, ' 
      c(1IE1IT ".D  Dlllllllllinlllllo.. _....'liIId ...In 0 millu.. colllining ,0"11"'_- PII""1oIr .,,......, 
  ~ Sf A81lIZATlDN I  IlUCATt-MIED  DllIIIIIIIInontIIII in_lilld..... ,...... COIIIInint ,.,...11: _..II, "'*"'1oIr ......, 
      ~TIOII  ..... 80 ,""'I~....,...... d.,n orpniC .......~, " HOPE) 0' Min, PII.....~",...., 
  ~ IIOlDlllCAl   IIDOI8AAllAt1OI  "'" ........ ......... 01...,11: -,., ",II:IM",""', ..,."Il1:o'''111, Il1o I_m .. inorpIlI: CJIIIIdo Of 
     ......., 
      IIITIIIIICA 1101  IIIIInIIaI com...'" .......,..,., ~it Ind III ..... 80 .......... In ,.....1.. 1IIIIri.. PII""io~ .,pIcob" 
  -t 'lM£AMAl   ..aIERA 1101  IIIIInIIaI com...... .. -.. down II -., ~.'om"""'"', .....,Iie....III, _I. .
        IIIIInIIaI com""" .. .....,.., In III ,.- oIo....n. lot ..,lie"" III' _I. 01 .,..ito. l
      PrAOI. V8S I I
      UClCRll I TIIIIId llliI- 80 Nddilod Imo.... InIm .... till co""'inllod .11nd .1udgoIWoIt...II .....-cI. I'll......, IIIpIicM" 
  -I OIIITt DlSP08AL     TIIIIId lllillIIIt 80 ,1Iood ., ...... -..liliiii1 dotitnod, .-IId1nd clnod in _or"-.iII ."Il1:o...  
      OIIITt lAIIDAll , ........... lot ."Il1:o... d18" Ii. C_II"'. 
      801.10 WAS1I LAlDFlll I TIIIIId llliI- 80111_- IIIIiI8 1I,.,.,.1IIId III. (1Ialllilo111 lIadIiI, ..,."Il1:o,,, d18" ACAA II.""" 
      .....mlng dio,o" 01 hi'" -.. 
  '-f DRtITt DISPOSAl.     TIIIIId llliI- 80111_- llllil810 , ,.nnlllld RellA 1'80 C'So*tilo C') IICiIy .., d....,  
     ACAA T8D FM:IlIIY  l'II....io., .,pIicM" 
      COI£IIT-MIED  I,... .... II ........., .--..1OiI. Ind, PIIftIoIIII_- '-d ""liIIIiDnIoolldlll:lCllln millll..'I, "'*"'~ .,,...... 
  -I ITAIIUlA 1101   8WTf.UI(O  I. - ..... 01...................,l1li. ond, tIy "',1l1li '-d ,..,.iDttIIaIdIIcoII m......, ",*",Io"~" 
  I    
      1II:HI1DIIP  .............. ,liliiii11."" ........ 8t ~.., lot ."Il1:o""01 ",nido. 
I \lUlU 11IEA1IIEIIT ~ -4    V\1MIC'A1IOI  II -..... aI,.''''' Wolnd _iIId co_il8Od .. II ,....... ....... _liioi_111.0 wino.. .1iI, ..,."Il1:o,,, d18 .. ... ,.,.linn, 01... ...... 
11IEIIIIAl    ......., 
      SOl R.USIIIIU  I1IjIcti, ai, ."". lllUffIcIIm..... 8"" comoil.... .1UiItr. III ...1II8d Cllllllllli_.. --... lot ."Il1:o.11 d18" ......- ....... .. t'" 
       ,,1li:iio, WIll IDcoIId dDwnglldiont 01 ~n .... -. ond ....d .~ 
  --f PIfYIIOII.OtEMICAl      
    VACUIIIMITEAII  A _'.lIIn II wohlnd ,....-m 'l1li" 80 UIId tolnjod ....Into till .18 - WCo. ...."Il1:o."111' Il1o ,.....,.m .. ",nidi. 0' ........ 
     I EITAAC1IDII I   
'.-,1          
TABLE 20
(CONT. )

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-74-
Alternative 2: Institutional Actions - Alternate Water
Supply, Closure of Private Wells, Deed Restrictions,
Monitoring
Alternative 2, considered a "limited action" response, is
considered a site-wide remedial action. This alternative
would involve not only ~losing existing private wells, but
supplying an alternate water supply for those potentially
affected drinking wells located downgradient from the Site.
Establishing deed restrictions would prohibit the drilling of
new water supply wells and the use of existing groundwater in
the area potentially affected by the Site. Monitoring of
existing water supply wells located outside the area of deed
restrictions would enable early detection of any site-related
contamination.
The reduction of groundwater contaminants to acceptable
levels would occur only through natural processes, thus
requiring many years before cleanup levels would be met.

This alternative involves the following costs:
Total Capital Costs
Total 0 & M Costs
Total Present Worth Costs
$524,000
5398.000
$922,000
Alternative 3: Collection/Treatment/Disposal - Groundwater
Extraction, Treatment with Ultra-violet Radiation-OXidation
and Precipitation/Piltration

This alternative would involve the recovery of groundwater
such that the remediation levels would be attained.
Contamination would be removed through extraction wells
placed in contaminated portions of the overburden-bedrock
aquifer and reduced through treatment by Ultraviolet
Radiation and Precipitation/Filtration. Discharge of the
treated groundwater would be either to the local
Publicly-owned Treatment Works (POTW) or to a nearby, unnamed
branch of Fishing Creek. All contaminants in the
groundwater would be reduced to levels which would be
acceptable by local POTW standards or to levels required by a
NPDES permit.

-------
-75-
The proposed extraction system (as with Alternatives 4 and 5)
would involve the installation of an estimated six recovery
wells arranged in such a manner to extract all
VOC-contaminated groundwater and to control any further
off-site migration of the contaminated groundwater. The
exact number of. extraction wells would be determined during
the Remedial De,ign.

The use of Ultraviolet Radiation, along with oxidizing agents
such as hydrogen peroxide and ozone, are a proven technology
for destroying dissolved organic contaminants as well as a
host of other contaminants including cyanide.
Precipitation/Filtration (or flocculation) is also a proven
physiochemical process whereby inorganic substances in
solution are transformed into solids and removed from the
liquid waste stream by forcing the groundwater through a
porous substance acting as the filter media. The technology
is based upon alternation of the chemical equilibrium
relationships affecting the solubility of an inorganic
species. Removal of metals as hydroxides or sulfides is the
most common precipitation application in wastewater
treatment. Precipitation is applicable to the removal of
most metals from wastewater, including zinc, cadmium,
chromium, copper, lead, manganese, and mercury. Certain
anionic species such as phosphate, sulfate, and fluoride can
also be removed.
Precipitation and Filtration are well-established
technologies. Precipitation/Filtration equipment is
relatively simple, readily available, easy to operate and
control, and integrates with other treatment technologies.
Several disadvantages are that residual sludge waste would be
generated from the treatment process and sent off-site to a
RCRA treatment, storage, and disposal (TSD) facility in full
compliance with its Part B permit, in accordance with EPA's
off-site policy. The process is non-selective in that
compounds other than those targeted may be removed.

