United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-93/130
December 1992
f/EPA Superfund
Record of Decision:
Koppers (Morrisville Plant),
NC
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-93/130
3. Recipient's Accession No.
Titlo and Subtitle
SUPERFUND RECORD OF DECISION
Koppers (Morrisville Plant), NC
First Remedial Action - Final
5. Rgport Dal*
12/23/92
7. Author(s)
8. Performing Organization Rapt. No.
9. Performing Organization Nam* and Address
10 Project Task/Work Unit No.
11. CentraeUO or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/800
14.
15. Supplementary Not^-
PB94-964026
16. Abstract (Limit: 200 words)
The 52-acre Koppers (Morrisville Plant) site is a wood laminating facility in Wake
County, Morrisville, North Carolina. Land use in the area is predominantly a mixture
of commercial, light industrial, and rural residential. Residents near the site
currently use the public water lines to obtain their drinking water supply. The site
contains several ponds and streams that drain eventually into Crabtree Lake. .From 1896
to 1961, the site was owned by the Gary Lumber Company, then subsequently by Unit
Structures. In 1962, Koppers purchased the site and began treating wood onsite using a
process known as CELLON. In this process, solvents, including PCP and isopropyl ether,
were injected into the wood, and the rinsate from this process was pumped directly into
two unlined lagoons at the site. In 1975, Koppers discontinued use of the CELLON
process and began receiving pretreated wood for their operations. As a direct result
of these past wood treatment processes and associated improper disposal activities, the
site has been contaminated with organics, including pentachlorophenol, m.dioxins and
isopropyl ether. In 1976, Koppers voluntarily began to conduct environmental studies
at the site focusing on the CELLON process area and the lagoon area. Based on these
studies, it was recommended that the two lagoons should be reclaimed by land treatment,
and the liquid contents of the lagoons subsequently were pumped out and land farmed, or
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Koppers (Morrisville Plant), NC
First Remedial Action - Final
Contaminated Media: soil, gw, sw
Key Contaminants: organics (dioxins, phenols)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Rsport)
None
20. Security Class (This Page)
None .
21. No. ol Pages
118
22. Price
(SeeANSI-239.18)
See Instructions on Rfvtrse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R04-93/130
Koppers (Morrisville Plant), NC
First Remedial Action - Final
Abstract (Continued)
sprayed. In 1980, Koppers conducted additional studies of the onsite ground water and
soil, which prompted three private removals between 1980 and 1986, in which a total of
1,560 yd-3 of contaminated soil were removed from the lagoon area and 150 yd^ were removed
from other site areas, with offsite disposal at a permitted facility. In 1980, EPA
evaluated two of the onsite ponds and several private wells, and documented that no
further action was considered necessary at the time. In 1986, Beazer and the State
investigated the ground water to determine if any of the contamination at the site had
migrated into private wells in the immediate vicinity of the site. In 1989, based on
study results, the State required Beazer to extend the public water supply lines to
affected residences; to conduct ground water sampling at the site on a quarterly basis;
and to provide bottled water to those residences who were not connected to the water line
extension. In 1990, EPA required extensive studies of the soil, ground water, drainage
pathways, and ponds, and also has determined that additional studies were needed to
further assess contamination of the surface soil in the lagoon and CELLON process areas.
This ROD addresses contamination of onsite soil, ground water, and surface water, as the
final action for this site. The primary contaminants of concern affecting the soil, ground
water, and surface water are organics, including dioxins and phenols.
The selected remedial action for this site includes excavating and mobilizing
approximately 2, 930 yd^ of soil from the lagoon and process areas to an offsite
incineration facility for treatment, with offsite disposal of the resultant ash at a
permitted landfilling facility; backfilling any excavated areas with clean fill, with
regrading and revegetation; extracting and treating contaminated ground water onsite using
equalization and filtration to remove solids, followed by carbon adsorption to remove
organics, with discharge of the treated effluent onsite to surface water, or offsite, if
no viable surface water discharge point exists onsite; dewatering and backfilling the
onsite ponds with clean fill; treating the pond water onsite using carbon adsorption, with
discharge of the treated effluent onsite to the surface water, or offsite if no viable
surface water discharge point exists onsite; regrading the site areas to promote proper
drainage flow, and mitigating any affected wetlands; conducting treatability studies to
determine the effectiveness of treating the soil onsite using dechlorination, as a
contingency remedy; and fencing of the pond, lagoon, and CELLON process areas. The
estimated present worth cost for this remedial action is $11,500,000, which includes an
annual O&M cost of §3,612,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS:
All soils contaminated with greater than 95 mg/kg PCP and/or 7 ug/kg dioxins/furans will
be excavated and removed offsite for treatment. Chemical-specific soil cleanup goals are
based on RCRA Land Disposal Requirements (LDRs) and a risk factor of 10~3.
Chemical-specific ground water cleanup goals are based on SDWA MCLs and a risk level of
10~6 and include PCP 1 ug/1; 2,4-dichlorophenol 20 ug/1; and dioxins/furans 0.00003 ug/1.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
KOPPERS CO., INC. (MORRISVILLE PLANT) SITE
MORRISVILLE, WAKE 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
Koppers Co., Inc. (Morrisville Plant) Site
Morrisville, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Koppers Co., Inc. (Morrisville Plant) Superfund Site in
Morrisville, 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 practicable, 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. EPA Headquarters concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy addresses the current and future unacceptable
risks posed by the Site to human health and the environment.
A primary remedy and a contingency remedy have been selected for
soils. The primary selection for soils, alternative S-9, will
permanently remove and destroy contamination in the soil through
treatment. This alternative involves off-site incineration of the
soils at a permanent permitted facility, to include:
0 Excavation of contaminated soils from the lagoon and
process areas onsite to meet cleanup standards,
0 Transportation of soils to an offsite permitted
incineration facility,
0 Backfilling of excavation areas with clean fill,
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0 Final regrading and revegetation of the excavated areas.
Dechlorination Treatability Studies will be conducted on soils.
Based upon the results, the contingency remedy unitlizing the
dechlorination process known as Base Catalyzed Dehalogenation, may
be selected as the contingency remedy for soils. The contingency
remedy would be required to permanently remove and destroy
contamination in the soil. If selected, would include:
0 Excavation of contaminated soils from the lagoon and
process areas onsite to meet cleanup standards,
0 Mobilization of soils to an onsite dechlorination
treatment system,
0 Backfilling of excavation areas with clean, treated
soils,
° Final regrading and revegetation of the excavated areas.
Alternative GW-4 for groundwater will remove site-related
contaminants in the groundwater through groundwater extraction and
on-site treatment by carbon adsorption. The following activities
are involved in this alternative:
0 Contaminated groundwater will be extracted from within
the plume via extraction well(s) and piped to an onsite,
above-ground treatment unit.
0 Treatment will consist of carbon adsorption through a
primary carbon adsorption unit and a secondary carbon
polishing unit.
0 Final discharge of the effluent will be to the surface
water, stipulated by the substantive requirements of the
National Pollutant Discharge Elimination System. If no
viable surface water discharge point exists on the site,
the discharge may be offsite, thereby requiring a permit
under the National Pollutant Elimination System.
0 Further delineation of the horizontal and vertical extent
of groundwater contamination will be conducted.
Alternative SW-3 for surface water will remove site-related
contaminants in the surface water by the dewatering of the ponds,
backfilling with clean fill, and regrading the areas for proper
drainage flow. Activities of the surface water component of the
remedy consist of:
0 The onsite Fire Pond and the Medlin Pond will be
dewatered.
0 The ponds will be backfilled with clean fill.
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The surface water will be treated by carbon adsorption.
Final discharge of the effluent will be to the surface
water., stipulated by the substantive requirements of the
National Pollution Discharge Elimination System. If no
viable surface water discharge point exists on the site,
the discharge may be offsite, thereby requiring a permit
under the National Pollution Elimination System.
Final regrading and drainage control of the pond areas
will be conducted.
Wetlands will be destroyed under this portion of the
remedy. Therefore wetlands mitigation will be required
under this remedy. Final location and requirements of
this mitigation will be decided during Remedial Design.
Evaluation of the associated habitats will be conducted
under a Habitat Restoration Plan.
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. This remedy utilizes permanent
solutions and alterative treatment and resource recovery
technologies, to the maximum extent practicable, and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal 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.
Patrick M. Tobin Date
Acting Regional Administrator
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TABLE OF CONTENTS
SECTION PAGE No.
1. 0 SITE NAME, LOCATION, AND DESCRIPTION 1
2 . 0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
4.0 SCOPE AND ROLE OF THE RESPONSE ACTION WITHIN SITE
STRATEGY 8
5 . 0 SUMMARY OF SITE CHARACTERISTICS 8
6 . 0 SUMMARY OF SITE RISKS 15
6.1 Contaminants of Concern 30
6.2 Exposure Assessment 35
6.3 Toxicity Assessment 37
6.4 Risk Characterization 39
6.5 Risk Uncertainty 41
6.6 Ecological Risk 43
6.6.1 Fire Pond 43
6.6.2 Medlin Pond 43
6.6.3 Summary of Ecological Risk 43
7.0 DESCRIPTION OF ALTERNATIVES 44
7.1 Remedial Alternatives to Address Soil
Contamination 44
7.1.1 Alternative S-l: No Action 45
7.1.2 Alternative S-3: Surface Cover 45
7.1.3 Alternative S-4: Surface Capping 45
7.1.4 Alternative S-5: Excavation and On-site
Landfill 46
7.1.5 Alternative S-6: Excavation and Off-site
Landfill 46
7.1.6 Alternative S-7: Excavation and On-site
Treatment by Dechlorination Process and
Replacement of Treated Soils 47
7.1.7 Alternative S-8: Excavation and On-site
Incineration 48
7.1.8 Alternative S-9: Excavation and Off-site
Incineration 48
7.1.9 Alternative S-10: Excavation and On-site
Storage 49
7.2 Remedial Alternatives to Address Groundwater
Contamination 50
7.2.1 Alternative GW-1: No Action 50
7.2.2 Alternative GW-3: Extraction, Above-ground
Bioremediation, Surface Water Discharge 53
7.2.3 Alternative GW-4: Extraction, Above-ground^
Pretreatment and Carbon Adsorption, Surface
Water Discharge 53
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TABLE OF CONTENTS (cont.)
SECTION PAGE No.
7.2.4 Alternative GW-5: Extraction, Above-ground
Pretreatment and UV/Chemical Treatment,
Surface Water Discharge 54
7.3 Remedial Alternatives to Address Surface Water
Contamination 55
7.3.1 Alternative SW-1: No Action 55
7.3.2 Alternative SW-3: Fond Dewatering, Surface
Water Treatment, Surface Water Discharge,
Backfilling in Pond 57
7.3.3 Alternative SW-4: Pond Dewatering, Surface
Water Treatment, Pond Lining and Refilling...58
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 59
8.1 Threshold Criteria 59
8.1.1 Protection of Public Health and
Environment 59
8.1.1.1 Protection of the Environment 60
8.1.1.2 Protection of Human Health 61
8.1.2 Compliance with Applicable or Relevant and
Appropriate Requirements ...63
8.1.2.1 Soils 64
8.1.2.2 Groundwater., 64
8.1.2.3 Surface Water 65
8.2 Evaluating Criteria 65
8.2.1 Cost 65
8.2.2 Implementability 65
8.2.3 Short-Term Effectiveness 66
8.2.4 Long-Term Effectiveness 86
8.2.5 Reduction of Mobility, Toxicity, and
Volume 87
8.3 Modifying Criteria 87
8.3.1 State Acceptance 87
8.3.2 Community Acceptance 88
9.0 SELECTED REMEDY 88
9.1 Source Control 89
9.1.1 Primary Source Control Remedy 89
9.1.2 Contingency Source Control Remedy 89
9.1.3 Excavation and Performance Standards 90
9.2 Groundwater Remediation 91
9.2.1 Extraction and Performance Standards 91
9.3 Surface Water Remediation 94
9.4 Additional Components 94
9.4.1 Sampling Requirements 94
9.4.2 Groundwater Evaluation and Plume Definition..95
9.4.3 Fencing and Maintenance 95
9.4.4 Habitat Evaluation 95
9.5 Compliance Monitoring 95
9.6 Applicable or Relevant and Appropriate Requirements.95
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TABLE OF CONTENTS (cont.)
SECTION PAGE No.
10.0 STATUTORY DETERMINATION 99
10.1 Protection of Human Health and the Environment 100
10.2 Compliance with Applicable or Relevant and
Appropriate Requirements 100
10.3 Preference for Treatment 100
10.4 Cost Effectiveness 100
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES 101
ill
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LIST OF FIGURES
FIGURE PAGE No.
1.1 Site Features Map 2
2.1 Location of Lagoon Area 4
5.1 Soil Sample Locations 10
5.2 Major Contaminant Concentrations: Process and Lagoon
Areas 13
5.3 Onsite and Near Off-site Monitoring Well Locations 14
5.4 Off site Monitoring Well Locations 16
5.5 Private Well Sampling Locations 17
5.6 Pentachlorophenol Groundwater Plume (>MCL) .22
5.7 Dioxin Detections i:i Groundwater 23
5.8 Surface Water Sampling Locations 24
5.9 Sediment Sample Locations 25
6.1 Site Divisions by Use and Contaminant Distribution 32
7.1 Pentachlorophenol Groundwater Plume (>MCL) 51
7 .2 PCDD/PCDF Detections 52
7.3 Pond Locations 56
IV
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LIST OF TABLES
PAGE No.
5.1A Contaminant Concentration Ranges in Surface
Soils in Process and Lagoon Areas 11
5.IB Contaminant Concentration Ranges in Subsurface
Soils in Process and Lagoon Areas 12
5.2A Contaminant Concentration Ranges in Groundwater:
Eastern Area. 18
5.2B Contaminant Concentration Ranges in Groundwater:
Western Area 19
5.2C Contaminant Concentration Ranges in Groundwater:
Off site 20
5.2D Contaminant Concentration Ranges in Groundwater:
Lagoon and Process Area 21
5.3 Contaminant Concentration Ranges in Surface Water:
Fire Pond 26
5.4 Contaminant Concentration Ranges in Surface Water:
Medlin Pond 27
5.5 Contaminant Concentration Ranges in Sediment: Fire
Pond 28
5.6 Contaminant Concentration Ranges in Sediment: Medlin
Pond 29
6.1 Representative Concentrations - Surface Soils,
Process and Lagoon Areas 31
6.2 Representative Concentrations - Subsurface Soils,
Process and Lagoon Areas 31
6.3 Representative Concentrations - Surface Water,
Fire Pond and Western Ditch 33
6.4 Representative Concentrations - Sediment,
Fire Pond, Fire Pond Discharge and Western Ditch....33
6.5 Representative Concentrations - Fish,
Medlin Pond and Fire Pond 33
6.6 Representative Concentrations - Groundwater 34
6.7 Major Assumptions for Residential Scenario 36
6.8 Major Assumptions for Onsite Worker Scenario 37
6.9 Cancer Slope Factors 38
6.10 Reference Doses 38
6.11 Current Carcinogenic Risks, Local Resident and
Onsite Worker 40
6.12 Future Carcinogenic Risks, Off site Resident 41
6.13 Future Carcinogenic Risks, Onsite Resident 42
6.14 Chronic Ecological Hazard Quotients 44
8.1 Potential Action-Specific ARARs 67
8.2 Potential Location-Specific ARARs 75
8.3 Potential Chemical-Specific ARARs 76
8.4 Potential Action-Specific ARARs (North Carolina)....77
8.5 Potential Location-Specific ARARs (North Carolina)..83
8.6 Potential Chemical-Specific ARARs (North Carolina)..84
8.7 Estimated Costs of Alternatives 85
9.1 Groundwater Cleanup Goals: Major Contaminants 92
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Record of Decision
Summary of Alternative Selection
Koppers Co., Inc. (Morrisville Plant) Site
Morrisville, North Carolina
1.0 Site N**"»e. Location and Description
The Koppers Co., Inc. (Morrisville Plant) Site is located in
Morrisville, North Carolina which is in Wake County. The 52 acre
site is located at the intersection of Highway 54 and Koppers Road.
The property of the site is owned by two companies: Beazer East,
Inc. ("Beazer") and Unit Structures, Inc. Beazer East is the
successor to the Koppers Company. The Koppers Company had
conducted wood treatment operations at the site. Unit Structures,
Inc. purchased portions of the site property in 1986 and currently
operates a wood laminating facility on approximately 80% of the
original site property. The portion of the site currently owned by
Beazer is inactive.
Figure 1.1 is a facility map which indicates the site features.
The process area and the lagoon area are both located near the Fire
Pond in the southeastern section of the site. The landfarm area is
the northernmost section of the site proper. The surface drainage
ditches on the eastern and western boundaries of the site are
shown. The western ditch flows downstream in a southerly direction
and merges with the outflow ditch of the Medlin Pond. The Fire
Pond outflow ditch flows into the Medlin Pond. The confluence of
these surface water features flows downstream and drains into
Crabtree Creek and subsequently into Crabtree Lake.
Land use is the area is a mixture of commercial, light industrial
and rural residential. Drinking water was obtained from private
wells prior to 1989. Public water lines have been extended to the
immediate area around the site by Beazer under an Administrative
Order by Consent entered into with the Environmental Protection
Agency in May of 1989.
2.0 Site History »T»d Enforcement Activities
History of the site ownership dates back to 1896. Gary Lumber
Company occupied the site and sold the property to a company known
as Unit Structures, Inc., in 1961. The original Unit Structures
company is unrelated to the present company at the site today.
Only the name is the same. The following year, in 1962, Unit
Structures sold the property to Koppers Company, Inc., ("Koppers").
At that time, Koppers began treating wood using a process known as
CELLON. CELLON treatment consisted of injection of
pentachlorophenol into the wood. Pentachlorophenol is a main
contaminant at the site. Isopropyl ether (IPE) was used as a co-
solvent in the process to increase the solubility of
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HK'irr I.I
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
pent-chlorophenol in a butane carrier. Synonyms for
pentachlorophenol are Fir and penta. These synonyms are used
interchangeably throughout the Administrative Record.
After treatment, residual pentachlorophenol was removed by a steam
process. The rinsate was processed by a coagulant to remove excess
pen-;achlorophenol which *s then filtered off. The final rinsate,
presumed to be predominantly water, was pumped into two onsite
lagoons. It is believed that these lagoons were not lined. Figure
2.1 presents the locations of the lagoons.
The CELLON process was used at the site from 1968 until 1975.
Beazer has stated that after the CELLON process was discontinued,
the facility began receiving pretreated wood to continue
operations.
In 1976, Koppers voluntarily began to conduct environmental studies
at the site focusing on the CELLON process area and the lagoon
area. According to the history of the site provided by Beazer and
based on those studies, it was recommended that the two lagoons be
reclaimed by land treatment. In 1977, the liquid contents of the
lagoons were pumped out and landf armed, or sprayed, in the
northernmost portion of the site. This area is identified on site
figures and in the Administrative Record as the landf arm area.
Fertilizer was spread over the area and the area was plowed again.
The lagoon bottom sludges were mixed with surrounding soils and
spread to dry over the former lagoon areas. The lagoon areas were
also fertilized and seeded. By definition, the lagoon contents
sprayed in the landfarm area are considered F032 wastes; likewise,
the lagoon bottom sludges which were placed back in the same area
are characterized as K001 wastes.
Beginning in 1980, Koppers conducted more studies on the site.
Investigations of groundwater and soils were conducted. Results of
these investigations prompted the following soil removal actions.
During the spring of 1980, approximately 220 cubic yards of
contaminated soil were removed from the lagoon area. Later that
same year, 240 more cubic yards of contaminated soil were removed
from the area. In 1986, another soil removal was conducted.
Approximately 1100 cubic yards were taken from the lagoon area, 50
cubic yards from the filter bed area and 100 cubic yards from the
blowdown pit area. According to Beazer, final disposal of these
soils was to permitted facilities.
In 1980, the Environmental Services Division (ESD) of the
Environmental Protection Agency (EPA), conducted a site inspection
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Figure 2.1
H —
i
•i
*D /
f^L. ' \
, Aflpaaxn
f
UTF ST7XAM LOCATION
0 (
f»
•
. • \
^ .• \
d>
;0; /
Location of l.agoon
Area
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
of the Fire pond, the Medlin pond and select private wells. No
further action was considered necessary at that time. In 1986,
Beazer began sampling off site private residential wells. North
Carolina Division of Health Services, Superfund Branch also began
investigating the groundwater in the area to determine if any of
the contamination at the site had migrated into private wells in
the immediate vicinity of the site. Eventually, a cooperative
effort between the State of North Carolina and Beazer began
monitoring private wells in the vicinity. This sampling has been
conducted on a quarterly basis since February 1989, and continues
to be a part of the program at the site. This effort remains a
cooperative effort between Beazer and the State. Based on the
results of the private well sampling, Beazer provided bottled water
to all residents whose wells showed any detectable amounts of
isopropyl ether or pentachlorophenol. This action was elected
during the re-evaluation of the carcinogenicity of
pentachlorophenol.
