PB95-964001
EPA/ROD/R04-95/189
November 1994
EPA Superfund
Record of Decision:
National Starch & Chemical Company,
Salisbury, NC,
10/6/1994
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT #4
NATIONAL STARCH & CHEMICAL COMPANY SITE
SALISBURY, ROWAN COUNTY
NORTH CAROLINA
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u.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 1994
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DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
Chemical Starch & Chemical Company
Cedar Springs Road, Salisbury, Rowan County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Operable Unit Four Remedial Action for the National
Starch & Chemical Company Superfund Site in Salisbury, 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 Oil and Hazardous Substances Contingency Plan. This decision is
based on the Administrative Record file for this Site.
The State of North Carolina concurs with the selected remedy for Operable Unit Four. The
State's concurrence on this Record of Decision can be found in Appendix A of this document.
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. Presently, no
unacceptable current risks were identified associated with the National Starch & Chemical
Company Site. The principle threat pertains to the future and potential use of the groundwater
beneath and downgradient of the Site and the potential adverse impact contaminated soils will
have on the quality of the groundwater.
DESCRIPTION OF THE SELECTED REMEDY
This Operable Unit is the fourth and final Operable Unit for this Site. The first two
Operable Units addressed the contamination associated with the Trench Area. The third and
fourth Operable Units addressed the contamination associated with the active production area of
the National Starch & Chemical Company facility and the wastewater treatment lagoon area.
Operable Unit Three addressed the contaminated groundwater and this Operable Unit addresses
the contaminated soils.
This Operable Unit, Operable Unit #4, is a contingency remedy initially relying on natural
degradation processes to reduce the level of contaminants in the soil. In the event that natural
degradation fails to result in a significant reduction in soil concentrations within two years of the
signing of this Record of Decision, the contingency remedy will be implemented. The contingency
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remedy involves the installation of a soil vapor extraction system with an emissions control
technology such as fume incineration or activated carbon filtration or a combination of both to
control air stream discharged to the atmosphere.
The major components of the selected remedial alternative for Operable Unit #4 include:
Devise and implement a biodegradative study to substantiate that natural degradation is
occurring, identify where in the subsurface the degradation is occurring, and determine the
rate of degradation.
Implement institutional controls including deed restrictions and maintenance of both the
fence around the plant operations area and the paved areas around Area 2.
Develop and implement a long-term monitoring plan to ensure that natural degradation
continues to be effective until the specified performance standard is achieved and
maintained.
Performance of five (5) year reviews in accordance to Section 121 (c) of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 until
the cleanup goals specified in this Record of Decision are achieved.
The major components of the contingent remedial alternative include:
Volatile organic contaminants will be removed from the soils by means of a vapor
extraction systems.
Extracted contaminated air from Area 2 will initially be treated using fume incineration.
After concentrations of contaminants decrease in the extracted air, this contaminated
vapor will be treated via vapor-phase activated carbon adsorption filters prior to the air
stream being released into the atmosphere.
The extracted contaminated air from the lagoon area would be treated using vapor-phase
activated carbon adsorption filters to remove the volatile organics prior to the air stream
being released into the atmosphere.
o
The contaminants captured by the vapor-phase carbon filters would be destroyed through
the thermal regeneration of the used activated carbon at an off-site, commercial
regeneration facility.
A review/assessment would be performed in accordance to Section 121(c) of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 to
verify that the soil vapor extraction system is proceeding as anticipated or achieved the
specified cleanup goals stipulated in this Record of Decision.
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 alternative
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treatment technology to the maximum extent practicable. and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal
element. Since this remedy may result in hazardous substances remaining in the groundwater
on-site above the chemical-specific applicable requirements, 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.
Q~rn~ h
John H. Hankinson, Jr. {
Regional Administrator
OcJt"o~ G. I /'19~
Date '
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DECISION SUMMARY
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT #4
NATIONAL STARCH & CHEMICAL COMPANY SITE
SALISBURY, ROWAN COUNTY
NORTH CAROLINA
PREPARED By:
u.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 1994
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1.0 SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . . . . . . . . . .
1
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION. . .. ... . . . . .. ., . . ..,...... 5
4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY. . . . . . . . . . . 6
5.0 SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
5.1 SOILS[[[ 8
5.2 GROUNDWATER............................................... 26
5.3 SURFACE WATER AND SEDIMENT.. .. . . . . .. . .. . . . . . .. ., . ...,.. .... 27
5.4 HYDROGEOLOGICAL SETTING. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 27
6.0 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28
7.0 REMEDIAL ACTION OBJECTIVES. . . . . . . . . . . . .. . . . . . . . . . . . . . . .., . . . .,. 31
7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS........ 32
7.2 PERFORMANCE STANDARDS. .. . . . .. . . . . .. . .. . .. . . . . . . . ........,. 32
7.3 EXTENT OF CONTAMINATION. . .. . ... . .... . . . . . . . . . . . . . . .......,. 32
8.0 DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33
8.1 REMEDIAL ALTERNATIVES TO ADDRESS SOIL CONTAMINATION...... ... 33
8.1.1 ALTERNATIVE S 1: No ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33
8.1.2 ALTERNATIVE S2: NATURAL DEGRADATION AND INSTITUTIONAL
CONTROLS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 38
8.1 .3 ALTERNATIVE S3: SOIL VAPOR EXTRACTION WITH FUME
INCINERATION AND ACTIVATED CARBON FILTER
TO CONTROL EMISSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 40
8.1.4 ALTERNATIVE S4: SOIL VAPOR EXTRACTION WITH ACTIVATED
CARBON FILTER TO CONTROL EMISSIONS. . . . . . . . . . . . . . . . . . . . . . . . .. 41
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . ..., . .. ... 41
9.1 THRESHOLD CRITERIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .., . . . . .. 41
9.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 45
9.1.2 COMPLIANCE WITH APPLICABLE OR RELEVANT
AND APPROPRIATE REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . .. 45
9.2 PRIMARY BALANCING CRITERIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 46
9.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE. . . . . . . . . . . . .. 46
9.2.2 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME. . . . . . . . . . . . .. 46
9.2.3 SHORT-TERM EFFECTIVENESS '............................. 47
9.2.4 IMPLEMENTABILITY ...................................... 47
9.2.5 COST.................................................. 47
9.3 MODIFYING CRITERIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 48
9.3.1 STATE OF NORTH CAROLINA ACCEPTANCE. . . . . . . .. ... . . . . ... 48
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10.0 DESCRIPTION OF THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . " 48
10.1 PERFORMANCE STANDARDS TO BE ATTAINED. . . .. .. ... . . . . . .. . " 50
10.2 SOIL REMEDIATION. '" . . ... ... .... . . . . . . . . . .... .. . . . . . . ..... 50
10.3 BIODEGRADATION STUDY... .... '" . . . .. . .. . . .. .. .. . . . . . . .. '" 50
1 0.4 COST[[[ 50
11.0 STATUTORY DETERMINATION. ....... .. .. . . .. '" . . .. .. . . . . . . . .... .. 51
11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT. .. ........ 51
11.2 COMPLIANCE WITH ARARS .................................... 51
11.3 COST-EFFECTIVENESS....................................... 51
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE TECHNOLOGIES
TO THE MAXIMUM EXTENT PRACTICABLE..... . ... . .. .. . .. ..... .. 51
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT. . . . . . . . .. 52
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APPENDICES
APPENDIX A CONCURRENCE LETTER FROM THE STATE OF NORTH CAROLINA AND
RESPONSE FROM THE AGENCY
APPENDIX B PROPOSED PLAN FACT SHEET
APPENDIX C RESPONSIVENESS SUMMARY
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LIST OF FIGURES
FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
FIGURE 8
FIGURE 9
FIGURE 10
FIGURE 11
FIGURE 12
FIGURE
PAGE No.
TITLE
SITE LOCATION MAp . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
LOCATION OF FACILITIES THAT COMPRISE OPERABLE UNIT #4 . . . . . . . . . . . .. 3
LOCATION OF SOIL SAMPLES COLLECTED FROM PARKING LOT. . . . . . . . . . . .. 11
CONCENTRATIONS AND EXTENT OF 1,2-DICHLOROETHANE
CONTAMINATION IN THE SOIL IN AREA 2 . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
SOIL CROSS SECTION LOCATION MAp ............................. 15
SOIL PROFILE A-A' WITH 1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT AREA 2 .......................................... 16
SOIL PROFILE 8-8' WITH 1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT AREA 2 .......................................... 17
CONCENTRATIONS AND ESTIMATED EXTENT OF 1,2-DICHLOROETHANE
CONTAMINATION IN THE SOILS AT THE WASTEWATER TREATMENT
LAGOON AREA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18
SOIL PROFILE 8-B' WITH 1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT THE WASTEWATER TREATMENT LAGOON AREA. . . . . . . . . . . . . .. 19
DISTRIBUTION OF ACETONE IN SOILS IN AREA 2 AND THE .
WASTEWATER TREATMENT LAGOON AREA. . . . . . . .. . . . . . . . .. . . . . . . . .. 20
BEDROCK STRUCTURAL CONTOUR MAp SHOWING CROSS SECTION
LOCATION A-A' ..........................................,.. 29
HYDROGEOLOGICAL CROSS-SECTION A-A' . . . . . . . . . . . . . . . . . . . . . . . . . .. 30
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LIST OF TABLES
TABLE 1
TABLE 2
TABLE 3
TABLE 4
TABLE 5
TABLE 6
TABLE 7
TABLE
PAGE No.
TITLE
RANGE AND FREQUENCY OF DETECTION OF ORGANIC
CONTAMINANTS AND INORGANIC CONSTITUENTS FOUND IN THE
ENVIRONMENTAL MEDIA SAMPLED. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
VOLATILE ORGANIC COMPOUNDS IN AREA 2 SOILS. . . . . . . . . . . . . . . . . . . . .. 21
VOLATILE ORGANIC COMPOUNDS IN SOIL SAMPLES FROM
WASTEWATER TREATMENT LAGOON AREA. . . . . . . . . .. . . . . . . . . . . . . .. . .. 23
CONCENTRATIONS OF INORGANIC ANALYTES IN SOIL
CONTAMINATION CHARACTERIZATION SAMPLES. . . . . . . . . . . . . . . . . . . . . . . .. 25
ApPLICABLE OR RELEVANT AND ApPROPRIATE REQUIREMENTS. . . . . . . . . . . . .. 34
INITIAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS
FOR SOIL REMEDIATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 42
SECONDARY/FINAL SCREENING OF TECHNOLOGIES AND PROCESS
OPTIONS FOR SOIL REMEDIATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 44
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LIST OF ACRONYMS
AOC
ARAR
CERClA
CD
DNAPl
1,2-DCA
e.g.
EPA
FS
tVday
tVyr
HRS
Le.
MCls
mg/kg
NCAC
NCDEHNR -
NCP
ND
NPDES
NPl
NSC
NSCC
O&M
OU
BCPs
ppb
ppm
PRP
PW
RA
RCRA
RD
RD/RA
RI
RI/FS
ROD
SARA
SVOCs
TAL
TBC
TCl
TClP
TMV
UAO
~g/kg
~g/l
VOCs
Administrative Order on Consent
Applicable or Relevant and Appropriate Federal, State or local
Requirements
Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (Superfund)
Consent Decree
Dense Nonaqueous Phase Liquid
1,2-Dichloroethane
for example
Environmental Protection Agency
Feasibility Study
Feet per day
Feet per year
Hazardous Ranking System
that is
Maximum Contaminant Levels
milligrams per kilogram
North Carolina Administrative Code
North Carolina Department of Environment, Health, and Natural Resources
National Oil and Hazardous Substances Pollution Contingency Plan
Not Detected
National Pollution Discharge Elimination System
National Priority List
National Starch & Chemical Company
National Starch & Chemical Company
Operation and Maintenance
Operable Unit
Polychlorinated Biphenyls
parts per billion
parts per million
Potentially Responsible Party
Present Worth
Remedial Action
Resource Conservation and Recovery Act
Remedial Design
Remedial Design/Remedial Action
Remedial Investigation
Remedial Investigation/Feasibility Study
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
Semi-volatile Organic Compounds
Target Analyte List
To Be Considered
Target Compound List
Toxicity Characteristic Leaching Procedure
Toxicity, Mobility, or Volume
Unilateral Administrative Order
micrograms per kilogram
micrograms per liter
Volatile Organic Compounds
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT FOUR
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
SALISBURY, ROWAN COUNTY, NORTH CAROLINA
1.0 SITE NAME. LOCATION. AND DESCRIPTION
The National Starch & Chemical Company Site (NSCC Site or the "Site") is located on
Cedar Springs Road in Salisbury, Rowan County, North Carolina. The Site is approximately 5
miles south of the City of Salisbury at latitude 35°37'49" north and longitude 80°32'03" west.
Figure 1 shows the location of the Site with respect to the City of Salisbury. The areas of the
Site that compose Operable Unit (OU) #4 are shown in Figure 2. au #4 includes the
following areas of the NSCC facility: Area 2, the parking lot, and the wastewater treatment
lagoons. Area 2 consists of the following operations: Area 2 Reactor Room, the Tank Room,
Raw Material Bulk Storage, and the Warehouse. The lagoon area includes three lagoons
which were constructed between 1969-1970 as unlined lagoons. Wastewater was pumped
into Lagoon 2 from 1970 to 1978. In 1978, Lagoon 1 was put into service and Lagoon 3 was
lined with concrete. Lagoons 1 and 2 were originally used as settling and evaporation
lagoons. In 1984, Lagoons 1 and 2 were excavated and also lined with concrete.
Contaminated soil excavated from beneath the lagoons was removed and disposed of in an
area west of the plant area. The saturated soil was landfarmed and then used as fill material
for expanding the facility's parking lot. A fourth .Iagoon was installed in 1992 as part of the
treatment system to treat the contaminated groundwater generated by the OU #1 Remedial
Action (RA). In the remainder of this Record of Decision (ROD), the term "Site" refers to the
areas investigated as part of OU #4 (i.e., Area 2 and the wastewater treatment lagoon area)
unless otherwise specified.
Land use of the areas immediately adjacent to the NSCC property is a mixture of
residential and industrial developments. An industrial park is located on the east and south
sides of the NSCC facility. Another industrial park is located along the southern property line.
A mobile home park adjoins the extreme southwestern comer of the property. Two housing
developments lay to the north, one of which is adjacent to the facility property. The location of
the nearest private, potable wells is approximately 2,700 feet north of Area #2.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
In September 1968, Proctor Chemical Company purchased the 465-acre tract of land on
Cedar Springs Road. Within the next year, Proctor Chemical was acquired by NSCC which
operated the facility as a separate subsidiary. Construction of the plant on Cedar Springs
Road began in 1970. On January 1,1983, Proctor Chemical Company was dissolved and its
operations merged with NSCC.
The primary products of this facility are textile-finishing chemicals and custom specialty
chemicals. Volatile and semi-volatile organic chemicals are used in the production process
along with acidic and alkaline solutions. Acidic and alkaline solutions are also used in the
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FIGURE 1
LOCATION OF THE NATIONAL STARCH &
CHEMICAL COMPANY SUPERFUND SITE
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NA11ONAI. SrARal & CHBIICAl CoMPANY SUPERRJHD SITE
REOORD OF DEaSON FOR OPERASLE UNIT 14
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cleaning processes. The liquid waste stream from the manufacturing processes include
reactor and feed line wash and rinse solutions. This wastewater may include a combination of
the following chemicals: acrylimide, 1,2-dichloroethane (1,2-DCA), methyl isobutyl ketone,
methanol, styrene, maleic anhydride, vinyl toluene, sulphonated polystyrene, epichlorohydrin,
oetyl alcohol, ethyl alcohol, allyl alcohol, allyl chloride, sodium hydroxide, and sulfuric acid.
As the result of finding contaminants in groundwater and in the surface water/sediment
of the Northeast Tributary, the original scope of work specified in the initial 1987 Remedial
Investigation/Feasibility Study (RI/FS) Work Plan was expanded. The first RI/FS resulted in
OU #1 ROD which was issued by the Environmental Protection Agency (EPA or Agency) on
September 30, 1988. The OU #1 ROD divided the Site into two Operable Units. The ROD
for OU #1 required the installation of a groundwater interception, extraction, and treatment
system in the western portion of the facility. The contaminants in the groundwater in this area
are emanating from the trench area. OU #2 further investigated the contaminated soils in the
trench area along with additional monitoring of the surrounding tributaries. OU #2 ROD was
signed on September 28, 1990 and required additional work to identify, characterize, and
delineate the contamination being continuously detected in the Northeast Tributary. This
investigation resulted in the development of OU #3 and OU #4. OU #3 ROD was signed on
October 7, 1993 and required a more thorough evaluation of alternatives to address the soil
contamination in Area 2 and the wastewater treatment lagoon area (i.e., OU #4).
The NSCC Superfund Site was proposed for inclusion on the National Priorities List
(NPL) in April 1985, re-proposed in June 1988, and finalized on the list in October 1989 with a
Hazardous Ranking System (HRS) score of 46.51. The HRS score was based on the
following exposure route scores: exposure via groundwater pathway - 80.46, exposure via
. surface water pathway - 0.00, and exposure via air pathway - 0.00. Currently, the Site is
cataloged as Number 257 of the 1,249 Superfund sites across the country on the NPL.
Since there has only been one owner/operator of this property after being developed
into an industrial complex, no "Responsible Party Search" was performed. National Chemical
Starch & Chemical Company has been and remains the owner/operator of the facility. A
special notice letter was sent on May 30, 1986 to provide NSCC an opportunity to conduct the
first RI/FS. A good faith offer was submitted and negotiations were concluded with NSCC
signing an Administrative Order on Consent (AOC) on December 1, 1986. NSCC, the
Potentially Responsible Party (PRP), has performed OU #1, OU #2, OU #3, and OU #4 under
the direction and requirements specified in the December 1986 AOC.
The first RI/FS was completed on June 21, 1988 and September 8, 1988, respectively.
Following the signing of OU #1 ROD, the Agency sent a special notice letter to the PRP to
initiate negotiations on a Consent Decree (CD) for implementing the OU #1 Remedial
Design/Remedial Action (RD/RA). However, negotiations on the CD were not successful
resulting in the Agency issuing an Unilateral Administrative Order (UAO) directing NSCC to
design and implement the RA specified in the OU #1 ROD. The effective date of the UAO
was July 27, 1989. To date, NSCC is in compliance with the requirements of the July 1989
UAO.
In support of OU #2, NSCC generated Supplemental RI and Feasibility Study (FS)
Reports. These reports were prepared in accordance to the December 1, 1986 AOe. These
reports were completed in May 1990 and September 1990, respectively. The Supplemental
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NA'!1ONAL STARQt & CIIaIICAl COWPAHY SUPeRRniD Sm;
REcoRD OF DEOSION FOR OPERABl£ UNIT 14
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RI reported continued detections of contaminants in the' Northeast Tributary but did not identify
the source of this contamination. Consequently, the OU #2 ROD divided the Site into a third
operable unit. Following the signing of the OU #2 ROD, the Agency sent the PRP another
special notice letter in March 1991 to initiate negotiations on a second CD. This CD govemed
the implementation of the OU #2 RA. The CD was signed in August 1991 and was entered by
the Federal Court on July 20, 1992.
On December 4, 1991, EP A issued written notification to NSCC to conduct a third RIIFS
to determine the source, nature, and extent of contamination entering the Northeast Tributary
as required by OU #2 ROD. As with the previous RifFS efforts, the OU #3 RifFS was
conducted in accordance to the December 1, 1986 AOC. The OU #3 RI and FS reports were
completed on June 2, 1993 and June 21, 1993, respectively. Due to an inadequate
evaluation of source control remediation alternatives in the OU #3 FS document, the Agency
decided to split the groundwater and source control efforts into OU #3 and OU #4,
respectively. The OU #3 ROD was signed on October 7, 1993 and required a fourth operable
unit. On October 12, 1993, EPA requested NSCC to initiate OU #4 in accordance to the
December 1986 AOC. Since only the evaluation of the source control remediation alternatives
was in question, the June 1993 OU #3 RI sufficed as the OU #4 RI report. The June 20,
1994 OU #4 FS was conditionally approved by the Agency on July 8, 1994. NSCC will be
provided an opportunity to conduct the OU #3 and OU #4 RDfRA as specified in this ROD and
OU #3 ROD through the issuance of a third RDfRA special notice letter.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
In 1986, community relations activities for this Site were initiated in conjunction with the
development of the RifFS Work Plan. In developing the August 1986 Community Relations
Plan, the issues and concerns expressed by local citizens from the Site area were compiled
and an overview of these issues and concerns was prepared. A copy of the Community
Relations Plan was placed in the Information Repository located at the Rowan County Public
Library in Salisbury. A mailing list was developed based upon people interviewed, citizens
living around the Site, and people attending Site related public meetings. The mailing list also
includes local, State, and Federal public servants and elected officials.
Numerous fact sheets were mailed and several public meetings were held with respect
to OU #1, OU #2, OU #3, and OU #4. The following community relations activities were
conducted by the Agency with respect to OU #4.
The public was informed through the Proposed Plan Fact Sheet and an ad published on
July 12, 1994 in The Salisbury Post newspaper of the July 26,1994 Proposed Plan Public
Meeting. The Proposed Plan Fact Sheet was mailed to the public on July 8, 1994. The basis
of the information presented in the Proposed Plan was the June 1994 OU #4 FS document.
The Proposed Plan also informed the public that the public comment period would run from
July 12, 1994 to August 11, 1994.
Prior to the Proposed Plan Public Meeting, representatives from EPA met with City and
County officials to present to them a summary of information to be shared with the public
during the evening public meeting. This meeting also provided locally elected officials the
opportunity to ask questions and make comments concerning the Agency's proposed
activities.
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NAT10NAl STARai & CHBlICAI. CoMPANY 5uPeRFIJND SITE
REcoRD OF DroSlON FOR OPERABl£ UNIT 14
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The goals of the Proposed Plan meeting were to review the remedial alternatives
developed, identify the Agency's preferred alternative, present the Agency's rationale for the
selection of this alternative, encourage the public to voice its own opinion with respect to the
remedial alternatives reviewed and the remedial alternative selected by the Agency, and
inform the public that the public comment period on the Proposed Plan would conclude on
August 11, 1994. The public was also informed a 30 day extension to the public comment
period could be requested and that all comments received during the public comment period
would be addressed in the Responsiveness Summary.
After the Proposed Plan public meeting, the Agency received a request for a 30-day
extension to the public comment period which extended the public comment period to
midnight September 9, 1994. A notice was mailed on August 9, 1994 to the addressees on
the mailing list informing them of this extension. An ad was also published in the August 11,
1994 edition of The Salisbury Post newspaper informing the public that the public comment
period had been extended to September 9, 1994.
Pursuant to Section 113(k){2)(B)(i-v} and 117 of Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), all documents associated with
the development of the Proposed Plan and the selection of the remedial alternative specified
in this ROD were made available to the public in the Administrative Record located both in the
Information Repository maintained at the EPA Docket Room in Region IV's office and at the
Rowan County Public Library in Salisbury, North Carolina. A copy of all literature distributed
at each public meeting, as well as a transcript of meeting proceedings, were also placed in
the Information Repositories.
4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
As with many Superfund sites, the problems at the NSCC Site are complex. As a result,
EPA organized the work into four operable units. These are:
OU #1 -- Groundwater in western portion of the NSCC property
OU #2 -- Trench Area soils and surface water/sediments in the Northeast Tributary
OU #3 -- Groundwater under Area 2, the parking lot, and the wastewater treatment
lagoons and the surface water/sediments in the Northeast Tributary
OU #4 -- Contaminated soils in and around Area 2 and the wastewater treatment
lagoons.
This ROD has been prepared to summarize the remedial selection process and to
present the selected remedial alternative for the contaminated soils in and around Area 2 and
the wastewater treatment lagoons. Although neither surface nor subsurface soils pose an
unacceptable current risk to the public health, there are unacceptable future risks due the
concentration of chemicals found in the soils associated with OU #4. Based on a comparison
between the target compound list (TCL) analytical results for 1,2-DCA in soil to the
corresponding toxicity characteristic leachate procedure (TCLP) concentration by using a least
squares linear regression on the data, it was hypothesized that the current concentration of
-------
NATIONAl. STARQj & CHalICAL COUPAH'f SuPERRnm SITE
REcoRD OF DeaSlON FOR OPERABlE UHTT 14
-7-
1,2-DCA in the soils could adversely impact the underlying groundwater above the
performance standard presented in the OU #3 ROD which 1 microgram per liter (~gll) or 1
part per billion (ppb).
EPA has already selected remedies for OU #1, OU #2, and au #3. Construction on the
OU #1 remedial action phase began in August 1990. OU #2 was initiated on July 20, 1992,
the filing date for the CD. OU #2 ROD specified no action for the soils in the Trench Area,
long-term monitoring of the soils in the Trench Area, and an investigation to determine the
source of contamination being detected in the Northeast Tributary. The Agency will combine
negotiations for performing the RD/RA for OU #3 and OU #4 with NSCC.
The purpose of this response is to prevent current or future exposure to the
contaminated soils. OU #4 is the final operable unit for this Site.
5.0 SUMMARY OF SITE CHARACTERISTICS
The NSCC OU #4 RIIFS is complete. The June 2, 1993 RI report, conditionally
approved by the Agency on July 7, 1993, identified the sources, characterized the nature, and
defined the probable extent of the uncontrolled hazardous wastes in the soil, groundwater,
and surface water/sediment in the areas addressed by this Operable Unit. The June 1993 AI
report included the Baseline Risk Assessment. The Baseline Risk Assessment defined the
risk posed by the hazardous contaminants present in the areas investigated. The Proposed
Plan Fact Sheet, based on the June 20, 1994 OU #4 FS document, provided the public with a
summary of the detailed analysis of the four (4) soil remediation alternatives.
The overall nature and extent of contamination associated with this area of the Site is
based upon analytical results of environmental samples collected from surface and subsurface
soils, the groundwater, surface water and sediment of the Northeast Tributary, and the
chemical/physical and geologicallhydrogeological characteristics of the area. Environmental
samples were collected over a period of time and activities. The majority of the samples
collected were screened for volatile organic compounds (VOCs) as the previous Remedial
Investigations conducted at the NSCC facility identified VOCs as the primary contaminants at
the Site. A review of the historical use of chemicals in the manufacturing processes at the
Site also supports this appraisal. The remainder of the samples were analyzed for the entire
TCl and target analyte list (TAL) constituents. The TCl includes VOCs, semi-volatile organic
compounds (SVOCs), pesticides, and polychlorinated biphenyls (PCBs); the TAL includes
inorganics such as metals and cyanide.
VOCs, SVOCs, one pesticide, and numerous inorganic analytes were detected in the
soils and groundwater and two VOCs and a number of metals were detected in the surface
water/sediment samples. Detailed discussions on groundwater and surface water/sediment
were provided in the OU #3 ROD.
Background/control samples were collected for groundwater and surface water and
sediment. No background surface or subsurface soil samples were collected, therefore, any
organic contaminant detected in the soils that could not be attributed to cross contamination,
was presumed to be a Site related contaminant. The inorganic analytical results for the
upgradient sediment sample collected from the Northeast Tributary was used to portray
-------
NATIONAl. STARO! & CHBlICAI. CalPANY SUP£RRJND SITE
REcoRD OF DeaSlON FOR OPERABlE UNIT t4
-8-
background conditions for evaluating inorganics detected in surface and subsurface soil
samples.
Table 1 lists the contaminants detected in each environmental medium sampled as well
as the frequency and range of concentrations detected. As can be seen, no PCBs were
detected in any of the environmental samples collected. The pesticide detected at the Site
was delta-hexachlorocyclohexane (delta-BHC). It was detected once in the soil and once in
the groundwater at very low concentrations. Pesticides have never been manufactured at this
facility. Cyanide was detected twice in the soil and twice in the groundwater. The
concentration of delta-BHC is below health base clean up goals. Based on the above
information, the following contaminants or group of contaminants will not be discussed in the
following sections: PCBs and pesticides. The following sections discuss the results and
interpretations of the data collected and generated for each environmental medium
investigated as presented in the June 1993 RI report.
Air samples were not collected, however, the air was monitored during the RI field work
as part of the field health and safety effort. Based of the information collected, the quality of
the air at and around the Site is not currently being adversely impacted by the Site. The PRP
also runs routine air sampling in the active portions of the facility as part of their internal,
corporate health and safety procedures.
5.1 SOILS
A total of 107 soil samples were collected to identify the source, characterize the
contaminants present, and delineate the extent of soil contamination. These soil samples
were collected in 59 different locations in the following three areas of the Site: the parking lot,
Area 2, and the wastewater treatment lagoon area. These soil samples included 11 surface
soil samples (0 to 2 feet below the surface) with the rest being collected between 2 feet below
surface to either the water table interface or auger refusal.
A total of 14 different vecs, one (1) svec, one (1) pesticide, 14 metals, and cyanide
were detected. As can be seen in Table 1, the vecs most frequently detected and observed
in the highest concentrations were acetone, 2-butanone, chloroform, 1,2-DCA, toluene, and
vinyl chloride (listed alphabetically). A variety of inorganic analytes were also detected in the
soils. Although these inorganic analytes occur naturally in soil, elevated concentrations of
cyanide and eight (8) metals were detected. The following metals were either detected in
onsite soils but not in the background sample or detected onsite at concentrations at least two
times greater than the background concentration: barium, chromium, cobalt, copper,
manganese, nickel, thallium, and vanadium.
As stated earlier, the landfarmed saturated soils from the wastewater treatment lagoon
area was used as fill material in the expansion of the parking lot. Prior to placement of this
soil in 1988, the soil was sampled and analyzed. The concentration of 1,2-DCA in the sample
collected was 533 ppb. Figure 3 provides the location of the two soil samples collected in the
parking lot area in June 1992 as part of the RI. The concentrations of 1 ,2-DCA were 220 ppb
and 370 ppb in samples PLS-1 and PLS-2. respectively. Six (6) other vecs were detected in
these two soil samples.
-------
NAroNAl STAR()I 8. CHalx:Al COIAPAH'f SUPERRINt> SITE
REcoRD Of DeaSON FOR OPEP.ABI.E UNIT "
-9-
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS FOUND IN THE ENVI RONMENT AL MEDIA SAMPLED
COMPO UN D SOIL G ROUN DWATE R SU R FACE SEDIMENT
WATER
Acetone 22-4,000 (40) 9-4,200 (15) 18-52 (3) 12-63 (7)
Bis(2 -chloroethyl)ether 13-32 (2)
Bromodichloromethane 1 -220 (7) 1 (1 )
2-Butanone 3-42 (30)
Carbon Disulfide 4.8 (3)
Chloroethane 3-35 (6)
Chloroform 2-900 (1 7) 7-8,900 (2)
Dibromochloromethane 3-31 (5)
1 ,2-Dichloroethane 2-1 ,600,000 (42) 1-660,000 (30) 2-3.200 (7) 9-1 ,000 (5)
1 ,1 -Dichloroethene 1 -1 4 (3)
1 ,2-Dichloroethene 1-200 (4)
1 ,2-Dichloropropane 5 (1 )
Ethylbenzene 9-36 (2)
Methylene Chloride 1 -160 (5)
T etrachloroethene 2 (1 ) 1 07 (4)
Toluene 1 -3,1 00 (1 2) 1 -120 (3)
1 ,1 ,2- Trichloroethane 1 -3 (4)
Trichloroethene 1 1 -1 7 (2) 1 -5 (1 0)
Total Xylenes 1 (1) 2-90 (4)
Vinyl Chloride 32-1 90 (12) 1-1 20 (8)
Bis(2 -ethylhexyl) phthalate 8 (1)
Di-n-butyl Phthalate 2-1 7 (3)
Di-n~ctyI Phthalate 2 (1 )
-------
NA'!IONAl STARD\ & C11B11CAL COMPANY SUPERFUIID SITE
FIEaJRD OF DeaSlON FOR OPEIIABlE UNIT 14
-10-
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS FOUND IN THE ENVIRONMENTAL MEDIA SAMPLED
COMPOUND SOIL GROUNDWATER SURFACE SEDIMENT
WATER
Delta-Hexachlorocyclohexane 22 (1) 0.16 (1)
Antimony 5,100-8,2000 (5) 2-30 (3) 7,600 (1)
Arsenic 530-2,900 (7) 2.4 (1) 1,100-1,900 (2)
Barium 33,300-198,000 (7) 28.2-737 (8) 32.1-38.2 (2) 50,300-88,400 (2)
Beryllium 240-680 (7) 1-2.5 (2) 490-980 (2)
Chromium 10,000-97,900 (7) 12.9-59.6 (6) 35,100-36,500 (2)
Cobalt 13,700-74,100 (7) 47-66.4 (2) 23,600-28,000 (2)
Copper 46,700-161,000 (7) 12.4-23.7 (2) 48,400-90,300 (2)
Cyanide 2,500-21 ,900 (2) 12-16 (2) NA
Lead 1,300-9,400 (7) 3.3-3.9 (2) 3,000-15,100 (2)
Manganese 382,000-2,610,000 (7) 1.5-12,000,000 (14) 60-134 (2) 162-1,020,000 (2)
Mercury 50-50 (2)
Nickel 4,900-22,900 (7) 23.4-39.6 (3) 10,300-11,600 (2)
Selenium 880
Thallium 2,500 (1) 1-3 (2) 380
Vanadium 71,600-379,000 (7) 10.7-272 (1 1) 14.8-24.4 (2) 146,000-176,000 (2)
Zinc 19,700-50,000 (7) 22.6,410,000 (4) 10.3-1 1.4 (2) 23,900-48,500 (2)
Concentrations for water samples are reported in micrograms per I~er (~II) or in parts per billion (Ppb).