Discharge of the treated groundwater would be to the local
POTW or to a nearby, unnamed tributary of Fishing Creek. The
actual method of discharge and operating parameters would be
established by the party performing the work during the
Remedial Design.

-------
-76-
Further characterization would be conducted during the
Remedial Design phase to determine the full extent of
groundwater contamination. This characterization would be
necessary for groundwater alternatives 3, 4, and 5 prior to
drafting a detailed design for the groundwater pump-and-treat
system at the Site. To achieve this characterization, the
installation of. additional monitoring wells would be
necessary. The. costs for these additional wells were not
included in this ROD.
This alternative involves .the following costs:
Total Capital Costs
Total 0 , M Costs
Total Present Worth Costs
$2,657,000
51.852.000
$4,509,000
Alternative 4: Collection/Treat8ent/Disposal - Groundwater
Extraction, Treatment with Alkaline Chlorination,
Precipitation/Piltration, Air Stripping, and Carbon
Adsorption

Alkaline Chlorination is a proven technology for destroying
both VOCs and cyanide in groundwater with the use of chlorine
compounds such, as sodium hypochlorite and chlorine gas.
Precipitation/Filtration would be used to transform inorganic
substances in groundwater into solids and remove them from
the liquid waste stream by forcing the groundwater through a
porous substance. As described for alternative 3, sludge
would be generated from this treatment and would be sent
offsite for disposal in compliance with all ARARs listed in
section VII.
Air Stripping is the mass transfer process whereby volatile
contaminants are transferred from their combined state to a
gaseous state. Pour commonly used methods for air stripp~ng
liquids are packed column, cross-flow tower, coke tray
aerator, and diffused air basin procedures. Air stripping is
most commonly accomplished using a packed tower equipped
with an air blower. The packed tower works on the principle
of counter-current flow where the water stream flows down
through the packing material while the air is blown upward,
and is exhausted through the top. Volatile, soluble
compounds have an affinity for the gaseous phase.

-------
-77-
In the cross-flow tower, water flows down through the packing
as in the counter-current packed column; however, the air is
pulled across the water flow by a fan. The coke tray aerator
is a simple, low maintainance process requiring no blower.
The water being treated is allowed to trickle through several
layers of trays. This produces a large surface area for gas
transfer. .
Diffused aeratiGn stripping and induced draft stripping use
aeration basins similar to standard wastewater treatment
aeration basins. Water flows through the basin from top to
bottom of the basin. The air to water ratio is significantly
lower in either the packed column or the cross-flow tower
units.
Air stripping is normally utilized to remove volatile
organics from aqueous waste streams. Generally components
with Henry's Law constants greater than 0.003 can be
effectively removed by air stripping. The waste feed stream
must be low in suspended solids and may require pH
adjustments to reduce solubility and improve transfer to the
gaseous phase.
Air strippinq is sometimes only partially effective in
groundwater treatment and must be followed by other processes
such as carbon .adsorption or biological treatment. The
combined use of air stripping followed by other applicable
processes can be an effective means of removing the
contaminants from groundwater. Equipment for air stripping
is relatively simple, start-up and shut-down can be
accomplished quickly, and the modular design of packed towers
makes them somewhat mobile in their application.

An important consideration in the utilization of the air
stripping technology are the implications of the air
pollution which may result from the air stripping operation
itself. The gaseous stream generated during air stripping
may require collection and subsequent treatment.
The process of adsorption onto activated carbon involves
contacting a waste stream with the carbon, normally by flow
through a packed bed reactor. The activated carbon process
can be designed to selectively adsorb hazardous constituents
by a surface attraction phenomenon in which organic molecules
are attracted to the internal pores of the carbon granules.
. .

-------
-78-
Adsorption depends upon the strenqth of the molecular
attraction between the adsorbent substance and absorbate,
molecular weiqht, type and characteristics of the absorbent
substance, electrokinetic charqe, pH, and surface area. Once
the micropore surfaces are saturated with orqanics, the
carbon is spent and must either be replaced with virqin
carbon or removed, thoroughly regenerated, and replaced.

The time to reach breakthrouqh or exhaustion is the sinqle
most critical operating parameter. Carbon lonqevity balanced
aqainst influent concentration qoverns operating economies.
In the event that the carbon is regenerated on-site, the
supernatant from this process will be processed throuqh the
system constructed for treatinq the Site groundwater.
Activated carbon adsorption is a well-developed technology
which is widely used in the treatment of hazardous waste
streams. It is especially well suited for the removal of
mixed orqanics from aqueous wastes. Since carbon adsorption
is an electrical interaction phenomenon, the polarity of the
waste compounds will determine the effectiveness of the
adsorption process.

The more hydrophobic (insoluble) a molecule is, the more
readily the compound is adsorbed. As a result, low
solubility humic and fulvic acids which are present in the
qroundwater can absorb to the activated carbon more readily
than any waste contaminants and result in rapid carbon
exhaustion. Also, some metals and inorganic species have
shown excellent to qood adsorption potential. These include
antimony, arsenic, bismuth, chromium, tin, silver, mercury,
cobalt, zirconium, chlorine, bromine, and iodine. Activated
carbon can a180 be utilized in the powdered form, which
offers the advantages of qreatly increased surface area
availability and reduced costs.
Carbon adsorption technology can be used in conjunction with
or flowing biological treatment and/or gravity filtration~
Its purpose in this application is to remove the refractory
organics which cannot be biologically degraded.

The biological treatment and/or granular media filtration
steps prior to carbon adsorption reduce the organic and
suspended solids load to the carbon adsorption units.
Reduction of orqanic and suspended solid load minimizes
carbon usage and regeneration costs. Air stripping has also
been applied prior to carbon adsorption in order to reduce a
portion of the volatile ~ontaminants and reduce the orqanic
load to the carbon adsorption units.

-------
1--
-79-
Activated carbon usage is easily implemented into or along
with other treatment systems. The process is well suited to
mobile units as well as to on-site construction. Space
requirements are small and start-up and shutdown are rapid.

Regeneration of spent carbon for use is the highest operating
cost associated with the utilization of carbon adsorption
technology. In,addition, high capital costs can be
associated with,its use. Both capital and operating costs
can be substantially reduced through pretreatment of the
waste prior to its treatment with carbon adsorption.
Activated carbon treatment would not be utilized as a primary
remedial technology role at the Site, but would be used as a
supplementary technique in conjunction with other clean-up
technologies. This technology will be retained for further
consideration.
Treated groundwater would be discharged either to the local
POTW or a nearby tributary of Fishing Creek.

Costs for this alternative are based on discharge to the
local POTW as well as a remediation period of at least five
years.
This alternative involves the following costs:
Total Capital Costs
Total 0 & M Costs
Total Present Worth Costs
$2,498,000
52.683.000
$5,181,000
Alternative 5: Collection/Treatment/Disposal - Groundwater
Bxtraction, '1'reat8ent with Alkaline Chlorination, Ion
Bxchange, Air Stripping, and Carbon Adsorption
Alternative 5 would include the same treatment except Ion
Exchange would be substituted for Precipitation/Filtration.

