United States
       Environmental Protection
       Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R04-90/078
August 1990
EPA   Superf und
       Record of Decision:
       Bypass 601 Ground water
       Contamination, NC

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50872-101
REPORT DOCUMENTATION i. REPORT NO. 2
PAGE EPA/ROD/R04-90/078
4. Tin* ind Subtitle
SUPERFUND RECORD OF DECISION
Bypass 601 Groundwater Contamination, NC
First Remedial Action
7. Author(i)
». Performing Organization Name and Address
12. Sponsoring Organization Nama and Addreu
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipients Acceaalon No.
5. Report Date
08/31/90
6.-
8. Performing Organization Rept No.
10. Pro|ect/Taak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
 15. Supplementary Note*
 1C. Abstract (Limit: 200 words)

   The Bypass 601 Groundwater Contamination site,  is in Concord, Cabarrus County, North
   Carolina.  One of  the  potential sources of  onsite contamination  is  the -13-acre Martin
   Scrap Recycling Facility (MSR)  facility, an inactive battery salvage  and recycling
   operation.  Ground water at the site has also  been found to be contaminated with heavy
   metals by several  unknown sources.  The MRS Facility consists of  two  tracts of land;
   the larger tract includes a main facility that  was used for lead  reclamation
   activities; and the  second lot encompasses  the  floodplain area.   The  immediate area
   surrounding the MSR  Facility is commercial,  light industrial and  residential with
   1,400 persons residing within a 3-mile radius  of the site.  The Main  Facility is
   comprised of several lead-contaminated buildings including a scale  house,  several
   garages and sheds, as  a result of onsite battery cracking operations.   Contaminated
   debris including old tanks, drums, wires, casings, and trash is  spread throughout the
   Main Facility area.  The southeastern corner of the Main Facility has  been backfilled
   with cracked battery casings to a depth of  20  feet.  Approximately  57,000 cubic yards
   of lead-contaminated soil remains onsite from  previous battery salvage activities.  A
   1984 EPA site investigation found high levels  of metals in nearby wells.   This Record

   (See Attached Page)
 17. Document Analysis a. Descriptors
    Record of Decision  -  Bypass 601 Groundwater  Contamination, NC
    First Remedial Action
    Contaminated Media: soil,  debris
    Key Contaminants:   metals  (chromium, lead)

   b. Identifiers/Open-Ended Terms
   c. COSAT1 Field/Group
18. Availabilty Statement
19. Security Claaa (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
56
22. Pries
(See ANSI-Z39.18)
                                     See /nafructfona on Reverse
OPTIONAL rOHM Z7Z (4-77)
(Formerly NT1S-3S)
Department of Commerce

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EPA/ROD/R04-90/078
Bypass 601 Groundwater Contamination,  NC
First Remedial Action

Abstract (Continued)

of Decision (ROD)  addresses Operable Unit 1 (OU1),  which will contain the source
contamination from the MSR facility to minimize the continued degradation of ground
water and surface water.  Subsequent RODs will address the final action and remediation
of other onsite contaminant sources (OU2) and ground water contamination  (OU3).  The
primary contaminants of concern affecting the soil and debris are metals including
chromium and lead.

The selected remedial action for this site is an interim action, which includes
demolishing and disposing of debris from four onsite buildings; excavating and
consolidating the contaminated surface soil;  regrading the site, -covering with area
with 6 inches of clean fill, covering the soil with a HPDE liner, with 18 inches of
drainage soil and 6 additional inches of clean topsoil; revegetating the area;
backfilling excavated areas, realigning an adjacent stream to minimize the erosion of
the cap;  maintaining the soil cover; and enacting public awareness programs; and
implementing institutional controls including deed restrictions and site access
restrictions including fencing.  The present  worth cost for this remedial action is
$738,821, which includes an annual O&M cost of $9,700.

PERFORMANCE STANDARDS OR GOALS:  Soil contaminated with lead will be remediated to 500
mg/kg (EPA Interim Guidance).

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               Declaration  for the  Record of Decision
                        First Operable Unit
Site Name and Location

Bypass 601 Groundwater Contamination Site (Martin Scrap Recycling
Facility), Concord, North Carolina.
Statement of Basis and Purpose

This decision document presents the selected remedial action for the
Bypass 601 Groundwater Contamination Site (Martin Scrap Recycling
Facility), in Concord, North Carolina, which was chosen in accordance
with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to the
extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP).

The State of North Carolina concurs with the selected remedy.  The
information supporting this remedial action decision is contained in the
administrative record for this site.
Assessment of the Site

Actual or threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in this
Record of Decision (ROD), may present an imminent and substantial threat
to public health, welfare, or the environment.
Description of the Selected Remedy

This interim action operable unit is the first of three that are planned
for the site.  The first operable unit will address soil remediation at
the Martin Scrap Recycling Facility portion of the site.  This
alternative will address the source of contamination by excavating, and
consolidating the soils in a single location and installing a cover to
prevent human and environmental exposure to the contaminants, and to
minimize the generation of contaminated leachate entering the
groundwater environment.

While the remedy does address one of the principal threats at the site,
the second operable unit will involve continued study and possible
remediation of other sources of contamination, and the third operable
unit will address the groundwater contamination.

The major components of the selected remedy for the first operable unit
interim action include the following:

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                                -2-

— Demolish and dispose of four buildings.

— Consolidate contaminated surface soil into one area of contamination,
   regrade site, cover with 6 inches of clean fill, HDPE liner,  18
   inches of drainage layer, and 6 inches of clean topsoil, revegetate.

— Backfill areas where surface soil were excavated.

— Install perimeter fence at property boundary.

— Bi-annual maintenance of cover until final action.

— Institute deed restrictions on property.

   Conduct public awareness programs to inform public of hazards
   associated with the site.
— Conduct five-year reviews of the site conditions.


Declaration of Statutory Determinations

The interim action is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable
or relevant and appropriate directly associated with this action.  This
action utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this site, given the
limited scope of the action.  Because this action does not constitute
the final remedy for the site or operable unit, the statutory preference
for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element will be addressed by the final action.
Subsequent actions are planned to address fully the principal threats
posed by conditions at this operable unit.

Because this remedy will result in hazardous substances remaining
on-site, a review will be conducted within five years after commencement
of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
     n
                                              AUG
 reer C. Tidwell                       Date
Regional Administrator

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                               TABLE OP CONTENTS



1.0      Introduction  	      1

2.0      Site Name, Location and Description	      1

2.1      Area Land Use	      4
                           I
2.2      Surface Water 	      4

2.3      Groundwater	      5

3.0      Site History and Enforcement Activities  ....      5

4.0      Highlights of Community Participation 	      7

5.0      Scope and Role of Operable Unit	      7

6.0      Summary of Site Characteristics 	      8

6.1      Contaminant Source Investigation	      8

6.2      Groundwater	     13

6.3      Surface Water and Surface Sediment 	     15

6.4      Air Investigation	     19

6.5      Contaminant Fate and Transport	     19

7.0      Summary of Site Risks	     20

7.1      Selection of Indicator Chemicals	     22

7.2      Exposure Assessment Summary  	     23

7.3      Toxicity Assessment 	     24

7.4      Potential Carcinogenic and Noncarcinogenic
              Contaminants	     24

7.4-1    Noncarcinogenic	 .    24

7.4-2    Environmental Risks 	     25

8.0      Remedial Action Objectives and General
              Response Actions	     25

8.1      Site Remedial Action Objectives 	     25

8.2      Soils	     26

8.3      Volume of Lead Contaminated Soil	     26

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                            Table of Contents Cont'd.


 8.4      Cleanup Levels for Soils	                26

 9.0      Description of Alternatives	     27

 9.1      Overall Objectives  	     27

 9.2      Alternative 1, No Action	     27

 9.3      Alternative 2, Excavation, Consolidation and
               Capping	     27

 9.4      Alternative 3, In-situ-Solidification	     35

 9.5      Alternative 4, Excavation, On-site Treatment
               and Disposal	     38

 9.6      Alternative 5, Excavation, Off-site Treatment
               and Disposal	     39

10.0      Summary of Comparative Analysis of Alternatives.   .     39

11.0      Selection of Remedy	     40

12.0      Statutory Requirements	     40

12.1      Protective of Health and the Environment ....     40

12.2      Attainment of the Applicable or Relevant and
               Appropriate Requirements	     40

12.2-1    Contaminant - Specific ARARS 	     40

12.2-2    Location - Specific ARARS 	     42

12.2-3    Action - Specific	*.        42

12.2-4    To Be Considered Criteria 	     42

12.2-5    ARAR Attainment  	     42

12.3      Cost Effectiveness	     42

12.4      Utilization of Permanent Solutions and Alter-
               native Treatment Technology or Resource
               Recovery Technologies to the Maximum
               Extent Practicable	     43

13.0      Occupational Exposures	     43

14.0      Populations at Risk	     43

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                                 List of Figures
Figure  1

Figure  2

Figure  3

Figure  4

Figure  5

Figure  6


Figure  7


Figure  8

Figure  9


Figure 10


Figure 11


Figure 12



Figure 13


Figure 14

Figure 15

Figure 16

Figure 17

Figure 18

Figure 19

Figure 20
Vicinity Map   	

Site Location Map 	

Surface Soils Sampling Location Map .

Monitor Well and Soil Boring Location Map

Groundwater Sample Location Map

Offsite Surface Water and Sediment
Sampling Location 	
Toxicity Constants for Noncarcinogenic
Compounds	
Summary of Soil Lead Action Levels

Horizontal Extent of Lead - Contaminated
Soils (>500 mg/kg) in the 0-1'Internval).

Horizontal Extent of Lead - Contaminated
Soils (>500 mg/kg) in the l'-5'Internval)

Horizontal Extent of Lead - Contaminated
Soils (>500 mg/kg) in the 5'-15'Internval)
 2

 3

10

12

16


20
28
29
30
31
Horizontal Extent of Lead - Contaminated
Soils  (>500 mg/kg) at Depths Greater than
15'	32

Calculation of Soil Volumes Contaminated
with Lead in Excess of 500 mg/kg	33

Alternative 2 - Capping	36

Alternative 2 - Capping	37

Excavation, On-Site   	   41

Cost Estimates for Remedial Alternatives.  .  .   43

Chemical Specific ARARs, TCBs  	   46

Chemical Specific ARARs, TCBs  	   47

Dose - Response Effects of
Lead Adsorption in Children    	48

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           Record of Decision




     Remedial Alternative Selection
Bypass 601 Groundwater Contamination Site




     Martin Scrap Recycling Facility




     Soil  Remediation  Operable Unit  I




         Concord, North Carolina
              Prepared by:




  U.S. Environmental Protection Agency




                Region IV




            Atlanta, Georgia

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                               Record of Decision
                               First Operable Unit
                              The Decision Summary
                    Bypass 601 Groundwater Contamination Site
                        (Martin Scrap Recycling Facility)
                             Concord, North Carolina
1.0    Introduction

       The Bypass 601 Groundwater Contamination Site,  (Martin Scrap Recycling
       Facility)  was proposed for inclusion on the National Priorities List
       (NPL) in October 1984, and finalized in June 1986.   The Remedial
       Investigation report,  which examines air, sediment,  soil,  surface water
       and groundwater contamination was completed in April 1990.  The
       Feasibility Study report, which develops and examines alternatives for
       remediation of the site, was issued in final form to the public on May
       7, 1990.