In May.of 1989, EPA and Beazer entered into an agreement for Beazer
to install a public water line to the affected area. The specific
terms of the water line construction were developed between Beazer
and the town of Morrisville. Beazer tied into a pre-existing line
installed along Koppers Road. Beazer continues to provide bottled
water to some residences which did not connect to the water line
extension.
Very few of the private wells had concentrations of
pentachlorophenol which exceeded the current maximum contaminant
level (MCL) of 1 ppb identified under the Safe Drinking Water Act.
No MCL or State standard exists for isopropyl ether.
In 1986, the North Carolina Superfund Branch of the North Carolina
Department of Environment, Health and Natural Resources, conducted
an inspection of the site which was employed in the development of
the Hazard Ranking System package. The site was proposed to the
National Priority List (NFL) on June 24, 1988 principally due to
the groundwater contamination. Final rule and inclusion on the NFL
occurred on March 31, 1989.
In March of 1989, the Environmental Protection Agency signed an
Administrative Order on Consent which allowed Beazer to conduct the
Remedial Investigation and Feasibility Study for the site. Beazer
may also be referred to as the potentially responsible party or PRP
in this decision document and in the Administrative Record. In
November of 1989, the Work Plan for this work was approved. During
1990, extensive field work was conducted on soils, groundwater,
drainage pathways and the ponds. In June of 1991, it was
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
determined by the Agency that additional field work was required,
specifically on surface soils in the lagoon and CELLON process
areas. Additional groundwater sampling has also been conducted.
In 1986, a company known as Unit Structures, Inc., ("USI"),
purchased approximately 40 acres of the Site from Koppers. As part
of the settlement of certain legal matters between USI and Beazer,
USI reconveyed certain portions of the property back to Beazer in
March 1992. USI continues to own portions of the Site.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The EPA has encouraged public participation since NPL inclusion.
The community has an active association, the Shiloh Coalition for
Community Control and Improvement, that was established before the
site was finalized on the NPL. More recently a subgroup has been
formed out of the coalition which identifies itself as the Clean
Water and Environment Project. Other citizens and groups have
participated, but the Coalition represents the most vocal and
active sector in the community.
The community has been quite organized in their participation of
site activities and have held their own public meetings of which
EPA was sometimes invited to attend. A total of four public
meetings have been held by the Agency. Periodic fact sheets have
been distributed to update the community during the Remedial
Investigation and Feasibility Study.
EPA has solicited both formal and informal comments from the
community since initial development of the work plan. Documents
were placed in the information repository at the Gary Branch of the
Wake County library for review. Input received from the public has
influenced EPA's level of oversight of the investigation as well as
the substance of the project. EPA increased its oversight presence
during field activities in response to community concerns. Site
areas were further investigated as a result of specific input from
the community.
The community has had concerns with Beazer performing the work and
has frequently suggested that EPA should be doing the investigative
work instead of the PRP. This concern was heightened during the
development of the Baseline Risk Assessment. The community felt
that the report would not accurately reflect the hazards present at
the site.
A major concern of the community has been with the contamination
impact on groundwater in an area where most people have
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
traditionally used wells for domestic water supply. An alternative
water supply was provided to all residents whose wells showed any
detectable amounts of pentachlorophenol or isopropyl ether.
Bottled water was originally provided; permanent water lines were
installed later. Some residents continue to receive bottled water
if the location of the resident is not in close proximity to the
water line to make hook up feasible. The City of Morrisville
required that annexation petitions be submitted prior to hookup.
The resulting increase in taxation and the costs associated with
hookup have been a primary source of anger and frustration for many
of the residents. EPA's Regional Administrator sent a letter by
personal courier to a Town Council meeting requesting a waiver
and/or reconsideration of this requirement. However, the Town of
Morrisville decided to maintain the annexation requirement.
The local community was awarded a Technical Assistance Grant in the
fall of 1991. The EPA approved the use of the small purchase
procurement method which allowed faster hiring of a technical
advisor than is usual practice.
A public meeting was held on April 8, 1992 to discuss the findings
of the Remedial Investigation. Potential remedial technologies
were discussed. The public comment period on the proposed plan was
held from July 17, 1992 to September 16, 1992. A 30-day extension
was requested and is incorporated into this public comment period.
The Administrative Record is. located in the Site Information
Repository at the Gary Branch of the Wake County Public Library.
Public notice was provided as a display advertisement in the
Raleigh News and Observer on July 17, 1992, and as a press release
on July 21, 1992. It was also published as a public service
announcement on two cablevision advertisement stations during the
week of July 19, 1992. The formal public meeting identifying the
proposed plan was held on July 23, 1992 in accordance with CERCLA
Section 117(a)(2). The transcript of this meeting is enclosed as
part of the Responsiveness Summary. The Responsiveness Summary
also includes responses to community concerns which have been
expressed during the formal public comment period. All
requirements of CERCLA Sections 113(k} (2) (B)(i-v) and 117 have been
met.
An availability session was held on September 3 and 4, 1992 to
provide citizens with a second opportunity to express concerns and
ask questions directly to EPA representatives prior to the end of
the public comment period. An announcement was mailed to all
community members listed on the EPA site mailing list.
-7-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
4.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The response action defined in this Record of Decision (ROD) is
anticipated to be the final action and subsequently the final ROD
for this site. No separate Operable Units are anticipated as this
remedy will address all aspects of the site which currently pose a
threat to human health or the environment. Remediation of the
groundwater will be to levels that will allow the aquifer to be
returned to safe drinking water levels. Remediation of the soil
contamination will both eliminate direct exposure risks to onsite
workers as well as eliminate future adverse impacts to the
groundwater. Remediation of the surface water will eliminate
exposure pathways of site related contaminants to ecological
populations.
5.0 SUMMARY OF SITE CHARACTERISTICS
The Site has been subjected to the requirements of CERCLA which
mandate that a Remedial Investigation be conducted. This
description of site characteristics is based on that Remedial
Investigation, and presents a summary of the results. Further
detail can be obtained from the Remedial Investigation report,
contained in the Administrative Record for this Site.
The Remedial Investigation included the sampling and analysis of
groundwater, soils, surface water systems, associated sediments and
fish. The results of this sampling and analysis indicate that the
contamination generated by the use of the CELLON wood preserving
process has adversely impacted groundwater, soils and surface
waters at and in the vicinity of the site. Samples were analyzed
predominantly for extractable organic compounds, also known as
semi-volatile compounds, since pentachlorophenol was the main
chemical component of the wood treatment. Further refinement
categorized the majority of the site related contaminants as
phenolics. Approximately 15 % of all environmental samples, with
the exception of fish samples, were analyzed for metals, volatiles,
semi-volatiles, pesticides and PCBs to ensure that the historical
information available for the site was accurate and that additional
unknown contaminants were not adversely affecting the Site.
Analysis for PCDD/PCDF was also required of a percentage,
(approximately 15%), of the environmental samples collected during
the Remedial Investigation. PCDD/PCDF is known to be a contaminant
of pentachlorophenol. PCDDs/PCDFs refer to polychlorinated
dibenzo-p-dioxins and polychlorinated dibenzofurans, which are also
more commonly referred to as dioxins. TCDDs/TCDFs are the
tetrachlorinated congeners substituted in the 2,3,7,8-
configuration, specifically 2,3,7,8-tetrachlorodibenzo-p-dioxin and
2,3,7,8-tetrachlorodibenzofuran. Pentachlorophenol and PCDD/PCDF
are considered the major contaminants at the Site. Other phenolic
-8-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
compounds and isopropyl ether, a volatile organic compound, have
been identified at the site, but are considered minor site
contaminants due to frequency of detection and concentration.
The investigation of soil focused on the former process and lagoon
areas, the former landfarm area, the tepee area and the remaining
site proper. Figure 5.1 provides the locations of the soil samples
collected during the RI. Surface and varying depths of subsurface
soils were used in the characterization of the soils. The
analytical results demonstrate that the contamination in the former
process and lagoon areas poses a significant threat for human
exposure from direct contact as well as a potential source of
contamination to the groundwater. Tables 5.1A and Table 5. IB
identify site contaminants and the concentration ranges. Figure
5.2 provides the contaminant concentrations of the major
contaminants pentachlorophenol and TCDD toxic equivalents in the
former process and lagoon areas for surface soils. A concentration
range for total phenolics is also shown. Subsurface soil
concentrations are lower; Figure 5.2 shows maximum concentrations.
The former lagoon and process areas have been determined to be the
only areas of the site which currently contain unacceptable levels
of soil contaminants. Investigation of the land-farm area did not
demonstrate levels of contaminants which posed a risk to human
health or the environment; no offsite soils were identified to
contain unacceptable levels of soil contaminants. The volume of
contaminated soil in the lagoon and process areas originally
estimated in the Remedial Investigation Report was approximately
1000 yds3.
EPA had independent volume estimates conducted on the contaminated
soil based on electronic data provided by Beazer. This was
conducted in an effort to examine the accuracy of Beazer's volume
estimates. An upper bound estimate was determined at 10,000 yds3.
EPA qualified this estimate as a possible worse case scenario. The
data used for PCDD/PCDF had not been converted into toxicity
equivalency factors, and therefore is considered to be overly
conservative. A second independent volume estimate was conducted
by the University of Cincinnati; the result was an estimate of 2930
yds3. This Record of Decision will use the 1000 yd3 for costing
purposes. The final volume can only be determined after excavation
and confirmed by quantitative analysis. Changes in volume will not
affect the selection of the remedy.
Groundwater contamination was known prior to the initiation of the
Remedial Investigation and was the primary reason the site was
placed on the National Priority List. Figure 5.3 provides onsite
-9-
-------
5.1
i nun
C34 /, 51HA.I SUM SMI |M. IU(«IIOII
A sun Mn,Hr. „»•.,„«
\ HWKUMIIMI 'Hill IMHI1IK. UH»IH»I
— — W»/IH l»!il. IW 1 1«» •III II Km. ,,«
NU1I
IMIIKIKMII Mil MM1I5 rulli Illi VI*
SHIBT iiw. *i lift luiiMiNn luCAitor.
I S. « .%. » JO IM. • I'. WH» " V.I III
t, «oo w
II (•••>'• •'. I
Soil S.mi|ili- I.IK .It Ions
-------
Koppers Company, inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
Table 5.1A
SURFACE SOILS -
Process & Lagoon Areas
Contaminant
phenol
2 - ehlorophenol
2 -nitrophenol
2 , 4 -dime thy Iphenol
2,4- dichlorophenol
4 - chloro - 3 -me thy Iphenol
2,4,6- tr ichlorophenol
2 , 4 -dinitrophenol
4 -nitrophenol
2,3,5,6- tetracblorophenol
2 -methyl -4,6- dini trophenol
isopropyl ether
pentaehlorophenol
TCDD-TB
Minimum
(ug/Kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.480
Mftxisus
(ug/Kg)
ND
477.0
ND
646.0
383.0
568.0
190.0
8740.0
ND
3390.0
580.0
ND
3,220,000.00
270
Frequency
of
Detection
0:19
4:19
0:19
1:19
3:19
2:19
1:19
1:19
0:19
5:19
2:19
Otl
16 1 19
5:5
-11-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
Table 5. IB
SUBSURFACE SOILS -
Process & Lagoon Areas
Contaminant
phenol
2 - chlorophenol
2-nitrophenol
2,4- dime thy Iphenol
2 , 4 -di chlorophenol
4 - chloro - 3 -me thy Iphenol
2,4,6- trichlorophenol
2 , 4 -dini trophenol
4 - ni trophenol
2,3,5,6- tetrachlorophenol
2 -me thyl-4 , 6-dini trophenol
isopropyl ether
pentachlorophenol
TCDD-TE
Minimum
(ug/Kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.002
Maximum
(ug/Kg)
ND
1440
707
1320
1120
322
1120
127
640
2680
ND
621
560,000
3.99
Frequency
of
Detection
0:42
13:42
2:42
7:42
12:42
4:42
15:42
1:42
8:42
3:42
3:42
1:3
20:42
13:13
-12-
-------
Figure 5.2
=
."1 - \- LJula
hfM.
a** piid
|':T'5-"j
raira
Major Contaminant.
Concent rat IOIIH
Process and l.agoon
Area
POOR QUA"™
ORIGINAL
-------
HONIIUHIMti Mil
atA.'lll IA.1t. INC. HWtWY BOUNOAHY
imiii VHUCHMS ita: /»»/*«»»• OOUNOAHY
mill
tin MS urn tno AS
* HJMf'lM, ICSf MIL.
9CM.E
0 ISO 300 40O
Un.slte anil Near Off-
Site Monitor IUK Wet I
l.ocat Ions
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
and near site monitoring well locations. Figure 5.4 presents
offsite monitoring well locations. Extensive groundwater sampling
of private wells in the vicinity of the site was conducted. This
investigative effort was not. included in the scope of the Remedial
Investigation. The results of the private well investigation are
part of the Administrative Record and have been used in the
decision making process for remedy selection. The Domestic Well
Sampling Program can be found as Appendix I of the RI Report.
Figure 5.5 shows the private well sampling locations. The MCL for
pentachlorophenol was exceeded in wells OS-8, 5-H, 08-25, 08-12 and
14K during the private wells sampling program.
Tables 5.2.A, 5.2.B and 5.2.C provide the major contaminants and
the concentration ranges for the groundwater in the eastern area of
the site, the western area of the site and offsite, respectively.
Table 5.2.D focuses on groundwater contamination in the lagoon and
process areas. Figure 5.6 demonstrates the pentachlorophenol
groundwater plume defined as any concentration in monitoring wells
exceeding the MCL of 1.0 ppb. Figure 5.7 shows locations where
dioxin has been detected in groundwater. Additional groundwater
sampling of all monitoring wells and select private wells will be
conducted during Remedial Design to better define the lateral and
vertical extent of groundwater contamination.
The surface water investigation included the Fire Pond, the Medlin
Pond, the outflow ditches from both ponds and drainage features
termed the eastern and western ditches. The Fire Pond outflow
ditch progresses into the Medlin Pond; the western ditch converges
with the Medlin Pond outflow ditch and the confluence of these two
continues downstream joining Crabtree Creek 2-3 stream miles south
of the site.
Figure 5.8 shows the locations of the surface water sampling
points. Figure 5.9 presents the locations of sediment samples.
Table 5.3 identifies concentration ranges and frequencies of
detection for surface water samples in the Fire Pond. Table 5.4
provides that information for the Medlin Pond. Tables 5.5 and 5.6
provide the concentration ranges for sediment samples in the Fire
Pond and Medlin Pond respectively.
6.0 SUMMARY OF SITB RISKS
A primary directive under CERCLA is to protect human health and the
environment from both current and future potential exposures to
hazardous substances at Superfund sites. The Baseline Risk
Assessment provides the basis for taking action and indicates the
-15-
-------
> •' Mil •!!• MM MIM *ll
--— K.HH l.-.l |M: MU1RK
--—l.lll SllirllHS IW ••MUtlll,
CI7C
X'
CMC
Figure S.4
Monitoring
Well I .x.i I Ions
-------
Private Well Sampling
Locations
POORJQUAUTY
< ORIGINAL
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
TABLE 5-2. A
Groundwater
Eastern Area
Contaminant
phenol
2 - chlorophenol
2 -nitrophenol
2 , 4 -dime thy Ipbenol
2 , 4 -di chlorophenol
4 - chloro - 3 -methylphenol
2,4,6- trichlorophenol
2 , 4 -dinltrophenol
4 -nitrophenol
2,3,5,6- te trachlorophenol
2 -methyl -4, 6-dinitrophenol
isopropyl ether
pentachlorophenol
TCDD-TE
Minimum
(ug/1)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4.00E-07
Mfl^lff*"*11
(ug/1)
1.7
1.22
ND
ND
307.5
7.91
3.45
ND
3.46
0.73
ND
366
46.5
1.69E-04
Frequency
of Detection
3.12
2:11
0:12
Otll
1:11
2.11
1:11
Otll
2ill
• 1:11
Otl3
Iil4
9»15
3:3
ND - Contaminant was not detected
If the value identified in the Remedial Investigation Report
or Baseline Risk Assessment was below detection limit, the
value is reported as Non-detect for purposed of this Record of
Decision.
-18-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
TABLE 5-2. B
Groundwater
Western Area
Coulrf^nl OA&£
phenol
2 - chlorophenol
2 -nitrophenol
2 , 4 -dine thy Iphenol
2,4- dichlorophenol
4 - chloro - 3 -me thy Iphenol
2,4,6- trichlorophenol
2 , 4 -diaitrophenol
4 - ni tropheno 1
2,3,5,6- tetrachlorophenol
2 -methyl -4,6- dini trophenol
isopropyl ether
pentachlorophenol
TCDD-TB
•
Minimum
(ug/1)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
Ztaxiinum
(ug/1)
155
ND
0.98
ND
ND
9.8
ND
ND
10.7
ND
57.5
2.84
0.18
NA
Frequency
of Detection
2:13
0:13
2:13
0:13
0:13
3:13
0:13
0:13
3:13
0:13
1:16
2:16
9:19
OiO
ND - Contaminant wa« not detected
-19-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
TABLE 5-2. C
Groundwatar
Offsite
Contaminant
phenol
2 • chlorophenol
2 -nitrophenol
2,4- dime thy Iphenol
2,4- di chlorophenol
4 - chloro - 3 -me thy Iphenol
2,4,6- trichlorophenol
2 , 4 -dinitrophenol
4 -nitrophenol
2,3,5,6- tetrachlorophenol
2 -methyl -4, 6 -dinitrophenol
isopropyl ether
pentachlorophenol
TCDD-TE
MI n i union
(ug/1)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
l.OOE-08
Maximum
(ug/1)
32.4
11.5 J
134
ND
35.8
ND
ND
13.5
36.2
16.9 J
98
5.37
0.23
1. SOB- 07
Frequency
of Detection
4t23
1:23
2:23
0>23
3:23
0:23
Ot23
1:23
5:23
2:23
3:27
3:28
14:32
3:3
ND - Contaminant was not detected
J - Estimated Value
If the value identified in the Remedial Investigation Report
or Baseline Risk Assessment was below detection limit, the
value is reported as Non-detect for purposed of this Record of
Decision.
-20-
-------
Koppers Company, Inc. Sice
Morrisville, North Carolina
Record of Decision
12/23/92
TABLE 5.2.D
Oroundwater Former
Lagoon and
Process Area
Contaminant
phenol
2 -chlorophenol
2 -nitrophenol
2,4* dlmethylphenol
2,4- dichlorophenol
4 - chloro - 3 -methylphenol
2,4,6- trichlorophenol
2,4- dlni trophenol
4 -nitrophenol
2,3,5,6- tetrachlorophenol
2 -methyl -4,6- dini trophenol
isopropyl ether
pentachlorophenol
TCDD-TB
Minimum
(ug/1)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4.0 OB -07
MAxlmuB
(ug/1)
2.67
ND
ND
ND
ND
9.2
9.81
ND
1.66
16.3
12.7
2800
1490
7.93B-05
Frequency
of Detection
4:17
0:17
0:17
0:17
0:17
3tl7
3:17
0:17
1:17
4:17
3:22
14:22
22:27
5:5
ND - Contaminant was not detected
-21-
-------
Figure 5.6
LEGEND
tun
CAST. IMC. HWVHTY BOUNOAHY
UHir s roue runts IMC. morrmr BOUNDARY
More.
nut PHI HAS urn tico AS
A Hff'ING IIS? Htlt.
•— D
0 100 300 400
Figure 5.6
Pentachlorophenol
Croundwater Plume
OMCI.)
-------
Figure 5.7
LE6ENO
MONIIOHIHG Utt 1 1* 4 111*
unit siHuciuits inc. nufmir BUUHUHI
MOtf
Hill >'HI MS Ulll l/tl) 4S
4 tVMPINti IISI nil.
