-------
5 9
OU26
E. Shallow Groundwater Investigation
In June 1996, shallow temporary monitoring wells were installed at the Site to
define the shallow groundwater plume and to investigate possible active source areas at
the North Belmont PCE Site.
EPA collected groundwater samples from shallow temporary monitoring wells in
June, 1996 (Rgure 5-4). The wells were sampled to determine the shallow groundwater
plume. The shallow groundwater plume is approximately 30 to 35 feet below the land
surface. The contaminant isopleth for PCE is shown on Figures 5-5, and the results of the
sampling are noted in Table 5-2.
TABLE 5-2. MAIN CONTAMINANTS IN THE SHALLOW QW PLUME IN JUNE 1996 AT THE SITE.
4STATioN^pf-w:;*
UNITS
NBOOITWA(STW)
NB002TWA(STW)
NB003TWA(STW)
NB004TWA(STW)
NBOOSTWA(STW)
NB006TWA(STW)
NBOOTTWA(STW)
NB008TWA(STW)
NB009TWA(STW)
NBOIOTWA(STW)
CRITERIA
is»y»i>ce o
UG/L
1 U
1 U
520
1 u --': ' ""••..:•.
iO X';: . - ••••'-•
2200 •/,.:::..„>;:-,
1 U
100
1 U
1.2
5n',0.7«'
TCE:;'fes:O"'-v>:i
UG/L
1 U
1 U
13
': "-""••':."- :: • ;:-i' u
1 U
.' :.:.-:-.: :' 49
1 U
4 U
1 U
1 U
5(1),2.BB1
«MeiSi1.2OCE -::;*Q" •i'.;-^:'-y
UG/L
1 U
1 U
130
1 U
1 U
1100
1 U
2.9 J
1 U
1 U
70(1)
NOTES: ''' Primarv MCLs or MCLGs: « North Carolina GW Standards- U - Not detected- J - Estimated value
F. Top-of-Bedrock Groundwater Investigation
In July 1996, fifteen temporary monitoring wells were installed to top of bedrock.
Subsequent sampling of the temporary wells was used to design a permanent monitoring
well system to monitor both the movement of the plume along the top of the bedrock
interface and movement of the plume in the bedrock aquifer (Table 5-3).
Eight top of bedrock (MW-6 through MW-13) were installed during the remedial
investigation to determine the extent of contamination associated with releases from the
former dry cleaners location. Rgure 5-6 presents the location of all the monitoring wells.
The permanent monitoring wells were sampled in October/November 1996 and the
main contaminants are noted in Table 5-4A and Table 5-4B. The top of bedrock
groundwater plume varies from approximately 35 feet to 110 feet below the land surface.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997
5-7
-------
CONCRETE
SUPPLY
• SHAKO*
ra-io
MOT ID SCM£
&ERA
cn
CD
C
ro
FIGURE 5-4
Shallow Temporary Well Locations
-------
o
s
562009
681500
561000
i
560500
560000
559500
559000
1386500 138*7000 138*7 500 1388000 1388500 1389000 1389500 1
EASTING, feet
1390500
•'600
iT
fl
:•:•-••".• |0
SFPA
FIGURE 5-5
Shallow PCE Isopleth
NOT TO SCALE
-------
I 101
TOP W KMMCK UOMfORMO MUS
MMOCX MGM10KMO
FIGURE 5-6
Monitoring Well Locations
-------
5 9
OU30
TABLE 5-3. MAIN CONTAMINANTS IN TEMPORARY TOB QW PLUME JULY/AUG 1996 AT THE SITE.
STATION
UNITS
3PT1/TOR
rw2
rwa
FW3D
rw4
rws
rwsA
rwe
rw?
rwe
rws
rwio
rwn
rwi2
rwia
rwu
CRITERIA
>•*:«!• • -^ fe:«O';v; "i^l^TCE ^^'•K-^Q^^-^-A
UG/L
1400.0
10.0 U
460.0 J
560.0 J
1.0 U
1.7
1.0 U
2.0
10.0 U
10.0 U
5.1
3.1 ^
1.0 U
1.0 U
4.2
1.0 U
5<» 07*
UG/L
1 J
10 U
19 J
24 J
1 U
1 U
1 U
1 U
10 U
10 U
1 U
1 U
1 U
1 U
1 U
1 U
-:-::r':-?;:lttTMYLENEC»«LOBIDE::-':-:^V::-O--: ":::'v; • "*><
UG/L
NA
NA
50.0 U
62.0 J
5.4
5.0 U
5.0 U
5.0 U
NA
NA
5.0 U
5.0 U
50 U
5.0 U
5.0 U
5.0 U
5 ?fi« I 51*
>H
TABLE 5-4A. MAIN INORGANIC CONTAMINANTS IN THE PERM TOB GW PLUME OCT1996 AT THE SITE.
; • '• STATION 1 "::5 J-xCO - :i * ?« ' ':• • O : ; • ^ •• :
UNITS
VIW2
UW4
^W5
V1W6
^W7
«IW8
JIW9
^W10
^W11
^IW12
^W13
CRITERIA
U&L
1 U
1i U
1 U
12 U
1.2 U
¥-A^^-^-v<;.^:-Q':m
UG^.
160 U
62
60 U
1100
1300
1.2 U ! • 2700
1.2 U
12 U
72
1.2 U
1^ U
5'"
1600
98
4800
37
• V *»i • o i FE - ; ? : :- : : ':-;- ;- ; •••••: :Q • ; ::--:r-: ; :. :•
UG/L
4.0 U
2.6
1.0 U
52.0
340.0
180.0
3400
110.0
UG/L
60 U
500
20 U
1200
1400
1900
2400
120
160.0 | 3400
130.0 | 12 U
38 \ 2.5 U ! 12 U
50 -200 » I SO"" i 300*
North Beimont PCE Site
Record of Decision
North Beimont, Gaston County. NC
September, 1997
5-11
-------
5 9 OU31
TABLE 5-4B. MAIN ORGANIC CONTAMINANTS IN THE PERM TOB GW PLUME OCT 1996 AT THE SITE.
tTATinM : < <-iv»e « • M^.I o.fv»B n 'l: . -r»i eu n i • • -we ft •; : wr ' f%
rfW2
*W4
*W5
*W6
WIW7
dW8
dW9
MV10
YIW11
*W12
rtW13
dVV13D
:wi
;wa
:weo
CRITERIA
1.0 UR
1.0 U
1.0 UR
50.0 U
2.7 A
1.0 U
1.0 U
5.0 U
1.0 U
1.0 U
12.0
9.4
20.0 U
1.0 U
1.0 U
7.0'1"*
1.00 U
1.00 U
1.00 U
76.00
0.56 J
1.00 U
1.00 U
5.00 U
1.00 U
1.00 U
1.00 U
1.00 U
53.00
1.00 U
1.00 U
70"'
2.0
1.0 U
1.0 U
50.0 U
1.0 U
1.0 U
1.0 U
5.0 U
1.0 U
1.0 U
1.0 U
1.0 U
20.0 U
!.•;• 1;0 U
1D U
0.19*
1.00 U
1.00 U
1.00 U
49.00 J
0.54 AJ
1.00 U
1.00 U
5.00 U
1.00 U
1.00 U
1.00 U
1.00 U
16.00 J
1.00 U
1.00 U
.50! 2.8®
2.00
1.00 U
1.00 U
2500.00
1.00 U
1.00 J
14.00
80.00
1.70
37.00
1.00 U
1.00 U
630.00
1.00 U
1.00 U
5 "',0.7®
gOTES: « Primary MCLs or MCLGs; a North Carolina GW Standards; CW-6 had conoentrations of Heptachlor Epoxlde of 0.0097J which
»xeeerh North Carnlina RW Standard of 0 OO4
The top of bedrock sampling results were combined for both the temporary and the
permanent groundwater monitoring wells to obtain the contaminant isopleth for PCE as
shown on Figures 5-7.
G. Bedrock Groundwater Investigation
Nine bedrock monitoring wells (MW-14 through MW-22) were installed during the
remedial investigation to determine the extent of contamination associated with releases
from the former dry cleaners location. The bedrock groundwater plume was evaluated by
using data from the permanent monitoring wells installed within the bedrock aquifer as well
as the residential drinking water wells in the study area. The main contaminants of the
bedrock monitoring wells are noted in Tables5-5A and B. The contaminant isopleth for
PCE was computer modeled using the data from both the permanent bedrock monitoring
wells and the residential drinking water wells; as shown in Rgures 5-8.
H. Other Constituents in Groundwater
During the investigation of the groundwater plume, additional contaminants were
found which characterized a second plume. These contaminants were not found in the
original site plume; the top of bedrock aquifer contains 1,1-dichloroethene and the bedrock
aquifer contains 1,1-dichloroethene, 1,1,1-trichloroethane and trichlorofluoromethane.
These compounds were not noted in the above sections because they did not exceed
North Belmont PCE Site
Racord of Decision
North Belmont, Gaston County, NC
September, 1997
5-12
-------
562000
561500
561000
560500
560000
559600
389000 1389600 1390000 1390600
ugfl.
m
500
.-.•,.., 100
FIGURE 5-7
Top of Bedrock PCE Isopleth
NOT TO SCALE
-------
5 9
OU33
TABLE S-SA. MAIN ORGANIC CONTAMINANTS IN THE BEDROCK GW PLUME. PERM MONITORING WELLS
•: STATION '•••! :«*^t^-DCF -': '"'O : \''::'<-'ClfU "':-'<:"';:w-sQ •• •••
UNITS
SIB002CW
>IB002CWS
SIB003CW
4B003MW
4B004CW
4B005CW
4B006CW
4B007CW
4B009CW
MB014MW
4B01SMW
«JB016MW
•4B017MW
MB018MW
4B019MW
4B020MW
MB021MW
JB022MW
MB022MWD
CRITERIA
UG/L
1.00 U
1.00 U
13.00
11.00
0.80 J
26.00
940.00
9.40
1.00 U
7.10
1.00 U
110.00
1.00 U
1.00 U
1.00 U
1.00 U
1.00 U
1.00 U
1.00 U
70 '" v
UG/L
1.00 U
1.00 U
1.00 U
1.00 U
1.00 U
20.00 U
50.00 U
4.00 U
1.00 U
2.40 J
1.00 U .
1.40 .. •: .. •
1.00 U
1.00 U
1.00 U
0.83 J
1.00 U
1.00 U
1.00 U
0.19* : :
""'."I".-;- TEC •••'•"•'. • VQ 'I'-.': ' PCP " .' ' :': -:-:'-."O'%:
UG/L
1.00 U
1.00 U
3.00
4.00
1.00 U
20.00 U
280.00
7.40
1.00 U
4.00 U
1.00 . U
30.00
1.00 U
1.00 U
1.00 U
1.00 U
1.00 U
1.00 U
1.00 U
5 "'.2.8®
UG/L
0.50 J
0.50 J
77.00
69.00
2.00
520.00
3500.00
160.00
1.00 U
160.00
1.00 U
320.00
1.00 U
1.00 U
420
3.10
1.00 U
2.00
2.00
5 |1). 0.7 *
OOTFR ") PPD vah»>««>xeoed Primary Mri sorMCKSs- «> RJ LIP uahux pvroeei Mortti Carolina GW Slnnrtarrte
TABLE 5-5B. MAIN INORGANIC CONTAMINANTS IN THE BEDROCK GW PLUME, PERM MONITORING WELLS
STATION 1 CD O
UNITS
JB002CW
•JB002CWS
•JB003CW
gsooaww
4B004CW
4B005CW
vIBOOSCW
4B007CW
sIBOOSCW
MB014MW
4B015MW
MB016MW
JB017MW
>JB018MW
>IB020MW
SIB021MW
4B022MW
slB022MWD
CRITERIA
UGA.
2 U
2 U
1 U
1 U
1 U
1.2 U
1.2 U
1.2 U
10
1.2 U
1.2 U
1.2 U
12. U
12. U
12 U
12 U
12 U
12 U
5n»
PB ' ;'- ''« :!l:.'-i::-:":V JN V- , • ' V& '• \ - •:•-• .^At'' ' '^ i'i- O MM':'i O i ':-:'-:FE • ' O
UG/L
3.0 U
2.0 U
15JO
£0 U
3.0 U
5.3
12 U
48.0
280.0
12 U
12 U
12 U
12
12 U
12 U
12 U
12 U
12 U
15*
UG/L I
7400.0
7300.0
180.0
:20.0 U
.48.0
290.0
2.5 U
520.0
4400.0
13.0
2.5 U
52
18.0
82
27.0
2.5 . U
5.7
7.7
21 DO"9, 5000 m
UG/L
20 U
20 U
20 U
30 U
20 U
SO U
50 U
67
92
810
260
1300
5300
150
160
51
120
170
50-200"
UG/L
25.0
23.0
20.0
8.0 U
29.0
280.0
2.5 U
17.0
100.0
72.0
230.0
170.0
110.0
180.0
43.0
12.0
260.0
260.0
50 *"*
UG/L
30 U
120
1800
40000 U
540
29000
12 U
1800
21000
2700
7000
5400
5800
16000
1600
880
18000
19000
300 "x*
vIOTES:"1 RED Values exceed Primary MCU or MCLGs; e BLUE values exceed North Carolina GW Standards ;
'" rtRFFN \/aln»« pYrA*>rt Recontiary MCI «
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September. 1997
5-14
-------
562000
561500
561000
I
8
a
560600
560009
559500
TtM^^fyiin C-737 f?:01 X
1366500 1387
1388000
1388500 1389000
EASTING, feet
1389600 1390000
1390500
$
'M
10
1391000
&FPA
FIGURE 5-8
Bedrock PCE Isopleth
NOT TO SCALE
-------
5 9 OU35
regulatory guidelines or criteria in the groundwater monitoring wells. Figure 5-9 denotes
the concentration of the 1,1-dichloroethene at the respective locations in the top of
bedrock monitoring wells. Rgures 5-10 and 15-11 denote the concentration of 1,1-
dichloroethene and trichlorofluoromethane at the respective locations in the bedrock
monitoring wells and the residential wells (1,1,1-trichloroethane was not plotted due to its
similarity in concentration with 1,1-dichloroethene).
I. Ecological Survey
A bioassessment was conducted of the "unnamed tributary-A" located north of the
Site. Study objectives were to (1) characterize the benthic macro invertebrate community
of the tributary and an established reference stream (Dutchmans Creek) near Mount Holly,
N.C., (2) evaluate the quality of the stream habitat sites using the Rapid Bioassessment
Methodology (EPA, 1989), and (3) conduct in-situ physicochemical measurements.
Completion of these study objectives showed that the stream was not affected by the Site.
The headwaters of the unnamed tributary adjacent to the Site are located less than
1000' northwest of the railroad crossing at Goshen Grove (see Figure 5-12). The
unnamed tributary flows through an urbanized area for approximately one mile and then
joins another unnamed tributary prior to its confluence with Fites Creek. Due to their
proximity to urban areas, both unnamed tributaries and their floodplains have been
subjected to environmental degradation. Past studies by the NCDEHNR, 1974-75 & 1986,
found poor water quality due to urban runoff in the unnamed tributary that joins Fites Creek
northeast of North Belmont.
Sampling stations in the unnamed tributary adjacent to the Site were located near
the headwaters at the railroad crossing (UT-1), proximal to the Site (UT-1 A), and
downstream of the Site at the railroad crossing and just before the confluence with the
unnamed tributary to Fites Creek. NCDEHNR indicated a suitable reference site,
Dutchmans Creek, existed near Mount Holly, N.C. Reference sites are minimally impacted
sites and serve to provide insight into biological potential for an area and allow comparison
to other sites to determine if impacts exist and the severity of those impacts. Dutchmans
Creek was sampled at SR 1918 (Sandy Ford Road) north of Mount Holly.
The Rapid Bioassessment III of the unnamed tributary adjacent to the Site (stations
UT-1, UT-1 A, and UT-2) and Dutchmans Creek resulted in these findings:
• Benthic macroinvertebrate collections from the unnamed tributary (UT)
indicate that the creek is impaired. Pollution-tolerant species of benthic
macroinvertebrates, primarily midges and flies (Diptera) were predominant
numerically in both taxa (species) and individuals (density).
North Belmont PCE Site
Record of Decision
North Belmont Gaston County, NC
September, 1997 5-16
-------
m
2
z
FIGURE 5-9
1,1 -DCE Concentrations in
Top of Bedrock Aquifer
1000
1000
2000 Feet
SCALE
-------
FIGURE 5-10
1,1 -DCE Concentrations
in Bedrock Aquifer
en
vc
1000
1000
2000 Feet
SCALE
-------
FIGURE 5-11
Trichlorofluoromethane
Concentrations in Bedrock Aquifer
en
o
cr
UN!
oo
1000
1000
2000 Feet
SCALE
-------
SOURCE: OeLORME MAP EXPERT
&EPA *
SAMPLE LOCATION
SITE LOCATION
FIGURE 5-12
Ecological Survey Locations
NOT TO SCALE
OUJ9
-------
5 9 OU40
• Benthic macroinvertebrate collections from the reference station,
Dutchmans Creek (DC-1), were diverse with a total of 35 species
classified. Pollution-sensitive species of benthic macroinvertebrates
(Ephemeroptera, Plecoptera, and Trichoptera = EPT) were more prevalent
at DC-1 from both a numerical density and taxa richness perspective. No
impairment is indicated for DC-1.
• Habitat degradation was evident at all the unnamed tributary stations.
Lack of habitat diversity, siltation/sedimentation, and the absence of
riffle/runs all contributed to low habitat evaluation scores. This was an
obvious factor affecting the benthic macroinvertebrates at the unnamed
tributary since the biological potential of a site is largely determined by the
quality of the habitat at that site. Quality of the habitat at all the unnamed
tributary sites could only be classified as fair. Habitat evaluation scores
ranged from 56-67.
• The reference station, DC-1, had a habitat evaluation score of 100 which
falls into the classification of "good" based on the habitat assessment form.
Some sedimentation effects prohibited DC-1 from having a habitat
evaluation sWe in the "excellent" range (104-135). Habitat diversity,
coupled with no serious habitat degradation, led to a diverse benthic
macroinvertebrate fauna at DC-1.
• In-situ physicochemical measurements at the unnamed tributary (UT) and
Dutchmans Creek (DC-1) revealed no violations of state water quality
standards. Dissolved oxygen, pH, and water temperature were similar in
range in both creek systems. Conductivity values were higher at the
unnamed tributary possibly due to the effects of urban drainage.
Due to the unnamed tributary's location in a highly urbanized area, it is difficult,
without extensive and intensive study efforts, to ascertain what effect the Site has on
impairment of the benthic macroinvertebrate community. For example, both urban and Site
effects could be impacting the biology of the unnamed tributary.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September, 1997 5-21
-------
5 9 OU41
6.0 SUMMARY OF SITE RISKS
The North Belmont Site is releasing contaminants into the environment. The
Baseline Risk Assessment Report presents the results of a comprehensive risk
assessment that addresses the potential threats to public health and the environment
posed by the Site under current and future conditions, assuming that no remedial actions
take place, and that the surrounding area will remain a residential community.
The Baseline Risk Assessment Report consists of the following sections:
identification of chemicals of potential concern; toxicity assessment; human exposure
assessment, and risk characterization. All sections are summarized below.
A. Chemicals of Potential Concern
Data collected during the Ri were reviewed and evaluated to determine the
chemicals of potential concern at the Site which are most iikely to pose risks to the public
health. These contaminants were chosen for each environmental media sampled.
The chemicals of potential concern in groundwater are: 1,1-dichloroethene, cis-1,2-
dichloroethene, 1,4-dichlorooenzene trichloroethene, trichlorofluoromethane,
tetrachloroethene, methylene chloride/chloroform, bis(2-ethyl hexyl) phthalate, alpha
chlordane, gamma chlordane, heptachlor epoxide, aluminum, cadmium, chromium, lead,
manganese, and zinc.
The chemicals of potential concern in soil are benzo(a)pyrene, benzo(bk)
fluoranthene, benzo(a)anthracene, dibenzo(a.h) anthracene, indeno(1,2,3-cd) pyrene,
aluminum, chromium, manganese, and vanadium.
Once these chemicals of potential concern were identified, exposure
concentrations in each media were estimated. Exposure point concentrations were
calculated for surface soils using the lesser of the 95 percent upper confidence limit (UCL)
concentration or the maximum detected value as the reasonable maximum exposure
(RME) point concentration. For evaluation of groundwater, an alternative approach, often
used to assess potential future exposures from wells that might be installed in an area of
contaminated groundwater, is to select several different wells from the approximate center
of the groundwater plume, and to average these values to derive an estimate of
concentration values which might reasonably be expected under worst-case conditions. At
this Site, the highest concentrations of PCE and TCE occur in wells SPT1, MW6, CW6,
and TW6. Therefore, these wells were chosen to represent the center of the plume. In
accordance with Region IV guidance, the mean concentration (rather than the UCL or
maximum concentration) is used in this case. Exposure point concentrations are shown
for groundwater in Table 6-1 and for soil in Table 6-2.