Concentrations for soiVsediment samples are reported in micrograms per kilogram (J,1gA
-------
,', '. '/..............""""""'.""1 .':" AREA 2 ......--!
, ~ . ~ :: . . :
. ,,'. ! . I' . . . :
:: . ! -: ! :::-. :~:~:~:::. . . :
.~~ i:i ." :
! :'. .t, ,.' I
.........--------" DRIVEWAY i - -!-"- ,. I.... ..............-.......
. ---.1 ,--..""."""" ....-....----.
"'...... --.. - _0- -0. -." -... --. ...._-- --.... _0 .---- -- ".--- ----- -___eo. '0- .0.-..0 - 0° - - .-.0.. - \ ~::::::::::::: :
I PARKING :
I AREA :
t :
r. AMMONIA BURNINO SHED:
f: I
il '
:1 I
H PLS.1:o
., I
j' 'uuu_------------
pLS-2 0
"~~ II
E .350
I
E.5O
LEGEND
WA9TE.WATERCOllECTION PIT
N.35O -
:,:
"";:.',.., ~--- --- - ~Jo~'oo;;;;: ,;;; '1:==:==:=; ~_.-~.W_~ M
.
SOIl BORING LOCATION
l
WASTE.WA TER LINE. ARROW INDICA TES
DlREC110N OF ROW
ABANDONED LINE
LAGOON 2
LAGOON 1
N .650 L
E .650
FIGURE 3
LOCATIONS OF SOIL SAMPLES
COLLECTED FROM PARKING LOT
APPROXIMATE SCALE (ft) .
~~---
o 100 200
300
400
I
500
-------
NATIONAl. STARaI & CHEMICAl. CouPANY SUPERRJNO SITE
REa>Ro OF DEaSlON FOR OPERABlE UNIT t4
-12-
The objective of investigating the vadose zone in Area 2 and the wastewater treatment
lagoon area was to establish the lateral and vertical extent of soil contamination, the location
of the highest levels of 1,2-DCA in the soils, and to estimate the mass of contaminants
present in the soils. Figures 4 through 9 show the lateral and vertical distribution of 1,2-DCA,
the location of the sampling points as well as the highest concentration of 1 ,2-DCA detected in
each boring, and the depth this sample was collected.
Contamination of soil by 1,2-DCA is most extensive around Area 2. The lateral extent of
soil contamination in this area is shown in Figure 4. In Area 2, there are two areas where soil
contamination is concentrated:
along an elongated area northwest of the main plant and
in a broad area northeast of the loading docks and warehouse area.
Cross-section lines A-A' and 8-8' shown in Figure 5 illustrate the locations of vertical
contamination profiles at Area 2. Figures 6 and 7 show the vertical distribution of 1,2-DCA in
soils at Area 2 along cross-sections A-A' and 8-8', respectively. Unsaturated soils at Area 2
exhibited a pattern of 1,2-DCA concentrations decreasing downward. The distribution pattem
of 1 ,2-DCA at Area 2 is that which would be expected from leaking pipes; concentrations
comparatively high in soils near the ground surface, and decreasing downward. This type of
pattern is very well developed along the soil profile 8:8'. Soils at Area 2 are capped by
concrete and asphalt surfaces; therefore, recharge or infiltration through the soil at this
location is extremely restricted. The analytical data for the samples collected to evaluate Area
2 is presented in Table 2.
In the area around the wastewater treatment lagoons, 1,2-DCA contamination in soil is
much less widespread. The lateral extent of contamination in this area is shown in Figure 8.
The orientation of cross-section C-C' is shown in Figure 5. Figure 9 shows the vertical .
distribution of 1,2-DCA in soils at the wastewater treatment lagoons. Where unsaturated soils
exhibit 1,2-DCA concentrations, the levels either increase downward towards the water table
or exhibit non-detectable levels until the water table is reached. The highest levels are found
in soils near the northeast comer of Lagoon 2 (Figure 8) just above the water table. The
analytical data for the samples collected to evaluate the soils in wastewater treatment lagoon
area is presented in Table 3.
The vertical soil contamination pattern found in the soils at the wastewater treatment
lagoon area is in stark contrast to the pattern observed in the profile for Area 2. The soil
contamination profiles of Area 2 and the wastewater treatment lagoon area indicate that the
concentrations of contaminants in the soils in the vadose zone at the wastewater treatment
lagoon area are decreasing. This reduction is due the infiltration of precipitation flushing the
contaminants downward; whereas, the impervious surfaces in Area 2 effectively prevent the
infiltration of precipitation and thereby eliminate this flushing action.
Acetone is also widely distributed in the soils around Area 2 and the wastewater
treatment lagoon area as can be seen in Figure 10. Around the wastewater treatment lagoon
area, the distribution of acetone in soil appears to be very similar to the distribution pattern of
1,2-DCA in the soil. However, the same cannot be said for the distribution of acetone in Area
2. In Area 2, no distribution pattern is evident.
-------
NATIONAl. STARCH & CHancAI. CalPNI'f SuPERfUHDSITE
REcoRD Of DEaSION RJR OPERABlE UNIT 14
-13-
Table 4 presents the analytical data for the samples analyzed for SVOCs, pesticides,
and inorganics. This table also presents the analytical data for sample SE-13 which was used
to define the background conditions for inorganics. All metals detected are naturally occurring
for this area. Metals do not present an unacceptable risk.
In general, the greatest concentrations of organic contaminants were found in two (2)
areas. In the soils underneath Area 2 and north-northeast of the lagoon area. The majority of
the elevated levels of metals were detected in Area 2. Based on the information generated.
and collected as part of the RI, the following sources of contamination have been identified.
In Area 2, two sources of contamination were identified: the buried, terra-cotta (fired-clay)
pipeline and a solvent recovery system (distillation unit). The underground terra-cotta pipeline
transported wastewater from the production area to the wastewater treatment lagoons. In
February 1994, NSCC completed the replacement of the terra-cotta pipeline with an overhead
stainless steel pipeline, therefore, the terra-cotta pipeline is no longer in use. The solvent
recovery system now sits on a bermed, concrete platform so that any spills associated with
the operation of this system are controlled and not released into the environment
NSCC has also controlled surface water runoff from Area 2 through the use of berms
and sumps. The berms and the grade of the paved surfaces direct the surface runoff into the
sumps. The surface water runoff collects in the sumps and is then pumped through above
ground pipes to the wastewater treatment lagoons.
In the lagoon area, the source of contamination was eliminated in 1984 when NSCC
lined its lagoons with concrete. The contamination currently being detected in the soils and
groundwater in this area is the result of past practices and the residual contamination in the
soil.
The only additional field work conducted to support the au #4 FS focused on
addressing the concern that 1,2-DCA may exist as a dense nonaqueous phase liquid (DNAPL)
or as a residual DNAPL in the soils. In September 1993, six soil samples were tested using a
hydrophobic dye. The soil samples were collected from the area of the Site containing the
highest soil concentrations of 1,2-DCA identified in the June 1993 RI report. The result of the
hydrophobic dye test on these six soil samples indicate that 1,2-DCA does not exist as a free
liquid in the soils at the Site. These six samples were also chemically analyzed. The data is
present below:
Sample
Depth Sample
Was collected
Concentration
of 1,2-DCA
microarams per kilooram CI.lO/ko)
20A-6-8
20A-8-10
20A-10-12
20A-14-16
20A-18-20
6-8 feet
8-10 feet
10-12 feet
14-16 feet
18-20 feet
190,000
60,000
95,000
4,300
27,000
-------
,- oo noon 00-- _00 00 oonoo_S~~L/;/~~4;!~). SBA213 S~i75 ,,\ -
: :"'------'-----------_h__--.__- i': ..._...:", "" NO. ,. ..SBA2-ia,
, ' -----; ,.~_,_n,~:nn, ',' " ""'", SBA2.14 " .11540(35\'
t : I I, '. ! L ". ". ND ' . 'J ..
: : : :1 / :SBA2-19 : ", """" -..IIL....-"-"- ..,.' \, ...
: : : ij : ,1400(17 5) ~ "" "'..-.--....,..." ,'''-'''' ., \
i ! SBA2.11 i.~ /.:;~.;,,'''~'':'r::1:::::,:'.. """""",,,,,,,,,--,,""" "" \ !
: : 3J(5,5) i III Ii SBA2.20 ~ ! \ SBA2.0B SBA2.06 I I
i 1 i !:h1600000(5,5).m..:'--L!~~.~~1::~)n..-,--:::~~_~S,5)..." \ I!
: I : I: \ \', I " . i .' .. ""'.. ~ : !
: : : \ \'-.... i r' n -~.. SBA2.09' -:.:1.:.s: SBA2.Q4 SBA2.01
: : SBA2.10:.~ ~ \~~ 'I ~ 53000(13.5) ::::::: 17. 000(3.5) . 34000(3.5)
, : 2J(7,5). n ,;O~ SBA2-12.\..,.. """"'S;'" ' .
: : ! i\ ", \~~ 300I9.s)f::;::::::::::::\/ ": :' /i'.SBA217
i i i ! \,\","\,\, ~ i :/:/{~~:...i....,,?:~~'-~.'.'L.......~I \,1,') NO .
, , " ' , ' , " I...., . . . I .' :,. . . . . . . . . . . . . SBA2-Q3, . . 5M2 02' '
: I :: " ',\ 'L...I. .:;<.:. ~'" : . : . : . : . : . : . : . : . .." I:
: : :: ... ",", i i.:':;:/ I::::::: ::::::::: 240(5.5) , 8300(3.5)';,
! IHj ! I \'>\'I\il\ ~~:r~~.:)
L _.~~!!!!!!!:~:~:~:>:~:!!:_". ~ j ..J\L.i:;I.:_:'./:,:,::J.::::::::::::::::.IV.n..'----m n
""---- : _",,""SBLA.13~'/\ : i 1 .i..------------- ---
. 16000(11'51""".!] L'_~'_'-~'-~'---'.'.-.~~~~~-': ! f ~
n.--.m._----..------.......m.....--..'''-'''''-'-''\''\~''- i ./ /: 1J~
S15BOLA(9'152)'.'..:.'.".'.1....... 100 ,,"""":../ i ~
. I,', ..' I
. ',: '. 5 -- "PARKING:
, ,l-
Ii LOT: 3
iE
a:
~
~
o 100
APPROXIMATE SCALE (It)
I
200 300
I
500
I
400
LEGEND
. SOIL BORING LOCATION SHOWING MAXIMUM
1,2.[)CA CONCENTRATION (ppb) AND
(DEPTH (fin OF MAXIMUM CONCENTRATION
'. "'tb 1.2.DCA CONCENTRATION CONTOUR
I WASTE.WATER UNE, AAAOW INDICATES
t DIRECTION OF FLOW
NOTE: ConnnnaUon data aupplamentad by
eon saaenlng data
FIGURE 4
CONCENTRATIONS AND
ESTIMATED EXTENT OF
1,2-DICHLOROETHANE
CONTAMINATION IN THE
SOILS IN AREA 2
-------
CHAIN UNK FENCE
NORTHEAST
TRIBUTARY
.
A
r::r::::~==~;:~T~BA2-1~ . S,-: SBA2-'S
i 8 [ [ : ,SBA2-19 SBA2-14 \
: SBA2.11! ! .: SBA2-08 SBA2-06
: !! SBA2-2 ~.".".."".8."'..
! SBA2-10 ~ ! r:T::::::~.~::::SBA2-04 BA2-Q1
SBLA-12: PARKING!
8! Na: C'
SBLA-04
: SBLA-14 :
:..........................' SBLA.11
. I
8 8 SBLA-QS SBLA-10
. ~--~SBLA-01
-+-'~SBLA-15
. SBLA-Q2
~-
SBLA-24
SBLA-22
c
SBLA-08.
[]
SBLA-07
LAGOON 1
LAGOON 2
8 SOIL BORING LOCATION
FIGURE 5
SOIL CROSS SECTION LOCATION MAp
LEGEND
A A'
L-.J CROSS SECTION LOCATION
APPROXIMATE SCALE (It)
J...."""..-
o 100 200 300 400
500
-------
A
775 -
'i'
!t 770 -
c
it
o
.c
m 765
CD
"iij
U
(/)
~ 760 -
';::
CD
>
CD
ftj
E 755 -
's
Q.
Q.
«
[SBA2.12]
Top of Grade
+
745
[SBA2.20]
[SBA2.19]
[SBA2.07]
A'
775
770
765
760
755
750
745
FIGURE 6
SOIL PROFILE A-A' WITH
1,2-0ICHLOROETHANE CONCENTRATIONS
IN SOIL AT AREA 2
LEGEND
D
(410)
(1393* )
[SBA2-07]
I I I I I I
location of soli sample
1,2-DCA laboratory analytical results in ppb
1 ,2-0CA field analytical results in ppb
Soli boring 10#
Bedrock/Soil interface
1,2-DCA concentration contour line (ppb)
--1ft)
I I
o 30
I
eo
"" 5 ""
-------
B B'
(SBA2.11) 772
772
70
770
(3)
Gi (2) 765
Q) 765
:t.
c
~
.c. 760
(J)
:a 760
Q) Northeast
Iii
u Tributary
(J)
Iii Bedrock 755
u 755
'€
GI
>
GI
1ii
E 750
's(
e
Q.
Q.
c( 745
745 Badrock
740
740
IV 5 IV
Location of soli sample
1,2-DCA field analytical results in ppb
1,2-DCA laboratory analytical results in ppb
Soil boring ID#
Groundwater elevation .
1 ,2-DCA concentration contour line In ppb
FIGURE 7
SOIL PROFILE 8-8' WITH
1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT AREA 2
LEGEND
o
(1731
-------
HI "HHH HH'H'" iHH'
WASTE.wATER COllECTION PIT i PARKING i
! AREA !
SBLA-14 ii AMMONIA BURNING SHED i
290(3,5) Ii i
'i i SBLA.11
!: : . 7(175)
SBLA.23 SBLA.06 SBLA-04 r'HHHHs'Ei'LA~1'5H""HH'/i"\ I .
LA~3g0N .'-"_H_~~~lL*l._N,:l;,;;,~.;;:O:;~l,oj ",,:D:d;~~}.05 -~J!';'S:O
SBLA 2 . ".,:~,. I
t t 5J(5.'~ :' ':: I ~MP~::";H::"",~"',;;fr~:t:-:'L''''ii~6~LA(7 .5°)1
~.. \ I,', .~. : .
SBLA-20 ". ',',' .- '0<.i9ooo
ND "<:: '.: -- " .
SBLA.19
ND
SBLA.18
19000(7.5)
I. . . . . .. . . .. . . . . . . . . . .. . .... . . .... Jmmm
......
DRIVEWAY
SBLA-07
36(9.5)
LAGOON 1
~
o 100
APPROXIMATE SCALE (It)
II
200 300
\
400
H"H'! ::::i::! ' , , ,
I::::!::::::::::::::::::::::
! ::::L:: .:: >.~..:::::::. ."
i :: ~ : ~: ,,/ ~
i..-..-,'......:.,.'
LAGOON 2
-',
, ,
: . S\3LA.03
:; ~(7,5)
'-..."
.
SBLA.09
2J(3.5)
SBLA.08 .
3.1(1.5)
I
500
. '
HH"H'J.;:H "H""'H"H'
j
0:
!E
LEGEND
SOil BORING SHOWING I.2.OCA CONCENTRATION
. (ppb) AND (DEPTH (ft) OF MAXIMUM
CONCENTRATION
I WASTE.WATER UNE, AAPCN INDICATES
t OIRECOON Of FLOW
ABANDONED UNE
'. -- ;.,. 1,2.QCA CONCENTRATION CONTOUR
10000 -'
NOTE: eonnrmatlon data supplemented by
soli screening dsta.
FIGURE 8
CONCENTRATIONS AND
ESTIMATED EXTENT OF
1,2-DICHLOROETHANE
CONTAMINATION IN THE
SOilS AT THE WASTEWATER
TREATMENT LAGOON AREA
-------
i'
CD
~
c::
~
,g 765
(/)
CII
co
CD
iii
u
(/) 760
iii
u
'€
CD
>
~ 755
E
'g
D-
c.
« 750
C
775
[SBLA.24) SBLA.23)
SBLA-221
SBLA-07) [SBLA-061
[SBLA.04)
[SBLA.15}
[SBLA.14)
770
(NO)
'."""'"
. "....".
(~:Or"
(5)
..
""'"
745
\...EGENO__-
o Location of soil samples
(NO*) 1,2-0CA Field concentration in ppb
(3.0) 1,2-0CA Laboratory concentration in ppb
(NO) 1,2-0CA analyzed for but not detected
(SBLA-14]Soil boring 10#
......Yo..... Static groundwater level
""10 IV 1,2-DCA Concentration contour line In ppb
(NO)
(NO 1
-9<"'(111
, I
o 30
(NO)
Top 0' grade
.. .
(NO) ..'."
(NO)
(NO)
--t,\\
I
eo
[SBLA.10)
C'
775
770
765
[SBLA.11 )
760
755
750
(3)
(NO 1
745
(7)
FIGURE 9
SOil PROFilE 8-8' WITH
1,2-0ICHlOROETHANE CONCENTRATIONS
IN SOil AT THE WASTEWATER
TREATMENT LAGOON AREA
-------
."'''''. \ '
,.. "'--'-'--""""- ...--- ._-_.~.~~.~~._-- ./:,;'~: ~~'_~f~~_;~~) SBA2.15
: :' :' ;-..... SBA2.13 6.1(5.57 ,."... ",
: r""--'-''',-,-----,--",--- j: ......: --. "" NO. " ..SBA2.i6,
: . """--j ":-';'--,-'"----. ",' " ""'-" SBA2.14 " ,.540(35\ .
I I I I. '. ~~,', '. ND ' . 'J .
: : : :r :' ,'SBA2.19 : ", --"'"'' """-'u.."'."" .,' \ \
: : : :1 i :1400(17.5) Ii """ """"""'''''-'''''''''''-'''''' \ \
: : : ~ :" .:..':~::':'-:r:::I::::... ""'''...uuu...'''''''''' \ \ I
: : SBA2.11:W. ;:i.: :: '.:. I I
: : 3.1(5.5) 1 i Iii SBA2'20 J ! \ SBA2.08 SBA2.06 I I
: : : 1\;, 6 0 ~..: 1300(19.5) """29000(5.5)" 'II
, : . 1.\,1 0 000(5.5),...:--_.....-.-.---.-...-..---.., ". : I
: I : : \,', I : 8 : ,f It "".: f!
: : : \ \...... : r'" -!. - - SBA2.09' --:..:l..:...s: SBA2.Q4 SBA2.01
: : SBA2.10:.~ \ ~'~ '1.-:-s-53000(13,5) ::1:::::17000(35) .34000(35)
: : 2J(7,5): :: \ \?~ SBA2.1~'i:::' 1: :-:-, -::: \.: :: :.~' ':"" : '" '
I I' . , .. ',',',',',',',',',',',' I , .
: : : :'.'. .~~ 300!9.5)Y-:!:::::::::::::\;:: : : :1 SBA217
' , I " \. I ',', ',",',',',',',',', "..'. I i '\ I. .
: : : : ~ ~ '. \ : , ::r::/<::::::::::;:::;: "10~ : , i ND
i ! ! ! \ \ \\\ ! : /:,:,J\~#<->:~~~; "'~...:~L:'''''''~ \I!
, , " ' , " ., 1""""1" ,',',',",'SBA2-00, "S8A2021'
: . :: ",, ',,, 'I....t .: i< . :. ",:.:.:.:.:.:.:.: ..oO I'
, ' " ',' " '.., ' " ',',,',',',',', 240(5 5) ., 8300(3 5)' r
: i < i i '\:-:';::ll'(J > ~~~t,,~::,::j
,mmmm ' , ", I""'" ,',','.',',',',', . SBA218
i ~""",.._,i !,/~.J~!r.:jj)!!;::~,... : ... /: r;~
,. t ' '.
SBLA-12"."'" j.... 100 ..,......... ,.:: 'ir>
150(9.5) """ :'" " .......: ~
, I: '. 5 .' "PARKING:
1 lOT 1 a
~
~
~
o 100
APPROXIMATE SCALE (ft)
I I
200 300
I
500
II
400
LEGEND
. SOIL BORINO lOCATION SHOWING MAXIMUM
1,2.OCA CONCENTRATION (ppb) AND
(OEPTI-i (ftU OF MAXIMUM CONCENTRATION
". .,~ 1,2.QCA CONCENTRA11ON CONTOUR
I WASTE.WATER UNE. ARROW INDICATES
t DIRECTION OF FLOW
NOTE: Conllrmallon data 8upplemented by
son aaeenIng data
FIGURE 4
CONCENTRATIONS AND
ESTIMATED EXTENT OF
1,2-DICHLOROETHANE
CONTAMINATION IN THE
SOILS IN AREA 2
-------
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RECORD OF DECISION FOR OPERABLE UNIT '4
-21-
TABLE 2
VOLATILE ORGANIC COMPOUNDS IN AREA 2 SOILS
COMPOUND NAME
Acetone
2-Butanone
Chloroform
1,2-Dichloroethane
Methylene chloride
T etrachloroethene
Toluene
Vinyl chloride
COMPOUND NAME
Acetone
2-Butanone
Chloroform
1,2-Dichloroethane
Toluene
1.1.2- Trichloroethane
SBA2-01 SBA2-02 SBA2-02 SBA2-03 SBA2-04 SBA2-0S SBA2-06 SBA2-06 SBA2-06
2-4 ft 0-2 ft 2-4 ft 4-6 ft 2-4 ft 20-22 ft 4-6 ft 8-10 ft 20-22 ft
12/06/92 12/06/92 12/06/92 12/19/92 12/19/92 12/19/92 12/20/92 12/20/92 12/20/92
- ::~Jf'1~~~~~=
6 U 6 U 6 U 7 U 35 U 7 u!ii;!::!;m:m::;!;:~1Kt~:: 33 U 6 U
i;:~1;9P,g:::I::j!i!:j:::\::~!!:::::::::::::\::!::::~~i::: ;::::::[::\:;i;~gg:\m:I!:\~;:::::[i'!(::;'I~g.;Q[:[: .;1~;:~;~~ggg;i:m:;; 7 uf(:~1~11:;~] ;~];:~:;[!m:!J.~~~;:~!i ;::i.fm;ill;;~11~:\'~t~~11;
6 U 6 U 6 U 7 U 35 U 7 U~:!::!!!;:::;;!:!lggJ~~j 33 U 13 U
i;:!;:i~;\:\::::::!!!:::~il~:::: 6 U 6 U 7 U 35 U 7 U 38 U 33 U 6 U
6 U 6 U 6 U 7 U 35 U 7 u::~\!I!i::::!:i;::~;:::!!:~~:i1: 33 U 6 U
12 U 13 U 12 U 13 U::!::i::~:ii;:.:I::;!i!~g!:!I:: 13 U!::!;;:!~1!!::!::!!:!i:1:1!! 66 U 13 U
SBA2-07 SBA2-07 SBA2-07 SBA2-08 SBA2-08 SBA2-08 SBA2-09 SBA2-09 SBA2-09
8-10 ft 18-20 ft 20-22 ft 0-2 ft 2-4 ft 18-20 ft 12-14 ft 14-16 ft 16-18 ft
12/21/92 12/21/92 12/21/92 12/21/92 12/21/92 12/21/92 12/22/92 12/22/92 12/22/92
::;1:!!::!::::!!:::~:~g:::~::::
16 U
8U
110 U
au
8U
65 UJ 14 UJ 42 UJ 55 UJ 12 UJ 15 UJ 24 UJ 18 UJ
14 U 14 U 14 U 17 U 14 U ;!~j!!lii~:I:~:i\~~;I; ili~:j]lli~~gli~11~li1i!] i\!t~~1f1~;1\t~\lg1~:
7 U 7 U 7 U 8 U 6 U::!l(!!!!I!::~!~:!~;g!!~ 6 U 6 U
;:!~~~:::!j~:!~;Q!:g:::: !::j~!!::i::::!Z1g!::I:::!:::::!:::::::::::::::~ijgtQi! ;!!!!i1:*::::::;::!;::!:l~:~gl[~iiii:j:j::::~Zg1!I:fu;j!~~~lgl!~I~~ !;;iti~11w\lf!~~~1jz~&; 120 U
7 U 7 U 7 U 8 U 6 u!!!:!~::i:~iill::~:0\~\~!! 6 U 6 U
7 U 7 U 7 U 8 U 6 U ~!i!ii1~;~!!i!!!!li~:: 6 U 6 U
-------
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT '4
-22-
TABLE 2
VOLATILE ORGANIC COMPOUNDS IN AREA 2 SOILS
Acetone
2-Butanone
SBA2-10 SBA2-11 SBA2-11
6-6 It 4-6ft 6-6 ft
01/19/93 01119/93 01/19/93
):!:!:!:i:::~:~:::i::!:::i?4q:!:::::!:::i!:::4~999':::pi::; '::!:::::::!:!:::!::::::::!:!::iggq!:::.
::::;1~\i:::!!;:::::,:g:::~::i
SBA2-15
4-6 ft
01/20/93
SBA2-16
2-4ft
01/20/93
SBA2-16
12-14 ft
01/20/93
SBA2-19
12-14 ft
01/22/93
SBA2-20
4-6 ft
01/22/93
SBA2-20
6-10 ft
01122/93
COMPOUND NAME
15 U :::::!:::::!:!:::!::::::!.:::::::.~~:~:!::*!:!*::::!:::::::!:::!:i!:::!!j;~~::!:
15 U 13 U
1,2-Dichloroethane
Methylene chloride
Styrene
Tetrachloroethene
Toluene
6U
6U
Concentrations in ppb.
D . Compound analyzed at a secondary dilution.
J - Compound detected but below the quantitation limit; value estimated.
E - Concentration reported from outside of standard calibration curve.
Shaded areas C'//:;) depicts positive detection.
-------
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RECORD OF DECISION FOR OPERABLE UNIT '4
-23-
TAB L E 3 VOLATI LE ORGAN IC COM POUN OS IN SOl L SAM PL ES FROM WASTEWATER TR EATM ENT LAGOON AREA
SBLA-01 SBLA-01 SBLA-O 1 SBLA-020- SBLA-02 SBLA-02 SBLA-03 SBLA-03 SBLA-03
COM POUN D NAM E 2-4 ft 4-6 ft 6-8 ft 2 ft 2-4 ft 4-6 ft 2-4 ft 4-6 ft 6-8 ft
1 2/07/92 1 2/07/92 1 2/07/92 1 2/07/92 1 2/07/92 1 2/07/92 1 2/08/92 1 2/08/92 1 2/08/92
"P,'''''''''''''''''''''''' .:;::::::;:::::::::1:;~~Q:::P::::: ".",'.",".".'.".",".".".",".","."."."'.".".".","'. " ......".. .....".. ."... ... .,.. ''''''''''''',,'''''''..'' "d"""''''.......... :1:j:;11:~1::11:;1mi!:1:~:::;;1 .......................... ~f~::::li1i~1~~1~;\:;
............................... .............................. ........................,..
:;;tiii;::::I:;~~Qlg:I: -........................." .,.............................. ............"................ ffi:{:::iI1:::1:~;Q:i~:::;
""""""""::::':::::::l:nr::':: :;:;;:t~;~QQ::pJ;:::::: ;:tt:;t:::;';:::::Ig~Q;I: '::::::::::::::::::':::::::Yio:'::::::
Acetone ................. ....
......,"......, d... ............... ....
~~;~~~t~;~r{t~~t ..;. -. :-." )t~; ~~;~t~fttr;~..-;;::,.:.,...)~~~i~
:~~:::~:::~:::::~~:~~:::::::::::::~::m:
Bromodichloromethane 7 U 7 U 6 U 7 U 7 U 7 U 7 U 7 U mmWi:\W1.~i{!:
,........,..............,.'''' ~:;:::;1ii;it1;Q1~]! :~\1::1;\\~;~~i:~~:~~i:1
2-Butanone 1 4 U :::~:::::::;::j:::i::i:ffii~::::gj!il~i
Chloroform 7 U 7 U 6 U 7 U 7 U :;:;iili::@;1~;;~~m
Dibromochloromethane 7 U 7 U 6 U 7 U 7 U 7 U 7 U 7 U ;::lj1:1;i1:~\11~ili~~;y:,~
''''''''''''''''''...'''''' """""'"'''''''.''''''' i:i:j::::I::;:i:::::::::;::i:::;::~~::::i::: ;~~~jm1i1~::;;:1:::j:~~:i1~:
1 ,2-Dichloroethane ::;:EIm::m:i::i::~Q:::::i: ::j:::::Ii::::::;i::::::i::::~~:i;;: 7 U 7 U 7 U 7 U
Methyle ne chloride 7 U 7 U 7 U 7 U 7 U 7 U 7 U 9 U
Toluene 7 U 7 U 6 U 7 U 7 U 7 U M:;:ii:;:j::::::i:iIiffi:;ii:I;:i 7 U 7 U
SBLA-04 SBLA-04 SBLA-04 SBLA-05 SBLA-05 SBLA-05 SBLA-06 SBLA-06 SBLA-07
COM POUND NAM E 0-2 ft 2-4 ft 1 0-1 2 ft 2-4 ft 4-6 ft 6-8 f1 6-8 f1 8-1 0 f1 6-8 ft
1 2/08/92 1 2/08/92 1 2/08/92 1 2/08/92 1 2/08/92 1 2/08/92 1 2/08/92 1 2/08/92 1 2/09/92
;;;;:j:}~~~:::~~::11:: .........,.................. ;::i:::;:::il:::jjl:::i:ji~~i::~:::: .............................. j:~j:ili~;:iii::I:I:lij::~ :1:iil~~:~j::I:::j:II[~1:iili~: ~~~~~~~~~~i~l#f~~j t1~i:~fill~gg!p';\:;
Acetone :::ffi:1::i:1:Q:g:::Il:::::::: 71 U ;::;;:1::::1:;:::;1i::;::~~:::4:;:
.... ............ [1jill!~1i~~~~~ill~~1'4~1~i~j~~ :~::::;:;::::~::::::::~:::::::;::::::~::::::::::::
Bromodichloromethane 6 U 7 U .i::;:j:::::i::I:::;:ii:i:gg6:::Ii:. 6 U 6 U 6 U 7 U MWnm#Js,m
;:;:::::ffi;:j;;:;~!:;:ig~:i::;:!: ::;::;:1::1;;:;li:!::::::1::,l']1:i1 i:ii::~:::~:::i:::1:::::::::?ij:;i:::: ::i:;ii::::II::;I;:;i::::::::;~:::pi::: .'.'.'."...'.'."'.'.'...'.'.'.','.'.'...'.'.'.'.'.'. :;::;1~ittiiJ:~!:~!1!i ~~~~~1j\jt~t~~~j~jgl~~1i :!:~;!ii:lli;m:;::liij]::;
2-Butanone 71 U :::::::;:::r:::;:m:MJ:@;;
................,.......... ;;~:::::::iI:;::;::il::;::: .............................. .,......,.,.,............,.. ~[ill~~1~~j~m~1~IJ~1j~~ ili~[1~[t~tj~1j~~sI~1~
...............................