Q
Q
'- D V
BCALE 1FEETI
0 160 300 400
Figure 5.7
1)1 ox III Delect Inns
In (Jroiindw.iler
-------
5.H
i 5s o o
V
•>•
x-
x
5M?8
/'
A
7
tf »
«7
X^
X'-^
LfKMD
• SlMAtt »*UM UMK I IIN.AIIUMS
Q HIM MASIMtMMl (OCAHUM
• «»«» W*/tH IAHI. I ML mOPtHI* BUM)*IM
---— UM|I SIMICHWIS IMC mUPVMIf MIMH
Figure- 5.H
Siirr.-ii:e W;iter
S.impl (UK Local Ions
-------
KI mire 5.9
LE8END
._^_W«/IH»SI IIC nUMHIt MUMUIIt
_.._ (Mil SIMUCIIHS ll« IW1HII MUMUHl
SCALE IFEETI
0 120 240 360
Figure 5.9
Sediment Sample
l.ociit Ions
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
TABLE 5.3
SURFACE WATER -
FIRE POND
Contaminant
phenol
2 - chlorophenol
2-nitrophenol
2,4- dime thy Iphenol
2,4- dichlorophenol
4 - chloro - 3 -me thy Iphenol
2,4,6- trlchlorophenol
2,4- dini trophenol
4 -nitrophenol
2,3,5,6- tetrachlorophenol
2 -methyl -4 , 6 -dlnltrophenol
isopropyl ether
pentachlorophenol
TCDD-TEF
Minimum
(ug/1)
ND
ND
ND
ND
MD
ND
BID
ND
ND
ND
ND
ND
0.043
1.20E-04
Maximum
(ug/1)
1.02
0.61
ND
3.84
3.69
ND
ND
ND
4.13 («vg)
1.92
ND
ND
0.17
2.85E-04
Pre
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
TABLE 5.4
SURFACE WATER -
MBDLIN POND
Contaminant
phenol
2 - chlorophenol
2 -ni trophenol
2 , 4 -dime thy Iphenol
2 , 4 -di chlorophenol
4-chloro-3 -methylphenol
2,4,6- trichlorophenol
2 , 4 -dinitrophenol
4 - ni trophenol
2,3,5,6- tetrachlorophenol
2 -methyl -4,6- dini trophenol
isopropyl ether
pentachlorophenol
TCDD-TEP
Minimum
(ug/1)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4.60E-06
Maximum
(ug/1)
2.85
ND
1.3
0.74
0.55
ND
1.49
2.11
ND
4.89
1.13
ND
0.15
1.99B-05
Frequency
of Detection
3:11
0:11
3:11
1:11
2:11
0:11
1:11
1:11
0:11
5:11
1:11
0:6
6*11
2:2
ND - Contaminant was not detected
-27-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
TABLE 5.5
SEDIMENT SAMPLES
Fire Pond
Contaminant
phenol
2 - chlorophenol
2 -nitrophenol
2 , 4 -dime thy Iphenol
2 , 4 -di chlorophenol
4 - chloro - 3 -me thy Iphenol
2,4,6- trichlorophenol
2 , 4 -dinitrophenol
4 -nitrophenol
2,3,5,6- te trachlorophenol
2 -methyl -4,6- dinitrophenol
isopropyl ether
pentachlorophenol
TCDD-TBF
Minioum
(ug/kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.04
MJUCifllUB
(ug/kg)
197
802
94.4
184
ND
ND
ND
ND
ND
ND
233
ND
5040
0.49
Frequency
of Detection
5tl6
3il6
1:16
1:16
0:16
0:16
0:16
0:16
2:16
0:16
1:16
0:4
5:16
5:5
ND - Contaminant was not detected
If the value identified in the Remedial Investigation Report
or Baseline Risk Assessment was below detection limit, the
value is reported as Non-detect for purposed of this Record of
Decision.
-28-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
TABLE 5.6
SEDIMENT SAMPLES
MEDLIN POND
Contaminant
phenol
2 - chlorophenol
2 -nitrophenol
2,4- dime thy Iphenol
2 / 4 -dichlorophenol
4 - chloro - 3 -me thy Iphenol
2,4,6- trichlorophenol
2 , 4 -dinitrophenol
4 -nitrophenol
2,3,5,6- tetrachlorophenol
2 -methyl- 4, 6 -dinitrophenol
isopropyl ether
pentachlorophenol
TCDD-TEP
(ug/kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.54
Maximum
(ug/kg)
134
ND
ND
1590
ND
ND
ND
ND
ND
ND
ND
ND
ND
1.01
Frequency
of Detection
2:5
0:5
0:5
4:5
0:5
0:5
0:5
0:5
0:5
0:5
0:5
0:1
0:5
2:2
ND - Contaminant was not detected
If the value identified in the Remedial Investigation Report
or Baseline Risk Assessment was below detection limit, the
value is reported as Non-detect for purposed of this Record of
Decision.
-29-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
exposure pathways that need to be addressed by remedial action. It
serves as the baseline indicating what risks could exist if no
action were taken at the site. This section of the ROD reports the
results of the Baseline Risk Assessment using the analytical data
generated during the Remedial Investigation and summarizes the
current and future risks associated with the contamination which
presently exists at the site. The Baseline Risk Assessment was
developed by Beazer. The Administrative Order by Consent signed in
March of 1989 allowed Beazer to conduct the Risk Assessment
concurrently with Remedial Investigation work.
6.1 Cont**"1'' nants of Concern
Historical records and results of site sampling of environmental
media were used in the original selection of contaminants of
concern at the Koppers site. Pentachlorophenol , isopropyl ether,
and the congeners of the dioxin/furan family were known to be
contaminants at the site. To ensure that no additional major
contaminants existed, approximately 15% of the samples collected
during the Remedial Investigation were required to be "full scan"
which included volatile organic compounds, semi-volatile organic
compounds, pesticides and PCBs, (known as the Target Compound List)
and metals and cyanide, (referred to as the Target Analyte List).
The list of contaminants below is a subset of the overall list of
site contaminants that were included in the quantitative risk
assessment conducted in the Baseline Risk Assessment. This subset
was derived by identifying those site contaminants which contribute
to a site risk exceeding 1E-06 for carcinogens, or a Hazard
Quotient exceeding 1.0 for noncarcinogens . Carcinogenic risks and
hazard quotient data are discussed further in Section 6.3 and in
depth in the Baseline Risk Assessment.
These contaminants of concern are:
pentachlorophenol
PCDDs/PCDFs1
1 PCDDs/PCDFs refer to polychlorinated dibenzo-p-dioxins and
dibenzofurans, commonly referred to as dioxins. TCDDs/TCDFs are
the tetrachlorinated congeners substituted in the 2,3,7,8-
configuration, specifically 2,3,7,8-tetrachlorodibenzo-p-dioxin and
2,3,7,8-tetrachlorodibenzofuran. Due to the greater toxicity
associated with this 2,3,7,8- configuration, Toxic Equivalents
Factors (TEFs) are calculated for all congeners. The toxicity
assessment for the PCDDs/PCDFs are evaluated as TCDD-TEFs.
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Koppers Company/ Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
2,4-dichlorophenol
The tables in Section 5.0, Summary of Site Characteristics,
identify the concentrations of the site contaminants in each medium
of exposure. A site figure is provided for consistency to the
Baseline Risk Assessment. Figure 6.1 subdivides the site into
areas defined by use and contamination distribution. Tables 6.1
through 6.6 identify the subset of site contaminants and their
exposure concentration with respect to media.
Table 6.1
Surface Soil
Representative
Concentration 2
-------
OFFSME
KEST
Bc»:ta EtST. INC PRUPtRIt BOUHD4B*
unit sTRuciufUS Hit pnupean Hiiiji;o»m
Source Keystone. 1992
SC*UE IFEET)
0 100 ZOO
Figure 6.1
Site Divisions
by use & Contaminant
Distribution
luaSUl llivuMuj.il.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
TcJale 6.3
PCDD/PCDF
Representative Concentration
(ug/kg)
Surface Water
Fire Pond
2.29E-04
Western Ditch
Not Calculated
Table 6.4
PCDD/PCDF -TE
Representative Concentration
(ug/kg)
Sediment
Fire Pond
0.45
Fire Pond
Discharge
1.39
Wei';ern Dirzch
Not calculated
Table 6.5
PCDD/PCDF-TE
Representative Concentration
(ug/kg)
Fish
Medlin Pond
2.59E-03
Fire Pond
3.85E-02
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Hoppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
Table 6.6
2,4-
dichlorophenol
pentachloro-
phenol
PCDD/PCDF-TE
Representative Concentration
(ug/kg)
Groundwater
Of i site
5.59
Eastern Area
90.41
10.11
1.69E-04
Lagoon
Area
349.27
6.2E-05
The contaminants of concern can be related to the wood treatment
process historically used at the site. The land use of the
immediate site continues to be of an industrial nature, with an
active wood laminating facility on the western portion of the site.
Surrounding land use is a mixture of light industrial, commercial
and rural residential. Current land use and zoning maps are
included in the Baseline Risk Assessment. The likelihood of the
site reverting to residential is extremely remote. The entire area
known as the Raleigh, Durham, Research Triangle Park area is
developing for industrial and commercial use.
Drinking water was obtained almost exclusively in the immediate
area from groundwater prior to 1989, when Beazer signed the
Administrative Order by Consent to install water lines. Many area
residents outside the Immediate vicinity continue to be served by
groundwater for all domestic water uses. This groundwater is
designated as Class GA in accordance with North Carolina's water
classification system and Class IIB under USEPA Groundwater
Classification Guidelines (December 1986). The Class GA
classification means that the groundwater is an existing or
potential source of drinking water supply for humans, North
Carolina Administrative Code, Title 15, Subchapter 2L (NCAC
T15:02L). EPA classifies the groundwater as Class IIB since the
aquifer is of drinking quality. Class IIB groundwater must be
remediated to levels protective of residential consumption. The
onsite groundwater is not currently being used as a source of
drinking water.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
6.2 Exposure Assessment
The exposure assessment evaluates and identifies complete pathways
of exposure to human populations on or near the site. Land use and
human activity are utilized in this assessment.
The current principle human receptors (potentially exposed
populations) include local offsite residents, onsite workers, and
potential onsite trespassers. Onsite workers and trespassers may
be exposed to site-related contaminants in surface water,
sediments, and surface soil.
The primary future human receptors at the site may be onsite
workers and potential trespassers, construction workers and off site
residents. Potential future exposures would include surface soils,
sediments, and groundwater. The Baseline Risk Assessment ALSO
evaluated the potential future human receptors considering land use
under the residential scenario. However the remedial decision is
based on the industrial scenario rather than the future residential
scenario.
The current and future potential exposure pathways considered
included both direct exposure pathways in which the receptor comes
into contact with a contaminated medium and indirect exposures
through which exposure to site contaminants would be from food-
chain uptake. The exposure pathways listed below were evaluated
quantitatively:
Inhalation of soil as dust (surface and subsurface)
Dermal contact with and inadvertent Ingestion of soil
(surface and subsurface)
Dermal contact with and inadvertent Ingestion of sediment
Dermal contact with and inadvertent Ingestion of surface
water
Consumption of Groundwater
Inhalation of Volatile constituents from groundwater
while showering
Consumption of vegetables
Consumption of Fish
The exposure scenarios evaluated took various assumptions into
account to develop estimates which represent risks quantitatively.
A local off-site resident is assumed to live near the site property
for the first 30 years of his/her life. Further categorization
into age groups of young child (YC) ages 0 to 5, older child (OC)
ages 6-17, and adult (A) 18 to 29. The future onsite resident is
assumed to live on the site for 30 years. In addition, a local
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
off-site teenage trespasser is also evaluated and assumed to
trespass for 8 years during ages 10 to 17. A worker onsite is
assumed to be a 70 kg adult who works at the site 5 days a week for
47 weeks per year for 20 years. The major assumptions for both the
hypothetical resident and onsite worker are provided in Tables 6.7
and 6.8. Further detail and mathematical calculations can be
reviewed in the Baseline Risk Assessment Report.
:"':-7':;-': :';- ":":""7- " v -. '•••>•';•-, Table 6.7
Major Assumptions for: Residential Scenario
Body Weight
(kg)
Exposure
Duration (yrs)
Soil Ingestion
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
Table 6.8
Major Assumptions for Onsite Worker Scenario
Body Weight (Kg)
Exposure Duration
(year)
Soil Ingestion
(mg/d)
Exposure Frequency
(GW) (d/y)
Soil on Skin
(mg/cm2)
70
20
100
235
145
6.3 Toxicity Assessment
Toxicity assessment, as part of the Superfund Baseline Risk
Assessment process, considers (1) the types of adverse health or
environmental effects associated with individual and multiple
chemical exposures, (2) the relationship between magnitude of
exposures and adverse effects, and (3) related uncertainties such
as the weight of evidence for a chemical's potential
carcinogenicity in humans.
Cancer slope factors (CSFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic
chemicals. CSFs, which are expressed in units of (mg/kg/day)'1, are
multiplied by the estimated intake of a potential carcinogen, in
(mg/kg/day), to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level.
The term "upper-bound" reflects the conservative estimate of the
risks calculated from the CSF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. CSFs
are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic (systemic) effects. RfDs, which are
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Hoppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
expressed in units of ing/kg/day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals, which
will result in no adverse health effects. Estimated intakes of
chemicals from environmental media (i.e., the amount of chemical
ingested from contaminated drinking water) can be compared to the
RfD. RfDs are also derived from human epidemiological studies or
animal studies to which uncertainty factors have been applied
(i.e., to account for the use of animal data to predict effects on
humans). These uncertainty factors help ensure that the RfDs will
not underestimate the potential for adverse noncarcinogenic effects
to occur.
The Baseline Risk Assessment identified CSFs and RfDs for the
contaminants of concern for the Koppers site. Table 6.9 provides
the Cancer Slope Factors (CSFs); Table 6.10 provides the Reference
Dose (RfDs) values. Those site-related contaminants for which EPA-
derived RfDs or CSFs are not available, RfDs were derived using
standard EPA methods from toxicity studies identified in the
scientific literature. The contaminants of concern responsible for
the majority of the risk associated with the site are PCDD/PCDFs,
and to a lesser extent, pentachlorophenol.
TABLE 6.9
Constituent
pentachlorophenol
PCDD/PCDF
EPA
, Carcinogen
Class
B2
B2
EPA CSF
O:1.2E-1
I:ND3
O:1.5E+5
I:1.5E+54
Source
BEAST, 9/90
BEAST, 9/90
BEAST, 9/90
TABLE 6.10
Conl-am-i nan**
2 , 4-dichlorophenol
pentachlorophenol ' ' -Itf »••:• « ;.. y>;;
Oral RfD
(mg/kg/day)
3E-3
3E-25
Source
IRIS, 4/91
IRIS, 4/91
3 ND - Not determined.
4 I - CSF for exposure via the inhalation route.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
6.4 RISK CHARACTERIZATION
The risk characterization step of the site risk assessment process
integrates the toxicity and exposure assessments into quantitative
and qualitative expressions of risk. The output of this process is
a characterization of the site-related potential non-carcinogenic
and carcinogenic health effects.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) , or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's
reference dose. By adding the Hqs for all contaminants within a
medium or across all media to which a given population may be
reasonably exposed, the Hazard Index (HI) can be generated. The HI
provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single
medium or across media. The HI is equal to the estimated potential
exposure dose divided by the RfD. When this ratio exceeds unity,
the estimated potential exposure is greater than the allowable
exposure and the potential for adverse health effects may exist.
None of the hazard indices for the site exceed unity considering
the current and future land use scenario as industrial.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(i.e., IxlO'6 or 1E-6). An excess lifetime cancer risk of 1E-6
indicates that, as a plausible upper-bound, an individual has a one
in one million chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions at a site.
EPA has set an acceptable carcinogenic risk range of 1E-4 to 1E-6.
The current site related quantitative carcinogenic risks which are
either within or outside this risk range are presented in Table
6.11. Table 6.12 provides the future quantitative carcinogenic
risks for the off site resident; values for onsite worker do not
change from current scenario to future scenario. Table 6.13
provides the future quantitative carcinogenic risks for the
hypothetical onsite resident. The noncarcinogenic hazard quotient
for 2,4-dichlorophenol exceeds the Agency benchmark of 1.0 for the
ingestion of groundwater by the future onsite resident. (2,4-
5 CSF is identified for this contaminant in addition to the
RfD.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
dichlorophenol HQ = 1.44). This scenario is evaluated primarily to
address the groundwater contamination. Groundwater aquifers must
be evaluated upon their potential use and groundwater
classification. The groundwater at the site is classified as a
drinking water aquifer.
Table 6.11
Current Carcinogenic Risks
Local Resident (trespasser scenario)6
Surface Area Soils - Lagoon & Process Area
Fire Pond Surface Water (Oral & Dermal)
Fire Pond Fish
Western Ditch Surface Water (Dermal)
Fire Pond Discharge stream sediments
( oral , dermal )
7.8E-04
6.6E-06
1.9E-05
1.2E-06
7.1
E-06
TOTAL I »^lErr04
Onsite Worker7
Surface Area Soils - Lagoon & Process Area
Surface Area Soils - Area north of lagoon
& process area excluding the landfarm area
TOTAL
3.5E-03
2.2E-06
3.5E-03
6 All risks in the risk range are attributable to PCDD/PCDF
with the exception of the exposure to surface soils. The risk
breakout for surface soil in the lagoon and process areas is: PCP
= 6.1E-6, PCDD = 7.7E-4.
7All risks in the risk range are attributable to PCDD/PCDF
with the exception of the exposure to surface soils. The risk
breakout for surface soil in the lagoon and process areas is: PCP
- 2.8E-05, PCDD - 3.5E-03.
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Hoppers Company, Inc. Site
Morrz.sville, North Carolina
Record of Decision
12/23/92
Table 6.12
Future Scenario - Carcinogenic Bisks
Offsite Resident8
Trespasser -
Surface soil (lagoon & process
area)
Trespasser - Fire Pond Surface Water
Trespasser - Fire Pond Fish
Trespasser - Medlin Pond Fish
Western Ditch - surface water
Fire Pond Discharge Sediment
7.8E-04
6.6E-06
1.9E-05
1.4E-06
1.2E-06
7.1E-06
TOTAL |ii£E-04^v??
6.5 Risk Uncertainty
There is a generally recognized uncertainty in human risk values
developed from experimental data. This is primarily due to the
uncertainty of extrapolation in the areas of (1) high to low dose
exposure and (2) animal data to values that are protective of human
health. The Site specific uncertainty is mainly in the degree of
accuracy of the exposure assumptions.
Most of the exposure assumptions used in a risk assessment have not
been fully verified. For example, the degree of chemical
absorption from the gut or through the skin or the amount of soil
contact that may occur is not known with certainty. Generally EPA
standard methods were used in developing values when EPA derived
values were not available. In the presence of such uncertainty,
the Agency and the risk assessor have the obligation to make
conservative assumptions such that the chance is very small,
approaching zero, for the actual health risk to be greater than
that determined through the risk assessment process. On the other
hand, the process is not intended
8A11 risks in the risk range are attributable to FCDD/PCDF
with the exception of the exposure to surface soils. The risk
breakout for surface soil in the lagoon and process areas is: PCP
- 6.1E-06, PCDD = 7.7E-04.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
Table 6.13
Future Scenario - Carcinogenic Risks
Ons ite Resident
Surface Area Soils - Area B9
Surface Area Soils - Area C9
Subsurface Soils - Area C
Fire Pond Surface Water
(Oral & Dermal)
Western Ditch Surface Water
(Dermal)
Fire Pond sediments
(oral, dermal)
Western Ditch sediments
(oral, dermal)
Groundwater (oral) - Area B10
Groundwater (oral) - Area Cu
TOTAL - Area B
Area C
2.7E-05
4.3E-02
4.4E-06
1.5E-04
1.2E-06
3.6E-06
1.1E-06
5.4E-04
l.OE-03
8. IE- 04
4.4E-02
9 Area B is also referred to as the Eastern Area of the site.
A distinction is made in Section 6.0 Summary of Site Risks to be
consistent with the Baseline Risk Assessment Report. Area C is the
former lagoon and process area.
10A11 risks in the risk range are attributable to PCDD/PCDF
with the exception of the exposure to groundwater. The risk
breakout for groundwater in the Eastern Area of the site is:
= 2.5E-5, PCDD = 5.2E-4.
PCP
"All risks in the risk range are attributable to PCDD/PCDF
with the exception of the exposure to groundwater. The risk
breakout for surface soil in the lagoon and process areas is: PCP
= 8.6E-04, PCDD = 1.9E-04.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
to yield absurdly conservative risk values that have no basis in
reality. That balance was kept in mind in the development of
exposure assumptions and pathways and in the interpretation of data
and guidance for this Baseline Risk Assessment.
6.6 Ecological Risk
A qualitative ecological risk assessment using benchmark values was
conducted as part of the Baseline Risk Assessment for the Site.
The surface water of the Fire Pond and the Medlin Pond appear to
pose to greatest potential risk to ecological populations at the
site.
6.6.1 Fire Pond
The Ecological Risk Assessment showed a Chronic Toxicity Quotient
for 2,3,7,8-TCDD of 16.5 using the EPA Region IV Surface Water
Screening Values protective of aquatic life as benchmark value.
The riparian assessment showed a toxicity quotient of 0.11 for
mammalian receptor, the muskrat, and 0.60 for the avian receptor,
the belted kingfisher.