North Belmont PCE Site
Record of Decision
North Belmont Gaston County, NC
September, 1997 6-1
-------
DU42
TABLE 6-1
EXPOSURE POINT CONCENTRATIONS FOR GROUND WATER
(UG/L)
CHEMICAL OF POTENTIAL
CONCERN
Designated Center Plume Wells1
MW-6
CW-6
TW-6
SPT-1
1,1-Dichloroethene
cis-1 ,2-Dichloroethene
1 ,4-Dichlorobenzene
Trichloroethene
Trichlorofluoromethane
Tetrachloroethene
Methylene Chloride
Chloroform x
SemivoJaliJes
Bis(2-ethylhexyt)phthalate
SOU
76
SOU
49 J
SOU
2500
ND
SOU
SOU
940
20 U
' • 280 ':;-
SOU
3500
ND
SOU
110
28
1100
49
2200
ND
10J
1 J
1400
ND
MEAN
;";HfeC'::'^%:;^;:
25.0
531.5
17.5
94.8
25.0
2400.0
25.0
69.0
Pesticides
alpha Chlordane
gamma Chlordane
Heptachlor epoxide
inorganics
Aluminum
Cadmium
Chromium
Lead
Manganese
Zinc
0.25 U
0.25 U
0.1 U
0.25 U
0.25 U
0.1 U
0.13
0.13
0.05
1100
1.2 U
14
1.2U
52
250
SOU
1.2U
2.5 U
1.2 U
2.5 U
2.5 U
562.5
0.60
7.6
0.60
26.6
125.6
1 Exposure point concentrations for groundwater are based on data from wells in the center of the plume.
Data that was nondetect (i.e. 50 U) were assumed to be present at Vt the detection limit. As a result, data with
"U" qualifiers were multiplied by 0.5 before the mean was calculated.
ug/l - micrograms per liter
J = Estimated value
ND «= Not detected
North Beimont PCE Site
Record of Decision
North Beimont, Gaston County. NC
September. 1997
6-2
-------
TABLE 6-2
EXPOSURE POINT CONCENTRATIONS FOR SOIL
Chemical of Potential
Concern
SefflfvoiatteS
Benzo(a)anthracene
Benzo(bk)fluoranthene
Benzo(a)pyrene
lndeno(1 ,2,3-cd)pyrene
Dibenzo(a,h)anthracene
Irwrgantc*
Aluminum
Chromium
Manganese
Vanadium
Mean of
Log transformed
Data
'-
-1.16
-1.18
-1.16
-1.33
-1.35
9.8
3.20
5.59
5.43
Standard Deviation
of Logtransformed
Data
0.91
1.17
0.91
0.94
0.43
0.36
1.03
1-04
0.58
N">
6
6
6
6
6
6
6
6
6
H Statistic
4.478
6.001
4.478
4.478
2.947
2.651
4.905
4.905
3.287
Maximum
Concentration
(mg/kg)
2.0
3.2
2.0
1.6
0.62
29000
80
1800
450
95% UCU21
2.9
14
2.9
2.7
0.50
29363
397
4518
632
Exposure Point
Concentration
JmoAgJ131
2.0 (max)
3.2 (max)
2.0 (max)
1 .6 (max)
0.62 (UCL)
29000(max)
80(max)
1800(max)
450(max)
01 Number of Samples
m 95% Upper Confidence Limit
131 The 95% UCL of the mean concentration represents the exposure point concentration for a chemical unless
it exceeded the maximum detected concentration. Where the maximum detected concentration was exceeded,
the maximum detected concentration was used as the exposure point concentration.
mg/kg = milligrams per kilogram
en
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997
6-3
-------
5 9 0044
B. Exposure Assessment
The exposure assessment evaluates and identifies complete pathways of exposure
to human population on or near the Site. Current exposure pathways include exposure
through incidental ingestion of soil; inhalation of fugitive dusts from soils; dermal contact
with soils; and ingestion of water from private wells. Land use assumptions include
residential and commercial.
Future use scenarios consider construction of a water supply well within the
groundwater contaminant plume and ingestion of soil, inhalation of dusts and dermal
contact with soils as a worse-case scenario. Possible exposure pathways for groundwater
include exposure to contaminants of concern from the groundwater plume in drinking water
and through inhalation of volatiles evolved from water through household water use.
Further detail and mathematical calculations can be reviewed in the Baseline Risk
Assessment.
C. Toxicity Assessment J;
Under current EPA guidelines, the likelihood of adverse effects occurring in
humans from carcinogens and noncarcinogens are considered separately. These are
discussed below. Tables 6-3 and 6-4 summarize the carcinogenic and noncarcinogenic
toxicity criteria for the chemicals of potential concern.
EPA uses a weight-of-evidence system to classify a chemical's potential to cause
cancer in humans. All regulated chemicals fall into one of the following categories: Class
A - Known Human Carcinogen; Class B * Probable Human Carcinogen; Class C - Possible
Human Carcinogen; Class D - Not classifiable as to human carcinogenicity; and Class E -
Evidence of Noncarcinogenicity in humans.
Cancer slope factors have been developed by EPA for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic chemicals. Slope
factors, which are expressed in units of kg-day/mg, are multiplied by the estimated intake
of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level. The term "upperbound"
reflects the conservative estimate of the risks calculated from the slope factor. Use of this
approach makes underestimation of the actual cancer risk highly unlikely.
Reference doses (RfDs) have been developed by EPA for indicating the potential
for adverse health effects from exposure to chemicals exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates of lifetime daily exposure
levels for humans, including sensitive individuals; that are free of any adverse effects.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September. 1997 6-4
-------
TABLE e-: '"ARCIMOQEMIC TOXICTTY DATA
Chemical
vown«:.::;
CtitofOwm
1.4-ttehlorobenierw
1.1 Dlchloroethene
cis-t.2dichloToetnen»
Methytene chloride
TetracMoroelhene
Trlchtoroelhene
Trichlorollinrornetharie
SettllVtMBHm .
Benzo(a)pvrene
Benzo(b.k)Huoiin»hane
Betuo(»anlhraoene
»s<2-ethythe«yI)|)hlhaWe
Dibemo(a.h)anthracene
lndeno(t.2.3
NC
81
NC
A
82
NC
NC
NC
6IOE-03
2.4E4B
6006-01
»
7.SE-03
52E4B
t.tOE-OZ
-
;
730E«00
7.30EXI1
730E-01
I40E-02
730E»00
7.30E-OI
?;•';•• ":::-: :h:'"\:- l'~ '
1 30E»00
etuE'OO
••
NTV
••
NTV
NTV
••
Tumor Type
USA
Kidney tumors
Liver tumor*
_.. Adrenal
--
Hernalocellular
adenomas
NA
NA
Forestomach1"
ForeslomachK*
Forestomach '"
Liver carcinoma
Forestomach M
Forettomach"1
Liver carcinomas
Liver carcinomas
;
-•
-
--
-
Rat
Mouse
Rat
••
Mouse
NA
NA
Mouse
Mouse
Mouse
Mouse
Mouse
Mouse
Mouse
Mouse
• - .. .•
-
Reference
IRIS
HE AST
IRIS
IRIS
NCEA
NCEA
IRIS
IRIS. EPA IV
MIS. EPA IV
IRIS
IRIS. EPA IV
IRIS. EPA IV
IRIS
IRIS
IRIS
IRIS
IRIS
^•»cStfidor
Tumor Typt
atoE-oz
NTV
1.BE-01
I.64E03
200E43
600E43
" : - ••r:': ' •':• :•:• • '•
3ioe»oo
3IOE-OI
3 IDE 01
NTV
310E400
310E-01
I30E*00
91E»00
--
G3E*00
42E«Ot
NTV
Uv«r catdnomiB
-
adanoSrcmoma
-
Adenomas and
carcinomas
NA
NA
NA
NA
NA
--
NA
NA
Llvar carcinomas
Liver carcinomas
Lung, trachea
Lung cancer
Animal
Spaaet
Reference*
'.-:; •/:•., V;;'.; - -.^.
Mouae
••
MOUM
--
Mouse
NA
NA
--
NA
NA
NA
NA
NA
Mouse
Mouse
Human
Human
--
ms
-
IRK
-.
INS
NCEA
NCEA
--
NCEA
NCEA. EPA IV
NCEA. EPA IV
--
NCEA. EPA IV
NCEA. EPA IV
Sk&ftdof
T63E03
300E02
7SOE01
9.38E-03
6SE-02
I.38EO2
-
I46E*OI
)46E»00
146E+00
2.80E-02
146E»01
I46E*00
::.-.- -; •.-.'.•' ' :.'.'.
IRIS
IRIS
IRIS
••
IRIS
IRIS
260E»00
t 82E+01
en
vc
a = EPA \V - Region \\l Supplemental Guidance to RAGS. 1995; IRIS - Integrated Risk Information System (IRIS. 1997). HEAST - Health Effects Assessment Summary Tables (EPA. 1995); NCEA
Nalitonal Center lor Environmental Assessment (EPA. 1997)
b = Dermal Slope Factor = Oral Slope Factor/Oral Absorption Factor
c = Foroslomach squamous cell papttomas and carconomas
NA Not available. NC - Not classified as a carcinogen; NTV- - No loxtdly value available
6-5
-------
TABLE MOMCA
Chemfcal
VoMMr* s /i*!^
CMwotoftn
1.4-DleMof(*«r«»n»
1.1-Dtehloroelhena
ds-1.2-dte«oro«rthene
Trfchtofotfhtrw
StwKotelKw %J ••::'- ^
ffenzo(a)pyrene
Benro(a.b> )!luorant>en»
Bls(2.«ff^xyl)Tjr*aMe
OfbofUufs^htwttwttMfw
lndono<1,2.3-al)p|rwn«
Petto* ,-, - ..
Chkmtane
InotpcMtet ••
Aluminum
CaiJiiJijm(loooV8or1)
Cadmlum(water)
Chromium III
Chromium VI
Lead
ManovwM(tood)
Manganese (nondetary)
Vanadium
Zinc
Im^uoaEM
Oral RIO
(mrttfay) j
11,
1.00E-02
MTV
9.00E-03
1.00E-02
1 .OOE-02
8.00E-03
^S < 'v^J--
NTV
NTV
2.00E-02
NTV
NTV
eOOE-05
i '
t.OOEtOO
1.00E-03
5.00E-04
1.0E»00
5.0E-03
NTV
1.4E-01
470E-02
7.00E-03
300E-01
ic roxicrn
c^ar
?..- , . v>
MKfcjm
-
M«Hum
NA
HA
«' *S> ^?
•.'Svt^.i.;--v,
-•
••
Mrilum
••
-•
,
Mldlum
\ ""' >•. ^
NA
NA
NA
Lew
Low
•-
Medium
Medium
NA
Medium
f DATA
Toxldly Eftdpdm
•; \
Fatty cyst luiiiialluif In Mvaf
»
Liver Iwten*
hcmatoolVnMnogloMn
NA
x*)^lV! - -^ * « * :
Hft*^* ^ i . v1?'."
*•*
»"
•WwtoflOfetttrtlv* weight
*«• -:v-
-
>
Owhjtwirophy
;;- ; i v < , - .
NA
Prolehurta
Protatnuita
No eflactt observed
No atfectt obvafvad
«
CHS Meets
CNS aflecti
|L|n LLl.-IILL-llljui
no Riionnaiion
Decreased bkxx) enzyme
UF/MF
1000/1
••
1000/1
3000
100/1
NA
A -. •.
„
-
1«w<
-;:;-:.K::*> •/:-.'
--
100W*
NA
10/1
10/1
100/10
BOO/1
-
1/1
1/1
100
3/1
Reference
--
ins
--
-
UC&CT
NCEA
lOMS
,
-
«
; IRIS
.,-.'.:;: -
--
IRIS
IRIS
IRS
IRIS
I»S
l«3
1"
IR1S
IRIS
HEAST
IWS
Inhialton RIO
(mo«pyday|
,-
NTV
2.29E-01
NTV
NTV
HflnF.ol
NTV
jj •.•"
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
1.4E-05
NTV
NTV
ToxMty Endpotm
.. f
-
IncfaatadDvarwalght
-•
•• '
-
to^1SlamfflbnJnilUn0
•" s ^ •> % " -.^
••
•-
••
-
••
i „•„ ,\^ .'.."' i1
--
-
--
••
--
-•
••
-•
--
Impairment of neurooehsvtoral
--
UF/MF
-•
100/1
••
••
"
..
}• •• f •.
••
-
••
••
-
-•
••
-
-
••
-•
••
1000/1
Rttofflnoc^
>. :> •.
••
IRIS
-•
»
"
»
•. v ^ -, *
- *' ^'^J*.>'
••
•-
--
••
--
*" ^
--
V ' •.
--
--
--
••
--
--
IRIS
Dermal RID
^ *• •> %
800E-03
•-
7.20E-03
B.OOE-03
B.OOE-03
4BOE-03
%v % , \
-•
•-
1. OOE-02
--
•-
••
3.00E-OS
1 . ••
-•
2.00E-04
--
2.00E-01
1.00E-03
NA
9.4E-03
143E-03
6.00E-OZ
cn
cr
ON
IRIS - Integrated Risk Information System (IRIS. 1997); HEAST • Health Effects Assessment Summary Tables (EPA. 1995); NCEA - National Center tor Environmental Assessment (EPA. 1997).
b - Dermal Slope Factor. Oral Slope Factor/Oral Absorption Factor
NA - Not available; NC - Not classified as a carcinogen; NTV- - No toxWty value avertable
6-6
-------
5 9 GU47
Estimated intakes of chemicals from environmental media can be compared to the
RfD. RfDs are derived from human epidemiological studies or animal studies to which
uncertainty factors have been applied. These uncertainty factors help ensure that the
RfDs will not underestimate the potential for adverse noncarcinogenic effects to occur.
D. Risk Characterization
The risk characterization integrates the toxicity and exposure assessments into
quantitative and qualitative expressions of risk. The output of this process is a
characterization of the Site related potential noncarcinogenic and carcinogenic health
effects.
Potential concern for noncarcinogenic effects of a single contaminant in a single
medium is expressed as the hazard quotient (HO), or the ratio of the estimated intake
derived from the contaminant concentration in a given medium to the contaminant's RfD.
By adding the HQs for all contaminants within a medium or across all media to which a
given population may be reasonably exposed, the Hazard Index (HI) can be generated.
Calculation of a HI in excess of unity indicates the potential for adverse health effects.
Indices greater than one will be generated anytime intake for any of the chemicals of
concern exceeds its RfD. However, given a sufficient number of chemicals under
consideration, it is also possible to generate a HI greater than one even if none of the
individual chemical intakes exceeds their respective RfDs.
Carcinogenic risk is expressed as a probability of developing cancer as a result of
lifetime exposure. Excess lifetime cancer risks are determined by multiplying the intake
level with the cancer potency factor. EPA's acceptable target range for carcinogenic risk is
one-in-ten-thousand (1E-4) to one-in-one-million (1E-6),
Cancer and noncancer risks for the current and future use scenarios for the Site
are summarized in Table 6-5.
SOIL
As shown in this table, the screening-level Reasonable Maximum Exposure (RME)
Hazard Index for soil is below a level of concern for adults (Hi = 0.22), but is slightly above
levels of concern for children (HI = 1.8). This value is due to contributions from aluminum,
chromium, manganese, and vanadium. Because none of these chemicals cause
noncancer effects on the same target tissues, and because none of the chemical-specific
HQ values exceed a value of one, it is concluded that exposure to soil is not likely to pose
a significant noncancer risk to children.
North Belmont PCE Site
Record of Decision
North Belmont Gaston County, NC
September. 1997 6-7
-------
0048
TABLE 6-5
SUMMARY OF HAZARD INDICES AND CARCINOGENIC RISKS
REASONABLE MAXIMUM EXPOSURE SCENARIO
^i^UilflgCENAFHO '
Risks From Soil
Current/Future Child Resident1
Current/Future Adult Resident1
Combined Current/Future Child
and Adult Resident
TOTAL HAZARD INDEX ; f
^fOTALCANCER RISK J
1.80
0.22
; -. - -> -. .
3.1E-05
2.0E-05
5.1E-05
Risks From Groundwater2 ;
Future Child Resident • ';.
Future Adult Resident
Combined Future Child and Adult
Resident v
20.89
8.96
-•:. „ • :."
7.8E-04
1.5E-03
22E-03
Combined Risks From Soil and Groundwater
Future Child Resident
Future Adult Resident
Combined Future Child and Adult
Resident
22.69
9.17
—
8.1E-04
1.5E-03
2.3E-03
1 Risks from soil are the same for the current and future child and adult residents.
* Risks from groundwater are based on data from the center of the tetrachloroethene (PCE) and
trichloroethene (TCE) groundwater plume.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997
6-8
-------
5 9 OU49
Estimated RME excess cancer risks from soil to residents (child plus adult) are 5E-
05. This risk is due entirely to the presence of polyaromatic hydrocarbons (PAHs) in soil,
especially benzo(a)pyrene. The risk is contributed about equally by ingestion exposure
and dermal contact. These risk levels are within the range (1E-04 to 1E-06) that are
generally considered to be acceptable by EPA.
GROUNDWATER
The screening level RME Hazard Index would be in a range of concern for both
children (Hl=20.89) and adults (Hl=8.96) if water from the center of the plume were used
for drinking and showering. This risk is primarily due to PCE, with a smaller but still
significant contribution from cis-1,2-DCE. Other chemicals in the center of the plume do
not have HQ values that exceed one, and do not appear to pose significant noncancer risk.
Estimated RME excess cancer risk to residents {child plus adult) from water at the
center of the plume is 2.2E-03, substantially above the usual accepeptable risk range of
1 E-04 to 1 E-06. This estimated excess cancer risk is due primarily to PCE (1.9E-03), with
a smaller but still significant contribution (2.6E-04) from 1,1-DCE. These risks are derived
mainly from the ingestion rolite (2.1 E-03), with a relatively small contribution due to
inhalation of volatiles while showering (1.1 E-04). Other chemicals which contribute RME
risks greater than 1E-06 include chloroform,TCE, bis (2-ethylhexyl)phthalate, heptachlor
epoxide, and 1,4-dichlorobenzene. The combined RME risks from all of these chemicals is
6.9E-05.
The quantified carcinogenic risk for each chemical of concern is given in Table 6-6.
LEAD '-"••• '•'•:^,-^."^-'::-.; ,"'•:.•'-":'•" '.
Lead concentration data are available for 31 groundwater wells. Most of these
wells (24 out of 31) had lead levels at or below detection limits (<3 ug/l), and 29 of 31 had
concentrations at or below the current EPA action level for lead in drinking water (15 ug/l).
Only two wells(converted wells NB007 and NB009) had concentrations above the action
level, with measured values of 48 and 280ug/l, respectively. Based on the groundwater
data, it seems likely that most wells will be associated with lead levels that are not in a
range of concern.
E. Conclusions
Actual or threatened releases of hazardous substances from this Site if not
addressed by implementing the response action selected in this ROD, may present an
imminent and substantial endangerment to public health, welfare, or the environment.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September. 1997 6-9
-------
SCENARIO
Cur/ent/FulifH,
Risks from Sow
Future Risks
Utasedcn
uentef Plume
RECEPTOR
Child Resident
Adult Resident
._*
Chmj RostoBfrt
Adull Resident
_
CHEMICALS EXCEEDING.
PERCi
CHEMICAL
benzoiatovrane
dttwnziahtentiracene
benzofbkyhjor&nthene
benzofataiiwWrtOiino
banzofalDvrane
dttwnzfaJitantvacene
befuoftoMfluoranthene
hMvn/afcwtirarfinn
•nH^t^-nrtfn—
benzofatovrene
dw«iz(ah)aiinracene
penzoflMOnuoranthBne ,
hennWabmtiMflm
InrfDnrWI^'Ln'flliWn-
Tetrachloroethene (PCE)
Ll-Ofchtofoetwne
Trichtaroethene fTCE)
heotacrrioreiioxlde
1 A HirMrttlwMnino
Tetrachloroethene (PCE)
Chtorotonn
TricNoroethene fTCE)
bls(2-etivtiexvnphthalate
heoiachlor eooxlde
1 JJHrhbunh..*.**.
TetracMofoetnene (PCE1
1.1-Dtchtoroelhene
CfWJfUlUf Ml
Trtchloroethene fTCE)
bM2-etnt»xvnDhlnalaie
1 ^.nM,lnmhanf«n<.