Chloroform 6 U :Ii:::ii::::;:::@;IIi:::i;: j::iM~itm:j::M:i:~:;~::; i:::ii::;::::mm11::i\i:::ij::::. 6 U 7 U
........................... ;!;~~ll\:jil\::(?ilii:::::
Dibromochloromethane 6 U 7 U :;::::I;;;;::::;::::~1::::~:::: 6 U 6 U 6 U 7 U 6 U
1 ,2- Dlchloroethane 6 U 7 U 36 U 6 U 6 U 6 U 7 U :1~~;:i:;~;i~;:;~1l; 6 U
Methylene chloride 6 U 7 U ml:i::;:ji:lllii:i:ii:~Q::ig::;. 6 U 6 U 6 U 7 U 7 U 6 U
:j:::111i::j::::j:::;:::::::I::.~:;:: ........ ..........
...........,..............,.
Toluene .::iii::::iii;::ii:iiIi:::,;gHi 6 U 6 U 6 U 7 U 7 U 6 U
-------
-24-
NAt10NAl STARCH & CHEMICAL CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT .4
TABLE 3
VOLATILE ORGANIC COMPOUNDS IN SOIL SAMPLES FROM WASTEWATER TREATMENT LAGOON AREA
COMPOUND NAME
SBlA-07
8-10 ft
12/09/92
SBlA-08
0-2 ft
12/15/92
SBlA-08
4-6 ft
12/15/92
."...".................," .......,.".,.,............. "''''0''''''''''''''''''''''
Acetone i,'~:i~:::::~:i::~:~:~:::ili~~g~'1Uiili:~:::i~:~';gl:~:p:i:: :::::::::~:::~::~:~::i1j@'Q:~:'U;:::
Bromodlchloromethane 6 U 6 U 9 U
2-Butanone ,. 11 U 19 U
Chloroform
Dibromochloromethane 6 U 6 U 9 U
". ... ... ... ...
1 ,2-Dichloroethane ;mt:l;;:::i,:~1:i::~.e:::i,:~: 9 U
Methylene chloride 6 U 9 U 16 U
Toluene 6 U 9 U
COMPOUND NAME
SBLA-12
8-10 «
01/06/93
17 U
..,',...N.,',,',',','.,',',',',','..,',.',
.............................
;~@:i:::itE:~:~::i:::g:iu:::::
............................
,:Ii:'i,i~:::]:::::ii1:~Q;::I
30 UJ
7U
7U
7U
7U
7U
Acetone
2-Butanone
1,2-Dichloroethane
Methylene chloride
Tetrachloroethene
Toluene
Total xylenes
1.1.2- Trichloroethane
Trichloroethene
SBLA-12
10-12 ft
01/06/93
18 U
11 U
21 UJ
6U
6U
21 UJ
6U
6U
SBLA-13
10-12 ft
01/06/93
20 U
14 U
;:i,:;:~'~;~'aQ:::Q::::
7U
7U
7U
7U
7U
7U
Concentrations in ppb.
E - Concentration reported from outside of standard calibration curve.
Shaded areas <1;::::::) depicts positive detection.
SBlA-09
2-4 ft
12/15/92
14 U
7U
7U
SBLA-14
0-2 ft
01/07/93
10 U
13 U
18 UJ
6U
6U
6U
6U
6U
SBlA-10
6-8 ft
12/16/92
SBlA-10
16-18 ft
12/16/92
SBlA-11
12-14 ft
12/16/92
SBlA-11
16-18 ft
12/16/92
-----
..----
-----
..----
-----
-----
-----
-----
SBLA-24
6-8 «
01/09/93
18 U
13 U
~~:::::=:::::::=:::=:::::::=::~:=::,:::=:::::=::,:::=
;@Wm{@~i:I;1
6 UJ
6U
:i1;Ii,ili1iiUm~i:~ilij
6U
6U
6U
J - Compound detected but below the quantitation limit; value estimated.
D - Compound analyzed at a secondary dilution.
7U
':::::1:;:jqq::::P4'::::::~::::i,:::::::::::::;:;::~[I::g':!,: ;i,~j~;:;:::i,;i;::::;I~:;~~;~ i;;;;1:;];i~'~Q:iij'~;
.......... ............
'.'.....",',',",'.'."'.',',',',',',',',',',',',",",'
7 U 7 uii::i;mti:::::d:~m
13 U 15 U 14 U 13 U
j!':::::::::::::::::::::::::::::g4o.':::j1: ]!::::::;:::;::::i,;:!:;i~:@:~ 7 uj;;jijii::11;~:1g;ilii;
7 U 7 U )::::;1(;;ili\1;f::::::i!,g~~
7 U mii:i:::i,H::ilii:i~::i,aIDii, ;:::~~:::;~\:i!;~;;;~~iz:;:::;
19 U ,~:::::::::;:::::;:~i,~::::;::~~i::r 8 U 10 U
7U 7U 7U 7U
SBLA.14 SBLA-18 SBLA-22 SBLA-23
2-4 ft 6-8 It 4-6 « 2-4 ft
01/07/93 01/07/93 01/08/93 01/09/93
12 U::::lm:f:::::~~;1:iqf:l: 12 U 57 U
18 U 14 U 12 U ;1;*;:*~ili:;;lj;~i:u~;
:;;::;:;:::::::::::::;::j:'~lj::':: :':;::::~:I.~p::::m:::: !!~:t:\1l~!1\1]!;:~:m::::' 6 U
23 UH ::;:::::::;::i:::;!!!:ll~J.::i: 16 UJ 16 UJ
9 U ::i,;';;~;~::f::~::;;:::g:~:yi; 6 U 6 U
9 u~:!::!!;i!!::!:j1!~j~~l~f:: ~ili;ili!:l~:M~;ij;;:iil;1 6 U
9 U ::::;:~:~i~:::~::~~::::~1~1:!:~;1: 6 U 6 U
....",...... . .. ....
9 U ':Mi;;m:';;ili!:i,:~:i,i,:::: 6 U 6 U
9 U:!if:!~:::!:~:~~:~~::@1:1::'i!:, 6 U 6 U
-------
NATIONAL STARCH 8. CHEMICAL CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT '4
-25-
TABLE 4
CONCENTRATIONS OF INORGANIC ANAL VTES IN SOIL CONTAMINATION CHARACTERIZATION SAMPLES
COMPOUND/ANAL YTE
SE.12
(Background)
SBA2CC-06
4-6 ft
SBA2CC-06
8.10 ft
SBA2CC.09
12.14 ft
SBA2CC.09
14.161t
SBA2CC.20
4-6 ft
SBA2CC-20
8-10 ft
SBAlCC-18
6-8 ft
SEMIVOlA TilE ORGANICS
Delta-BHC
Bis(2 -ethylhexvnDhthalate
INORGANICS
ND 22 U 11 U
ND ':::::i;:::[;;:::::::::i:;l:::;;:;'~'3ok;":, :j:':;::::,:':::C:';};.:\::';i':;:::'.:~2)j::i
11 U
940 U
11 U
940 U
11 U
690 U
1 0 u!ii;:;::~\;:qmi::ig;ii;:&2i;~
670 U 930 U
Antimony
Arsenic
;::,::::,.~,.;:,::,:,;::j::::}t':,z;6'iJ;:":i::;:]':':'.:\i:':'};}'I':'s;S :;J ::. i':':'ij"{.:,:;;J::';::t:l::s;.i ':'u.',: ;':':':':':':"':::',!,)::';;.:::.:,:j,:;ti;:i::::j.:::',::;:::i::,;,.:t,:,:,,::., ;,.,:,:i;:!:g;aiu';:' i~M:\1:!~\::\k{tW6Yi1\m':; 3.6 U 3.9 U
':':':H'{,..,:""",':;::::;;:):;;:::}:::;:1'~gilt::i:;::,:;:t;';Mttt"",="",':1.(e::: ... . ',:,',:.'.2.9']) ": ;',if::i,:::;::::t:;:;'j::i:o;92:::U';:o. \::;:}\:;:::Kt::Ia!Ss.;ih ::,::::::i::::::i~:~j~fim:i!tijtll ;~;;1tii;M~))153i:u.:~ .;;;::;;~;;~1~:t~;1'(f;6~~t;
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:)::;::::::::~:J:.*I:::::m~:j1j46'::- ;'::~,:::::::~:;:i;::n;'H::~1;::~2S'(: ;;::j!::\:;:::::::::::;:'i!1:\::::j::::t;:iot:.:; ::':&!ii:::;::jt:::tH::::::::;i::~i~W ~::;:;::@::m::::::*:~;1:::;:::::2fj!:::: i:;I~;!:i~iIm::i;:*::;1(~*if .:!@;~!~t~~t~]:;iitl1'i~i~ 1;jMf~~fli~lt1m!7j~tl*:
;:ili;:'::~;';ii:l~~1:j:itt;~m::~ ;;:i:ii:::,::::~:::;;~~j;:::~~;~i;ij~::: i::;;:::";::::::;::[::::':i:;;;::;;::~~\~:'l~(;: :;;::::::;:;:i':;::::::!':;:i:;:;:':;::::ii:~::P::i:,'::::::!:::~;ti;~:::~1j;:;:~7;5j@:;: ;;;j;;(J;;;~;@;};\~2~~1,\ro.i\ ~~tf:~:'t~(@\~~~7::::~!: Iji~;:i;i11~\~;:::~Qli!J::;:
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Cyanide
lead
Manganese
Mercury
Nickel
Selenium
Thallium
Vanadium
Zinc
Concentrations are in milligrams per kilogram (mglkg) or parts per million (ppm).
J - Concentration is estimated.
U - Undetected.
Shaded areas rTm depicts positive detection.
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NA110NAl STARCH & CHBlICAI. CouPANY SuPERRJND SITE
REaIRD OF DeaSlON FOR OPERA8I£ UNIT 14
-26-
After reviewing the data presented in Table 1 and reviewing the history of the chemicals
used at the NSCC facility, it becomes apparent that a few of the compounds listed in Table 1
were not used at the facility. These include chloroethane and vinyl chloride. Their presence
at the Site indicates that some of the contaminants are being transformed by agents within the
environment. Currently, the identity of these agents is unknown; however, they are believed
to biological and not chemical.
5.2 GROUNDWATER
The nearest private potable wells are approximately 400 feet north of the NSCC property
line, which is approximately 2,100 feet from Area 2. These wells are approximately 2,100 feet
from the edge of the plume and 2,400 feet from the lateral extent of the contaminated soil.
These private potable wells are completed in the bedrock formation.
The saprolite and bedrock zones of the aquifer have also been adversely impacted by
activities at the Site. Contaminants detected in the groundwater include VOCs, SVOCs, one
pesticide, metals, and cyanide. Table 1 provides a complete list of contaminants detected in
the groundwater along with the frequency of detections and the range of concentrations
detected. The greatest concentrations of organic contaminants in the groundwater were found
underneath and north of Area 2 and north of the lagoon area. In Area 2, contamination can
be found throughout the entire aquifer. In the lagoon area, the highest concentrations
detected were in the bedrock zone of the aquifer.
A total of 61 groundwater samples were collected from 52 different locations. All of the
groundwater samples were analyzed for VOCs. Only groundwater samples collected from
permanent monitoring wells were analyzed for the full analytical analyses. To summarize the
analytical results, a total of 16 different VOCs, three (3) SVOCs, one (1) pesticide, 14 metals,
and cyanide were detected in the groundwater. VOCs detected in concentrations that exceed
either Federal Maximum Contaminant Levels (MCLs) or State groundwater quality standards
include (listed alphabetically) acetone, 1,2-dichloroethane, chloroethane, trichloroethene, and
vinyl chloride. The three SVOCs detected in the groundwater belong to family of organic
compounds called phthalates. Numerous metals were also detected in the groundwater. The
inorganics that were detected at concentrations exceeding two times the concentration found
in the background groundwater samples included: arsenic, barium, beryllium, chromium,
cobalt, copper, cyanide, lead, manganese, nickel, vanadium, and zinc.
Two plumes of contamination in the groundwater in the saprolite zone were delineated.
One is emanating from Area 2 and the other one originates in the lagoon area. Both plumes
have migrated approximately 400-500 feet from their source in a northerly direction. The
concentrations detected in the lagoon area are greater in the groundwater than in the
unsaturated soils. This indicates that the contaminants are being flushed out of the
unsaturated soils through the natural processes of precipitation and percolation.
The highest total concentration of volatiles and the greatest variety of volatiles were
found in the groundwater in the bedrock zone just downgradient of the wastewater treatment
lagoons. This finding also supports the conclusion that contaminants are being flushed out of
the unsaturated soils through the natural processes of precipitation and percolation in this
area of the Site.
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NA110NAl STARO! & CHEuICAL COMPANY SUPERFuND SITE
REcoRD OF DEaSlON FOR ()PERABl£ UNIT 14
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5.3 SURFACE WATER AND SEDIMENT
A total of 33 surface water and sediment samples have been collected from the
Northeast Tributary. The first samples were collected in March 1987 and the most recent
samples were collected in January 1993. All the samples collected were analyzed for VOCs.
In addition to being analyzed for VOCs, two of the samples were also analyzed for SVOCs
and metals. Each sampling event has shown contamination to be present in the surface
water and sediment of this tributary directly adjacent to Area 2. To date, only two (2) VOCs,
acetone and 1,2-DCA, have been detected in this stream. As in the other environmental
media samples, metals were also detected but these metals occur naturally. Two metals were
detected at concentrations at least two times greater than the background concentration.
They are manganese in the surface water and copper in the sediment. It was the continuous
detection of 1,2-DCA in this stream that led to the initiation of OU #3.
No contaminants were detected downstream of the plant prior to the stream leaving the
NSCC property which indicates that under normal weather conditions, no contamination is
leaving the Site via the Northeast Tributary.
5.4 HYDROGEOLOGICAL SETTING
The groundwater beneath the NSCC property is designated as Class GA in accordance
with North Carolina's water classification system and Class IIA under USEPA Groundwater
Classification Guidelines (December 1986). The Class GA classifications means that the
groundwater is an existing or potential source of drinking water supply for humans as
specified under North Carolina Administrative Code, Title 15, Subchapter 2L (NCAC 15-2L.02).
EPA classifies the groundwater as Class IIA since the aquifer is currently being used as a
source of drinking water in the vicinity of the NSCC facility. Therefore, the groundwater needs
to be remediated to a level protective of public health and the environment as specified in
Federal and State regulations governing the quality and use of drinking water.
At the NSCC site, a thick mantle of residual soil extends from the ground surface to the
bedrock. This mantle, the saprolite, is composed of clay-rich residual soils which range from
silty to sandy clays. The saprolite is derived from the intense chemical weathering of the
crystalline bedrock and has retained the structural fabric of the parent materials below the
oxidation profile. These residual soils exhibit increasing amounts of sand-sized relict mineral
grains below the oxidation horizon and closer to the bedrock. There appears to be a
complete gradation from saprolite/friable weathered bedrock, to fractured bedrock/sparsely
fractured bedrock. The depth to bedrock ranges from 10 to 100 feet below ground surface.
The deepest bedrock was encountered was in the vicinity of the Northeast Tributary. Figure
11 shows the orientation of the hydrogeological cross-section of the Site which is displayed in
Figure 12.
. Soil fissures near the water table are filled with geothite, presumably derived from the
weathering of the iron-bearing minerals present in the parent rock. There appears to be no
confining layer between the saprolite and bedrock. Therefore these two lithologic units are
hydraulically interconnected, and there is little or no impedance between these two zones.
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NATlONAI. STAROI & CHB/ICAI. CoIIPANY 5uPERRJND SITE
RECORD OF DEOSION FOR OPERABI.£ UNIT f4
-28-
The lithology of the soils underlying the Site was determined from drilling logs. The
thickness of the soil mantle varies across the Site. It appears that Area 2 occupies a
structural high and that the bedrock surface slopes steeply away from this area to the east
and more gently to the north. Rock core records show that the upper 10 to 15 feet of bedrock
is deeply weathered and friable. Bedrock begins to appear nonfriable and fresh 15 to 25 feet
below the bedrock/saprolite interface. However, fractures continue to be frequent and fracture
surfaces often exhibit oxidation staining to depths of 40 to 100 feet below the
bedrock/saprolite interface. Fracture frequency diminishes downward from the
bedrock/saprolite interface. It has been estimated that the bedrock becomes competent
approximately 200 feet below ground surface.
Water level measurements from the water table/saprolite zone of the aquifer indicate
that hydraulic heads decrease from both the east and west towards the Northeast Tributary
and towards the north along the stream. This data indicates that the Northeast Tributary acts
as a groundwater divide for the saprolite zone of the aquifer and receives groundwater
discharge along its entire reach. This explains the presence of contaminants being detected
in the surface water and sediment of this tributary. Additional data needs to be collected
during the RD to determine where groundwater in the bedrock zone of the aquifer is
discharging.
The hydraulic conductivity of the saprolite materials and the bedrock ranges from 0.72 to
3.35 feet per day (ft/day) and 0.01 to 1.13 ft/day, respectively. Based of the above
information, the horizontal flow of groundwater in the saprolite was estimated to have a
velocity of 80 feeVyear (ft/yr) in the lagoon area and 27 ft/yr in Area 2.
6.0 SUMMARY OF SITE RISKS
In order to assess the current and future risks from the NSCC Site, a baseline risk
assessment was conducted in conjunction with the RI. This section of the ROD summaries
the findings concerning the impact to human health and the environment if contaminated
media (Le., the soils) at the Site were not remediated. The baseline risk assessment is
incorporated into the June 1993 RI report which can be found in the NSCC Administrative
Record.
An exposure pathway is the route or mechanism by which a chemical agent goes from a
source to an individual or population (Le., the receptor). Each exposure pathway must include
(1) a source or mechanism of chemical release to the environment, (2) a transport medium
(e.g., soil, groundwater, air, etc.), (3) an exposure point (where a receptor will contact the
medium), and (4) an exposure route (Le., ingestion, inhalation, or dermal contact). A pathway
is considered complete when all of these elements are present.
Since use of the land surrounding the NSCC facility is a mixture of residential and
commercial, two scenarios were evaluated in the baseline risk assessment. The first is where
the property remains as a commercial area in the future and secondly, the property is
transformed into a residential area in the future.
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N 1300 -
-
~
~
o
z
~ N300=
NO.OO
E-3200
PlANT EAST (ft)
SCAlE 11'0
. ..... tDO «II IUD
LEGEND
. LDCATUIS_1II!1ImJSAI.
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FIGURE 11
BEDROCK STRUCTURAL CONTOUR
MAP SHOWING CROSS SECTION
LOCATION A-A'
I
-------
800
119.08
IIS-' ,
J
I
!
700
eoo
1
1
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400
o
1000
A'
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, WII... T- E"'-'
FIGURE 12
HYDROGEOLOGIC CROSS SECTION
LOCATION A-A'
i
f
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I
V_II E
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NATIONAl STAROI & CHEIIICAI. COMPANY SuPeRRIND SITE
REOORO OF DECISION FOR OPERABlE UNIT t4
-31-
Based on the information collected during the RI, the following pathways were
considered in the baseline risk assessment:
Potential current exposure under current land use conditions outside plant operations
area to contaminants in surface water and sediment and springs through incidental
ingestion and dermal contact, and inhalation;
.
Potential current exposure under current land use conditions inside plant operations
area to contaminants in surface water and sediment, surface soil, and springs through
incidental ingestion and dermal contact, and inhalation;
Potential future exposure under future land use conditions inside plant operations area
to contaminants in surface water and sediment, surface soil, and springs;
Future exposure of onsite residents to contaminants in the surface water and sediment,
surface soil, subsurface soils, groundwater, and springs through ingestion, inhalation,
and direct contact; and
Future exposure of potential onsite construction workers to contaminants in soil
(surface and subsurface) through incidental ingestion and direct contact; and to
contaminants in groundwater, surface water, and sediment through direct contact.
The baseline risk assessment indicated that there were no unacceptable current risks
from direct soil exposure. Future use of the Site as a residential area was also considered
with no unacceptable risks resulting from direct contact to surface soil. Future risks for
children exposed to subsurface. soils that become surface soil without dilution of the
contaminant (1 ,2-DCA) concentration in Area 2 were 2 x 10'" (2 in 1 0,000), just outside EPA's
acceptable risk range of 1 x 10'" to 1 X 10-6. However, the risk manager considers this
scenario so unlikely that it will not be a basis for the remedial decision. The remedial decision
will be based on protection of groundwater.
7.0 REMEDIAL ACTION OBJECTIVES
Section 5.0 defined the extent and characterized the contamination and the
environmental setting. Section 6.0 highlighted the human health and environmental risks
posed by the Site. This Section specifies the remedial action objectives to protect human
health and the environment. Protection of human health may be achieved by either reducing
exposure or reducing contaminant levels. Protection of the environment includes the
protection of natural resources for future uses.
The specific remedial action objectives and general response actions for the
contaminated soils at the Site are:
For Human Health - Prevent release of contaminants from soil that could result in
contaminant levels in excess of groundwater cleanup objectives
specified in the OU #3 ROD
For Environmental Protection -- Continue containment of contamination
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NATIONAl STAROI & CHalICAI.. COMPANY SuPeRRJHD SITE
RECXJRD OF DeaSlOH FOR OPERABlE UNIT 14
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7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
Section 121 (d) of CERCLA, as amended by Superfund Amendments and
Reauthorization Act of 1986 (SARA), requires that remedial actions comply with requirements
or standards set forth under Federal and State environmental laws. The requirements that
must be complied with are those laws that are applicable or relevant and appropriate. (ARAR)
to the (1) remedial action(s), (2) location, and (3) media-specific contaminations at the Site.
Applicable requirements defined in 40 C.F.R. ~ 300.400(g)(1) are those requirements
applicable to the release or RA contemplated based upon an objective determination of
whether the requirements specifically addresses a hazardous substance, pollutant,
contaminant. RA, location, or other circumstance found at a CERCLA site. These
requirements would have to be met under any circumstance. Relevant and appropriate
requirements defined in 40 C.F.R. ~ 300.400(g)(2) are those requirements that address
problems or situations sufficiently similar to the circumstances of the release or removal action
contemplated, and whether the requirement is well suited to the Site. The action-specific and
location-specific ARARs for the selected and contingent remedial alternatives are listed in
Table 5. The chemical-specific ARAR is discussed in Section 7.2 PERFORMANCE
STANDARDS.
7.2 PERFORMANCE STANDARDS
Currently, there are no Federal or State ARARs that govern the cleanup for the
contaminants present in the OU #4 soils if the contaminated soils are not excavated. The
following soil performance standard (cleanup goal) for 1,2-DCA is based on 1,2-DCA leaching
into the underlying groundwater. The concentration of 1,2-DCA that could be left in the soil
without increasing the concentration of 1,2-DCA in groundwater above the most stringent
groundwater quality concentration (NCAC 15-2L.0202) for 1,2-DCA was estimated to be 169
1!9/kg. This concentration was based on comparing the TCl analytical results for 1,2-DCA in
soil to the corresponding TCLP concentration using a least squares linear regression.
7.3 EXTENT OF CONTAMINATION
Figures 4, 6, 7, 8, 9, and 10 reveal the lateral and vertical extent of soil contamination
in Area 2 and the wastewater treatment lagoon area. These soil contamination delineations
are based on contamination levels detected in the soil as well as where there were no
detections of contaminants in the soil.
The estimated volume of soil contaminated above 169 ~lkg is over 231 ,300 cubic
yards. The quantity of contaminated groundwater in one pore volume of the aquifer beneath
Area 2 and the wastewater treatment lagoon area is estimated to be 131 million gallons (OU
#3 ROD).
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NATIONAL STARCH & CHEMICAl. CoMPANY SUPERRJND SITE
RECORD OF DeaSlON FOR OPERABI.£ UNIT t4
-33-
8.0 DESCRIPTION OF ALTERNATIVES
Table 6 inventories those technologies that passed the initial screening for remediating
contaminated soil. In the initial screening, process options and entire technologies were
eliminated from consideration if they were difficult to implement due to Site constraints or
contaminant characteristics, or if the technology had not been proven to effectively control the
contaminants of concern. Table 7 presents the results of the final screening of the soil
remediation technologies. Effectiveness, implementability, and relative capital and operation
and maintenance costs are the criteria used for evaluating the technologies and process
options in the final screening. The process options that were retained for further evaluation
are boxed in by a bold line. This table provides the rationale as to why certain technologies
were not retained for the detailed comparison.
The four (4) soil remediation alternatives retained to address the estimated 231,300
cubic yards of contaminated soil are described below.
8.1 REMEDIAL ALTERNATIVES TO ADDRESS SOIL CONTAMINATION
Alternative S 1 :
No Action
Alternative S2:
Natural Degradation & Institutional Controls
Alternative S3:
Soil Vapor Extraction with Fume Incineration and Activated
Carbon Filter to Control Emissions
Alternative S4:
Soil Vapor Extraction with Activated Carbon Filter to Control
Emissions
The cost information below represents the estimated Total Present Worth of each
alternative. Total present worth was calculated by combining the capital cost plus the present
worth of the annual operating and maintenance costs. Capital cost includes construction,
engineering and design, equipment, and site development. Operating costs were calculated
for activities that continue after completion of construction, such as routine operation and
maintenance of treatmMt equipment, and monitoring. The present worth of an alternative is
the amount of capital required to be deposited at the present time at a given interest rate to
yield the total amount necessary to pay for initial construction costs and future expenditures,
including operation and maintenance (O&M) and future replacement of capital equipment.
A 7 percent discount rate was used to calculate the Present Worth Operation & Maintenance
Costs.
8.1.1 ALTERNATIVE S1: No action
The No Action alternative is included, as required by CERCLA, to establish a baseline
for comparing the benefits achieved by the other soil remediation alternatives. Under this
alternative, no cleanup activities would be implemented to remediate the adversely impacted
soils at the Site (Le., the Site is left "as is"). Because these alternatives do not entail
contaminant removal or destruction, hazardous materials would remain on Site requiring a
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NATIONAL STARCH & CHEMICAL CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT t4
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TABLE 5
ApPLICABLE OR RELEVANT AND ApPROPRIATE REQUIREMENTS
On-site Container Containers 01 hazardous waste must be: RCRA hazardous waste (listed 40 CFR 264.171 These requirements are applicable or S3
Storage Maintained to good cond~ion or characteristic) held lor a (15A NCAC 13A.0009U)J relevant and appropriate lor any
Compatible with hazardous waste to be temporary period belore 40 CFR 264.172 contaminated soil or treatment system
stored treatment, disposal, or storage (15A NCAC 13A.0009U)J waste that might be containerized and
Closed during storage (except to add elsewhere. (40 CFR 264.10) in 40 CFR 264.173 stored on s"e prior to treatment or linal
or remove waste) a container (i.e., any portable (15A NCAC 13A.OOO9ml disposal. Soil containing a listed waste
device In which a material is must be managed as II " were a
slored, transported, disposed 01, hazardous waste so long as " contains
or handled). the lisled waste.
Inspect container storage areas weekly lor 40 CFR 264.174 53
deterioration. [15A NCAC 13A.00090Jl
Place containers on sloped, crack.lree base, 40 CFR 264.175 53
and protectlrom contact ~h accumulated (15A NCAC 13A.00090Jl
liquid. Provide containment system w~h a
capac"v 0110 percent 01 the volume 01
containers ollree liquids.
Remove spilled or leaked waste in a timely
manner to prevent overflow 01 the
containment system.
Keep compatble materials separate. 40 CFR 264.177 53
Separate incompatble materials stored near 115A NCAC 13A.00090Jl
each other by a dike or other barrier.
Soil Sampling Any non-waste material (e.9., groundwaler or Non-waste material containing RCRA 'contained in' 53
and Testing soil) that contains a hazardous waste must be listed hazardous waste principle
managed as if " were a hazardous waste.
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NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT 14
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TABLE 5 ApPLICABLE OR RELEVANT AND ApPROPRIATE REQUIREMENTS
LOCATION REQUIREMENT(S) PREREQUISITE(S) CITATION COMMENTS A8 RAb Teee
All Off-Site Shipment The oll-sne shipment 01 hazardous waste Generating site to sh~ waste oil 40 CFR 262 NC: 83
Requirements for requires that all RCRA and DOT site. ISA NCAC 13A.OOO7 . Generator must keep inspection
Hazardous Waste Per requirements lor manilesting and shipping 40 CFR 263 records lor 3 years
RCRA and Department papers as needed, marking, labeling, ISA NCAC 13A.OOO8 . D, F, H, & Ion NC manilest must
placarding, and special requirements based 40 CFR 171 through 179 be completed.
01 Transportation (DOT)
Regulations Will Be Met or type 01 carriage (i.e., rail, aircraft, public
by the OU #4 Site highway, etc.) be met.
(Generator) and
Transporter
Closure No Post- General performance standard requires Applicable to land-based unn 40 CFR 264.111 82
closure Care elimination 01 need lor further maintenance containing hazardous wasle. (ISA NCAC 13A.0009(h)) 83
(e.g., Clean and control; elimination 01 post-c/osure Applicable to RCRA hazardous
escape 01 hazardous waste, hazardous waste (fisted or characteristic)
Closure) constnuents, hazardous waste decomposition placed at 8ne after the effective
products. date 01 the requirements, or
disposed only belore the
effective date 01 the
requirements, or n treated in
snu, or consolidated within area
01 contamination. Designed lor
cleanup Ihat will nol require
long-tenT! management.
Designed lor cleanup to health-
based standards.
Disposal or decontamination 01 equ~ment, May apply to piping and 40 CFR 264.178 53
and structures. container or tank liners and (ISA NCAC 13A.0009U)J
hazardous wasle residues. 40 CFR 264.ttt
Removal or decontamination 01 all waste (tSA NCAC 13A.0009(k))
residues, contaminated containment system
components (e.g., liners, dikes), and
structures and equipment contaminated wnh
waste.
I'
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NATIONAL STARCH & CHEMICAL CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT .4
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TABLE 5 ApPLICABLE OR RELEVANT AND ApPROPRIATE REQUIREMENTS
LOCATION REQUIREMENT(S) PREREQUISITE(S) CITATION COMMENTS AI RAb TBCe
Treatment 01 wastes subject top ban on land Treatment 01 LDR waste 40 CFR 268.43 - Table The substantive portions 01 these 53
disposal must attain levels achievable by Best CCW requirements are to be considered In the
Demonstrated Treatment Technologies lor [15A NCAC 13A.OO12(c)) disposal 01 any OU #4 sne waste that Is a
each hazardous constituent in each listed restricted hazardous waste.
waste.
1,2-DCA (U077) non-wastewater 7.2 mgJ1
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NATIONAL STARCH & CHEMICAL CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT '4
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TABLE 5 ApPLICABLE OR RELEVANT AND ApPROPRIATE REQUIREMENTS
LOCATION REQUIREMENT(S) PREREQUISITE(S) CITATION COMMENTS AD RAb TBCe
Toxic Air Pollulant Guidelines. Emission 011 ,2.0CA 15A NCAC 20.1100 S3
Perm~ Requirements lor Toxic Air Pollutants. Emission 011 ,2-0CA 15A NCAC 2H.0610 De minimis lor permitting requirements lor S3
1,2-DCA is 260 Ibslyr. NSCC emitted
approximately 58,956 blyear. Permh will
be required.
Applicability. 2H.0610(a) North Carolina Toxic Air A toxics review is required lor 'existing S3
Pollutant Control lacilities that begin permhted construdion
Regulations, A Summary 01 a new source 01 any amount 01 any
of Ihe requirements, July listed toxic pollulant after April 30, 1990'.
31,1991 This will require compuler air dispersion
modeDing lor a predicted maximum annual
average concentration at the property line
to compare whh the acceptable (ML) 01
3.8 J.lg/m3
Emitting in Prevention 01 Significant Deterioration (PSO) Emitting in Rowan County, CAA Section 107 Proposed new and modnied sources In S3
Attainment of Review which is designated attainment Rowan County are potentially subJect to
Unclassifiable or Unclassifiable lor all PSO review. NSCC Is classified as an
Area for any regulated pollulants. existing major stationary source. Addhion
01 a SVE system is a modification,
Criteria Pollutant therefore, must check for signnicant
(1 ,2-DCA) emissions increase 01 any polMant
subject to regulation under CM (i.e.,
VQCs) PSD de minimis. 40 tons per
year increase; compare this to projected
1,2-DCA emissions after SVE system
addhion to determine n PSO review is
required.
a - Applicable Requirements for Alternatives as noted.
b - Relevant and Appropriate Requirements for Alternatives as noted.
c - Criteria "To Be Considered" for Alternatives as noted.
Note: All parenthetical citations are from North Carolina Hazardous Waste Management Regulations, North Carolina Administrative Code, Title 15A,
Chapter 13 - Solid Waste Management, Subchapter 13A - Hazardous Waste Management.