2.0    Site Name. Location and Description

       The Bypass 601 Groundwater Contamination site is defined as an area in
       Concord, North Carolina in which groundwater is contaminated by multiple
       unknown sources.  The Martin Scrap Recycling Facility is an inactive
       battery salvage and recycling operation just west of Concord, North
       Carolina (Figure 1).  The Martin Scrap Recycling Facility occupies
       approximately 13 acres of land in Cabarrus County and was identified as
       a potential source of the groundwater contamination.  U.S. Highway
       29/Route 601 Bypass borders the site on the west and provides access to
       the cities of Kannapolis, approximately 6 miles north, and Charlotte,
       approximately 21 miles southwest of the site, (Figure 2).   The 13-acre
       property is bordered by private commercial property (a flea market and a
       landfill)  on the north; to the east by Irish Buffalo Creek, a tributary
       of the Pee Dee Yadkin River; and an unnamed tributary of the Buffalo
       Creek to the south.  Residences are located south and west of the MSR
       facility.

       The MSR Facility consists of two tracts of land.  One lot, where the
       Main Facility is located, covers 2.92 acres.  .The second lot, which
       encompasses the Flood Plain area, covers 9.75 acres.

       The Main Facility, which consists of the smaller of the two lots, is
       where the Lead reclamation activities occurred.  This area consists of
       several buildings, including a main office building, a scale house,
       several garages and sheds, and an octagonal shed in which the battery
       cracking operations were primarily conducted.

       Most of the Main Facility area has been covered with asphalt, although
       some grassy areas still remain.  Debris such as old tanks, drums, wires,
       casings, and trash is spread throughout the main facility area.  The
       southeastern corner of the Main Facility has been backfilled with
       cracked battery castings.  When viewing the exposed portions of the
       slope separating the Main Facility from the Flood Plain area, it appears
       that the backfill has been deposited up to depths of 20 feet.

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    N
                                                 V.ARTIN'S SCRAP  RECYCl S3
SOURCE  CABANMUS COUNTY
	 N.C. 06PT. 0* TRANSPORTATION
                                                             MARTIN S SCS A?

                                                             RECYCLING
                             VICINITY MAP
                        BY PASS  601  / MSR SITE

                         C3NCOO  SOUTH CA»OL:VA
                                                                        FICLRE s

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Sir***

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                                       -4-

       An asphalt road, which winds down the slope and becomes a dirt road in
       the Flood Plain area, connects the Main Facility to- the Flood Plain
       area.

2.1    Area Land Use

       The immediate area around the MSR Facility is primarily commercial and
       light industrial with local residential neighborhoods nearby.  It is
       estimated that more than 1400 persons reside within a 3-mile radius of
       the MSR Facility.  It is also estimated that the entire population in
       the vicinity obtains its potable water supply from either public water
       supply wells or from private wells.  The closest residences are located
       on the northern side of Sumner Drive, immediately adjacent to the
       southern property line of the MSR Facility.

       Industries in the area include sand and gravel operations, private
       landfill operations, and manufacturing related to the textile industry.
       Commercial operations include convenience food stores and gas stations,
       auto part sales and repair shops, office supply stores, retail shopping
       centers, fast food restaurants and mobile home sales operations.
       Residential neighborhoods surround the light industrial/commercial areas
       which line the main roads within a three-mile radius of the MSR
       Facility.

2.2    Surface Water

       The entire province, and more specifically, the Concord, North Carolina
       area, consists mainly of rolling hills cut by many streams which usually
       originate in the mountains to the west.

       The Bypass 601 site, including the MSR Facility is located within the
       Rocky River drainage area, which includes Irish Buffalo Creek.  This
       creek, which forms the eastern facility boundary, is a tributary of the
       Pee Dee Yadkin River Basin, which includes a major North Carolina/South
       Carolina river that flows southeast toward the Atlantic Ocean.
       Generally, drainage is to the southeast because of the
       northwest-southeast orientation of the stream valleys which are
       controlled by the underlying bedrock  (Lefler, 1969).

       The MSR Facility is bounded on the west by State Route 29  (Bypass 601).
       The road bed has been artificially elevated with fill to create a
       "bridge" between two hills, one of which appears to have been later
       leveled for construction of the MSR Facility.  This artificial ridge
       caused by the highway directs surface water towards the MSR Facility.

       MSR Facilities have been constructed on fill materials.  Additional
       fill, which includes battery chips produced by the MSR operations, was
       added to the eastern edge of the Main Facility area to create an
       artificial surface.

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                                       -5-

       The Main Facility area slopes sharply from State Route 29 towards Irish
       Buffalo Creek at a slope of approximately 3.0-4.0 percent.  Along the
       floodplain, the land surface slopes toward Irish Buffalo Creek at a
       slope of approximately 2 percent.  The two separate portions of the MSR
       Facility are separated by a steep, approximately 22-foot embankment.

2.3    Groundwater

       Groundwater in the Piedmont Physiographic Region occurs in two zones.
       The saturated saprolite zone is the uppermost aquifer and is generally
       referred to as the water table or shallow aquifer (Moore, Gardner and
       Associates, April 1982).  Water is usually readily found between the
       pore spaces of the soil.  The soil acts as a reservoir to store water
       and is influenced strongly by climatic changes.  The other zone of
       groundwater occurrence is in the fractures and secondary openings in the
       underlying bedrock.  Water in this zone moves along the fractures as if
       they were pipelines.  Thus, water can be transmitted effectively over
       large distances by this "pipeline" network if the fractures and cracks
       are connected or overlap.  It appears that the two systems are
       hydraulically connected with the saprolite transmitting water to the
       underlying rock.  This would allow for contaminant movement over fairly
       large areas if the contaminants are transmitted to the bedrock.

       Reportedly, all residents in the immediate site area west of State Route
       29 and Bypass 601 use well water due to a lack of a major municipal
       drinking water supply system serving the area generally west of Irish
       Buffalo Creek.  In 1987, the City of Concord indicated that since
       mid-1985, the area west of State Route 29 and Bypass 601 is served by
       the County of Cabarrus water system.  Investigations confirmed that in
       the area outside the city limits of Concord, practically all domestic
       water supplies are currently obtained from wells.  Although some dug
       wells exist in rural areas, which obtain water from the weathered
       material/water table aquifer, it is believed that the vast majority, if
       not all, of wells in the vicinity of the site are drilled to tap
       fractures within the bedrock.  The average well depth in this area is
       approximately 186 feet below land surface (LeGrand, 1952).

       Data from the U.S.G.S. indicate that the general well yields in the
       Charlotte-Concord area are from 0 to 400 gpm, while the average yield
       ranges from 20-40 gpm.  The information from the above noted sources
       appear generally to agree and provide an adequate overview of
       groundwater well yields in the vicinity of the site.  According to
       information from the report by LeGrand and Mundorff (1952), yields from
       wells in the vicinity of the site can be as high as an average of 23
       gallons per minute with wells yields ranging from 0-150 gpm.

3.0    Site History and Enforcement Activities

       Early in 1981, MSR was cited for various Occupational Safety and Health
       Administration (OSHA) violations, the most serious one involved employee
       exposures to lead in the work place.  MSR was fined $13,000 for the OSHA
       violations.

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                                -6-

In August and September 1981 inspections of the MSR facility were
carried out by the State of North Carolina Division of Environmental
Management  (DEM) and the Division of Health Services (DHS),
respectively.  While DEM did not find evidence of air or water
contamination, the investigation conducted by DHS discovered 15
violations under the Resource Conservation and Recovery Act (RCRA).   On
February 24, 1982, DHS conducted a follow-up inspection of the MSR
facility.  By this time, MSR claimed to be selling all hazardous
by-products of the battery recycling operation.  MSR had discontinued
disposal of battery acid into the lagoon, which was filled with sediment
and sludge, and began storing the battery acid in steel holding tanks
until the acid was recycled or sold.  Additionally, MSR removed and sold
two to six inches of topsoil from around the plant operations buildings.

In October 1984, MSR was ranked on the National Priorities List (NPL), a
list of hazardous waste sites across the country eligible to receive
Federal Superfund monies for clean up.  In June, EPA Region IV and the
State of North Carolina conducted a joint inspection of the MSR
facility.  Water samples taken from the unnamed stream showed high
levels of contamination by heavy metals.

Throughout 1983 and 1984, DEM and DHS continued sampling of surface
water and sediment from areas surrounding the MSR facility.  Sediment
samples taken from the Irish Buffalo Creek approximately five miles
downstream from the facility showed elevated levels of arsenic, cadmium,
chromium, mercury, nickel, lead and zinc.  Water samples taken from the
Iris Buffalo Creek showed the presence of lead in water 2,500 feet
upstream of the facility and higher concentrations downstream of the
facility.  DEM and DHS were not able to conclude, however, that the MSR
facility was having an effect on off-site portions of the creek.
Samples collected from three groundwater monitoring wells located on the
MSR property indicated the presence of arsenic, cadmium, and lead at
levels exceeding Federal standards.

EPA completed a site investigation report for the MSR facility portion
of the Bypass 601 site in late summer 1984.  EPA sampling of monitoring
wells, private wells, surface water and sediment, both on and off site,
detected lead, arsenic, cadmium, and chromium at levels high enough to
be a threat to public health and the environment.

The Bypass 601 site was formally proposed for inclusion on the NPL in
October 1984, even though MSR was determined to be in full compliance
with State RCRA requirements.  However, additional site visits and data
gathering conducted in 1985 by EPA and the State identified further
areas where MSR was not in compliance with regulations.  The site was
finalized on the NPL in June 1986, with a Hazard Ranking System (HRS)
score of 37.93.  In July 1986, MSR filed a petition for bankruptcy.

In the spring of 1987, EPA began planning for a Remedial Investigation
(RI) of the Bypass 601 site.  An RI/FS Work Plan was developed to
address gaps in existing data which are required to determine the nature
and extent of contamination.  A field investigation was implemented from
April 27 to September 1, 1989, and the final RI report was completed in
April 1990.

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                                       -7-

       The Rl field inveatigation included surface and subsurface soil
       investigations, groundwater quality investigations,'and surface water
       and sediment investigations.  A total of 96 surface soil samples were
       collected at 48 locations.  Another 167 subsurface soil samples were
       also collected from soil borings and monitor well installations.  Of the
       numerous compounds detected, the inorganic compounds were present in the
       greatest concentrations and frequencies.  At least 9 other potential
       contaminant sources separate from the MSR facility were identified in
       the Bypass 601 area.

       The RI reported gross metal contamination of soils throughout the MSR
       facility.  The volume of soils contaminated with lead in excess of 500
       milligrams/kilogram (mg/kg) was estimated to be approximately 57,000
       cubic yards (CY).   The existing contamination is continuing to spread
       throughout the soils, surface water, stream sediments and groundwater
       regimes.  The contaminated soils and buried battery casings are
       continuing to load the groundwater with contaminants.