-fcft£$$$ftlB&*C RISK AND THEIR
CARCINOGENIC RISK
1.9E05
49E06
31E06
19E06
1KFf>R
1.3E45
3.1E06
20E06
1 3E 06
inpjvt
32Efl5
80E06
5.1E-06
39F-OR
9RPJ1R
6 BE 04
flPF^S
57E-06
sap^e
25F06
»1PJM
1.2E-03
18E^4
2.0E^)5
1.5E-05
91E46
43E416
iv.n«
1.9E-03
2.6E04
2.1 EOS
2.1E-05
1.4E-05
BBE-06
PERCENT
62.3%
16.1%
10.2%
6.2%
X9V.
637%
15.2%
9.8%
64%
40*.
62.9%^
15.7%
100%
63%
•11*.
B72%
105%
0 7%
07%
03%
ntv.
800%
120%
1.3%
1.0%
06%
03%
niv.
800%
12JJ%
1.3%
10%
06%
03%
PKPO^l 1RF OOI ITCQ P VOPFOIWi'i t P f¥i f* AQf*tUfV*CMtr* DICI/ iTrtTAI
TVvf*T5 T^wJIi /^VV VfiwJ* AW wrv»\ jlW J W«Ti» w ftHMJ vl W^Jlir ^l^jh* lildl^l Uv^liri^*
EXPOSURE ROUTE
gejmal Contact with Surface
ggmal Contact with Surface
ggjmaJ Contact with Surface
Ingestton of Groundwater
Note' NontnoBSllon Use was
n^evaTuatelflorlie cNM
resuenl.
^~.
Ingeston of Groundwater
Nontaestton Uses of
GrounDwaler
CARCINOGENIC RISK
2.5E45
5.4E06
LIE-OS
90E06
36E-05
14E-05
1.1E-04
1.1E-04
2.1E03
1.1E-04
PERCENT
822%
17.8%
550%
450%
71.4%
286%
92.4%
7.6%
92.4%
7.6%
950%
50%
6-10
-------
SCENARIO
RECEPTOR
CHEMICALS EXCE
tC R.SK AND THE.R
CHEMICAL
CARCINOGENIC RISK
PERCENT
wrararaBei^
EXPOSURE ROUTE
CARCINOGENIC RISK
PERCENT
CMM Resident
Tetracntoroethene (PCE)
1.1-DfcMoKMtlMW
benzofalpvrane
Titehtoroethena fTCE)
dtMoria.h>antwa
benzo4bk)fluof W rtl MM 10
heptacfilof opoxidB
1.4-OfcNoraberuera
68E4M
841%
82E-05
10.1%
24%
07%
Oamai Contact with Surface
53E-06
07%
49E-06
0.6%
GroundHvator
25E45
54E-05
78E«4
3.1%
07%
962%
04%
25EXW
03%
03%
19E4K
02%
Adult Resident
Tetrachlofoettiene (PCE)
1.1-Ochloroetiene
CNofolwin
TrichtofMthMie (TCE)
benzo(alpvrene
heplacntaf opoxidB
djbgtftn h>Hiilmueir
hBtira^hk)* • i«in)|y^
ataoti
t.2E 03
827%
1.8E-04
12.4%
20E4S
1.4%
10%
09%
91E06
06%
43E-06
03%
Dgmal Contact wtthSurtaoB
of Groundwater
Uses of
1.1E-05
90E-06
13EXX)
07%
06%
91.1%
7.6%
3.9E-O8
0.3%
3.1E-06
02%
0-1%
1 TF-fK
Telfachtofpethene (PCE)
1.1-DWitoroetiene
CMoroiofifi
TricNoraethafW (TCE)
bb(2-ethvlhexv»)phlhalale
heplacNor oDoxkto
I.^Otchtoroberuene
benziXMOfkiofanthone
19F.03
833%
Ingestton of Graundwater
26F04
11.4%
1 4%
2.1E-OS
09%
0.9%
0.6%
_BJ£J]6_
04%
0.3%
Detmal
Contact with Surface
2.1EO3
1.1EO4
36EO5
1.4E-OS
929%
4.9%
1.6%
0.6%
03%
S.1E-06
39E-06
01%
OU51
6-11
-------
TABLE 6-. >ort. SUMMARY OF CHEMICALS AND EXPOSURE ROUTES EXCEED,.... A HAZARD INDEX OF 1; REASONABLE MAXIMUM EXPOSURE SCEN, .0
SCENARIO
Current/Future Risks
From SoH
Future Risks From
Groundwaier
Combined Future Risk
From SoH and
Groundwater
(Center Plume Wets)
RECEPTOR
CNW Resident
Adult Resident
ChM Resident
AduN Resident
CNkf Rosktent
Adull Resident
CHEMICALS EXCEEDING A HAZARD INDEX OF 1
AND THEIR PERCENT CONTRIBUTION
CHEMICAL
No chemlcab exceeded a
hazard index oil
No dMrtbab exceeded a
hazard Index oil
TB^HI nlllik»MMjftMtna
ds-1.2Dtehtoroethene
Y*A*4J«MHkMAMIfMk
Tetrachtoroeiriene
ds-1 ,2-DtcWoroethene
cU- 1 ,2-Otchloroethene
Tetrachloroethene
_|_ « A jTMiliijiKLT-nrti iLjia
HAZARD INDEX
153
34
1.0
66
1.5
153
3.4
10
66
1.5
PERCENT
73.4%
16.3%
4.8%
734% S
16.3%
67.6%
15.0%
45%
71 7%
159%
EXPOSURE ROUTES EXCEEDING A HAZARD INDEX OF 1 (TOTAL RISK
FROM ALL CHEMICALS) AND THEIR PERCENT CONTRIBUTION
EXPOSURE ROUTE
Incidental Ingeslon ol Surface
So«
No exposure routes exceeded a
hazard Index oil
InQestfon of Grondwotoi
Note: Nordngestton Use was not
evaluated tor the chid resident
Ingestton ol Graundwater
Ingeslon ol Groundwater
Ingeston ol Groundwaier
HAZARD INDEX
1.7
20.9
9.0
209
9.0
PERCENT
96.0%
100.0%
998%
92.1%
97.6%
en
vc
O
cr
CTI
6-12
-------
5 9 0053
SECTION 7. APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARS)
The requirement that ARARs be identified and complied with and the development
and implementation of remedial actions is found in Section 121 (d)(2) of CERCLA,
42 U.S.C. Section 9621 (d)(2). This section requires that for any hazardous substance
remaining on-site, all federal and state environmental and facility citing standards,
requirements, criteria, or limitations shall be met at the completion of the remedial action to
the degree that those requirements are legally applicable or appropriate and relevant
under the circumstances presented at the Site.
Three classifications of requirements are defined by EPA in the ARAR determination
process: • .•^.••.•r-^" :-:KV -V^-.'/
• Chemical-specific: These requirements set protective remediation levels for the
chemicals of concern.
• Location-specific: These requirements restrict remedial actions based on the
characteristics of the site or its immediate surroundings.
• Action-specific: These requirements set controls or restrictions on the design,
implementation, and performance levels of activities related to the management of
hazardous substances, pollutants, or contaminants.
A. Chemical-Specific ARARs
Chemical-specific ARARs include those laws and regulations governing the release
of materials possessing certain chemical or physical characteristics, or containing
specified chemical compounds. Chemical-specific requirements set health- or risk-based
concentration limits or ranges in various environmental media for specific hazardous
substances, contaminants, and pollutants. These ARARs, when applied to site-specific
conditions, establish numerical values that define the acceptable amount or concentration
of a chemical that may be found in, or discharged to, the ambient environment. Examples
include drinking water standards and ambient air quality standards. Chemical-specific
ARARs are established once the nature of the contamination at the site has been defined,
which is accomplished during the Rl. Chemical-specific ARARs for this Site are listed in
Table 7-1.
North Belmont PCE Site
Record of Decision
North Belmont Gaston County, NC
September. 1997 7-1
-------
TABLE 7-1 -
ARARS, CRITERIA. AND GUIDANCE FOR THE SITE
FEDERAL
Sato Drinking Water Ad
National Primary DrtnMng WaUr Standards
National Secondary DrtnUng Water Standards
Maximum Contamtnart Law! (MCL) Goals
dean Water Act
Water Quality Criteria
Resource Conservation and Recovery Act (RCRA), as amended
RCRA Groundwaler Protection
Clean Air Ad
National Primary and S
Standards
Jary Ambient At OuaMy
National Emissions Standards tor Hazardous Air Pollutants
4QUSC Section
300
40 CFR Part 141
40CFR143
40 CFR 141
33 USC Section
1251-1376
40 CFR Part 131
40 CFR Part 264
40 USC 1857
40 CFR Part 50
40 CFR Part 61
Establishes health-based standards tor public water
systems (MCLs).
Establishes wetlaretesed standards tor pubHc water
systems (secondary MCLs).
Establishes drinking water quality goals set at levels ol no
known or anticipated adverse hearth elteds.
Sets criteria lor water <
organisms and human?
I on toxtoty to aquatic
Provides for groundivaler protection standards, ganeral
monitoring requirements, and technical requirements
Sets prtnary and secondary air standards at levels to
protect put** health and public welfare
Provides emissions standard lor hazardous air polutants
lor which no ambient air quality standard exists
The MCLs for organic and horoante contaminants are relevant
and appropriate to the groundwaler contaminated by the site
since lite aquifer is a drfiWng water source.
Secondary MCLs lor organic and Inorganic contaminants are
guidelines to be considered lor groundwater since it is a
vintiing water source.
MCLQs tor organic and Inorganic contaminants are relevant
andappropnate to tie groundwaler since It Is a drinking water
source.
May be relevant and appropriate H groondwater, either treated
or untreated. Is discharged to a Surface water body. Also
retovanl and appropriate to any runott trom contaminated soil or
RCRA groundwator protection standards are relevant and
appropriate lor gnoundwaler at tie site.
May be relevant and appropriate II onslte treatment units or
excavation are a part ol remedial action.
May be relevant and appropriate II onslte treatment units or
excavation are a part ol remedial action.
STATE
North Carolina Drinking Water Ad
North Carcttw Groundwator Standards
North Carolina Water Ouatty Standards
North Carolina Surface Water Effluent Llmttallon*
North Carolina Air Pollution Cornrol Regulations
North Carolina Hazardous Waste Management Rules
130A NCAC 311- Regulates water systems within the state that supply
327 drtftkftgwater that may affed the public health
15A NCAC 2L Establishes groundwater classification and water qualty
standards.
15A NCAC 2B Establishes a series of classifications and water qualty
standards lor surface water.
15ANCAC2B Estabfeha fcrtls and guidelines lor effluent discharged to
waters ot tie state.
15A NCAC 20/2O Regulates ambient air quality and establishes air qualty
standards lor hazardous air poDutanls.
15ANCAC13A Establishes standards for hazardous waste treatment
facilities
Provides tie state with the authority needed to assume primary
enforcement responsibility under the federal act.
Guidelines for alowabto levels of toxic organic and Inorganic
compounds in groundwaler used lor drtnkfhg water. Relevant
and appropriate to groundwater at the Site.
May be appKcabfe If treated groundwater Is discharged to
surface waters.
May be appkabte II treated gnoundwater Is discharged to
surface water. r
May be appkabte Is on-sHe treatment or excavation Is part ol
the remedial action.
May be appHcabte If hazardous waste Is excavated and stored
or treated as part ol the remedial action.
North Belmont PCE Site
Record of Decision
•torth Belmont. Gaston County. NC
•ptember. 1997
5 9
0054
-------
5 9 0055
B. Location-Specific ARARs
Location-specific ARARs are design requirements or activity restrictions based on
the geographical or physical positions of the Site and its surrounding area. Location-
specific requirements set restrictions on the types of remedial activities that can be
performed based on site-specific characteristics or location. Examples include areas in
a flood plain, a wetland, or a historic site. Location-specific criteria are generally
established early in the RI/FS process since they are not affected by the type of
contaminant or the type of remedial action implemented. Location-specific ARARs for
this Site are listed in Table 7-2.
C. Action-Specific ARARs
Action-specific ARARs are technology-based, establishing performance, design,
or other similar action-specific controls or regulations for activities related to the
management of hazardous substances or pollutants. Action-specific requirements are
triggered by the particular remedial alternatives that are selected to accomplish the
cleanup of hazardous wastes. Action-specific ARARs for this Site are provided in Table
7-3. '• ' : '••• .--... :-...-
D. Media of Concern
Based on the results of the remedial investigation and the baseline risk
assessment, the North Belmont Site has one contaminated media; groundwater.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997 7-3
-------
0056
TABLE 7-2 - LOCATION-SPECIFIC ARARS. CRITERIA. AND GUIDANCE
Standard. Requirement,
Criteria, or Limitation
Federal
Resource Conservation and
Recovery Act (RCRA), as
amended
RCRA Location Standards
Fish and Wildlife Conservation
Act
Ftoodplain Management
Executive Order
Endangered Species Act
Wetlands Management Executive
Order
State
North Carolina Hazardous Waste
Management Rules
North Carolina Solid Waste
Management Rules
Citation
42 USC 6901
40CFR264.18(b)
16 USC 2901 et
seq. ; . ;
Executive Order
^ngsa^ocFR
6.302 :
16 USC 1531
Executive Order
11990; 40 CFR
6.302
15ANCAC13A
15ANCAC13B
Requirements
Synopsis
A treatment/storage/
disposal (TSD) facility
must be designed,
constructed, operated,
and maintained to avoid
washout on a 100-year
floodplain, ; ; :
Requires states to identify
significant habitats and
develop conservation
plans for these areas.
Actions that are to occur
•in ftoodplain should avoid
adverse effects, minimize
potential harm, restore
and preserve natural and
beneficial value.
Requires action to
conserve endangered
species or threatened
species, including
consultation with the
Dept of interior.
Action to minimize the
destruction, toss or
degradation of wetlands.
Location requirements for
hazardous waste
treatment/storage/
disposal facilities.
Siting requirements for
solid waste disposal
units.
Comment
May be relevant and
appropriate if an onsite
TSD facility is required as
part of overall remediation
and it exists within the
1 00-year floodplain.
Confirmation with the
responsible state agency
regarding the Site being
located in one of these
significant habitats.
Remedial actions are to
prevent incursion of
contaminated groundwater
onto forested floodplain.
Endangered species thus
far, have not been
identified at the Site.
Relevant and appropriate if
remediation occurs in
wetlands.
May be applicable to
hazardous waste
excavated, stored, and
treated on-site.
May be relevant and
appropriate to
nonhazardous waste
disposed on-site.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997
7-4
-------
Ji E 7-3 - ACTION-SPECIFIC ARARS. CRITERIA. AND GUIDANCE \ THE SITE
OR UMfTATON
CtTAHOM
COMMENT
Groundwatfr Extinction and Tmatrmrt
Resource Comorvalon and Recovery Ad (RCRA), a*
amended
IdantMcatlon of Hazardous Waste
Treatment of Hazardous Wastes In a UMI
Requirements for Generation. Storage,
Transportation, and Disposal of Hazardous Waste
Land Disposal Restrictions
Disposal • Discharge to Surface Waf tr/POTW
dean Water Ad
Requires use of Best Avatabte Treatment
Technology
Requires Use of Best Management Practices
National
(NPDES) Permit
arge Elimination System
must be constslent wffh the r
Discharge must not Increase contaminant
concenfartons In orlsite surface water.
Other
Occupational Safety and Health Administration
STATE
North Carolina Water OuaMy Standards
North Caro»na Groundwater Standards
Wastewater Discharge to Surface Waters
North Carolina Air PoUuton Control Regulations
42 USC Section 6901 el seq.
40CFR261
40CFR268
33 USC Section 1351-1376
40CFR122
40CFR12S
40CFRl22SubpartC
40CFR122
29 CFR 1910 Pan 120
15ANCAC2B
15ANCAC2L
1SANCAC2H
1SANCAC2Dand2Q
Federal requirements for dassfflcaton and (dsntfflcatkin of hazardous wastes.
Rules and requirements tor fhe teatment of hazardous wastes.
Regulates storage, tansportatlon, and operation of hazardous waste generators.
Prohibits dNulton as a substitute for treatment.
Used best awHabte technology economlcaBy acWevBble to required to control dhcnarge of
toxic poUulanis to PubfidyoSffed treatment works (POTW)
Requires devetopment and Implementation of a Best Management Practices propram to
prevent Vie release ol toxic constituents to surface water.
Use ol best available technology eoonomlcaly acNevaMe for toxic pokitants discharged to
surface waters.
Discharge must comply with EPA-approved Water Oualtty Mar
wit Plan.
Selected remedal action must establish a standard ol control to maintain surface water
quality.
Provides safety rules lor handHng specific chemicals for site workers during remedal
activities.
Surface water quality standards.
Establishes groundwater standards, regulates Injection wels. sets criteria lor natural
attenuation.
Regulates surface water discharge and discharges to POTW.
Regulates amUenl air quality and establishes air quality standards lor hazardous air
podulanls.
Relevant and Appropi lute
D^^L^B^ AMdi * »ial«IIHilll I I
HeMMn via Appr upiuie
Retownl and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
Apptcabte
Retovant and Appropriate
Relevant and Appropriate
Reterart and Appropriate
Maybeapplcabteloron
site irealmeni/excavalion
North Belmont PCE Site
Record of Oectsion
North Belmont. Gaslon County, NC
September. 1997
UUb7
75
-------
5 9
GUB8
SECTION 8.
REMEDIAL ACTION OBJECTIVES
Considering the requirements for risk reduction and the risk-based remediation
levels derived in the Baseline Risk Assessment, and the ARARs discussed previously,
the remediation goals specifically developed for groundwater across the entire Site are
presented in Table 8-1.
The remediation goals were selected as the most conservative of the chemical
specific ARARs or the health-based risk goals. The contract required quantitation limit
(CRQL) was chosen if the chemical-specific ARAR was below this limit. The
background concentration would have been selected as the remediation goal if it had
exceeded the risk-based goal, as is the normal procedure.
TABLE 8-1 • REMEDIATION GOALS FOR GROUNDWATER AT THE NORTH BELMONT SITE
CONTAMINANTS OF
CONCERN
Tetrachloroethene (PCE)
Trichloroethene (TCE)
Cis-1 ,2-Dichloroethene
(1,2-DCE)
Chloroform (CLFM)
Methylene Chloride
1 ,1 -Dichloroethene
(1.1 -DCE)
Bis(2-ethylhexy1)prrthalate
Lead
MAX (UG/L)
3,500
280
1,100
2.4
62
;....- ,4. ...;.:,,.,.,
110
280
REMEDIATION
GOAL (UG/L)
. . -,.:.1 •,.•
2.8
70
•":•' 1
.- :. 5 . •'•. '•
"V-. •:••>: ••'•••
3
15
BASIS
CRQL (NCGS 0.7 ug/l)
NC 2L GS
NC 2L GS
CRQL (NC 2L GS - 0.19 ug/l)
NC 2L GS
NC 2L GS
NC 2L GS
NC 2L GS
Notes: CRQL - Contract Required Quantitation Limit; NC 21 GS - North Carolina Administrative Code Subchapter 2L
Groundwater Standard
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997
8-1
-------
59 0059
SECTION 9.
DESCRIPTION OF ALTERNATIVES
Table 9-1 lists the remedial action alternatives developed for the North Belmont
PCE Site.
TABLE 9-1. REMEDIAL ACTION ALTERNATIVES FOR GROUNDWATER AT THE SITE.
NUMBER
Alternative 1
Alternative 2
Alternative 3
Alternative 4
NAME
No Action
Limited Action . ; :
Groundwater Exposure
Abatement
Groundwater Exposure
Abatement plus
Groundwater Treatment
DESCRIPTION
Site is left "as is";
Five-year reviews conducted
Deed recordations
Semi-annual groundwater monitoring
Five-year reviews conducted
Grty Water connections
Wellhead treatment
Semi-annual groundwater monitoring
Five-year reviews conducted
City Water connections
Wellhead treatment
Semi-annual groundwater monitoring
Treatment of contaminated groundwater
Five-year reviews conducted
Descriptions of the alternatives developed for remediation of groundwater are
discussed below. All of the alternatives except the "No Action" alternative include
periodic monitoring of the groundwater including monitoring wells and potable wells for
site contaminants to evaluate the site conditions and the migration of contaminants
over time.
Note: Lead was found in two converted wells (residential wells that were
converted to monitoring wells) above EPA's action level and North Carolina's
Groundwater Standard of 15 ug/l. This occurrence of lead may be due to the pipes in
these wells. Therefore, lead is not considered to be wide-spread problem at this Site,
and no treatment has been proposed for lead. If monitoring shows that lead is more
widespread than now believed, EPA will address this situation at that time.
A. ALTERNATIVE 1 • NO ACTION
Under the No Action alternative, the Site is left "as is", and no funds are
expended foY active control of the groundwater contaminant plume. Contaminated
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September. 1997
9-1
-------
OU60
groundwater would remain uncontrolled allowing for the potential migration farther
downgradient and deeper into bedrock. The NCR requires consideration of this
alternative as a baseline for comparing other remedial actions and the level of
improvement achieved. However, five-year reviews of the Site remediation decision,
which consist of one round of sampling of selected monitoring and potable wells, would
be conducted over an estimated 30-year period.