Ion Exchange is a process where the toxic ions present in a
waste stream are removed by being exchanged with relatively
harmless ions held by the ion exchange material. Ion
exchange resins are primarily synthetic organic materials
containing ionic functional groups to which exchangeable ions
are attached. These synthetic resins are structurally stable
(can tolerate a range of temperature and pH), exhibit a high
exchange capacity, and can be utilized to selectively
exchange ions.. .
. .

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This technology can be used to remove a wide range of
inorganic species from water. These include: all metallic
elements when present as soluble species (either anionic or
cationic); inorganic anions such as halides, sulfates,
nitrates, cyanides; organic acids such as carboxylics,
sulfonics, and some phenols; and organic amines.
Ion exchange i~ a well. established technology for heavy metal
removal and hazardous anion removal from dilute waste
solutions. A problem which exists with ion exchange is the
disposal of contaminated regeneration solutions.
Consideration should be given to selection of these solutions
when evaluating the technology. Based on the data available
for this screening, the contaminants present, amenability of
other treatment technologies, and costs, ion exchange is not
being considered for further evaluation as a remedial
technology at the Site.

This alternative involves the following costs:
Total Capital Costs
Total 0 & M Costs
Total Present Worth Costs
$2,539,000
52.786.000
$5,325,000
B.
Remedial Alternatives to Address Sludqe/Soil
Contamination
The response actions to address sludge/soil contamination
are:
Alternative 1:
No Action
Alternative 2: Fencing, Warning Signs, Deed
Restrictions, Capping
Alternative 3:
Disposal

Alternative 4: Excavation, Treatment with
Oxidation-Reduction, stabilization, On-site
Disposal, Capping
Excavation and Off-site
Alternative 5: Excavation, In-situ
Vitrification, On-site Disposal,
Capping
Each of the five alternatives is described below.

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Al ternati ve 1:
Ho Action
In this alternative, no sludge or soil remediation would
occur. The costs associated with this alternative are the
same as the costs shown for Alternative 1 for the groundwater
remedia~ion. These costs include:
Total. Capital Costs
Total 0 , M Costs
Total Present Worth Costs
$170,000
5329.000
$499,000
Alternative 2: Institutional Actions - Fencing, Warning
Signs, Deed Restrictions, Capping

This alternative would include fencing of the Site to limit
access to the property, as well as posting warning signs to
identify the property as an EPA Superfund hazardous waste
site. Deed restrictions would also be established to limit
land and groundwater use in the area of contamination.
Prolonged monitoring of the contamination would be
implemented. A cap would be placed over the sludge drying
bed area to reduce the possibility for physical contact with
contaminants, .the ~ossibility for airborne contamination, as
well as the possibility for contamination of surface water
and sediments. . The exact nature of the cap would depend on
the results of the treatability studies performed during the
Remedial Design phase.
Total Capital Costs
Total 0 , M Costs
Total Present Worth Costs
$524,000
5398.000
$922,000
Alternative 3:
Bzcavation and Offsite Disposal
Alternative 3 would include excavating the contaminated
sludge and soil and transporting the material off-site to. an
approved RCRA treatment, storage, and disposal (TSD)
facility. The sludge and soil is classified as a mixture of
RCRA - FOO6 and F019 Listed Waste, and would therefore be
regulated as such by the Land Disposal Restrictions (LDRs),
(40 CFR 268). Trucks would be loaded by conventional
earthmoving equipment. Once the trucks are loaded, a cover
would be installed over the material, and the trucks would be
transferred to a decontamination facility for final cleaning
and inspection prior to transport. The total quantity of
contaminateg sludge and soils to be removed is estimated to
be 3,000 yd , which would require approximately 230
truckloads to complete the off-site transporting of the
material.

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Once all contaminated sludge and soil is removed from the
Site and the excavated area is backfilled with clean fill and
topsoil, a vegetative cover would be established and the area
could be opened for unrestricted use. The time required for
excavation and off-site disposal of the sludge and soil may
be determined by local authorities and their restrictions on
truck traffic or by the disposal facility's processing
capabilities. ,At a disposal rate of 5 trucks per day, the
disposal would ~ake approximately 2 months.
Total Capital Costs
No 0 & M Costs
Total Present Worth Costs
$2,363,000
o
$2,363,000
Excavation, Treatment with Ozidation-
Reduction, Stabilization, On-site
Disposal, Capping

Alternative 4 would include excavating the contaminated
sludge and soil, treating the material with
Oxidation-Reduction and Stabilization, and backfilling the
solidified material into the excavated area. No lateral
expansion of the area of concern will occur.
Alternative 4:
Oxidation-Reduction is a type of treatment whereby
contaminants undergo a chemical process to either destroy or
convert each constituent to a less hazardous form.
Stabilization and solidification are terms which are used to
describe a type of treatment which accomplishs one or more of
the following objectives:
*
improve waste handling or other physical
characteristics of a waste;
*
decrease the surface area from which transfer or
loss of contained pollutants can occur; and

limit the solubility or toxicity of hazardous waste
constituents.
*
Stabilization is used to describe processes whereby one of
the aforementioned objectives are obtained by production of a
monolithic block of waste with high structural integrity.
The contaminants do not necessarily interact chemically with
the resulting solidification reagents, but are mechanically
locked'within the solidified matrix.
. .

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Contaminant loss due to leachinq is minimized by reducinq the
surface area available. Stabilization methods usually
involve the addition of materials which limit the solubility
or mobility of the waste constituents even thouqh the
physical handlinq characteristics of the waste may not be
improved.
Stabilization and solidification techniques may include
various fixatinq aqents such as cement, silicate-based
materials, and brqanic polymers; they may also utilize the
adsorptive capabilities of various materials includinq
thermoplastic processes, surface encapsulation, or
vitrification.
Once the solidified material has been backfilled into the
excavated area, cappinq would be used to cover the material
to minimize contact with atmospheric waters. The use of
cappinq at the Site as a supplemental or follow-up treatment
subsequent to the backfillinq of the stabilized sludqe and
soil would also help to deny human contact with the
stabilized materials. The nature of the cap to be used with
this alternative shall be determined from the results of the
treatability study performed durinq the Remedial Desiqn.

Generally, cappinq is utilized when subsurface contamination
at a site precludes excavation and removal of wastes because
of potential hazards and/or unrealistic costs, or the intent
of the remediation is to isolate a non-mobile waste from
direct contact.
The main disadvantaqes of cappinq include the potentially
siqnificant maintenance requirements as well as the
uncertainty of the desiqn life. For more information on the
type of cap which would be used at the Site, refer to paqe
98.
Total Capital Costs:
Total 0 , M Costs:
Total Present Worth Costs:
. $1,090,000
5121.000
$1,211,000
Alternative 5: Bxcavation, Treatment with Vitrification,
Backfilling, On-site Disposal,
Capping
Alternative 5 includes excavatinq the contaminated sludqe and
soil, treatinq the materials with ex-situ. Vitrification,
backfillinq and cappinq the area.