4.0    Community Relations

       The RI/FS and proposed plan for the MSR facility were released to the
       public in May 1990.  These documents were made available to the public
       in the administrative record and in the information repository
       maintained at Charles A. Cannon Memorial Library, 27 Union Street North,
       Concord, North Carolina.  The notice of availability was published in
       the Concord Tribune.  The public comment period was held from May 10 to
       July 11, 1990.  A public meeting was held on May 17, 1990, to present
       the remedial alternatives for the site.  During the meeting, EPA, DHR,
       DHS, and representatives from Hunter/ESS (the RI/FS consultant)
       presented the results of the RI/FS.  DHR and EPA presented the proposed
       plan and answered questions about problems at the site and the remedial
       alternatives under consideration.  A response to comments received
       during the public comment period is included in the Responsiveness
       Summary, which is part of the ROD.  A transcript of the public meeting
       is available for review in the repositories.

5.0    Scope and Role of Operable Unit

       As with many superfund sites, the problems at the Bypass 601 Groundwater
       Contamination Site, Martin Scrap Recycling Facility, are complex.  As a
       result, the work has been divided into units or phases, referred to as
       "operable units".   The operable units (OUs) at this site are:

          OO One:   Addresses soil contamination at the Martin Scrap Recycling
                    Facility (interim containment followed by final action OU).

          OU Two:   Intensive study and possible remediation of other sources
                    of contamination.

          OU Three: Addresses groundwater contamination at the Bypass 601
                    Groundwater Contamination Site.

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                                       -8-

       The first: operable unit will address soil remediation at the Martin
       Scrap Recycling Facility portion of the site.  This "alternative will
       address the source contamination by excavating and consolidating the
       soils into one area of contamination and installing a cover to prevent
       human and environmental exposure to the contaminants, and to minimize
       the generation of contaminated leachate entering the groundwater
       environment in the interim until a complete assessment of the multiple
       sources and the site can be addressed.

       The second operable unit will involve an intensive study of additional
       potential sources of contamination around the MSR Facility and the
       Bypass 601 area.

       The third operable unit will address the groundwater contamination.

       The interim action will be consistent with any planned future actions,
       to the extent possible.

6.0    Summary of Site Characteristics

       The RI at the MSR site was designed to determine the extent of
       contamination at the site, to determine potential impacts of the
       contaminants on human health and the environment, and to develop data
       needed for an engineering evaluation of further remedial actions.

       Earlier studies at the site had found on-site areas of soil, sediment,
       and groundwater contamination.  The RI expanded the search for
       contaminants to off-site areas, and also re-examined areas previously
       excavated and covered with asphalt to determine residual contaminant
       levels in the soils.  The RI was designed to identify and quantify
       metals and organic chemical contamination in the groundwater, in surface
       and subsurface soils on the MSR Facility, and in surface water and
       sediments along the unnamed stream and Irish Buffalo Creek.  In
       addition, the RI provided geologic and hydrogeologic characterizations
       for the MSR property, limited investigations of private wells and their
       water quality, and a survey of other potential sources which could act
       as contaminant sources for the Bypass 601 Groundwater Contamination
       Site.

       The RI was a comprehensive assessment of site conditions that included
       additional characterization of site hydrogeology, new site mapping by
       aerial surveys, completion of additional magnetometer surveys, air
       sampling and soil test borings, and sampling of streams and wells
       off-site.

       The investigation of the MSR site was conducted during the period from
       April 27, 1989, through September 1, 1989.

6.1    Contaminant Source Investigation

       A total of 96 surface soil samples were collected at 48 locations
       (Figure 3).  Another 167 subsurface soil samples were also collected
       from soil borings and monitor well installations (Figure 4).  Of the

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                                -9-

numerous compounds detected in the soils, four were selected as
indicator compounds for the RI.  Selection of indicator compounds was
based on contaminant concentration, frequency of occurrence,
distribution in the environment, and potential risk to human health and
the environment.  The four compounds selected as indicator chemicals for
the MSR Facility are Lead, Chromium, Nickel and sulfate.

In the surface soils, a total of 19 organic compounds were positively
identified and an additional 35 compounds were tentatively identified by
the CLP laboratories in the 23 samples analyzed.  Of the positively
identified compounds, 14 were detected in 3 or fewer samples which had
erratic geographical distributions.

The final positively identified compound, Bis(2-ethylhexyl)-phthalate,
is a common plasticizing compound.  It was detected in 4 geographically
distant locations on the MSR Facility.  The presence of this compound is
attributed to the actual battery casing debris.

In the subsurface soils, a total of 18 organic compounds were positively
identified and an additional 17 compounds were tentatively identified by
the CLP laboratories in the 51 samples analyzed.  Of the positively
identified compounds, 8 were detected in 3 or fewer samples which had
erratic geographical distributions.

The largest suites of compounds were generally limited to 4 samples.
These samples were all collected in areas associated with buried battery
casing debris:  BP-SB-05 (14-16'), BP-SB-07 (13-15'), BP-MW-02 (8-10'),
and BP-MW-05 (28-30').

Bis(2-ethylhexyl)-phthalate was the most frequently detected extractable
organic, occurring in 8 of the 12 samples in which extractable organic
compounds were found, and all of which (except BP-MW-05) are on or along
the slope between the Main Facility and the Flood Plain.  This compound
is also a common component of plastics, and its presence at the MSR
Facility is likely to be due to the presence of battery casing chips,
although the pervasiveness and distribution cannot currently be defined.

No trends for extractable organic compounds could be established in the
surface or subsurface soils of the MSR Facility.

Several compounds detected in the surface soils were eliminated as
naturally occurring elements.  These compounds included Aluminum,
Calcium, Manganese, Mercury, Strontium, Titanium, and Yttrium.

Lead was detected in 22 of the 23 samples sent to CLP laboratories and
93 of the 96 samples analyzed by the On-site Laboratory (OSL).
Concentrations ranged from 18 mg/kg in the 0-0.5' interval at sample
location BP-SS-45 (CLP) to 110,000 mg/kg in 1.5-3.0' interval at
BP-SS-40 (OSL).

Although Lead was detected throughout the entire MSR property, the
heaviest surface soil contamination was found (BP-SS-40) in the area of
the buried battery casing debris located at the southeast corner of the

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                                -11-

Main Facility area.  Surface soil samples with Lead concentrations in
excess of 10,000 mg/kg were also detected throughout the western portion
of the Flood Plain area, more sporadically along the eastern portion of
the Flood Plain area, and throughout the Main Facility area.

Lead concentrations in excess of 1,000 mg/kg were found in all parts of
the MSR Facility.  No significant difference between the Main Facility
area and the Flood Plain area could be detected, nor could such a
difference be found to differentiate the area of the former surface
impoundment from the rest of the Flood Plain area.

Lead in subsurface soils was detected in 35 of the 51 samples sent to
CLP laboratories and in 105 of the 167 samples analyzed by the OSL.
Concentrations ranged from 2.8 mg/kg in the 23-25' interval at sample
location BP-SB-45  (CLP) to 136,000 mg/kg in 4-6' interval at BP-SB-05
(OSL).  The resultant volume of 57,719 cubic yards of soil are estimated
to be contaminated with Lead in concentration in excess of 500 mg/kg.

As with the surface soil samples, the heaviest subsurface soil
contamination was found (BP-SB-05) in the area of the buried battery
casing debris located at the southeast corner of the Main Facility area
and along the slope that separates the Main Facility area from the Flood
Plain area.  Subsurface soil samples with Lead concentrations in excess
of 10,000 mg/kg were limited primarily in areas adjacent to • this slope,
and generally at depths of 5' or less.

No significant difference between the Main Facility area and the western
Flood Plain area could be detected, but the eastern portion of the Flood
Plain area showed markedly lower concentrations of Lead in the
subsurface soils.

Nickel was detected in 34 of the 51 subsurface soil samples sent to CLP
laboratories.  Concentrations ranged from an estimated value of 2 mg/kg
in the 8-10' interval at sample location BP-MW-03 to 66 mg/kg in the
9-11' interval at BP-SB-02.  Unlike the surface soil samples, the
subsurface soil samples showed the presence of Nickel throughout the MSR
Facility, as well as in the soils collected during installation of two
monitor wells at locations off the MSR property.

Sulfates derive naturally from automotive battery cracking operations,
since suIfuric acid is an electrolyte used in such batteries.  The
mobility of sulfate in the natural environment makes it a good indicator
of potential extent to which soluble contaminants may have migrated.

Sulfate was detected in 88 of the 96 surface soil samples analyzed by
the OSL.  Concentrations ranged from 46 mg/kg in the 1.5-3.0' interval
at sample location BP-SS-20 to 10,800 mg/kg in 1.5-3.0' interval at
BP-SS-02.

The highest concentrations appear to be associated with the areas in
which battery cracking operations occurred or around the abandoned
surface impoundment area.  However, elevated sulfate concentrations were
found consistently throughout the MSR Facility.

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                                      -13-

       There appears to be no distinction between the two surface soil levels
       sampled (0-0.5'  and 1.5-3').   Concentrations of sulfate tended to be
       different by an order of magnitude between the levels,  but the 0-0.5'
       level contained the higher level  of sulfate as frequently as the 1.5-3.0
       level.

       Sulfate was detected in 121 of the 129 subsurface soil samples analyzed
       by the OSL.  Concentrations ranged from 12.3 mg/kg in the 13-15'
       interval at sample location BP-MW-05 to 20,400 mg/kg in 3.5' interval  at
       BP-SB-04.  With only a few exceptions, sulfate concentrations tended to
       generally increase with depth down to either the 8-10' interval or the
       13-15 interval,  and then gradually begin to decrease.
6.2    Groundwater
       Twenty-one temporary monitor wells and 10 permanent well clusters (each
       cluster consisting of one shallow and one deep monitor well) were
       installed during this investigation of the MSR Facility (Figure 5).
       Initial groundwater investigation activities involved installation of
       the temporary wells in the Main Facility Area and in the western portion
       of the Flood Plain area of the MSR property.

       After the temporary well installation program was completed,  placement
       locations of the permanent monitor well clusters were selected, based on
       the analytical data generated by the on-site laboratory.  Each cluster
       consisted of a shallow permanent monitor well which was installed in the
       shallow aquifer to the top of bedrock and one deep monitor well which
       was installed to a final depth of 20 feet into the fractured bedrock.

       Originally, RI/FS Work Plan specified that 9 permanent well clusters
       were to be installed — 8 clusters on the MSR Facility property and one
       background well cluster.  After the analytical results of the temporary
       well groundwater investigation were assessed, it became apparent that
       the extent of contamination had not been defined, even though temporary
       wells had been installed in all accessible areas of the MSR property.