B. ALTERNATIVE 2 - LIMITED ACTION
In this alternative, deeds in the area would be required to record the fact that
groundwater contamination exists under the property, and if a potable well is
constructed, a strong possibility exists that the water will be contaminated with
unacceptable levels of volatile organic contaminants. These recordations would
remain in place until the groundwater quality would allow unrestricted use.
Semi-annual groundwater monitoring would be conducted on both monitoring
wells and potable drinking water wells. Wells would be sampled for volatile organic
compounds. The five-year reviews would be required because concentrations of
chemicals remain at the Site above levels that allow unlimited use of the groundwater.
C. ALTERNATIVE 3 - GROUNDWATER EXPOSURE ABATEMENT
Under this alternative, all homes, churches, and businesses in the North Belmont
PCE Site area not currently connected to the City of Gastonia or Gaston County public
water supply would be connected. In addition, residents will also be given the option to
obtain wellhead treatment of their private well, i.e. groundwater treatment such as a
carbon filter unit would be connected to the private water supply well.
Semi-annual groundwater monitoring would be conducted on both monitoring
wells and potable drinking water wells. Wells would be sampled for volatile organic
compounds. The five-year reviews would be required because concentrations of
chemicals remain at the Site above levels that allow unlimited use of the groundwater.
D. ALTERNATIVE 4 - GROUNDWATER EXPOSURE ABATEMENT PLUS
GROUNDWATER TREATMENT
This alternative would include all the provisions of Alternative 3 plus would add
treatment of the contaminated groundwater plume. The groundwater plume has been
divided into three distinct plumes contained within the shallow, saprolite aquifer, the top
of bedrock aquifer, and the bedrock aquifer. The treatment process will consist of a
North Betmcnt PCE Site
Record of Decision
North Belmont Gaston County, NC
September. 1997 9-2
-------
59 0061
combination of two different process options: in-well vapor stripping and jn-situ
biological treatment.
The in-well vapor stripping and in-situ bioremediation technologies would be
used throughout the plume. A treatability study would be performed to determine the
optimum combination of these two treatment processes, and the best conditions for the
use of each.
Additional studies and monitoring would be needed to determine the
effectiveness of this combination of treatments. The study would also focus on
determining the optimum treatment technology based on the unique aspects of each
plume; i.e., the shallow plume would be more accessible than the other two, the
bedrock plume would be more complex due to the depth and the presence of bedrock
fractures. In addition, another factor that should be taken into consideration is the
location of this Site; the majority of the plume is located in residential, privately-owned
areas and the remedy would be designed so that it will not be overly intrusive to the
neighborhood.
North Belmont PCE Site
Record of Decision
North Belmont. Gaston County. NC
September, 1997 9-3
-------
5 9 0062.
SECTION 10. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In this section, each alternative is assessed using seven evaluation criteria
required under CERCLA. Comparison of the alternatives with respect to these evaluation
criteria are presented in summary form. This approach is designed to provide sufficient
information to adequately compare the alternatives, aid in the selection of an appropriate
remedy for the Site, and demonstrate satisfaction of the statutory requirements.
Each alternative is evaluated in terms of its ability to:
• Be protective of human health and the environment.
• Attain ARARs or provide grounds for invoking a waiver.
• Use permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable.
• Satisfy the preference^ for treatment that reduces toxicity, mobility, or volume of the
hazardous substances, pollutants and contaminants as a principal element.
• Be cost-effective.
The seven evaluation criteria required to address the above CERCLA requirements
serve as the basis for conducting the detailed analysis. The evaluation criteria are briefly
described below. i
1. Overall Protection of Human Health and the Environment determines whether each
alternative meets the requirement that it be protective of human health and the
environment in both short- and long-term, from unacceptable risks posed by
hazardous substances, pollutants, or contaminants. This criterion is of key
importance. While the remedy selected may on occasion seek a waiver of a given
ARAR, the remedy selected must be protective of human health and the
environment.
2. Compliance with ARARs is used to determine how each alternative complies with
federal and state ARARs as defined in CERCLA Section 121, as discussed in
Section 2, or provide grounds for invoking one of the waivers.
3. Short-Term Effectiveness addresses the impacts of the alternatives during the
construction and implementation phase until remedial response objectives have
been met. Alternatives are evaluated with respect to their short-term effects on
human health and the environment.
North Betmont PCE Site
Record of Decision
North Betmont, Gaston County, NC
September. 1997 10-1
-------
5 9 OU63
4. Long-Term Effectiveness and Permanence addresses the results of a remedial
action in terms of the risk remaining at the Site after response objectives have been
met. The primary focus of this evaluation is the effectiveness of the controls that will
be applied to manage risk posed by treatment residuals or untreated wastes.
5. Reduction of Toxicity, Mobility, and Volume addresses the statutory preference for
selecting remedial actions that employ treatment technologies that permanently and
significantly reduce toxicity, mobility, or volume of the hazardous substance as their
principal element. This preference is satisfied when treatment is used to reduce the
principal threats at the Site through destruction of toxic contaminants, irreversible
reduction in contaminant mobility, or reduction of total volume of contaminated
media.
6. Implementability addresses the technical and administrative feasibility of
implementing an alternative and the availability of various services and materials
required during its implementation.
7. Cost estimates for the FS are expected to provide an order-of-magnitude evaluation
for comparison of alternatives and are based on the site characterization developed
in the Rl. Capital cost, annual cost, and a present worth analysis are part of this
evaluation. The present worth represents the amount of money that, if invested in
the initial year of the remedial action at a given rate, would provide the funds
required to make future payments to cover all costs associated with the remedial
action over its planned life. The baseline present worth is computed at a discount
(interest) rate of 7 percent over a 30 year period. Appendix A contains
spreadsheets showing each component of the present worth costs.
The first two criteria are referred to in the RI/FS guidance manual (EPA 1988) as the
"threshold factors", implying that for further consideration of an alternative, these two
criteria must be satisfied. Alternatives which do not satisfy these threshold factors are not
feasible (40 CFR 300.430(f)(1)(l)(A). Criteria 3 through 7 are referred to as "primary
balancing factors" (page 4-25 of RI/FS manual), implying that these criteria are used to
select the alternative among the feasible alternatives. There are two other criteria, state
acceptance and community acceptance, which are provided by state and local agencies
and the public. These criteria will be evaluated in the responsiveness summary. A
detailed analysis of the alternatives using the above criteria is presented below.
A. Alternative 1 - No Action
Section 300.430 (e) of the NCP requires that the "no action" alternative be carried
forward for consideration in the detailed analysis of alternatives as a baseline for
comparison of the other alternatives. Under the no action alternative, funds are not
expended for routine monitoring, control, or cleanup of groundwater contamination
associated with the Site. Funding would, however, be required for the five-year review.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September. 1997 10-2
-------
5 9 01)64
Overall Protection of Human Health and the Environment
This alternative would not provide any increased protection to human health or the
environment. If no action is taken, the groundwater plumes would continue to migrate.
Residents in the vicinity of the Site would continue to drink water from private wells that
contain contaminants above the remediation goals. However, since soils at the Site did
not contain any significant amounts of contamination, the concentration of contaminants in
the groundwater would be expected to decrease with time due to natural processes and
dilution. Under this action, monitoring or verification of the decrease would be conducted
only at the five-year review stage.
Compliance with ARARs
The "no action" alternative would not address compliance with ARARs since there
would be no active measures taken to reduce the contaminant concentrations. The
volatile organic contaminant concentrations would be expected to decrease with time due
to natural processes and dilution. Location- and action-specific ARARs do not apply to
this alternative since further remedial action would not be conducted.
Short-Term Effectiveness
Because no activities would be implemented, there would be no additional impact
on the community. Also, no construction or operation related impacts to the environment
would occur, since no site activities would be performed.
Long-Term Effectiveness and Permanence
Because remedial actions would not occur, this alternative would not provide any
long-term effectiveness or permanence. The long term risks caused by the contaminated
groundwater would not be addressed. However, since the Site soils did not contain any
significant amounts of contamination, the concentration of contaminants in the ground
water would be expected to decrease with time due to natural processes and dilution.
Reduction of Toxicity, Mobility, and Volume
The "no action" alternative would provide no reduction in toxicity, mobility, or volume
of contaminated groundwater.
Implementabllity
This criterion is not applicable because remedial activities would not occur.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September, 1997 10-3
-------
5 9 0065
Cost
The cost of this alternative consists only of 5-year review expenses. The total
present worth cost for this alternative is approximately $291,066.
B. Alternative 2 - Limited Action
This alternative includes deed recordations and groundwater monitoring to protect
human health and the environment. Under this alternative, no groundwater remedial
measures will be undertaken at the Site. Five-year reviews are required under the NCR to
determine if contaminants which remain on-site are causing additional risk to human
health or the environment. As a result of this review, EPA will determine if additional site
remediation is required. Five-year reviews are assumed to be conducted for a 30-year
period.
Deed recordations would require amending the property deed to note that
contaminated groundwater is located on the property. These recordations would be
required on properties within the extent of the groundwater plume. These recordations
would remain in place until the groundwater quality improved enough to allow for
unrestricted use.
Groundwater will be monitored semi-annually for five years and annually for 25
years at approximately 30 existing monitoring, converted residential, and residential wells.
Groundwater will be collected and analyzed for VOCs and lead.
Overall Protection of Human Health and the Environment
Deed recordations would alert residents of the potential hazards associated with the
contaminated groundwater. They would limit exposure by warning of unlimited use of the
groundwater; however, the recordations would not completely eliminate the risk of
exposure or control the plume migration. Consequently, this alternative would not provide
active protection of human health and the environment, although monitoring would reveal
future threats to human health and the environment.
Compliance with ARARs
This alternative does not achieve the remedial action objectives of chemical-specific
ARARs established for groundwater. Through natural processes and dilution, a decrease
in the contaminant concentration would be expected with time. However, the magnitude
of the decrease can only be qualitatively determined. It is not known whether natural
processes and dilution alone would result in sufficient contaminant reduction to attain
ARAR's. Location- and action-specific ARARs do not apply to this alternative since
further remedial actions of an intrusive nature would not be conducted.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September.1997 10-4
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5 9 0066
Short-Term Effectiveness
Implementing this alternative would require approximately one year. Groundwater
monitoring could begin immediately. No significant environmental impacts would be
expected during the sampling events.
Long-Term Effectiveness and Permanence
Properly implemented deed recordations would make residents aware of the
contamination and thus potentially prevent ingestion and direct contact with contaminated
groundwater, thereby reducing risk to potential users. Implementation of deed
recordations with continued monitoring would be required indefinitely. The long term
monitoring results and the actual effectiveness of the deed recordations would require
periodic reassessment to determine the continued effectiveness of this alternative. If the
degree of protectiveness to human health is insufficient, further remedial actions would
have to be implemented.
Reduction of Toxiclty, Mobility, and Volume
This alternative would not actively reduce the volume, toxicity or mobility of the
contaminants. The size of the contaminant plume could increase with time. However, as
the size of the plume increases the contaminant concentrations are expected to decrease
via natural processes and dilution.
Implementability
This alternative would be readily implemented since there are no remedial activities of
an intrusive nature being performed. The implementation of monitoring would present no
difficulties. Implementing and enforcing deed recordations would require the cooperation
of the state and local governments. The deed recordations may be subject to change in
legal and political interpretations over time. Voluntary acceptance by adjacent property
owners is questionable. Consequently, present or future property owners could choose to
ignore or be unaware of the deed recordations. The recordation could also be lost during
future property transfers. For the above reasons, the reliability of groundwater use deed
recordations is considered uncertain. Legal services, field personnel and analytical
laboratories necessary for implementation of this alternative are readily available. If
additional monitor wells are required, well drilling services are readily available. Monitor
equipment is readily available for groundwater sampling.
Cost
The total estimated present worth cost for this alternative is $432,255. The capital
costs associated with this alternative include fees for implementing deed recordations and
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September. 1997 10-5
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5 9 0067
sampling equipment for monitoring. The O&M costs include long-term monitoring
activities, which have been evaluated for a 30-year period.
C. Alternative 3 - Groundwater Exposure Abatement
Under this alternative, all homes, churches, and businesses in the North Belmont
PCE Site area not currently connected to the City of Belmont or Gaston County public
water supply would be connected. The North Belmont PCE Site area is defined in Figure
1-2 of this Record of Decision. In addition, residents will also be given the option to
obtain wellhead treatment of their private well.
If requested, aqueous phase activated carbon units for removal of organics from
groundwater supply would be installed at the wellhead of each residential well. Filtration
will also be used as a precursor to the carbon treatment units.
This alternative also includes monitoring of groundwater from approximately 30
monitoring wells for 5 years on a semi-annual basis and for 25 years on an annual basis.
All connections to the ojty water system would require assistance from state and local
authorities, especially in the areas of public notification, system design, and system
construction. During initial procedures, an accurate count of the number of residences
that are, or may be potentially affected by the groundwater contaminant plume would have
to be determined. Once determined, EPA, state and local authorities would have to notify
each resident and present the positive and negative aspects of a public water connection.
Recognition of the fact that some residents will not want to accept public water supply
connection is understood. After notification of the public, system design will begin.
System design will require agreement between local authorities and EPA as to the total
number of connections and total extent of pipeline. Following completion of the system
design, system construction will commence. The system will most likely be installed by
the local authority or qualified contractor.
Groundwater treatment at the wellhead will consist of the installation of a filtration unit
and granular activated carbon (GAC) unit. Both of the filter systems will be installed in-
line on present residential water systems. The systems will be designed to remove
particulates from the influent groundwater as well as any organics present.
The first tittering unit of the in-line treatment system will consist of a paniculate filter
for removal of sediment and other matter from the influent water line. Following the
paniculate filter, the feed water will flow into a GAC system. The GAC system will consist
of two units operated in a downflow fixed-bed mode, as it has been found to be most cost
effective and produces the lowest effluent concentrations for low solids feed streams.
Due to space constraints, each unit will contain a maximum of 50 pounds of carbon and
will be replaced on a semi-annual to annual basis. Spent carbon will be taken offsite for
regeneration or disposal.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September, 1997 10-6
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5 9 0068
To assess the effectiveness of the treatment system, the water effluent will be
routinely monitored. Monitoring will be more frequent during startup and early operation.
A typical/comparative ground water monitoring program is described in Alternative 2 -
Limited Action.
Overall Protection of Human Health and the Environment
This alternative provides protection of residents from contaminated groundwater
during an extended period of time; therefore, risks to current and potential groundwater
users are expected to decrease. However, this alternative does not preclude potential
damage to the environment from migration of the current groundwater plume or migration
of the plume to other areas. ;
Compliance with ARARs
Under this alternative, groundwater recovered from the wellhead treatment will be
treated such that contaminant concentrations in the effluent will be below the remediation
goals. However, this alternative will do little to control the migration of the overall
groundwater plume. \
Short-Term Effectiveness
Appropriate levels of protection will be used during installation of the treatment
system and connection of residents to the city water supply. Disposal of any wastes
generated during construction and operation will follow proper handling practices and
should not have adverse environmental impact.
Long-Term Effectiveness and Permanence
Connecting affected residents to city water supply will provide a permanent remedy
for protection of human health. The wellhead treatment would require regular
maintenance and continued monitoring.
Reduction of To x I city, Mobility, and Volume
Pumping at a water supply well would capture the plume on a limited basis and thus
reduce the mobility. Treating the groundwater by aqueous phase GAC will reduce the
concentrations of organics in the groundwater to the remediation goals and therefore, the
toxictty and volume.
Implementability
This alternative involves installation of in-line groundwater treatment units, including
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997 10-7
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u u o
filtration units and activated carbon units. These components are widely; available and the
system can be assembled using normal construction techniques. All of the units of the
treatment system are easily transportable and installed. For the organic contaminants
detected at the Site, carbon adsorption is a proven technology and is often used as a
means for treatment.
Water lines currently used by the city are in close proximity to many of the residences
at the Site and would only require extensions of the lines to connect new residences.
Permits and designs would have to be obtained by the local authority or qualified
contractor.
COSt :-:OVv-^V^h;.
Costs associated with the connection of residences to the public water supply include
public notification, system design, and system construction. For estimating purposes,
EPA assumed 75 residents would be connected to city water. Capital costs associated
with the groundwater treatment unit portion of the alternative includes treatability study
costs, installation of the filter and carbon adsorption units, and other associated
instrumentation and equipment. For estimating purposes, EPA assumed that 50 residents
would request wellhead treatment with operation and maintenance for a period of 1 year.
The estimated total present worth cost for this alternative is $2,196,275.
D. Alternative 4 - GW Exposure Abatement Plus GW Treatment
This alternative includes all the provisions of Alternative 3 - Groundwater Exposure
Abatement plus adds remediation of the groundwater that contains contaminant
concentrations above the remediation goals. The major components of the groundwater
treatment option include in-well vapor stripping and in-situ biological treatment.
The in-well VOC removal system volatilizes VOCs contained in groundwater and
removes them as a vapor. The vapor is retrieved using vacuum extraction and is treated
above ground by adsorption onto granular activated carbon (GAC). The VOC-enriched
vapor is extracted and the partially cleaned water is returned to the aquifer. The system
recirculates the groundwater through air-lift pumping. The system converts groundwater
contamination into a vapor that is vacuum-extracted and treated. At the same time, air-lift
pumping circulates the groundwater, which becomes cleaner with each pass through the
in-well air stripper. The only input to the system is gas, which is injected into the well.
The injected gas is typically air and can be recycled during the process.
The only output of the system is gas that is removed from the well; this gas contains the
VOCs removed from the groundwater. After removal, this VOC vapor is adsorbed onto
GAC. The GAC is regenerated and reused. No major facilities are needed for this
technology. Power is needed to operate the pumps and compressors. The method itself
North Belmont PCE Site
Record of Decision
North Belmont Gaston County, NC
September, 1997 10-8
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5 9 0070
involves no moving parts beneath the ground surface; however, careful packer and well
designs would be required to successfully divert the groundwater from the well back into
the saturated zone and to the water table.
The system is expected to operate approximately 10 years. The maximum amount of
contamination is estimated to be removed within the first three years. After 10 years of
operation, the treatment system will be evaluated for its effectiveness and the decision will
be made on the continuation of this treatment.
The second component of the treatment system would be in-situ bioremediation to
degrade the contaminants in the aquifer. The process involves the addition of
microorganisms, nutrients, and an oxygen source (if aerobic) to the aquifer to enhance the
natural degradation process. A treatability study will be conducted to determine the
optimum concentrations of nitrogen, phosphorus, and other trace minerals that are
required by the microorganisms to best degrade the organic compounds.
Groundwater monitoring will be conducted quarterly for the first three years, semi-
annually for the next seven years, and annually for five years thereafter.
Overall Protection of Human Health and the Environment
This alternative would provide significant protection of human health and the
environment through groundwater remediation and connection of residents to the city
water supply.
Compliance with ARARs
Under this alternative, groundwater will be treated such that the contaminant
concentrations in the effluent will be below remediation goals. This treatment option will
comply with chemical-, location-, and action-specific ARARs.
Short-Term Effectiveness
During installation of the treatment system, the usual precautions necessary for
construction activities will be taken. The installation of wells and the treatment system will
not involve a significant release of volatiles to the environment. Disposal of any wastes
generated during construction and operation would follow established handling practices.
Long-Term Effectiveness and Permanence
The use of treatment processes provides a permanent method for treating the VOC
contaminants in the groundwater. Spent carbon will be disposed in an approved facility or
regenerated off-site.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September. 1997 10-9
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5 9 0071
Reduction of Toxicity, Mobility and Volume
Pumping at the wells would capture the plume and thus reduce plume mobility.
Treating the groundwater would remove VOCs present in the groundwater to the
remediation goals, thus reducing the toxicity and volume of groundwater contamination.
This process would not release VOCs to the atmosphere.
Implementability
This alternative involves installation of groundwater extraction wells, small pumps,
compressor, and GAG canisters, in addition to electrical connections. These components
are widely available and the system can be assembled using common construction
techniques. All the units of the treatment system are easily transportable and installed.
Cost
The total present worth cost for this alternative is approximately $4,716,400. Total
capital costs are estimated to be $2,779,270. :
:;.. X :":' :"; ;:v ': • Vr:^-;v '
E. Comparative Analysis of Alternatives
Presented in Table 10-1 are ranking scores for each evaluation criteria, excluding
cost. Each alternative's performance was ranked on a scale of zero to five, with zero
indicating none of the criteria's requirements were met, and five indicating all of the
requirements were met. The ranking scores are not intended to be quantitative or
additive. They are summary indicators only of each alternative's performance against the
evaluation criteria. The ranking scores combined with the present worth costs provide the
basis for comparison among alternatives.