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Vitrification uses electrical power to heat and melt
contaminants in the sludge and soil to form a stable glass
and crystalline structure with very low leaching
characteristics. Once the materials were vitrified, they
would pass through a separation chamber, where the glass-like
materials are separated from the gases. The gases then pass
through a collection system before being discharged. The
materials would~be backfilled and capped in. the same manner
as in Alternative 4.
The advantages of vitrification include the potential ability
to destroy, remove, or immobilize all contaminant groups and
to reduce the waste/media being treated. The need for
off-gas collection and treatment, however, is a disadvantage.
Total Capital Costs:
Total 0 & M Costs:
Total Present Worth Costs:
$1,058,000
S121.000
$1,179,000

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IX. SUllMARY OP COMPARATIVE ANALYSIS OP ALTERNATIVES
The remedial alternatives to address qroundwater and
sludqe/soil contamination were evaluated usinq the nine
evaluation criteria as set forth in the NCP 40 CFR 300.430
(e)(9). A brief description of each of the nine evaluation
alternatives is provided below.
THRESHOLD CRITERIA
1.
Overall Protection of Human Health and the
Environment addresses whether each alternative as a
whole will provide adequate or institutional
protection to human health and the environment.
This includes an assessment of how the public health
and the environmental risks are properly eliminated,
reduced, or controlled throuqh treatment,
enqineerinq controls, and/or institutional controls
placed on the property to restrict access and
(future) development. A deed restriction is an
example of control to restrict development.

Compliance with AD~licable or Relevant and
ADDroDriate Reauirements tARARs) address 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 provide the qrounds
for invokinq a statutory waiver.
2.
PRIMARY BALANCING CRITERIA
3.
Lona-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. Mobilitv. or Volume refers to
the anticipated performance of the treatment
technoloqies a remedy may employ. The 1986
amendments of the Superfund statute state that,
whenever possible, EPA should select a remedy that
. uses a treatment process to permanently reduce the
level of toxicity of contaminants at the site; the
spread of contaminants away from the source of
contaminants; and the volume, or amount, of.
contamination at the site.
4.

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6.
7.
-86-
s.
Short-term Effectiveness refers to the likelihood of
adverse impacts on human health or the environment
that may be posed during the construction and
implementation of an alternative until cleanup goals
are achieved.
~ 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.
Imclementabilitv refers to the technical and
administrative feasibility of an alternative,
including the availability of materials and services
needed to implement the alternative.
8.
MODIFYING CRITIERIA
9.
State Accectance addresses whether the State
with, opposes, or has no comments on the
alternatives EPA are proposing as the remedy
site.
concurs
for the
Community Acceptance 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 meeting and
during the public comment period.

These evaluation criteria relate directly to requirements in
Section 121 of CERCLA, which determine the overall
feasibility and acceptability of the remedy. Threshold
criteria must be satisfied in 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 21 provides a summary of the ten alternatives
retained after the evaluation process along with the total
present worth costs for each. The evaluation of the
potential remedial alternatives to address sludge, soil, and
groundwater were developed as follows.

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TABLE 21
SUMMARY OF CLEANUP ALTERNATIVES
Medium
Alternative I
General Response
Action
Present Worth
Costs
Groundwater ,Alternative 1 No Action $499,000
 Alternative 2 Institutional $922,000
  Actions 
 Alternative 3 Collection/Treatment/ $4,509,000
  Disposal 
 Alternative 4 Collection/Treatment/ $5,181,000
  Disposal 
 Alternative 5 Collection/Treatment $5,325,000
  Disposal 
Medium
Alternative t
General Response
Action
Present Worth
Costs
Sludge/Soil Alternative 1 No Action  $499,000
 Alternative 2 Institutional Actions $922,000
  Containment  
 Alternative 3 Excavation and $2,363,000
  Offsite Disposal 
 Alternative 4 Excavation/Treatment/ $1,211,000
  Onsite Disposal 
 Alternative 5 Excavation/Treatment/ $1,179,000
  Onsite Disposal 

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A.
Groundwater Remediation
The following alternatives were subjected to detailed
analysis for groundwater remediation:
Alternative 1:
60 Action
Alternative 2: Alternate Water Supply, Closure of
Private Wells, Deed Restrictions, MonitorinCJ

Alternative 3: Groundwater Treatment with
Ultra-violet Radiation-oxidation,
Precipitation/Piltration
Alternative 4: Groundwater Treat8ent with Alkaline
Chlorination, Precipitation/Piltration, Air
Stripping, Carbon Adsorption

Alternative 5: Groundwater Treat8ent with Alkaline
Chlorination, Ion BxchanCJe, Air Stripping,
Carbon Alkaline
Overall Protection
Alternative 1 would not be protective of human health.
Potential impacts to the environment were identified the Risk
Assessment, and if present would not be mitigated by this
alternative. Alternative 2 would provide protection against
any potential risk associated with the use of contaminated
groundwater, but would require long-term enforcement of the
institutional controls. Alternatives 3, 4, and 5 would
mitigate current or future risks derived from exposure due to
inhalation, dermal contact, and/or ingestion of contaminated
groundwater.
CCDlDliance with ARAR8

Alternative 1 would not comply with the contaminant-specific
ARAR regarding the cleanup of the groundwater contamination.
ARAR waivers are not justified for this alternative because
none of the criteria for a waiver are met through "No Action"
remedial responses. Alternative 2 would not satisfy the
North Carolina requirements regarding the restoration of
Class GA waters (15A NCAC 2L) nor would it meet the
chemical-specific ARAR for the aquifer (NC water quality
standards). Alternatives 3, 4, and 5 would recover all
contaminated groundwater and treat it to remediation levels.

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Lana-term Effectiveness and Permanence

Alternatives 1 and 2 would not reduce the toxicity, mobilit~
or volume of the contaminant concentrations contributing to
the risks identified in the RI report. Groundwater
contamination would continue to migrate off-site; therefore,
it is not considered to be a permanent or effective remedial
solution. Existing risks regarding the contaminated
groundwater may ' decline in the future due to natural
processes, but in the absence of engineering or institutional
controls to prevent exposure, the Site will remain a threat
to human health.
Contaminant concentrations would be permanently reduced
through groundwater recovery and treatment in Alternatives 3,
4, and 5. Carbon adsorption (alternatives 4 and 5) is
considered Best Available Treatment for volatile organic
compounds in groundwater. Metals found in the groundwater
would also be permanently reduced through either
Precipitation/Filtration or Ion Exchange. BPA would conduct
a five-year review of the remedial alternative to determine
whether complete restoration of the aquifer is feasible.

Reduction of Toxicitv. Mobilitv. or Volume
Alternatives 1 and 2 would have no impact on the toxicity,
mobility, or volume of the contaminants in the groundwater
other than those natural processes mentioned above.
Continued extraction and treatment of the aquifer in
Alternatives 3, 4, and 5 from the overburden/bedrock aquifer
would effectively reduce the toxicity, mobility, and volume
of the groundwater contamination plume.

Short-term Bffectiveness
All of the alternatives can be implemented without
significant risks to on-Site workers or the community and
without adverse environmental impacts.
T~lementability

No implementation is needed for Alternative 1. Alternative 2
would require extensive coordination between State and local
agencies in order to institute long-term controls
effectively.

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Alternative 3 would require compliance with EPA, Department
of Transportation (DOT), aand any other regulations regarding
the transport and disposal of hazardous materials.
Alternatives 4 and 5 are technically feasible, but would
require treatability studies to determine the effectiveness
of each treatment technology.