6.6.2 Medlin Pond
The Ecological Risk Assessment showed Chronic Toxicity Quotients
for some of the phenolic compounds and PCDD. These are considered
benchmark values and are also based on EPA Region IV Surface Water
Screening Values protective of aquatic life as benchmark values,
with the exception of 2,3,5,6-tetrachlorophenol which used a Lowest
Observed Effect Level (LOEL) for bluegill divided by a safety
factor of 10 which is considered protective of more sensitive
species.
6« 6«3 SnTnrns^TV of Ecological Risk
While EPA Region IV Surface Water Screening Values are not designed
to serve as remedial action levels, these values do serve as an
indication of potential ecological threats. This value (0.00001
ppb) is also suggested by the United States Fish and Wildlife
Service as being protective of aquatic life (Eisler, R. 1986.
Dioxin Hazards to Fish. Wildlife, and Invertebrates: A Synoptic
Review. U.S. Fish and Wildlife Service Biological Report 85(1.8),
37 pp). Table 6.14 provides the chronic toxicity quotients for
five site contaminants. Based on the chronic toxicity quotients
provided, remediation of the surface water in both the Fire and
Medlin ponds is deemed appropriate.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
Table 6114 - Chronic Ecological
: : ; /• ''••:' Contaminant
;'•:.'•. . -'••':••• :-.:-::v.;S .;;'•. . •;.. • :..,.:.
2,4, 6-trichlorophenol
2 , 4-dinitrophenol
2,3,5, 6-tetrachlorophenol
2-methyl-4 , 6-dinitrophenol
2,3,7,8-TCDD
Hazard Quotients
Fire Pond
Quotient
—
—
0.0671
—
16.5
(.:. •'-. .•••::,;:--., •.;:.•"." '-".::.::,:: "":/' O':
Medlin Pond
Quotient:; ;
0.184
0.105
0.149
2.43
1.22
7.0 DESCRIPTION OF ALTERNATIVES
The media requiring remediation at the Koppers Company Site include
soils, groundwater and surface water. The description of
alternatives will address the separate components of the remedy by
media.
The former wood treating process area and the former lagoon area,
also described as Area C, are targeted for remediation of
contaminated surface and subsurface soils. The current risk
associated with the contaminated surface soils for an on-site
worker is calculated to be 3.5xlO~3. Cleanup numbers have been
established to reduce the risk to within the acceptable range.
Soil remediation will be conducted in the former lagoon and process
areas and will be conducted until concentrations in the soil of
PCDD/PCDF are at or below 7 ppb and concentrations of
pentachlorophenol are at or below 95 ppm. Upon completion of the
soil excavation, the risk associated with direct contact for an on-
site worker at the site becomes 3.2xlO~£ for pentachlorophenol and
1.2x10-* for PCDDs/PCDFs.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
7.1.1 ALTERNATIVE S-ll SOILS
No Action
Capital Costs: $ 0
PW O&M Costs: $ 140,000
Total PW Costs: $ 140.000
Time to Implement: None
CERCLA requires that the "No Action" alternative be evaluated at
every Superfund Site to establish a baseline for comparison. No
further activities would be conducted with Site soils under this
alternative (i.e., the Site is left "as is"). CERCLA also requires
that the selected remedy be protective of human health and the
environment. Since the Site poses a future risk to human health
and environment, the No Action alterative will not be selected. In
this alternative, no soil remedial activities would occur. There
are no construction costs. Operation costs would involve a review
of the remedy every 5 years for 30 years.
7.1.2. ALTERNATIVE S-3: SOILS12
Surface Cover
Capital Costs: $ 19,000
PW O&M Costs: $ 1.307.000
Total PW Costs: $ 1,326,000
Time to Implement: 1 month
This alternative provides for surface capping over the contaminated
soils and includes surface drainage controls. Final soil
compaction, seeding and mulching would be conducted to provide long
term erosion control Use of a surface cover would be designed to
eliminate or substantially reduce potential ingestion, dermal
contact, and inhalation exposure pathways. Drainage control and
long term maintenance would be required.
7.1.3. ALTERNATIVE S-4: SOILS
Surface Capping
Capital Costs: $ 109,000
PW O&M Costs: S 1.368.000
Total PW Costs: $ 1,477,000
Time to Implement: 5 months
12 This Record of Decision does not identify an alternative
titled S-2. The soil alterative S-2 was eliminated in the
screening process of the Feasibility Study due to the lack of
protectiveness; descriptive codes, e.g., S-5,S-9, etc., were kept
for easy reference back to the Feasibility Study Report.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
This alternative would be used to isolate the contaminated soils in
the process/lagoon area. This alternative would specify the
construction of a Resource Conservation & Recovery Act (RCRA) cap
over the contaminated soils. This alternative also includes
surface drainage controls. This alternative involves the
implementation of institutional controls to prevent direct contact
and incidental ingestion of contaminated soils by the general
public. A RCRA multi-layer cap consists of the following layers in
ascending order: a densely compacted 2 foot-thick clay layer placed
over the contaminated soils, a synthetic polyethylene liner,
minimum thickness no less than 30 mils placed on top of the clay
layer, a synthetic fabric to prevent clogging of the drainage
layer, and finally, 18 inches of native soils and 6 inches of top-
soil on top of the geotextile fabric. A vegetative cover would be
completed and fencing would be installed to provide a barrier to
trespassing. Long-term maintenance would be required.
7.1.4. ALTERNATIVE S-5: SOILS
Excavation and On—site Landfill
Capital Costs: $ 663,375
PW O&M Costs: $ 1.506.625
Total PW Costs: $ 2,170,000
Time to Implement 7 months
This alternative involves excavating the contaminated soils and
landfilling the soils on-site. Major components of this on-site
alternative would include capping and lining the landfill area to
meet RCRA regulations. A leak detection system would be installed
to ensure the liners do not fail. A leachate collection and
removal system would installed. The cap would be identical to the
RCRA cap as identified in Alterative S-4 for soils. Maintenance of
the landfill would require periodic mowing and control of
vegetative cover. Long term groundwater monitoring would be
required to implement this alternative. The excavated areas would
be backfilled with clean soils, graded, and revegetated. Long term
maintenance would be required for this alterative.
7.1.5 ALTERNATIVE S-6: SOILS
Excavation and Off—site Landfill
Capital Costs: $ 816,000
PW O&M Costs: $ 0
Total PW Costs: $ 816,000
Time to Implement approx. 12 months
This alternative involves excavating the contaminated soils in the
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Koppers Company, Inc. Site
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Record of Decision
12/23/92
same manner as identified in Alternative S-5. Tl:e contaminated
soils would be transported to a RCRA-permitted of~-site landfill.
The excavated areas would be backfilled with clean soils/ graded/
and revegetated. This alterative for soils would be complete upon
final transport of soils and analytical confirmation of cleanup
standards. No long term maintenance would be required.
7.1.6. ALTERNATIVE S-7: SOILS
Excavation and On-site Treatment bv Dechlorination
Process and Replacement of Treated Soils
Implementation
Capital Costs: $ 4/530/000
PW O&M Costs: 1 0
Total PW Costs: $ 4/530/000
Time to Implement: Unknown
* Based on estimations using the APEG
process.
Treatability Study $ 1,000,000 **
** Assumed to be an over-estimate.
No data exists for development of a
treatability study for base catalyzed
dehalogenation.
This alternative involves excavating the contaminated soils and
then chemically treating the contaminated soils on-site. A mobile
treatment unit would be placed on-site. The chemical process
attempts to detoxify and chemically decompose the contamination in
the soils by removing the chlorine atoms from the pentachlorophenol
and the PCDDs/PCDFs. Dechlorination is an innovative technology
available. Currently/ two separate dechlorination processes have
been developed/ glycolate dehalogenation and base catalyzed
dehalogenation. These two processes are based on fundamentally
different chemical reactions. Glycolate dehalogenation uses
polyethylene glycol as the reagent to dechlorinate. A lab-scale
treatability study was conducted on contaminated site soils using
APEG/ which is a patented glycolate dehalogenation process. The
test did not prove the successful dechlorination of PCDD/PCDF on
contaminated site soils. Base catalyzed dehalogenation uses
bicarbonates as the reagent to dechlorinate the contaminants of
concern. This process has not been utilized in the field on soil
contamination, though generic lab-scale tests have been successful.
No tests have been conducted on contaminated soils from the site.
Costs identified above were based on assumptions using the APEG
process. It is assumed that the costs for base catalyzed
dehalogenation would be comparable. Upon final treatment of the
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12/23/92
soils, the soils would be washed and replaced back into the
excavated area(s). This alternative would comply with the land
disposal restrictions through a Treatability Variance for the
contaminated soil. The treatment level range established through
a treatability variance that dechlorination must attain for
pentachlorophenol is 90 - 99% reduction.
7.1.7 ALTERNATIVE S-8: SOILS
Excavation and On-site Incineration
Capital Costs: $ 3,240,000
PW O&M Costs: £_^ 0
Total PW Costs: $ 3,240,000
Time to Implement: 6-9 months
This alternative involves excavation and incineration of the
contaminated soils in an on-site mobile incinerator. The
incinerator destroys the organic contaminants in the soils.
Excavation is expected to be done using conventional equipment and
earthmoving techniques. Following excavation, the excavated soils
would be transported to an on-site soil incineration unit. Soils
would be stockpiled prior to treatment. For purposes of destroying
PCDDs/PCDFs, the incinerator is assumed to be a mobile rotary kiln
incinerator with appropriate air cleaning equipment. Site
contaminants would be burned in the rotary kiln by heating the
solids to a temperature of approximately 1400°C. Waste solids are
discharged directly from the kiln, while the off-gases are
discharged to a secondary combustion unit where complete oxidation
is insured. Off-gases from the secondary combustion unit are
treated in a multi-stage scrubbing unit for removal of particulates
and neutralization of acidic gases formed during combustion. The
treated soils (also considered ash) would either be placed back
into the area of excavation onsite or disposed of in a
RCRA-pennitted landfill. The preference under SARA would provide
for final onsite disposal. Onsite land disposal of the residual
ash would require compliance with RCRA.
7.1.8 ALTERNATIVE S-9: SOILS
Excavation and Off—site-Incineration
Capital Costs: $ 4,750,000
PW O&M Costs: S 0
Total PW Costs: $ 4,750,000
Time to Implement: 6-9 months
This alternative involves excavating and transporting the
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contaminated soils to a RCRA permitted off-site incineration
facility. The contaminated soils would be incinerated which would
result in the elimination of the potential risk of ingestion,
dermal contact, or inhalation associated with the soils in the
process and lagoon areas. It is anticipated that excavation would
be accomplished using conventional equipment and earthmoving
techniques. Following excavation and removal of contaminated
soils, clean fill would be placed in the excavated area(s). Each
area would be graded to achieve desirable surface drainage.
For the destruction of site contaminants, use of a rotary kiln
incinerator is assumed. Temperatures reaching approximately 1400°C
are used in conjunction with all appropriate air cleaning
equipment. Waste solids are discharged directly from the kiln,
while off-gases are discharged to a secondary combustion unit where
complete oxidation is insured. Off-gases from the secondary
combustion unit are treated in a multi-stage scrubbing unit for
removal of particulates and neutralization of acidic gases formed
during combustion. The ash which would result from the
incineration would be disposed of at a secure chemical landfill and
would be the responsibility of the operator of the incinerator
facility. The excavated areas would be backfilled with clean soil,
graded and revegetated.
7.1.9 ALTERNATIVE S-10: SOILS
Excavation and On-site Storage
Capital Costs: $ 125,000
PW O&M Costs: $ 534.000
Total PW Costs: $ 659,000
Time to Implement: approx. 3 months
This alternative involves excavating the contaminated soils and
moving them to an on-site storage facility that would be
constructed for the soils storage. A synthetic liner, leachate
detection and collection system, concrete foundation with curbs,
and a cover manufactured of synthetic liner material would be used.
Excavation would be conducted as described in previous
alternatives. The excavated areas would be backfilled with clean
soil, graded and revegetated. This alternative would be a
temporary measure utilized only until acceptable technology for
treating the soils becomes available, and would be required to meet
the requirements defined by RCRA for onsite storage. This
alternative would eliminate the exposure routes for ingestion,
dermal contact/ and inhalation as well as the mobility of the
contamination in the soils.
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7.2 REMEDIAL ALTERNATIVES TO ADDRESS GROONDWATER CONTAMIHATIOH
The area of groundwater contamination which exceeds the cleanup
standard in monitoring wells for pentachlorophenol is depicted on
Figure 7.1. The monitoring wells which have PCDD/PCDF levels
exceeding the cleanup standard for PCDD/PCDF are shown on Figure
7.2. The groundwater at the Koppers Site is classified as Class GA
by North Carolina and Class I IB by the EPA. Since this groundwater
is a potential source of drinking water, remediation is required to
be protective of public health and the environment; cleanup
standards will be met throughout the plume.
The Safe Drinking Water Act and North Carolina Administrative Code,
Title 15, Subchapter 2L (NCAC T15:02L.0202) establish maximum
concentration levels (MCLs) and non-zero maximum contaminant level
goals (MCLGs) for numerous organic and inorganic constituents. The
contaminant 2,4-dichlorophenol does not have a Federal or State
cleanup goal; the cleanup standard identified
below is a risk-based cleanup standard calculated at a 10'* risk
level* The cleanup standards are:
Site Contaminants:
Pentachlorophenol11
2 , 4-dichlorophenol
Dioxins/furans
Cleanup Standards
1.0 ppb
20 ppb
3.0xlO'5 ppb
The groundwater extraction and treatment alternatives were
developed based on ah estimate of a 30 year operation time. Actual
duration will be based on performance.
7.2.1 ALTERNATIVE GW-1: NO ACTION
Capital Costs: $ 0
PW O&M Costs: S 140.000
Total PW Costs: $ 140,000
Time to Implement: None
This alternative for groundwater contamination would require no
further activities to be conducted for on-site groundwater. The No
13 Federal Maximum Contaminant Level (MCL).
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Kit-ure 7.1
LEGENU
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Figure 7.1
Pentacliloroplienol
Contaminant Plume
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(-•tgurc 7.2
LEGEND
MONITORING HELL LOCATION
BEAfEH CAST. INC. PROPERTY BOUNDARY
UNIT STRUCTURES INC. PROPERTY BOUNDARY
NOTE:
HELL PHI HAS UTILIZED AS
A PUMPING TEST HELL.
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Figure 7.2
PCUD/I'CDK
Detect ions
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Action alternative is required to be established for comparative
basis under CERCLA. Groundwater contamination would is expected to
continue to migrate with groundwater flow. This alternative
involves no capital costs. Operating costs are based on the review
of Site conditions every 5 years. There would be no maintenance
costs.
7.2.2 ALTERNATIVE GW-3: EXTRACTION, ABOVE-GROUND BIOREMEDIATION,
SURFACE WATER DISCHARGE14
Capital Costs: $ 869,000
PW O&M Costs: S 4.231.000
Total PW Costs: $ 5,100,000
Period of Operation: 30 years
This alternative involves installing extraction well(s) in the
contaminant plume to actively extract groundwater for treatment.
The steps in the treatment include equalization, filtration of
suspended solids, Ph adjustment, removal of organic contaminants
and a carbon polishing step. The primary organic treatment
consists of a submerged fixed film bioreactor to permanently remove
and destroy the organic contaminants. Effluent will be discharged
to the surface water and monitored to insure compliance with
National Pollution Discharge Elimination System (NPDES) discharge
requirements.
7.2.3 ALTERNATIVE GW-4: EXTRACTION, ABOVE-GROUND PRETREATMENT &
CARBON ADSORPTION, SURFACE WATER DISCHARGE
Capital Costs: $ 419,000
PW O&M Costs: S 3.612.000
Total PW Costs: $ 4,031,000
Period of Operation: 30 years
This alternative involves the installation of extraction well (s) in
the contaminant plume on-site to actively extract groundwater for
treatment. The steps in the treatment system would consist of
equalization, filtration for removal of suspended solids, and
carbon adsorption of dissolved organics. Groundwater would be
pumped from extraction well(s) into an equalization tank designed
to provide a 24 hour residence time for a predetermined flow rate.
Groundwater would then be pumped into a sand filter for removal of
14 The Alternative GW-2 was eliminated due to the lack of
adequate protectiveness during the screening process in the
Feasibility Study. The original codes identified in the
Feasibility Study are retained.
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suspended solids and other matter which could inhibit subsequent
treatment units and hinder treatment capabilities. The filtration
system would include a sand filter, backwash tank, and backwash
pump. Soils would be removed periodically from the backwash tank
and disposed of. Final disposition of the backwash soils would be
determined during Remedial Design. If possible, onsite disposal is
preferable. The filtered groundwater would be pumped from the sand
filter into the activated carbon units; at present a minimum of two
units of 500 pounds of activated carbon each, have been used in the
conceptual design. A series arrangement would be used with the
first unit serving as the primary adsorption unit and the second
unit serving as a polisher. Disposal of spent carbon would be
necessary. Final disposal options of spent carbon would be
determined during Remedial Design Stage. The difference of
treatment between GW-3 and GW-4 alternatives is the elimination of
the fluidized bed biological reactor system. The pH adjustment
would not be necessary since this step is taken to optimize
conditions for the biological treatment. Effluent would be
discharged to surface water and monitored to insure compliance with
NPDES discharge requirements.
A treatability study was conducted to evaluate the performance of
activated carbon adsorption for the contaminated groundwater from
the site. The results of the Treatability Study indicated that
granular media filtration in combination with activated carbon is
an effective treatment technology for the site groundwater. The
spent carbon and backwash soils would be the residual waste
associated with the groundwater component of the remedy and would
be treated in accordance with all applicable or relevant and
appropriate requirements. Due to the PCDDs/PCDFs, incineration may
be the choice for the disposal of the carbon units.
7.2.4 ALTERNATIVE GW-5: EXTRACTION, ABOVE-GROUND PRETREATMENT AND
UV/CHEMICAL TREATMENT, SURFACE WATER DISCHARGE
Capital Costs: $ 419,000
PW O&M Costs: $ 4.714.000
Total PW Costs: $ 5,133,000
Period of Operation: 30 years
This alternative involves installing extraction well(s) in the
contaminant plume on-site to actively extract groundwater for
treatment. The steps in this treatment alternative consist of
equalization, filtration for removal of suspended solids, treatment
in a UV/chemical oxidation reactor, including addition of peroxide
for oxidizing/converting dissolved organic compounds to chemical
species which meet required discharge levels and a carbon polishing
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step for adsorption of residual organics. Extracted groundwater
would be pumped to an equalization tank designed to provide a 24
hour residence time/ followed by sand filtration. The filtered
groundwater would then flow by gravity into a reaction tank
equipped with ultraviolet (UV) lights. Hydrogen peroxide (H202)
would be used as an oxidizing agent which, in the presence of UV
light, will chemically oxidize the contaminants at the site. Site
contaminants would be converted to chemical species which are
detoxified. The reaction vessel would be designed to provide
intimate contact between the extracted groundwater and the oxidant.
The degree to which UV/chemical oxidation breaks down organic
compounds is dependent upon: (1) the oxidant dosage, (2) the
initial concentration of chemicals in solution, and (3) their
molecular structure. Effluent from the reaction vessel would be
pumped through. two activated carbon units, a primary desorption
unit and a secondary polisher unit. Effluent would be discharged
to surface water and monitored to insure compliance with NPDES
discharge requirements.
7.3 REMEDIAL ALTERNATIVES TO ADDRESS SURFACE WATER CONTAMINATION
There are two main surface water ponds that will be addressed under
this component of the remedy. These are the Fire Pond and the
Medlin Pond. Figure 7.3 shows the locations of the ponds. The
remediation of the surface waters and the associated sediments is
based on protection of the environment. No unacceptable human
health risks are present. The Baseline Risk Assessment identifies
the quantitative human health risks associated with the surface
water and sediments.
7.3.1 ALTERNATIVE SW-1: NO ACTION
Fire Pond
Capital Costs: $ 0
PW O&M Costs: $ 70.000
Total PW Costs: $ 70,000
Time to Implement: None
Medlin Pond
Capital Costs: $ 0
PW O&M Costs: $ 70.000
Total PW Costs: $ 70,000
Time to Implement: None
This alternative for surface water contamination would require no
further activities to be conducted for on-site groundwater. This
alternative is required to be developed under CERCLA. No
protection of environmental concerns would be afforded under this
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Figure 7.3
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alternative. Costs are based on reviewing the remedy every 5
years. There are no construction costs.