Under overall protection, the no action alternative (Alternative 1) is ranked the lowest
("0") since contaminated groundwater is left onsite with no further actions being
conducted. Alternative 2 is ranked slightly higher ("1") since deed recordations will be
implemented in an attempt to limit contact with the contaminated groundwater. Alternative
4 is ranked higher ("5") than Alternative 3 ("4") since this alternative provides for treatment
of the entire contaminant plume and would provide added protection to residents
downgradient of the Site who are currently not affected by the Site.
Under compliance with ARARs, Alternatives 1 and 2 are ranked the lowest ("0") since
contaminated groundwater remains onsite and chemical-specific ARARs are not met.
Alternative 3 is ranked lower than Alternative 4 since ARARs will not be met over the
entire plume.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997 10-10
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5 9
01)72
Under long-term effectiveness, the no action alternative is ranked the lowest since
contaminated groundwater would be left onsite with no further actions being conducted.
Alternative 2 is ranked slightly higher since deed recordations would somewhat limit
contact with the contaminated groundwater. Alternative 4 is ranked highest since
contaminated groundwater over the entire plume would be remediated.
Under reduction of T/M/V, Alternatives 1 and 2 are ranked the lowest since
contaminated groundwater remains as is. The mobility, toxicity, and volume are reduced
in both Alternatives 3 and 4, however, to a greater extent in Alternative 4.
Under short-term effectiveness and implementability, Alternative 1 is ranked the
highest since no further actions are being conducted. Alternative 2 is ranked next since
the only actions taking place are deed recordations and groundwater monitoring. The
remaining alternatives are ranked equally. :
Table 10-1. Comparative Analysis of Alternatives
Overall Protection
Compliance w/ ARARs
Long-Term Effectiveness
Reduction of M/T/V
Short-Term Effectiveness
Implementability
Present Worth Costs
1-NO
Action
V
0
0
0
0
5
- 5.: .-
$291 ,066
2-Limrted
Action
1
0
1
0
4
, 4 ' ..
$432,255
3-Groundwater
Exposure Abatement
4
4
4
4
3
3
$2,196,275
4-Groundwater
Exposure Abatement
& Treatment
5
5
5
5
3
3
$4,716,400
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September. 1997
10-11
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5 9 0073
SECTION 11. THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCR, the detailed
analysis of alternatives and public and state comments, EPA has selected Alternative 4
as the groundwater remedy for this Site. The remedy includes connecting all homes,
churches and businesses in the "North Belmont PCE Area" as depicted in Figure 1-2 of
this document to the City of Belmont public water supply; optional installation of
granulated carbon filters on private wells with operation and maintenance of the filter
for one year with a filter replacement after the first year of operation; and groundwater
treatment by insitu biological treatment and in-well vapor stripping. At the completion
of this remedy, the risk associated with this Site has been calculated to be within the
accepted risk range determined to be protective of human health and the environment.
The total present worth of the selected remedy is $4,716,400. Tables 11-1 and 11-2
provide a detailed cost estimate for the chosen remedy.
A. Groundwater Remediation
Groundwater remediation will address the contaminated groundwater at the Site.
The major components of the groundwater treatment option include in-well vapor
stripping and in-situ biological treatment. The in-well VOC removal system volatilizes
VOCs contained in groundwater and removes them as a vapor. The vapor is retrieved
using vacuum extraction and is treated above ground by adsorption onto granular
activated carbon (GAC). The VOC-enriched vapor is extracted and the partially
cleaned water is returned to the aquifer. The system recirculates the groundwater
through air-lift pumping. The system converts groundwater contamination into a vapor
that is vacuum-extracted and treated. At the same time, air-lift pumping circulates the
groundwater, which becomes cleaner with each pass through the in-well air stripper.
The only input to the system is gas, which is injected into the well. The injected gas is
typically air and can be recycled during the process.
The only output of the system is gas that is removed from the well; this gas
contains the VOCs removed from the groundwater. After removal, this VOC vapor is
adsorbed onto GAC. The GAC is regenerated and reused. No major facilities are
needed for this technology. Power is needed to operate the pumps and compressors.
The method itself involves no moving parts beneath the ground surface; however,
careful packer and well designs would be required to successfully divert the
groundwater from the well back into the saturated zone and to the water table. The
system is expected to operate approximately 10 years.
North Belmont PCE Site
Record of Decision
North Belmont Gaston County, NC
September, 1997 11-1
-------
GU/4
Table Number: 11-1 PRESENT WORTH CAPITAL COST
Alternative No. 4 -GW Exposure Abatement plus GW Treatment
Site Name: North Belmont PCE Site Discount Rate: 7%
Site Location: North Belmont NC Date: July 1 997
ITEM DESCRIPTION
MOBILIZATION
Transport Equipment/Staff
Temporary Facitibes
INWELL VAPOR STRIPPING
Installation/equipment
INSITU BIOREMEDIATION
Treatability Study
Reinfiltration System
CITY WATER CONNECTIONS
Installation/75 residents
Design specifications, regulatory
approval, permits (20%)
WELLHEAD TREATMENT
Installation per residence
Treatability Study
HEALTH AND SAFETY
EQUIPMENT/TEMPORARY UTILITIES
QUANTITY
1
1
20
1
1
10,560 feet
SO
\ 1
1
UNIT COST ($)
15,000
15,000
25.000
25.000
80.000
60/toot
5,500
lump sum
fejmpsum
SUBTOTAL - CAPITAL COST
CONTRACTOR FEE (10% of Capital Cost)
LEGAL FEES. LICENSES, AND PERMITS (5% of Capital Cost)
ENGINEERING & ADMINISTRATIVE (15% of Capital Cost)
SUBTOTAL
CONTINGENCY (25% OF SUBTOTAL)
TOTAL CAPITAL COST
PRESENT WORTH O&M COST
TOTAL PRESENT WORTH COST
TOTAL COST DOLLARS
$15.000
$15,000
$500.000
$25,000
$80.000
$633,600
$126,720
$275.000
$10.000
$30.000
$1.710.320
$171,032
$85.516
$256,548
$2.223.416
$555,854
$2.779,270
$1,937,130
$4,716,400
North Belmont PCE Site
Record of Decision
North Belmont Gaston County. NC
September. 1997
11-2
-------
OU/5
Table Number 11-2 . REMEDIAL ACTION OPERATION COST
Alternative No. 4 -GW Exposure Abatement Plus GW Treatment
Site Name: North Belmont PCE Site Discount Rate: 7%
Site Location: North Belmont NC Date: July 1997
ITEM DESCRIPTION
WELL MAINTENANCE
GW Monitoring
Quarterly
VOC Analysis
Labor(sampling)
Report Preparation
Semi- Annual
VOC Analysis
Labor(sampling)
Report Preparation
Annual
VOC Analysis
Labor(sampling)
Report Preparation
5-YEAR REVIEW
Report Preparation
WELLHEAD TREAT
Labor/Maintenance
Monitoring of effluent
GAC replacement
INWELL VAPOR
STRIPPING
Maintenance
Maintenance
BIOREMEDIATION
Additives
System Maintenance
ANNUAL
QUANTITY
1
120
4
4
60
2
2
30
1
1
1
50x4 =200
50
•20
20
12
12
UNIT COST
($)
lump sum
$l25/sample
$2.400/event
$2,500/event
$125/sampte
$2.400/event
$2.500/event
$125/sample
$2.400/event
$2,500/event
^ $2.500/raport
8% of capital
$125/sample
$530/unit
$12.000
S6.000
$2,500/month
$500/month
TOTAL COST
PER YEAR
$20.000
$15.000
$9.600
$10,000
$7.500
$4.800
$5.000
$3,750
$2,400
$2.500
$2,500
$22,000
$25,000
$26.500
$240,000
$120.000
$30,000
$6,000
OPERATION
TIME (YEARS);
OCCURENCES
10
3
3
3
7
7
7
5
5
5
2
1
1
1
3
7
10
10
TOTAL PRESENT WORTH O&M COSTS - $1,937.130
North Betmont PCE Site
Record of Decision
North Belmont. Gaston County. NC
September. 1997
11-3
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5 9 0076
The second component of the treatment system would be in-situ bioremediation
to degrade the contaminants in the aquifer. The process involves the addition of
microorganisms, nutrients, and an oxygen source (if aerobic) to the aquifer to enhance
the natural degradation process. A treatability study will be conducted to determine the
optimum concentrations of nitrogen, phosphorus, and other trace minerals that are
required by the microorganisms to best degrade the organic compounds.
The groundwater treatment is expected to last approximately 10 years.
Groundwater monitoring will be conducted quarterly for the first three years, semi-
annually for the next seven years, and annually for five years thereafter.
Performance Standards
The goal of this remedial action is to restore the groundwater to its beneficial use.
Based on information obtained during the Rl, and the analysis of all remedial
alternatives, EPA and the State of North Carolina believe that the selected remedy will
be able to achieve this goal.
Groundwater contamination may be especially persistent in the immediate vicinity
of the contaminants' source^ where concentrations are relatively high. The ability to
achieve remediation levels at all points throughout the area of attainment, or plume,
cannot be determined until the treatment system has been implemented, modified, as
necessary, and plume response monitored over time.
Groundwater shall be treated until the following performance standards are
attained throughout the contaminant plumes:
Contaminant
Lead
Methylene Chloride
Cis - 1 ,2-Oichloroethene
Trichloroethene
Tetrachloroethene
Bis(2-ethylhexvl)phthalate
Chloroform
1,1-Dichloroethene
Remediation Level
15UQ/I
5ug/l
70ug/l
2.8ug/l
1 us/l
3UQ/I
1 ug/l
1 ug/l
Risk Level
NA
1E-05
HI = 0.4
1E-06
1E-06
1E-06
1E-06
1E-05
Hazard Index (HI) - Relates to non-cancer risks
1E-06 Risk Level - Probability for carcinogenic effects
(See Section 6 of this document for an explanation of HI and Risk Levels)
NA - Not applicable. Risk from lead is not calculated using HI or risk level.
ug/l - micrograms per liter
North Betmont PCE Site
Record of Decision
North Belmont, Gaston County; NC
September, 1997
11-4
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5 9 0077
If it is determined that certain portions of the aquifer cannot be restored to their
beneficial use, all of the following measures involving long-term management may
occur, for an indefinite period of time, as a modification of the existing system:
a) engineering controls such as physical barriers, or long-term gradient control
provided by low level pumping, as contaminant measure;
b) performance standards may be waived for the cleanup of those portions of the
aquifer based on the technical impracticability of achieving further contaminant
reduction;
c) institutional controls may be provided/maintained to restrict access to those
portions of the aquifer which remain above remediation levels;
d) continued monitoring of specified wells; and
e) periodic revaluation of remedial technologies for groundwater restoration.
The decision to invoke.any or all of these measures may be made during a periodic
review of the remedial action, which will occur at 5 year intervals in accordance with
CERCLA Section 121(c).
The remedial actions shall comply with all ARARs (See Section VII).
B. Additional Sampling Requirements
Additional groundwater sampling shall be conducted to further define the extent of
contamination. Specifically, the following shall be obtained at a minimum:
* Additional monitoring wells are needed in the following areas:
* West and southwest of Source Area A (across Woodlawn Dr), surficial zone;
* South of Source Area B and MW-10, top of bedrock zone; and
* East of Source Area B and TW-11/MW-10, top of bedrock zone.
* Periodic private well sampling to determine if any of the residents' wells exceed the
Emergency Response action level of 70 ug/l for PCE.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997 11-5
-------
5 9 0078
SECTION 12. DOCUMENTATION OF SIGNIFICANT CHANGE
CERCLA Section 117(b) requires an explanation of significant change from the
preferred alternative presented in the Proposed Plan dated July 29,1997. In the
proposed plan, Alternative 4 was chosen for groundwater at the North Belmont Site.
In the original proposed plan, EPA had proposed to allow residents the opportunity
to have carbon units put on their private well so that they could continue use of these
wells without fear of ingesting contaminated water. EPA had proposed operation and
maintenance of these carbon filter units for a period of ten years. This Site is a fund-
lead Site; there are no viable potentially responsible parties. Therefore, according to
the NCP, the State would be required to pay for the operation and maintenance of
these carbon filter units after the first year of operation. The State would take over the
O&M on the groundwater treatment and monitoring system after 10 years.
However, a comment from the State was received after the Proposed Plan was put
out for public comment. By letter dated August 6,1997, NC DEHNR stated that "We
would not support selection of a remedy which would require the State to pay for
operation and maintenance of these filter units. We would support this remedy only if
the residents who opted for these units agreed to assume operation and maintenance
costs."
Therefore, the remedy will incllde installation and monitorjng of the carbon unit for
one (1) year with a replacement unit to be installed^ at the ejcf of the first year.
Following this one year period, operation and maintenance costs associated with
continued effectiveness of the carbon unit shall be the responsibility of the well owner.
This change is reflected In the new cost estimates for Alternatives 3 and 4. EPA will
continue to monitor a number of private wetJs to determine if residents are being
exposed to contaminants above the MCLs.
Other changes in the cost estimate include the addition of five extra inwell vapor
stripping wells, and five years of groundwater monitoring.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997 12-1
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5 9 0079
APPENDIX A
RESPONSIVENESS SUMMARY
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September. 1997
-------
5 9
0080
RESPONSIVENESS SUMMARY
NORTH BELMONT PCE SITE
NORTH BELMONT, NORTH CAROLINA
This Responsiveness Summary for the North Belmont Site (hereinafter referred
to as the "Site") is divided into the following sections:
SECTION I
OVERVIEW
The overview summarizes the public's reaction to the
remedial alternatives listed in the Proposed Remedial Action Plan
(Proposed Plan). The Proposed PJan outlines the various methods
of remediation at the Site and discusses EPA's preferred
alternative.
SECTION II
BACKGROUND ON COMMUNITY INVOLVEMENT
The background section summarizes the major community
concerns identified in the Community Relations Plan and public
comment period on the Remedial Investigation/Feasibility Study
(RI/FS) and Proposed Plan.
SECTION III
SUMMARY OF COMMENTS AND QUESTIONS RECEIVED
DURING THE PUBLIC COMMENT PERIOD AND EPA'S
RESPONSES
This section responds to all significant comments and
concerns received by EPA during the public comment period.
I. OVERVIEW
The Proposed Plan for the Site was issued in July 1997. EPA's public comment
period for the Site was originally scheduled to run from July 29,1997 through August
29,1997. The comment period was extended an additional 14 days to September 12,
1997.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County. NC
September. 1997
A-1
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5 9 0081
EPA conducted a public meeting on August 7,1997. At this meeting, the public
was given an opportunity to ask questions and to comment on the remedial alternatives
outlined in the Proposed Plan and EPA's preferred alternative. The comments and
EPA's responses are included in Appendix B, the transcript of the public meeting. In
general, the public supported EPA's preferred alternative to connect all residents,
businesses and churches within the Site area to city water, and to treat the
contaminated groundwater.
II. BACKGROUND ON COMMUNITY INVOLVEMENT
EPA's involvement with the North Belmont Site began in 1991, when EPA's
Emergency Response Unit connected North Belmont Elementary School and a number
of residents to the City of Belmont public water supply. EPA began preparation of a
work plan for the RI/FS in late 1995. Since that time, EPA has implemented a
community relations program in the Site area designed to inform the public of Site
activities and solicit input from the community regarding its site-related concerns and
questions. These efforts have included disseminating printed public information
materials and conducting public meetings and information sessions to coincide with
technical milestones at
EPA conducted community interviews with residents in April 1996 to identify
community issues and concerns regarding the Site, and from this information prepared
a Community Relations Plan outlining Agency outreach activities. A local information
repository was also established to house EPA documents developed during the
Superfund process. The repository is located in the Belmont Branch of the Gaston
County Public Library System.
Interviews conducted with residents in the immediate vicinity of the Site revealed
concerns about water quality and health effects of chemicals in the groundwater. Key
issues raised by area residents during the 1996 interviews were:
• Water quality of private wells
• Cost of connection to City water
• Health effects on children from contaminated water
• Loss of property value
Public meetings were held in: June 1996 to discuss the upcoming RI/FS; and
July 1997 to discuss the Proposed Plan. Based upon the attendance at public
meetings and the overall feedback EPA has received from the public, the level of
community interest in the Site is characterized as medium. In general, residents have
responded favorably to Site remediation.
North Belmont PCE Site
Record of Decision
North Belmont Gaston County, NC
September. 1997 A-2
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5 9 OU32
Display ads announcing the meetings were placed in two area newspapers.
Fact sheets were mailed to individuals on the Site's mailing list announcing major
milestones and meetings. EPA also conducted meetings with city and county officials
to keep them informed and abreast of ongoing activities. Telephone conversations
were also held with citizens in the area.
III. SUMMARY OF COMMENTS AND QUESTIONS RECEIVED DURING THE
PUBUC COMMENT PERIOD AND ERA'S RESPONSES
This section contains a summary of verbal questions and comments received
during the public comment period. No written comments were received.
Comment: A resident on School Street who has city water, wants to continue to use
their well to water their yard. They would also like to continue to get their
well tested.
Response: Residents can continue to use their private wells for uses other than for
drinking water and showers. EPA will continue to test a number of private
wells periodically.
\ :- - .-i-.' •'--';-:-:- ;
Comment: One homeowner in the Site area took the initiative to connect to city water
after the contamination was discovered in 1991. The would like to know if
they can get reimbursed for this connection, since they would have been
connected by EPA during this remediation.
Response: EPA is looking into this situation to determine if some type of
compensation can be given to the resident.
Comment: The City of Belmont City Manager wanted a list of names and addresses
of those who will need city water. He also stated that engineering plans
will have to meet State and City specifications for extension of water lines.
Response: EPA will work closely with city officials to ensure that all Site residents will
be connected properly to the City's public water supply.
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September, 1997 A-3
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5 9 OU83
APPENDIX B
PUBLIC MEETING TRANSCRIPT
\
North Be)mont PCE Site
Record of Decision
North Betmont. Gaston County, NC
September, 1997
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5 9 QU84
NORTH BELMONT PCE SUPERFUND SITE
BELMONT, NORTH CAROLINA
\
7:10 P.M.
August 7, 1997
North Belmont Elementary School
210 School Street
Belmont, North Carolina
PUBLIC HEARING
(dourt IReporimg, 3rtr.
CMflttt JJorttj drolbas 28220
(r04)373-D347
OcD 1m (BUD) 455^424
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5 9 0085
Ms. Diane Barrett
Community Relations Coordinator
Ms. Giezelle Bennett
Remedial project Manager
TABLE 0£ CONTENTS
ly.
Opening Remarks Ms. Barrett
Presentation Ms. Bennett
Questions from the audience
Page
3-7
7-20
20 - 65
This is a transcript of the Proposed Plan
Public Meeting conducted by the United States Environmental
Protection Agency, being taken by Muriel A. Marcus, Notary
Public, at North Belmont Elementary School, 210 School
Street, Belmont, North Carolina, on the 7th day of August,
1997, beginning at 7:10 P.M.
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MS. BARRETT:
Can you see it? You can't -- I'll show you where
it is. The site discovery is here and we — the site
was discovered some years ago and our office at EPA in
Atlanta got it in 1995. We're going through the
writing process right now, developing all of our data
for that. The remedial investigation has begun and
that's why we're here tonight, to go through our
remedial investigation and the feasibility study are
both — go hand in hand.
The remedial investigation spans — if you were —
live right around the area, you might have seen people
out doing all kinds of sampling of the groundwater and
wells, the soil and so forth. That's a part of the
remedial investigation when they go out and take the
samples to determine, well, what contaminants are here,
what quantity is here, how deep are the contaminants
and so forth. So all of that — the samples come back
and they're analyzed and we have a report cover the
investigation of what's in the repository, as well as a
feasibility study.
The feasibility study is a study of all the
possible remedies that can be used to treat the
contaminants that we've found. And then, step five
right here, is the public comment period and that's
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what we're getting to right now, where we have the
Record of Decision that will be coming up after we have
the public comment period. He come in and tell you,
"This is what we've found and this is what we propose
to do. What do you think? Bow do you feel about
this?" So that's our purpose here tonight, to get your
input, to find out what you think about it and we have
a thirty-day comment period, but it's been extended
fourteen more days.
Once all the comments have come in and been
answered, we will then propose a responsiveness
summary. That is attached to what we call the Record
of Decision, which is this one right here, the Record
of Decision. These are all legal documents that we
prepare and they are admissible in court and so forth
like that, so they are legal.
Then after the Record of Decision, which says this
is — these remedies that have been selected based on
all the data that we have found and all the information
that the public has given us. This is what we choose.
Then after that, in step number seven, the cleanup
plan, that's the remedial design and the remedial
design is like a blueprint of what we're going to do
and that takes a little while to do. Usually the —
let me back up just a little bit.
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The remedial investigation and feasibility study
process, that can usually take anywhere from a year to
two years. It just depends on the complexity of the
site and what all we have to do. The cleanup process
plan, right under number seven step there, the remedial
design and the remedial action, that can take about six
months to a year, just, there again, depends on the
complexity of the treatment technology that we have to
design.