Cost
Total present worth (PW) costs for the groundwater
remediation alternatives are as follows:
Alternative 1:
$499,000
$922,000
Alternative 2:
Alternative 3:
$4,509,000
$5,181,000
Alternative 4:
Alternative 5:
$5,325,000
State Acce9tance

The State of North Carolina conditionally concurs with the
selected remedy. State comments can be found in Appendix A
of this document, as well as EPA's responses to those
comments.
C~itv Acceatance
A Proposed Plan fact sheet was released to the public on
Thursday, April 9, 1992. The public meeting was held on
April 16, 1992. The public comment period was held from
April 9, 1992 to June 8, 1992. The letters and comments
submitted during the April 16, public meeting, the 30-day
comment period, and the 30-day extended comment period are
summarized in the attached Responsiveness Summary.

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B. Sludae/Soil Remediation

The following alternatives were developed for Site sludge and
soils and were subjected to a detailed analysis:
Alternative 1:
Alte~ative ~:
Alternative 3:
Alternative 4:
Alternative 5:
&0 Action
Alternate water supply, Private
well closure, Deed Restrictions,
Monitoring

Excavation, Off-site Disposal
at a RCRA Facility
Bxcavation, Treatment with
Oxidation-Reduction, Stabilization,
On-site Disposal, Backfilling,
Capping
Bxcavation, Treatment with
Vitrification, On-site Disposal,
Backfilling, Capping
Overall Protection

Potential risks due to Site sludge and soils under
current and future conditions and potential future
(residential scenario) exceed the acceptable range
specified in the National Contingency Plan (NCP).
Alternative 1 would not be protective of human health.
Impacts on the environment have not been identified, but if
present would not be mitigated by this alternative.
Alternative 2 would reduce the potential risk due to dermal
contact or ingestion of the sludge and soil, but would not be
protective of groundwater or the environment. Alternatives
3, 4, and 5 would not only reduce the risk associated with
dermal contact and ingestion, but would mitigate any further
degradation of the groundwater by reducing the toxicity,'
mobility, or volume of the sludge and soil.
COIDDliance with ARARs
both
conditions
of risk
There are no Federal or State ARARs for inorganic
contamination in soils. There are no action-specific ARARs
for Alternatives land 2. Alternative 3 would comply with
EPA's off-site policy and applicable land disposal
restrictions (LDRs). Alternative 4 and 5 would comply with
all applicable ARARs, including LDRs (through a Treatability
Variance under 40 CFR S 268.44).
. .

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Lona-term Effectiveness and Permanence
Alternatives 1 and 2 would not be effective in reducing
contaminant levels and, therefore, would not be a permanent
remedy. Alternatives 3, 4, and 5 would result in long-term
reductions in contaminant levels.
Reduction of Toxicity. Mobilitv. and Volume.

Inorganic contaminant levels would remain unchanged for
Alternatives 1 and 2. Alternative 3 would reduce the
toxicity, mobility, and volume of inorganics significantly.
Alternatives 4 and 5 would reduce the mobility of the
inorganics significantly, but would not reduce their volume
or inherent toxicity.
Short-tera Effectiveness
All of the alternatives can be implemented without
significant risks to on-site workers or the commu~ity and
without adverse environmental impacts.

Tmnlementability
No implementation is needed for Alternative 1. Alternative 2
would require extensive coordination between State and local
agencies in order to institute long-term controls
effectively. Alternative 3 would require compliance with
EPA, DOT, and NCDEBNR regulations regarding the transport and
disposal of hazardous materials. Alternative 4 is
technically feasible, but would require treatability studies
to determine the effectiveness of each treatment technology.
Alternative 5, Vitrification, is not a proven technology and
its availability is limited.

Cost
The present worth (PW) costs for the sludge/soil remedial
alternatives are as follows:
Alternative 1:
Al ternative 2:
$499,000
$922,000
Alternative 3:
$2,363,000
$1,211,000
Alternative 4:
Alternative 5:
$1,179,000

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State AcceDtance

The NCDBHNR has reviewed and provided BPA with comments on
the RI and FS Reports. The NCDEHNR also reviewed the
Proposed Plan and BPA's preferred alternative and
conditionally concurs with BPA's selection.
Community AcceD~ance
The community made verbal comments on the Proposed Plan
during the public meeting held in April 1992. The communit)
also made comments on the ROD during the comment period.
Responses to each comment is included in Appendix B - the
Responsiveness Summary, located at the end of this document.

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x.
THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
NCP, the detailed analysis of alternatives and public and
state comments, EPA has selected a remedy for contaminated
sludge/soil and groundwater at this Site. This remedy will
reduce the total cancer risk posed by the Site to a risf
levgl that is within EPA's acceptable risk range of 10- to
10- , .and which,EPA considers to be protective of human
health and the environment. To obtain this level, this
remedial action alternative requires the extraction and
treatment of groundwater above MCLs and State water quality
standards, as well as the excavation and treatment of
sludge/soil which poses a potential health risk due to dermal
contact and ingestion exposure. The total present worth cost
of the selected remedy, Groundwater Alternative '4 and
Sludge/Soil Alternative '4, is estimated at $6,392,000. The
major components of the remedy include:
A.
Groundwater Remediation
Alternative 4:
Groundwater Extraction, Treatment with
Alkaline Chlorination, Precipitation/
Filtration, Air Stripping, and Carbon
Adsorption

Sludae/Soil Remediation
B.
Alternative 4:
Excavation, Oxidation-Reduction,
Stabilization, Backfilling (On-site
Disposal), and Capping
A.
Groundwater Remediation
This remedial action will consist of a groundwater extraction
and treatment system, and an overall monitoring program for
the Site. Groundwater contaminated above the remediation
levels indicated in Table 18 shall be extracted from the
entire area known to be effected. The contaminated aquif~r
will be remediated until the remediation levels included in
Table 18 are achieved.
For costing purposes during the Feasibility Study, six
recovery or extraction wells were anticipated for the
pump-and-treat system. The actual design, construction, and
operation parameters of the extraction system shall be
established during the remedial design phase, and shall be
conducted in accordance with all ARARs l~~ted in Sec~ion VII,
including but not limited to the RCRA requirements set forth
~n 40 C.F.R. Part 264 (Subpart F). The actual monitoring
requirements shall also be established during. the Remedial

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Design phase. The extracted groundwater will first pass
through an equalization tank for pH and temperature
adjustment and the flow will be equalized. Following
equalization, alkaline chlorination will be used to destroy
cyanide as well as VOCs in the groundwater with the use of
chlorine compounds such as sodium hypochlorite, sodium
hydroxide, or chlorine gas.

Chemical precipitation of dissolved metals from the
groundwater is the next step in the treatment process. The
metals will be precipitated from the solution as hydroxides,
sulfides, or carbonates, depending on the precipitating
agent(s). The sludge generated through the chemical
precipitation process will subsequently undergo treatment an
disposal in compliance .will all ARARs listed in Section VII.
The supernatant from the clarification tank will then pass
through a multimedia filter to remove suspended solids.
Following precipitation/filtration, air stripping will be
used to remove the VOCs from the groundwater by converting
them from an aqueous state to a gaseous state (the VOC-laden
air or gaseous stream generated during air stripping may
require collection and subsequent treatment with vapor phase
carbon adsorption). Carbon Adsorption will be used as the
follow-up groundwater treatment to reduce VOC concentrations
to cleanup levels. The treatment and/or disposal of spent
filters used in either the air stripper or the carbon units
will be in compliance with the ARARs listed in Section VII.