       Cluster BP-MW/DMW-08 was installed on the opposite side (south) of the
       unnamed stream, approximately 100 feet west of Irish Buffalo Creek.
       Cluster BP-MW-/DMW-10 was installed across Irish Buffalo Creek from the
       MSR Facility on a parcel of land owned by the Concord Lace Company.
       Cluster BP-MW/DMW-09 was installed topographically and hydrogeologically
       upgradient of the MSR Facility, on a parcel of land located along
       Montford Avenue.

       It should be noted that wells BP-MW-09 and BP-DMW-09 were originally
       designed to comprise the background well cluster.  It was not possible
       to find an accessible location upgradient from the MSR Facility which
       did not contain battery-cracking debris and still remain within the same
       local drainage basin.  As a result, the upgradient well cluster was
       installed to provide information only on the upgradient groundwater
       quality and on hydrogeologic conditions, and not on background water
       quality.

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100     0      100    .'UU


    C
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                                -14-

The ground surface at each of the temporary well installation points and
the top of each permanent monitor well casing were surveyed for
horizontal location and vertical elevation.  All points were tied to
U.S. Geological Survey benchmarks located in the vicinity of the MSR
property.

Lead was detected in 17 shallow aquifer samples in concentrations which
ranged from 5 ug/L (BP-MW-06) towards the eastern end of the Flood Plain
to 2,300 ug/L (BP-TW-03 and BP-TW-05) at the western property boundary
at the top of the slope and in the area of the buried battery casing
debris, respectively.

Chromium was detected in 23 of the 29 shallow aquifer samples in
concentrations ranging from 15 ug/L (BP-EMW-03) to 1,000 ug/L
(BP-TW-03).  Chromium was detected in only two of the bedrock aquifer
samples (120 ug/L in BP-DMW-03 and 40 ug/L in BP-DWM-04), and both were
associated with high chromium concentrations in the shallow aquifer.

Sulfates were detected in all 29 shallow aquifer groundwater samples in
concentrations ranging from 24.4 ug/L in BP-TW-01 near the main entrance
to 21,000 ug/L along the Flood Plain.

A total of 12 private wells were sampled during this RI field
investigation.  All 12 samples were sent to CLP laboratories for TCL and
TAL analysis.

It should be noted that no information was available on the depths of
the private wells or on their construction details.

No extractable organic compounds were detected in the private well
samples.

A total of 9 different volatile organic compounds were detected in 7 of
the 12 private wells sampled.  Five of the 9 compounds, Trana-1,
3-Dichloropropene, Dibromochloromethane, Bromoform, Tetrachloroethene,
and an unidentified compound, were detected only once.  Two compounds,
1,1,1-Trichloroethane and Vinyl Acetate, were detected only twice.  In
the case of 1,1,1-Trichloroethane, the two wells in which it was
detected were nearly half-a-mile apart (BP-PW-08 and BP-PW-09), and were
located along different ridges.  Vinyl Acetate was detected in two
adjacent wells (BP-PW-02 and BP-PW-03), but the concentrations were very
low (3 ug/L and 1 ug/L, respectively).

On volatile organic compounds, 1,1,2-Trichloroethane, was detected in 3
wells (BP-PW-02, BP-PW-03, and BP-PW-05), but again all three locations
are on different ridges.

The final volatile organic compound, 1,1,2,2-Tetrachlorethane, was
detected in 4 wells (BP-PW-01, BP-PW-02, BP-PW-03, and BP-PW-05).

None of the volatile organic compounds, except the one unidentified
compound, were present in concentrations in excess of 5 ug/L.  Because
of the low concentrations, low frequencies of occurrence, and (in some
cases) wide separation, volatile organic compounds in private well
samples will not be discussed further.

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                                       -15-

       The only inorganic compound of concern detected in the private well
       samples was Lead, which occurred at a concentration'of 6 ug/L in three
       wells  (BP-PW-08, BP-PW-11, and BP-PW-12) all of which were separated by
       large geographical distances.  In addition, no information was available
       on well construction materials.  If Lead solder was used in any of these
       .wells, it could be the source of the detected Lead.  Until more is known
       about the well depths and their construction, it is not possible to
       discuss inorganics in these private wells.

       Only one pesticide, Heptachlor Epoxide, was detected in two wells, both
       of which were located near each other along South central Drive.  In
       both cases, the quantities detected were very low:  0.054 ug/L in
       BP-PW-02 and 0.068 ug/L in BP-PW-03.  Heptachlor Epoxide is a commonly
       used pesticide, but it is not possible to speculate on its source.
       Until more is known, this compound is eliminated from further
       discussions.

       No PCBs were detected in any of the private well samples.

       None of the private well samples were analyzed for sulfates.

6.3    Surface Water and Surface Sediment

       Surface water and stream sediment samples were collected from 11 sample
       locations during the RI field investigation sample locations (Figure 6)
       were selected as follows:

       — One background sample (BP-SW/SD-01) collected approximately 2000 feet
          west (upstream) of the Site along the unnamed stream;

       — One background sample (BP-SW/SO-02) collected from the unnamed stream
          approximately 850 feet west  (upgradient) from the abandoned MSR
          Facility;

       — One on-site sample (BP-SW/SD-03) along the unnamed stream
          approximately 1,750 feet upstream from the confluence with Irish
          Buffalo Creek;

       — One on-site sample (BP-SW/SD-04) along the unnamed stream
          approximately 1,500 feet upstream from the confluence with Irish
          Buffalo Creek;

       — One on-site sample (BP-SW/SO-05) along the unnamed stream
          approximately 1,200 feet upstream from the confluence with Irish
          Buffalo Creek;

       — One on-site sample (BP-SW/SD-06) along the unnamed stream
          approximately 725 feet upstream  from the confluence with Irish
          Buffalo Creek;

       — One sample location (BP-SW/SD-07) along Irish Buffalo Creek
          approximately 325 feet downstream from the confluence with the
          unnamed stream;

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(M

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                                -17-

— One sample location (BP-SW/SD-08)  along Irish Buffalo Creek
   approximately 200 feet downstream from the confluence with the
   unnamed stream;

— One on-site sample (BP-SW/SO-09) along the unnamed stream
   approximately 100 feet upstream from the confluence with Irish
   Buffalo Creek;

— One sample location (BP-SW/SD-10)  along Irish Buffalo Creek
   approximately 2,400 feet upstream from the confluence with the
   unnamed stream; and

— One sample location (BP-SW/SD-11)  along Irish Buffalo Creek
   approximately 1 mile upstream from the confluence with the unnamed
   stream.

All 11 surface water and all 11 sediment samples were analyzed for Lead,
Cadmium, total chromium and sulfates by the on-site laboratory.  In
addition, 2 sediment samples were sent to a laboratory for Total Cr,
Cr  , and Cr   analyses.

A total of 11 surface water and stream sediment samples were collected
along the unnamed stream and Irish Buffalo Creek during this RI field
investigation.

No volatile organic compounds were detected in any of the 11 surface
water samples.

Analysis of the surface water samples indicate that Lead was detected in
6 of the 11 samples collected, and ranged in concentration from an
estimated value of 6 ug/L (BP-SW-07)  to an estimated maximum of 56 ug/L
(BP-SW-05).  Lead was detected in only those surface water samples
collected from the unnamed stream at points which are physically on the
MSR (BP-SW-03 through BP-SW-06) and from the confluence of the unnamed
stream with Irish Buffalo Creek (BP-SW-09).

Analysis of the sediment samples indicate that Lead was detected in all
11 samples collected, and ranged in concentration from an estimated
value of 3,2 mg/kg (BP-SD-01) to an estimated maximum of 84 mg/kg
(BP-SD-06).  Lead concentrations increased in the unnamed stream from
the moat upgradiant sample (BP-SD-01) to the most downgradient sample
(BP-SD-06).  The sample collected from the confluence between the
unnamed stream and Irish Buffalo Creek (BP-SD-09) was not significantly
different (estimated at 80 mg/kg) than the most downgradient sample from
the unnamed stream (84 mg/kg).

The trend along Irish Buffalo Creek indicates an increase in Lead
concentration at the confluence with decreasing values downstream from
the MSR Facility.

Chromium was found in all but the most upgradient sediment sample
collected from the unnamed stream in concentrations ranging from 2.1
mg/kg (BP-SD-02 and BP-SD-03) to 18 mg/kg  (BP-SD-05).  In general, the
concentrations of Chromium in the stream sediment samples displayed the
same trends as Lead.

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                                      -19-

       No PCBs were detected in any of the surface water  or  stream sediment
       samples collected from either the unnamed stream or Irish Buffalo Creek.

       Sulfates were detected in all 11 surface water samples.   The
       concentrations along the unnamed stream increased  from 14 mg/L at the
       most upstream location (BP-SW-01) to 70 mg/L at the most downstream
       location (BP-SW-06).  Along Irish Buffalo Creek, the  upstream sulfate
       concentrations were low, but increased notably at  the confluence with
       the unnamed stream, and then decreased again at the downstream
       locations.

       Sulfates were also detected in 10 of the 11 stream sediment samples, the
       only sample with no detectable levels of sulfates  was collected at
       BP-SD-04, along the western end of the Flood Plain area.  The highest
       concentration was 519 mg/kg at BP-SD-09, at the confluence between the
       unnamed stream and Irish Buffalo Creek.  As was seen  with the surface
       water samples, sulfates in the unnamed stream systematically increase
       from upstream locations to downstream locations.

6.4    Air Investigation

       Air sampling will be performed prior to remedial action in accordance
       with the work plan for the purpose of acquiring background data.  This
       will be necessary to measure the level of fugitive emission from the
       site prior to the commencement of remedial actions, thus determining the
       level of protection necessary for the workers on the  site and to
       evaluate potential impact on the public downwind of the site.

6.5    Contaminant Fate and Transport

       Based on a detailed assessment of contaminant fate and transport from
       the MSR Facility, both migration of surface soils  via erosion mechanisms
       and contaminated groundwater were identified as exposure pathways.  The
       soils,  until remediated, will continue to be a source of groundwater
       contamination as the soil contaminants are leached.   In addition, eroded
       soils are being deposited into the unnamed stream  as  sediments which are
       currently being transported to Irish Buffalo Creek.   Groundwater
       migration of contaminants is expected to continue  in  a
       south/southeasterly direction.  Also, groundwater  modeling efforts
       suggested three additional potential sources of groundwater
       contamination: the upgradient location discussed above (BP-MW/DMW-09),
       the flea market area and the private landfill located along the northern
       boundary of the MSR Facility.

       It is anticipated that the indicator chemicals, Lead  and Nickel, and
       other metals in the groundwater, may pass the boundaries of the MSR
       Facility, although their migration is retarded by  adsorption to soils.
       Modeling efforts indicate that sulfate and Chromium,  being more mobile,
       have spread beyond the property boundaries, and will  continue to do so.

       Operations at the MSR Facility were suspended in 1986, and on-site
       disposal was stopped in 1982, therefore, the source of new additional
       contaminants entering the environment has been eliminated.  However, the

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                                       -20-

       existing contamination is continuing to spread throughout the soil,
       surface water, stream sediments and groundwater regimes, and the
       contaminated soils and buried battery casings are continuing to load the
       groundwater with contaminants.