7.3.2 ALTERNATIVE SW-3: POND DEWATERING, SURFACE WATER TREATMENT,
SURFACE WATER DISCHARGE, BACKFILLING IN POND15
Fire Pond
Capital Costs: $ 1,300,000
PW O&M Costs: $ 0
Total PW Costs: $ 1,300,000
Time to Implement: 3 months
Medlin Pond
Capital Costs: $ 695,500
PW O&M Costs: 5 0
Total PW Costs: $ 695,500
Time to Implement: 3 months
This alternative would require the draining of the on-site Fire
Pond and the Medlin Pond, with surface water storage followed by
treatment with activated carbon. The storage tanks would provide
the necessary equalization capacity and would reduce suspended
solids. Surface water from the ponds would be treated by mobile,
truck-mounted carbon adsorption units. Dewatering of ponds would
be assisted by the construction of diversion channels and berms to
route stormwater run-on away from the existing pond waters. A
mobile pumping unit would be used to pump the surface water to
temporary storage tanks. The dewatering process would be staged to
allow for the concurrent backfilling of the pond. Temporary
cofferdams, consisting of portable dams would be used to
segmentally dewater and backfill the pond. After dewatering and
backfilling are completed, final grading of the Fire Pond area to
control surface drainage would be conducted. Once final grading is
completed, the disturbed land would be seeded and mulched to
provide long term sediment and erosion control. Temporary storage
tanks would function to equalize dewatering flows and to reduce
suspended solids in the surface water prior to pumping the water
through the treatment facility. Equalization storage required
15 Alternative SW-2 was eliminated during the original
screening process in the Feasibility Study due to lack of adequate
protection to human health and/or the environment. The original
codes are retained for ease of reference to the Feasibility Study.
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would be based on the difference between the dewatering rate and
the treatment rate, over a one-day period. Two carbon units,
configured in a series for desorption and polishing would be used.
Final effluent would be discharged to surface water and monitored
to insure compliance with NPDES discharge requirements. The pond
would be filled in with clean soil. The area would be graded to
control surface drainage and a vegetative cover would be planted.
Wetlands construction would also be conducted under this
alternative to restore the wetlands which would be eliminated by
this alternative.
7.3.3
ALTERNATIVE SW-4: POND DEWATERING, SURFACE WATER TREATMENT,
POND LINING AND REFILLING
Fire Pond
Capital Costs: $ 952,000
PW O&M Costs: S 0
Total PW Costs: $ 952,000
Time to Implement: 3 months
Medlin Pond
Capital Costs: $ 710,000
PW O&M Costs: 5 0
Total PW Costs: $ 710,000
Time to Implement: approx. 6 months
This alternative is identical to Alternative SW-3 except that the
Fire Pond and Medlin Pond would be lined with a multi-layer
synthetic liner which would be anchored into the banks of the ponds
by an anchor trench. The ponds would be allowed to refill by storm
water within the respective drainage areas. Disturbed soil areas
would be revegetated for sediment and erosion control. Wetlands
construction would also be conducted onsite under this alternative
to restore the wetlands associated with the Fire Pond which would
be eliminated by this alternative. Long-term maintenance may be
necessary to ensure the integrity of the liners.
No specific treatability study was performed on surface water due
to the successful results of the groundwater treatability study.
Site contaminants are the same for the surface water and
effectiveness is anticipated to be similar to that demonstrated
during the groundwater treatability study using activated carbon.
The spent carbon would be the only residual waste associated with
the groundwater component of the remedy and would be treated in
accordance with all applicable or relative and appropriate
requirements. Due to the PCDDs/PCDFs, incineration may be the
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choice for the disposal of the carbon units. Wetlands construction
would also be conducted under this alternative to restore the
wetlands which would be eliminated by this alternative.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The various remedial alternatives for all components were evaluated
using the selection criteria presented in EPA Directive 9355.3-02.
These criteria relate directly to factors mandated by Section 121
of CERCLA, 42 U.S.C. § 9621, and considerations which measure the
overall feasibility and acceptability of the remedy.
8.1 THRESHOLD CRITERIA
8.1.1 Protection of Public Health and Environment:
Protection of human health and the environment is the central
mandate of CERCLA, as amended by SARA. Protection is achieved by
reducing risks to acceptable levels and taking action to ensure
that there will be no future unacceptable risks to human health and
the environment through any exposure pathway. Different remedial
alternatives will have varying long-term and short-term impacts on
the protection of human health and the environment.
All alternatives evaluated in this document, with the exception of
the No Action alternatives, provide some degree of protection of
public health and the environment. The degree of protection and
the permanence of that protection vary between the alternatives.
All alternatives evaluated for groundwater and surface water
remediation, excluding the No Action alternative, would provide
equivalent protection of public health and the environment. This
is due to the performance standard that must be met regardless of
treatment technology.
Alternatives involving excavation of contaminated soils from the
uncontrolled area would provide a higher long-term degree of
protection for human health and would minimize the need for ongoing
operation and maintenance (O&M) activities and land use
restrictions. Alternatives involving long-term management of the
soil in-place or in a disposal unit would require more extensive
monitoring and maintenance and reliance upon land use and access
restrictions to adequately protect human health and to assure the
continued effectiveness of the remedy.
Removal of soils exceeding the cleanup standard for designated non-
residential land usage represents a substantially reduced risk to
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human health and the environment. A minimum one-foot vegetative
soil cover would further reduce risk by providing both a barrier
against potential exposure and dilution of subsurface soils in the
event of soil disturbance.
Both treatment and disposal were considered for final management of
contaminated soils. Land disposal results in some risk of future
release from the disposal facility as long as the dioxin remains in
the environment. Thermal treatment of contaminated soil destroys
dioxin to undetectable levels, permanently removing the
contamination from the environment and eliminating the need for
continuing maintenance or monitoring of the treated material.
8.1.1.1 Protection of the Environment:
The primary environmental concern at the Site is in the surface
water of the Fire Pond and the Medlin Pond. These surface water
bodies are not in violation of the Federal Ambient Water Quality
Criteria (AWQC, EPA, 1986); however, EPA screening values were used
in the development of acute and chronic toxicity quotients for
qualitative risk evaluation with respect to the ecological
receptors. The chronic toxicity quotient for dioxin indicates an
area of high concern in the Fire Pond and an area of potential
concern for dioxin in the Medlin Pond. Alternative SW-1 would not
be protective of the environment because the No Action Alternative
would not remove this threat.
The placement of clean fill into the pond areas, as required in
Alternative SW-3, will reduce or eliminate the existing potential
for further environmental impairment. The fill will eliminate
future ponding and the potential for future surface water to become
contaminated. The fill also renders the residual dioxin
contamination in the sediments biologically unavailable by creating
anaerobic conditions. The continued integrity of the soil cover
would not be critical for maintaining the effectiveness of the
remedy. Future contamination degradation and mixing of soils
through natural processes is expected to further reduce residual
contaminant concentrations and the potential for environmental
impairment.
The action of wetlands mitigation provides reconstruction of the
wetlands which will be destroyed by the surface water remediation.
This action is protective of a vital environmental resource.
The remediation of soil and groundwater at the Site is primarily
•based on protection of public health but will provide extensive
protection of the environment with the final cleanup of affected
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and contaminated environmental media.
8.1.1.2 Protection of Human Health:
In this document, EPA establishes cleanup standards for soils
contaminated with pentachlorophenol and PCDOs/PCDFs at the Site.
A cleanup level of 95 ppm for pentachlorophenol and 7 ppb for
PCDDs/PCDFs has been recommended for the protection of public
health based upon the non-residential land usage of the site.
These levels were established for the protection of groundwater,
but are protective levels for dermal contact as well. The Agency
believes that the continued non-residential usage of the site is
assured based upon the current land development trend and the
current zoning restrictions on adjacent properties. This is a
practical consideration of the existing conditions of the
immediately adjacent area known as Research Triangle Park in North
Carolina. This consideration also acknowledges the current
presence of an active facility of the Site property.
In-place containment of the contaminated soils would attain the
objective of reducing surface concentrations to an acceptable
level. Monitoring and maintenance requirements would be more
extensive than for alternatives involving the removal of
contaminated soils. Eventual replacement of the cover or cap may
become necessary. Land use restriction would also be necessary to
protect the soil cover and prevent possible human exposure in the
event of cover failure. In the event of cap failure, there would
be potential for offsite migration and human exposure.
Land disposal of the contaminated soils in a permanent facility
meeting RCRA design criteria would provide a higher degree of
protection to public health and the environment than in-place
containment alternatives. There would be some risk of release due
to failure of the disposal facility. This risk should be minimal
if the disposal facility is properly designed, constructed and
maintained. Regular monitoring and maintenance would be required
to assure the continued integrity of the land disposal facility.
Access restrictions would also be required to protect the disposal
facility and prevent possible human exposure in the event of a
facility failure.
An increased short-term risk associated with soil-disturbing
activities is associated with all of the alternatives involving
excavation and handling of dioxin-contaminated soil. This short-
term risk is due to potentially contaminated dust which could be
created during excavation activities. Mitigative measures, such as
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dust suppression, are available to control this potential risk.
Thermal treatment alternatives S-8 and S-9 represent technologies
which have achieved destruction of dioxin in soils to undetectable
levels. These alternatives provide the greatest level of long-term
protection of human health and the environment of the soil
alternatives evaluated in the feasibility study because the
toxicity and mobility of contaminated materials would be
substantially reduced in comparison to the containment
alternatives. Reduction of volume would be minimal. Alternative
S-8, onsite incineration may not be capable of meeting the 99.99%
Destruction and Removal Efficiency (DRE) requirement for the
thermal treatment of organic hazardous materials.
Ongoing monitoring and maintenance requirements are less for
alternatives involving removal of contaminated soils than for in-
place containment alternatives. The removal of soils exceeding the
cleanup standards are protective of human health for the industrial
scenario. Since soils exceeding cleanup standards are removed, the
continued integrity of any subsequent cap or soil cover is not
essential to maintain the effectiveness of the remedy. In-place
containment alternatives require critical maintenance for
effectiveness.
The protection afforded by dechlorination alternative for soils,
(Alternative S-7), which involves onsite treatment, is currently
undefined. This is due to the unknown effectiveness regarding the
dechlorination of PCDDs/PCDFs. Treatability studies would be
necessary to determine effectiveness on site-specific soils., If
dechlorination can be shown to be adequately effective, the long-
term protection of human health and the environment would be
administered because of substantial reduction of mobility and
toxicity. For the glycolate dechlorination process, the use of
solvent material also generates a new waste requiring a residuals
disposal plan; this may also be the situation for the base
catalyzed dechlorination process. The toxicity, the volume, and
the potential RCRA classification of these residuals using any
dechlorination process cannot be adequately defined at this time.
All alternatives involving transportation of contaminated soils to
an offsite location for treatment or disposal would require special
considerations to assure the short-term protection of human health
and the environment during transport. These considerations include
the method of containment and transport of contaminated soil,
transportation routes and scheduling of hauls.
All alternatives, with the exception of "No Action", involving the
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treatment of groundwater are cor idered equally protective of human
health. This is primarily due to the intent to conduct mass
removal of the contaminants from the aquifer, thereby ultimately
restoring the groundwater to drinking water quality. Performance
standards are the same regardless of technology.
Relevant and
Section 121(d) of CERCLA, as amended by SARA, requires that onsite
remedial actions comply with applicable or relevant and appropriate
requirements or standards (ARARs) under Federal and State
environmental laws. Such a standard or requirement must be
attained if it is determined to be either directly applicable or
both relevant and appropriate. Some of the requirements discussed
in this section are directly applicable to a particular aspect or
component of a remedial alternative. Other requirements are
identified as being both relevant and appropriate to a remedial
alternative. Both of these categories of requirements constitute
ARARs and must be attained by the remedial alternative.
Three basic types or ARARs exist, Action-Specific ARARs, Location-
Specific ARARs, and Chemical-Specific ARARs. Table 8.1 identifies
potential federal action-specific ARARs for this site. Tables 8.2
and 8.3 list the potential federal location-specific and chemical-
specific ARARs for the site. Potential State ARARs are identified
in Tables 8.4, 8.5, and 8.6. These tables represent a
comprehensive list of potential ARARs which were considered during
the development of the Feasibility Study. Section 9.0 identifies
the specific ARARs for the components of the selected remedy as
presented in this Record of Decision.
Action Specific ARARs
Action-specific requirements are technology-based and establish
performance, design, or other controls related to the management of
the wastes associated with a site.
Location-Specific ARARs
Location-specific ARARs are standards or criteria which may affect
the types of remedial alternatives or technologies used to
remediate a site due to the location of the site. These ARARs
consider any restrictions which may be present at the site and the
area surrounding the site, which may require special consideration
during the remediation. Types of locations-specific ARARs include
regulations protective of wetlands, scenic rivers, and endangered
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species.
Chemical-Specific ARARs
Chemical-specific ARARs are usually risk-based standards or
criteria which may affect the types of remedial alternatives used
to remediate a site. Maximum contaminant levels as identified
under the Safe Drinking Water Act are examples of chemical-specific
ARARs.
The following summaries are provided with respect to media.
8.1.2.1 Soils
There are no action-specific ARARs for the No Action Alternative,
S-l. RCRA requirements for S-4 (capping) may be relevant and
appropriate. An onsite landfill, S-5, will be subject to the
disposal standards of RCRA. Alternative S-7 would be required to
comply with Land Disposal Requirements (LDRS) through a
Treatability Variance for the contaminated soil/debris. LDRs can
be considered as action-specific since excavation triggers land ban
requirements, and as chemical-specific in view that specific
reduction requirements are identified for specific contaminants.
The Treatability Variance does not remove the requirement to treat
restricted soil/debris wastes; they allow the establishment of LDR
standards on actual data collected form the Site. LDR treatment
levels would be met for the soils/debris and for any sludge or used
activated carbon generated by the treatment or processes. S-9 will
be required to comply with LDRs. Alternative S-10 would be
required to meet all onsite storage regulations as defined by RCRA.
All soil alternatives which involve the excavation of soil will be
subject to the generator standards of RCRA.
8.1.2.2 Groundwater
MCLs and North Carolina standards are ARARs for Site groundwater.
Alternative GW-1 would not comply with ARARs. Alternatives GW-3,
GW-4 and GW-5 would attain chemical-specific ARARs by achieving
MCLs and cleanup standards throughout the contaminant plume.
Construction of the groundwater recovery, treatment, and discharge
system for each of these alternatives would satisfy action-specific
ARARs. The disposal of any sludge or spent activated carbon
generated by the groundwater system would also comply with ARARS.
Final discharge of the treated water will comply with the
substantive requirements of the National Pollutant Discharge
Elimination System, (NPDES). Offsite discharge requires an NPDES
-64-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
permit.
8.1.2.3 Surface Water
The No Action Alternative SW-1, would not comply with the ARARs
associated with the surface water contamination. Alternatives SW-3
and SW-4 would comply with location-specific and action-specific
ARARS. Treatment of the surface water of Alternatives SW-3 and
SW-4 would result in compliance with the State of North Carolina
chemical-specific ARARS. Final discharge of the treated water
would comply with the substantive requirements of the National
Pollutant Discharge Elimination System. Offsite discharge and
action would require a permit.
Onsite actions for CERCLA sites, such as the disposal of structures
and debris, are exempt from requiring permit administrative
requirements. Nonetheless, all onsite actions would be required to
meet all substantive requirements of any and all identified ARARs.
8.2 Evaluating Criteria
8.2.1 Cost:
The benefits of implementing a particular remedial alternative are
weighed against the cost of implementation. Costs include the
capital up-front costs of implementing an alternative over the long
term, and the net present worth of both capital and operation and
maintenance costs. Again, the components of the remedy are broken
out by media and are presented in Table 8.7. These costs are
relative costs developed for remedy selection based on 1000 yds3.
8.2.2 Implementability:
EPA considers the technical feasibility (e.g., how difficult the
alternative is to construct and operate) and administrative ease
(e.g., the amount of coordination with other government agencies
that is needed) of a remedy, including the availability of
materials and services.
Evaluation of the soils alternatives indicates that no
implementation is needed for the No Action alternative.
Construction of the cover or cap (Alternatives S-3 and S-4) would
pose no significant difficulties. Likewise, construction of a
landfill onsite would present no significant implementation
problems. Alternative S-7 would require an additional treatability
study to determine whether assure achievement of Site-specific
remedial goals and ARARS is possible with dechlorination technology
-65-
-------
Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
in soils. Uncertainties are associated with the effectiveness of
the dechlorination of PCDDs/PCDFs. Treatability Studies would
delay remediation at the site. Treatment units may not be
immediately available. Site conditions of potential concern for
on-site treatment using dechlorination are the clay and moisture
content. A treatability study was conducted using the APEG-PLUS™
process. The treatability study using the APEG-PLUS™ process was
not successful in demonstrating effective dechlorination of
PCDDs/PCDFs. There are other dechlorination processes available,
such as K-PEG, and BCD. An additional problem associated with
dechlorination is the disposal of residual waste. Due to the use
of solvents in the process, waste is generated which must also be
properly disposed. Alternative S-8 would reguire test burns. Due
to the 99.99% destruction and removal efficiency (DRE)
requirements, onsite incineration may not be implementable. The
99.99% DRE may not be achievable by a mobile incinerator for the
soils at the Koppers site given the low levels of contaminants in
the soils. There may also be difficultly in obtaining a mobile
incinerator vendor for,the small quantity of soil associated with
the Site. Alternatives S-6 and S-9 would pose no implementation
difficulties. Potential facilities have been identified that are
permitted to accept material such as the Site soils.
None of the groundwater remedial alternatives pose significant
concerns regarding implementation. Final design of the treatment
systems for Alternatives GW-3 through GW-5 cannot be completed
until discharge requirements are defined.
None of the remedial alternatives pose significant concerns
regarding implementation. Final design of the treatment systems
for Alternatives SW-3 and SW-4 cannot be completed until discharge
requirements are defined.
8.2.3 Short-Term Effectiveness: The length of time needed to
implement each alternative is considered and EPA assesses the risks
posed to workers and nearby residents during construction and
implementation.
The short-term effectiveness is immediately accomplished for soils
using Alternatives S-l, S-3, and S-4, since these alternatives
could be implemented without significant risks to on-site workers
or the community and without adverse environmental impacts. The
principal short term impacts of implementing Alternatives S-5
through S-10 is the potential exposure of workers during excavation
and the handling of contaminated soils.
All of the groundwater remedial alternatives can be implemented
-66-
-------
Table 8.1
POTENTIAL ACTION SPfcCIHC AJtARi
1-ORMfcR KOPPt-RS COMPANY. INC SITI:
BEAZt-R BAST. INC
MORRISVILU:. NORTH CAROLINA
CONSOLIDATION
WITHIN • UNIT
Not* applicable
CONTAINER STORAGE
Coouincr* of RCRA tuuardou* waaiee
mutt be:
- Maintained in good condition.
- Compeliblc with hazardou* watte lo
be aHycd. and
Ptcra(u
When RCRA h&uidiHii wadc« aic
moved into or IMII of an area nl
conUmuulHin. MCRAdi«|Niul
iet(uifciDcnii are ap|ilicable lo
the wanle being nuuugoJ and
certain Ircaloiciil. Morale. »r
diapoaal ie>|uircmcnl« aic
applicable lo llic area receiving
the waate. (t« Cloiurc)
Storage ol RCRA waatc* (lined >u
characlcrimc) not mcduig mull
inianlMiy generator trilcria held
for a temporary period greater
than 10 day* before treatment.
dupoaal or atoragc cl«cwhcr>:
(40 CFR 264 10) in a container
A generator wbo accumulate* or
•tofc* ruuarduui waalc on mlc
for 90 dayi or lea* in compliance
wild 40 CFR 2b2 J4(.)(l 4) u not
•ubjccl to full RCKA aloragc
requirement* Small quantity
generator* arc not •uli(Ocl to
the 90 day limit (40 Cl R lt>l Vt
(c). (J). anil (c»
4(U I K
IM
40 Cl R 2M 112
Clotcd during *l»ragc (e»cc|H In add
i>i remove waklc)
•III I I K .'(
I / 1
-------
Table 8.1 (cont.)
PdTI-NTIAI ACTION SPIU'll l« AKAN.
I-ORMIK KOmiNS COMPANY. INC Sill:
BI:A/hR tAST. INC
MURRISVII I.E. NORTH CAROLINA
Pracquisila
laapact coatitacr storage tic* weekly
for deterioration.
('Hal ton
40CI-R 264 I /-I
pUca cas*alag»s 04 I/I
Keep cooUincft of ignilcblc or re*>.1ivc
wuu •! le** SO feet from the
ficiUie* property line
Keep incoapaliblc oulcrul* *c|Mnlc
Scpcrde iacompaliblc oulcrult alored
OCM e*ck other by • dike or barrkr
Al clocufc. remove all haurdout
•ad ruiduei from the containment lyucm
aad decooUBiiulc or remove all
corMaincri. liner*.