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NAmNAl STARDI & CHalICAI. COMPANY SlHRRIND SITE
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review of the Site remedy every five years in accordance with CERCLA Section 121(c). This
review process will continue every five years until the performance standard (cleanup goal) for
the identified contaminants in the soil are achieved. The implementation of this remedy could
begin immediately and would have no negative impact on future remedial actions.
If no action is taken migration of contaminants from the soil into the underlying aquifer in
the vicinity of the wastewater treatment lagoon area will continue. This migration results from
the natural movement of precipitation (e.g., rain and melted snow) moving through the soils
and carrying the contamination downward as the precipitation recharges the aquifer. This
migration force does not exist in Area 2 as this area is covered with concrete building
foundations and asphalt driveways. These structures prohibit precipitation from percolating
into the underlying soils. Therefore, all precipitation becomes surface runoff which is
controlled by the slope of the asphalt driveways and the curbs built around the asphalt
driveways. Surface runoff is directed into sumps where the water is pumped to the
wastewater treatment lagoons. Although Alternative S1 does not actively reduce or eliminate
soil contamination, it is anticipated that the levels of 1 ,2-dichloroethane will decrease over time
due to the process of natural degradation.
There are no initial capital costs for Alternative S1. Annual operating costs are based
on conducting periodic monitoring of the soil in order to prepare the five year review every five
years for a period of 30 years. As part of the five year review, soil samples will be collected
for chemical analyses once every five years in both areas, Area 2 and the wastewater
treatment lagoon area.
Capital Costs:
Annual O&M Costs
First Year:
Second Year:
Third Year and Later:
Present Worth O&M Costs:
Total Present Worth Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$
o
$ 16,000
$ 0
$ 0
$199,000
$199,000
None
None
Over 30 years
8.1.2 ALTERNATIVE 52: Natural Dearadatlon & Institutional Controls
Natural degradation relies on natural processes to destroy the contaminants present.
The most common degradation process is the result of microorganisms (bacteria, fungus, etc.)
present in the soil using the contaminants as an energy (food) source; thereby, destroying the
contaminant. The presence of two chemicals at the Site, chloroethane and vinyl chloride,
neither of which were reportedly used at this NSCC facility, is a strong indication that 1,2-DCA
is being transformed via natural degradation process(es). The rate and effectiveness of the
natural degradation process is dependent on a number of environmental factors, such as
nutrient availability, soil moisture content, presence or absence of oxygen in the soil, etc.
Using a published half-life of two (2) years for 1 ,2-DCA in the environment under
anaerobic conditions, the following degradation rates were estimated: in less than 10 years,
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NATIONAl STARaI & CHEMICAL CoMPANY SuPeRAJND SI1E
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the concentration of 1,2-DCA should decrease a conceritration of 7 mg/kg; in less than 21
years the concentration of 1,2-DCA should decrease to 169 J.lg/kg, the concentration that can
remain in the soil but not adversely impact the quality of the underlying groundwater above
the performance standard for 1,2-DCA; and in approximately 35 years, the concentration of
1,2-DCA in the soil should reach a concentration of 1 mg/kg. It was estimated over 130 years
of pumping the groundwater will be require to remediate the groundwater to the specified
ARAR of 1 J.lQ/I, as specified in the OU #3 ROD.
As part of this alternative, a biodegradative study will be conducted. This study will be
designed to (1) confirm or refute that natural degradation in the soil is occurring in the area of
OU #4, (2) if confirmed, locate where in the subsurface environment biodegradation is
occurring, and (3) ascertain if biodegradation will reduce the soil contamination within a
reasonable timeframe to a level which will protect groundwater and will not cause an
exceedance of the OU #3 groundwater cleanup goal for potential breakdown products (such
as vinyl chloride). In the event that natural degradation is occurring at an acceptable rate,
then the data from the biodegradation study will be used in the CERCLA Section 121{c)
required 5-year review. With the completion of the overhead pipeline in February 1994, no
additional contamination should be entering the soils beneath the Area 2 building. Based on
the degradation discussion above, a substantial decrease in the concentration of 1,2-DCA in
the soil should be observed over the next several years. In the event that the concentration of
1,2-DCA in the soil does not decrease as anticipated, a contingent remedy consisting of an
active soil remediation technology (as described in Alternative S3 below) shall be implemented
to achieve the reduction of contaminant levels that would be protective of the quality of the
underlying groundwater.
As this alternative is not a "No Action" alternative it is important to recognize the need
for continued monitoring of the Site. The biodegradative processes are subject to numerous
outside influences that may change over time (e.g., precipitation, infiltration, soil/nutrient
chemistry, etc.). Therefore, should the decision be made to remain with natural degradation,
a long term monitoring plan will be prepared which shall govern monitoring until the
performance standards are met. The monitoring parameters will include those that pertain to
the biodegradative processes (e.g., soil gases/degradation products/nutrients) as well as direct
measures of contaminants in question. The biodegradative study is to accomplish the goals
specified above and the long term soil monitoring is to provide data that substantiates that
natural degradation is continuing to occur in the adversely impacted soils of OU #4.
Institutional controls include using various controls and deed restrictions. The specific
institutional controls considered for this alternative are 1) using and maintaining the existing
fence around the plant operations area to limit access to the contaminated areas; 2) repair
and sealing of all cracks, seams, and other points of infiltration through the paved or built-over
areas, 3) periodic inspection and maintenance of paved areas around Area 2 to insure the
integrity of the cap over this area, and 4) a deed restriction to control future land use of the
NSCC property. The deed restriction will contain language to accomplish the following four
objectives: 1) to inform any potential buyer of the property of the contamination present, 2)
restrict future land use which would decrease the likelihood of human exposure to
contaminated soils, 3) to prevent the installation of a potable well at the Site until the levels of
contamination in the groundwater under the Site are deemed safe, and 4) to prevent
excavation in contaminated soils without sufficient personal protection for the workers. The
suitable deed restriction shall be recorded in the appropriate county registrar's office.
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NAT10NAL STARCH & CHalICAL COUPANY SUPeRfUHD SITE
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Capital Costs:
Annual O&M Costs
First Year:
Second Year:
Third Year and Later:
Present Worth O&M Costs:
Total Present Worth Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$196,000
$ 4,000
$ °
$ °
$ 50,000.
$246,000
3 months
1 month
Over 30 years
.. The Total Present Worth Cost is approximate and
was developed without regard for long term
monitoring, therefore, Total Present Worth Cost
may be slightly higher than that presented.
8.1.3 ALTERNATIVE 53: Soli Vapor Extraction with Fume Incineration and Activated
Carbon Filter to Control Emissions
This alternative will remove volatile organic contaminants by means of vapor extraction
wells installed in the soil above the water table. A preliminary design for Area 2 suggests a
system of 10 horizontal soil vapor extraction wells drilled underneath the buildings and
driveways. These 10 extraction wells will remove a total of 1 ,300 cubic feet per minute of
contaminated air. The preliminary design for the wastewater treatment lagoon area suggests
a system of seven vertical extraction wells removing a total of 20 cubic feet per minute of
contaminated air. The extracted contaminated air from Area 2 would be treated using fume
incineration to destroy the volatile organics prior to the air stream being released into the
atmosphere and the extracted contaminated air from the lagoon area would be treated using
vapor-phase activated carbon adsorption filters to remove the volatile organics prior to the air
stream being released into the atmosphere. The contaminants captured by the vapor-phase
carbon filters would be destroyed through the thermal regeneration of the used activated
carbon at an off-site, commercial regeneration facility. The incineration of chlorinated organics
in the fume incinerator will create hydrochloric acid gas that will require a scrubber. The
scrubber water will require treatment and disposal.
Remediation of the soil in Area 2 and the wastewate"r treatment lagoon area is expected
to be completed within 4 to 7 years and 1 to 2 years. respectively. A review/assessment in
accordance to CERCLA Section 121 (c) would be performed to verify that the soil vapor
extraction system is proceeding as anticipated or accomplished the specified cleanup goals
that will be stipulated in the Record of Decision.
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NA11ONAI. STARCH & CHatICAL COMPANY SUPeRRJro Sm:
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Capital Costs:
Annual O&M Costs
First Year:
Second Year:
Third Year and Later:
Present Worth O&M Costs:
Total Present Worth Costs for 7 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$2,887,000
$ 507,000
$ 416,000
$ 416.000
$2,394,000
$5,281 ,000
9 months
3 months
Over 7 years
8.1.4 ALTERNATIVE 54: 5011 VaDor Extraction with Activated Carbon Filter to Control
Emissions
This alternative is identical to Alternative 53 with the exception that the extracted
contaminated air from both areas would be treated using vapor-phase activated carbon
adsorption filters to remove the volatile organics prior to the air stream being released into the
atmosphere. As before, the contaminants captured by the vapor-phase carbon filters would
be destroyed at an off-site, commercial regeneration facility.
Capital Costs:
Annual O&M Costs
First Year:
Second Year:
Third Year and Later:
Present Worth O&M Costs:
Total Present Worth Costs for 7 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$2,918,000
$3,353,000
$1,566,000
$ 475.000
$6,270,000
$9,188,000
9 months
3 months
Over 7 years
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 8.0 describes the remedial alternatives that were evaluated in the detailed
analysis of alternatives set forth in the June 20, 1994 OU #4 Feasibility Study Report. This
section summarizes the detailed evaluation of the soil remediation alternatives in accordance
with the nine (9) criteria specified in the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Section 300.430{e){9){iii).
9.1 THRESHOLD CRITERIA
In order for an alternative to be eligible for selection, it must be protective of both human
health and the environment and comply with ARARs; however, the requirement to comply
with ARARs can be waived in accordance to 40 CFR Section 300.430(f)(1 )(ii)(C).
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Genera' Process Option
Assessment-
Response Technlca'
Action Technology Type Implementablllty Comments
No Action N/A N/A
Deed Restrictions
Institutional Action Access RestrIctions
Fence already In place.
~ Cley/Soll
Containment Capping
Concrete
In Situ Treatment
Cannot captUle prior to groundwater table.
In Situ Treatment
Innovative tachnology; t ,2-DCA not easily oxidized
Not applicable for volatile organic contaminants.
Not appllcabla lor volallle organic contaminants
."t;~;;:~;:;~: Innovative, commarclally unproven technology.
:~:;~;~}::~;:;;:~:i':;;:::::te)(cii\iilllOtI:;~;;;;;:;i::\}:i::i~::;:\:
::;;;:\i'CoiW&nIl6i'ii'i'~Excliviillonnrh ~~~;~~:o:rrrs\~~~::'8slbI9: Excavation could
:{:;:;:;::t?'}fOff'iillffDlli' . ~ill::{::::;:::::::):::::J
No Such faclllly exists.
'.;:::):Y::;\:;;:;Oi):$IJQO s'
No such faclllly exIsts.
TABLE 6 INITIAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR SOIL REMEDIATION
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General
Response
Acllon
Process Opllon
Assessment-
Technical
Implementabillty
Technology Type
}:::)~iill6fiiil..t:XciiwilOii::i?::::::
:{::::;:::;:::;:/Pti. iiICiilTieiiIfflGi'iF:::::;::::g::/:
))(:::{:::CtiOOilcftlTreiUiiii#it:t::::::::(?::
:::::::::::::::'i::::::R4iri16V1il/Dfs'" siit:'i:g::::~}::
';:::::i:::,:::;:::}:::;:r""'"
.
:,:,::"""'::::':::::::::':~::::
liibftllillkiri'::;=':,:",::,:::,:":,:,:,:,,,,::,,::,
.........." .......
::~:::::::~::*~r::::::~:~::::~:.
...' \'::{tTtieiffiill'Treatriiiliit:::::?:::':':::'::::::
:::::::::::::{:::::;:::::::::::::~::BI()1r&iittMnt{:~:!:~:~f.
It(?",,::::P:::::::\:?N:::):::::){:/:(:::(:):::/(:)::;::(':I -Technology or process option that has been screened out.
Comments
Plan area Is moslly Inaccessible; Excavation could
damage IIIgoon structure
Innovative technology
Innovative technology
Not applicable for organIc contaminants.
Not oppllcable for organk: contaminants.
No such facility exfsts.
No such facility exIsts.
TABLE 6 INITIAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR SOIL REMEDIATION
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General
Response Inslltutlonal EHectlveneas
Action Technology Type Process Option Implementablllty In Meeting RAOs Cost
No Action N/A NIA Easily Implementable Not Effective Low
Deed Restrictions Easily Implementable Somewhat Effective Low
Instltutlonsl Action Access Restrictions
Easily Implementable Somewhat Effective Low
~ Clay/Soll Implementable with Difficulty Somewhat Effective Low
Containment Capping
Concrete Implemantable with Difficulty Somewhat Effective Low
Easily Implementable Effective Moderate
In Situ Treatment In Situ Trestment SteamlAlr Str' I Implementable with Difficulty Effective High
Bioventln Easily Implemenlable Somewhat Effective Moderate 10 High
I .Process Opllon RelDlned
TABLE 7 SECOND/FINAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR SOIL REMEDIATION
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REa>RD OF DEOSQi fOIl OPERABl£ UNIT 14
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9.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the alternatives to determine whether they can adequately
protect human health and the environment from unacceptable risks posed by the
contamination at the 5ite. This assessment considers both the short-term and long-term time
frames.
As stated in 5ection 6.0, under current conditions the 5ite does not pose an
unacceptable risk to human health or the environment. Future use of the 5ite as a residential
area was also considered with no unacceptable risks resulting from direct contact to surface
soil. Future risks for children exposed to subsurface soils that become surface soil without
dilution of 1,2-DCA in Area 2 were just outside EPA's acceptable risk range. However, this
scenario is so unlikely that it was not a basis for the remedial decision. The remedial decision
was based on protecting groundwater.
All four alternatives, 51, 52, 53, and 54 are expected to provide long-term protection for
human health and the environment in conjunction with the OU #3 remedial action. However,
Alternatives 52, 53, and 54 will provide protection, more quickly, from exposures to
contaminated subsurface soils. Of these three alternatives, Alternatives 53 and 54 will afford
the greatest protection to human health as they substantially reduce the contaminants in the
soil within 4-7 years of initiation of the alternatives. Under Alternatives 51 and 52,
contaminant levels are anticipated to decrease as a result of natural degradation. Alternatives
53 and 54 protect the environment by removing contaminants from the soil, thereby
eliminating the potential for migration of contaminants to groundwater. In conjunction with the
OU #3 groundwater remedial action, Alternatives 51 and 52, will also be protective of the
environment. This protection stems from the following factors: 1) all contaminated soils are
within the groundwater plume to be remediated by OU #3, 2) the au #3 remediation will
prevent the spread of contaminants and remove contaminants from the groundwater, and 3)
soil contaminants should be reduced by natural processes within the timeframe required to
complete the au #3 groundwater remediation. Alternative 51 does not provide short term
protection for human health, however, as discussed previously, the Site does not pose an
unacceptable risk under the current use scenario.
9.1.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
This criterion assesses the alternatives to determine whether they attain ARARs under
federal and state environmental laws, or provide justification for waiving an ARAR. 5ite action
and location specific ARARs are identified in Table 5.
As long as the soils are left in place (Le., not excavated), no Federal or 5tate ARARs for
contaminants found in the OU #4 soils are triggered. Alternatives S3 and 54 will comply with
action-specific and location-specific ARARs which include operations at a hazardous waste
site, disposal of used activated carbon as solid waste, and air emission controls. Alternative
52 will comply with the location-specific ARAR related to operations at a hazardous waste site
and there are no action-specific ARARs that apply to this alternative. No ARARs were
identified for Alternative 51 as no action is being taken.
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9.2 PRIMARY BALANCING CRITERIA
Five criteria are used to evaluate the overall effectiveness of a particular remedial
alternative.
9.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE
. This criterion assesses the long-term effectiveness and permanence an alternative will
afford as well as the degree of certainty to which the alternative will prove successful.
Alternatives S3 and S4 will provide effective and permanent solutions for the
contaminated soil. The chemicals of concern will be removed from the soil by the soil vapor
extraction system and destroyed. Neither alternative will leave any treatment residuals on
Site. The reliability of both Alternatives 53 and 54 is high because they rely on proven and
applicable technologies and the extent of the contamination is relatively well defined. The
reliability of Alternative S4 is higher than Alternative S3 because of the maintenance problems
associated with the fume incinerator. Alternatives S1 and S2 do not directly remove, treat, or
isolate subsurface contaminants; therefore, they are comparable to one another in terms of
reducing potential residual risks. However, contaminant levels should gradually decrease to
levels that would be protective of groundwater quality due to natural degradation processes.
The time required to reach this concentration falls well within the au #3 groundwater
remediation timeframe (estimated to be 130 years). Alternative S2 involves long-term
institutional controls to prevent future exposures to subsurface soils as well as the use of the
contaminated groundwater beneath the NSCC facility. The projected adequacy and reliability
of these controls depends on land use, but should be relatively high because the impacted
area is small, within the plant boundaries, and land use is not expected to change. Soil
monitoring and periodic reviews at five-year intervals will be required for all four alternatives,
but the duration of performing such reviews for Alternatives S1 and S2 is expected to be much
longer. The long term effectiveness and permanence of Alternatives S1 and S2 are
dependent on the rate of degradation and effectiveness of the au #3 remedial action.
9.2.2 REDUCTION OF TOXICITY. MOBILITY. OR VOLUME
This criterion assesses the degree to which the alternative employs recycling or
treatment to reduce the toxicity, mobility, or volume (TMV) of the contaminants present at the
Site.
Both Alternatives S3 and S4 actively reduce the toxicity and mass of contaminants in
the soil. This is accomplished through the removal of the contaminants from the soil via the
soil vapor extraction system followed by fume incinerator or the thermal destruction of
contaminants trapped on the carbon filter. Neither Alternative S1 nor S2 directly reduce the
toxicity, mobility, or volume of contaminants through an engineered treatment process, but
reduction due to natural processes is expected to occur well within the time period required
for, and in conjunction with the au #3 groundwater remediation.
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9.2.3 SHORT-TERM EFFECTIVENESS
This criterion assesses the short-tenn impact of an alternative to human health and the
environment. The impact during the actual implementation of the remedial action is usually
centered under this criterion.
There are no short-time risks posed to site workers, the general public, or the
environment associated with either Alternative S1 or S2. There are minimal short-tenn risks
associated with Alternative S4 which are primarily due to general safety issues associated
with the construction of the soil vapor extraction and air emissions treatment systems. In
addition to risks associated with Alternative 54, Alterative S3 as two additional risks,
maintenance problems associated with the fume incinerator and the handling of hydrochloric
acid generated by the scrubber associated with the incinerator. Potential risks could also exist
during the operating period, especially workers exposure to fugitive vapors. If either the
carbon adsorption or fume incinerator/scrubber systems malfunction, temporary volatile
organic emissions would be controlled and minimized through properly installed monitoring
and control processes. Surface runoff-during construction, as for any construction project,
would be controlled to protect nearby surface waters.
9.2.4 IMPLEMENTABILITY
This criterion assesses the ease or difficulty of implementing the alternative in tenns of
technical and administrative feasibility and the availability of services and materials.
Alternative 51 requires no implementation. Alternative 52 will be easy to implement
because minimal construction activities are required. Both Alternatives S3 and 54 are
projected to require approximately 12 months to design and construct, and approximately 4 to
7 years of operation.
9.2.5 COST
This criterion assesses the cost of an alternative in terms of total present worth cost.
Total present worth was calculated by combining the capital cost plus the total present worth
of the annual O&M costs. Capital cost includes engineering and design, mobilization, Site
development, equipment, construction, demobilization, utilities. and sampling/analyses.
Operating costs were calculated for activities that continue after cornpletion of construction,
such as routine operation and maintenance of treatment equipment, and soil monitoring. The
present owrht (PW) of an alternative is the amount of capital required to be deposited at the
present time at a given interest rate to yield the total amount necessary to pay for initial
construction costs and future expenditures, including O&M and future replacement of capital
equipment.
More detailed infonnation on the development of the total present worth costs for each
alternative can be found in Section 8.
Altemative S 1 -
No Action:
$ 199,000
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Alternative S2 -
Natural Degradation and Institutional Controls:
$ 246,000
Alternative S3 -
Soil Vapor Extraction with Fume Incineration
and Activated Carbon Filter to Control Emissions:
$5,281,000
Alternative S4 - Soil Vapor Extraction with Activated Carbon
Filter to Control Emissions:
$9,188,000
9.3 MODIFYING CRITERIA
State and community acceptance are modifying criteria that shall be considered in
selecting the remedial action.
9.3.1 STATE OF NORTH CAROLINA ACCEPTANCE
The State of North Carolina has reviewed and provided EPA with comments on the
reports and data from the RI and the FS. North Carolina Division of Solid Waste Managment
(NCDSWM) has also reviewed the Proposed Plan and EPA's preferred alternative and
concurs with the selected remedy as described in Section 10. The State's correspondence
providing concurrence can be found in Appendix A.
9.3.2 COMMUNITY ACCEPTANCE
The Proposed Plan Fact Sheet was distributed to interested residents, to local
newspapers and radio and television stations, and to local, State, and Federal officials on July
8, 1994. The Proposed Plan public meeting was held in the evening of July 26, 1994. The
public comment period on the Proposed Plan began July 12, 1994 and closed on September
9, 1994.
Written comments were received from one citizen, the City of Salisbury, and NSCC
during the public comment period. The questions asked during the July 26, 1994 public
meeting and the Agency's response to the written comments are summarized in the
Responsiveness Summary, Appendix A. Minimal input was received from the community at
large.
10.0 DESCRIPTION OF THE SELECTED REMEDY
This is a contingency ROD. Alternative S2 is selected for addressing the contaminated
soils at the Site with the contingency remedy being Alternative 53. Briefly, the selected
remedy (Alternative S2) for this Site is:
Perform a "Biodegradative Study" to (1) substantiate that natural degradation of
contaminants of concern is occurring in the OU #4 area, (2) identify where in the
subsurface of the au #4 area degradation is occurring, (3) determine the rate of
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NATIONAL STARCH & CHEIoIICAL COMPANY SUl'ERRIND SITE
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degradation, and (4) develop and implement a for long term monitoring plan (refer to
Section 8.1.2) to monitor the biodegradative process until the performance standards
have been achieved. The collection of this data will begin after this ROD.
In the event that the "Biodegradative Study" cannot substantiate the occurrence of
significant natural degradation of 1,2-DCA and other contaminants of concern, or the
study shows that degradation products increase the site risk, the contingent remedy
(Alterative 53) shall be implemented. For the purposes of this ROD, "significant
biodegradation" is defined as a statistically significant decrease in levels of
contaminants of concern (particularly 1,2-DCA) that is coupled with multiple indicators
of biological activity, which includes the appearance of degradation products such as,
but not limited to, chi oro ethane, ethane, vinyl chloride, ethene, carbon dioxide,
hydrogen sulfide, methane, and soluble iron(lI)) and the depletion of electron acceptors
(including oxygen, nitrate, iron, sulfates, or others). This decision will be made by EPA
two years after the signing of this ROD.
If, at any time, the Biodegradative Study or long term monitoring indicates that Site
risks are increasing due to incomplete biotransformation of contaminants of concern
(transformation to vinyl chloride which do not continue to ethene as an end product).
The contingency remedy may be implemented.
The institutional controls to be implemented are deed restrictions and maintenance of
both the existing fence around the plant operations area and the paved areas around
Area 2. A deed restriction will be recorded in the appropriate county registrar's office
to prohibit any owner of the Site from utilizing the groundwater as potable water until
such time as the contaminated plume meets drinking water standards. A plan will also
be developed by NSCC, as needed, to protect workers in the event that the
contaminated soils are to be excavated prior to the levels of 1,2-dichloroethane
reaching the appropriate direct contact health based risk concentration (i.e., 7 ppm).
NSCC will provide EPA written confirmation that the worker(s) read and understood the
plan.
Five year reviews/assessments, in accordance with CERCLA Section 121(c), will be
performed until the specified performance standard for 1,2-DCA in the soil is achieved
(Le., concentration of 169 ppb).
The contingency remedy, Alternative 53, includes the following activities:
Volatile organic contaminants will be removed from the soils by means of vapor
extraction systems installed in the soil above the water table. The extracted
contaminated air from Area 2 will initially be treated using fume incineration to destroy
the volatile organics prior to the air stream being released into the atmosphere. After
concentrations of contaminants decrease in the extracted air, this contaminated vapor
will be treated via vapor-phase activated carbon adsorption filters. The extracted
contaminated air from the lagoon area will be treated using vapor-phase activated
carbon adsorption filters to remove the volatile organics prior to the air stream being
released into the atmosphere. The contaminants captured by the vapor-phase carbon
filters will be destroyed through the thermal regeneration of the used activated carbon
at an off-site, commercial regeneration facility.
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NA110NAL STARCH & CHEMICAl. COMPANY 5uPERRJND SITE
REcoRD OF DeaSlON FOR OPERABlE UNIT 14
-50-
A review/assessment in accordance to CERCLA Section 121 (c) will be performed to
verify that the soil vapor extraction system is proceeding as anticipated or has
accomplished the specified cleanup goals that will be stipulated in the Record of
Decision.
10.1 PERFORMANCE STANDARDS TO BE ATTAINED
Table 5 lists the action-specific and location-specific Site ARARs.
Performance standards include any applicable or relevant and appropriate standards/
requirements, cleanup levels, or remediation levels to be achieved by the remedial action.
The performance standard for 1,2-DCA in the soils to be meVattained by the NSCC OU #4 RA
is 169 Jlg/kg or ppb. This is the anticipated concentration that will protect the quality of the
underlying aquifer of being adversely impacted above the remediation goal established for 1,2-
DCA in the OU #3 ROD.
10.2 SOIL REMEDIATION
The RA shall comply with all ARARs listed in Table 5. The presence of contamination
in the soils will require deed restrictions to document their presence and could limit future use
of the area known to be affected by the contaminated soils.
10.3 BIODEGRADATION STUDY
A Work Plan to implement and govern the "Biodegradative Study" will be developed for
EPA approval as soon as possible after the signing of this ROD. The objectives of this
Biodegradative Study Work Plan are: (1) confirm or refute that natural degradation in the soil
is occurring in the area of OU #4, (2) if confirmed, locate where in the subsurface environment
biodegradation is occurring, and (3) ascertain if biodegradation will reduce the soil
contamination within a reasonable timeframe to a level which will protect groundwater and will
not cause an exceedance of the OU #3 groundwater cleanup goal for potential breakdown
products.
10.4 COST
The total present worth costs for 30 years for the selected alternative is $246,000 and
$5,281,000 for the contingency remedy.
The break down of these costs are specified below. The present worth (PW) cost
components are:
Selected Remedy --. Altemative S2
Capital Costs
TOTAL PW O&M COSTS (at annual PW O&M Costs of $4,000)
TOTAL PRESENT WORTH COST
$ 196,000
$ 50,000
$ 246,000
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NA 11OtIAI. STARCH & CHatICAl. CoMPANY SUPeRRlND SITE
REcoRD OF DEcISION FOR OPERABlE UNIT 14
-51-
Contingency Remedy -- Alternative S3
Capital Costs
TOTAL PW O&M COSTS (at annual PW O&M Costs of $416.000)
TOTAL PRESENT WORTH COST
$2,887,000
$2.394.000
$5,281,000
11.0 STATUTORY DETERMINATION
Based on available information, both the selected and contingent remedies satisfy the
requirements of Section 121 of CERCLA, as amended by SARA, and the NCP. Both
remedies provides protection of human health and the environment, are cost-effective, utilize
permanent solutions to the maximum extent practicable, and satisfy the statutory preference
for remedies involving treatment technologies.
11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
In conjunction with the OU #3 RA, both the selected and contingent remedy will protect
human health and the environment. The potential for exposure to Site contaminants via
dermal, ingestion, and inhalation pathways will be greatly reduced.
11.2 COMPLIANCE WITH ARARS
The selected remedy will be designed to meet all Federal or more stringent State
environmental laws. A complete list of the action and location-specific ARARs which are to be
attained is included in Table 5. No waivers of Federal or State requirements are anticipated
for OU #4.
11.3 COST-EFFECTIVENESS
The selected soil remediation technology is more cost-effective than the other
acceptable alternatives considered. The selected remedy will provide greater benefit for the
cost as it is anticipated to permanently remove the contaminants from the impacted soils. In
the event the selected remedy is not effective in attaining the specified performance standard,
the contingent remedy is a proven technology for removing and destroying VOCs in soils.
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE
The selected remedy represents the maximum extent to which permanent solutions and
treatment can be practicably utilized for this action. Of the alternatives that are protective of
human health and the environment and comply with ARARs, EPA and the State have
determined that the selected remedy provides the best balance of trade-offs in terms of:
long-term effectiveness and permanence; reduction in mobility, toxicity, or volume achieved
-------
NA110NAL STARCH & CHEilICAI. CoI/PANY 5uPERRJND SITE
RECORD OF DEaSlON R)R OPERASI.£ UNIT t4
-52-
through treatment; short-term effectiveness, implementability, and cost; State and community
acceptance; and the statutory preference for treatment as a principal element. The contingent
remedy will satisfactorily fulfill the above parameters as well.
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The preference for the treatment of contaminated soil is satisfied by the use of
employing indigenous microorganisms to degrade the volatile contaminants in the soil at the
Site. It is anticipated that the principal threats at the Site will be eliminated by use of this
treatment technology. In the event that the selected remedy will not achieve the specified
performance standard within an acceptable timeframe, the contingent remedy also satisfies
the preference for treatment.
12.0 SIGNIFICANT CHANGES
The July 1994 Proposed Plan Fact Sheet for au #4 identified two potential alternatives
as the contingent alternative in the event that natural degradation could not be substantiated.
The two alternatives were Alternative S3 Soil Vapor Extraction with Fume Incineration and
Activated Carbon Filter to Control Emissions at an estimated cost of $5,281,000 and
Alternative S4 Soil Vapor Extraction with Activated Carbon Filter to Control Emissions at an
estimated cost of $9,188,000. The emphasis of the Proposed Plan Fact Sheet was to stress
the fact that an active remedial action alternative would be implemented if natural degradation
was not occurring. This ROD selected Alternative S3 as the contingent alternative as this
alternative is more cost effective than Alternative 54.
-------
APPENDIX A
CONCURRENCE LETTER FROM THE STATE OF NORTH CAROLINA
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- - -- . - -
--r -- -"
I . --" "'"
I
State of North Carolina I
Department of Envlrorvnent.
Health and Natural Resourcesl
Division of Solid Woste Monagement
AVA
C>E I-II'JFI
Jomes B. Hunt, Jr., Governor
Jonathan B. Howes, Secretory
William L Meyer, Director
September 29. 1994
Mr. Curt Fehn. Chief
NC Remedial Section
U.S. EP A Region IV
345 Courtland Street. N.E.
Atlanta. GA 30365
Subj: Conditional Concurrence with the Record of Decision for OU4
National Starch and Chemical Company NPL Site
Salisbury. Rowan County. HC
Dear Mr. Febn:
The Division of Solid Waste Management (DSWM) bas completed review of the
attached Revised Record of Decision for Operable Unit 4 (OU4) and concurs with the
selected remedy subject to the following conditions.
1.
The DSWM is aware that institutional controls are subject to uncertainties regardiDg
enforceability. Our conc:urrence is with the understaJ1m~ that BPA shall attempt
to reach an enforceable agreement with the respon5lble party regarding stipulated
penalties which the respoDSlble party will incur if the property is sold. We request
that we be notified prior to entering these negotiations so that we may provide EPA
with information and input regarding tlDs issue.
DSWM 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 DSWM receive new or additional information which significantly affects the
conclusions or remedy selection c:ontaiDed in the Record of Decision. it may modify
or withdraw this cOneurrence with written notice to BPA Region IV.
2.
P.O. Box 27687. Raleigh. North Carolno 27611.7687 Telephone 919-733-4996 FAX 919-715-3606
An Equal ~ity Aftm\atNe ActiQn EmpIover 601. recycled/ 101. paltoContI61\8r paper
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-;
- - - -. - .. - --- 0"__'.
. _. .--- . -., .---
--r -- --
1.....,..." ....,...,
Mr. Curt Fehn
9-29-94
Page 2
3.
DSWM concurrence on this Record of Decision in DO way binds the State to concur
in future decisions nor commits the State to participate, finAncially or otherwise. in
the clean up of the site. 1be State reserves the right to review. CODlD1eDt, and make
independent assessments of all future work relatiDs to this site.
The responsible party for this site is undergoing a review of its compliance with the
North Carolina Hazardous Waste Management Rules. Conc:urrence on this Record
of Decision in no way affeC:ta or alters the compliance requirements or enforcement
of the North CaroliDa Hazardous Waste Rules which are .dmin1~red by the
Hazardous Waste Section of DSWM.
4.