7.0    Summary of Site Risks

       Risks calculated in this assessment are based on one of two scenarios.
       The current use scenario is of a child, age 6-15 years, trespassing onto
       the site 3 days per week to play, and thus comes in contact with the
       contaminated soil.  The future use scenario is based on a resident
       child, age 1-15 years, that comes in contact with the soil on a more
       frequent basis.  The exposure assumptions and constants are listed.

       The RI Report, Phase I (April, 1990)  for this site lists detected lead
       concentrations in soil as analyzed by either a Contract Laboratory
       Program (CLP) lab or an On-site Laboratory (OSL).  Since the Upper (95%)
       Confidence Limit (UCL) for the CLP samples, the latter UCL is used in
       this assessment because it represents more thorough coverage of the
       site.
                                EXPOSURE SCENARIOS

                                        Age 1-6                  Age 6-15

       ASSUMPTIONS

       Body Weight  (BW)                 16 kg                    35 kg

       Soil Ingestion Rate (IR)              200 mg/d                 100 mg/d

       Exposure Frequency  (EF)
          current                  N/A                      120 d/y
          future                   280  d/y                  200 d/y

       Exposure Duration  (ED)           5 y                      9 y


       CONSTANTS

       Averaging Time (AT)  - ED  * 365 d/y

       Conversion Factor  (CF) =  10~6 kg/mg

       Upper  (95%)  C.L. of lead  cone, in soil  (SPb) * 8580 rag/kg
       d = day; y « year;  N/A - Not Applicable

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                               -21-

The Intake (I) of lead by incidental ingestion of contaminated soil is
calculated from the following equation:

   I(mg/kg-d) = SPb * IR * CF * EF * ED
                       BW * AT

The noncarcinogenic Hazard Index (HI) is calculated by dividing the
Intake (I) by the reference Dose (RfD):

                                 HI -  I
                                      RfD
An HI of greater than 1.0 is generally an unacceptable risk, and
indicates that some type of action is necessary.

No EPA-verified RfD currently exists for lead.  For this assessment,
safe drinking water lead concentrations of 5 ug/1 and 15 ug/1 have been
used to calculate RfD. and RfD-  respectively.  The resultant RfDs
are listed.
                          SUMMARY OF RISKS

                                           Scenario
                                 Current Use	Future Use

Exposure Age Range  (yrs)                        6-15   1-15

Calculated Lead Intake  (mg/kg-d)           0.0081     0.095

Reference Doses (mg/kg-d)
   #1  (RfDj^)                              0.00014
   #2  (RfD2)                              0.00043

Hazard Index (unitless)
   -based on RfD1                     58             679
   -based on RfD2                     19             221
To determine appropriate health-based soil cleanup goals for this site,
the equation used above to calculate Intake  (I) was modified to solve
for lead concentration in soil (SPb).  The resulting equation:

             SPb (mg/kg =     I * BW * AT
                          IR * CF * EP * ED

uses all the same assumptions and constants.  The respective RfDs are
used for Intake (I).

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                                       -22-

                     Health-based Remediation Goala for Soil

                        Target Soil Concentration (mq/kal
                                                       Scenario
                                             Current Use     Future Use
          -based on RfD^^                     149            15
          -based on RfD2                     458            45
       SUMMARY OF RISK ASSESSMENT:  According to the His calculated in this
       assessment for the different scenarios (All much greater than 1.0),  the
       lead contamination in the soil at this site poses a sizable risk.   To  •
       achieve an acceptable health-based risk (HI = 1.0), the soil-borne lead
       concentration would need to be reduced considerably.  If it were reduced
       to 458 mg/kg, it would be protective for the least conservative scenario
       and RfD value.  Cleanup to lower soil-lead concentrations would
       obviously be protective of more conservative exposure assumptions.

       Although not an ARAR, the lead reference dose (RfD) should be considered
       here, as adherence to this criterion is necessary to ensure the
       protectiveness of the remedial alternative and is appropriate for the
       site.  As the capping alternative will eliminate the ingestion and
       dermal contact pathways, this alternative will meet the RfD criterion.

7.1    Selection of Indicator Chemical

       The indicator chemical selection process was able to reduce the number
       of chemicals to be evaluated in the discussion of contaminant
       distributions and in the qualitative risk assessment.  Thus, the four
       indicator chemicals  (Lead, Chromium, Nickel, and sulfate), are
       representative of the most toxic contaminants detected in the soils and
       groundwater at the MSR Facility.

       However, the indicator selection process is simply a manner in which the
       overall suite of compounds identified at the MSR Facility can be
       justifiably limited.  It is important to note that the selection of
       these four indicator chemicals must not be interpreted to mean that
       other contaminants detected at the MSR Facility are not of concern.
       Other compounds were excluded because they were detected at low
       frequencies or concentrations, because too little is known of the health
       risks posed by these compounds, because they pose a risk, but that the
       subjective risk is lower than the risk posed by one or more of the
       selected indicator compounds, or because there is too little available
       toxicological data to adequately address their risk.  Since they occur
       in association with one or more of the selected compounds they are
       inherently addressed.

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                                      -23-

       A second concern involves the unusually high concentrations of Iron
       detected in the shallow aquifer,  although there are' other contaminants
       of similar concern.   Iron, at the levels detected,  could significantly
       affect the quality of the surface waters and their  effect on aquatic
       ecology since the groundwater has been found to discharge to the surface
       water environment.  No information was obtained on  the aquatic
       environment, so the potential impacts of Iron (or other compounds)
       cannot be.  This lack of ecological data is the reason that ecological
       impacts of the MSR Facility are not addressed here.

       Finally, it should be reiterated that the exclusion of organic compounds
       from the indicator selection process should not be  interpreted to mean
       that these compounds are not of concern.  As with the example of
       Benzene, some of the compounds may be present in concentrations of
       concern, but cannot  be addressed due to the limitations of the
       analytical data base.

7.2    Exposure Assessment  Summary

       Because all potential source areas or the extent of contamination have
       not been confirmed by analytical results, most of the potentially
       significant exposure pathways have been deferred to the two other
       operable units.   Only those pathways for which analytical data are
       available are included in the preliminary risk analysis, which is
       quantitative in nature.   Risks cannot be quantified because the
       resulting values based on the available data would  not allow for
       apportionment of risks to a specific source area, which, subsequently
       would not allow for  the prioritization of source areas or the
       establishment of individual cleanup goals.  Based on the initial
       exposure assessment, the screening has reduced the  preliminary routes to
       the following four pathways for the preliminary risk analysis and
       include:

       — Exposure to surface soils at the MSR Facility (direct contact,
          ingestion, and inhalation of dusts);

       — Exposure to surface water and sediments at the eastern and southern
          physical boundaries of the MSR Facility (direct  contact, ingestion);

       — Exposures to groundwater; and

       — Ecological exposures to surface soil, surface water, and sediments at
          the eastern and southern physical boundaries of  the MSR Facility in
          Irish Buffalo Creek and the unnamed stream, respectively.

       The remainder of the potential exposure pathways will be addressed in
       subsequent operable  units.  These pathways include:

       — Exposure to surface soils at source areas upgradient and downgradient
          of the MSR Facility (direct contact, ingestion,  and inhalation of
          dusts);

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                                       -24-

       — Exposure to surface water and sediments at source areas located
          upstream and downstream of the MSR Facility (direct contact and
          ingestion);

       — Ecological exposures to surface soil, surface water, and sediments to
          Irish Buffalo Creek upstream and downstream of the MSR Facility area
          as noted above.

7.3    Toxicitv Assessment

       The objective of the toxicity assessment is to characterize the nature
       of the potential health effects associated with the indicator chemicals
       identified at the MSR Facility such that, in conjunction with the
       exposure information, a preliminary risk analysis of the Facility can be
       performed.  The characterization is a qualitative evaluation of the
       available health effects data in order to provide a toxicological
       profile for each indicator chemical of concern.  To more clearly
       understand the toxicological profiles, terms relevant to the toxicity
       profiles and dose-response information are also presented.

       A number of terms commonly used in toxicity assessments for carcinogenic
       and noncarcinogenic effects are defined in the following subsections.
       Acceptable intake for Chronic Exposure  (AIC).  The AIC, also referred to
       as the acceptable daily intake  (ADI) is the highest human intake of a
       chemical, expressed as mg/kg/day, that does not cause adverse effects
       with long term exposure.  The AIC is usually based on chronic animal
       studies, since few data exist on long-term human exposures and is used
       in evaluating potential noncarcinogenic health effects resulting from
       chronic exposure to a chemical  (EPA, 1989a).

       Cancer Risk.  Cancer risk is a unitless probability of an individual
       developing cancer and is calculated by multiplying the average daily
       exposure dose by the appropriate Carcinogenic Potency Factor to convert
       the dose directly to an incremental risk of an individual developing
       cancer.  For example, a cancer risk of 1 x 10   is the risk of one
       additional case of cancer per 1 million people (EPA, 1989a).

       Carcinogenic Potency Factor (CPF).  The CPF is an upper-bound estimate
       of the probability of a response per unit intake of a chemical over a
       lifetime, and is generally reported in  (mg/kg/day)  .  The CPF is
       derived by applying a model to the available dose-response data set and
       using the model to extrapolate from the relatively high doses
       administered to experimental animals to the lower exposure levels
       expected for human contact in the environment  (EPA, 1989a).

       Chronic Hazard Index (HI).  The HI is a ratio of the lifetime average
       daily exposure of a noncarcinogenic chemical contaminant.

7.4    Potential Carcinogenic and Noncarcinooenic Contaminants

7.4-1  Noncarcinogenic

       Detected compounds were evaluated with regard to their frequency of
       occurrence, distribution and concentrations.  As & result, several

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                                      -25-

       compounds were eliminated.   Of the remaining compounds,  none were known
       or potential carcinogens in the media which were assessed (soil and
       water), so evaluation of carcinogenic effects as part of the indicator
       chemical selection process was eliminated.

       Although hexavalent Chromium is a potential carcinogen via inhalation
       pathways, analytical data were generated to determine the ratio of
       hexavalent Chromium to the noncarcinogenic  trivalent form.  The result
       of those analyses indicate that the hexavalent form was not detected in
       any of the samples analyzed.  Therefore, it should be noted that any
       discussions on Chromium refer to the trivalent form.

       Compounds detected were categorized by their noncarcinogenic effects.
       The toxicity constants for noncarcinogenic  chemicals are provided in
       Figure 7.  The toxicity constants used to calculate the indicator scores
       for each of the inorganic chemicals detected at the MSR Facility are
       derived from the most current numbers available in the EPA Health
       Effects Assessment Summary Tables (EPA, 1989b) and the Integrated Risk
       Information System (EPA, 1989c).

       Toxicity constants for noncarcinogens  (nT*) were derived using the
       reciprocal of the reference dose  (1/RfD).  Toxicity constant units are
       the inverse of their respective concentration units; therefore, the
       values in the calculation of the  indicator scores will be unitless.  The
       indicator score (IS) is the sum of the product of the concentration of a
       chemical in a given medium and a  toxicity-based concentration.