Discharge of the treated groundwater shall be either to the
local, publicly owned treatment works (POTW), commonly
referred to a8 the sewage treatment system, or as surface
water discharge to an unnamed branch of Fishing Creek.
Discharges from the groundwater treatment system shall compl
with all ARAR8 listed in Section VII, including, but not
limited to, .ubstantive requirements of the NPDES permittin~
program under the Clean Water Act, 33 U.S.C. S 1251 et sea.,
and all effluent limits established by EPA.
Groundwater shall be treated until the following levels are
attained at the extraction wells:
Benzene
1,2,-Dichloroethane
1,1,-Dichloroethene
1,2,-Dichloroethene
Tetrachlor~ethene
1,1,1,-Trichloroethane
5 ppb
0.38 ppb
7 ppb
70 ppb
0.7 ppb
200 ppb.

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Trichloroethene
Vinyl Chloride
Barium
Chromium
Copper
Lead
Nickel
Zinc
Cyanide
2.8 ppb
0.015 ppb
1,000 ppb
50 ppb
1,000 ppb
20 ppb
100 ppb
500 ppb
154 ppb
The goal of this remedial action is to restore groundwater to
its beneficial use as a drinking water source. Based on
information collected during the RI and on a careful analysis
of all remedial alternatives, EPA and the State of North
Carolina believe that the selected groundwater remedy will
achieve this goal. The ability to achieve remediation levels
at all points throughout the area of the plume cannot be
determined until the extraction system has been implemented,
modified as necessary, and plume response monitored over
time. If the implemented groundwater extraction system
cannot meet the specified remediation levels, at any or all
of the monitoring points during implementation, the system
performance standards and/or the remedy may be re-evaluated.
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 environment, and are technically practicable under the
corresponding circumstances.
For cost estimating purposes, groundwater extraction was
projected for a period of 5 years, during which time the
system's performance will be carefully monitored on a regular
basis. Monitoring may be adjusted as warranted by the
performance data collected during the initial operation of
the system. Modifications shall be approved by EPA prior to
implementation, and may include any or all of the follow~ng:

* alternating pumping at wells to eliminate stagnation
points;
* pulse pumping to allow aquifer equilibration and to
allow adsorbed contaminants to partition into
groundwater;

* installation of additional extraction wells to
facilitate or accelerate remediation of the contaminant
plume; or

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* discontinue pumping at individual wells where
remediation levels have been attained, only after
analytical confirmation.

To ensure that remediation levels will be obtained and
maintained, the aquifer will be monitored at those wells
where pumping has ceased initially every year following
discontinuatio~ of groundwater extraction. This monitoring
will be incorporated into an overall Site monitoring program,
which will be fully delineated in the Operations and
Maintenance portion of the Remedial Design. If EPA
determines, on the basis of the preceding criteria and the
system performance data, that certain portions of the aquifer
cannot be restored to their beneficial use(s), EPA may
require all of the following measures involving long-term
management for an indefinite period of time, as a
modification of the original system:
* engineering controls such as physical barriers, or
long-term gradient control provided by low level
pumping, as containment measures;
* chemical-specific ARARs may be waived for the
remediation of those portions of the aquifer based on
the technical impracticability of achieving further
containment reduction;
* institutional controls may be provided/maintained to
restrict access to those portions of the aquifer which
remain above remediation levels, since the aquifer is
classified as a current drinking water source;
* continued monitoring of specified wells; and

* periodic re-evaluation of remedial technologies for
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 intervals of at least every five years, in
accordance with CERCLA 121(c). To ensure State and public
involvement in this decision at this Site, any changes from
the remediation levels identified in this ROD will be
formalized in either an Explanation of Significant Difference
document or an Amendment to this Record of Decision.
Depending on a number of variables such as allowable pumping
'rates "nd removal efficiencies, the period of extracting
contaminated groundwater may last up to 30 years.

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-98-
B.
Sludae/Soil Remediation
Remediation of the metal-contaminated sludge/soil will
include excavation and staging of the sludge/soil, treatment
with oxidation-reduction and stabilization, followed by'
backfilling and. capping of the area. Since it is not
practical to separate the sludge and soil during excavation,
the sludge/soil , will be considered soil contaminated with
RCRA listed hazardous waste.
A treatability study will be required during the remedial
design to demonstrate that the Land Disposal Restrictions
(LDRs) levels (standards) are achieved as the primary
objective. In the event that the treatability study
demonstrates, to BPA's satisfaction, that the LDRs levels
cannot be achieved, then the treatability study shall
demonstrate that the alternate Treatability Variance levels
are achieved. Monitoring of the treated sludge/soil will be
required at the Site. If monitoring of the treated
sludge/soil indicates that LDRs levels have been exceeded, or
in the event that the treatability study demonstrates, to
BPA's satisfaction, that the LDRs standards cannot be
achieved and the alternate Treatability Variance levels have
also been exceeded, the effectiveness of the remedy component
will be re-evaluated.
The maior comDonents of sludae/soil remediation to be
implemented include:

The sludge/soil will be excavated until the remaining soil
achieves the health-based levels shown in Table 19. All
excavation shall comply with the ARARs listed in Section
VII. The excavated sludge/soil will be staged prior to
treatment within the same Area of Concern from where it was
excavated. In the event the excavated sludge/soil is staged
outside the Area of Concern, the staging (including storage)
must comply with the requirements of 40 C.P.R. S 268.50.
Oxidation-reduction will be utilized as the initial treatment
process to destroy the inorganics in the sludge/soil by
converting them to nontoxic or less hazardous compounds. The
oxidizing agents to be used will be approved by SPA during
the remedial design. After first being slurried, the
oxidizing agents and contaminants will be mixed in a process
reactor where the oxidation or reduction reactions occur.
Temperature and pH levels will be regulated to ensure the
reaction goes to completion. .

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-99-
Stabilization will be"the follow-up treatment subsequent to
oxidation-reduction. The purpose of using stabilization is
to reduce the mobility of the remaining metals in the sludge/
soil. The metals are immobilized within a mixture containing
a silicate- or cement-based fixating agent. The stabilized
materials will be placed back into the areas previously
excavated provided that LDRs levels (standards) or
Treatability Va~iance levels have been achieved to EPA's
satisfaction.
Backfilling and capping will follow-up the stabilization, and
involves construction and operation of an engineering cover
to deny human access to the solidified sludge/soil. Based on
the results of the treatability study, a delisting of the
waste may be sought by the party performing the work. In the
event that the waste is delisted prior to capping, the cap to
be constructed shall comply with the requirements established
by RCRA, Subtitle D. In the event that the treatability
study results show, to EPA's satisfaction, that the LDR and
Treatability Variance levels are not being attained for
delisting these wastes, they will be managed as RCRA Subtitle
C hazardous waste. For such a RCRA listed hazardous waste,
RCRA closure requirements require that a landfill closure be
used at the Si~e. The unit must be capped with a final cover
designed and constructed to:
* provide long-term minimization of migration of
liquids;
* function with minimum maintenance;
* accommodate settling and subsidence; and

* have a permeability less than or equal to any
bottom liner system or natural subsoils present.
Post-closure care includes maintenance of the final cover;
operation of a leachate and removal system; and maintenance
of a groundwater monitoring system [40 CFR 264.117,
264.228(b)].
Treatment Levels
The sludge/soil at the Site is considered to be a mixture of
RCRA F006/F019 listed waste, soil, and any debris present in
the Area of Concern. The treatment levels for the
s.ludge/soil are therfore RCRA Land Disposal Restriction (LDR)
standards.