The DSWM appreciates the opponunity to comment on the Revised Draft Record of
Decision for OU4 for the subject site, and we look forward to working with BPA on the
final remedy. If you have auy questions concerning these comments please contac:t Broce
Nicholson or me at (919)733-2801.
Sincerely,
~~~.
Jack Butler. PE
Head, Remediation Branch
bin\let\nsou4con
cc: Michael Kelly
Bruce Nicholson
Jon Bornholm
Attachment
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APPENDIX B
PROPOSED PLAN FACT SHEET
-------
.~.
~I
II8Pn 4
SUPERFUND PROPOSED PLAN FACT SHEET
OPERABLE UNIT #4 - SOIL REMEDIATION IN PLANT
OPERATIONS AND TREATMENT LAGOON AREAS
NATIONAL STARCH & CHEMICAL COMPANY
July 1994
Salisbury, Rowan County, North Carolina
rlm8'" I»Id .. ptInt .. *6nItl1n . ,..., 1oaIMJ" "" «td III thII publIcdGft. 7l* fII:t "., " not 8D ". Cf1IIIId8rId .
I8drtJaI tIDcumIIW but his ,.", ptfpItWJ 8D ptrwIdt . ,."" ........., to "" puIJIc.
1NTR0DUCn0N
. 'TNs Proposed Plan unrnariz8s tie m 20, 1994 0p8nIIII UIft
14 (OU 14) FeasIiity SUi)' and idenIifies tie preiIIn8cI cIBarLIp
option for addr8ssiIlg the c:ontami1al8d sol assodaled with Area
2 and the wast9waI8r nunent lagoon anta at the NaIonaI Starch
& Chemical Company (NSCC) ~ ~ In SaIistuy, North
CaroIi1a. The 181m "Operable ld" Is used when idvkUII
actions 818 taken as a part 01 an 0Y8I'8I siIIt cIBarLIp. A runber
of operable mts can be used In tie QUS8 of a siIIt cIBarLIp. 'nis
Fcu1h Operable lkit Is 8I1IicipaI9d ~ be tie last Operable Ur* for
the NSCC n. The Proposed Plan Fact Sheet for 0perabB lkit
t3 (00 t3), which adchssed tie c:onIan'Iina8d ~
II1dertying these same areas of the NSCC praperty, was
cis8iIuI8d to tie pl.tiic In JtJy 1993.
The ErwIronmentai PIotBdion kl«r:t (EPA),18ad IG«r:y for ~
activities, pepargd Ills Proposed Plan with tie assisIance of tie
North CaroIna Departnent of EnvIRnnent, HeaItI and NaUaJ
Rescutes (NCDEHNR), the apt tIQBI1CY. The data and
Information presenlBd In Ihe RemedIIIlnvIsIgdon for OU t3
also ~rted the OU 14 FeIsIIIIIty Studr. EPA, In consutation
with NCDEHNR. Wl1 select a remedy for OU 14 ony aft8r tie
p.ti1C comment period ends and at Infonna1ion UmiIIBd ~ EPA
cUi1g Ills time has been reviewed and COIISideled.
EPA Is isUtg tis Proposed Plan as part of lis IUIIic participation
respollstilities it accordance with Section 117(a) of tie
~ EnvIranmentII RespoI-. Campenlllar,,-
LIabIlIty Act (CERCLA~ also known as Supemm Ttls
Proposed Plan Fact Sheet sunmariz8s iIformaIon presell8Bd it
the m 1993 OU t3 Remeciallnvestigation Report. wtich
IncUIes lie BIsIIn RISk AssIsSmIrC. and tie .hIIe 20, 1994
OU f4 Feasibii1)' SUtydoctlnert, and other docunentscontained
In the _malIGn RIposIlaly/Adnratrdvt RIconI for this
SiB. EPA and the StaIB encocnge lie JUlie ID review ...
docunenIs ID beIer II'IdetstaIId lie SiB and the Superf&nI
activities conIb:8IId. The AdmiitbcdHe Record Is avaIabIe for
sU* review IocaIy at the Rowan NIle Lbary at 201 West
FistIJr S1r8et, SaIistuJ, NorII CarolIna.
EPA, it c:onsUtation will NCDEHNR, may mocffy the preferTed
III*ndv8 or select another response action presenlBd h lis Plan
and Ihe RemecIaJ IrMstigation and lie FeasIIIIity Study Repons
based on new InIonnatIon ancfIorp&illc comments. Therefor8,Ihe
sU* Is enccxnged ~ review and comment on aI aItematives
dscussed below. TIis Proposed Plan:
1. IncUies a brief tIac:I9OIIId of lie Site and the principal
frdngs of OU t3 SiIe RernecIaJ Investigation and tie r&eenI
~ d)'e 8Bst;
2. PresenIs 1h8 nII118CiaJ (c:Iearq) aII8rnatiws for OU 14
considered by EPA;
3. ~ I1e evaIuaIonaitBriausedlD recommend a remeciaI
a18Bma1146;
4. SUnmariz8s the nJysIs based on the evaluation criteria;
5. Presents EPA's I3tionaIe for Is recammencI9d remeciaJ
abemative; and
6. ExpIW the opporUIities far the sU* ~ comment on lie
remeciaI aIIsmatives and become InvoIwd in lie process.
PROPOSED PLAN PUBUC MEETING:
DATE: .uy 26, 19M
LOCA11ON: AgItcUtunI ExtensIon C8nI8I'
fm Old CancCI'd RoId
SIIIsIuy, NartII CIraIna
11IE: 7:00 PII . HI) PII
, PUBLIC COI8IENI' PERIOD: .'2, 19M . August 11, 19M
.
.
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SITE BACKGROUND
The NSCC facfty occupies approximately 465 acres on Cedar
Springs Road five mBes sooth of the CHy of Safisbury. North
Carolina (refer to Rgun /). Presently, land use bnmedbtery
adjacent to the Site is a mixture of residential and industrial
developments. East and soufi of the Site are industrial parks
eonsistinoprimanTy of Ip^hdustn^ operations. The west and north
sides of the NSCC property are bontered by residential
developments. Refer to the /^ 2 for Ste location.
A surface stream on the NSCC property, referred to as tie
Northeast Tributary, tows psraM to Cedar Springs Road and
passes wiWn 50 yards of he manufacturing area of fie facKy (refer
to Figure 2). Surface water runoff from the eastern side of IB
fadty dfccnarges into this tributary. The primary objective of
Operable Units 43 and 94 was to determine he source, nature, and
extent of the contaminafion being continuously detected in (his
stream on the NSCC property.
Primarily, NSCC manufactures texSe-finishing chemicals and custom
spedaftychemfcals. VolttJfe art ««rf-vditfle organic chemlcafe
are used in the producfion process along with atidte and afcafine
solutions. Actfc and alKalne solutions are also used in the cleaning
processes. The waste stream from the manufacturing process
includes wash and rinse solutions.
Operable Units 13 and f4 focus on the areas of the fadCty referred
OU*3» GrourxMatef in Area 2 and the wastewater trealment
lagoon area; surface water/sectments in the Northeast
Tributary
OUf4* SoBs in Area 2 and the wastewater treatment lagoon
3). Area 2 consists of the (blowing operations: Area 2 Reactor
Room, fie Tank Room, Raw Material Buk Storage, and tie
Warehouse. The lagoon area includes three lagoons. A fourth
lagoon was instated in 1992 as part of the treatment system butt to
treat the'contaminated groundwater being extracted from the aquifer
as part of the Operable Una fl (OU fl) Remodel Action.
As in Operable Units #1 , *2, and 13, the work performed for OU §4
was financed by NSCC, Ihe Potentially ResponsB* Paly.
The NSCC site was proposed for inclusion on the National
Priorities List in April 1 985 and finatzed on the 1st in October 1 989.
The Site had a Hazardous Ranking System score of 46.51. Only
Sites wHh a Hazardous Ranking System score of 285 or higher are
efigfote to be placed on the National Morales List
SCOPE AND ROLE OF OPERABLE UNTT WITHIN STIE
STRATEGY
As wft many Supertax! sites, the NSCC site is complex.
Consequently, EPA dMded the work into four manageable
components caled Operable Units (OU); fliey are:
OUf1 • Groundwater in the western portion of the NSCC
property
OUf2« Trench Area soils and surface watef/sedbnents in the
Northeast Trfcutary
RESULTS Of THE OU 13 REMEDIAL INVESTIGATION USED
FOR OU M FEASIBILITY STUDY
As reported in previous Fact Sheets, contaminants have been found
in the sofls, groundwater, and surface water/sedrnent on the NSCC
property. This contamination can be traced back to past chemical
handfing and dbpc^practk^tf the NSCC tacfflty. The sources
rt fie ccrtamhafion were MenBied. The types and concentrations
of the contaminants have been verified. The extent of contamination
in the vadose sol ZOM has been defined. The vadose zone is
comprised of subsurface soil that is not saturated with water. The
interface between the vadose tone and he saturated zone is
comnwily referred to as the intertable. Fourteen Different volatile
organic compounds, one semi-volatile organic compound, and one
pesticide were detected in the vadose soils.
The primary sources of contamination in Area 2 were a buried,
teaMng tena-cotta (fired day) pipeline and a solvent recovery
system. The tena-cotta pipefine transported iquid waste from Area
2 to the wastewater treatment lagoons. Replacement of the terra-
cotta pipeline with an overhead stainless steel pipefne was
completed in February 1994. Therefore, the terra-cotta pfpefine is
no longer in use. Sols associated with operating the solvent
recovery system have been contained since 1988 when a concrete
containment structure was constructed around the solvent recovery
system. Prior to Iris, material containing 1,2-dfchtoroethane was
spiled drecfly onto the ground. The source of the contaminants
detected in the wastewater treatment lagoon area is fie sofl under
and around the lagoons which were contaminated prior to fie
lagoons being fined with concrete.
The primary contaminant is 1,2-dfchloroethane which is a
chlorinated organic compound that is typicaly used as a solvent
U-DichloroetiiarBWIafiizesrBadflyan^
hurnan carcinogen. A carcinogen is any substance that can cause
or contribute to the development of cancer.
Ofierorganic chemicals were detected. The chemicals of potential
concern at the Site are (fsted alphabetically): acetone, bis (2-
cntoroethyf) ether, bis (2-ethyfhexyl) phfnalate, 2-butanone,
cadmium, cartx)ndfeufficte,cWciofemi,<^roetfiare,cWta^HC. 1,2-
dcntoroethene, dtobutyl phthalate, dnvoctyl prrthalate, ethyl
benzene, metriytene chloride, styrene, tetrachloroelhene, toluene,
1,U-trichlofoethane, trichloroelhene, vinyl chloride and total xyfene.
The toflowing inorganics were also detected: aluminum, antimony,
arsenic, barium, beryOum, chromium, cobalt, copper, cyanide, lead,
manganese, mercury, nickel, selenium, thalium. vanadum, and zinc.
The only field work performed to support OU #4 activities inaddrfion
to fie field investigation conducted as part of OU 13 was a
-------
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GRAPHtC SCALE. I'''''
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FIGURE 2
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FIGURE 3
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~ dye Bst. 'The ~ dye _was corDJcted 10
det8nni1e if 1,2-dicNoroe1hane exis8Bd as a IiqIid In the UUface
soils at the Site. 1.2~18 belongs 10 ht family of
chemi:aIS I1at I Uficient quantities of 1,24d11oroehll8 are
present, hIn lie 1,2~1fI' wi COIISOidaI& In tie
SIb!uface envinImIent and fDnn pools of 1,24ct*1roe11il1&. It
was Importanl to deBmi181f 1,2-<1ct1101oehu18 exIs8Bd as a IcPd
In the Us&rfac8 enviraI.nert as .. AfIItr:y has IDUId ~
exper!eIlCIS at other ~ . that .. pesellC8 of such a
pool of contaninaIion wi act as a conIiUIus ICXR8 of
contamInaIion for many, many,us. ConsecpInIy, lie pnJS8nC8
of such a pool of COIItamilIdon wUf canRlthe success or fab8
of.. SII8's cIBarq) as well as the cost of.. cIeIIq). Ora In ..
UUface, . is cItfiIUt If not impossIIIe. 10 IICIMI' II of ..
trapped pooled c:ontaminant from the pnf.
In a ~ cl)'81Bst. a soli or grMdwaIer sample Is mixed In
.' a glass contanr hit contains a ...... of wDr and a ctte that will
attach IIseIf 10 1.2-<1dD'oethn. If no cl)'81s bnf ~ to I1e
Iides of the IPSS container, lien 1,24ctioro&"1& does not exist
as a fr8e IiqIid In the sample 8St8d. To hu8 .. most ~
InIonnation was obtained, .. six 101 samples used In ..
~ dye lest WIII8 coIecI8d fRIm lie area of the Sits
conIaiing the tiPS! soB c:once..cdiu.aof 1,2-c1c:Noroe1&I8. 'The
rids of.. ~ dy8 lest (SepIBmber 1993) on these six
samples indicate hit 1,24c:h1oR1et1an8 does not - as a fr8e
IiqIid in I1e sois at the SiIe.
Replacement of the terra.:coua pipeIne will an overhead stainless
steel plpelile elini1at8d the I8IeaSe of 1,24ch1oroethane to I1e
soils ben9aIh Ar8a2 and. \IIimaI8Iy,to" "*'Ying~.
'The concrete tIoori1g of lie IxMng 0.8.. .. bI1dation) and I1e
asphaIf cmeway hit sunMRts I1e txiIcIrV act as an ImpenIous
cap. By replacing I1e IeaJQng terra-cotIa pipeIi1e willi the owrt1ead
",peine. tffo goals were acIiewId. First, lie scuce of
c:onIarnination was elinlnated. Second. water leaking from lie terra
co1ta pipe comprised a driving force tor the downward m9atiOn of
1.2~thane, and ttis driving force was also eIinRd8d.
'Therefore, . is not exped8d that contamInanIs present in I1e sol will
adversely inpact~.
All 118 metals (morgarics) deI8d8d In the soil 818 natIIaIy
0CCU'ring. 'The dfference it COIICBlIbaWns between the backgrcKrId
seciment sample and 0MiI8 soB samples Indica!8 the SiB has not
released inorgaric contaminants Ir*> the envInnnenL
SUMllARY OF SITE RISKS
A goal of the Remecial ~ StJdy process Is 10
analyze and estimate the tunan health and enWom\entaJ problems
that c:oUd red If tie conIamlnation Is not cleaned LC). nis
analysis Is caIed a BaseIne Risk Assestment. In cabating risks
to a popUation If no remecIaI acIon Is taIcIIn, EPA evaluates I1e
reasorUIe maxim\ln expoS&I8 IIMIIs &rider arrent and potential
fuUe expostn SCBIIIrios 10 SiIe c:or8mi IIIIt5. 'The risk scenarios
evaluated In the Baseline Risk Assessment "* arrent COIdtions
Induded trespassers on .. ttSCC SIIa as wJ8S empIo,..
working on tie Sits. -The risk scenarios d8'~ In tie Baseline
Risk Assessment far !!!y! cordIions Included a resident Iving on
the NSCC property and ~ a well insIaIIed In .. c:ontami.med
~ as IIeir SOU'C8 of potable WIdBr (Le.. wa8Br used for .
Gtidng. cookiV. baling. ft.). In corQdng INs assessment,
EPA focuses on the adwInii tunan heaIIh etIects that aUd nWt
tRIm IDng-tBrm daly, cIrect expoS&I8 as a red of ingestion,
InIIaIaIian, or dermal contact 10 caclllOg8l~ d8nicals (cancer
cuing) as well as the acMrse heaIIh effects IIat ccU:I red from
long-term 8XpOSII8 10 non-can:inogIIn chemicals pr8S8It 81 ..
SiB.
EPA's goal at ~ siIBs Is 10 recU:8" ucess lifetime cancer
risk eM 10 chemicals preser4 at the SiB. this means that ..
chance of conrd ID cancer Is between one In IBn thousand and
one In one mIion.
In the expoIU8 assessment, EPA COIISidered iIgestion of sol.
ImaJaticIn of sol vapor ancVor particL8J8S, and cIrect contact as I1e
by expos&n paIhways lor .. tunan recep1DrS.
EPA concUfed I1at IIIder CIIT8f1I c:onciIions, the soil ccnlamnation
assodatBd .. OU 14 does not pose an &meeeptabIe .£!!!!!!1 risk
tD tunan heaIIh. Ther8 Is no camn &meeeptabIe risk because
ttB8 Is no complete 8xpos&n paIhway i:Ir lie conIamInanIs 10
r&ach tlelU* at large. However, me fuU8 risk scenariOS were
Identified wtich could lead tD &meeeptabIe 1YY! risks as a I8SI.ft
of being exposed 10 Ihe chemical contamination at I1e Ste. The fist
scenario In¥oI\'8s resIdenIs iving in homes Idt on or near the Sie
and using the conIaminatad ~ as tIeir scuce for potable
water. 'The key expos&n palhway In tIis scenario is the use of tie
contaninided IJO'I1dWat8r as a potable SCIUC8. 'The second
scenario that cWd reNt in anohIr &meeeptabIe !Y!!:!! risk Is I1e
8XpOSII8 of a cHd to tie uface watsr, sedinent, and sprfng water.
C\mn8y, tie poIBntiaI for expoS&I8 tInMqI tis pa!I1way Is
sIsJificanIY reduCed because access tD that portion of ht snam
where eIBvated COIlC8lltIatioIlS of conIanII1anIs are present Is
encompassed witin Ihe fenced &nil of .. NSCC property. 'The
IhId, po1riaIlIIICC8ptabIe!!!!!! risk Involves exposing idvIcUds
to contamitaled UUface soil. 11is risk 8Jists tor bo1h WOlters
on-siI8 as weI as flUe residents living on-siIe and dWng into I1e
aQuface solis. The wortcer risks can be ~ reduced by
proviIq adeql8l8 personal plolldiol..
REMEDIAL AC110N OBJECTIVES
'The mail goal of R8mecIII AcIIon ObftcllVlS Is t) protect tunan
heaItI and .. enviromI8ft by preventing 8JPOS&I8S t)
collcentralions 0' contaminants above risk-bas8d !llnan heafIh or
erwinnnental s1andards. Protecting tunan heaIt1 may be achieved
by eitIer recb:ing expos&I8 or reduci1g contaminant levels.
Prot8dion of tie envinmIent Includes protection 0' nauaJ
resouces for iJIII8 uses.
In Ider1IifPIg .. RemeciaI Action Objec:tiws, the fincqs of ..
BaseIi1e RIsk Assessment W8f8 used as wet as an examndion 0'
II po8BntiaI federal and stale enviomIentaI Appf~ ar RIIMnt
-------
and ApproprtaII ~ (ARARI). ARARs can be
cat8gDjizedasc:h8micaJ.spec:1ocatioMpec:i&: or adioIHpecific.
CI1emicaJ.speci ARARs .. acceptable exposII8 IMIs ~
paricUar c:I8nic;aIs and Is .. Imit I1aI must be met lor that
contaminantwltin an envIRxmental meclwn (Le., wa!8r. sol, or Ii)
at a specific compliance pcK LocaIolI"specif£ ARARs adchss
si8-speci~: aspecIS such as crIIcaI habitat.... wIich 8I1daI1gIII'8d
species or h8aInd species dBpends. .. presence of a weiand,
or NsIDrIcaIy aii\pjblllBallns. ActJon.spec:ik recpremeru are
conInIIs or ,diclicM. tar partIcUar acIvIIes reIaIBd ~ tie
Implemenlatlon of lie pqIOS8d l8ntecIaJ aItemaIIve. ~ unmary,
the RemecIaI AcIIon 0bjectMs tar salls In Area 2 and ..
was8BwaI8r Ir8aIment lagoon area are:
8 For H\Inan HeaItt PnMrt cIrIct contact . solis hamg
IMIs reUtq In cancer risks above accepIabIe IInIIs
8 For H\Inan HeaIIh: PrMrt release of contamInanIs from soD
that c:CQd red ~ WI"'. levels n excess of ~
dearI.Ip objecIves specified n the OU 13 Record of DecIsIon
8 For Envi'omIentaI Prot8cIor.: ConIIru8 contamert of
conlamillatior..
The oIIjecIve of a ~ Sill dearI.Ip Is 1D I8Cb:e the
conIaminaIion 1D concetdratlons specified by 8MJ.As8 or that Is
proBctiY8 of tunan heaIIh. 1bere 118 no Federal or Slate ARARs
that govern the c:Iearq) of conIaminaIBd sols that are nor
excavaI8d.. The following sol performance standards (cieatq)
goals) tar 1,2-cich1oroethane were based on (1) drect conIaCt
exposn and (2) IeactUIg of 1,2~ InID the &IIdeItyi1g
QrO\I1dIraI8r.
Risk.aised COIlC8lltIationsfar 1 ,2~t1ane were calclllatBd for
the taIIawing expoue scetlarios: a worker exposed 1D c:ontamin;dBd
soil and a fubn resident exposed ~ c:ontarninaIBd sol. The
COIMlidlation prot8Ctive of a WOItcer Is 63 mlJ9ams per ~
and for a iJUe resIdert. 1 mllipns per Idbgram. Based on t1e
data coIJectsd, no Uface solis at the SiB exceeded t1e risk-based
vallIt of 7 mllipns per Iciogram a 1,24ctDoe1hane. Therein,
ufac8 soils do nor pose an nccepIabIe risk ~ tunan heaItt
LI1der QII'8I1t or fuII.n expoan scenarios. .
!
HowMr. S1iIuface soils W1demeaIh Area 2 and the wastewater
InIatm8nt lagoon area have 1,2-c1c:tDoelhalie COIlC8ldrations of
1,600 miflpllS per kIogram and 19 mlligrams per kik9al1l
respectively. boll exceecing 7 miIigrams per IdIopn. If these sois
shaUcI be exposed LI1der a fuUe residential scenarios (I.e.. cUi1g
cIggiIg or consIrUCion), tIey woUd pose an LI1aCC8Pt3bIe heaItt
risk.
The nexI step n estabIsting Site ~ goals Is 1D develop soil
dearI.Ip levels 1D proIBct~. EPA deBrmines what
corMIIdiation of conIamnant can remain ~ the sol without IeachiIg
1D pIIdwater 11 quantities that woWd be above a protedive 11M!
for the~. The estina8d COIlC8ilbation of 1,2-
cIcNorodIane that coUd be 18ft In the sol wiIhout ~ tie
corM1d1dtion of 1,2~ 11 ~ above tie most
stringent ~ou'dwaIB'- quality COIICeI nti«I (NCAC 15-2L.0202) for
1,2~ is 169 rnicropns per IdIopn.
Based on tie risk-based YIWB of 7 miligrams per kiIoSrcIm. ..
esIinaIBd vokIne of soil conIamnatsd above lis CIOrICIfdlatWlls
35,940 C&tic yards. The estimaIBd vohIne of soil COIItambJalBd
above 169 microgIams per kilogram Is over 231.300 ca: yards.
SUllMARY OF REMEDIAL ALTERNA11YES
The foIowng section unmarIz8s .. ~ IBdr1oIogies and
aIIBmativeS developed n tie OU 14 Feasibiity SbJdy docunent for
adchsskJg tie sol contami1ation In Area 2 and tie wastswatsr
tru.tment lagoon na. DescrtpIions of the ~ aII8matives all
S&IIIrnariz8d below.
The cost Informdon below represents t1e estimated t3ta1 presert
worth of each aIIBmaIive. Total present worth was caJcUaIBd by
combiing tie capital cost Ilks the present worth of the arruI
operatiIlg and mairEnaJa costs. Capital cost Incbies
construction, 8f9nee(oIJg and des;;:'1. equipment, and siIB
development. Operating costs were ::aicUat8d for activiIies that
conIiIJB * compIeIIon of conswction. such as routine operation
and mainIenance of lr8aIment equipment, and morlloring" The
present worth of an aIIemative Is the amO&l1t of capital requied t3
be deposited at .. present time at a ~ InIerest rate 1D yield the
total amcxI1t necessary 1D pay for ~ construction costs and fUbn
expencitlns, incUing operation and mai1tenance and fuU8
replacement of capital eqIipmert.
For more Infonnation about t1e Remecial Action Objectives and
aJtematives a OU 14. please refer t3 the JII18 20. 1994 Feasiblity
Sludy doc&ment and other doaJnents available in the information
repositoly In the Rowan PubI:~ Ubrary.
REMEDIAL ALTERN~ i, ;ES TO ADDRESS SOIL
CONTAllNAT1ON
The foil' aIIematives for addressing conIamina1Bd SOIls in:LUdB:
AlternatIve 51: No ActIan
Alt8mdvt S2: Natural Degradation & institutional Controls
AIIematIY8 $3: Sol Vapor Ex1r8cIIon with FumlIncInerItIon
and ActIYat8d Carbon Riter CD Control
EnasIonI
AIIematIY8 54: SoU Vapor ExtnICIIon with ActIvated Carbon
Filter CD Control EnUsIons
A description of each a/te-r.atiw foIbws:
-------
ALTERNATIVE $1: No AI:nDN
CapiIaJ Costs:
ArnJaJ Operating & Mai1I8nance Costs
Fist Year:
Second Year.
TIIrd Year and LaIBr:
PnIsent Worth Operalng & MamllIalICe Costs:
Total Present Worth Costs for 30 Years:
Tillie tD Des9I:
ConsIruction Tillie:
DIlation .. AdieYe ~:
$
o
$16,000
$ 0
S 0-
$199.000
$199.000
None
None
CMr 30 JI8IS
CERCLA reqWes that lie "No N:t»n" aII8matIve be evakIat8d at
every ~ Si18 .. esIabiSh a baseline for compadsor.. No
fII1her activiIies woUd be concu:8d wIIh SiIe salls "* Ills
ahBmative (i.e., 11:1& Sill Is 18ft "as Is"). Becaus& this aII8maIiv8
. neitler removes nor desroys 1he coramiuliion (L8.. conIamilalion
Is left orHi18), a mi8w of 1he I8III8dy will need .. be cxnb:IBd
every five years In accordance wiIh CERCLA Section 121(c). 1his
review process wII contiu every five )'88lS l11li lie c:IIIarIIp goals
. for the Identified contaminants ~ the soli are adIMd.
If no action Is taken m9afion of contarnhInIs tam the soB 11m lie
II1derIying aqIifer In 1he vidrity of fie wasI8waIBr nann lagoon
area wil contiu. 1his migration resUIs fnIm lie natInI movement
of precipitation (e.g., rain anet meIIed snow) moving tI1IUj1lhe solis
and c:arryiIg fie contamination downward as Ihe predplation
recharges fie aqUfer. TIis migration force does not exist ~ MIa 2
as lis area Is covered wiIh c:oncr8B bIiIcIng focIIdaIions and
asphalt ctiv8ways. These strudIns pnHIit pI8Cipitation tam
percoIaIi1g k1tD 1he iIIdertying solis. 1hInfore, aI ~1aIion
becomes u1ace MOil which Is conIroIIed by lie slope of lie
asphalt driveways and b cubs Idt anxn:I b asphalt ~
Swface nmft Is dir8dBcI inID unps wtwe fie watIIr 18 pIInp8d ..
the wastBwat8r Ir8atment lagoons. AIIhoIq1 AhBmaIiv8 $1 does not
actively recb:e or eIiminaI8 soli contamndion, It Is antqDd that
the Ie't'8Is of 1,2-<1ch1oroe1hane wiI decrease over time u .. ..
process of na1InI degradation.
There are no IrItiaI capital costs tor AbBmative $1. ArruII operdlg
costs are based on conducIi1g periCIcic mcriDring of lie soil ~
order to prepare Ihe five )'881' review every five )'88lS for a period of
30 years. As pari of Ihe he )'881' review, sol samples wi be
coIIectBd for chemical analyses once every five )'88lS ~ boIh areas.
ArIa 2 anetlhe was8Bwat8r lrealment lagoon area.
ALTERNA11VE S2: - NATURAL DEGRAlJATDi AND tmmITIONAL
Camr:Jc.s
CapiIaJ Casts:
ArnJaI ~ & MaiUlIIIIC8 Costs
Fist Year.
Second Yew:
TIIid Y81JI ani LaIBr:
Present WarII ~ & MaD..1Ce Costs:
TOIaI PresenI WOI1h COsts tor 30 YellS:
Tine D DesVt
CansN:Iion Tine:
D&nIiIIn.. Ad1IM ~
$196.000
$ 4.000
$ 0
S 0
$50.000
$246,000
3 monIIs
1 monII
. CMr 30 J8III'S
NaUaI dIVaddon Illes an naIInI pacesses .. desRy ..
CCIIItamiII8II15 preserj. T11e most CGIIIIIOn dIVaddon process Is
1he red of rnIcROIgaIUms (bacIBrta, bVJs. ft.) present ~ ..
sol using .. CXIf8nhr1Is as an energy (food) SOIR8; hnby,
destroying lie ClAlI81iIalL T11e presellC8 of 2 d8naIs at lie
SiIe, cNoroehue and W1yI c:NarIde, neither of which were used at
IIis NSCC facility, Is a strong RIcaIon that 1,2-c1ctDoet1a111t Is
being nlSformedvla naIu'aI depiaIion proc:ess(es). 1I1e rata and
8fIBctiv8ness of lie natInI depiaIion process Is dependent an a
runbar of enviomIenIaI tactDrs, such as IIJIrient avaIIabIity. soil
moisb.n conIBrt. presellC8 or absence of oxygen In the sol, S.
Using _shed IIfonnation. Ihe foIowIIg depiaIion rates were
esIInalBd: In leSS than 10 years. lie CCIIlC8tdJalion of 1,2-
cidD'oeIIaJlIt shoUd decrease .. .. cIrect contact health based
risk concelltuDol1 of7 mDsPms per~; ~ less than 21 )'88lS
1he CCIIlC8tdlalion of 1.24ct11oroe1haJ1It shoUd dec:r8ase .. 169
mlcn9ams per 1cIogram. lie CCII_dllaL111at can rerran In ..
I0Il but not adversely Impact lie quaIty of .. II1dertyi1g
gnxnIwaIBr aIIove Ihe pertonnance standard tor 1,24ctDo-
ethane: 8Id ~ approximaIBIy 35 years. .. CCllMlidlation of 1,2-
dicNoroetIaI. In the sol 8hcUd II8Ch a CCllMllcllaIion of 1
microgram per 1IIcIpm. n estimaIId that It wiI recpre over 130
JI81S of pu'llpiIg lie gRMntwaIBr, as reqW8d by OU 13, ..
I8III8CIaB the ~ to .. specified MAR of 1 microgram
per 1tBr. .
As part of lis allel'na6we, a biocIepiati\'I study will be concb:ted.
Ttis stufy wi (1) confirm that natInI dI9adaIion In tie sol is
0CMIng and (2) ascertain If ~ wi reMe Ihe soli
contamination cUIng remecIaIion of OU 13 ~ m a level
1hat wit not cue an exceedaJlC8 of lie au 13 ~
c:IearI4) goal ~ the event that natInI dI9adaIion Is occuring at
an aoc>tptatIIe raIB. I1en the data tom the biodegradaIion SIIIfy wiD
be used it Ihe CERCLA SecIion 121 (c) reqUred s-,&arf8view. Will
1he compIIttion of .. 0V8Ihead pipeline In February 1994, no
8Ici1ianaI canlamilation shoUd be am; Ihe sols beneaIh ..
Area 2 tddng. Based on lie ~ dscussion above. a
aDsaIIiaJdecreaselnthe CClfMllcllclllonof 1,2~ ~..
soil stmd be obs8Md over lie next severaI)'88fS. In lie event
1hat .. COIundlaiioo of 1,2«t11oR1e1hal1lt ~ Ihe sol does not
decr8ase as~Mlj.aCCII._remedy~ofanaclive
101 remecIaion 8BCtdllogy (such as descrIIed In AItBmaIve S3 or
S4 below) sIBIl be ~ m achieve .. recb:Iion of
-------
contaminant IBveIs that wWd be protBc:tiw of the cpIity of the
IRIerIying gRU1dwaI8r.