7.4-2  Environmental Risks

       A preliminary natural resources survey has been completed on the Bypass
       601/Martin Recycling (MSR) Groundwater Contamination Site, by the U.S.
       Department of the Interior.

       The survey reveals that the site  and surrounding area provide suitable
       habitat for migratory birds, a trust resource of the Department of the
       Interior.  Numerous species of migratory birds would be expected to
       occur seasonally in this area, and several species were seen on a recent
       field inspection.

       Acid and metal contamination have been recorded in the surface waters,
       soils, stream sediments, and groundwater on and near the site.

8.0    Remedial Action Objectives and General Response Action

8.1    Site Remedial Action Objectives

       The remedial action will reduce the environmental risk posed by the
       contaminants at the MSR Facility.  The remedial action is protective by
       reducing direct exposure to contaminated soils.  Reduce the mobility of
       contaminants by limiting wind dispersion of soils and infiltration of
       wastes into groundwater; however, contaminants remain on-site.  A fence
       will be used to limit access, but may not completely eliminate the
       access to trespassers to the MSR Facility.   Institute deed restrictions
       on property while action is going on.

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                                       -26-

       Continual monitoring will be conducted to determine whether remedial
       measures are performing successfully.
8.2
       An interim cleanup level of 500 to 1,000 mg/kg of Lead in soil has been
       derived by CDC  (1985) and has been adopted as a technical directive by
       the Office of Solid Waste and Emergency Response for Superfund Sites
       (EPA, 1989d).  A Lead soil action level of 500 mg/kg will be used for
       the MSR Facility.

       Because the oral toxicity of Lead is 5 to 10 times more toxic than
       Chromium, Nickel or sulfate and the concentration of Lead at the MSR
       Facility are several orders of magnitude higher in soil and sediment
       than the other indicator chemicals, action-level development was only
       performed for Lead.

       Alternative 3 —  In-situ solidification, involves the solidification of
                         contaminated soils at the site with minimal potential
                         for exposure to subsurface soils.

       Alternative 4 —  Excavation, on-site treatment and disposal.  The soils
                         will be treated using solidification and disposed of
                         on-site.

       Alternative 5 —  Excavation, off-site treatment and disposal, involves
                         disposal and treatment of contaminated soils at a RCRA-
                         licensed facility.                                     '

8.3    Volume of Lead Contaminated Soil

       The volume of soil contaminated with Lead was calculated.  Figures 9,
       10, 11 and 12 show surface and subsurface soil sample locations with
       Lead concentrations in excess of 500 mg/kg identified based on the
       intervals 0-1',  1-', 5-15' and below 15'.

       Finally, all sub-volumes were added together to obtain a final estimate
       of the total volume of soil contaminated with Lead  (Figure 13).  The
       resultant volume of 57,719 cubic yards of soil are estimated to be
       contaminated with Lead in concentrations in excess of 500 mg/kg.

8.4    Cleanup Levels  for Soils

       There are no ARARs for soils; however, EPA Interim Guidance on
       Establishing Soil Lead Cleanup Levels at Superfund Sites was considered
       for determining a soil action level.  Concentrations of Lead greater
       than 500 mg/kg  in soils pose a potential health risk.  A concentration
       of 500 mg/kg is the soil action cleanup goal.  This action level for
       Lead will be applied to surface and subsurface soils.  This Lead
       concentration represents the lower end of the recommended action level
       range for residential areas (500-1,000 mg/kg, USEPA, 1989d).  Chromium
       and Nickel were not found to be present at concentrations significantly
       above background and therefore have no action levels.  Sulfate has no
       health based limits in soil, therefore, no soil action level for sulfate
       has been selected.                                                       '

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                                      -27-

9.0    Description of Alternatives

9.1    Overall Objectives

       In the Focused Feasibility Study (FFS), a number of steps were performed
       to evaluate thoroughly the potential remedial action alternative for the
       HSR site.  These steps were: (1)  formulation of site remedial action
       objectives, (2) identification of general response actions, (3)
       identification and screening of technologies, (4) development and
       screening of remedial action alternatives, and (5) detailed analysis of
       alternatives.

       Alternatives developed and screened included the following:

       Alternative 1 —  No action, but long-term water monitoring.

       Alternative 2 —  This is an interim action.  Excavation, consolidation
                         and capping, involves capping the contaminated soils
                         at the site to limit direct exposure and reduce
                         migration of contaminants.  EPA will be able to pursue
                         investigations of the groundwater at the MSR Facility
                         and soil and groundwater at the other potential
                         sources.

       Table 20 shows a tentative order of several dose-response effects in
       children.  However, it must be remembered that there is considerable
       overlap between the effects noted,  and these effects may vary accordings
       to sex, age, and length and duration of elevated PbB.  Benchmark for
       that chemical in that medium that is used to rank the site chemicals.

9.2    Alternative 1 - No Action, But Loncr-Term Monitoring

       This alternative involves taking no action at the MSR Facility.  The MSR
       Facility property would be left in its current condition.  Monitoring of
       soils at the MSR Facility needs to be incorporated into a comprehensive
       monitoring plan for all media so all migration pathways may be
       evaluated.

9.3    Alternative 2 - Excavation. Consolidation and Capping

       Four buildings in the Main Facility area consisting of concrete slab,
       cement block and metal frame construction will be demolished  (Figure
       14).  The large octagon-shaped building, where Lead reclamation

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   3  10  0294
  /7
-------
   5  10  0294
            Toxicity  Constants for Noncarcinogenic Compounds
            Bypass  601  Groundwater Contamination Site --
            Martin  Scrap  Recycling Facility.

Chemical
Name *
Barium
Chromium
Cobalt
Ccpper +
Iron
Lead -n-
Manganese
Nickel
Sulfates •*
Titanium
Vanadium
Yttrium
Zinc
nT*

NL
Water
nT*
'(mg/kg/day)-l
2-OOE-t-Ol
l.OOE+00
NL
2.70E+01
NL
2.00E+03
5.00E+00
5.00E+01
"Cf 8.75E-02
NL
1.11E+02 '
NL
5.COE+00
» I/reference dose
reference doses obtained from
* value not listed in available
Soil
nT*
(ag/kg/day)-l
2 .OOE-01
l.OOE-CO
NL
2.70E-01
NL
2 .OCE-03
5.00E-00
5. OOE-01
8.75E-02
NL
1. 11E+02
NL
5.00E-00

HEAST or IRIS
literature
            or databases
          » inorganic compounds
          • no reference dose determined for copper;
            acceptable intake calculated using  adult
            exposure to MCL of 1.3  mg/L
          - no reference dose determined for lead;
            acceptible intake calculated using  child
            exposure to proposed MCL of 0.005 mg/L
          • no reference dose determined for sulfates;
            acceptable intake calculated using  adult
            exposure to EPA guidance level  of 400 mg/L
-g/kg/day - milligrams per kilogram per day
     mg/L • milligrams per liter
Source:  EPA, 1985c,  1989b, and 1989C.

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       r "
       U i.
                    SUMMARY OF SOIL LEAD ACTION LEVELS
              BYPASS 601  -- MARTIN SCRAP RECYCLING FACIL1TT)
                    PHASE I FOCUSED FEASIBILITY STUDY
 Soil Lead
Level for the
Protection of
Human He*1th
Source
Basis of Decision
Background
Levels
50 mgAg
500 to
1.000 ag/kg

500 to
1.000 «g/kg

1.000 ag/kg
2.500 mgAg
EPA Region I,  ROD,
Nyanza Chemical,  MA,
1983

EPA Region II, ROD.
Burnt Fly Bog Site,
NJ. 1983

Centers for Disease
Control, 198S

EPA OSVER Directive
•9355.4-02. 1989.

EPA Region IV, ROD.
Peppers Steel, FL,
1986

EPA Region IX'. ROD,
Celtor Cheaical Vork
Site, CA, 1986
Action level for
industrial property


Action level for
industrial property
Reeooaended action level
for residential areas

RecoaBended action level
for residential areas

Action level for an
industrial site
Action level for an
industrial site
Source:  Hunter/ESE,  1989.

-------
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State in F««l ~'
'"**»"* ^J..
.l...»n T'.
I^K*a,/Huaa
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IU' t^unluul
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-------
C. '

-------

-------

-------
      C'J/9
      /3    Calculation of Soil  Volumes  Contaminated
            with Lead in Excess  of  500 mg/kg.   Bypass
            601 Groundwater Contamination Site  --
            Martin Scrap Recycling  Facility.



X-section
A
B
C
D
. r
: F
G
H
. I
J
K
; L
M
i N
i 0
P
1 Q


Area
(sq. ft.)
4,095
3,770
6, 095
290
355
0
0
0
0
160
0
0
0
0
0
0
0
























Interval
-A
A-B
B-C
C-D
D-E
E-F
F-G
G-H
H-I
I-J
J-K
K-L
L-M
M-N
N-0
0-P
P-Q
Sub-Volume
Between
Adjacent Cross-
Sections (cu. yd.)
10,617
14,565
13,269 :
11,824 :
1,194
657
0 *
0 *
0 *
296 i
296 I
0
0 *
0 *
0 *
0 *
0 *
            Estimated Volume
57,719 cu yd
* = No Lead Contaminated Soils Detected in Excess
    of 500 mg/kg.
Note:  Distance between x-sections * 100 feet
Source:  Hunter/ESE, 1990

-------
                                -34-

activities were conducted, is believed to be contaminated,  based on the
soil sample collected from inside the building and the acid-etched
concrete floors.  The building debris will be disposed of in a secure
landfill, except  for the metal materials, which may be reclaimed through
recycling.  Concrete and stone from the buildings will be crushed and
consolidated with the contaminated surface soils.

Contaminated surface soils at the northern section of the main facility
area and at the eastern side of the slope towards the floodplain will be
excavated.  This  surface soil will be placed over the area where
subsurface soils  are contaminated and graded to reduce the slope to no
greater than 15%  (Figure 15).  Clean sandy fill will provide a layer
over the contaminated soils for the replacement of a synthetic liner.  A
high density polypropylene (HOPE) liner will be placed over the area and
anchored around the perimeter using trench and fill method.  Eighteen
inches of clean fill will be placed over the HOPE liner and then covered
with 6" of clean  topsoil to support shallow root vegetation.  The cap
will eliminate the direct exposure to surface soils and limit vertical
infiltration and  potentially reduce the leaching of contaminants into
the groundwater until a final remedy is chosen.

Areas where surface soils are removed will be filled with clean soil to
the approximate grade before excavation.  The unnamed stream will be
realigned along the southern property boundary to minimize erosion of
the cover.

During the construction phase of the cap, air sampling will be conducted
to monitor the workers and neighbors potential exposure to airborne
particulate and dust.  Air sampling results will be used to determine
the level of worker protection and potential risk to neighbors.  Oust
suppressants such as water, calcium chloride solution, or foam will be
used to control airborne particulate and dust, if necessary.