4I)( I K 264 I/O
40CI R 264 1/7
4UC| H ,>04 1/8
Storage of banned wartct muil be in
accordance »nh 40 CFR 268 When .uch
aloragc occurs beyond one year.
the owner/operator bears the liuiJcn <>l
proving lhal such storajic is lolcly for
the purpose of atxuiiiulaiing sullicicnl
«|uanlilics to allow lor |m>fier rciovcry.
Hcalniciil. and I|I>|H>UI|
4IM I k .'(Jl M)
-------
Table 8.1 (conI.)
POTENTIAL ACTION SPIiCII 1C ARARa
FORMIiR HOPPERS COMPANY. INC SITU
BEA/ER tAST. INC
MORRISVIUJi. NORTH CAROLINA
Prcnquutoa
DISCH AROE of TREATMENT
SYSTEM EFFLUENT
•EST AVAILABLE TECHNOLOGY
UM of bo* available technology (BAT)
tfflmmtfnlly achievable ia required i»
coalrol toite a*d •oacoavenlionai
pnllytaati UM of bed coovenlionaJ
pnlliitaal coajfol technology (BCT) u
required lo control coavcntionaj
polluUnl* Technology bxed limiuiioni
•uy be ddcrmjned OA • CAM '
Puinl tuuicc ductuigc* (n wtlcit
of (he United Suic*
(Any WMCI body or wetland
CERCI.A un-iilc *uivilie> tie
ciempl from pcroiUluiK
requiicmcnU. bill oiuri mat llie
lechnical requirement* of
•polkablc rcguUluiiii )
40CIR
4-«(.)
WATER QUALITY STANDARDS
Applicable Federally approved Stale
water qualiry alandarda muat be complied
wMh TheM aundarda nay be in
addition Jo or mure atringcnl than oihcr
Federal atandarda under the CWA
BEST MANAGEMENT PRACTICES
Develop and implement a Beat Management
Practice Program lo prevent the rcleaac
of loitc conatilulcnlt of concern lo
turfacc walcrt.
The Beat Management Practice Program
muat:
- Eatabliih apecilic procedure* lor the
control of lo«ic and hajardout
pullultnl tpdl*
Diuharge lo walcik ol the I) S
(CL'KCI.A on iilc ailivilic* arc
cicinpt Irom pcraiiliuig
requirements, but muni mco llic
idhnical icquiiemciui ol
a|i|ihcablc regulation! )
401 I H \U 44
•IK) Stale rcgi
cO untlci
IJI
4(1 CIR
|(M>
40 Cl H I.'S IIM
-------
ActfcM
Table 8.1 (cont.)
POTENTIAL ACTION SPECIHC AMAH!
FORMER KOPPERS COMPANY. INC SITE
BEAZER EAST. INC
MORRISVII.LE. NORTH CAROLINA
- ladud* • prediction of the direction.
nh> of flow, aad loul quantity of
lo«lc pnlluiaata where experience
•aoaable potential fur
I failure
- Aaaura proper management of aolid and
haurdoua waatc u accordance with
regulation* promulgated under RCRA
MONITORING REQUIREMENTS
Diachafgc muat be monitored to auurc 4
-------
Table 8.1 (cont.)
POTtiNTIAt. ACTION SPfcClt-K: AH AH.
HORMKR HOPPERS COMPANY. INC SITE
BEAZER EAST, INC
MORJUSVII.LE. NORTH CAROLINA
Artioa KayrimMU Pterequuiua (•«**«>
- Duty to BUIi|plc any idvct «e cflecl*
of My duckvge, utd
- flop* opcraHna and •linlcoaacc of
liyrtca.
DISCHARGE lo PUBLICLY Duckvgc of polluUM* llul |MM Indirect ducturgc »l (Nilluianu 44) (IK
OWNED TREATMENT WORKS lhrou(k Ike POTW witkoul ircMmou. lo POTW
(POTW) inUflctc wuh POTW operation.
(ON tile Mtivily) cunUoiuwlc ihc POTW tludgc. «>t c«ibaotl
ic piohibilioiK (irctiludc I lie
duthaigc ul pullulmnu in P(>1 W« thai
- Create • Arc or c»|>loaion hu«ril in
Ike POTW.
- Will c*tue coitouvc Miuclural chuigc
lo POTW;
- ObHrucI How reaulluig in
uiUrfeiciKc.
- Are duchargcd >l • How nlc uid/or
cuocenlidion thai will rcnull in
inlerfercncc. and
-------
Table 8.1 (conI.)
POTENTIAL ACTION SPECIHC ABA*.
Adfca
PLACEMENT of WASTE
to LAND DISPOSAL UNIT
FORMER KOPPERS COMPANY. INC SITI:
BEA/EM EAST. INC
MORRISVII.LE. NORTH CAROLINA
- kcrowc Ike temperature of waalewalcr
(•Urlag Ike treatment plant thai
would (Mull in interference, but in
•o CMC raiae Ike POTW influent
Uaqwralure above 104 F (40 C)
Diackarge mu* coaply wild local POTW
pntnutmat progrun, including
POTW-^ieciric puUuUnlt. i|>ill
prevent tun ptogrca fequircmcnl*. unl
reporting aad nuoiluring re^uircoocnl*
RCRA pccuu by culc r«|uiicmcnli
(including cof leclivc •clkia whcic the
NPOES permM MM luued ifter
Novcnbcr I. IV84) mum be complied
with for duchifgc* u( RCRA noKiduui
«UU< lu POTW.
LAND DISPOSAL RESTRICTIONS
ABU* l**d dupoul *lrc«laicnl
•Und«(d*" before pulling w.«e into
(•adnil lo comply wuh land ban
ruliicliua. A IrcMmeiil iUnd*id can
be; • conccnlralMMi level lo be achieved
(performance baaed), or a •pocilicd
technology thai murt be uaed (lechnulnn
baaed ) If (he tfandard i. |WI|HMIUUICC
baaed, any technology can be iiKd lo
achieve Ilic ManJartl. (See Timiiiicitl
wlicn wairfc urlll l»c l.aml l>ik|i«iscj )
CdalKMi
•10 CI H 401 •
40 C I H
W)
Tl.n.|Hirt ol HCHA KaurJou. w.dc
lo POTW. by truck, rail, or
dedicated |>i|ic (40 OK 204) which
dtachargca from within the
CERCLA «il£ l<> wuhui the
boundaries of (he POTW
Placement ol RCRA h&urdou. waMe 4O ( I H 268 |l>)
in * landfill, surface
impoundment. wa«c pile.
injection well, land treatment
Utility, aall bed or ull dome
loimalioii. ol underground niinc 01 cave
lor which I. DR. have been |>iocnul^ilcJ
-------
Table 8.1 (cont.)
POTbNTIAl. ACTION SPtCIHC AMAH*
KORMIiR KOPPbRS COMPANV. INC SITt
BI-AZI-M KAST. INC
MORRISVII 11. NORTH CAROLINA
TANK STORAGE (Oa-Ste)
bave •ufftcical strength u>
•Mure that Ibey do MM fuplurc or
Tub auut have Mcoaduy cuouinmenl
Md mflklMl fradMMrd to prevcnl
ovaflow by wave •dion.
of crack, or leak*.
S(»i*gc ol KCKA haulJout
nm meeting null <|utniilx
gciicr«l4ir criUcu
40CIK 2(A I>M>
4()( IR 2M I4|
4UOR 2M 10
40 CI R 2M 193 I'M
- Al cloMirc. *ll luuidoui wutc and
WMIC residue nuM be cleaned from lank
40CI-R 2W l'>6
4UI'IH 264 II;
TREATMENT in • UNIT
ntfiucafott will be uitludod
if Ikit becoBci «n •lleriMlive.)
Dc«i|n «nd upcr«4uig MamfarJi for unit
in wbjcb buarduui mute U Irulcd.
(Sec ciUIHM* for decigji and operating
coquuencou for tpceific uniU )
Trcalmcul ol ha/ar
in • uml
40 (IN 264 I'M)
2t>4 147 (Taukil
40CIR 264 111
(l.anJ Tfcalmciil Iliulil
40 C| K it,* M\
(Miac 'I lealiuciii llini>l
-------
Table 8.1 (cunt.)
POTENTIAL ACTION SPECIFIC AHA*.
FORMER KOPPERS COMPANY. INC. SITI:
BEAZER EAST. INC
MOHRISVIU.E. NORTH CAROLINA
Prerequisite*
TREATMENT Jmtmitt of mule mbjad to but on Dupottl of Mime imputed «>il 40 CFR 2611 10
will bt bod 4UpOMl mum Mute Icvdi «od dcbru roulling from < ERt I A 4O CI-R 268 11
IDAT tot tmck kaurduut napuuc tcHotu or MCHA 40 (•) M 268 12
I !• Mck luud ••*•. corrective wtHNU u ni4 Mihpxl 4Orik2684l
lo land dupovd pioiubiKwu
uolil M.y I. 1942 N» I DR.
have been caubhthcd fur
FOJ2 in >ki«
-------
Table 8.2
POTENTIAL IjOCATION SPECIHC ARARs
FORMER KOPPERS COMPANY. INC SITE
UEAZER HAST, INC.
MORRISVILLE. NORTH CAROLINA
Location
Wetlands
Action to prohibit discharge of dredged
or fill material into wetland* without
a permit.
Action to avoid adverse effects, minimize
potential harm, and piecerve and enhance
wetland*, to the extent possible.
Prerequisite*
Wetlands as defined in US Anny
Corps of Engineers regulations.
Action involves construction »l
facilities or management of
properly in wetlands, as defined
by 40 CI-R 6, Appendix A, section
Federal
Citation
Clean Water Act
section 4(M,
4<) Cl R IM
:i.» CI-R 1JO .III)
40 < I R I'm! (,.
Appendix A
(Note: 40 CFR 6. subpart A aels forth EPA policy for carrying out the provisions of Executive Orders 11988 (Hoodplain Management)
•od 11990 (Protection of Wetlands). Executive Orders are binding on the level (e.g., federal, stale) of government for which they
•re issued.)
Are* affecting stream Action to protect fish or wildlife.
or river.
Diversion, channeling or other
activity that modifies a stream
or river, and affects fish or
wildlife.
16 DSC 661 ct v (
(i ish A WilJhie
Coordination Ail),
40 Cl R b Ml
-------
Table 8.3
POTENTIAL rilliMICAI. SPIiCII 1C AKAKs
-R KOPPI-;RS COMPANY. INC sin:
III:A/I:K I-AST. INC.
MOKKISVII.I.b. NORTH CAROLINA
of Coacen
RCRA Maiinuai
COBC. LutiU
(MCL.)
Pbeaolt
Phenol (Tout)
2 Chloropbeool
2 - Niliophenol
2,4-Dimethylpbenol
2.4 Dichlorophenol
4 Chloro 3 Meihylphenol
2,4,6- Trichlurupnenol
2.4 Dimirophcoul
4-Niliophenol
2.3.5,6 Telr«chloropben»)l
2 Methyl 4.6 DimUophcnol
PenUchlorophenol
Dioxios tad Funuu
2.3.7.1-TCDD
SDWA SDWA SOWA NPDWK
NPDWR Maximum NPDWR Minoium Soc
-------
Table 8.4
POTtiNTIAl- ACTION SPtCII 1C ARARa (NORTH CAROI INA)
FORMER KOPPKRS COMPANY. INC SITi:
BbA/tK HAST. INC
MORRISVILLE. NORTH CAROLINA
Criteria, or
Nortfc Carolbu Solid awl
Hazardoua Waato
North Carolina Solid Wutt
ManageaBcol RcgulalHMU
DeacripUoa
Eatabliahea rcguUlHiM fur handling
•nd dupo«*l of conMtudioa debm.
Iruh. iludgc. and haurduui w«*e
Alw> tcgulMe* recycling «nd
proccuing of thc*e nuicruh
Rule* governing the ouuugcmcnl ul «>lid
WMle. Inclutlc* Huragc. collection.
Iruuportalion. and du|niul of
•olid WMIC
(i S I30A. Ailulc
ISA NCAC I 111
North Cuiolin* Huardoui Wule
. MuwgcmcM Cumniutoo Act
tdabhihc* regulation* lot tiling,
coBMruction «nJ operation ul 1 Sl)l k
(i S I Mill
North CaroliM Oil Pollution
•nd Huirdout SubiUncc
Control Act
Eiubluhe* rcgulalioa* protecting the
land wid walcn over which the Suit
hai juriidiclion regarding oil
product! and other luuardouk
lubMancca
U S 14j. Arli.lc .'(A
North Carolina Water
Pollution Control Regulation*
LtUblutic* NPDI:S permit
and lce». lui Jiachaigc* (>i w«(cit
»l I he klalc
N( A( .'II
-------
Table 8.4 (conL.)
POTENTIAL ACTION SPECIFIC ARAK. (NORTH CAROI INA)
FORMER KOPPERS COMPANY. INC Sill:
BEAZER EAST, INC
MORRJSVIU E. NORTH CAROIJNA
Criteria, or Uafcatfaa
DtmcripUtm
WASTEWATER DISCHARGES TO SURFACE WAI I US
Requite* permit fat the din-forge
of poilulaa** uilo water* of ihe
Uajted Stale*
datum
ISA NCAC 711 OHM)
WASTE NOT DISCHAROED TO SURFACE WATI R
Require* permit for ly^eou whurk
do nul dudurge lu wrfacc w«iei
of Ike HMc, include* tcwer tymcm».
lre*lmenl work*, uid tludge dupo**J
•yucmt wkich diickarge w**4c onto or
below land *urf«cc.
DA NCAC 211 (IJIX)
WATER QIIAI.ITY CERTIFICATION
Require* di*ch«rgeri lo obuin •
Certificate of Coverage, prior lo
iimitnrf of a diachargc permit
ISA NCAC 211 OSOO
STANDARDS FOR PRETREATMENT FACII ITItiS
Require* permit fur pretrcalmcnl
facilitic* di*chniging wade lo a
Trcalrociil Worka
ISA N( A( .'II
N C. Water Quality Standard*
ElllucAl Guideline* and
Standard* Applicahle
In Surface W.lcn
CLASSIFICATIONS AND WATER QUALITY STANDARDS
APPI.ICABI I TO Sllkl-ACF. WA7I HS OF N C
Require* i|icli>i«<.lcii«ut
fm di*char|(e under Nl'lll S |N:IIIIII>
\~>A Nl At .'II H.'CNI
-------
Table 8.4 (cont.)
POTENTIAL ACTION SPIiCII 1C ARAR* (NORTH CAROLINA)
FORMER KOPPERS COMPANY. INC SITE
BEAZER EAST. INC
MORRISVILLE. NORTH CAROUNA
CriMfc. M
Description
EFFLUENT LIMITATIONS
Require* technology bated cfllucnl
limiUliaM for pollutant*
STORMWATER RUNOFF OISPOSAI.
ISA NCAC 211 (H4N)
ISA NCA< .'II IINMI
North Caroluu Haurdout
Wulc MciMgcneM Rc|ulilioai
E««blithc« iulc« governing the
nuuwgcmenl uf h&uirtloui wane within
the Suic.
ISA WAt' HA
(•IUCIH 262)
IDENTIFICATION AND LISTING Of MA/ARIM)IIS
WASTE
Eiubliabc* ciiicria for idc4ilifit«lion
o( huaidout wulc
STANDARDS APPLICABLE TO GENERATORS OF
HAZARDOUS WASTE
EiUbliihe* Muulartli lor gcncralori
wailc*
ISA N( A( IJA
(4UCIk 201)
ISA NCAC I)A (KH)/
(40CIH 262 10 I.')
STANDARDS APPI ICABI I: TO TRANSPORTERS
OF HAZARDOUS WASH
EaUbluhea Maiulardt a|i|.lual>lc In
llwlt|KiHci> ul hataid.m. wade wilhm
Ilic US
ISA N( A( i IA
|4(M I H .'(.I|
-------
Table 8.4 (cont.)
POTENTIAL AtmON SPECIFIC ARARa (NORTH CAROLINA)
FORMER KOPPERS COMPANY. INC SITH
BbAZER EAST. INC.
MORMSVILLE. NORTH CAROUNA
SiMdwd.
Crt»»rta. or UmlUtk* Dcacripttoa
STANDARDS FOR OWNERS AND OPERATORS Ol I5A NCAC I )A 0009
HAZARDOUS WASTE TREATMENT. STOMAlit. <4(> < I K 264)
AND DISPOSAL FACILITIES
lot Uw acceptable m*n»gcmcal at
h«iifA 0010
ouaagcncnl of hazardous waau during (40 I'l k 265)
Ike period of latcriai alalui and unld
ccrtUkation of final cloaurc of if
the facility ia aubject lo
poai-cloaufc requirencnl*, ualil
poal- cloaure rcapua»ibililic* arc
fulfilled
LAND DISPOSAL RESTRICTIONS f>A N( At I IA mil.'
Edabhahca limeublc lur ic«lrKti
-------
Table 8.4 (cont.)
POTENTIAL ACTION SPECIFIC ARARs (NORTH CAROI IN A)
FORMER KOPPERS COMPANY. INC SITE
BEAZER EAST. INC
MORRISVILI.E. NORTH CAROLINA
Crtoria. 0* UaftatfcM
HAZARDOUS WASTE PERMIT PROGRAM
Establishes provUiuni covering basic
EPA peraultug re<|uirciDcnl actions
ISA NCAI I U 0011
(40 OH 2 ID)
North Carolina Drtnfcjng Water
•ad GtouMiwatCf Standards
CRITERIA AND STANDARDS APPI If ABI t TO WATLK
SUPPLY AND CERTAIN OTHER TYPk Wl 11 S
EiUbluhea rcgulaliofu dclmuig
injecliun wclli. and the conMiucliun
•ad mimitoiing requirement! Mtoculol
with Ihcro
N( At 2.
regulMitms wid ciMiitrui:lii»ii
crtferi* for welli. uvi icgittiilion
tcx)uiicmciiU (»c drillcru
ISANf Af 2. 2t
(N f Well
f i>n»lfui-||im Ail)
NC OROUNDWATtR t I ASSII (CATIONS AND STANDAKDS ISA Nt'At Jl OHM)
CUuifiCAliua* wid wMct quality U J cMaMi>hc>
a >Hc nulling »y.tlrin
ti S II \A.
ISA Ni'AI I If
i<. s i IIIA."'II i
AHi>lc '')
-------
Table 8.4 (cont.)
POTENTIAL ACTION SPECIFIC AMARi (NORTH CAROI IN A)
FORMER KOPPtRS COMPANY. INC SITt
BEA/ER EAST. INC
MORRISVII.I.E, NORTH CAROLINA
Criaaria. or I lailaartna Pcacripdua _ <
Recyclable Material* Uead EfUbliifced rcgulationi which I SA N( AC 11A 0011
ta • Minn-r CoMUtuliB| apply lo recyclable maicruli (44) ( IT ->66 JO)
Diapoaa! IkM are applied lo at placed
oa> lac land.
NC Air PollulitM CoMiol Ertabliahc* «uie air pull"""" 'SA Ni'AC 21) (LNM)
RequircacaU cuolrul policy.
-------
Table 8.5
POTENTIAL IjOCATION - SPKCIHC ARAIU (NOKIII CAMOI INA)
FORMER HOPPERS COMPANY. INC SITE
BEAZER EAST. INC
MORRISVII.LE. NORTH CAROLINA
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Table 5.6
POTENTIAL CHEMICAL-SPECIFIC ARARs (NORTH CAROLINA)
FORMER KOPPERS COMPANY, INC. SITE
BEAZER EAST, INC.
MORJUSVTLLE. NORTH CAROLINA
Constituents of Concern
OMMWS ClaafC
Grouadwater Surface Water Surface Water
Maximum Maximum Maximum
Levels fMCLs) Level* (MCLs) Level* (MCLs) Aquaac Life Human Health
Phenols
2-Chiorophenol
PejitachJoropheool
Total phenol
Diovas
:.3.T.S-TCDD
0.0001 mg/T. («»
0.22 mg/L it)
1 0 ug/L (b)
2.20E-10 mg/L (a) 0.000013 ng/L (b)«
(d)
O.OOOOU ng.'!. •;••
(i) 15A NCAC 2L.0202 (Wttet Quality Sun
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Record of Decision
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f
Table 8.7
Soil Alternatives
SI - No Action
S3 - Surface Cover
S4 - RCRA Cap
S5 - On-site Landfill
S6 - Off-site Landfill
S7 - On-site Decr.lorination
S8 - On-site Incineration
S9 - Off-site Incineration
SlO- On-site Storage
$ o
$ 1,326,000
$ 1,477,000
$ 2,170,000
$ 816,000
$ 4,530,000
$ 3,240,000
$ 4,750,000
$ 659,000
Groundwater Alternatives
GW-l: - No Action
GW-3: - Extraction,
Bioremediation, Surface
Water Discharge
GW-4: - Extraction, Carbon
Adsorption, Surface Water
Discharge
GW-5: - Extraction, UV/OX,
Surface Water Discharge
$ 0
$ 5,100,000
$ 4,031,000
$ 5,133,000
Surface Water Alternatives |[ Fire Pond
SW-1: - No Action
SW-3: - Pond Destruction,
Carbon Adsorption, Surface
Water Discharge
SW-4: - Pond Lining, Carbon
Adsorption, Surface Water
Discharge
$ o
$ 1,300,000
Total
$ 952,000
..