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                             -100-
The selected remedy shall achieve the LDRs levels set forth
in 40 C.F.R. SS 268.41 and 268.43.  Specifically, the
selected remedy shall achieve the following LDRs levels in
the TCLP extract:

              Cadmium           .066 mg/1
              Chromium           5.2 mg/1
              Lead               .51 mg/1
              Nickel             .32 mg/1
              Silver            .072 mg/1

In addition, the selected remedy shall achieve the following
LDRs levels in the non-TCLP extract:

              Cyanide (total)    590 mg/1
              Cyanide (amenable)  30 mg/1


In the event that the treatability study demonstrates, to
EPA's satisfaction, that the selected remedy will not achieve
the LDRs levels, then the selected remedy, as established
below, shall comply with the LDRs through a Treatability
Variance for the contaminated sludge/soil.  The treatment
levels or ranges established through the Treatability
Variance that oxidation-reduction and stabilization will
attain for each constituent, as determined by TCLP analyses,
are:
              Antimony    0.1-0.2 ppm
              Arsenic     0.3-1 ppm
              Barium      0.1-40 ppm
              Chromium    0.5-6 ppm
              Nickel      0.5-1 ppm
              Selenium    0.005 ppm
              Vanadium    0.2-20 ppm
              Cadmium     0.2—2 ppm
              Lead        0.1-3 ppm
              Mercury     0.0002-0.008 ppm
In the event that the treatability study demonstrates, to
EPA's satisfaction, that LDRs levels are not attained, or
that the Treatability Variance levels are not attained, the
remedy component for the treatment of the sludge/soil will be
re-evaluated.

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-101-
Treatability Study

A treatability study will be required during the remedial
design phase to demonstrate that Alternative 4 will comply
with the Land Disposal Restrictions (LDRs) levels
(standards). In the event that the treatability study
demonstrates, to EPA's satisfaction, that the LDRs levels
(standards) cannot be achieved, then the treatability study
shall demonstrate that the alternate Treatability Variance
treatment levels are achieved. In the event that the
treatability study demonstrates, to EPA's satisfaction, that
the Treatability Variance levels cannot be achieved, then the
remedy component will be re-evaluated. The treatability
study will also determine the optimum stabilizing agent and
stabilization mixture needed to meet the treatment levels.
Based on the results of the treatability study, EPA may seek
to delist the waste through an Explanation of Significant
Difference (ESD) or ROD Amendment.
Additional Data Reauirements/Monitor Existina Conditions

In addition to delineating the work specified above, the
remedial desiqn (RD) will also have to address a number of
additional information/data requirements.
Since the RI was not able to completely define the extent of
the groundwater contamination, especially in the bedrock zone
of the aquifer, additional monitoring wells will need to be
installed during the RD. The placement of these wells as
well as the construction specifications will be made after a
review and evaluation of the existing groundwater monitoring
system. This review is to insure the groundwater monitoring
system will provide adequate information to assess the
long-term quality of the groundwater and to demonstrate the
effectivene88 of the groundwater extraction system. This
review effort may also include additional groundwater
modeling and aquifer testing.

In order to help establish a broader data base on groundwater
quality, additional groundwater samples will be collected and
analyzed for VOCs, SVOCs, and metals.

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-102-
In additon to monitorinq the qroundwater, additional surface
water and sediment samples shall be collected from the
surface water pathways located adjacent to and downqradient
of the Site to confirm and verify that these pathways are not
beinq adversely impacted by the Site. If BPA determines that
the Site is ad~ersely .impactinq aquatic life in the surface
water pathways, .then toxicity testinq usinq methods specified
in u.S. EPA, Region IV, Standard Operatinq Procedure for
Toxicity Testinq Hazardous Waste Assessment, dated 1991, as
amended, will be implemented. If contaminants in either
surface water or sediment exceed screeninq criteria levels
established by the National Oceanic and Atmospheric
Administration (NOAA SR-L/ER-H), then a bio-survey will be
conducted in conjunction with tissue analyses on appropriate
orqanisms. Based on this data, it may be necessary to issue
an Explanation of Significant Difference (BSD) or amend the
ROD to incorporate the appropriate cleanup technoloqy for
either the surface water or the sediment or both.

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-103-
XI. STATU'l'ORY DB'l'BRMIBAl'IOB
Under its legal authorities, BPA's primary responsibility at
Superfund sites is to undertake the remedial actions that
achieve adequate protection of human health and the
enviro~ent. In addition, Section 121 of CERCLA establishes
several other statutory requirements which must be attained
by the selected, remedy [HCP 40 CFR S 300.430 (f) (ii) A-E].
These specify tnat when complete, the selected remedial
action for this Site must comply with applicable or relevant
and appropriate environmental standards established under
Federal and State environmental laws unless a statutory
waiver is justified. The selected remedy also must be
cost-effective and utilize permanent solutions and
alternative treatment alternatives or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ
treatment that permanently and significantly reduces the
volume, toxicity, and mobility of hazardous substances. The
following sections discuss how the selected remedy meets the
statutory requirements.

The selected remedy satisfies the requirements of Section 121
of CBRCLA.
Overall Protection
The selected remedy will permanently treat the groundwater
and sludge/soil, and will remove or minimize the potential,
risk associated with the ingestion of contaminated
groundwater, as well as the potential risks due to dermal
contact and incidental ingestion of contaminated
sludge/soil.
ComDliance With ARARs

The selected remedy will be designed to meet all Federal or
more stringent State environmental laws. A listing of the.
ARARs which are to be attained is included in Section VII.
This section also describes the TBC materials.

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-104-
Utilization of Permanent Solutions and Alternative Treatment
Technoloaies or Resource Technoloaies to the Maximum Extent
Practicable
The selected remedy represents the maximum extent to which
permanent solutions and treatment can be practicably utilized
for this action. Of the alternatives that are protective of
human health anq the environment and comply with ARARs, EPA
and the State have determined that the selected remedy
provides the best balance of trade-offs in terms of long-term
effectiveness and permanence; reduction in toxicity,
mobility, or volume achieved through treatment; short-term
effectiveness, implementability, and cost; State and
community acceptance, and the statutory preference for
treatment as a principal element.

Preference for Treatment as a PrinciDal Element
The preference for treatment is satisfied by the use of
oxidation-reduction, stabilization, and capping to meet
cleanup levels for the sludge/soil and the use of alkaline
chlorination, precipitation/filtration, air stripping, and
carbon adsorption to treat contaminated groundwater at the
Site. The pri~cipal threats at the Site will be mitigated by
use of these t~eatment technologies.