So all of that — these steps here are yet to
come, then the long-term cleanup itself. That's what
we call the remedial action and that's when the plants
themselves are actually constructed and treatment
begins, the soil being dug up or groundwater being
pumped and treated. That's going to be in that number
eight.
Then all during this whole process, we have the
community relations aspect. With all the various
things that we do, we have a community relations plan
already prepared. He have the information repository,
as I said, at the Belmont branch library; we value such
contacts and we have, like, (inaudible) here and voices
in effect here, too, (inaudible), keep in touch with
them and the state people, local folks. Then we have
informal meetings and formal meetings like we're having
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5 9 UUd9
1 tonight. We also issue fact sheets, have press
2 releases and different things.
3 Also, there are what we call technical assistance
4 grants available. These grants are for a sum of
5 $50,000, which is given to — awarded to a community
6 group that vants to form to recruit or hire a
7 consultant to help them go through all the stages that
8 we're developing to get a better understanding of the
9 technical aspects of the project and to provide us with
10 comments. So a technical assistance grant is available
11 for citizens that want to form a group.
12 And then there's another group that we call the
13 CAG, for short. That's the community advisory group
14 and those are not funded, however. Those are voluntary
15 and there are a lot of communities that do have these
16 kinds of folks get together and hear about what's going
17 on and gather on a monthly basis to find out and have
18 their input on what's being said.
19 Also, we have a toll-free number. It is on the
20 literature that you have, the fact sheet, the green
21 fact sheet that you got in your hand right there on the
22 very back page. It should be on the back page. It's
23 1-800-435-9233. So if at any time you have any
24 questions, please call. We are — Giezelle and myself
25 are there and if we happen to be out of the office,
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1 we've got answering machines and —
2 UNIDENTIFIED SPEAKER:
3 Repeat that phone number, please.
4 MS. BARRETT:
5 1-800-435-9233. And that will get you to our
6 secretaries there in the office and they will give
7 information, switch you to us. We will be glad to
8 assist you and help you in any way we can with your
9 questions or you see something, you know, if you have
10 any concerns, please call. That's what that 800 number
11 is for. We want to hear from you. And that pretty
12 much covers, I think, what I wanted to tell you from
13 the community relations aspect.
14 I appreciate your time and thank you very much.
15 And, Giezelle, if you want to come up and start, she's
16 going to tell you what all they've found and I think
17 that will bring us up to date.
18 MS. BENNETT:
19 I'm just going to quickly switch sides so I won't
20 be standing in front of anything. Can y'all see that
21 in the back?
22 (Discussion regarding visual aid equipment)
23 MS. BENNETT:
24 As Diane mentioned, this is the North Belmont PCE
25 Site Proposal Plan Public Meeting and in this meeting,
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5 9 OU91
1 we want to discuss EPA's proposed cleanup remedies for
2 the site.
3 Mow, the site is located in a mixed residential
4 and light commercial area. It consists of two former
5 dry cleaning facility locations. They're shown as site
6 A, which is the Roper's Shopping Center on Woodlawn
7 Drive. It was operated from 1960 to 1975 and the owner
8 . reportedly disposed of the dry cleaning solutions that
9 contained hazardous chemicals on the ground in back of
10 his shop. Site B is located at the intersection of
11 Suggs And Acme and that was reported by a citizen to
12 have been a dry cleaning facility before 1960.
13 Mow, just a brief background about the site. The
14 site was discovered in February of 1991. The Gaston
15 County Health Department sampled the North Belmont
16 Elementary School well and they found volatile organic
17 compounds or what we refer to as VOCs. The Region 4
18 Emergency was notified and they, with the health
19 department, sampled twenty-five additional private
20 wells and they again found the volatile organic
21 compounds. As a result of this sampling, some
22 residents were connected to city water. Others chose
23 not to be connected.
24 Now, this is a pictorial view of the extent of the
25 groundwater contamination as it existed in 1991. In
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5 9 OU92
1 July of '91 the state investigated the site and then in
2 October, '95, EPA began a long-term investigation,
3 referred to as the remedial investigation.
4 Now, as I had mentioned, the objectives of the
5 remedial investigation are to determine the nature and
6 extent of the contamination, determine where the
7 contamination is going and determine the potential
8 receptors. That means who will be affected by this
9 contain! nation.
10 Mow, as you-all probably recognize, this shows
11 your neighborhood; this shows our RI study area. The
12 two red dots show the former dry cleaning facilities.
13 There's also a green triangle that shows a previous
14 refrigerator repair shop that we also thought might be
15 a source of groundwater contamination and it also shows
16 a machine shop.
17 (Discussion regarding the site)
18 MS. BENNETT:
19 Now, the first thing we thought we should do was
20 to take a well survey and I know a lot of people were
21 contacted about whether or not you still use your
22 private well and what usage you use it for. This shows
23 what we now believe is the well use in this area.
24 The green shows the people who are on city water
25 and this part that's in — it's up here — that's hard
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1 to see, too, I guess, from where you're sitting, but
2 basically what it is is green, blue, red and what other
3 color is there?
4 MS. BARRETT:
5 Yellow.
6 MS. BENNETT:
7 Yellow. The blue dots on there, those are the
8 • ones we really need to know about, as to whether or not
9 people are still using the residential wells and so
10 that will come into play later. That's why we have
11 that larger map over there.
12 This figure shows our initial sampling locations.
13 that we came out in March, 1996; we took samples of
14 residential wells and also prior residential wells that
15 were now converted into monitoring wells and based on
16 this sampling, one additional residence was connected
17 to city water, due to high levels of organics. This
18 well was previously free of organics, in 1991, so that
19 told us that that plume that you previously saw, that
20 area of contamination, had moved.
21 He took soil samples to determine if there was any
22 additional contamination in the soil that may also be a
23 source of contamination in the groundwater. We found a
24 few metals in the soil but none of the volatile organic
25 compounds that we had been seeing in the groundwater*
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1 We took surface water and sediment samples in a
2 nearby stream to determine if the site was impacting
3 the stream. Again, we found a few metals but none of
4 the volatile organics that would be associated with the
5 site. In connection with the surface water sediment
6 sampling, the EPA also conducted a bio assessment in
7 the area to determine if the stream was healthy, that
8 . is, could organisms live in this stream. The
9 conclusion was that the stream was in fair condition,
10 which means that it wasn't pristine, but it wasn't in
11 really, bad shape either, but we could not determine
12 whether this was due to the stream being in an urban
13 area or because of site effects.
14 This figure shows the shallow wells that we put
15 in. Now, we have three different aquifers at this
16 site: a shallow, which is approximately thirty to
17 thirty-five feet below land surface, and these are —
18 this is a pictorial of the wells that we put in and
19 this shows the contamination that we found in the
20 shallow aquifer.
21 This figure is of the tetrachloroethene plumes
22 that we found. He found values as high as 2,200
23 micrograms per liter and just to give you a reference,
24 the EPA's drinking water standard is five micrograms
25 per liter and the state groundwater standard is 0.7.
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5 9 OU95
1 We also found both PCEs, trichloroethene and 1,2-
2 dichloroethene. These are all volatile organic
3 compounds.
4 So based on the depth of some of the residential
5 wells that were contaminated, we also conducted an
6 investigation of the deeper aquifers. This figure
7 - shows the wells that were installed both at the top of
8 bedrock — I don't know — you can refer to the figure
9 over there that Diane has up of the water cycle --
10 where these are right above the rock that's down below
11 the surface and we also had some that were installed
12 into the bedrock. The top of bedrock ranged between 35
13 to 110 feet deep and this map shows the top of the
14 bedrock plume, which contains tetrachloroethene or what
15 we call PCE. These levels ranged as high as 2,500 and
16 that map is also the map on the wall, the one furthest
17 from me. As you can see, it's a big difference between
18 the one we had in '91 and the one now we have in 1997.
19 The next figure, which is the one closest to me,
20 shows the contamination that we found in the bedrock
21 plume and these levels range up to 3500 micrograms per
22 liter.
23 Our next step, once we identified the
24 contamination, was to — what to do about it so,
25 therefore, the next step was a feasibility study. The
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5 9 OU96
1 objectives of the feasibility study were to develop
2 cleanup goals for the groundwater, identify and screen
3 different ways of cleaning that up and then identify
4 different alternatives based upon the different
5 technologies that we found.
6 The cleanup goals are based on ARAHs, which are
7 applicable or relevant and appropriate requirements/
8 . and there are three types of those. They are
9 chemical-specific, such as laws that specify the
10 drinking water standards, as I previously told you;
11 location-specific, such as laws that protect wetlands,
12 and action-specific, such as land disposal restrictions
13 and restrictions on the discharged treated water.
14 And these are the cleanup goals that were
15 developed for the North Belmont PCE Site. These are
16 based on both state maximum contaminant levels and EPA
17 levels. As you can see, the first column shows the
18 name of the contaminant; the second was the maximum
19 that we found in the groundwater and the third is our
20 goal, which means that's what we want to get the
21 groundwater to or below.
22 The next thing we did was look at the varying
23 technologies for cleaning up groundwater. He knew
24 where the contamination was and the levels that were —
25 we were required to obtain and now we want to achieve
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1 our goals. So, as you can see, we have a big variety.
2 We look at everything first and then determine if it
3 has even the slightest chance of working at the site.
4 And as a result of the initial screenings, we had a
5 number of viable options that passed our initial
6 screenings, anywhere from just putting it on the deed
7 to off-site disposal.
8 Now, these were further screenings to
9 effectiveness, will it work on the contaminants that we
10 found at the sight? How easily can it be implemented,
11 the availability of the equipment and the compliance
12 with the various laws and regulations and the cost of
13 it. Is it high, is it moderate or is it low compared
14 to other similar technologies?
15 Based upon that, we came up with four alternatives
16 for cleaning up the groundwater and achieving the
17 cleanup goals. The first is called No Action and I
18 know it's kind of hard to figure that's going to meet
19 our cleanup goals, but this is required under our
20 National Contingency Plan and that's — what that would
21 be is the site would be left just as it is today with
22 no further EPA work. He would then be required to
23 conduct a review of the site every five years to
24 determine if the contaminants remaining on the site are
25 causing any additional risk to human health or -the
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environment. As a result of this review, the EPA can
determine if additional site remediation is required.
So the cost that you see there is just for us to
come up once every five years and sample approximately
thirty wells and prepare a report, and that would be
done over a thirty-year period. The cost is about four
hundred — basically about $400,000. Mo, 291,000. I
read it wrong.
The next alternative, or Alternative 2, is Limited
Action and what that would be would be the deed
recordation. That means everybody who lives in the
area that had contaminated water, this will be recorded
on your deed, saying that you had contaminated water
under your property and if you installed the well on
that property, then contaminated water may result.
This also includes the periodic sampling of thirty
wells over the next thirty years and, of course, the
five-year reviews, since the contaminants would be left
on site. And this would be about $400,000.
Our third alternative includes the groundwater
monitoring and the five-year reviews, but it also
includes connecting all homes, churches and businesses
in the site area to the City of Belmont public water
services lines. These are people that are not
currently connected now. In addition, people would be
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5 9 OU99
1 given the option to obtain wellhead treatment of their
2 private wells. This would be carbon filters would be
3 placed on the well to treat the water and filter out
4 contaminants before it got to your house.
5 Originally, in your proposals, we had envisioned
6 paying for the upkeep of these filters and sampling
7 them periodically and changing the filters out yearly.
8 , This was proposed in the fact sheet that you had.
9 However, in a cleanup when we don't have a private
10 party paying for the cleanup, such as this one, the
11 Superfund has to pick up the tab for this and the State
12 of North Carolina will be required to take over the
13 upkeep of these wells after a year or so. So,
14 therefore, it was decided that if you choose the
15 wellhead treatment, EPA will maintain it for a year and
16 then after that, you would be required to take over the
17 maintenance of it and we have coated it out. The cost
18 for changing the filter, maintaining it and having
19 somebody come out and check it will be about $1,000 a
20 year.
21 In the fourth alternative —
22 UNIDENTIFIED SPEAKER:
23 Excuse me.
24 MS. BENNETT:
25 — or the third alternative will be about 3.1 —
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1 UNIDENTIFIED SPEAKER:
2 Excuse me. IB that per well?
3 MS. BENNETT:
4 Yes.
5 UNIDENTIFIED SPEAKER:
6 A thousand dollars per year per well?
7 MS. BENNETT:
8 Right.
9 UNIDENTIFIED SPEAKER:
10 Per individual?
11 MS. BENNETT:
12 Per well.
13 UNIDENTIFIED SPEAKER:
14 The homeowner would have to pay that?
15 MS. BENNETT:
16 Per well, right.
17 UNIDENTIFIED SPEAKER:
18 For the homeowner?
19 MS. BENNETT:
20 Right.
21 UNIDENTIFIED SPEAKER:
22 What happened, though, to the State?
23 UNIDENTIFIED SPEAKER:
24 Yeah. What is —
25 ********
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1 UNIDENTIFIED SPEAKER:
2 You mentioned the State would be required or would
3 pick that up —
4 MS. BENNETT:
5 Well, —
6 UNIDENTIFIED SPEAKER:
7 - — after a year.
8 MS. BENNETT:
9 Right. That — that would be per our agreement
10 with the State.
11 UNIDENTIFIED SPEAKER:
12 But the — then why would the individual do that
13 and be responsible for it if the State did it?
14 MS. BENNETT:
15 Well, I mean, — let me —
16 UNIDENTIFIED SPEAKER:
17 Only through taxes, I know that.
18 MS. BENNETT:
19 Okay. But let me get through these alternatives
20 first and then when we open it up for questions, I'll
21 explain it more thoroughly.
22 The cost of the third alternative is about 3.1
23 million.
24 In the fourth alternative, we would include all
25 the provisions in the third alternative except that we
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1 would add groundwater treatment and in this one, EPA
2 would attempt to clean up the contamination that you
3 see in these two photographs or these two shots. We
4 would propose a new technique called in-well vapor
5 stripping, which would cause air to strip the
6 contaminants from the groundwater and then that air
7 would be treated with a carbon filter. And, also, we
8 will include in-situ bioremediation, which would
9 enhance and speed up the degradation process already
10 happening in the aquifer. We are proposing that this
11 alternative would be carried out for ten years as
12 opposed to the thirty-year time frame of the other two.
13 Now, the EPA's preferred alternative, the one that
14 we are proposing tonight, is alternative 4, which
15 includes the city water connections, the optional
16 wellhead treatment, the cleanup of the contaminated
17 groundwater, along with the groundwater monitoring and
18 the five-year reviews. This would be operational for
19 ten years and cost 4.6 million dollars.
20 Now, as Diane said, we have a comment period until
21 September 1st. We would like to hear from you and let
22 us know what you think about the city water
23 connections, about the wellhead treatment, et cetera.
24 So that —
25 ********
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1 MS. BARRETT:
2 Hell, let me just say one thing, then. As you
3 make your comments, if you'll please give your name so
4 the court reporter can get them because it's supposed
5 to be a verbatim transcript of the meeting so we'll all
6 know who makes the comments. And if you want to
7 comment, please state your name. Thank you.
8 MS. BENNETT:
9 And if you — you can stand up and —- so everybody
10 can hear your questions.
11 MS. BARRETT:
12 There was a comment over here.
13 MR. SMITH:
14 I don't really have much of a comment. My name is
15 Merle Smith. Those proposals, can there be a copy
16 given to each one here to study and to look at?
17 MS. BARRETT:
18 Yes, sir. In your fact sheet, there is a brief
19 write-up of those.
20 MS. BENNETT:
21 In the green.
22 MS. BARRETT:
23 The green one there that you have?
24 MR. SMITH:
25 The green one?
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1 MS. BARRETT:
2 Yeah, look through those. Here they are:
3 Alternatives 1/2, 3 and 4.
4 MR. SMITH:
5 Okay. Now, 4 is the one y'all are proposing;
6 right?
7 MS. BARRETT:
8 That is correct. But you'll have to look at it
9 with alternative 2 because it does include — I mean,
10 3. It does include 3.
11 MR. AUSTIN:,
12 My name is Randy Austin. If you connected all the
13 people that are in the affected area to ground — to
14 city water, how long would it take for this to
15 naturally clean itself up?
16 MS. BENNETT:
17 Hell, the level is what we call high, you know,
18 over 1,000 parts per million or micrograms per liter,
19 »o I — I have no way of knowing. It would continue to
20 spread, so at the beginning near Roper's, the
21 concentration would eventually get lower, but
22 downstream, as we see it moving further downstream,
23 those people would be affected.
24 MR. AUSTIN:
25 So while it's beginning to spread, it's also
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1 diluting itself?
2 MS. BENNETT:
3 Right; that's true.
4 MR. AUSTIN:
5 So over what period of time would it take for it
6 to dilute itself down to a point where it'd reach
7 acceptable levels? I mean, y'all — it sounds to me
8 like y'all have jumped to a conclusion to go out and
9 put in wells and filter the water and bring the levels
10 down to nothing, but if I remember my biology
11 correctly, it has to degrade over some period of time.
12 It's not like radiation that's going to last for a
13 million years, so with dilution and over time it has to
14 degrade, but how long a period of time? And if you put
15 everybody on city water, it seems reasonable to me that
16 if nobody's using that water for any human purpose,
17 potable water in particular, there shouldn't be a
18 problem.
19 MS. BENNETT:
20 Hell, the problem there wouldn't be this
21 neighborhood that we see right here. It would be the
22 next neighborhood further down and eventually, we'd
23 have to go over there and say, "Well, it came from over
24 here and we put all those people on city water, so now
25 if you're continuing to use your private well, now
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59 O'l06
1 you're pulling that water toward you."
2 MR. AUSTIN:
3 But even if you do that, it's going to bee
4 considerably less than 4.6 million dollars. I mean,
5 even though the EPA may be paying for this, that's
6 still our tax dollars. I mean, we're still paying for
7 it.
8 MS. BENNETT:
9 Hell, no, Super fund is based on a tax of chemical
10 and petroleum industries.
11 MR. AUSTIN:x
12 I know what it is, but it's still coming from —
13 from our tax dollars. It's still coming from tax
14 dollars somewhere. Somebody's paying for this and the
15 general public somewhere is paying for this and it just
16 doesn't seem reasonable to spend that much money doing
17 it if, over time, it's going to work itself out and you
18 just move people to city water.
19 MS. BENNETT:
20 Hell, that's one of the things we're doing, is
21 we're going to try this in-situ bioremediation and what
22 that would be is that would help speed up that
23 degradation process. In that process, you put in
24 nitrogen and other nutrients that the microorganisms
25 use to eat this kind of contamination up, so we would
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59 .0107
1 try to speed that process up. I mean, as you can see,
2 our — our levels that we need to get down to for
3 people to be able to drink this water are extremely low
4 and if you look at the numbers that we have now, it
' 5 would take quite a bit of time for those numbers to get
6 down to acceptable levels.
7 MR. AUSTIN:
8 Okay. I've looked at all the charts that you had
9 and what you had in 1991 and what's moved to 1995 and
10 1996. It doesn't look like the movement is that
11 significant. It looks like you'd be able to calculate
12 where the plume is going to go over the course of the
13 next ten, twenty or thirty years and what the cost
14 would be to convert all those people that would
15 eventually be affected into city water. Even if you do
16 that, it still seems like it'd be a lot less expensive
17 than spending the 4.6 million dollars.
18 MS. BENNETT:
19 Yeah, but one of the things you have to realize,
20 our mission is not only to protect human health, but
21 it's to protect the environment as well. Our first
22 mission is to restore this groundwater to beneficial
23 usage. I mean, if everywhere we went we ended up
24 writing off the groundwater because it was
25 contaminated, you know, eventually we wouldn't have any
-------
25
59
O'iOS
1 safe drinking the water.
2 MR. AUSTIN:
3 But how long do you write it off for? That's the
4 question that I've asked that hasn't been answered. I
5 mean, how long would it take to clean itself up?
6 MS. BENNETT:
7 And I'm saying I don't know.
8 MS. BARRETT:
9 Hell, it could be hundreds of years as slow as
10 groundwater does move.
11 MS. BENNETT:
12 He just don't know.
13 MS. BARRETT:
14 Hell, to bring up one point, I just wanted to show
15 the difference. On the initial plume — I don't know
16 if you can see that. It shows here on Magnolia and
17 Apricot, right in this area here, that was the original
18 plume. So you can see the size there and then the way
19 it looks now, it's far beyond Apricot and on down here.
20 So it's — it has spread quite a bit.
21 MR. AUSTIN:
22 But what — I guess the other point is what
23 levels, what's the detectible levels? As the plume
24 spreads, what's the detectible level out at the edge of
25 the plume and how much does it increase as it goes in?