Institutional controls n:tuII8 using various COI'IRIs and deed
resn:tions. The spec:ific instituIionaI conroIs COIISid8IId for !tis
. ahBmativ8 8r8 1) using and rnaIrIIaiq the existing IIInc8 8RUId
the pIart opeIdons araa to ImIt access to the caramInidBd 8nIIS;
2) periodc i1spection and malrEnance of paved ar&as 8atI1dNu
2 ID Ins&n the kIIBtfty of lit cap over tU 8188, and 3) a deed
resaidIon ID conInII bII8 land use of the NSCC property. The
deed resIrIdIon wi contai1lar9age to accomplish the foIowkIg
feu objedives: 1) ID InIDnn Itf'/ potIInIIaI buyer of the property of tie
contamiIJdon pr&sert. 2) restrict "*" land use wtidI woci:I
decrease the Ikehod of Iunan tXpOSII8lD conIaI1'dIl8f8d sols, 3}
to pevent hllnstaIaIion of a potable well at the SiIe dthe IMIs
of contaminaIion In hi pnIwat8r "* ht SItB ar8 dBemed safe,
and 4) to pr8V8t1t excavaIon In COI1IImInal8d soils wiIhcU sufIcIent
personal po18dio.n for the worIcIn. The dabIe deed I8AIdian
. shall be I8CORIed In hi approprIaIe COII'4)' res;strafs oIfice.
ALTERNATIVE 83: SOL VWR Emw:noN wrTH FUME
INcINERATION AND ACTIVATED CARIKJN FLTER ro CCtma. SllSSICWS
CapftaI Costs:
ArnIII Operating & Mai1t8nance Costs
First Year:
Second Year:
TtIrd Year and LaIBr:
Present Wort! Operating & Main8anance Costs:
Total Present Worth Costs lor 7 Years:
Tane to Design:
ConsIruction Time:
EUaIion ID Achieve Clean-up:
$2,881.000
$ 507.000
$ 416.000
S 416.000
$2,394.000
$5,281.000
9 monl1s
3 monl1
Over 7 years
1Iis aItBmative wiI rernow wIatiIe organic c:ontaminanIs by means
of vapor exIracIion weIs Installed In tie soil above the waIBr table.
A prelinilaty design lor ArIa 2 suggests a system of 10 horIzanIaI
soil vapor extraction wells aiDed IIIderneaIh the IxiIIings and
ctiv8ways. 1hese 10 extraction wells wi! remove a IDtaI of 1.300
cubic feet per miUe of contamiIlaBd air. The preirninary design for
the wastBwa18r natment lagoon area supsts a systBm of SMn
vettieal extraction wells remomg a IDtaI of 20 cubic feet per mirIIIe
of conIaminafBd air. The extradBd c:ontamInaIed .. from ArIa 2
woWcS be nacs using tine Inchration ID destroy the voIaIIe
organics prior to the air snam being released kilo hi atmosphere
and hi extrad8d conIaminafBd .. from the lagoon area wNd be
tr8ated using vapor-phase ac:tivDd cartIon adsorpIion liters ID
rernow the wIatiIe orgri:s prior to hi air Sham being I8Ieased
inID the afmosphere. The contaminanIs c:apU8d by the vapor.
phase carbon fhn wUI be desIroyed ~ the thermal
regeneration of the used activated carbon at an off.siIe, commercial
regeneration facility. RemecIdon of hi sol in ArIa 2 and tie
wastBwat8r trBaIment lagoon area Is expected ID be complOd
wieIn 4 ID 7 years and 1 ID 2 )'88fS. respectively. A
reviewJassessment in accordance to CERClA Section 121 (c) wocif
be petformed ID verify. flat the soli vapor exnction SysI8m Is
proceecIIIg as IIdqIaIed or accomplshed the spec:ified cIearq)
goals that wit be stiR!lIated in 1he Record of Dec:isian.
ALTERNATIVE Sot: SOL VAPOR ExTRAcnoN WITH AcnvATED
CNIIm Fl.TER ro CCtma. BlISSDiS
Capital Costs:
ArnJaI 0peraIing & Mai1tenance Costs
First YB:
Second YB:
TIird Year and LaIBr:
Present WortI 0peraIng & MainlBlIaIIC8 Costs:
Total Present Worth Costs for 7 Years:
TnlD DesV1:
ConsWcIion Tn:
Dwation ID N:tiJNe Clean-up:
$2,918.000
$3.353.000
$1.566.000
S 475.000
$6,270.000
$9,188.000
9 monlhs
3 month
Over 7 )'IllS
11is aI8BmaIve Is ldenblto AIIBrnatiw S3 wit1 f1e exception that
the extradBd contaminatBd air from both areas woUd be b'eatBd
using vapor-phase actiYaI8d carbon adsorption liters to rernow the
wIatiIe organics prior to the .. S1ream being released kilo the
a1mOsphere. 1£ before, the contaminants capILIed by the vapor-
phase cartIon fillers woUd be destroyed at an off-sile, commercial
regeneration facIity.
CRfTEIIA FOR EVALUATING REMEDIAL ALTERNATIVES
The selection of the preferred cIenp alternative for the NSCC OU
14, as deSCribed in this Proposed Plan, is the reUt of a
comprel1ensiw screri1g and evaklation process. The Feasibllty
Study for OU 14 was c:ondUc:8d ID identify and analyze f1e
ahBmativ8s considered for adchssing contamination in Area 2 and
the wasIBwDr trea1ment lagoon area. The FeasHty Study and
other docunenlS for the NSCC OU 14 site descrb, in detail. f1e
dm1atives consider8d, as wet as f1e process and crheria EPA
used ID narrow the 6st of the polBntial remeclal aIIematives ID
adchss hi sol COI1Iamination in llis portion of the NSCC facity.
M stated previously, aI of f1ese docunents are available for IUiC
review In the infonnalion reposilDry/aclmirislrative record.
AItBmativ8 S5. Bioventi1g was not retaI1ed a the detailed analysis
because tis aItemaINe does not provide any appreciabIB
Improvement in I8CU:tion of risk or other performance meastnment
over either NIemaIve S3 or S4.
EPA always uses f1e following nine c:rit8ria to evaluate aItsmatives
lden&fied In f1e FeastiiIy Study. The remedaI aJtemaIive seIecIBd
for a SupemnI siI8 must achieve the two heshoId criteria as well
as attaI't the best balance among 1he five evaluation cri1Bria. The
rme c:riIeria are as follows:
THRESHOLD CRITERIA
,. Overlll DrOIeCtIon of hwnan health and the
environment: The degree to which each alternative
elinina1es, f8duces, or conb'oIs threatS to pubic health and
the envirorment ~ treatnent, engineering methods or
insWionaI c:onIrOIs. .
A
-------
2. ConIIIIance WIlt! AIIDIIcIbIt or RIll. II ...
AIIDroDrtate AecadIIn8IIs (AAAAs): The abBmaIiveslU8
evaJuaBd tor complance wII'I aD staIB and federal
envirorInentaJ and pU:IIic heaIt1laws and requiemenIs that
apply or IU8I81evant and 8RII~ to the sIB COId"'~
EVALUA1IG CRITERIA
3. Cost The benefits of In.mtllillQ . p;IIt/cUar r&mecIaI
aItIImdve IU8 W8ipd agak1st the cost of /nJpIemenIaIorL
CosIs Include the capital (..,.) cost of ~lillY 81
aIIIImaIve 0Y8r tie long term, and.. net presertworth of boI1
C8IIi1af and operaIIon and maiII8nance COSII.
4. IIImIem8ntIbIJt EPA COIISider5.. Bc:tI1Ica/ feasIIIIity (8.Q.,
how IIfticUIthe aItIIrnaIw Is 8D construct and operam) and
IdnWsnhe ease (e.g., the 8IICMI1t of coordiIlIIioiI wIIh other
gcMmII8nt agencies flat Is needed) of a remedy,lncIucing ..
avaIIabIity of nIICBSSaIy maIBItaIs and senIces.
5. ShorI-I8nn tffecIIv8n8ss: The Iengt) of line needed 8D
Implement each aII8mative Is consider8d, and EPA assesses
the risks that may be posed 8D workers and nearby I8SIdenIs
. cUi1g consIrucIion and /rnpIemenIaIon.
6. LanIHenn tffecIIv8n8ss: The aIIamaIives IU8 eva/uaIBd
based on thei atJIiIy 8D mai1IaiI reiabIe protection of pU:IIic
heaIII and the env/rom1ent over time once 118 c/earq) goals
have been met.
7. ReirucaCli of cantlmlnant IaIIcfty. rnobIIJty, ... vohIne:
EPA eva/ua!8s each aIBnatiYa based on how It nICU:es (t) the
haanfU na1In of 118 contarnllanls, (2) .. abIity 8D move
~ 118 environment, and (3) 118 YOhIne or 8I1ICUIt of
contamination at.. sII8.
IIODIFYING CRITEfIA
8. State 1CCIDIanc:e: EPA r&queSts staIB commenas on ..
RemeciaJ mestigalion and Feastiity Study I'8pOI1s, as well as
118 PrQposed Plan, and 111US11ake inID consIderaIion whether
the state conc&I'S with, opposes, or has no comment on EPA's
prdmd aIBnatiYa.
9. CormuIJty 1CCIDIInCe: 10 trISII8 that 118 petie has an
adequaIe opportriy to provide qIUt, EPA holds a pU:IIic
comment period and considers and responds to aD conunents
received tom 118 commriy pi« to the final seIecion of a
remeciaJ action.
EVALUATION OF ALTERNA11YES
The foIbwIng lUllmat)' profIes 118 cornparatiya analysis of the feu
ahBmatives In terms of the line evaluation criteria:
Overall Prol8c:1loh: All bJ'aIIIImdves, St, S2, S3, and S4 88
upedBd 8D provide Iong-tBrm ploBc:tUI tor tunan heaIIh and ..
env/nnnent n ~ wIIh the OU 13 I8IIIecIaI acIion.
However, Mmdiv8s S2. S3, and S4 wiI provide piQl8Ction, more
quIc:IcIy. fRm expos&I'8S to conIami1al8d Rbuface soils. Of f1ese
Itne aII8maIiwts, AI8maIives S3 and S4 wi afb'd .. pdest .
plfI~'. 8D JulIan heaIIh as I1ey SIbsIantiaIIy I8Ue ..
contamillllt5 In the soil wItin 4-7 years of IniaIion of ..
ahBrnahes. Lbier AIIBmaIMts St and S2, COI1lai18.ilMls IU8
-*'PaW 8D cI8c:r8ase as a rBS&It of nauar degrada!iorL
AhBmaIi-- S3 IIId S4 protBct .. envI'orment by ~
conIamInants tam the soil, IhenIby e&nIIdv 118 potBnIiaI for
IIIVdon of conlaml.... to~. In corjn:Iion wIIh 118
au 13 ~ I8fII8diaJ acIon, AI8maIives St and S2. wi!
also be prVI8cIve of the envIraatt. TIU prol8ctiu.. SlBms tam
the faIowrng facIDrs: 1) II COIItaI....aI8d sols 118 wIIt*1 ..
~ pUne being I8m8Cia!8d by OU 13. 2) .. OU 13
I8I1I8CIaIion wi pI8V8rt the spread of conIamlnanls and remove
COIIIa..IiI..tom...~. and 3) soB conIamhanlsstllUd
be ndad by nauaJ prace$S8$ wItin the IImeframe I8CJinJd 8D
camp/et8 .. OU 13 grocntwatsr remecIaIiorL AIIBmaIive St does
not provide short tBnn plDIedk,n for tunan heaIIh. howev8r. as
discussed previously, 118 She does not pose an INCC8ptab/e risk
LIIdIIr 118 CII'I8nt use scenario.
ConIIIIIncI willi ARARs: M long as tie sols IU8 left n place
(I.e.. not ercavatad), no Federal or StaB ARARs for contaminants
In sols 118 trWncl Allematives S3 and S4 wII c:ompIy wi1h
adion-spedficandloc:ation-spec:ARARs wtich Include operations
at a hazardous waste sII8, dsposaJ of used activated carbon as solid
wasIII, and air emission c:onb'oIs. AIIemaIiv8 S2 wiI compIywitllle
focaIion..speci MAR ruIat8d to operations at a tmardous waA9
siIB and Ihere IU8 no actioMpec:ific ARARs IhaI apply 8D tis
aI8Bmatiwt. No ARARs were identified for AIt8matiw St as no
action is beng taIc8n..
LanrHerm Eff8cIIveness Ind fJInnanence: AIIBmatiYes S3 and
S4 wit provide etrecM and permanent sokItions lor ..
cOlltamiuaBd sol. The chemicaJs of concern w/I be I8I1IOV8d tom
the sol by the sol vapor eXlradion sysIem and desIro)'8d. NeiIher
aI8Bmatiwt wl!1eaw any lr8a1ment resicbds on She. The reIabIity
of bo1hAltematives S3 and S41s tIg1 because by rely on proven
and appIicaIIIe IBCb IOIogiR and the extent of b c:onIaminalion is
I8IatiwIIy well deIi1ed. 'The reIiabiity of AIIemative S4 is tIpr bin
AIIemative S3 because ofb mainIenance problems associaIBdwi1h
the tine IIICillel'a8Df. AItematives S1 and S2 do not cInIc:tIy f8IIIove.
treat, or IsoIa8 IU8Iface conIaminants; 1Befor8, IIey 118
comparable In tBrms 01 r8Cb:ing potential resicUIJ risks. HowewIr,
contaminant levels shoWS gracisIIy decr8ase 8D levels IhatwoWf be
protBctiye of groc.ndwatsr quaity cbI to naI&nJ ~
pr1)C8S$8$. The Ime r&quied to reach tis concenIration faIs well
wIf1in tie OU 13 gro&I1dwaIer l8IIIecIation timeframe (estimat8d 8D
be t30 ~). AII8maIMt S2 nvoJves IonQ-tenn Institutional
c:onIroIs 8D pI8wnt fuILn expoues to samrtace soils as well as
b_ofthe~~~the~~~.
The projeded adequacy and relabilty of these controls depends on
land -, bur shcUd be r&IaIiYeIy ,. because tie /mpac:IBd area
Is sma//, wiIhn b plant bcuIdaries. and land - is not expec8Bd
to chaI9t. Sol moritDItIlg and periocic reviews at fi¥e1ear In8InaIs
-------
wl be recMred for al three alternative: t tie duration of
performing such reviews for Alternatives SI and S2 is expected ID
be much longer. The long term effectiveness and pennanence of
Alternatives SI and S2 are dependent on fie rate of degradation
and effectiveness of tie OU*3 remedal acfon,
Reduction of Toxteftv. MobPtvor Votorm: Bctt Alternatives S3
and S4 actively reduce the toxfcty and mass of contaminants h tie
soi. Trite is accompishedtfroi^^ removal of fa cortantinarte
tan to sot via to sol vapor extraction system Mowed by fume
Incinerator or tftethennalofrstructta of cortan^
carton fitter. NsHhar Aterrafve Slnor S2 dredy reduce tie
toxJcfty, rnotxlty, or volunie of contaminants through an engineered
treatment process, but reduction due to natural processes is
expected to occur wel wflrti fie fme period required for. and in
conjunction wMi the OU13 groundwater remedfetion.
ShorMerm Bfecttventss: There are no short*
; posed to
site workers, Vie general pubfic, or tie environment associated wHh
eftw Alternative SI or 82. There are mWmal shorMerm risks
associated with Alternative S4 which are primarily due to general
safety issues associated wtti the construction of the son vapor
extraction and air emissions tBatment systems, kiaddffiontorisks
assodatedwWi Alternative S4, Alterative S3 as two addBonal risks,
maintenance problems associated with the fune incinerator and (he
rtandfing of hydrochloiic acid generated by the scrubber associated
wHh the Incinerator. Potential risks could also exist during tie
operating period, especially workers exposure to fugitive vapors. I
ether the carbon adsorf or fume incinerator/scrubber systems
malfunction, temporary volatie organic emissions woukf be
controlled and minimized through properly instated monitoring and
control processes. Surface runoff during construction, as for any
construction project would be controlled to protect nearby surface
waters.
Alternative 51 requires no implementation.
Alternative S2 will be easy to implement because Bute to no
construction is required. Both Atemafives S3 and S4 are projected
to require approximately 12 months to design and construct and
approximately 4 to 7 years of operation.
Total present worth costs for tie sols alternatives are
presented betow:
AttemafiveSI • No Action: $ 199,000
AtemativeS2 • Natural Degradation and
Institutional Controls: $ 246,000
Alternative S3 • Soi Vapor Extraction with Fume
Incnerafion and Activated Carbon
Rtter to Control Emissions: $5,281.000
Alternative^ • SoB Vapor Extraction with
Activated Carbon Fatar
to Control Emissions:
$9,188.000
ERA'S PREFERRED ALTERNATIVE
After conducting the above detailed analysis, EPA is proposing tr» folwwig alternative to aotfress tte «
2 and tie wastewater treatment lagoon area. The EPA preferred sofl remedfetion alternative is:
ALTERNATIVE S2: NATURAL DEGRADATION AND INSTTTUT10HAL CCMIMU
Based on currert information, this alternative appears to provio^t» best oalance of trade-offs v^ respect to the nine cM
EPA uses to evaluate alternatives. EPA beleves the oreferred alternative wil satisfy the statutory requirement of Section 121(b)
of CERCIA. 42 USC 9621(b), which provides tat t» selected alternative be protective of r^nan health arid tt» environment,
COTpry wan ARARs.be cost effedrve, a/id utfizepeni^^ The
selection of the above alternative is preliminary and couW change in respc«se to pubfc comments.
As this alternative refes on natural degradation to dean the soils, NSCSwfl be retired to substantiate (hat naiu^
Is occurring, identify where In the subsurface the degradation is oceurmg, and ctetemre Iterate of ctegracftm The cdection
of this data via Ihe bkxtegradafive study wB begin after record of r^cision for OU 14 is signed.
h the event that the bwdegradafive study data caniot substantiate fte occurrence
-------
.t
COMIIU.tI1'Y PAR11aPA11ON
EPA has developed a commllity raIaIIons propn as mandat8d by COI9'ess &rider ~ to I8SpOIId » ciliz8n's concerns and needs
for InIonnation, and » enable residents and rdiC officials » partc:ipatB in the dedsiarHnaIdng process. NIle InvoIv8ment activities
II1der1ak8n at ~ sII8s consist of InIBI t'I8ws wIIh IocaII8Sid8nIS n eIect8d otIiciaIs. a COIIIIIIdy reIaIans plan for each siIe. fact
sheets, avaiabiity sessions, IX.tiic meetngs, IX.tiic comment periOds. newspaper advertisements, site visits. and Tec:hricaI AssIstance
Grants. and any other actions needed ~ k8ep the canmunty Informed and i1voIved.
EPA Is c:ancU:ting a 3CHIIy pIMc connnt pIItod flam Ny 12, 1.. 10 AuguIt 11, 1'" to proWte an opporUity for p&jIIic
Involvement In S8Ie*g the final cIe8q) metIod lor tis SII8. N)IIc qu on aD aII8rnaIiv8s. n on the WonnaIion 1hat ~ tie
. aIBmatiws Is an mportant c:anIrIbuIion to tie l8medy seIBction process. EUt1g tis comment period. the puIIIIc Is InvIt8d » ItI8nd .
IUIIIc IIIIIIIng an AugUit 3, 1993, It the AgrIcIftnI Emuslon CInIIr AucI1DrtIlll, mT Old ConcanI RoId. SIIIatuy, Nanh
CIrDIIn8 beglmng It 7:00 p.m. at wI1ich EPA wi present hi Remedal i1vesIigatioW FeasIbiity Study and Proposed Plan deScribing hi
preferred a/Iemative fortnmnent of the c:antanIIrDd sol at I1e NSCC ~ SiB and» answer any questions. Because this Proposed
Plan Fact Sheet provides My a unmary descripion of hi dearq) aII8matives being cansider8d, the p&Mc is enccuagecI ~ cand hi
Information reposiay lor a more de1aIed explanation.
Dlring this ~y comment period. I1e rdiC Is iwhBd ~ nMew aD si8-reIaIBd doaInents housed at the iIfonnalion repository IocatBd
at1he Rowan CcxI1ty NIle Library. 201 West FISher snet. SaIistuy. Nor1h Carolina and otfercammenls" EPAeilherOl3lly at the p&jIIic
meeting or in writI8n fonn ~ tis time period. 1hB ICUII remecIaI action ccUd be dfIBrent from the pteferred ahemative. deperdng
upon new information or stUlmenls EPA may r&c:eive as a I8Ut of p&.ti1C cammenIs. . you prefer ~ SI.tImit written camments, please mail
1hem postrr\al1(ed no later than micnght August 11. 1994~:
DIInI 8Ifr8tf
NC CDmnuIIty RtIItIons COGrdlrIIfDr
U.s.£PA., "."",4
Notfh 1IImedIII ~ IIr8nt:h
SfS CoIItIInd SIIIIt, NE
AIMfI, GA 30365
~
All cammenls wII be r&viewed and a response pr&par&d In maIdng hi InaI cIeBrmination of 1he most appropriate aJIernatiw for
~ of 1he Sits. EPA's final chaice of a remedy wi! be Issued In a Record of Decision (ROD). A docunent c:aI8d a
Responsiveness SurnmIry runmarizllg EPA's response ~ aD p&jIIic cammenIs wi also be issued witt the ROD. Once the ROD is sipd
by 1he Regional Mninistraa it will became part of the Mniisntive Recard (bcatsd at the Lbary) mdI contains aI docunenIs used
by EPA In maIq a final detBrmlnation of the best c:IearqI.baImen lor the Site. Once the ROD has been approved. EPA wi begin
negotiations witl1he Pot8nIIIIIy R8spansIbIe PIrIIII ~ allow him tie opporI1IIty to design, mplement and absom aD casts of the remedy
detennined In the ROD In ac:carcIance with EPA gIidance and pmxaI. . negotiations do not red in a setIemert. EPA may CGnIb:t hi
remecIaI activity using ~ Trust mories, and sue for r&imtusemenI of Its casts with the assisaa of the Departnent of JusIic:e.
Or EPA may Issue a riaI8raI miisntive order or cbcIy fie &&it to force NSCC ~ c:oncU:t the I8III8cIaI activity. Once an apmIent
has been reached. the design of the seIedBd remedy wit be developed and implementation of the r&medy can bE9n. 1hB prececJrIg actions
are 1he standard procecUes utilized cUi1g the ~ process.
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As part of the Superfund program, EPA provides affected communffies by a Supeffund stej»«h the opporturity to apply for a Technical
Assistance Grant (TAG). This grant of up to $50 .000 enables flie group to hire a technical aoVisor or consultart to assist them in interpreting
or commenting on site findmgs and proposed remedbl action plans.
For more Wonnafion concernirig this grant program, please contact Ml ftosmvy Pttton, CoorOnttor
AC TMftflrca/ Assistance Grants
WtstfMtntgemtntDMsion
345CourtJtnd$tn*,NE
Atttn*,GA30XS
(404)347-2234
INFORMATION REPOSITORY LOCATION:
Rowan County Puttie Library
201 Wast Fisher Street
Salisbury, North Ctroflni 28144
Phone: (704) 633-5578
Hours: Monday-Frtdiy 8«Oaja-9.-00|un.
Saturday 9HX)am-5K)Opjn.
FOR MORE INFORMATION ABOUT SITE ACTIVITIES, PLEASE CONTACT:
Mr. Jon Bomholm, Rmwflal Project Manager or
Ms. Diane Ban«t,NC Community Relations Coordinator
North Superfund Remedial Branch
Waste Management DMston
vbonmental Protection Agency, Region IV
345 CourUand Street, NE
Atlanta, Ga 30365
ToO Free No.: 1-8004354233
UA1UNG LIST ADDITIONS
If you are not already on our maSng 1st and would Be to be placed on the 1st to receive future information on the National Starch
& Chemical Company Superfund Site, please complete this form and return to Diare Barrett Community F^twns Coordhator
at the above address:
NAME:
ADDRESS:.
CITY, STATE, ZIP CODE:
PHONE NUMBER:
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GLOSSARY OF TERMS USED M TMS FACT SHEET
Aipjtfor. An underground geological formation, or group of formations, cwdctining usablo amounts of groundwater that can
supply wels and springs.
Record: A fte which is mabNalned and contains alinfomialion used by the bad agency to note
tosetecfiontfanietiodtobeublzedtodeanup/frBatconta^^ This Safe held h In information
reposaory for pubic review.
Tte
must attain. These requirements may vanr among sites and various altemafves.
Btstint KslcAsstssnwntA means of estimating the amount of damapje a Superfund cle could cause IP human heath and
(he environment. Objectives of a risk a^sessnient are to: tatoobtermlitt to medfw
chemicals that can remain on tie tfe after cleanup and stffl protect heaiti and to envtonnertf; and provide a basis for
comparing diOMMit ctetnup methods.
QvtftM0in:Any substance that can cause or contribute to to proeteta of careen cencer-proobcirig.
irfts^^
mcxffied in 1986 by to Superfund Amendmerte arid The Acts created a special tax paid by
producers of various chemicals and ol products tat goes into a Trust Fund, commonly known as Superfund. These Acts give
EPA the authority to investigate and dean up abandoned or uncontrolled hazantous waste sflesuodngrnoney torn the
Superfund Trust or by taking legal action to force parties responsHe fortocortaminationtopayforandcleanuptosite.
fins/Wry Stooy Refer to Remedal InvestJgatiofVFeashlty Study.
CmunOwxtar. Water found beneath to earth's surface tat Os pores bet»i(eenrnalBrials such as san4 sol. or p/avel (usually
in aquifers) which is often used for supplying wels and springs. Because grounoVralBr is a major source of drinking water ihere
is growing concern over areas where agricultural and inoWrial pollutants or substances are ge^ into grounds
Htardous RtnUng Systam (HRS): The principte screening tool used by EPA to evaluate risks to pubic health and the
environment associated with hazardous waste sites. The HRS calculates a score based on to potential of hazardous
substances spreaolng from the site through the air, surface water, or greoidwater and en ctor factors such as nearby
poputefion. Trfe score is to primary factor in decking if the site should be on to NafionaJPrion^esUstaM if so, what ranking
rt should have compared to otor sites on to Ost
tofomitton Repository: A He containing accurate up4o-c^ inferrnafion, technical t^
about to Technical Assistance Grant, and any other materials perinent to to site. This fie is usualy located in a pubic
building such as a fibrary, city had or school, that is accessible tor local residents.
of pollutants into waters of to inked States unless a special permit is bsued by EPA. a state or (where delegated) a «al
government on an Indan reservation aBowing a controled olscfBuge of lo^ after ft has undergone treatmert.
Nftfont/ Prtcvftfes Ust (NPL): EPA's 1st of to most serious unconMed or abarxfonedtazardous waste sites identified lor
possible bng4erm remeolal acfion under Superfund. A site must be on to NPL to receive money from to Trust Fund for
remeolal action. The 1st is based prfmarly on to score a site receives from to Hazard Ranking System (HRS). EPA is
required to update to NPL at feast once a year.
Op0oMf Unit Term tor each of a number of separate actrvtesunofcrtaken as part of an overal Superb
prtentialyresponsfctefor.circcrtrib^ Whenever possible, EPA requires
Potenfialy Responsible Paries, through administrative and legal actions, to dean up riazantous waste sfiesFvtentialy
Responsible Partes rave contaminated.
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".",..., AI:fIon 0IIJ«.1IWr.1hese are specific ~ which are Identified t) poBct bo1h tunan heaIh and 1he
envinnnent that IaIc8 rm COIISidBraIon 1he envinmIenIaI mecIa Wlda.lillded fLl.. gnMI1dwat8r, soB. ufac8 waIBr, secinerf,
or Ii) and tie contamiIlaIU presert In each medUn. The main goal of .. objec:Iives Is t) prevent exposn to conIaminanIs In
~, sol. sufac8 waIBr. secImert. or air In excess of rIsk-based tunan health or envIrorIIIenIaI stand8dS.
"",.", ~..." (1I/FS):1be RemecIaI hwIsIigaIion Is an irHJepI1, 8XI8nsive sampIi1g and analytical
SIudy to gat'I8r daIa necessaJy t) dBI8rmht .. naIIn and 8JIIIIt of canlamlnalian at a ~ sII8; ID estabIsh aiIIIrIa far
c:Ie8Iq &4) "Ihe; a d8scItpIon II1d nIysis of .. poIBnIiaI c:IIIrq) aIIBmIdIv8s tIr r&mediaI actions; and ~ ..
tsdricaI and cost ar8yses of .. aIaIImaIIv8L The r"'i SIudy also usuaIy recommends seIecIion of 8 cost-eft8ctiv8
ahImdv&.
RtCOId 1/1 DIdsIan (ROD): A pM: cIocunert hit 8IIW1C8S and ... wti:h meIfI)d has been seIecIBd by the AfIJltf to
be used at 8 ~ slBlD clean &4) the canlamRdian. .
Rerpanst~ SIIIJn8y. A IUIIINrY of oral and wrbIn IUiC cammenIS I8C8iv8d by EPA cbiV a p&Mc comment period
and EPA's I8SPOfIS8S ID those COIIIIII8IIIS. The responsiveness SIIIIII8Y Is a k8y part of.. Record of DecisIon.
Slml-V.". 0rpnIc CanpuJdI fSVOCI): CaJtIon.conIaii chemic:aJ compcMnls hit, at a relatively low temperatIn,
,. t'u:IuatB between a vapor staIB (8 gas) and 8 IIPd staIB.
Vidast Sol ZeN: Is Ihe &nIaIiIaBImne of sol starIiIg at Ihe uface and encIng at .. wa!8r IabIe 0.8.. .. space belween
Ihe soU particles contains both waIBr and aIr).
VoIItI1I 0tpJIc CanpuJdI (VOCS): My orgaric compcxn:Ithat evaporaI8S readIy Into Ihe u at room temperat&le.
W".,. Tlblc The level below whIc:h Ihe soil or rock Is SidircdIId with water, sometines refemId to as Ihe ~ StIface 0' the
satIIated zone. The Jew! o,~.
.. ,
. - .. ~ . .
-------
. ""-- --"_.
. ... .- - .-p
ft
=
A"""n4
u.s. EnviranmIIUI PIWcdon AQtney
$65 CaurtIIIIIIt su.t, U.
AII8nII, Georgia 30315
Ollie. 8uI~
Pelllly for Priv.. "" $300
NorIII ~ R"" BnncII
Di8r., lima, CcInIIIdy ........ C:-dinIIw
... BomIIDIm, R8cnIdiII Project .......
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APPENDIX C
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION
FOR OPERABLE UNIT #4
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
SALISBURY, ROWAN COUNTY, NORTH CAROLINA
Based on Public Comment Period
July 12 through September 9, 1994
Which Includes July 26, 1994 Public Meeting Held In
Agricultural Extension Center, Salisbury, North Carolina
Prepared by:
U.S. Environmental Protection Agency, Region IV
September 1994
-------
RESPONSIVENESS SUMMARY
OPERABLE UNIT #4 PROPOSED PLAN
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
TABLE OF CONTENTS
SECTION
PAGE No.
1.0 OVERVIEW........................................... A-1
2.0 BACKGROUND........................................ A-1
3.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/
STATEMENTS VOICED DURING PROPOSED PLAN
PUBLIC MEETING AND RESPONSES. . . . . . . . . . . . . . . . . . . . . . . . . A-3
3.1 OU #1 GROUNDWATER EXTRACTION.... . '" ..... . . . ... A-4
3.2 NOISE LEVEL ASSOCIATED WITH THE SOIL VAPOR
EXTRACTION SYSTEM. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-4
3.3 DEED RESTRICTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-4
3.4 REVISION OF OU #3 GROUNDWATER REMEDIATION.
TIMEFRAME . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. A-5
3.5 AVAILABILITY OF JULY-AUGUST 1992 DRINKING
WATER DATA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-5
4.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/
STATEMENTS VOICED DURING PUBLIC COMMENT PERIOD. ..... A-5
4.1 DISCONTENT WITH SELECTION OF ALTERNATIVE S2
AS THE PREFERRED ALTERNATIVE. . . . . . . . . . . . . . . . . . . . A-5
4.2 CONCERN EXPRESSED ABOUT POTENTIAL ADVERSE
IMPACT ON GRANT CREEK WASTEWATER TREATMENT
PLANT IF COMBINED WATER TREATMENT NOT FULLY
ON-LINE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-6
4.3 ELIMINATION OF THE NEED FOR INSTITUTIONAL
CONTROLS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-6
4.4 INTRINSIC BIOACTIVITY. . ..... . . . . . . . .. . . . . .. .. . . . .. . A-7
4.4 ANAEROBIC/AEROBIC BIOACTIVITY. . . . . . . . . . . . . . . . . . . . A-8
4.5 POINT OF COMPLIANCE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-a
ATTACHMENTS
Attachment A - Transcript of Public Meeting
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RESPONSIVENESS SUMMARY
OPERABLE UNIT #4 PROPOSED PLAN
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
1.0 OVERVIEW
The development of this Responsiveness Summary is in accordance to the requirement
set forth in 40 CFR 300.430(f)(3)(i)(F). This community relations Responsiveness Summary is
divided into the following sections:
Section 2.0 BACKGROUND This section discusses the Environmental Protection
Agency's preferred alternative for remedial action, provides a brief history of
community interest, and highlights the concerns raised during the remedial planning
for Operable Unit #4 (OU #4, OU#4, or OU4) at the National Starch & Chemical
Company (NSCC or NSC) Superfund Site.