$ 2,252,000
Medlin Pond
$ o
$ 695,000
$ 1,995,000
$ 710,000
$ 1,662,000
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without significant risk to the community or on-site workers and
without adverse environmental impacts.
All of the surface water remedial alternatives could be implemented
without significant risks to the community or on-site workers. The
potential impacts on the environment from implementation of
Alternative SW-3 includes the removal of wetlands and the natural
habitat for fish and wildlife by the destruction of the Fire Pond.
This impact will be countered by a wetland mitigation plan which
will restore wetlands in a portion of the area.
8.2.4 Long-Term Effectiveness: The alternatives are evaluated based
on the alternatives' ability to maintain reliable protection of
public health and the environment over time once the cleanup goals
have been met.
For soils, alternative SI would not be effective, long or short-
term in reducing contaminant levels in the soil. Alternatives S-3
and S-4 could be effective in the long term through regular
maintenance of the cover or cap, but a review of the remedy would
be required every five years since a cap or cover is not considered
to be a permanent remedy and leaves wastes in place that are above
health protective levels. Alternative S-5 would also require the
5-year periodic review due to the levels of contaminants remaining
onsite. Onsite landfilling, S-6, would require the same cap
maintenance as Alternative S-4. Long-term maintenance at a
permanent landfill would be required for offsite landfilling.
Alternatives S-7 through S-9 call for treatment of the contaminated
soil and therefore, result in the highest degree of long-term
effectiveness by permanently reducing the Site risks. Alternative
S-7 provides for onsite treatment by dechlorination. The
effectiveness of this technology cannot be measured without
treatability study results on Site-specific soils. The technology
must provide equivalent levels of protection of human health and
the environment to be deemed effective. Alternative S-10 does not
provide long-term effectiveness or permanence since on-site storage
would be on a temporary basis until better technology is developed.
Under Alternative GW-1, groundwater contamination would continue to
migrate off-site, therefore the No Action Alternative would not be
considered a permanent or effective remedial solution. The
contaminant concentrations in the groundwater will be permanently
reduced through groundwater extraction and treatment specified in
Alternatives GW-3 through GW-5.
Under the No Action Alternative, surface water contamination would
remain in the surface water; therefore, this is not considered a
permanent or effective remedial solution. Contaminant
concentrations in the surface water would be eliminated by either
Alternative SW-3 or SW-4. These alternatives are considered to be
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effective on a long-term basis and permanent.
8.2.5 Reduction of Mobility, Toxicity, and Volume: EPA evaluates
each alternative based on how it reduces (1) harmful nature of the
contaminants, (2) their ability to move throughout the environment,
and (3) the volume or amount of contamination at the site.
Consideration of the soil remedial alternatives established that
contaminant levels would remain unchanged for Alternatives S-l, S-
3, S-4, S-5, S-6, and S-10. Alternatives S-3 and S-4 would not
reduce the toxicity or the volume of the contamination, but would
reduce the mobility and therefore the effective toxicity may be
reduced. Alternative S-5 may reduce the mobility of the
contamination. Alternative S-6 would permanently reduce the
mobility of contamination in soils at the site; volumes and
toxicity remain unchanged. If effective, Alternative S-7 would
reduce the toxicity and mobility of the contaminants in the soils.
Since the effectiveness of this treatment has not been demonstrated
for site-specific soils, the reduction of overall toxicity,
mobility and volume for Alternative S-7 is unknown. Alternatives
S-8 and S-9 would effectively reduce the toxicity, mobility and
volume of site contaminants in the soils. Alternative S-10 would
reduce only the mobility of the soil contaminants, therefore,
eliminating a source to groundwater.
Alternative GW-1 would not significantly reduce the toxicity,
mobility or volume of contaminants in groundwater. Alternative
GW-3 through GW-5 would reduce the volume of contaminants in the
aquifer through recovery. The groundwater treatment systems will
comply with the statutory preference for alternatives that reduce
toxicity of contaminants.
The implementation of Alternative SW-1, No Action, would not reduce
the toxicity, mobility or volume of contaminants in the surface
water. Alternatives SW-3 and SW-4 eliminate the contamination in
the surface water.
8.3 MODIFYING CRITERIA
8.3.1 State Acceptance:
As a matter of course, EPA requests State comments on the Remedial
Investigation and Feasibility Study reports as well as the Proposed
Plan, and must take into consideration whether the state concurs
with, opposes, or has no comment on EPA's preferred alternative.
The NC-DEHNR has reviewed and provided comments on the reports and
data from the RI, the FS and the Baseline Risk Assessment. The
State of North Carolina provided conditional concurrence on
September 18, 1992. The conditions included a request to conduct
a treatability study on dechlorination to determine whether the
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technology can be effectively used on the site contaminated soils.
8.3.2 Community Acceptance:
The community has gone on record in support of the surface water
and groundwater remedial alternatives identified in the Proposed
Plan. EPA does not have community acceptance for off site
incineration. The residential community has expressly stated that
dechlorination or onsite storage would be the only technologies
acceptable to them. EPA has received comments from commercial
representatives, including the current owner of Unit Structures,
that favor offsite incineration. The Responsiveness Summary
provides greater detail of the community comments and their
respective positions concerning the remedy selection. A response
to comments is included in a Responsiveness Summary which is a part
of the Record of Decision (ROD) for the Site.
9.0 SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
National Contingency Plan, the detailed analysis of alternatives
and public and state comments, EPA has selected a multi-component
remedy for this site to include source control for contaminated
soils, groundwater and surface water remediation. At the
completion of this remedy, the risk associated with this site has
been calculated to be within the accepted risk range determined to
be protective of human health and the environment. The total
present worth cost of the selected remedy is estimated at $11.5
million. This estimate includes source control, groundwater and
surface water remediation, treatability studies and fencing of the
Fire Pond, lagoon and CELLON process areas.
The selected remedy is protective of human health and the
environment, is cost-effective, attains ARARs, and utilizes
permanent solutions and resource recovery technologies to the
maximum extent practicable. This Record of Decision identifies
both a primary and a contingency remedy for source control.
Remedy-selection treatability studies will be conducted on site
contaminated soils to evaluate the effectiveness of dechlorination.
Sufficient quantities of treated product and treatment residuals
must be generated to fully characterize the usability of this
technology. The contingency remedy must be shown to provide
adequate dechlorination of site contaminants and cost effectiveness
with respect to the primary source control remedy; together, these
two components would meet the evaluating criteria of remedy
selection. The threshold criteria of overall protection of human
health and the environment, as well compliance with ARARs must also
be satisfied. The contingency remedy will be used if treatment of
site soils can effectively reduce the levels of contaminants in the
soil such that the soil no longer requires management as a
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hazardous waste.
The primary remedy employs thermal destruction to eliminate the
principal threat at the site, this option also satisfies SARA's
preference for remedies which utilize treatment as their principle
element to reduce toxicity, mobility and volume. If proven
effective on site soils, the contingency remedy will also satisfy
this preference.
9.1 Source Control
9.1.1 Primary Source Control Remedy
Source control remediation will address the contaminated soils at
the Site. The primary source control remedy requires that the
contaminated soils located in the former process and lagoon areas
be excavated and transported to a permitted offsite incineration
facility. Excavation will be conducted on all soils.contaminated
with greater than 95 ppm of pentachlorophenol and/or 7 ppb of
dioxins/furans. Costs associated with this component of the remedy
are approximately $ 4.8 million. This cost is based on a volume of
1000 yds3.
Additional soil characterization will be required, either before
excavation begins or as part of the excavation process, to more
accurately define the lateral and vertical extent of soil to be
excavated. It is anticipated that excavation will be accomplished
using conventional excavation equipment and earthmoving techniques.
Following excavation and removal of the soils, clean fill will
be placed in all excavated areas. A minimum of 1 foot of clean
fill will be required. Areas will be graded to achieve desirable
surface drainage patterns and revegetated.
The primary source control remedy mandates that the contaminated
soils will be transported to an offsite permitted facility and
incinerated. At a minimum, the facility permit must allow the
treatment of KOO1 waste. CERCLA requires that the compliance
history of a receiving facility be reviewed prior to transporting
the material. Hazardous waste manifests will be required for the
transport of the materials.
Upon completion of incineration, the residual ash will be disposed
in a secure landfill and will be the responsibility of the operator
of the incineration facility.
9.1.2 Contingency Source Control Remedy
Source control remediation under the contingency remedy would
utilize dechlorination. Contaminated soils located in the former
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process and lagoon areas will be excavated and moved to an onsite
treatment facility. Excavation will be conducted on all soils
contaminated with greater than 95 ppm of pentachlorophenol and/or
7 ppb of dioxins/furans. Costs associated with this component of
the remedy are approximately $4.6 million. This cost is also based
on a volume of 1000 yds3.
As in the primary source control remedy, additional soil
characterization will be required, either before excavation begins
or as part of the excavation process, to more accurately define the
lateral and vertical extent of soil to be excavated. It is
anticipated that excavation will be accomplished using conventional
excavation equipment and earthmoving techniques.
The soils will be treated in an onsite treatment facility until
treatment standards are met. The treatment standard for PCDD/PCDF
will be equal to or less than the cleanup standards established for
excavation, 7 ppb. In this Record of Decision, EPA is granting a
treatability variance for the contaminated soil pursuant to 40 CFR
268. The treatment standard for pentachlorophenol is dictated by
the treatability variance and must meet the 90-99 % reduction range
and be below the excavation standard of 95 ppm. The technology
will be deemed effective if the treatment of the soils can
effectively reduce the levels of contaminants in the soil such that
the soil no longer requires management as a hazardous waste.
Following excavation and treatment of the soils, the treated soils
will be placed in all excavated areas. Areas will be graded and
revegetated to achieve desirable surface drainage patterns.
9.1.3 Excavation and Performance Standards
Excavation shall continue until the remaining soil and material
achieve the following maximum contaminant levels.
Pentachlorophenol
Dioxins / f urans
Cleanup Standard
95 ppm
7 ppb
Risk Level"
3.2E-06
1.2E-04
The cleanup standards identified above, which are established for
a current and future industrial scenario, were originally developed
for the protection of groundwater. These levels are more stringent
than those levels established for direct contact exposure, and are
therefore more protective.
"Numbers represent a carcinogenic risk level.
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9.2 Groundwater Remediation
Groundwater remediation will address the contaminated groundwater
at the Site. Groundwater remediation will include extraction of
contaminated groundwater, treatment and final discharge to surface
water.
Groundwater at the Koppers Site occurs in the weathered bedrock
unit (10 to 30 feet below land surface) underlying the surficial
sediment deposits and in the lower fractured bedrock aquifer.
Recharge is supplied to the fractured aquifer by leakage from the
overlying semi-confining bed in the residual soil. Water producing
fractures decrease in size, frequency, and interconnectedness with
increasing depth. Water-bearing fractures in the bedrock are
generally encountered at depths ranging from 30 to 55 feet below
ground surface.
The current design of the pumping strategy consists of one main
groundwater extraction well which is located in the onsite plume.
Extracted groundwater is expected to contain pentachlorophenol,
dioxins/furans, and phenolic compounds. During the Remedial Design
and/or the Remedial Action, assessment of the effectiveness of the
existing extraction well will be made. Additional extraction wells
will be added if necessary.
The treatment of the groundwater will consist of equalization,
filtration for removal of suspended solids/ and carbon adsorption
of dissolved organics to required discharge levels. Discharge of
treated water will be to the nearest viable surface water body.
9.2.1 Extraction and Performance Standards
Groundwater will be extracted from the plume using the existing
extraction well PW-1. This well is located adjacent to the former
lagoon area. Additional extraction wells will be installed if
necessary. The groundwater flowrate to treatment is approximated
at 10 gallons per minute. Actual flow rate will be determined
during remedial design. To accommodate the need for potential
future additional groundwater pumping, treatment system components
will be designed to treat 50 gallons per minute of groundwater.
Final discharge after treatment will be to the nearest viable
surface water. Discharge standards will be driven by NPDES
requirements and will be defined during the development of the
Remedial Design. If the discharge is onsite, a permit will not be
required; all substantive requirements of an NPDES permit will be
met.
Groundwater shall be treated until the following maximum
concentration levels are attained throughout the plume.
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9.1 Groundwater ;
• Cleanup Standards
pentachlorophenol
PCDD/PCDF
2 , 4-dichlorophenol
Cleanup Standard
(ppb)
1 (MCL)
3E-05 (MCL)18
20"
Risk Level or
Hazard Quotient
3E-0617
1E-0417
0.220
The goal of this remedial action is to restore the groundwater to
its beneficial use, as defined in Section 6.0. Based on
information obtained during the Remedial Investigation, and the
analysis of all remedial alternatives, EPA and the State of North
Carolina believe that the selected remedy may be able to achieve
this goal.
Groundwater contamination may be especially persistent in the
immediate vicinity of the contaminants' source, where
concentrations are relatively high. The ability to achieve cleanup
goals at all points throughout the area of attainment, or plume,
cannot be determined until the extraction system has been
implemented, modified as necessary, and plume response monitored
over time. If the selected remedy cannot meet the specified
performance standards, at any or all of the monitoring points
during implementation, the contingency measures and goals described
in this section may replace the selected remedy and goals for these
"Number represents a carcinogenic risk level.
18 The promulgated North Carolina standard for dioxin in
groundwater is 2.2E-10 parts per million. This state standard is
more stringent than the federal MCL, but is below detection
capability. North Carolina's regulations state that "where the
maximum allowable concentrations of a substance is less than the
limit of detectability, the substance shall not be permitted in
detectable concentrations." In such a case, the Practical
Quantitation Limit, PQL, is the established standard. The PQL for
PCDD is equivalent to the MCL.
"The cleanup goal for 2,4-dichlorophenol is a health based
value calculated by the same methodology used to determine MCLGs
for noncarcinogens. The number is based on the chemical-specific
reference dose, a water ingestion rate of 2 liters, a body weight
of 70 Kg., and a relative sources contribution of 20%. As with the
MCLGs, the cleanup goal was adjusted by the percentage of the total
daily exposure expected to be contributed by drinking water or the
relative source contribution.
"Number represents a noncarcinogenic hazard quotient (HQ).
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portions of the plume. Such contingency measures will, at a
minimum, prevent further migration of the plume and include a
combination of containment technologies and institutional controls.
These measures are considered to be protective of human health and
the environment, and are technically practicable under the
corresponding circumstances.
The selected remedy will include groundwater extraction for an
estimated period of 30 years, during which time the system's
performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during
operation. Modifications may include any or all of the following:
a) at individual wells where cleanup goals have been attained,
pumping may be discontinued;
b) alternating pumping at wells to eliminate stagnation points;
c) pulse pumping to allow aquifer equilibration and encourage
adsorbed contaminants to partition into groundwater;
d) installation of additional extraction wells to facilitate or
accelerate cleanup of the contaminant plume.
To ensure that cleanup continues to be maintained, the aquifer will
be monitored at those wells where pumping has ceased on an
occurrence of every 2 years following discontinuation of
groundwater extraction.
If it is determined, on the basis of the preceding criteria and the
system performance data, that certain portions of the aquifer
cannot be restored to their beneficial use, all of the following
measures involving long-term management may occur, for an
indefinite period of time, as a modification of the existing
system:
a) engineering, controls such as physical barriers, or long-term
gradient control provided by low level pumping, as contaminant
measure;
b) chemical-specific ARARs may be waived for the cleanup of those
portions of the aquifer based on the technical
impracticability of achieving further contaminant reduction;
c) institutional controls may be provided/maintained to restrict
access to those portions of the aquifer which remain above
remediation standards;
d) continued monitoring of specified wells; and
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e) periodic reevaluation 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 5 year intervals in accordance with CERCLA Section 121 (c).
9.3 SURFACE WATER REMEDIATION
The surface water contained in the Fire Pond and the Medlin Pond
will be removed by pumping; water will subsequently be treated by
carbon adsorption and discharged to the nearest viable surface
water body. All applicable requirements associated with the
National Pollution Discharge Elimination System will be complied
with.
Diversion channels and berms will be constructed to minimize the
amount of rainfall draining to the ponds during dewatering. The
surface water will be treated by carbon adsorption units. Clean
fill will be placed into the drained ponds to ensure that future
surface water contamination by contaminated sediments does not
occur. Current levels in sediments pose this potential problem.
Pond sediments must be sampled to ensure concentrations of site
contaminants do not exceed soils cleanup standards established for
the site. Filling of the ponds with clean fill will result in the
dioxin contamination being removed from the sediment-water
interface and prohibit additional surface water contamination.
Clean soil will be used to backfill the ponds. After dewatering
and backfilling are completed, final grading of the pond areas to
control surface drainage will be conducted. Final revegetation
will be maintained to provide long term sediment and erosion
control .
Wetlands construction will be conducted to restore the wetlands
which will be destroyed by the surface water remediation. This
work will involve the creation of new wetlands or the expansion of
existing wetlands at a nearby location.
9.4 ADDITIONAL COMPONENTS
In addition to the source control, groundwater and surface water
remediation requirements identified in this section, additional
components of this Record of Decision are identified in the
following paragraphs:
9.4.1 Sami In Reuirements
Additional confirmatory samples will be collected in the western
ditch, the Fire Pond overflow, and pond sediments. The laboratory
analysis will be for phenolic compounds and PCDD/PCDF. Analytical
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methodologies selected must be approved by EPA prior to use and
must meet Level IV data quality objectives.
9.4.2 Groundwater Evaluation and Plume Definition
The groundwater monitoring wells installed during the Remedial
Investigation will be resampled for phenolic compounds and
PCDD/PCDF. Complete definition of contaminant plume will be
conducted. Discrepancies between contaminant levels in domestic
wells which were not confirmed in monitoring wells will be
investigated and explained by monitoring well installation,
sampling and analysis. Analytical methodologies selected must meet
with EPA approval prior to use and must meet Level IV data quality
objectives.
9.4»3 Fencing and Maintenance
The area requiring remediation that consists of the Fire Pond,
Medlin Pond, the CELLON process area and the lagoon area shall be
enclosed with adequate fencing and security measures until
remediation is complete. Grounds maintenance shall be conducted on
a timely and frequent basis to ensure minimal hazards due to snake
infestation or neglect of premises.
9.4.4 Habitat Evaluation
Wetlands will be eliminated as a result of the surface water
component of the remedy. This surface water remediation will
subsequently eliminate certain habitats associated with these
wetlands. Therefore, a habitat restoration plan will be developed
in conjunction with wetlands mitigation.
9.5 COMPLIANCE MONITORING
Groundwater, treated soils and surface water monitoring shall be
conducted at this site. Analytical methodologies selected must be
approved by EPA prior to use and must meet Level IV data quality
objectives. After demonstration of compliance with Performance
Standards, the Site including soil and groundwater shall be
monitored for five years. If monitoring indicates that the
Performance Standards set forth in this Record of Decision are
being exceeded at any time after pumping has been discontinued,
extraction and treatment of the groundwater will recommence until
the Performance Standards are once again achieved. If monitoring
of soils indicates that Performance standards are exceeded, the
effectiveness of the source control component will be re-evaluated.
9.6 Applicable or Relevant and Appropriate Requirements (ARARs)
CERCLA Section 121(d)(2) requires that the selected remedy comply
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with all federal and state environmental laws that are applicable
or relevant and appropriate to the hazardous substances,
pollutants, or contaminants at the site or to the activities to be
performed at the site. Therefore, to be selected as the remedy, an
alternative must meet all ARARs or a waiver must be obtained.
North Carolina Hazardous Waste Management Regulations
Federal regulations under the Resource Conservation and Recovery
Act ("RCRA") establish minimum national standards defining the
acceptable management of hazardous waste. States can be authorized
by EPA to administer and enforce RCRA hazardous waste management
programs in lieu of the Federal program if the States have
equivalent statutory and regulatory authority. If the CERCLA site
is located in a State with an authorized RCRA program, the State's
promulgated RCRA requirements will replace the equivalent Federal
requirements as potential ARARs. If the State is authorized for
only a portion of the RCRA program, both State and Federal
standards, for the portion of the RCRA program not delegated to the
State, may be ARARs.