-------
26
59 .0*109
1 MS. BENNETT:
2 But, eeet the drinking water standard here in
3 North Carolina is one. That's as low as we can detect
4 on a — in a laboratory, so everywhere we find it, it's
5 above our standards. Like I said, in '91, we had
6 people who didn't want to go on city water because
7 their wells were fine. When we cane back in '96, one
8 lady had over 300 parts per billion in her well. She
9 didn't know it; she was drinking it, and that's far
10 above our level of one that we want to get down to. So
11 you caji say yes, it has decreased from the initial
12 15,000 that was found in '91, but would you want to be
/
13 the person drinking 300?
14 MR. AUSTIN:
15 That's not —
16 MS. BENNETT:
17 And the only way we can discover that is until it
18 actually gets in your well and you're drinking it. So
19
20 UNIDENTIFIED SPEAKER:
21 Isn't it true that —
22 MR. FOREMAN:
23 My name is Allen Foreman and I'd like to say that
24 as far as I'm concerned, clean water is one of the few
25 things that I would like to see exist in this country.
-------
27
59. 0110
1 We've contaminated so much already that I don't want to
2 put a dollar value on cleaning up this water and who
3 knows what effects it has already bad and what it would
4 have in the future if we've done nothing.
5 The second thing I'd like to say is that I noticed
6 in this area when they were doing the testing that they
7 did several wells on my property and I had asked — I
8 have a house that, at this time, we even had a joint
9 well with the house next to us. The well was on the
10 other owner's property and I was trying to find out
11 about ythis sampling and testing and never did. I did
12 have someone to come one time to take a sample from the
13 inside of my house, which they say could not be real
14 accurate or as accurate as from the well, but I never
15 heard any results of that, so I then — I just tapped
16 onto the city myself. The question being those people
17 — I know of others that have done that out of fear,
18 just not knowing what was going on. Are they going to
19 be reimbursed for the expense that they incur
20 themselves is you choose alternate 3 or 4?
21 MS. BENNETT:
22 No; we have no provision for reimbursement. As I
23 said, the alternative would include connecting those
24 who are not currently connected to city water.
25 ********
-------
28
59 0111
1 MR. FOREMAN:
2 Okay. The man who lives across the street from me
3 was reimbursed.
4 MS. BENNETT:
5 I don't —
6 MR. FOREMAN:
7 And I was told not to tap onto city water at that
8 time due to the EPA was still doing work and I should
9 wait and see and I waited about ninety more days and
10 then I — I went ahead and tapped on, and that's —
11 that's what I want to know. I know of another that has
12 tapped on and two others that wanted to, but we were
13 instructed to wait to see what the results were, but I
14 have children at home and I — I didn't want to just —
15 I don't want my kids drinking this stuff.
16 MS. BENNETT:
17 Can you come up and talk to me after the meeting?
18 MR. FOREMAN:
19 Yes.
20 MS. BENNETT:
21 Okay.
22 MS. THOMPSON:
23 My name is Debra Thompson. I was wondering about
24 the side effects of people who drank this stuff from,
25 what, '85 to now or '65, whenever it was done.
-------
29
59 .0112
1 What are we supposed to do about anything that
2 comes up as far as health problems in the future? Are
3 we responsible for all this or can you contact or make
4 the person who done it responsible for it or what are
5 we supposed to do when all this cancer-causing is —
6 we've all got it and our kids have got it? Bow long
7 does it take for you to drink this stuff before you can
8 — it starts harming your health?
9 MS. BENNETT:
10 Hell, we have no way of knowing that. What we
11 look *t are current conditions. We have documents that
12 say what are the effects of these chemicals and, you
13 know, we can talk about each individual one, but as far
14 as cumulative effects or overall effects over time, we
15 don't have those kind of statistics. All we can say is
16 whether or not they — it's a probable cancer-causing
17 agent or a possible cancer-causing chemical. Doc, can
18 you — can you help us out here from the health
19 department?
20 UNIDENTIFIED SPEAKER:
21 Yeah; we had — we had (inaudible) —
22 UNIDENTIFIED SPEAKER:
23 Toxicology tells us that these are —
24 MS. BENNETT:
25 Wait. Can you state your name?
-------
30
59 .O'liS
1 MR. HUNT:
2 Boyce Bunt, environmental health administrator.
3 Toxicology tells us that these contaminants are
4 carcinogens. It depends on the person, depends on your
5 age, your weight, et cetera, a number of factors, the
6 whole physiology of how much you drink and what other
7 health defects you may have thrown in, so many factors,
8 there's no way that I can tell you or I don't know of a
9 physician or a toxicologist or anyone else who could
10 answer that question.
11 MS. BENNETT:
12 As far as those responsible, this site is a —
13 what we call a Fund B. We have no responsible parties
14 here, so all cleanup expenses will be paid by the EPA
15 and the State.
16 MS. THOMPSON:
17 Okay. I've got one other question. This proposal
18 number 2 about the deeds, that's going to devalue our
19 land if we decide to sell because nobody's going to
20 want to buy contaminated land. If you put this on our
21 deed, there's no point in us trying to sell. If you do
22 that proposal, how is it going to benefit us in any
23 way?
24 MS. BENNETT:
25 Which one, 2?
-------
31
59 0114
1 MS. THOMPSON:
2 Uh-huh. About putting it on our deed about being
3 connected — our water being contaminated.
4 MS. BENNETT:
5 Well, see, 2 wouldn't say that your land was
6 contaminated; it would say that the groundwater beneath
7 your land is contaminated and, really, according to
8 real estate laws, if you are selling your house and you
9 know your groundwater is contaminated, you should tell
10 the potential buyer so they won't try to put in a
11 private well and then get contaminated water.
12 MS. THOMPSON:
13 That's my point. If you tell them or if it's on
14 your deed, they're — they're going to say, "Well, I
15 don't want this property because the groundwater's
16 contaminated and I don't want any part of it," the same
17 reason we don't like it, because it's a health problem.
18 MS. BENNETT:
19 Right. Well, that — you know, we're going to —
20 the alternative that we're proposing here is going to
21 try to clean this up a lot faster that if it would
22 degrade on its own.
23 MS. BARRETTS
24 And, of course, that wouldn't be a deed
25 recordation either. If we're cleaning it up, it would
-------
32
59 Or] 5
1 not be any kind of record on the deed because the
2 water's being cleaned up.
3 MS. BENNETT:
4 But the fact of the matter would still be that the
5 groundwater beneath your property is contaminated.
6 . Sir, wait. This gentleman behind you has been
7 trying to —
8 MR. BLACKWELL:
9 My name is Eugene Blackwell and I was going to ask
10 isn't it true that all groundwater has some
11 contamination? That's the first question, and the
12 second one is are you telling us that the Belmont
13 water, if we hook onto it, has less than one or one
14 contamination?
15 MS. BENNETT:
16 Well, to answer your first question, there are a
17 number of different things in — in water, different
18 metals and everything, but these kinds of chemicals
19 aren't naturally occurring, so we wouldn't expect to
20 see them in the groundwater. Different places we
21 sampled, you know, they all contained those. A lot of
22 places we always see aluminum and iron and that kind of
23 stuff in the water, but everywhere you go you don't see
24 trichloroethene or tetrachloroethene.
25 And your second question was — what was your
-------
33
59 0 VI 6
1 second question?
2 MR. BLACKWELL:
3 The Belmont water, does it have any contaminant in
4 it, city water?
5 MS. BENNETT:
6 Hell, the city water, since it serves over twenty-
7 five people, is governed by a clean drinking water —
8 well, the State's Drinking Hater Act, so yes, they have
9 to go by these standards. Their water is tested
10 periodically and they have to meet these standards, not
11 only these, but a lot of others.
12 MR. BLACKWELL:
13 But do they meet the standards is the question?
14 (Inaudible response by health department)
15 MS. BENNETT:
16 The health department is saying yes, they do. If
17 they aren't, they're fined, so you would see it in your
16 -tax dollars, I suppose.
19 MR. BROOME:
20 My name's Larry Broome. The — you got —- it
21 doesn't look like you've got a handle on it, I don't
22 think. It don't make any difference what the price of
23 it is. Hater is our most valuable resource and we
24 won't — without water, we won't function anyway and
25 that thing's like a fire: if you're going to put it
-------
34
59 0 VI 7
1 out, now is the time to put it out, just don't keep
2 talking about it and putting dollar marks on it. The
3 best thing is if you just want to clean the thing up,
4 it's like a fire. If you're going to put it out, put
5 it out and just don't let the thing keep on and on and
6 on.
7 I'm not in the habit of — I don't worry about
8 myself giving it to the neighbors, you know. I don't
9 care nothing about it spreading on down the line and
10 working on somebody else trying to get free with city
11 water^ which probably city water's got enough chemicals
12 in there to kill you anyway without drinking out of a
13 river, but, you know, this, I think it's here and I
14 think it ought to be addressed. I think it ought to be
15 cleaned up.
16 I don't care — the administration spends more
17 than that five million dollars. They waste that much
18 on airplane flights, so I don't care. I think we ought
19 to have it cleaned up. I mean, that — that's my
20 opinion and I don't speak for anyone else, but it's
21 there, clean it up. I don't see no sense in talking
22 about it. It's there and it's growing. I'm going to
23 die anyway. I don't care enough about leaving it to
24 somebody else. I mean, I'd just do it and — but it's
25 on our property, but I'd like — I'd like to have it
-------
35
59 0118
1 cleaned up. I don't care if it costs me more in taxes.
2 I mean, they're going to tax me to death anyway.
3 MS. BARRETT:
4 Thank you.
5 MR. PERKINS:
6 My name is George Perkins. I don't live in this
7 community, but I'm a representative of Centerview
8 Baptist Church which is right down the street at the
9 end of School Street. Within seventy-five or 100
10 yards, there's con- — and our water's not
11 contaminated, but within seventy-five or 100 yards on
12 each side or all around the church, the water is
13 contaminated.
14 Will our water eventually become contaminated and
15 what's the chances that it will be? We paid $60.00 a
16 quart to get our water tested and so far, it has not
17 been contaminated, but, actually, my question is will
18 it eventually become contaminated?
19 MS. BENNETT:
20 You're at the corner? Do you know where that
21 location —
22 MR. PERKINS:
23 No, down at the end of School Street, just a
24 couple of tenths of a mile down here.
25 *******
-------
. 36
59 0 'I 1 9
1 MS. THOMPSON:
2 Right at my house, Giezelle, the church at my
3 house.
4 MS. BENNETT:
5 Okay.
€ MS. BARRETT:
7 - Yeah, the corner.
8 MS. BENNETT:
9 Well, it depends on how deep your well is. As we
10 showed you, the shallow water, which is less than
11 thirty-five feet, that's a real localized area as far
12 as the groundwater contamination, but if it's deeper
13 than thirty-five feet, yes, it will eventually get
14 there.
15 MR. AUSTIN:
16 Randy Austin, again. If you decide to go with
17 proposal 4, when will you begin?
18 MS. BENNETT:
19 Hell, this site has to be placed on the National
20 Priorities List to receive fund money since we don't
21 have a potentially responsible party. We would have to
22 do a remedial design, which would look into the — what
23 we call the probability, the treatability of these
24 different alternatives, so we could be looking at
25 probably about three years before we start.
-------
37
5 9 0120
1 MR. AUSTIN:
2 Okay. The other thing that you mentioned was that
3 the EPA, according to the Superfund, would come in and
4 put the wellheads in and the filters and then after a
5 year, then we would be responsible to change the
6 filters. Does the State pay for that or do we pay for
7 that?
8 MS. BENNETT:
9 Hell, after a year, you would be responsible for
10 paying it. We start it up, make sure it is functioning
11 properly, have somebody come out and make sure, after a
12 while, it was continuously functioning properly, but
13 after then, if you want the treatment on your well,
14 yes, you would have to be responsible for maintaining
15 it. That's why we are emphasizing that we want all —
16 the — that whole, entire area, churches, homes,
17 businesses, connected to city water because that way we
18 know you're drinking safe water. We don't have to
19 worry about you maintaining your filter, you forgetting
20 about it, you can't afford it or whatever. That way,
21 you'd have city water and we know your water will be
22 safe.
23 MR. AUSTIN:
24 Bow much is this plume going to spread in three
25 years?
-------
38
5 9 : 0121
1 MS. BENNETT:
2 Well, I don't know that. It has spread from right
3 there — from the shopping center to where it is now
4 from '91 to '97, over the last six years, so I don't
5 know.
6 MS. CRAMER:
7 My name is Dot Cramer. I'm a resident on my mom's
8 property on O'Daniel Street where you have a test well
9 and you tested the shallow end and then you tested the
10 deeper well and at first we thought it was really bad
11 contaminated and we — nobody drank the water. He'd
12 carry water and use bottled water and then we got a
13 letter saying it wasn't too bad; it wasn't to a point
14 where it would be safe but to keep checking it.
15 My question is we're anxious not to drink the
16 water anyway since it's already been said it was and
17 now it is not or may be safe, but how long would it be
18 before we'd — we'd be connected to the city water?
19 MS. BENNETT:
20 Hell, as I told that gentleman there, we have a
21 number of steps we have to do before we actually start
22 the cleanup process.
23 MS. CRAMER:
24 Does that include the connections?
25 ********
-------
39
5 V ;Cri22
1 MS. BENNETT:
2 Yeah. That would be one of the first things we
3 did.
4 MS. CRAMER:
5 Three years?
6 MS. BENNETT:
7 We could do that before we did anything else, but
8 we will periodically come back and sample some of the
9 private wells in the meantime. We would definitely do
10 that within this three-year period.
11 MS. CRAMER:
12 We're concerned about it because we have rental
13 houses there and our renters, we feel responsible for
14 them.
15 MS. BENNETT:
16 Right. That's one of the reasons why we went
17 ahead and started this investigation. Normally, we
18 wait until the site gets on the National Priorities
19 List before we even start the investigation, but our
20 on-scene coordinator, who worked closely with Doc,
21 recommended that we go ahead and start this
22 investigation, so we did that earlier than normal.
23 MR. SMITH:
24 Merle Smith again. Not being able to see the map
25 too well there, how is this thing spreading on Woodlawn
-------
40
59 0123
1 Street now? Site A is right here and the water will
2 run out here and that's on Woodlawn and I live just
3 down here from the cemetery. Now, how far is this
4 getting —
5 MS. BENNETT:
6 Yeah, but we —-
7 MR. SMITH:
8 It seems like it's going that way according to my
9
10 MS. BENNETT:
11 Hell, that's the way groundwater is flowing;
12 however, we did test one private well over there. Mr.
13 Roper's son has a well over there and they use —
14 MR. SMITE:
15 We share the same well.
16 MS. BENNETT:
17 About 500 feet deep.
18 MR. SMITH:
19 Yeah.
20 MS. BENNETT:
21 And the only explanation we have is that, you
22 know, from the pumping of that well, that it has
23 somehow hit a fracture down there that was contaminated
24 that was connected with the water underneath the dry
25 cleaners and it had just pulled it over that way, but
-------
41
59 -0124
1 that area will be included in the city water
2 connections.
3 MR. HAAS:
4 My name is Jimmy Baas. On this cleanup that is
5 number 4, what will be done with the water that y'all
6 strip in the carbon filters? Will it go into the city
7 sewer?
8 MS. BENNETT:
9 No; that's one of the unique things about this new
10 treatment technology. It constantly recycles the water
11 so the^ water never comes up out of the ground. It
12 continuously cleans it, so it — the only thing that
13 comes up is the air and the air is treated with a
14 carbon filter.
15 MR. BAAS:
16 That's different from the Jack Bughes?
17 MS. BENNETT:
18 Right. In the Jack Hughes site they are actually
19 pulling the water out of the groundwater — out of the
20 ground and then treating it and then putting it into
21 the publicly owned treatment water for the sewer
22 system; right. But we aren't proposing that here and
23 one of the main reasons we aren't is because this is a
24 — more of a residential community. He don't have a
25 big block of land like they do and so I don't know if
-------
42
5 9 0125
1 you have been by there. They have a big treatment
2 tower that they have and we don't want to just put one
3 of those in somebody's back yard so —
4 MR. BAAS:
5 That's why I was wondering if it was going to be
6 similar to that. I know with that site over there, it
7 takes up a good bit of room.
8 MS. BENNETT:
9 Right. Yes; we were trying to look for
10 alternatives where we would be the least intrusive on
11 the neighborhood and also clean up the groundwater.
12 MS. TOMSON:
13 My name is Jolee Tomson. Our house is on Site B
14 and do you feel like that since we're on city water
15 that that takes care of all the risks, just putting you
16 on city water and right now the risks are gone?
17 MS. BENNETT:
18 Right. That would be your only risk. We didn't
19 find any contamination in the soil on your property/ so
20 just so long as you don't put in a private well and
21 drink the water, then you're fine.
22 MR. ROBINSON:
23 My name is Elliot Robinson. I have two questions.
24 I'll ask one and then the other. What happens if the
25 — toward the end of the ten-year period you find
-------
43
5 9 0126
1 you're not reaching your goals as you might wish? Is
2 there a re-evaluation done?
3 MS. BENNETT:
4 Well, as I said, we have what we call five-year
5 reviews. After every five years, we look at the remedy
6 and we evaluate it to see if it's continuing what it's
7 supposed to do and if it's not, yes, we will evaluate
8 after five years and after ten years and if that comes
9 up/ then we'll have to look at something else or, you
10 know, just re-evaluate the whole thing.
11 MR. ROBINSON:
12 The other question is in the middle of the
13 process, if some new technology becomes available, is
14 it possible to introduce that to the site rather than
15 what you say you're going to do in the beginning?
16 MS. BENNETT:
17 Well, it would have to be pretty radical and a
18 whole lot better than what we're doing for us to switch
19 in the middle of the project.
20 Does anybody else have any other questions?
21 MS. BARRETT:
22 I want — I just want to ask the audience one
23 thing. Are — do you most of you understand how
24 groundwater flows, how it moves or anything like that?
25 Because a lot of times in the — when we go to the
-------
44
59 CTI27
1 site, they don't. People think it's a river.
2 Hell, I don't know if you can see this or not, but
3 it shows how groundwater — groundwater flows like this
4 down here. Groundwater flows in all these cracks like
.5 this right there. It can coxae from the rain or
6 whatever gets on the soil surface leaches down, okay,
7 leach or percolate down, and it goes in these cracks
8 and it flows through these cracks and to answer your
9 question awhile ago about the depth of your well, all
10 right. See this well. This is 500 feet and if the
11 contamination's up here and your well draws from this
12 depth, it really wouldn't have contamination from this
13 spot. It could from something else flowing this way,
14 but not from, say, this site. But what Giezelle was
15 saying is that the contamination from the site might
16 have gotten down in these cracks, come on down and
17 gotten down there in that one location.
18 So that's kind of how groundwater flows. It flows
19 through these cracks right here and it — and that's
20 why I said, in answer to your question a little bit
21 earlier, it does flow rather slowly because it's going
22 through these little cracks.
23 MS. BENNETT:
24 It seeps.
25 MS. BARRETT:
-------
45
5 9 0128
1 Yeah.
2 MS. BENNETT:
3 That's called fractures.
4 MS. BARRETT:
5 Right, fractures. Fractures. But that's how it
6 flows and, then, too, it shows different wells. This
7 would be like a city well there and this would be like
8 a citizen's well with more shallow surfaces here and,
9 then, too, a lot of times it flows into a water body so
10 here it shows water coming to this water body and water
11 coming to this ~ I mean, the groundwater moving into
12 this water body so that kind of helps maybe, I hope, to
13 give you a little bit of understanding about the
14 groundwater itself, about how it moves and flows.
15 UNIDENTIFIED SPEAKER:
16 The rivers and the — like, the South Fork River
17 and all is polluting the ground as much as this is.
18 MS. BARRETT:
19 Well, whatever is — say —
20 UNIDENTIFIED SPEAKER:
21 Going through the ground.
22 MS. BARRETT:
23 Yeah. Whatever is here will eventually move
24 toward a major water body 'cause it's being drawn that
25 way, but, too, like, — and one things that was brought
-------
_____ 46
5 9 CTI29
1 up, if all of these wells, say, in this area stop
2 pumping, but if this guy over here is still pumping,
3 well, he can draw contamination toward him because he's
4 pumping when everybody else has stopped. Be would have
5 a greater pull on water coming to him, to his well.
6 UNIDENTIFIED SPEAKER:
7 So if somebody, say, ten houses on up above you is
8 on city water and you're not, you done sucked all the
9 contamination down the well. Do you —-
10 MS. BARRETT:
11 You're going to pull it to you faster because
12 with, say, 100 wells pulling, all right, you're all
13 pulling at a certain rate, but then 99 stop and one's
14 pulling, then it's bypassing all these others to that
15 one.
16 MS. BENNETT:
17 That's how we think that the groundwater got where
18 it is today because so many people were — in that
19 immediate area were put on city water and they closed
20 down their wells and those people further out were
21 still pumping.