Section 3.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS
VOICED DURING PROPOSED PLAN PUBLIC MEETING This section provides a
summary of issues/concerns and questions/comments voiced by the local community
and responded to by the Agency during the Proposed Plan public meeting. "Local
community" may include local homeowners, businesses, the municipality, and not
infrequently, potentially responsible parties.
Section 4.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS
VOICED DURING PUBLIC COMMENT PERIOD This section provides a
comprehensive response to all significant written comments received by the Agency
and is comprised primarily of the specific legal and technical questions raised during
the public comment period.
2.0 BACKGROUND
The Environmental Protection Agency (EPA) conveyed its preferred remedial alternative
for OU #4 NSCC Superfund Site, located in Salisbury, North Carolina in the Proposed Plan
Fact Sheet mailed to the public on July 8, 1994, and through an ad in The Salisbury Post
newspaper. The ad was published in the July 12, 1994 edition of this newspaper. The public
meeting was held on July 26, 1994 at the Agricultural Extension Center in Salisbury, North
Carolina. The purpose of the meeting was to present and discuss the findings of the OU #4
RemediallnvestigationlFeasibility Study (RIIFS), to apprise meeting participants of EPA's
preferred remedial alternative for OU #4, to respond to any questions or address any
concerns expressed during the public meeting, and to take their comments and make them a
part of the official record. A copy of the transcript from the July 26 public meeting was placed
in the Information Repository for public reading. The Proposed Plan Fact Sheet and the
newspaper ad informed the public that the 30-day public comment period would run from July
12 to August 11, 1994. However, a request was made for a 30-day extension to the public
'comment period. Consequently, the public comment period was extended to September 9,
1994.
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au ~ National Stan::h & Chemical Company
ResponsiYeness Surnmcuy
A-2
Community interest and concern about the NSCC Site has fluctuated from moderate to
high over the past two decades. Awareness of and concern about the NSCC -Plant-, not the
Superfund related hazardous wastes, were very high in the communities which are adjacent to
and nearby the -Plant-. NSCC received considerable news media attention when its Lumber
Street Plant, which is also located in Salisbury, North Carolina, experienced an explosion
which destroyed a section of the plant. In 1984, at the NSCC Cedar Springs Road Plant
where the Superfund Site is located, a production process reportedly boiled over releasing a
vapor cloud containing acetic acid. The vapor cloud reportedly injured vegetation for up to 1.5
miles from the plant.
A 1985 newspaper article indicated there were mixed feelings in the communities
surrounding the plant. Some of the residents believe that NSCC is a responsible company
with an excellent record and that NSCC will work with EPA and cleanup the dump. Other
residents were concerned about the effects on their health and believe their community has
borne the brunt of living near to NSCC. As stated above, the community has maintained a
high level of awareness and concern regarding NSCC as a result of the incidents reported in
the media.
The following provides details on the accumulative community relations efforts
conducted by the Agency. A Community Relations Plan identifying a positive public outreach
strategy was completed in September 1986. As part of this initiative, Information Repositories
including the Administrative Record, were established at the Rowan County Public Ubrary and
in EPA, Region IV Information Center in Atlanta, Georgia to house the Administrative Record
for the Site. The Information Repository and Administrative Record are available for public
review during normal working hours.
Fact sheets and public meetings were the primary vehicles.for disseminating information
to the public. EPA sponsored a number of public meetings and released several fact sheets
to keep the public apprised of current activities, to help the community understand the .
Superfund program and the public's role in the process, and to share information regarding
the direction and technical objectives of data collection activities at the Site. Only a few
individuals from the community attended the Proposed Plan public meeting. In addition to
these individuals, one representative from the news media, representatives from NSCC, and
representatives from various government agencies also attended the meeting.
3.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS VOICED
DURING PROPOSED PLAN PUBUC MEETING AND RESPONSES
This section summarizes the major issues and concerns expressed during the Proposed
Plan public meeting. Five questions were asked during the public meeting. They related to:
.
Is it possible that the OU #1 groundwater extraction system is adversely effecting off-
site potable wells?
.
How loud is the noise associated with the soil vapor extraction system?
.
Will the proposed deed restrictions pertain to off-site property?
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ou ~ Na1ional Starch " Chemical Company
Responsiveness SUmmaty
A-3
Why was the 30 year au #3 RA duration revised to 120 years?
Is the analytical data from sampling private potable wells in July-August 1992 available?
A recount of the questions summarized above, the discussion that revolved around the
questions asked, and the Agency's response can be found on pages 16-48 of the transcript of
the Proposed Plan public meeting (Attachment A).
3.1 OU #1 GROUNDWATER EXTRACTION SYSTEM
This issue had several facets, but to focus the following discussion, the question is
summarized as follows:
0:
Can the au #1 groundwater extraction system, which is now extracting
approximately 130,00 gallons per day, cause the water table off-site to drop and
if so, who is responsible for any adverse impact on off-site private potable wells?
A:
Based on the data presented in the .Ouarterly Report - First Quarter 1994 -
Operable Units One and Two., dated July 1994, the cone of influence created by
the extraction wells extends down to the Southwest Tributary but does not extend
beyond the stream. Since the wells are completed in fractured bedrock, it is
possible, due to preferred fracture flow, that the extractions wells are influencing
the off-site private, potable well. However, the potential is remote. The first
information to review are the construction details of the wells involved. If a
connection was determine, then the Agency or NSCC will need to consider taking
actions to alleviate the situation.
3.2 NOISE LEVEL ASSOCIATED WITH THE SOIL VAPOR EXTRACTION SYSTEM
0:
Will the noise created by the soil vapor extraction system be objectionable to
homes 1 ,500 feet away?
A:
Insufficient information was available to give a direct response to this question.
3.3 DEED RESTRICTION
0:
Will the proposed deed restrictions pertain to adjacent land?
A:
The deed restrictions will only focus on the soils in those areas of Area 2 and the
wastewater treatment lagoon area that are contaminated (i.e., only to certain
parcels of the NSCC property).
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ou ~ National Starch & Chemical Company
Responsiveness SummaJy
A-4
3.4 REVISION OF OU #3 GROUNDWATER REMEDIATION TlMEFRAME
0:
Why was the tirneframe for the operation of the OU #3 groundwater extraction
and treatment systems revised from 30 years to 120 years?
A:
The 30 years was based on remediating the contaminated groundwater to the
maximum contaminant level (MCL) for 1,2-dichloroethane (1,2-DCA) which is 5
parts per billion (ppb). The 120 years is the estimated timeframe to obtain the
performance standard of 1 ppb specified in the OU #3 ROD. The 1 ppb is based
on the State of North Carolina's groundwater protection regulations.
3.5 AVAilABilITY OF JULY-AUGUST 1992 DRINKING WATER DATA
0:
Will the Agency send a copy of it's analytical data for the samples collected from
private, potable wells sampled in July-August 1992 to the well owners?
A:
If available, yes. The State will also be requested to provide any analytical data
the State may have for the groundwater samples collected in July-August 1992.
4.0 SUMMARY OF MAJOR ISSUES/CONCERNS/OUESTIONS/STATEMENTS VOICED
DURING PUBLIC COMMENT PERIOD
This section summarizes the major issues and concerns expressed during the Proposed
Plan public comment period. The major issues and concerns on the proposed remedy for OU
#4 NSCC Site can be grouped into the following areas:
Discontent with the selection of Alternative S2;
.
Partial versus full operation of NSCC wastewater treatment system;
Elimination of the need for Institutional Controls;
Intrinsic Bioactivity;
o
Anaerobic/Aerobic Bioactivity; and
Point of Compliance.
Below is each written comment received and the Agency's corresponding response in
italicized print.
4.1 DISCONTENT WITH SELECTION OF ALTERNATIVE S2 AS THE PREFERRED
ALTERNATIVE
COMMENT #1: A citizen voiced disapproval with the selection of Alterative S2 but did not
identify a preferred alternative.
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ou ... National S1an:h & Chemical Company
Rasponsiv8ness Summary
RESPONSE:
A-5
Of the four alternatives that remained after the screening and evaluation
process incorporated into the Feasibility Study, Alternative 52 is the most
cost effective approach that will ultimately achieve a reduction in the toxicity,
mobility, and volume of contamination present at the Site. However, this
approach relies on natural degradation which has not been substantially
demonstrated as occuffing at Site. It as been assumed natural degradation
is occurring at the Site due to the presence of two chemicals in the
groundwater and soils that reportedly were never used at the facility. The
process of natural degradation would result in the fOfTJJation of these
chemicals. To prevent drawn out discussions in the future, a contingency
was incorporated into the ROD in the event that the process of natural
degradation cannot be substantiated within two years. "the bioremediation
treatability study fails to demonstrate that natural degradation is occurring at
an acceptable rate, then an active remediation alternative (Alternative 53)
will be implemented.
4.2 CONCERN EXPRESSED ABOUT POTENTIAL ADVERSE IMPACT ON GRANT CREEK
WASTEWATER TREATMENT PLANT IF COMBINED WATER TREATMENT NOT FULLY
ON-LINE
COMMENT #2:
RESPONSE:
Concern was expressed about the circumstances surrounding the combined
operation of all the operable units and the impact on NSCC's pretreatment
system, and thereby the Grant Creek Wastewater Treatment Plant and
meeting its NPDES requirements.
The Agency is aware of the City of Salisbury concern and has relayed that
concem on to NCDEHNR.
COMMENT #3:
4.3 ELIMINATION OF THE NEED FOR INSTITUTIONAL CONTROLS
In addition to the institutional controls already in place (Le., the existing
fence around the plant operations area and the paved areas around Area 2),
NSC is currently, voluntarily placing deed restrictions on those portions of
the property affected under OU#1, OU#2, OU#3, and OU#4. Such deed
restrictions will (a) prevent the utilization of groundwater for drinking water
purposes until the contaminated plumes meet drinking water standards, and
(b) prevent future use of such property for residential purposes until such
time as the CERCLA remedial activities conducted at the Site have rendered
those portions of the property safe for such purposes. NSC anticipates that
such deed restrictions will be in place by October 15, 1994.
Inasmuch .as this is new information that was not available to EPA during
their selection of the preferred remedial alternative, NSC recommends that
EPA change the preferred remedial alternative to NO ACTION. This revision
is warranted due to the lack of any current or Mure risk to human health
under the scenarios defined in the OU#4 Feasibility Study, once the above
deed restrictions are in place.
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~ .. -... . -
ou ~ National &arch & Chemical Company
Responsiveness Summary
RESPONSE:
A- 6
Inasmuch NSCC has voluntarily initiated placing deed restrictions on those
portions of the property affected under OU #1, OU #2, Ou #3, and OU #4,
the deed restrictions will not be in place at the anticipated signing date for
the OU #4 ROD. In addition, neither the Agency nor NCDEHNR has had an
opportunity to review the language of the proposed deed restriction clauses.
Other questions need to be addressed: What entity will enforce the
restrictions? Where does the authority come from for enforcing these deed
restrictions? What will be the penalties, if any, if the restrictions are not
adhered to? In addition to the argument stated above, the institutional
controls as described in Section 10.0 incorporates other activities in addition
to deed restrictions. Consequently, the Agency does not feel it is warranted
to select the No Action alternative by removing the requirement for
institutional controls from the selected remedy.
COMMENT #4:
4.4 INTRINSIC BIOACTIVITY
RESPONSE:
Recent industry experience with intrinsic bioactivity of chlorinated aliphatics
indicates that it is an effective means of removing contamination trom both
soil and groundwater. Field experience has also indicated that the success
of intrinsic bioactivity is a strong function of the ability to deliver nutrients to
the target microbes in an manner that provides the microbes with a relatively
constant supply. The ability to control the effectiveness of the delivery can
be impacted by any of a number of factors, but the rate and direction of
groundwater flow is a significant consideration.
The existing data base indicates that the constituents of concern are not
likely to significantly migrate towards any potential receptors during the time
interval required for evaluation of intrinsic bioactivity applicability. It is
therefore recommended that the design for the Groundwater Treatment
System (GWT) identified in the ROD for OU#3 be developed to incorporate
any relevant data developed during the assessment of ongoing
biodegradation in OU#4. Inclusion of the data to be developed during the
conduct of an intrinsic bioactivity precursor study into the design of a Gwr
for OU#3 is expected to yield significant benefits as the system could be
designed to augment and supplement the intrinsic bioactivity at OU#4.
The Agency concurs with the statement that the success of intrinsic
bioactivity is strongly associated with parameters identified in the comment.
It is the Agency's opinion that additional field work will be necessary to
support the OU #3 groundwater extraction system design (i.e., better
delineation of the extent of contamination in the bedrock zone of the aquifer).
The Agency envisioned that the assessment of ongoing biodegradation will
be initiated with this OU #3 RD field work.
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au... Nalional Starch & Chemical Company
Responsiv9ness Summary
A-7
COMMENT #5:
4.4 ANAEROBIC/AEROBIC BIOACTIVITY
RESPONSE:
NSC notes that there are differing processes 01 intrinsic bioactivity of
chlorinated aliphatics. One process utilizes aerobic microbiological
populations to remediate constituents while a second is based on anaerobic
processes. Based on discussions with, various organizations having
experience in these areas, we have discovered that each process is most
successful when appropriately applied. Aerobic processes appear to be
restricted to remediation of impacted areas located above the water table
(i.e., in the vadose zone). As there is significant data indicating that a large
portion of the constituents of interest at this site are located in the saturated
zone, it is unclear whether the Biodegradation Study Proposal presented in
the FS for OU#4 is the optimum approach. NSC recommends that EPA
permit further evaluation of the various biological processes to ensure
selection of the most appropriate method (i.e., aerobic or anaerobic).
The Biodegradation Study Proposal was just that, a proposal. The Agency
is anticipating that a work plan along with the accompanying supporting
documents (e.g., Sampling ,Analysis Plan, etc.) will be developed to direct
this initiative on verifying and substantiating intrinsic bioactivity.
COMMENT #6:
, 4.5 POINT OF COMPLIANCE
Based on the ROD for OU3, a cleanup level of 1 ppb for 1 ,2-DCA must be
met throughout the groundwater plume. As we have previously commented,
it is doubtful that this cleanup level could ever be achieved, given the track
record of pump and treat remedies in a fractured bedrock media and fate
and transport modeling. In response to our comments, EPA cited 40 CFR
300.430(a)(1 )(iii)(F) that states "EPA expects to return usable groundwater to
their beneficial uses wherever practicable, within a time frame that is
reasonable given the particular circumstances of the site." Based on the
groundwater modeling presented in the OU3 FS report, it appears that the
time required to reduce the level of contamination in groundwater to 1 ppb is
approximately 150 to 200 years (optimistically). As we have indicated in
earlier comments, we believe that a more realistic and practicable ARAR for
OU #3 of 5 ppb (which is the federal standard adopted by EP A pursuant to
the Safe Drinking Water Act) should be adopted instead of 1 ppb in light of
the time required to meet 1 ppb. In any case, if the requirement cited by
EPA for beneficial uses implies reducing contaminants to the ARAR
throughout the contaminant plume, then the time frame is neither reasonable
nor practicable. We believe that it is much more practicable to maintain a
cleanup goal of 1 ppb at the plume boundary than by attempting to achieve
a cleanup goal throughout the plume. As noted by EPA, the source of
contamination has been eliminated, and it is not expected that contaminants
present in the soil will adversely impact groundwater.
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au ~ National SIatdI & Chemical ~
Responsiv8ness Summary
A-8
RESPONSE:
-
Technically, the source of contamination to the soil has reportedly been
eliminated, however, the same cannot be said for the groundwater. As long
as contamination remains in the soil, this contamination can be termed a
source of contamination for the groundwater. The selection of 1 ppb as the
performance standard for 1,2-DCA in groundwater was not arrived at
arbitrarily. As stated in the Responsiveness Summary for OU #3 ROD, 40
CFR 300.400(g)(4) states, -Only those state standards that are promulgated,
are identified by the State In a timely mannllr, and are more stringent than
federal requirements may be applicable or relevant and appropriate-. The
state groundwater quality standard for 1,2-DCA, as specified in the North
Carolina Administrative Code (NCAC) 15-2L.0202(g), is 0.38 pg/l. This is a
more stringent standard than what is specified for 1,2-DCA in the Safe
Drinking Water Act. However, NCAC 15-2L0202(b)(I) allows the state
groundwater quality standard to be raised to the detectable concentration.
Consequently, the Agency raised the groundwater performance standard for
1,2-DCA from 0.38 pgA to 1.0 pg/l as 1.0 pg/l is the detection limit for 1,2-
DCA under the drinking water analytical protocols, EPA method 524.2.
Based on the Superfund Analytical Methods for Low Concentrations Water
for Organic Analysis for the Contract Laboratory Program, dated June 1991,
the quantitation limit for 1,2-DCA is set at 1 pgA.
40 CFR 300.430(f)(1 )(ii)(C) provides the grounds for invoking a waiver.
Based on the Agency's evaluation on the request for a waiver to the State's .
groundwater quality standard (NCAC 15-2L0202), the Agency concluded
that the request does not satisfy any of the specified grounds for invoking a
waiver.
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ATTACHMENT A
TRANSCRIPT OF PUBLIC MEETING
- ... .- -
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NATIONAL STARCH AND CHEXICAL COMPANY
SUPERFUND SITE
7:09 P.X.
July 26, 1994
Salisbury, North Carolina
Agricultural Extension Center
2727 Old Concord Road
Salisbury, North Carolina
~
PROPOSED EL6H MEETING
OPERABLE 1lIa H
'.
~(Q)~W
QIqzn-Intte QIouri lUpnrlmg. 3Int.
fat
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A~E~ARA!f~~a
Ms. Diane Barrett
Community Relations Coordinator
U.s. Environmental Protection Agency
345 Courtland Street, Northeast
Atlanta, Georgia 30365
Mr. Jon Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, Northeast
Atlanta, Georgia 30365
Mro BoE Graulich
4 Waldon Road
Califon, New Jersey 07830
Mr 0 Ray Paradowski
Post Office Box 399
Salisbury, North Carolina 28145-0399.
Mr 0 Hike Sturdevant
IT Corporation
312 Directors Drive
Knoxville, Tennessee
37922
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.)
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MS. BARRETT :
2
3
Thank you, Gentlemen, for coming.
We appreciate
your time.
I'm Diane Barrett; I'm the community relations
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5
coordinator and Jon Bornholm is the remedial project manager
for this site.
And I think just about everybody in here has
6
been to all the other meetings; right?
So we should
Okay.
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have a lot of information.
The city
I will -- let's see.
-- city and county people, we welcome you, Mr. Vest and Mr.
Lasa- -- Lasater, is that correct, and everybody else?
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Okay.
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The purpose of tonight's meeting is to discuss the
National Starch and Chemical Company operable unit 4 soil
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Thus far we've had four proposed
remediation project.
planned public meetings.
One in '88, in 1990 and '93 and
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tonight.
Each public meeting has had a public comment
period; usually that's thirty days and has been extended
17
sometimes to sixty days.
We have displayed -- had display
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ads published in our local news -- in your local newspaper
advertising this meeting as well as mailing out fact sheets.
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I hope you all received these in the mail or either if you
didn ' t in the mail, you can pick them up outside.
And,
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a1so, please sign in if you didn' t.
I think most everybody
has.
'rhese are just some of the ways that we keep people
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J.nfoxmed through the cOllllllWU.ty relations effort.
At -- at the present time we are in step number 5,
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public comment period, for operable unit 4.
All of the
other items that are on the screen here have L2en fulfilled
through the community relations efforts and will continue to
be updated.
Tonight there will also be a transcript made of
the meeting.
Our court reporter here is -- this is an
official meeting, so the transcript, once it has been
completed, will be available in our information repository.
And for those of you that don't know, but I'm sure you all
do know, the repository is located at the Rowan County
Public Library at the reference center.
The public comment period time for this operaple
unit 4 phase is July the 12th through August the 11th.
That
is the standard thirty-day public comment period.
And if
the public requests, a thirty-day extension can be given and
will be given if -- if the time is needed.
That, I believe, will pretty much complete my
section of the meeting, since most of you are familiar with
our process and have participated in previous meetings.
I
.
do hope -- we do appreciate your time and if -- if at any
time that you need assistance, we have a 1-800 number which
is on page twelve of the fact sheet.
Also, if you don't,
want to look, it's 1-800-435-9233.
50 we will be glad to
receive your calls at any time.
Peel free to call U8.
Thank you for your attention.
Now I will turn the meeting
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'"-. 15
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~
over to Jon.
* * * * * * * *
HR. BORNHOLM:
Our branch has got into the 21st century~ we now
have voice-mail and my -- my extension number is 4106 and
Diane's is 4111, so it keeps you from going through the
alphabet and pushing a lot more dials to get to us if you
need us.
One of the handouts on the -- in the front, the
thick one, is basically just a -- a copy of the overheads I
will be going through tonight.
As most of you are familiar
with the site, I'll probably go -- I'll be going throu9~ the
first couple ones relatively quickly.
Basically, the plant
operations started back in approximately 1970 and then have
been going on since.
The site was first proposed for the national
superfund site or national priorities list in April of '85
and it was finalized on the list in October of '89, and the
hazardous ranking scoring was 46.51 and basically we -- we
use 28.5 as our cutoff score.
Anything below that does not
-- is not listed on the map in the priorities list.
Now, just to briefly look at the 8ite, we are
working on operable unit number 4.
I'll just go through,
because the next couple of sheets talk about. the other
operable units as well.
Operable unit 3 deals with the
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contamination associated with the trench area and the
contaminating ground water emanating from the trench area
that flows in a westerly direction, meaning the remediation
of that ground water is basically operable unit number 1.
The soi1s in the trench area are operable unit number 2.
Operable unit 3 and 4 deal with plant area 2 which is right
here (indicating on screen) in the lagoon area.
Operable
unit 3 deals with the ground water in this area which is
basically flowing in -- in this direction.
The operable
"unit 4, which I'm discussing tonight, deals with the
contaminated soils associated with area 2 of the -- or the
plant operations area and the lagoon area.
And, again;. just
to s111mlUllrize what operable unit was -- 1 was, it's deal with
the contamination which they found on the site.
This record
decision associated with this operable unit split the site
into what we call operable units, which are just basically
segregating the site into different manageable areas.
As a result of requiring a -- well, as a result of
splitting the site into a second operable unit, Rational
Starch initiated additional studies of the site and looked
at the trench soils and then the record decision for
operable unit 2 was signed September of -- of '90 and this
-- because of continuing contamination" being found in the
northeast tributary, the base team, with -- along with the
State, again split the site into an additional operable unit
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1
2
to try to identify the source of that contamination.
For operable unit 3 which we proposed to the
3
public back in July, September, August of last year,
identified the same alternative for the contaminated ground
4
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water and again we split the site into a -- a fourth,
appropriate, final operable unit and that fourth operable
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unit, again, as I mentioned before is dealing with the
contaminated soils.
8
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So basically we're here tonight with the proposed
10
planned public meeting.
After the thirty-day public comment
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period, if it's not extended, we'll end in -- August 13th?
MS. BARRETT:
August 11th.
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HR. BORNHOLH:
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-- Aug- -- August 11th, and we anticipate having
the record of decision signed for this operable unit
17
somet~e late September.
And then, just to, again, just to
18
19
identify the areas we're talking about, area 2 is the plant
area and it contains the reactor room, the tank room, the
raw material storage area and warehouse and includes the
terra cotta pipeline that led from the production area to
the lagoons and the sol vent recovery operations.
And just
to point them out here (indicating on screen), again, thi8
is area 2; terra cotta -- terra cotta pipelines basically
ran like this (indicating on diagram) and 80lvent recovery
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8
1
2
area was located up in this area (indicating on diagram).
And then for the lagoons, this overhead basically
3
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identifies the history of the lagoons that were constructed
back in the early seventies.
They were re- -- well, they
5
6
were excavated and lined with concrete back in '84 and
basically the contamination found associated with those
lagoons results from the contaminated soil that -- from the
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contamination entering the soil up to '84, before they were
excavated and lined with, concrete.
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Okay.
Operable unit 4 feasibility studies built
on the operable unit number 3 remedial investigation.
There
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was suf- -- there was sufficient data generated during. that
remedial investigation to be used as part of -- or to be
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used as the feasibility study for operable unit 4.
There
was one adctitional piece of fieldwork done as part of
operable unit 4 and that was a hy- -- hydrophobic dye test,
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basically to answer the question whether or not we have a
dense aqueous liquid or what we te%D1 a Dinaphthol at the
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site.
The primary contaminant which has been found
throughout the site in all the operable units and one that
operable unit 4 also concentrates on is the
1,2-Dichloroethane or 1,2-DCA, and basically this i8 a list
of organics detected in the soils and the --.the range of
concentrations and the frequency of the number of times we
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s
1
encountered it in our samples.
Using this data, National Starch contoured the
2
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concentrations of 1,2-Dichloroethane and this overhead 8hows
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the -- again, area 2, the plant production area, and then
the contours.
Here's the most heavily contaminated area
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And then this area down here 18
(indicating on screen).
associated with the terra cotta pipeline and then plant
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And then the next overhead depicts the s011
operations.
contamination of 1,2-Dichloroethane associated with the
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lagoon area.
Again, it's very localized.
Okay.
As part of the remedial investigation and
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feasibility study effort, a risk assessment was perfo~
and basically that's looking at the types of cont~mi"~ftts,
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the concentration of contaminants present and determining
what risk the site poses to both the public and the
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Basically, it briefly identifies, first, in
environment.
order to be -- in order for a risk to be there, first you
have to have a pathway for that contaminant to get to the
18
19
public, and secondly, the chemicals there have to be at a
sufficient concentration to have some degree of toxicity to
20
21
cause a health problem.
And under superfund for
22
23
carcinogenic compounds, anything with -- any risk greater
than a 1 through -4, which is one out of every ten thousand
24
25
people or a hazard index of one, which really doesn't equate
to a ratio of one out of ten thousand.
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1
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! 3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
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25
10
And, again, this is -- this is based on the data
generated from operable unit 3, remedial investigation.
There is no current risk posed by the site and there is no
current risk because there is no complete pathway for
contaminants, but there are three, what we -- as part of
that risk assessment, we look at future risk scenarios and
there are three unacceptable future risks, which means if
site conditions change, these are -- these are
possibilities.
And then these are the risks associated with
those scenarios and the greatest risk would be using the
ground water as drinkable water.
And, again, the key te%m
here is an on-site resident.
Right now, again, there's.--
the site doesn't cause -- there is no unacceptable risk or
current risk associated with the site, but if site
conditions change and some PeOple build homes on there, then
that risk changes and we would look at that.
that's -- that's a future potential risk.
But, again,
Also as part of the risk assessment or risks --
risk process, we come up with cleanup goals or perfoJ:mance
standards.
For this site we looked up three situations I
one, to protect the workers on site; second one, to protect
potential future -- again, potential future residents, and
the last one is to be Protective of the quality of the
ground water.
And the agency has selected the more -- the
most stringent one, a cleanup goal, as the goal for operable
-------
. ,
....L
1
unit number 4 as our cleanup goal for the soils or as our
target for the soils for 1,2-Dichloroethane at 169 parts per
2
3
billion.
4
And using that concentration, the next two
overheads depict the extent of soil contamination, lateral
5
6
soil -- extent of soil contamination using that
7
8
concentration.
Again, this is associated with area 2, the
plant operations.
9
10
MR. PARADOWSKI:
That's not included, Jon.
11
12
MR. BORNBOLK:
What's that?
13
14
MR. STURDEVAN'r:
It's the last two.
15
16
MR. PARADOWSKI:
Oh, I'm sorry.
17
MR. BORNHOLK:
18
19
I'm sorry.
MR. PARADOWSKI:
20
21
I didn't catch it.
MR. BORNBOLII:
And then the next -- the next figure shows the
22
23
lateral extent of the contamination 4880ciated with the
24
25
lagoons that surpassed the -- that perfor.mance 8tan~A~d.
Okay.
using this infoDlation, we'll go into the
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18
. 19
20
21
22
23
24
25
12
1
2
feasibility study and basically the feasibility study is
built on the process of elimination, starting with a broad
3
base of technologies, and as you eliminat- -- eliminate
those technologies due to either implementability,
4
5
6
effectiveness or cost on the initial sweep through those
technologies, we start to narrow them down to a more
7
8
manageable number of technologies that we can do a detailed
evaluation on.
9
10
50 the first step is to screen all -- all
technolog~es using basically tt~3e three criteria.
The
11
12
next step is try to' put those technology -- technologies
together to fo:cn remedial alternatives, and once we've" .done
13
14
that, again, we use -- then we use these three criteria to
do an initial screening of those remedial alternatives,
15
16
again, try to eliminate those that are either duplicative of
one another or don't meet the needs of these criterias.
And
17
after that process, then we take what's remaining and
perfor::-: a detai~. 3d evaluation using basically these seven
criteria, the threshold criteria and the evaluating
criteria.
The alternatives must pass the threshold criteria
and then these other evaluating criteria are used to
evaluate the alternatives against one another.
And then the last two are -- is based on what the
community -- the public comment period's about, at least for
the community's acceptance, as well as -- and the -- and the
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...~
1
2
State's been involved all throughout the process.
These are the four alternatives that made it
3
4
through that screening process.
By law, we're required to
keep the no action alternative, and that gives us a base
5
6
line to measure the other alternatives.
On -- the next
alternative is S2, natural degradation and institutional
7
8
controls and the associated cost.
Alternative 3S is soil
vapor extraction with fume incineration in the initial phase
of that process when you're pulling out large quantities of
9
10
-- of contaminants, and then as that rate of -- of removal
decreases, then we change the filtering method from fume
11
12
incineration to activated carbon filters to control the
13
14
the emissions from the process -- from the soil vapor
extraction process.
Then alternative S4 basically
15
16
eliminates the fume incinerator and we just use .activated
carbon.
And the reason it's so much more expensive is
17
18
because you're going to be using a lot of activated carbon
in the initial start-up of the soil vapor extraction system.
19
20
And then what the agency has proposed, and the
State has given concurrence with some. reservationS, the
21
22
agency is proposing alternative 82, natural degradation with
institutional controls.
Just the key points I want to make
23
24
to support the selection of this remedy is, one, if we go
back to the map of the site, most of the contAmination with
25
the lagoons is -- is in this area and the majority of -- of
-------
19
20
21
22
23
24
25
J..'t
1
contamination has already been -- has already migrated into
2
3
the ground water here (indicating on screen).
As far as
area two, most of -- most of this area is already capped
with an impervious layer, either the building itself or the
4
5
6
macadam driveway surrounding the area.
So we're not
anticipating the contamination to migrate from the soil
down to the ground water in this area because of that
7
8
impervious cap.
The other -- the second point is National Starch
9
10
has proposed that based on published literature,
1,2-Dichloroethane degrades with a half-life of two years,
11
12
which means that every two years the concentration of .
13
14
1,2-Dichloroethane should decrease by one-half.
And based
on those -- on that rate of degradation, it's anticipated in
less than ten years that the concentration will fall to the
15
16
7,000 parts per million level which -- where is that?
Where
17
18
is the overhead?
Here it is -- which is -- which would --
would be protective of -- of the public from geDial contact.
And then in less than twenty-one yea,re, we would -- the
concentration would degrade down to tt:e concentration.
And
this -- this process, the natural degradation process, is
accomplished through the -- the activities of -- of bac- --
of bacteria microorganisms found in the eoil.
And then the other POints I want to -- other
points -- other facts to point out which -- let's put this
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~5
1
2
one back up here.
Operable unit 3 is -- to extract
contaminating ground water, there will be extraction wells
located in this area (indicating on screen), general area,
3
4
to extract the contaminated ground water.
50 if there is
5
6
any migration of the contaminates from the soil down into
the ground water, we will be protecting both the environment
7
and public health through the use of those eXtraction wells.
And then the last point to make out is, again, in
8
9
this area (indicating on screen) there is no current
unacceptable risk posed by the contamination presented in
10
11
this area because there is no direct link or exposure
pathway.
12
13
Okay.
This is going to be a contingency ROD,
14
which basically means that if natural degradation does not
pan out as anticipated, we are going to require National
15
16
Starch to go in and use an active remediation to remove the
volatile organics from the soil, which would be either
17
18
alternative 53 or S4, and basically we'd put a time frame to
that and propose a plan of two years from the signing of the
19
20
ROD to be able' to show that natural degradation is occurring
and the rationale behind that is basically contamination has
21
22
been there, let's say, prior to 1980.