A six foot high chain-link fence will be installed along the property
line of the MSR Facility.  This fence will be topped with strands of
barbed wire to limit trespassers.  An access gate will be installed at
the northwest corner of the property along State Road 29.  Warning signs
will be posted at appropriate intervals on the fence.  The fence will
limit but not completely eliminate trespassers.

Deed restrictions will be required for the MSR Facility to protect he
cap and limit exposure.  The deed restrictions must limit the owner or
occupant of the property to activities that would be consistent with
minimizing exposure and risk to human health and the environment.  These
restrictions would be carried with the deed on the property and
transferrable upon the sale of the property.  The State of North
Carolina and Cabarrus County would be responsible for inspecting the
site to determine that the deed restrictions are not transgressed.

A public awareness program would be implemented to educate the public of
the potential human health hazards associated with the MSR Facility
soils and groundwater.  The program would include periodic meetings and

-------
                                      -35-

       presentations in the local neighborhood and pamphlets.   These  programs
       would be coordinated through the  State of North Carolina Department of
       Environment,  Health, and Natural  Resources and Cabarrus  County.

       Maintenance of the cap may require mowing the vegetative cover and
       re-establishing any areas where erosion threatens the integrity of the
       cap.   Since contaminants would remain on-site, CERCLA regulations
       require that the site be reviewed every five years.   Data collected
       during the bi-annual site investigations will be used to evaluate the
       site.  This plan would not include environmental media sampling and
       analysis since such a plan will be developed later for the entire Bypass
       601 site.

9.4    Alternative 3 - In-situ Solidification

       Reagents effective for immobilizing metals will be tested in bench and
       pilot scale studies.  Samples of  untreated soils will be analyzed for
       moisture content, bulk density, permeability, pH, Unconfined Compressive
       Strength (UCS), weathering, TCLP  and other possible parameters.  This
       analysis will be used to select the type and amount of reagents, as  well
       as determining the effectiveness  of reagents.  The most effective
       reagents (low leachability, adequate strength and resistance to
       weathering) will be used for pilot testing.  The pilot test will
       determine process rate and effectiveness.

       The same demolition and disposal  of buildings, consolidation of
       contaminated surface soil, site regrading, and stream relocation
       described in Alternative 2 would  be don in Alternative 3.

       The selected reagents will be mixed with the contaminated soil via
       injection and mechanical mixing using a vertical auger.   The treated
       soil columns are positioned to overlap and create a continuous
       solidified mass.  The auger would be advanced to a depth sufficient  to
       treat all contaminated soils in excess of the action level.

       During solidification of soils, approximately 65 quality control samples
       will be collected.  Thirty-five samples will be treated for the
       parameters described below.  The  results will be used to confirm that
       the construction meets specifications.  Thirty of the 65 samples will be
       splits and, once set, buried on-site.  Every five years, five samples
       will be uncovered and analyzed for the same suite of parameters.  These
       test results will be used to determine the long term integrity of the
       solidified mass.  The results will also be evaluated as part of the  five
       year site review.

       The area of treated soils will be covered with 18" of clean fill and 6"
       of clean top soil.  The site will be revegetated and inspected
       biannually.

       The fence installation, deed restrictions, and public awareness program
       described in Alternative 2 are the same for Alternative 3.

-------
^.
 c

                                                            2QQ
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                                                                 --— -- • *C'  Ccntsi..- [zjii;--
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                                      Graphic Scale in  Feet
                                                                   L»CC  - So. »  >;;: -;
                                                                   .tec  - So; *  <«:•: --
                                                          AREA OF  CONSOLIDATE:  sr
                                                                  REGRADED  A,\D
X
  BUILDINGS  TO
  BE  DEMOLiSHED
                                                Alternative 2  - Capping
                                  Figure   /4-    Bypass 601  Ground*ater  Cc-'.:~ •='• -"  -
                                              1  Wartin  Scrap  Recycling rcc":..

-------
                                                                                                                                       -r-
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-------
                                       -38-

9.5    Alternative 4 - Excavation. On-Site Treatment and Disposal

       All the buildings in the Main Facility area will be demolished and the
       debris stored in a staffing area on the Flood Plain area (Figure 6),
       east of the slope separating the Flood Plain and the Main Facility areas
       east of the Flood Plain area where contaminated soils were found.

       The contaminated surface soils from the Main Facility area will be
       excavated and place on top of the contaminated soils at the base of the
       slope separating the Main Facility and Flood Plain areas, where soil
       contamination was identified during the Phase I field investigation.
       Once the Main Facility area is cleared of buildings and surface soil,
       excavation of a disposal cell will begin.  The Main Facility was
       selected as a disposal area because it is not prone to flooding and
       provides additional distance between treated soils and the groundwater.
       The demolition of all the buildings allows the cell to be placed as far
       north as possible, thus further away from the flood plain and ensuring
       the greatest separation of the treated soils and the surficial
       groundwater.  Starting with excavation along the northern perimeter of
       the Main Facility area, clean subsurface soils will be excavated.   The
       uncontaminated subsurface soils form the Main Facility area will be
       staged on clean soils further east form the debris staging area in the
       Flood Plain area.

       Contaminated soils will be treated by solidification; battery casing
       debris will be ground and consolidated with the contaminated soil, all
       of which will be consolidated using cement based stabilization.  The
       treated soil will be placed in the disposal cell in the Main Facility
       area.  The clean soil excavated from the Main Facility Area will be used
       to backfill the areas where contaminated subsurface soils were
       excavated.  Excavation of the Main Facility Area and treatment and
       disposal of contaminated soils will be staged.  The contaminated soils
       in the western portion of the Flood Plain area  (south of the Main
       Facility area) will be also excavated, treated, and finally disposed of
       in the Main Facility disposal cell.  Excavation of the Main Facility
       Area will continue until all soil contaminated with Lead in excess of
       500 mg/kg action level is removed, treated and disposed.

       After excavation of the contaminated soils in the western section of the
       Flood Plain area, that area will be regraded and slopes will be
       maintained at a 15% (or less) grade as shown in Figure 14.

       A mound will be created at the Main Facility Area to provide for the
       increase in volume of treated soils due to the addition of
       solidification agents.  The volume of solidified soil is expected to be
       15% to 25% larger than the volume of excavated soil, depending on the
       volume of solidification agents used.  The area of treated soils will be
       covered with 16" of clean fill and 6" of clean top soil.  The site will
       be revegetated with shallow root vegetation.

-------
                                      -39-

9.6    Alternative 5 - Excavation.  Off-Site Treatment and Disposal

       Four buildings on the Main Facility Area (Figure 16)  will be demolished
       and disposed of off-site at a secure landfill.  The contaminated soils
       will be excavated using power hoes.  The excavated material will be
       placed in trucks and transported to a subtitle C facility.

       The licensed treatment and disposal facility will be required to treat
       the soils which are EP Toxic for lead by solidification.   It is
       estimated that half the volume of soil received will require treatment.
       The remaining volume of soil can be landfilled directly since it would
       not be a restricted waste.

       During the excavation, air sampling will be conducted to monitor the
       level of contaminated dust generated.  Confirmation sampling will be
       conducted on a 50 foot grid to determine if all soils contaminated in
       excess of the soil action level are removed.  Approximately 70
       confirmation samples will be analyzed for the indicator compounds.

       Because the treatment of groundwater will be evaluated in Operable Unit
       3,  this alternative will not consider excavating the soil below the
       groundwater table for the purpose of preparing a cost estimate.

       The excavated areas will be backfilled with clean soil, regraded and
       revegetated.

       The site will be visited 6 months after site demobilization to inspect
       the revegetation program.  No long-term monitoring will be required
       since no waste will be left on-site.

10.0   Summary of Comparative Analysis of Alternatives

       It is concluded that all the alternatives except the no action
       alternative are protective of human health and the environment.  The
       treatment alternatives will be more protective than the capping
       alternative.  Alternative 5 is expected to be more protective than
       Alternative 3 or 4, however, due to off-site treatment and disposal of
       contaminated soils in a secure landfill.  Alternative 3 and 4 will
       require bench and pilot-scale studies to confirm the level of
       contaminant immobility and to optimize the design to achieve this
       efficiency.  Exposure to the contaminated soil on the MSR Facility will
       be eliminated under this alternative.  Therefore, the risks associated
       with dermal contact and ingestion will be eliminated.  A periodic
       inspection and maintenance program is necessary to guarantee the
       continued protectiveness of this alternative.

       The shortest estimated time necessary for implementing an alternative is
       two months for capping (Alternative 2) and the longest is seven months
       for excavation, on-site treatment, and disposal (Alternative 4).  Both
       Alternatives 3 and 5 are estimated to take five months to implement.

       Alternative 1 will do nothing to eliminate the risk due to direct
       exposure of contaminated soil and leaching of contaminants to the
       groundwater.  Alternative 3 will eliminate the direct exposure to soils

-------
                                       -40-

       and reduce the leaching to groundwater.  All the treatment alternatives
       are expected to eliminate the exposure to soils and leaching to
       groundwater.  Alternative 5, however, would provide the greatest level
       of protection since the treated soils would be disposed of in an
       off-site secure landfill.  Bench, pilot-scale, and environmental studies
       are required to determine the relative level of effectiveness for
       Alternatives 3 and 4.

11.0   Selection of Remedy

       The selection remedial alternative for the MSR Facility is Alternative
       2.  A list of Figures 9 thru 12 showing the extent of lead
       contamination, capping soil consolidation and a more complete
       description can be found in section 9.0 of this ROD.

       This alternative will also incorporate all the retained limited action
       technology process options:  site fencing, deed restrictions, and public
       awareness program.  Alternative 2, provides a relatively inexpensive
       interim remedial action for the MSR Facility.  This alternative would
       not prohibit future remedial actions at the site, but would provide a
       level of protection until such time that a treatment and/or disposal
       alternative could be implemented.

12.0   Statutory Requirements

       The Agency has determined that this interim action satisfies the
       statutory requirements of providing protection of human health and the
       environment, attaining applicable or relevant and appropriate
       requirements (ARARs) of other environmental statutes, will be
       cost-effective and will utilize permanent solutions and alternative
       treatment technologies or resource recovery technologies to the maximum
       extent practicable.  The remainder of this section discusses how the
       statutory requirements relate to this site.

12.1   Protective of Health and the Environment

       No unacceptable short term risk or cross media impacts will be caused by
       implementation of the interim action.

12.2   Attainment of the Applicable or Relevant and Appropriate Requirements

       Remedial actions performed under Superfund must comply with all ARARs.
       The following ARARs were identified for this site.

12.2-1 Contaminant-Specific ARARs

       The contaminant-specific ARAR pertinent to the capping remedial
       alternative is the NAAQ standard for lead, which is codified in the
       Clean Air Act of 1976 and the North Carolina Air Control Regulations.
       As stated above, water sprays or other dust suppressants are envisioned
       to be used to control fugitive dust emissions such that this standard is
       not exceeded.