Cost
The selected groundwater and sludge/soil remediation
technologies are most cost-effective when compared with the
other acceptable alternatives considered. The selected
remedies provide greater benefit for the cost because they
permanently treat the waste.
XII.
~08 OP SIGBIPICAJIT DIPPBRB1iCB
The propo.ed plan i.sued by EPA in April 1992 selected
Alternative 4 for both groundwater and sludge/soil
remediation. In relation to the sludge/soil remediation, . the
proposed plan required excavation, oxidation-reduction,
stabilization, backfilling (on-site disposal), and a non-RCRA
cap.

The determination of whether to use a non-RCRA cap versus a
RCRA cap will depend on the type of material that will be
backfilled at the Site. The sludge/soil at the Site is
qonsidered to be a mixture of RCRA F006/F019 listed hazardous
waste, soil, aDd any debris present in the area of c~ncern.

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-105-
Based on the results of the treatability study, a delisting
of the waste may be sought. If the waste material is
delisted, then a non-RCRA cap (RCRA subtitle D), will be used
to cover the backfilled material. The proposed plan included
this type of cap.
However, in the event that the waste material to be
backfilled is not delisted before capping, the material wiil
still be considered a RCRA F006/F019 listed hazardous waste.
Therefore, the waste material will require handling and
disposal as a RCRA hazardous waste (including a RCRA subtitle
C cap). Based on the contingency of not being able to delist
the waste, the selected remedy will require a RCRA subtitle C
cap, as described in section X of the Record of Decision.
This eventuality differs from the non-RCRA cap included in
the proposed plan. This change is required in order to
comply with the applicable RCRA requirements.

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APPENDIX A

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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.o. Box 27687 . Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
William L. Meyer
Director
30 June 1992
Mr. McKenzie Mallary
Remedial Project Manager
US EP A Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE:
Draft Record of Decision
JFD Electronics/Channel Master
. NCD 122263 825
Oxford, Granville County, NC
Dear Mr. Mallary:
The North Carolina Superfund Section has received and reviewed the Draft Record
of Decision for the subject site. A copy of this document has also been forwarded to the
North Carolina Division of Environmental Management (DEM) for concurrent review.
Comments from DEM will be forwarded when they are received by our office. The North
Carolina Superfund Section concurs with the chosen remediation technologies conditioned
on the following requirements being met:
1.
Treatability studies as discussed on page 100 of the ROD will be used durin~
the Remedial Design phase to ensure that the chosen soil remediatioI1
technologies will achieve the cleanup goals.
2.
Onsite disposal of treated soil must meet the requirements of the Nortl~
Carolina Solid Waste Disposal Regulations (NCAC Title 15A, Chapter 13H
Section .0503). Specifically the treated soil may not be deposited less thar
four feet above the seasonal high groundwater .table. It i,) our understandin~
that the treated soil/sludge will contain extractable levels of contaminants les!
than ten times the NC Groundwater standards as specified in NCAC Title 15
Subchapter 2L, Section .0202.
An Equal OpportUnity Affirmative Action Employer

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Mr. Mallary
June 30, 1992
Page 2
5.
3.
The on-site disposal of treated soil/sludge or presence of any residual
contamination that presents an overall total risk greater than 10-6 will require
deed recordation/restriction to document the presence of residual
contamination and limit future use of property as specified in 0.5. 130A-
310.8.
4.
The minimum buffer requirements as set forth in North Carolina Location
Requirements for Hazardous Waste Facilities (NCAC Title 15A, Chapter
13A, Section .0009 [c and r]) must be met for any proposed on-site treatment
technology. 'Data must be presented to address the applicable risk posed
standards for the North Carolina Location Criteria in NCAC Title 15A,
Chapter 13A, Section .0009 (c and r).
The proposed soil cleanup level of 310 ppm as specified in Table 19 of the
ROD should assume all of the chromium is trivalent, not hexavalent as
indicated in Table 19.
The North Carolina Superfund Section appreciated the opportunity to review this
document. If you have any questions please contact me at (919) 733-2801.
JB/dk/19
Sincerely,
~~&~/

Jack Butler, PE
Environmental Engineering Supervisor
Superfund Section
cc:
Curt F ehn

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     3        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

  ^                         REGION  IV
                        345 COURTLAND STREET. N E
                         ATLANTA. GEORGIA 3O365

 Jtfl  0 $ S92

 4WD-NSRB

 Mr.  Jack  Butler
 North Carolina Dept. of Environment,
 Health,  and Natural Resources
 401  Oberlin  Road,  Suite 150
 Raleigh,  North Carolina  27605

 Subject:  Responses to ROD  Comments
          JFD Electronics/Channel Master Site

 Dear Mr.  Butler:

 EPA-Region IV appreciates  the State's conditional concurrence
 with the  Record of Decision (ROD) for the JFD Electronics/
 Channel Master site located in Oxford, North Carolina.  For
 the  record,  EPA would like to respond to the comments made by
 NCDEHNR-Superfund Section, as submitted in your letter to me
 dated June 30, 1992.  The purpose of these responses is
merely to reflect our telephone conversation made on July 9,
 1992 with Curt Fehn.  This letter, along with your June 30,
 1992 letter, will be included as an appendix to the ROD.
These letters should stand as offical documentation that
EPA-Region IV and NCDEHNR-Superfund Section have agreed on
the preferred alternatives at this point in time, based on
the  following conditions:

     1)   that Treatability Studies will be conducted on the
         chosen remedies to ensure that the cleanup levels
         can be met;

    2)   that clean fill will be placed into the excavated
         sludge pits to ensure that the treated sludge/soil
         will not be deposited less than four feet above the
         seasonally high water table, and that by doing so,
         the original grade of the area will be affected
          (without any lateral expansion). We also agreed that
         a cap would be necessary on top of the affected
         area;

    3)   the treated sludge/soil will pass TCLP.  As stated
         in  the past, EPA's position is that the State's
         policy of comparing extractable levels of
         contaminants to either its groundwater standards or
         ten times its groundwater standards is not
         enforceable and thus not an ARAR.  However, we
         anticipate that,  at this Site, the treated
         sludge/soil will probably contain extractable levels
         of  contaminants less than ten times the NC
         Groundwater Standards as specified in NCAC Title  15,
         Subchapter 2L, Section  .0202;
                                                         Printed on Recycled Paper

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-2-
4)
that, in the future, the State may put in place,
persuant to State law (G.S. 130A-310.8), a deed
recordation to document the presence of an "inactive
hazardous substance or waste disposal site";
5)
that the location requirements (NCAC Title 15A,
Chapter 13A, Section .0009 (c and r» for the Site
regarding the location of any treatment units with
regard to a 100-year floodplain will be met. We
also agreed that the sludge bed area (or future
treatment/disposal area), to the best of our
knowledge, does not violate location requirements
with regard to its proximity to residential
dwellings, wells, or any other requirement; and
that the sludge/soil cleanup level for chromium (310
ppm for a child) is calculated for hexavalent
chromium, whereas the calculated cleanup level for
trivalent chromium is 59,500 ppm for a child.

Please contact me at (404) 347-7791 if you have any questions
or comments regarding this matter.
6)
Sincerely,
i1~t~~1f

McKenzie Mallary
Remedial Project Manager
cc: Curt Fehn

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