If it'8 going to --
23
24
if natural degradation is occurring, we should 888 it now
because the last source of contamination was. el i1llin~ted back
25
in February of -- of this year when they completed the
-------
16
.
1
2
removal of that terra cotta -- terra cotta pipeline.
feel that within two years we should see substantial
50 we
3
4
decreases in contamination.
And that ends my prepared presentation.
We will
5
6
-- I'm happy to answer any questions that you may have.
first ask that you please give your name -- is that all?
I
7
8
HS. BARRETT:
(Nods head affir.matively)
MR. BORNHOLK:
9
10
That you give your name prior to asking a
11
12
question.
Yes, sir~
MR. BARE:
13
14
Odell Bare.
How much water are you pumping over
there now?
15
16
MR. BORNHOLK:
Mike?
17
18
MR. STURDEVANT I
About 130,000 gallons a day.
19
20
MR. BAREl
Well, we got a well across the creek that's going
The water level is below the pump we put in there.
21
22
dry.
The -- the bill usually runs about fifteen to twenty
c1ollars~ it's seventy, eighty dollars.
23
24
MR. BORNHOLKI
Okay.
25
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.i I
1
2
MR. BARE:
The pump is below -- the water is pulled below the
3
4
well.
MR. BORNHOLK:
5
6
I -- National Starch just submitted a --
MR. STURDEVANT:
7
8
Quarterly report.
MR. BORNHOLK:
9
10
-- monitoring and a quarterly report that depicts
the contours of their cone of influence.
I have not -- it
11
12
was submitted -- I got it Monday, so I have not looked at
it.
But I talked to Kike and from what Hr. Sturdevant" 8aid,
13
14
the cone of depression does not go or reaches the stream,
does it not?
15
16
MR. STURDEVANT:
I think the cone of influence is approximately at
17
18
the southwest tributary.
property.
It runs on the backside of the
19
20
MR. BARBa
Is it down to the branch?
21
22
MR. STURDBVANT a
It'8 -- it's approzimately down to the branch, in
23
24
there.
MR. BORHBOLHa
25
I don't know where you're --
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21
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23
24
25
18
1
MR. BARE:
2
3
Is it across from the bridge?
MR. STURDEVANT:
4
5
Not that -- not that we're aware of.
In fact,
one's a downgradient monitoring well and I believe it's
NS-32 is artesian, and that's the one that's closest to the
6
7
-- where you're talking about, as far as the -- the wells.
8
9
MR. BARE:
Well, see -- that's what they -- it's lowering the
water level there; you're pulling the water out from under
10
11
12
that well and lowering the ground water there.
MR. STURDEVANT:
13
14
What I'm saying -- what I'm saying --
MR. BARE:
15
16
That well when it was put in, twenty-five feet was
water level, and that's below the well, --
17
18
MR. STURDEVANT:
What I'm saying is --
19
20
MR. BARE:
-- below the pump.
MR. STURDBVAN'l'1
What I'm saying is the monitoring well that i8
closest to your -- the area that you're referring to is
artesian, whereas it has a head that is pushing water out of
the well.
The water table elevation is actually above --
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'-'
19
1
2
above the well.
MR. BORNBOLM:
3
4
Is that down at the branch?
MR. STURDEVANT:
5
6
Yes.
MR. BORNBOLM:
7
8
And that -- that's still artesian?
MR. STURDEVANT:
9
10
That's still artesian.
HR. BARE:
11
12
Is it running all the time?
MR. PARADOWSKI:
13
14
But that's a monitoring well, not a pumping well.
HR. STURDEVANT:
15
16
I know but I quess they're monitoring the
No; no.
condition on that side of the creek.
17
18
MR. PARADOWSKI:
Right.
MR. STURDEVANT:
19
20
And it's an artesian creek well --
21
22
HR. BARB:
Is that running all the t1JDe?
lIS. BARRETT:
23
24
Bxcuse me.
Bxcuse me.
Just say your name fer
25
the record, please.
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1-
18
19
20
21
22
23
24
25
~u
1
2
MR. PARADOwSKI:
I'm sorry.
3
MS. BARRETT :
4
5
Say your name for the record.
MR. PARADOWSKI:
6
I'm sorry.
I'm Ray Paradowski from National
7
Starch.
But just to clarify that Particular artesian well,
8
9
that's a monitoring well and there's no pump in that well.
There's no water being taken out of it.
10
11
MR. BARE:
Is it pumping water out all the time?
12
13
MR. PARADOWSKI:
Ya- -- well, except it's capped.
14
15
MR. BARE:
Well, that's probably lower than the well up on
the hill that we're talking about.
16
17
MR. PARADOWSKI:
well.
As I said, no water is being taken out of that
It's strictly there as a test hole.
MR. BARE:
What about the other one?
You drilled two down
there, didn't you?
HR. PARADOWSKI:
Yeah, but those are -- neither of. tho8e wella are
being used for pumping water.
-------
21
.
1
MR. BORNHOLM:
2
3
But are they --
MR. PARADOWSKI:
4
5
We're not pumping any water right now.
MR. BORNHOLM:
6
7
But are they showing drawdown, though?
MR. PARADOWSKI:
8
9
Pardon me?
MR. BORNHOLM:
10
11
Are they showing drawdown?
MR. STURDEVANT:
12
13
The -- the extraction wells are upgradient from
the monitoring wells, which are down close to the creek.
If
14
15
we had a map -- I don't know if they've got a map over
there.
16
17
MR. BORNHOLM:
I don't.
18
19
MR. STURDEVANT:
I can sketch it.
20
21
MR. PARADOWSKI:
Let's see the report.
22
23
HR. BORNBOLK:
I'm not sure if the report goes into -- but I
guess the point to be made or to reemphasize. right now,
24
25
based on the infomation that National Starch has, the cone
-------
22
.
1
2
of influence reaches the stream.
HR. BARE:
3
4
What's that?
Were you talkinq to me?
HR. BORNHOLM:
Yeah.
The -- the extraction wells that they
5
6
installed on -- on their property, the influence on the.
qroundwater based -- from the extraction of that -- of the
7
8
9
water in -- throuqh those wells has reached the stream.
I
-- and I don't -- do not know where your well is located, so
10
11
I can't --
MR. BARE:
12
13
It's probably, what, three hundred feet, four
hundred feet?
14
15
MR. BORNHOLM:
Is it a -- is it drilled into bedrock or is it --
16
17
is it drilled into bedrock?
MR. BARE:
18
19
The well?
MR. BORNHOLMI
20
21
Your well.
JIR. BARB I
22
23
Yeah.
JIR. BORNBOLMI
24
25
It's in hard rock?
* * * * * * * *
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
....- 15
16
17
18
19
20
21
22
23
24
25
23
MR. STURDEVANT:
If you have a -- a marker, I could draw a little
map up on the board there.
MR. BORNHOLK:
What type of marker is this?
MR. BARRETT:
Erasable marker?
Okay.
(WHEREUPON, xr. Sturdevant prepared a diaqram
on the board.)
MR. STURDEVANT:
This is the trench area (indicating on diaqram).
This is the southwest tributary down in this area.
I ..
believe where you're talking about is the Little Acres~
right?
MR. BARE:
Yes, sir.
HR. STURDEVANT:
You're over here.
I'm not sure whereabout in this
property that you have your well located, but from here down
.
to the stream, what would you say that is, approximately?
HR. BARBa
I'm not -- I don't know ezactly.
I'd say four
hundred feet.
HR. STURDEVANT a
Yeah, I would say about four to five hundred feet
-------
18
19
20
21
22
23
24
25
24
1
there, directly here.
We have monitoring wells 29, 30, 31,
2
3
and I think 32 is somewhere in this location.
What we're
seeing in these monitoring wells is that we have a cone of
4
influence -- we have these two extraction wells working all
5
6
the time.
Extraction well -- this is extraction well 2;
this is extraction well 3.
These are the two extraction
7
wells that are pumping water.
HR. BARE:
We see --
8
9
Are they pumped twenty-four hours a day?
HR. STURDEVANT:
10
11
That's rig~t; that's right.
The normal hydraulic
12
13
gradient across this area, of course, is down -- right.~own
to the stream.
When you have these wells operating, you see
14
15
a cone of influence somethJ.ng like this (indicating on
diagram) .
And what that means is that you're. actually
16
17
having an influence of ground water in the downgradient
direction, actually reversing back towards these extraction
wells but at a limited distance.
We're only affecting out
in this area, oh, about a hundred feet away from the well in
the downgradient direction.
Okay.
We're seeing decreases
in concentrations of contaminants in the moni- --
downgradient monitoring wells.
This Particular monitoring well right here, IIS-32,
the most downgradient well and closest to your property, i8
what we refer to as an arte8ian condition.
That means that
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
'-.. 15
16
17
18
19
20
21
22
23
24
2S
'"
25
the hydraulic gradient is actually pushing up in this region
so that once you tap into the bedrock aquifer at this point,
into the -- into the aquifer at this -- at this location,
you have a head of water that is above the surface water,
above -- above the surface elevation.
MR. BARE:
Is that across the creek from the plant?
MR. STURDEVANT:
Here's your -- here's your creek right here
(indicating on diagram).
This is the southwest tributary.
Okay.
So it's across the creek.
MR. BARE:
Is that contaminated over there?
MR. STURDEVANT :
No, never has been.
It continually registers
non-detect.
So your -- your well is probably, if I was to
-- to estimate, I would say it's at least fifteen hundred
feet, maybe two thousand feet away from this cone of
influence over here on the property.
MR. BARB:
Well, they built that high-rise prison over there
and they pump water like --
HR. STURDBVAlrr:
Well, that could be
* * * * * * * ..
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26
1
2
MR. BARB:
-- it's going out of style.
Now the water is
3
4
below the pump.
HR. STURDEVANT:
5
6
That could be your problem.
If they're
withdrawing huge quantities of water from the prison, they
could be impacting the water in this area (indicating on
7
8
9
diagram) .
MR. BARB:
10
11
You see, they don't use it no more.
MR. STURDEVANT:
12
13
Well, disregard what I said.
Oh, okay.
MR. BARE:
14
15
Well, it's got a couple of trailers on it, but
it's going down below the -- the pump ~ where the pump WAS
16
17
put in the ground, it was put down in -- way down in the
water.
1f : MR. BORNBOLK:
1
20
The other thing that ~:. could look at if -- if you
have information available, is look at the depth -- the
21
22
depth of this well versus the depth of this well
(indicating on diagram).
23
24
MR. BARBa
Okay~ okay.
25
* * * * * * * *
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2 -,
1
2
MR. BORNHOLM:
And then if this well -- if these wells are Above
the depth of this well, there's no way that you have
3
4
influence from that site.
5
6
MR. STURDEVANT:
Again, I'd like to point out, Odell, that the only
place we're extracting ground water is out of the extraction
7
8
9
wells, the EX-2 or the EX-3.
The -- the monitoring well,
10
NS-32, we're not extracting any water out of that well
whatsoever~ it's just monitoring the condition there.
11
12
MR. BORNHOLK:
Again, another thing we can look at is the depth
of -- of this well (indicating of diagram), elevationwise,
13
14
com- -- compared to sea level and these wells here that --
could -- will help answer any questions.
15
16
MR. BARE:
17
18
Well, that well sits higher than any of those --
that -- that's on pretty high ground.
19
20
MR. BORNHOLMI
You know, I don't know the terrain around there,
so I can't respond to that.
21
22
HR. ARBYI
23
24
My name is Javis Arey and I work with Hr. Odell
Bare and Hr. June Goodman in Little Acres Jfobile Home Park.
25
We're responsible for the overall operation of the Little
-------
28
.
1
2
A.cres Mobile Home Park.
We have numerou8 wells throughout
the development.
:Ohere are "57 families, 157 mobile homes
3
in Little Acres tonight.
Each of them are feeding different
4
wells.
My question is why, after eighteen months,
5
6
thereabout, of just pumping 120,000 gallons, which is --
it'll go to 200,000, is that correct, per day?
volume increase to 200,000?
Will the
7
8
MR. STURDEVANT:
9
10
That's the maximum amount that -- that we have
desiC"':'~d for.
Yeah.
Whether we need to pump 200,000, based
11
12
on the results that we're seeing from our quarterly
monitoring program, I doubt it will have go that high.'-
13
14
MR. AREY:
All right.
Where is the ground water
15
16
approximately eighteen months, speaking of today in
relationship to this ground water table before these
17
extractions started -- before you started -- started pumping
a ~undred thousand -- is the over.....:.l ground water table
~8
19
dropping?
MR. STURDEVANT:
20
21
In that area of influence that --
22
23
HR. AREI.
Yes; right.
HR. STURDEVANT.
24
25
-- I pointed out there?
-------
29
- .
1
2
MR. AREY:
If it's 120,000 -- 130,000, it's got to came from
3
4
somewhere.
Is it coming from --
MR. STURDEVANT:
5
6
Okay.
All right.
MR. AREY:
7
Are you with me here?
MR. STURDEVANT:
8
9
Yeah. I sure am; I sure am.
If I may again?
10
11
(WHEREUPON, Mr. Sturdevant approached the board.)
MR. STURDEVANT:
12
13
If you look at this whole region, the waters~
area begins up here at the top of the hi.ll and eztenda way
14
15
back up, I guess, all the way up to Reynolds Aluminum plant
factory.
Okay.
16
17
MR. AREY:
Right.
MR. STURDEVANT:
Highway 29.
18
19
So you've got thi.s huge regional aquifer that' 8 .
coming down through this area, through the southwest
20
21
tributary, and you have water, of course, that's flowing
22
23
down this c:tirection from the top of the hill.
So what
you're -- what you're pulling out from these extraction
wells is the water that's coming down from the top of the
24
25
hill, under here and the water that's flowing down through
-------
30
1
2
this valley.
MR. AREY:
3
Yes, sir.
4
5
6
HR. STURDEVANT:
Okay.
So that's where all this water's coming
7
from that you're pulling out of the extraction wellB right
8
9
here (indicating on diagram).
The water, I would -- I would
.assume that the water that you're Beeing across here iB
coming from an area up here, looking at, again, the -- the
10
11
topography in the area.
this zone is back up --
It looks like the watershed for
12
13
HR. BARE:
14
15
That well up there is about the peak of the hill.
HR. STURDEVANT:
16
17
Okay.
So --
MR. BARE:
18
19
It's -- it's about the peak.
MR. STURDBVAN'l':
20
21
. The crown?
JIlt. BARB :
22
23
Yeah.
JIlt. STURDBVAN'r:
So you're probably -- you're probably gathering
24
25
water from up in this area and also the water that's, again,
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2
running down through this valley.
HR. AREY,
3
4
Is the water table itself dropping any?
HR. STURDEVANT:
5
6
The water table in this area, thi.s cone of
influence, we've seen it drop about -- I believe it's two
7
8
feet --
HR. VEST:
9
10
That's not the point that he's asking, though,
Hike.
11
12
HR. STURDEVANT,
-- right -- right around thi.s well right here~
13
14
these wells.
That's all.
It's just a -- a real shallow
zone.
15
16
MR. VEST:
I just want to make a point for Kike to make.
The point he's making is the four moni. tor wells, which are
17
18
outside the cone of influence, have you got the standing --
MR. STURDEVANT I
19
20
Right.
21
22
HR. VESTa
-- you got the standing elevation of tho8e to show
that that has not changed --
23
24
HR. STURDEVANT I
25
That's right.
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20
21
22
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24
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32
1
2
1m. VES'l' :
-- through the year --
JIR. STURDEVANT:
3
4
5
'l'hat's right.
1m. VES'l':
6
7
-- of pumping?
'l'hat's his question.
1m. STURDEVANT:
8
9
'l'hese -- these wells down here, these -- these
monitoring wells, the elevation of the water in those
1('
moni taring we 1s has not changed from this pumping action
here.
11
12
1m. VES'l'1
13
14
Which is on the other side of the creek where you
are.
15
16
1m. .S'l'URDEVANT:
We haven't seen any depression of -- of the ground
water down in this area (indicating on diagram) what8oever.
17
18
It hasn't been decreasing~ the ground water elevation has
not decrea8ed with these well8 operating.
MR. BAREl
Well, what is -- these wells that you're pumping,
how deep are they?
JIR. STCRDBVAH'l'1
Approximately -- let' 8 888.
they're 170 feet, I believe.
I thfft~ -- I think
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2
MR. BARE:
Do they qo down into the rock --
3
MR. STURDEVANT:
4
Yes.
5
6
MR. BARE:
-- or do they just qo down to the rock?
MR. STURDEVANT:
7
8
No.
They qo into the rock.
9
10
MR. BARE:
Into the rock?
11
12
MR. STURDEVANT:
That's riqht.
The rock beqins in this area,-,
13
14
(indicatinq on board) down near the %-02; the rock beqins
around five, ten feet below the surface.
So most of the
15
16
well is --
MR. BARE:
17
18
So you really -- you really latched onto an
underqround stream somewhere that you're pumpinq water off
19
20
of, a vein somewhere.
MR. STURDEVANT:
21
22
These are all -- this is all fractured rock system
down throuqh here.
23
24
MR. BARB:
So you could be pumpinq off a vein' of -- that runs
riqht across that hill to that other well, because when --
25
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16
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2
I've drilled hundreds of wells~ I know what I'm talking
about.
When you hit a vein, then the'water comes.
Then it
3
4
-- then it -- the vein makes -- you don't know which way
that vein is coming.
5
6
MR. S'l'tJRDEVAN'l':
We have these monitoring wells at the same depth
as the extraction wells (indicating on diagram).
7
8
MR. BARE:
9
10
Well, the surface water there wouldn't -- I mean,
- the water leval there wouldn't necessarily lower, but you
11
12
could -- you could still maintain that surface there and be
pumping from another vein, somewhere, pumping off another
13
14
vein, pulling another vein down.
You don't pull that -- the
area you're pumping, you don't know where that water's
coming from if you're down in the rock and not pumping
surface water.
1m. S'l'tJRDEVAN'l':
We're -- we're pretty sure that, baaed on our
measurements, that we're not having an influence out in this
.
area, that the only influence we're having is right around
these two wells.
That' 8 all we see from all the data
mea8urements we've collected.
JIR. BARB:
the rock?
Well, how i8 that contAmination getting down into
How deep is the well?
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35
--
1
2
MR. STURDEVANT:
About 170 feet.
3
MR. BARE:
4
So you -- you hit rock at eight feet and it's got
to go 160 feet through rock before you can get it?
5
6
MR. STURDEVANT:
7
8
What we're doing is we're pulling
No; no.
contaminants from the full depth of the contaminated
9
10
aquifer.
What we found is from our initial investigations
here, is that the fractures in the rock pinch out, actually
decrease, to a point that you can't even see them any longer
11
12
after you get about 170 feet deep.
13
14
MR. AREY:
So, sir, you're saying that the actual ground
water table has not changed any in the overall area of,
15
16
like, two miles around Nation -- National Starch?
17
18
MR. STURDEVANT:
I couldn't say that.
If there's been other wells
19
20
placed in -- in the area, that's, you know, -- no; I can't
say that, not two miles.
MR. ARBY:
21
22
I'm not trying to put words in your mouth.
I'm
23
24
just --
MR. STURDEVANT:
25
Yeah; yeah.
All I'm saying i8 locally right here
-------
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20
21
22
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1
where we have our extraction system, " know that we haven't
2
3
seen any changes in these downgradient monitoring wells.
MR. BARE:
4
We had another well down on Sidney Drive there
that went dry last summer, the people -- the -- the lot that
5
6
we sold, and they -- they said their well was dry; there's
7
8
not enough water in it.
been there --
Now, what would cause that?
It's
9
10
MR. AREY:
Eighteen years.
11
12
MR. BARE:
Ten or fifteen years.
13
14
MR. AREY:
Our problem is -- our real question is if we had
one well tonight in trouble due to lack of production and we
15
16
have to -- have -- do we have -- are each of the other wells
17
18
a candidate for being the same thing one year from tonight?
MR. BORNHOLK:
And to answer that the best that we have -- with
the data that we have is we're not influencing that area.
Again, the gentleman brought up a point that maybe there is
a vein across that runs that way.
We don't know.
We don't
know that.
MR. AREYz
Whose responsibility should it be to dete%mine
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37
1
that?
2
3
MR. BORNHOLM:
It's going to have to fall on us.
We're the --
4
5
And, again, I think the first
the responsible parties.
thing. we need to look at would be the depths of -- of the
wells themselves.
6
7
MR. AREY:
8
9
Okay.
MR. BORNHOLM:
Thank you.
10
Are there any other questions?
11
12
MR. AREY:
Yes, sir, please, and I don't mean to be
13
14
predominant.
Aqain, Javis Arey, Little Acres Mobile Home
Park.
Question: in relationship to how much noise will
15
16
these soil valve extractions make, will it be a terrific
vibration running twenty-four hours a day?
that noise be extended?
How far will
17
18
MR. BORNHOLM:
19
20
You're going --
MR. STURDEVANT:
21
22
What's that?
MR. BORHBOLJh
23
24
You're going up to where agaJ.n that it --
MR. STURDEVANT z
25
Well, I think you're askJ.ng about the soil vapor
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.Hs
1
extraction.
2
3
MR. ARBY:
Yes, vapor extraction.
4
5
MR. STURDEVANT:
We're not proposinq to put those wells in place.
6
7
MR. ARBY:
You're not proposinq to put them in?
8
9
MR. STURDEVANT:
That's riqht.
The proposal is -- is institutional
10
11
control and natural deqradation.
MR. BORNHOLH:
12
13
If we need to take --
MR. STURDEVANT:
14
15
If -- yeah.
MR. BORNHOLM:
16
17
If we need to move on to that step, my -- my
memory serves me, they're semi-loud.
18
19
MR. ARBY:
All riqht.
Would -- would you and your -- object
20
21
for you and your family to live, just, say, about 1500 feet
from it on a constant basis?
22
23
MR. BORNHOLM:
I can't --
24
25
MR. ARBY:
You don't know?
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;. 15
16
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HR. BORNHOLK:
I -- I really can't answer that, 'cause I don't
know.
I don't know how loud they are.
I've never been
around one.
But the -- I'm assuming we might -- if
-- if
necessary, we'd have to muffle them somehow.
I'm sure
there's technology there.
First of all, we'd have -- we're
going to have to control the emissions coming off of the --
the blowers themselves to control the contaminants that
we're pulling out.
So it's -- it's going to be -- the
sound's going to be dampened through that process anyway.
HR. AREY:
But that's strictly one of the potential
possibilities down the road?
HR. BORNHOLK:
Yes.
And that decision --
HR. AREY:
You're not going to meet it 'til it arises?
HR. BORNHOLK:
That decision will be made J.n two to three years,
HR. AREY:
All right.
HR. BORHBOLH:
-- after we deteJ:m1ne whether or not natural
degradation is or is not working.
If it is not working,
-------
40
.
1
that's where we're headed~ yes.
2
MR. AREY:
"3
4
Thank you.
A third question and, again, I don't
mean to be so predominant here, in the covenant restrictions
as I've read here in the communication, we have a tract of
5
6
land that is homogeneous with, common boundary line, with
National Starch that we have had for sale approximately two
7
8
9
and a half or three years.
I read here that National
Starch's property, if it is ever sold, the deed covenant
restriction will be placed in there that it cannot be
10
11
developed or commercially produced.
Now, are we going to
12
13
have to abide by those rules?
If we sold that property to
you, sixty-two acres, and we get a --
14
15
MR. BORNHOLH:
Sold it to National Starch or --
16
17
MR. AREY:
Pardon me?
18
19
MR. BORNHOLH:
No~ those covenants would -- would zero in on
20
21
those areas that are -- are contaminated --
MR. AREY:
22
23
Okay.
MR. BORNHOLH:
24
25
-- are
contaminated.
* * * * * * * *
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41
1
MR. AREY:
2
3
Are we allowed to disturb the soil?
MR. BORNHOLK:
4
On your property?
5
6
MR. AREY:
Yes, sir.
7
MR. BORNHOLK:
8
9
As -- as far as I know you are.
I mean, I -- I'm
not sure where your property is, but I -- there's no reason
for me to believe that it's even contaminated.
10
11
MR. AREY:
12
13
We have had different prospects for this tract of
land and once a potential buyer sees in the enviroument
14
15
there, speaking of National Starch, they don't become
interested.
It's a valuable tract of land.
16
17
MR. BORNHOLK:
We would not -- that covenant would not pers- --
pertain to that certain tract of property.
18
19
MR. AREYs
20
21
We could give a -- questions we could give a deed
in fee simple?
22
23
MR. BORNHOLlh
Yes.
We -- we don't have any say on your
24
25
property.
'* '* '* '* '* '* '* '*
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6
7
8
9
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12
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, .
! 21
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HR. AREY:
You have no command of the property, period?
HR. BORNHOLM:
Correct, on your --
MR. AREY:
Would -- would you have a command if once dirt
started being moved around, road construction started,
houses being built?
HR. BORNHOLM:
It does not pertain to the National Starch
superfund site; no.
HR. AREY:
Okay.
HR. BORNHOLM:
And even on parts of -- even if National Starch
went out of business and sold their property, that covenant
would only pertain to those areas that are contaminated.
So
there are no -- and there -- those tracts of -- of National
Starch property that's not contaminated and I don't think
there'd be a problem with developing those as residences.
MR. PARADOWSKI:
Can we
can we put that one slide up that you
have, Jon, to -- to illustrate that?
HR. BORNHOLK:
The area -- the area we're talking about that --
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43
1
2
this deed of restriction would be associated with the
3
contamination around this area (indicating on screen) and
around this area only.
4
MR. AREY:
5
6
Only?
MR. BORNHOLM:
7
Only.
And there is -- again, --
8
9
MR. AREY:
The restrictions would be --
10
MR. BORNHOLM:
11
12
As far as I know, there's no contamination down
here and -- and therefore there's no risk and therefore~ you
13
14
know, the public is protected as far as we're concerned.
Now, what we'd say -- you know, we would pro1>ably prevent or
15
16
the State would prevent construction of homes in this area
until the concentrations in the soil drop to a protective
17
18
level and then --
MR. AREY:
19
20
Which is only inside the fence?
MR. BORNBOLK:
21
22
Within the National Starch property, yes.
Would
-- I don't --
23
24
MR. AREY:
Repeat that.
I'm sorry.
25
* * * * * * * *
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44
1
2
MR. BORNHOLK:
The source -- the source contamination is all
3
4
within the National Starch property.
MR. AREY:
5
6
Yes, sir.
MR. BORNHOLK:
7
You've got this area of contamination and this
8
9
area of contamination in the soils (indicating on screen),
10
MR. AREY:
11
12
All right..
MR. BORNHOLK:
13
14
-- which would prevent -- you know, I -- as a
homeowner, I wouldn I t want to build a house there until I
15
16
was assured that there was no health associated with those
areas -- health concerns associated with that area.
17
18
MR. AMY:
All right.
Thank you.
A fifth question, please,
19
20
and I apologize for the fourth time, why did your
.
organization go from a thirty-year plan to a 120-year plan
21
22
on the cleanup
superfund plan?
Pardon me.
-- or
HR. BORNHOLK:
23
24
The -- there's a miscODllllUnication here.
Well, not
a miscommunication.
It's been estimated to clean up the
25
ground water in this area is going to take over a hundred
-------
21
22
23
24
25
45
1-
2
years and basically the thrity-year estimate was based on a
different cleanup criteria, was based on a perpetual cleanup
3
4
number and we are forced to -- to use the most stringent
number, which is the State's number, which requires more
5
6
extraction.
The -- the federal number is five parts per
million.
7
MR. PARADOWSKI:
8
9
Per billion.
MR. BORNHOLM:
10
Per billion.
Five parts per billion.
That's the
11
12
federal cleanup goal, called the MCL.
And that -- and
that's contained under the safe drinking water act.
State's cleanup number is .8 or something like that.
The
13
14
HR. PARADOWSKI:
15
16
Point 3.
MR. BORNHOLK:
17
18
But we had to raise it -- we had to raise it to
one part per billion because we can't test, we can't detect
19
20
below one part per billion.
It's in the -- we just don't
have technoloqy now.
So going from five parts per bill- --
per billion down to one part per billion increased the
amount of water that needed to be pumped and, therefore, the
length of time to clean up the ground water.
So the
estimate of cleanup this contaminated ground" water is now
approximately 120 years.
That's where that 120 comes from.
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46
1
2
MR. AREY:
But that could potentially, possibility, be
extended again from 120 to 150?
3
4
MR. BORNHOLM:
5
6
In all likelihood, it will go on into infinity.
MR. AREY:
7
Thank you.
And my last -- last question, please,
8
9
as I touched base with you for the meeting, 1 was with your
personnel and Raleigh's personnel on-site two years ago --
10
approximately two years ago.
Water samples were taken: they
11
12
were analyzed by National Starch Chemicals and Atlanta and
Raleigh. Unfortunately, I have never received any
13
14
communication pertaining to what those analyses were.
MR. BORNHOLM:
15
16
1 sent that
I sent it to your -- your partner.
letter to Mr. Odell.
17
MR. AREY:
18
19
Oh, you sent it to him?
MR. BORNHOLM:
20
21
Yeah.
I don't know if he got it, but -- and the
-- the estimated time frame was in July of ' 92 that those
samples were --
22
23
MR. ARBY:
24
25
Yes, sir, '92, in July.
* * * * * * * *
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1
2
3
4
9
10
47
MR. BORNHOLK:
Okay.
We need that to try to track that data
down.
MR. AREY:
Ray paradowski did call me
5
6
Thank you.
Mr. -- Mr.
and said that as far as they, National Starch, everything
7
8
was fine.
MR. BORNHOLK:
And is that about right, July of ' 92 --
MR. pARADOWSKI:
11
12
Yes.
MR. BORNHOLH:
-- were -- when the samples were collected?
13
14
MR. pARADOWSKI:
15
16
That's correct.
MR. BORNHOLK:
I've had difficulty
17
18
Like I said, I'll find out.
tracking --
MR. AREY:
19
20
We will get a report, then?
MR. BORNHOLK:
21
22
I will send you the data.
23
24
MR. AREY:
Thank you.
* * * * * * * *
25
-------
,-
18
19
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21
22
23
24
25
48
1
2
MR. BORNHOLK:
Any other questions?
3
4
MR. PARADOWSKI:
Excuse me, Jon.
Ray Paradowski.
Could we get a
5
6
copy of that data, too?
MR. BORNHOLK:
7
Yes.
8
9
MR. PARADOWSKI:
Is that okay?
MR. BORNHOLK:
10
11
You never got it documented?
If I can find it.
12
13
I've had difficulty looking, as I explained to the gentleman
in the back.
14
15
MR. AREY:
Arey.
MR. BORNHOLK:
16
17
I've looked at both under type of ground water or
type the sample was and the date and haven't found it yet.
MR. PARADOWSKI:
Mr. Arey said that National Starch's result, but
actually that was a -- an outside certified laboratory.
didn't do it ourselves.
We
JIR. AREY:
Well, thank you.
this is Javis Arey.
I -- I thought you and your --
-------
49
1
2
MR. PARADOWSKI:
We sent it off.
3
4
MR. GRAULICH:
We paid for it.
S
6
MR. PARADOWSKI:
We paid for it, but it was an outside certified
laboratory that did the analysis.
7
8
MR. AREY:
9
10
Thank you.
MR. BORNHOLM:
11
12
Are there:any other questions?
Well, thank you
for your -- your time and attending our meeting.
(WHEREUPON, the hearing was adjourned at 8:09
13
14
.P.K.)
lS
16
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;.J.J_-
--_..
STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
)
)
)
kIB:l.lZ.lkA:l~
I, Kichelle A. Kitchell, Notary Public, do
hereby certify that the foregoing forty-rUne (49) pages
constitute a verbatim transcription of the said hearing.
I
do further certify that the persons were present as stated.
I do further ce::-tify that I am not of counsel
for or in the employment of any of the parties to this
action, nor do I have any interest in the result thereof.
IN WITNESS WHEREOF, I have hereunto subscribed
my name, this 9th day of August, 1994.
~C2~~..
Michelle A. Kitchell.... ' .
Notary Public i :.
00
, .'
My Commission Expires:
June 1, 1999.
~ I.
\. ,. ( ,
\.:. :: >'.,'
0\
. -~.
. );'
. .':,..."
. 0..: 0'''/ ' ..
PLEASE NOTE that unless otherwise specifically requested in
writing, the tape for this transcript will be retained for
thirty days from the date of this certificate..
,
oJ
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