22 UNIDENTIFIED SPEAKER:
23 Who paid for that?
24 MS. BENNETT:
25 EPA did.
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47
59 CTI30
1 UNIDENTIFIED SPEAKER:
2 Hell, why would they not be responsible for these
3 other people that's here that's got wells now?
4 MS. BENNETT:
5 Well, I'm going to talk to him after the meeting
6 about that, but generally, what we do is we have to
7 look at the current risks right now and, currently,
8 he's not at risk and he's on city water.
9 MR. FOREMAN:
10 It cost me $1,000 not to get that way.
11 MS. PARKER^
12 My name's Kay Parker. Hasn't they given the
13 choice to get on the city water or keep their well
14 water?
15 MS. BENNETT:
16 Some people were and I think we had seven who
17 chose not to connect to city water back in '91. But
18 this time, we don't want anybody to opt not to because
19 we might not be back, so it would —•
20 MR. PAYSEUR:
21 Okay. I — I'm Willie Payseur and when I found
22 out the well was contaminated, when they dug in with
23 city water, I hooked up and cut my well off, but nobody
24 ~ it's 325 feet deep and nobody has ever come out and
25 checked it and how can you put mine on it, on the deed
-------
48
5 9 0131
1 that it's contaminated if nobody's never checked it?
2 MS. BENNETT:
3 Well, the only thing that we're saying is if we
4 . chose Alternative 2, then the whole area would be put
5 on it because if it either has it or may have the
6 potential to have it.
7 MR. FAYSEUR:
8 And before that, my water had been fine, 'course I
9 haven't had it checked since then.
10 MS. BARRETT:
11 What is your name, sir? The court reporter didn't
12 get it.
13 MR. PAYSEUR:
14 Willie Payseur.
15 MS. BARRETT:
16 Thank you.
17 MR. PAYSEUR:
18 201 School Street.
19 MR. SMITH:
20 Excuse me. Merle Smith. Let's just clarify one
21 thing here, though. Y'all are not proposing
22 alternative number 2. Y'all are proposing alternative
23 number 4, —
24 MS. BENNETT:
25 Right.
-------
49
5 9 0132
1 MR. SMITH:
2 So we need to get the deeds off our minds.
3 MS. BENNETT:
4 Right.
5 MR. SMITH:
6 'Cause that's not what you're proposing.
7 MS. BENNETT:
8 Well, that's not what we're proposing, but we do
9 open this up for public comment. Like, if all of you
10 said that, "No; we don't want to be connected to city
11 water^ We don't want any of that stuff. Just leave
12 the site as it is," well, I don't know if we could
13 leave the site as it is, but —
14 MR. SMITH:
15 Well, I don't feel that anyone in here is wanting
16 proposal number 2, you know.
17 MS. BARRETT:
18 But when we come for a proposal meeting, we have
19 to put all of them on the floor for your consideration.
20 MS. BENNETT:
21 Right.
22 MR. GADDIS:
23 I'm Miles Gaddis. The last time that dry cleaners
24 was used was in '75?
25 *******
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50
5 9 0133
1 MS. BENNETT:
2 Right.
3 MR. GADDIS:
4 And in '91 they found contamination and from '91
5 to '97 it has spread a whole lot. Hell, what happened
6 in those twenty-two years? It just stayed in one
7 place?
8 MS. BENNETT:
9 Well, but the thing about it is is when the dry
10 cleaner disposed of it, he disposed it on the ground,
11 so it \had to have time to seep through ground to the
12 groundwater and then start moving, so if he would have
13 had a well and he'd injected it right into the well,
14 right into the groundwater, you probably would have
15 seen it a whole lot faster.
16 MR. GADDIS:
17 Well, what it did, in twenty-two years, you know,
18 it hadn't moved very far, you know, and then all at
19 once it started flowing a lot. I just wondered about
20 that.
21 MS. BENNETT:
22 Yeah. There's a lot about groundwater that we
23 don't know.
24 MS. MEBAFFEY:
25 My name is Edna Mehaffey. I'm just wondering,
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51
5 y . OV34
1 will you do each well, pump it out and clean it or do
2 you do a site and it cleans up the wells in this area?
3 MS. BENNETT:
4 Say that again?
5 MS. MEHAFFEY:
6 Do you go to each well and clean it or do you
7 clean, like, a well and the next — the houses around
8 that area will be okay? Do you know?
9 UNIDENTIFIED SPEAKER:
10 On your cleanup —
11 MS. BENNET^:
12 He wouldn't use the private wells. We would come
13 in and put in what we call some treatment wells for the
14
15 MS. MEHAFFEY:
16 Oh, you don't mess with our wells? Okay.
17 MS. BENNETT:
18 We couldn't use your well.
19 MS. MEHAFFEY:
20 Okay. Okay.
21 MS. BENNETT:
22 In fact, we would close your well up probably.
23 UNIDENTIFIED SPEAKER:
24 (Inaudible).
25 ********
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52
5 9 0135
1 MS. MEHAFFEY:
2 I didn't know if you went down in our wells or,
3 you know, how it —
4 MS. BENNETT:
5 That's right. And each well would have a — what
6 we call a cone of influence. It would influence water
7 within so many feet around it and so that's part of the
8 design. We would have to find out exactly how many of
9 those we would have to put in to clean up this entire
10
11 MS. BARRETT:
\
12 Well, it's a good question.
13 MS. BENNETT:
14 Yeah.
15 MS. BARRETT:
16 You think you know about wells (inaudible)
17 (Many people in the audience talking at once)
18 MR. FOREMAN:
19 I've read in the fact sheet, it seems to me like I
20 read in there something about a septic tank in Site A
21
22 MS. BENNETT:
23 Right.
24 MR. FOREMAN:
25 — that was never found.
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53
5 9 OV36
1 MS. BENNETT:
2 Well, we could —
3 MR. FOREMAN:
4 It could possibly still be seeping these poisons
5 or contaminants into the water. What will be done to
6 find that septic tank or can it be found?
7 MS. BENNETT:
8 Well, I don't know. I mean, the State came out in
9 '91 and looked for it and didn't find it. We came out
10 in '96 and early '97 and couldn't find it and you saw
11 the p\ot there that showed all the different soil
12 samples that we took. We didn't find any of the
13 organics in the soil.
14 MR. FOREMAN:
15 Well, I think what I was after when I — in your
16 cleanup sites you were predicting days when this stuff
17 could start to be cleaned up and if you chose
18 Alternative 4 and you were going to clean this water
19 and that septic tank is still out there and it's still
20 pumping contaminants in, is that not going to delay the
21 process?
22 MS. BENNETT:
23 It would, but we don't believe that's the case
24 because the contamination levels have gone down since
25 '91. Like I said, you know, some of those they had
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54
5 * 0137
1 found in '91 were 15,000. Now the highest that we've
2 found was 3500, so like I told that gentleman, they're
3 going down but not nearly fast enough to say that it
4 will eventually clean itself up within our lifetime
5 anyway.
6 MS. GALLOWAY:
7 It's only after we get through the cleanup process
8 that we'll be able to go back to using our wells or do
9 we have to stay on city water?
10 MS. BENNETT:
11 Well, that's a hard question. We wouldn't want
12 anybody to use their well until we got back down to
13 those levels that we showed you, which are our cleanup
14 goals, and so I guess if and when you got down there
15 and you made the determination that the water was safe,
16 then you could probably put in another city — I mean,
17 put in another private well.
18 MS. GALLOWAY:
19 But what would happen if, like he said about this
20 septic tank, if we went back on our wells and it got
21 contaminated again? Would we just have to do all this
22 over again or —-
23 MS. BENNETT:
24 No; we would monitor — we are going to be
25 monitoring the groundwater to make sure the levels are
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55
5 y OV38
1 going down, so — and like I said, we wouldn't
2 recommend that anybody put in a new private well or use
3 their old private well until we determine that the
4 water was safe to drink, and that may or may not
5 happen. We don't know.
6 MS. BARRETT:
7 . What was your name? Excuse me.
8 MS. GALLOWAY:
9 Julie Galloway.
10 MS. BARRETT:
11 Julie. Thank you.
12 MR. GADDIS:
13 Miles Caddie again. If your well has been checked
14 and your water is good, would it be all right to water
15 your lawn and all with it?
16 MS. BENNETT:
17 Well, you know, you and I talked about that
18 before.
19 MR. GADDIS:
20 Yes.
21 MS. BENNETT:
22 That's one of those things where if we put
23 everybody on city water and you are the only well
24 that's pumping in the whole area, --
25 *******
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56
5 * 0139
1 MR. GADDIS:
2 That could pull it to it.
3 MS. BENNETT:
4 Yeah. But, like I said, now, our toxicologists
5 have said that the volatiles don't uptake into the
6 vegetables and things, but, then, you would be spraying
7 that water and volatiles would be in the air.
8 MR. GADDIS:
9 You know, when I used to water my garden and yard,
10 you know, with my well water, it grows beautiful, but
11 this city water I got, it dies.
12 MS. BENNETT:
13 Well, I don't know. I mean, you were one of the
14 people I had in mind when we talked about doing the
15 wellhead treatment and putting the carbon on the wells
16 and everything.
17 MR. GADDIS:
18 Yes; uh-huh.
19 MS. BENNETT:
20 So I don't know if you want to look at maintaining
21 a filter or if you can find somebody to keep it in
22 operation.
23 (Inaudible comments from the audience.)
24 MR. GADDIS:
25 You can buy a lot of city water for that.
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57
5 9
QUO
1 MR. PERKINS:
2 George Perkins again/ the representative from
3 Centerview. Last year they came down and asked
4 permission — I assume it was the EPA —- came down and
5 asked permission to dig two wells on our church
6 property, on some property that we had — not adjoining
7 the church property, but the church owns across the
8 street over there on Centerview Street and they dug two
9 wells and they told me that they would send me a copy
10 or a report of what they found, but they never did.
11 Can you tell me how deep they went and the
12 findings they found and —
13 MS. BENNETT:
14 I surely could. Come up to me and talk to me
15 after this.
16 MR. PERKINS:
17 Okay.
18 MS. BENNETT:
19 All right. We sent out letters, though.
20 MR. PERKINS:
21 We didn't get one, to my knowledge. If we did, it
22 didn't get to my hands. I'm not saying we didn't get
23 one. I'm saying I didn't get it.
24 MS. BENNETT:
25 Okay.
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58
59 0141
1 MR. BLACKWELL:
2 They dug a well here ~ this is Gene Blackwell.
3 They dug a well here on the school property back about
4 four or five years ago. What was the result? What did
5 they find?
6 MS. BENNETT:
7 They dug a well on —
8 MR. BLACKWELL:
9 They drilled a well; they drilled a well.
10 MS. BENNETT:
11 It was one well drilled on the school property and
12 it was a deep well —
13 MR. BLACKWELL:
14 Yes.
15 MS. BENNETT:
16 — and contamination was not found in it.
17 MS. BARRETT:
18 Any other questions?
19 MS. BENNETT:
20 Well, I want to emphasize, like I said, we would
21 like for all people to be connected to city water who
22 are not currently connected to it, and in that regard,
23 that well survey that we have is really important.
24 We'll be coming back around and doing another one to
25 update that, but, like, we have a lot of them that are
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59
5 9 O'l 42
1 unknown, you know, or some that say they're on city
2 water which may not be on city water and so if somebody
3 comes around and asks you, please make sure that you
4 respond so we'll know exactly who needs to be
5 connected.
6 MS. TOMSON:
7 Jolee Tomson. Is your proposal that you're going
8 to —• be based on our comments tonight totally or who
9 will make the final decision on what proposal that gets
10 chosen?
11 MS. BENNETT:
12 Hell, EPA, jointly with the State, makes the
13 final, but we always present it to the public. We
14 don't want to shove anything down anybody's throat, so
15 any comments that people have, we'll definitely listen
16 to them.
17 MS. TOMSON:
18 Hell, I say clean it up whatever the cost.
19 MS. BARRETT:
20 And not just tonight 'cause there's a comment
21 period which ends September the 12th, so you can write
22 your comments in.
23 MR. PERKINS:
24 So what you're eaying is we won't know until
25 September the 12th what you plan to do up there?
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60
59 0143
1 MS. BENNETT:
2 No; it'll be after that. That's when the comment
3 period closes.
4 MR. PERKINS:
5 Okay. That's — okay. And how long after the
6 12th will we know what you decide — what you have
7 decided to do?
8 MS. BENNETT:
9 It'll be about a month or so after that and Diane
10 usually puts out another fact sheet that says what the
11 final or what we call the Record of Decision was that
12 has been signed by an official EPA which will give our
13 position (inaudible)
14 MS. BARRETT:
15 Uh-huh.
16 MR. PERKINS:
17 And every resident and every business and every
18 church will get a copy or a notification of what you
19 plan to do?
20 MS. BARRETT:
21 Who is on the mailing list will get a copy, —•
22 MR. PERKINS:
23 Okay.
24 MS. BARRETT:
25 — but I will also put a notice in the paper. I
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61
59 0144
1 don't know if y'all saw the ads I put in the paper --
2 (Affirmative comments from the audience.)
3 MS. BARRETT:
4 Okay. Okay. So that's one — another way. I put
5 it in the paper also.
6 MR. BROOME:
7 - Why does it take so long to get going?
8 MS. BARRETT:
9 Well, —
10 UNIDENTIFIED SPEAKER:
11 Bureaucracy.
12 MS. BARRETT:
13 — you got to draw up all kinds of plans. It's
14 just like when you're going to build a building, if
15 you're going to build a house, you've got to have all
16 kinds of blueprints, you got to — you know, you got to
17 account for your — your foundation, concrete, pipes,
18 wires, everything that's involved.
19 (Inaudible comments from the audience.)
20 MR. BROOME:
21 Well, I guess what I'm trying to say is, you know,
22 there ain't no (inaudible) been found in all these
23 years and they're still getting in here?
24 MS. BENNETT:
25 Well, what the — the main thing on this site is
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62
59 0145
1 the National Priorities List. I mean, if we had a
2 responsible party who was ready to gear up and go with
3 this, we could go ahead and the very first thing we'd
4 do is get everybody on city water. But because this
5 money is coining through, you know, government, through
6 the Super fund, then it has to be on the National
7 Priorities List. That takes time and then after that,
8 we can start.
9 MS. BARRETT:
10 Hell, one thing, too, EPA was just brought into
11 this situation in 1995, so we just really started.
12 MR. BROOME:
13 Okay.
14 MR. BLACXWELL:
15 The EPA checked the well, now, at the church much
16 earlier than that.
17 MS. BENNETT:
18 Hell, the emergency people came out in '91; right.
19 MS. BARRETT:
20 Yeah. The emergency response team —
21 MR. BLACKWELL:
22 You said the well they drilled on the school
23 property was deep. What do you mean by deep? Bow deep
24 was the well?
25 ********
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63
59 OU6
1 MS. BENNETT:
2 it went into the bedrock. I show the bedrock
3 varies anywhere between thirty-five to over 100 feet
4 deep.
5 MS. BARRETT:
6 We've gone from the surface down.
7 MR. BIACKWELL:
8 . But you don't know how deep they went?
9 MS. BARRETT:
10 I — I don't know. There should — there's a
11 record, somewhere. Doc, do you have any idea how deep
12 the school well was?
13 MR. THOMPSON:
14 (Nods head affirmatively)
15 MS. BARRETT:
16 You're shaking your head yes. How --
17 MR. THOMPSON:
18 I'm Doc Thompson, Gaston County Health Department.
19 We — there is a record of the wells in the reports. I
20 don't have any idea how deep the well is. I do know,
21 like you said, it's a deep well. When they refer to
22 deep wells, they refer to alleged bedrock. Any time
23 you go into bedrock, it's referred to as a deep well
24 When you refer to a surface well, that's a sample, like
25 a bored well, which is a very shallow well, but you
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64
59 0147
1 don't extend into the bedrock, so that's what we mean
2 by a deep well, is that it was extended to the level of
3 bedrock, whether it's thirty-five feet or whether it's
4 500 feet. That's considered what we call a deep well
5 because they extend past the sapolite area into the
6 bedrock area.
7 MS. BARRETT:
8 But there are records that would show the depth.
9 We just, off the top of our heads, don't know.
10 UNIDENTIFIED SPEAKER:
11 Well, I had a bored well that was about seventy
12 feet deep. It didn't go into the rocks.
13 UNIDENTIFIED SPEAKER:
14 That's right. It was a bored well. You can't
15 penetrate rock with no bore.
16 UNIDENTIFIED SPEAKER:
17 Well, they went down a 100 foot in theirs — in
18 mine and 225 foot and it's bedrock.
19 MS. BARRETT:
20 Did you have a question? You have raised your —
21 UNIDENTIFIED SPEAKER:
22 I'm going to catch you after the meeting with mine
23 'cause it's — I don't want to take up all these
24 people's time.
25 ********
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65
59 GU8
1 MS. BARRETT:
2 Any other questions? Good questions. Good
3 questions.
4 MS. BENNETT:
5 We appreciate the turnout.
6 MS. BARRETT:
7 It's really good.
8 MS. BENNETT:
9 Like I said, we would like to hear from you. All
10 of these will be recorded. It will then — we will
11 then prepare a — prepare a responsiveness summary that
12 has all of your comments into it. In it we will have
13 responses to those comments.
14 MS. BARRETT:
15 And it will all be put in the repository.
16 UNIDENTIFIED SPEAKER:
17 I was just starting to ask. All of this
18 information is at the library?
19 MS. BARRETT:
20 That we're talking about tonight, yes, ma'am, it
21 is. It's — when you go in the Belmont branch, when
22 you walk in the door there beside the desk, it's
23 straight back on the top shelf on the — a wall. It's
24 about seven volumes and they're three-ring, white
25 notebooks, but they're there.
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66
5 9 0149
1 MS. BENNETT:
2 Hell, we'll be around after the meeting if you
3 want to come up and speak with us or ask any questions.
4 MS. BARRETT:
5 Thank you very much and good night.
6 (WHEREUPON, the meeting was concluded at 8:25 P.M.)
7
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12
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STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
5 9
67
CTI50
I, Muriel A. Marcus, Notary Public, do hereby
certify that the aforesaid meeting was taken by me and
transcribed under my supervision and that the foregoing
sixty-six (66) pages constitute a verbatim transcription of
the proceeding conducted herein. I do further certify that
the persons were present as stated.
I do further certify 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, financial or otherwise,
in the result thereof.
IN WITNESS WHEREOF, I have hereunto
subscribed my name, this 29th day of August, 1997.
Muriel A. Marcus"* - :
Notary Public
My Commission Expires:
June 16, 2002
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.
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5 9 0151
APPENDIX C
STATE CONCURRENCE LETTER
North Belmont PCE Site
Record of Decision
North Belmont, Gaston County, NC
September. 1997
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59 0 'I 5 2
State of North Carolina
Department of Environment,
Health, and Natural Resources
Division of Waste Management
James B. Hunt. Jr.. Governor
Wayne McDevitt, Secretary
William L Meyer, Director
September 19, 1997
Ms. Giezelle Bennett
Superfiind Branch, Waste Management Division
US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
RE: Conditional State Concurrence with the
September 1997 Record of Decision
North Belmont PCE Site
North Belmont, Gaston County, NC
Dear Ms. Bennett
\
The North Carolina Superfund Section has received and reviewed the attached Record of
Decision (ROD) for the North Belmont PCE Site and concurs with the selected remedy subject to
the following conditions:
1. Our concurrence on this ROD and of the selected remedies for the site is based solely
on the information contained in the attached ROD and to the conditions listed here.
Should we receive additional information that significantly affects the conclusions or
remedies contained in the ROD, we may modify or withdraw this concurrence with
written notice to EPA Region IV.
2. Our concurrence on this ROD in no way binds the State to concur in future decisions
or commits the State to participate, financially or otherwise, in the cleanup of the Site.
The State reserves the right to review, comment, and make independent assessments
of all future work relating to this Site.
P.O. Box 29603, Raleigh, North CoroBno 27611-9603 Telephone 919-733-4996 FAX 919-715-3605
An tquol Opportunity Afftn>ull»» Acflon Employ* SOU R*cydad/ 10*P
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59 0153
Ms. Giezelle Bennett
September 19, 1997
Page 2
3. If, after remediation is complete, the total residual risk level exceeds 10"6, the State may
require deed recordation/restriction to document the presence of residual contamination
and possibly limit future use of the property as specified in NCGS 130A-310.8.
4. A typographical error was found in the first sentence of paragraph 4 of page 12-1
of the ROD and should be corrected as follows: "Therefore, the remedy will include
installation and monitoring of the carbon unit for one (1) year with a replacement unit
to be installed at the end of the first year."
We appreciate the opportunity to comment on this document and look forward to continuing
to work with the EPA to remediate this Site.
Site Evaluation and Removal Branch
Superfund Section
Attachment
cc: Philip Vorsatz
Jack Butler w/o attachment
G. Doug Rumford w/o attachment
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