Since EPA has delegated the RCRA program to North Carolina, the
North Carolina hazardous waste management regulations are potential
ARARs, except for requirements such as those promulgated under the
Hazardous and Solid Waste Amendments of 1984 ("HSWA"), which have
not been delegated to North Carolina.
The bottom sludge from the wood treatment process lagoons is
classified as K001 hazardous waste. Although the disposal of these
wastes originally occurred prior to the effective date of the RCRA
regulations (November 19, 1980), the ROD requires the excavation of
the soil contaminated with those wastes. That soil therefore must
be treated as K001 hazardous waste. Therefore, except for the HSWA
requirements, North Carolina hazardous waste management regulations
at ISA NCAC 13A are applicable requirements for this Site. Certain
of the regulations are described in greater detail below.
ISA NCAC 13A.0007
The ROD requires excavation of the contaminated soil. Such
excavation will qualify as the generation of hazardous waste.
The treatment residuals generated from on-site dechlorination,
if implemented, and residuals from the groundwater and surface
water treatment processes will also qualify as K001 hazardous
waste. These regulations establish standards applicable to
generators of hazardous waste and are applicable at this Site.
ISA NCAC 13A.0009
These regulations establish standards for hazardous waste
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treatment, storage and disposal facilities. The on-site
dechlorination remedy, if implemented, will qualify as the
treatment of hazardous waste. The provisions of these
regulations pertaining to treatment facilities are applicable
requirements for that remedy. The provisions of these
regulations pertaining to storage facilities are applicable
requirements for any on-site storage of hazardous waste.
Resource Conservation and Recovery Act Regulations
Federal regulations promulgated pursuant to HSWA which have not
been delegated to North Carolina are also applicable requirements
for the Site.
Land Disposal Restrictions; 40 CFR Part 268
K001 waste is subject to the provisions of 40 CFR Part 268,
commonly referred to as the Land Disposal Restrictions ("LDRs").
These LDRs are applicable requirements at this Site. Certain of
these provisions are described in greater detail below.
40 CFR 268 Subpart D - Treatment Standards
The ROD calls for the treated soil from the dechlorination
process to be redeposited at the Site. These regulations
require that the soil be treated to specified levels prior to
placement in the ground and are applicable requirements at
this Site. The contingency remedy will comply with the LDRs
through a Treatability Variance for the contaminated soil as
defined 40 C.F.R. §268.44. The LDRs are also applicable
requirements for any on-site land disposal of residuals from
the groundwater and surface water treatment systems, or
residuals from the dechlorination process.
40 CFR 268 Subpart E - Storage Requirements
LDR hazardous waste stored on the Site must comply with 40
CFR § 268.50, which sets forth conditions on the storage of
hazardous waste which are regulated under Fart 268.
North Carolina Solid Waste Management Regulations; ISA NCAC 13B
Any on-site disposal of waste materials not regulated as hazardous
waste, e.g. solid waste would be governed by these regulations
rather than the Hazardous Waste Management Regulations at ISA NCAC
13A.
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Safe Drinking Water Act; National Primary Drinking Water Standards;
40 CFR Part 141
The Safe Drinking Water Act sets Maximum Contaminant Levels
("MCLs") for public drinking water systems. These regulations
identify MCLs for pentachlorophenol and dioxin at 1 part per
billion ("ppb") and 3 x 10'5 ppb, respectively. These MCLs are
relevant and appropriate requirements at this Site.
North Carolina Groundwater Regulations; ISA NCAC 2L
These regulations set a dioxin water quality standard for
groundwater at 2.2 x 10'7 ppb. This, however, is below the
practical quantitation limit ("PQL") for dioxin. The North
Carolina regulations further state that for contaminants for which
the water quality standard is below the PQL, the standard shall be
the PQL. The PQL for dioxin is 3 x 10'5 ppb.
North Carolina Well Construction Regulations; ISA NCAC 2C
These regulations apply to injection wells and are therefore not
applicable to this Site. However, these regulations are relevant
and appropriate to the construction of the additional groundwater
monitoring wells to be installed at the Site.
Federal Water Pollution Control Act: Discharge Limitations; (33
U.S.C. S 1311; 40 CFR Parts 122. 125. 129. 133 and 136)
Under the Federal Water Pollution Control Act ("Clean Water Act"),
provisions relating to the National Pollution Discharge Elimination
System ("NPDES") and regulations promulgated thereunder govern
discharges to surface waters. The NPDES provisions of the Clean
Water Act, and regulations promulgated thereunder, are applicable
requirements for the surface water discharges required by the ROD.
Federal Water Pollution Control Act; Water Quality Criteria; (33
U.S.C. S 1314)
Water quality criteria set under the Clean Water Act may be
relevant and appropriate requirements for the surface water
discharges required by this ROD.
North Carolina Water Pollution Regulations and Water Quality
Standards; ISA NCAC 2B and ISA NCAC 2H
These regulations govern surface water discharges and are
applicable requirements for the surface water discharges required
by this ROD.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
FEDERAL WATER POLLUTION CONTROL ACT; Dredge And Fill
Section 404 of the Federal Water Pollution Control Act (33 U.S.C.
§1344) governs the permitted discharges of uredged or fill
material. The surface water remedy will result in che destruction
of wetlands. Regulations implementing Section 404 are found at 40
CFR Part 230 and 33 CFR Parts 230-330 and are applicable
requirements for this Site.
Fish and Wildlife Coordination Act; 16 U.S.C. S661 et.seq.
This statute requires measures to mitigate, prevent and compensate
for losses of wildlife resources resulting from any control or
structural modification of streams or the Ponds as required by this
Record of Decision. This statute is an applicable requirement for
this Site.
North Carolina Sedimentation Pollution Control Act; G.S. 113A,
Article 4
This statute requires the development of erosion and sedimentation
control plans and is an applicable requirement for any land
disturbing activities at this Site.
To Be Considered
In the selection and implementation of the remedy defined in this
Record of Decision, EPA is also considering certain additional
guidances. These include:
Superfund LDR #6A (Second Edition), Obtaining a Soil and Debris
Treatabilitv Variance for Remedial Actions, OSWER 9347.3-06,
September 1990.
U.S. EPA Statement of Policy on Floodplains and Wetland Assessments
for CERCLA Actions - August 5, 1985.
Executive Order 11990, Protection of Wetlands
Executive Order 11988, Floodplain Management
10.0 STATUTORY DETERMINATION
Based upon available information, the selected remedy, including
the contingency source control remedy, satisfies the remedy
selection requirements under CERCLA, as amended by SARA, and the
National Contingency Plan. The remedy provides protection of
public health and the environment, is cost-effective, utilizes
permanent solutions to the maximum extent practicable, and
satisfies the statutory preference for remedies involving treatment
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
technologies .
10.1 Protection of H"*"**" Health and the
The selected remedy for the Site will provide a high degree of
protection of human health and the environment. For soils, the
primary remedy offers the highest degree of overall long-term
protection; likewise, the contingency remedy will be required to
provide equal protection to be implemented. The soils remedy
selection will eliminate all onsite potential exposure pathways
associated with soils. The groundwater component of the remedy
will significantly reduce contaminant levels within the aquifer.
An alternative drinking water supply has been made available to the
immediate area to include approximately 4 miles of water lines.
This action was taken under an EPA Administrative Order on Consent
in 1989. The potential for a private drinking water well to
contain levels of contaminants which exceed the maximum contaminant
levels has been substantially reduced; this potential will be
further reduced upon implementation of the groundwater extraction
system by disallowing the plume to migrate further. Surface water
remediation will eliminate all potential exposure pathways
associated with the Fire Pond and the Medlin Pond.
10 « 2 Compliance with Applica^>le or Relevant and Appropriate
Requirements
The selected remedy will be designed to meet all Federal or State
ARARs. No waivers of State or Federal requirements are anticipated
for this site.
10.3 Preference for Treatment
The selected remedy satisfies the statutory preference (established
by SARA) for remedies involving treatment which result in the
permanent reduction of the volume/ toxicity, or mobility of
hazardous substances. Thermal treatment destroys the PCDD/PCDF and
pentachlorophenol contamination, thereby eliminating the toxicity
associated with the contamination in the soil. Dechlorination, if
implemented, must destroy PCDD/PCDF and pentachlorophenol
contamination in the soils and by that destruction would
permanently reduce the toxicity and mobility associated with the
soil contamination. Mass reduction of contaminants in the
groundwater by extraction and treatment will also satisfy this
statutory preference .
10.4 Cost Effectiveness
The selected remedy provides a greater level of protection and
permanence for the soils at the site within the same relative cost
of the other technologies evaluated. If equally protective, the
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
contingency remedy will be more cost effective than the primary
remedy selection for soils. Onsite incineration may not be able to
meet the destruction and removal standard of 99.99%, which a
permitted facility operates under. A greater level of protection
and permanence causes the soil remedy selection to be cost
effective. Carbon adsorption provides treatment of both the
groundwater and surface water in a cost effective manner.
10.5 Preference of Permanent Solutions and Alternative Treatment
Technologies or Resource Technologies to the Maximum Extent
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 and the environment and comply with ARARs, EPA has
determined that the selected remedy provides that best balance of
trade-offs in terms of long-term effectiveness and permanence
reduction in toxicity, mobility and volume achieved through
treatment, short-term effectiveness, implementability , and cost,
State and community acceptance, and the statutory preference for
treatment as a principal element. State and community acceptance
of dechlorination over incineration were key factors in the
decision to utilize a treatability study to determine the
implementabilty of the contingency source control remedy.
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
CERCLA Section 117 (b) requires an explanation of any significant
changes from the preferred alternative presented in the Proposed
Plan. The EPA has selected a multi-component remedy consisting of
excavation and treatment of contaminated soils, groundwater and
surface water remediation. The major components of the remedy
identified in the Proposed Plan are identical to the description in
this Record of Decision with the exception of costs of soil
remediation, and the addition of a treatability study and a
contingency remedy for the soil contamination based on the results
of that treatability study.
Volume - Volumes were re-evaluated during public comment
period. On behalf of EPA, The University of Cincinnati
estimated the volume after excavation to be 2930 cubic yards.
Costs - Both the revised Feasibility Study and EPA independent
cost estimates reflect increased costs with increased volumes.
The cost estimates for offsite incineration increase rapidly
with increase of volume. The Feasibility Study costs for
onsite and offsite incineration were based on standard
estimates used in the industry. These costs did not
accommodate the current costs for the destruction of PCDD/PCDF
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
contamination. During public comment period, Beazer submitted
revised cost estimates which more accurately reflect current
industry standards for offsite incineration. These estimates
were developed for 1000 cubic yards and 3000 cubic yards; the
revised costs are $7.75 million and $14.4 million,
respectively. EPA also evaluated the costs during public
comment period. These independent estimates were $3.8 million
for 1000 cubic yards and $11.3 million for 3000 cubic yards.
This Record of Decision reflects Beazer's revised cost for
1000 cubic yards. However, in light of the fact that there
may be 3000 cubic yards, the final cost could increase to the
revised estimate. The range of this cost is $11.3 million
(EPA estimate) to $ 14.4 million (Beazer estimate). This
potential increase in soil volumes and costs will not affect
the selection of remedy identified in this Record of Decision.
The cost comparisons between the primary and the contingency
source control remedies are valid if dechlorination can be
shown to be effective. If the technology is not effective,
the primary remedy would be the best demonstrated available
technology and perhaps the only demonstrated available
technology for the contaminated soils. Onsite incineration
would not be considered for various reasons: the 99.99%
destruction and removal efficiency requirement may not be
obtainable for a mobile incineration unit in the destruction
of low-level PCDD/PCDF contaminated soils; a vendor may be
difficult to obtain for such small volumes; the local
community does not accept or concur with onsite incineration.
Additional major components of this final Record of Decision are
the identification of a contingency remedy and the use of a
mandatory treatability study. These components are in direct
response to the public comments received from Beazer, the state of
North Carolina and the community expressing a strong desire to
implement dechlorination especially at possible increased volumes.
Minor components were discussed at the July 23, 1992 public
meeting, but were not explicitly identified in the Proposed Plan
Fact Sheet. These minor components consist of the following items:
Groundwater Confirmation Sampling - sampling of the monitoring
wells will be conducted. Select private wells will be
included in the sampling. Methodology will be clearly
selected and approved by EPA prior to sampling commencement,
and will be required to meet all appropriate detection limits
and Level IV data quality objectives defined by the EPA. Re-
evaluation of the plume will be necessary under Remedial
Design.
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Koppers Company, Inc. Site
Morrisville, North Carolina
Record of Decision
12/23/92
Soil Excavation Confirmation Sampling - sampling of the soils
must be conducted to ensure that all soils which exceed the
cleanup standards identified for pentachlorophenol and
PCDD/PCDF, 95 ppm and 7 ppb, respectively. Confirmation
sampling will also be required of the sediments of both ponds
prior to covering with clean fill to ensure that the soil
cleanup standards are not exceeded.
A perimeter fence to enclose that area of the site property
which will require remediation will be installed. Signs
noticing the public of a Superfund Site will be posted on at
least two places on the fence, one along Koppers Road side and
one along Highway 54 side.
Additional changes may be incorporated into this Decision Document
based on any potential changes EPA deems necessary in response to
significant community or state comments.
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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
DCS G. Martin, Governor William L. Meyer
illiam W. Cobey, Jr., Secretary Director
September ' 18, 1992
Mr. Greer C. Tidwell
Regional Administrator
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Subj: Conditional Concurrence with the Draft Record of Decision
Koppers Company NFL Site
Morrisville, Wake County, NC
Dear Mr. Tidwell:
The NC Division of Solid Waste Management (DSWM) has completed
review of the attached Draft Record of Decision (ROD). However,
State review of the ROD cannot be considered complete until the NC
Division of Environmental Management (DEM) completes its review of
the ROD. Although DEM requires 5 to 6 weeks to review a ROD, they
are attempting to accelerate their schedule in this case, and, if
possible, provide comment by September 30, 1992. We will forward
any additional comments at that time. Until then, the DSWM concurs
with the selected remedy subject to the following conditions.
l. The State is listening to the concerns of the affected
community and is aware that they support on-site
dechlorination over off-site incineration for a soil remedy.
The State is also aware of EPA Region IV's recent attempts to
gather additional information from other EPA Regions and
offices about dechlorination to assess its effectiveness for
soil treatment. The State was made aware of the significant
problems with odors and handling of treated soils at an NPL
Site in Houston, TX, where the enhanced alkaline polyethylene
glycol process (APEG-Plus) was used. We have personally
discussed this failure with Region VI and agree that there are
serious questions about APEG's ability to treat clay soils.
However, because community interest in this subject is
very high and serious questions have been raised, the details
of the reassessment and how the recently gathered information
affects the decision for the Koppers Site should be a part of
An Equal Ooocxtunitv Afflimative Action Employer
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Mr. Greer C. Tidwell
18 September 1992
Page 2
the public record. Therefore, the state requests written
documentation as to Region IV s reassessment of the
dechlorination technology as it applies to the Koppers Company
Site. This would include assessment for any and all
technology, such as APEG-Plus and Base Catalyzed Decomposition
(BCD), that would have the capability of treating soils. Such
a document (which would be natural to include in the
Responsiveness Summary for the ROD) could answer some
important unanswered questions, such as, is off-site thermal
treatment still the treatment of choice after a review of the
status of dechlorination? Also, what is EPA's opinion on the
efficacy of conducting further site-specific
treatability/pilot studies of dechlcrination for the Koppers
Site? Is it feasible to include the Koppers Company Site in
EPA's Superfund Innovative Technology Evaluation (SITE)
program for testing of innovative technology?
2. On page 2 of the Declaration for the ROD, a fourth activity
describing additional monitoring requirements should be added
to the three bulleted activities presented for the groundwater
alternative. Such activity should comprise of placement of
additional monitoring wells on and off site to define the
horizontal and vertical extent of contamination and to address
the disparity between results in the existing set of
monitoring wells and private wells.
3. On page 6 of the ROD, the last sentence of the fourth
paragraph states, "The annexation requirement was maintained".
For clarity of meaning the State suggests that the sentence be
modified to read, "However, the Town of Morrisville decided to
maintain the annexation requirement."
4. On Page 78 of the ROD, Section 9.1.1, cleanup goals are
presented. The NC Environmental Epidemiology Section has
previously commented that the cleanup goal for
pentachlorophenol should be 30 mg/Kg instead of 95 mg/Kg to
maintain a 10-6 risk level. Therefore, the State asks that
EPA consider revising this goal.
5. On page 79 of the ROD, Section 9.2.1.2, it is stated that
"Groundwater shall be treated until the following maximum
concentration levels are attained at the wells designated by
EPA as compliance points." The State realizes that compliance
points may not be able to be selected at this time. However,
the general theory as to where they will be should be
discussed. The State requests that the compliance points be
selected both on and off site such that they cover the entire
plume. This will ensure that the entire plume will be reduced
to the goals and not the on site portion of the plume.
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Mr. Greer C. Tidwell
18 September 1992
Page 2
6. If State comments are not incorporated into the cleanup goals
as described above in Comment 4, the total additive residual
risk after site cleanup will exceed 10~. If, after
remediation is complete, the total residual risk level exceeds
10""6,the State may require deed recordation/restriction to
document the presence of residual contamination and possibly
limit the future use of the property as specified in NCGS
130A-310.8.
7. State concurrence on this Record of Decision and the selected
remedy for the site is based solely on the information
contained in the attached Record of Decision. Should the
State receive new or additional information which
significantly affects the conclusions or remedy selection
contained in the Record of Decision, it may modify or withdraw
this concurrence with written notice to EPA Region IV.
8. State concurrence on this Record of Decision in no way binds
the State to concur in future decisions or commits the State
to participate, financially or otherwise, in the clean up of
the site. The State reserves the right to review, comment,
and make independent assessments of all future work relating
to this site.
The State of North Carolina appreciates the opportunity to
comment on the Draft Record of Decision for the subject site, and
we look forward to working with EPA on the final remedy.
Sincerely,
Jack Butler, PE
Environmental Engineering Supervisor
Superfund Section
bin\let\koprodcn
cc: Michael Kelly
Bruce Nicholson
Curt Fehn
Barbara Benoy
Attachment
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I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
V, ^ REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 3O365
SEP 2 8 1992
4WD-NSRB
Jack Butler
North Carolina Department of Environment,
Health, and Natural Resources
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605
Re: North Carolina's Conditional Concurrence
Koppers Co., Inc. (Morrisville Plant) Superfund Site
Record of Decision
Dear Mr. Butler:
EPA-Region IV appreciates the State's conditional concurrence on
the Record of Decision (ROD) for the Koppers Co., Inc. (Morrisville
Plant) Superfund Site located in Morrisville, North Carolina. For
the record, EPA would like to respond to the conditions identified
by North Carolina Department of Environment, Health, and Natural
Resources (NCDEHNR) - Superfund Section and specified in your
September 18, 1992 correspondence to Mr. Greer Tidwell. Your
September 18, 1992 letter, along with this response, will be
included as an Appendix to the ROD. These letters should stand as
official documentation that EPA-Region IV and NCDEHNR-Superfund
Section have agreed on the preferred alternatives at this point in
time.
In response to the first condition, EPA may provide for the
inclusion of a treatability study for the dechlorination of the
contamination soils. The Superfund Innovative Technology
Evaluation (SITE) program may be involved to participate in the
analytical evaluation of the treatability study.
The second condition requested an additional bulleted item on page
2 of the Declaration clearly requiring further delineation of the
groundwater plume. This will be added. A discussion of analytical
disparity is not appropriate in the declaration; the text of the
ROD clearly requires further sampling of the monitoring system.
Any disparity or inconsistency will be resolved during the Remedial
Design.
The third condition requests a sentence to be reworded for clarity;
the sentence will be reworded as requested.
In response to the revision of the soil cleanup goal for
pentachlorophenol provided in condition number four, please refer
to EPA's response to your sixth condition.
KOP.924.NCCON -'
Printed on Recycled Paper
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Response to Conditions
North Carolina's Conditional Concurrence
Koppers Co., Inc. (Morrisville Plant) Superfund Site
Record of Decision
September 28, 1992
Page 2
In response to the fifth condition, the points of compliance for
the groundwater remediation will include the entire plume.
Of the remaining conditions expressed, only the sixth condition
requires a response from the Agency. In response to this
condition, the State may in the future put in place, pursuant to
State law (G.S. 130A-310.8), a deed recordation/restriction to
document the presence of residual contamination which may limit the
future use of the property. And, as stated, this would be done
after the completion of the Site's remediation.
Please contact me at 404/347-7791 or fascimile number 404/347-1695
if you have any questions or comments regarding this matter.
Sincerely yours,
Barbara H. Benoy
Remedial Project Manner
Waste Management Division
cc: Curt Fehn, EPA
Rick Leahy, ORC
Bruce Nicholson, NCDEHNR
KOP.924.NCCON
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