-------
                                                        ««—•— 10' Contour

                                                    2QQ  • —  — '0' Contour
                                Graphic Seal* in F««t
                                                  AREA TO DISPOSE OF
                                                  SOUDIRED  SOILS
BUILDINGS  TO
BE  DEMOLISHED
                                                     REALIGNMENT OF _
                                                     UNNAMED-STtfE&T
--65C-
   »*

/ 0 4$ x
J • '«' <° ^ y
' / ^ , / .e
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-------
                                      -42-

12.2-2 Location-Specific ARARs

       The location-specific ARAR that may be activated by the interim action
       is the Fish and Wildlife Coordination Act for Wetland and Flood Plains.
       Consultation with the U.S. Fish and Wildlife Services will be required
       if realignment of the unnamed stream involves wetlands.

12.2-3 Action-Specific

       Several action-specific ARARs will be applicable or relevant and
       appropriate for capping remediation.  All on-site workers must meet the
       requirements of OSHA under 29 CFR, Parts 1910, 1926, and 1904.
       Additionally, worker exposure to air contaminants must be kept below
       allowable concentrations  (threshold limit values) set by the American
       Conference of Governmental Industrial Hygienists (ACGIH).

       Although not an ARAR, the lead reference dose (RfD) should be considered
       here, as adherence to this criterion is necessary to ensure the
       protectiveness of the remedial alternative and is appropriate for the
       site.  As the capping alternative will eliminate the ingestion and
       dermal contact pathways, this alternative will meet the RfD criterion.

12.2-4 To Be Considered Criteria

       To be considered (TBC) criteria are those criteria which, although not
       required by or based on federal statutes (as ARARs are), may be
       applicable to the MSR Facility.

       Because groundwater contamination is not being addressed in this ROD,
       groundwater ARARs are presented only in the context of dewatering
       activities associated with the soil excavation activities.

12.2-5 ARAR Attainment

       All other alternatives, with the exception of Alternative 1, would meet
       their respective ARARs and cleanup goals.  The contaminated soil is not
       a RCRA hazardous waste and is currently under the soil and debris
       exemption to the Land Disposal Restrictions (LDR).  Therefore, the LDR
       are not ARARs for this site.  No waiver from ARARs would be necessary to
       implement the active cleanup options.

12.3   Cost Effectivenesa

       Figure 17, presents the comparison of the present worth, capital annual
       O&M, and five-year costs for Alternatives 2, 34, and 5.

       EPA's selected Alternative affords a higher degree of overall
       protectiveness in not only protecting the public against direct exposure
       to surface soils but also in reducing the threat of future contamination
       to surface water and sediments at the eastern and southern physical
       boundaries of the MSR Facility.  The present worth estimated cost of
       EPA's selected remedy is approximately $738,821.

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                                       -43-

12.4   Utilization of Permanent Solutions and Alternative Treatment Technology
       or Resource Recovery Technologies to the Maximum Extent Practicable

       U.S. EPA believes this interim action is the most appropriate cleanup
       solution for the MSR site and provides the best balance among the
       evaluation criteria for the remedial alternatives evaluated given the
       limited scope of the action.  This remedy provides effective protection
       in both the short- and long-term to potential human and environmental
       receptors, is readily implemented, is cost-effective and is consistent
       with future response actions that will be undertaken at the site.
       Preference for treatment will be addressed in the final decision
       document.

13.0   Occupational Exposures

       The National Institute for Occupational Safety and Health (NIOSH) has
       estimated that >1 million American workers are occupationally exposed to
       inorganic lead in >100 occupations (NCI 1985).  The highest and most
       prolonged lead exposures are found among workers in the lead smelting,
       refining,  and manufacturing industries.  In all work areas, the major
       route of lead exposure is by inhalation an ingestion of leadbearing
       dusts and fumes.  Airborne dusts settle onto food, water, clothing, and
       other objects, and may subsequently be transferred to the mouth.
       Therefore, good housekeeping and good ventilation have a major impact on
       the extent of exposure.  Although occupational exposure is widespread,
       environmental monitoring data on levels of exposure in many occupations
       are not available.  This is partly because lead exposure is frequently
       monitored by biological testing (e.g., determination of urinary lead
       levels, blood lead levels, urinary coproprophyrin, or
       delta-aminolevulinic acid) rather than monitoring the workplace
       environment for lead concentrations (NCI 1985, EPA 1986a).

       Potentially high levels of lead may occur in a wide variety of
       occupations including:  lead smelting and refining industries, battery
       manufacturing plants, steel welding or cutting operations, construction,
       rubber products and plastics industries, printing industries, firing
       ranges, and gas stations (EPA 1986a, NCI 1985, Feldman 1978).  Workers
       involved in the production of gasoline additives, tetraethyl lead and
       tetramethyl lead, are exposed to both inorganic lead and lead alkyIB.
       The major potential hazard to these workers appears to be from dermal
       exposure (EPA 1986a).

       Secondary occupational exposure may occur among families of workers who
       inadvertently bring home lead dusts on clothing worn at work.  Blood
       lead levels have been found to be markedly higher in household members
       residing in homes of occupationally exposed workers compared to members
       of homes of people not occupationally exposed (EPA 1986a, Grandjean and
       Bach 1986).

14.0   Populations at Risk

       As discussed by EPA (1986a), at least three groups of populations at
       risk can be identified:  pre-school age children, the fetuses, and white
       males between 10 and 59 years of age.

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                                               COST  KST1HATKS
                                          FOR REMEDIAL ALTERNATIVES
                                BYPASS 601 -- MARTIN SCKAI' RECYCLING FACILITY
                                      PHASE I FOCUSED FEASIBILITY STUDY
Remedial Alternative Present Worth

Alternative 2 -- $ 738,821
Capping
Alternative 3 -- $ A. 539, 118
In-Situ Solidification
Alternative A -- $ 11,511.757
On-Slte Treatment and
Disposal
Alternative 5 -- $ 16.A7l.823
Off-Site Treatment and
Disposal
Capital Annual O&M 5-Yi-,n Review
1
$ 681.155 $ 9.700 $ 20.000

$ A. 243. 995 $ 9.700 $ 52,500

$ U.198.1A7 $ 10.900 $ 52.500


$ 16.A71.823 $ 00 $ 00


Source:  ESE. 1990

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                                -45-

Young children are inherently more susceptible to the effects of lead
because of the greater intake of lead by infants and young children in
the respiratory and gastrointestinal tracts on a body-weight basis
compared with adults; the greater prevalence of nutrient deficiency,
which can affect gatrointestinal lead absorption; normal hand-to-mouth
activity and pica; differences in the efficiency of lead sequestration
in bone; and incomplete development of the blood-brain barrier
increasing the risk of entry of lead into the nervous system.

Fetuses are at even greater risk.  As discussed in Section 4.2-2 on
distribution and body burden in the Toxicological data section, lead can
readily cross the placental barrier; therefore, exposure of women to
lead during pregnancy results in uptake by the fetus.  Furthermore,
since the physiological stress of pregnancy may result in mobilization
of lead from maternal bone, fetal uptake of lead can occur from a mother
who was exposed to lead before pregnancy, even if no lead exposure
occurred during pregnancy.  Prenatal exposure may be related to
postnatal mental retardation, impaired postnatal neurobehavioral
development, and reduced birth weight and gestational age.

Increased blood pressure is associated with blood lead concentrations
possibly as low as 7 ug/dL (EPA 1986a).  It appears that this
relationship is particularly significant for middle-aged white males
(aged 40 to 59).

Figure 20 shows a tentative order of several dose-response effects in
children.  However, it must be remembered that there is considerable
overlap between the effects noted, and these effects may vary according
to sex, age, and length and duration of elevated pbB.

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                                                      CMNICAt SPtCIHC ARMS.  IK*.  OMUtl*.  AND OIIOAma
                                                           •tPASS 601 -  NMIIH SOUM> ttCmilK IACIIIIT
                                                                •MAS* i laaisto rtASititiif siuot
                                                                                                                                            I
                                                                                                                                           ( I
>tUHAIO»»
  tivft
    ARM  IKMimCAIIOJI
                                                      SIAIUS
                              HCOUUtMtMl SMOPSIS
federal
CWA Mater Duality  Criteria
(UK) for Protection ol
Health «id Aquatic
                 •C*A   Naiimum
                 limit* (Kiel
                Concentration
•elevent end
Appropriate
•elevent end
Appropriate
federal
SOWA MM ieuaCont eminent level*
UBj>tian alone.

Provide* ttandard*  for U toiic caapounds
end    peclicide*    for   protection    of
groundttater.  lhe*e  tlandard* are e  II..
«aniatja coniaMinatit  levels at •ypask 6til  i.
determine  levels of coniaBinalion.
Ihe  proMJlgated values are included u>  iiir
SOtM NCI* (Refer to SOU* below).  Ihe <:«•«,1,^
standards are used to coapare mth the •• «!•••
contaminant levels at lypass 601 to
the level of contamination.
fight actall ic species and one tome
(cyanide)  were  identified   in
contamination.  Ihe SIMM NCIi.  in cunium 11.«.
with NC Ambient Quality Standards and guitUm «•
value*.  Mill  be  used  to  selett   inditan.i
chemicals and as treatment retirement*
                                              Since  the HClCs  are non-enforceable  yoaii
                                              they are used as reference values to ioli. «i
                                              treatment  system performance only.'

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                                                            MCM WtCIIIC AIMS. OIIIEtlA. MD CUIDMKt
                                                         •IPASS 401  - MMIIIi SOMT •fCTCllW tACUIIV
                                                               PtMSf I fOCUSCD ItASIfMUlf SIUDI
UtOUKHMI
  tivu

Stale
                     OHM
State
Water    rollution    Control
••fulatiom    for   Cftluant
lialtatlom » MCAC 211.0118
Water  Ouality  Stamtardi  for
freah     Surface    Water
Claaaification and Standard*
1* HCAC 21.0211
•« levant and
Afipropriat*
•elevant and
Af^irapriate
Provide*   concentration   criteria   for
discharge  of effluent  to  curtate  Mater
environments,      these   standard*   arc
developed to cnaur* protection of surface
Mater resources and acBjatlc species.

Establtahe* Mater quality atandard* for  16
tone substances and peatlclde*.  including
ChrodiuB. lead,  and nickel and establishvs
discharge  li«lt*  tor  pN  for  all   fresh
•urface Mater*.
                                                                              fS COMMOtMIIOl
Discharge  of  li rated  groundbiter  lo  ir.r
•urface Mater* (tl«»k C) at  the N$t faic
Mhen   developing  treatacnt  criteria  Im
dewatering Materc  prior to discharge  tu  •
surface Mater body.

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• 7 ••
    •-.  2o   Dose-Response Effects of Lead Adsorption  in Children.
            Bypass  601 Groundwater Contamination Site  -- Marti.-.
            Scrap Recycling  Facility.


Blood Lead Level
    (ug/dL)                    Effect


     <10                       Inhibition of ALA-D

      15                       Elevation of ZPP

      30                       Elevation of ALA  and  Coprcprcp'-yrir.
                               in the urine

      40                       Shortening of red cell  life  spar.

      50                       Peripheral neuropathy (succlir.ical;

      70                       Anemia

   80 to 100                   Impannent of renal  function

   80 to 100                   Encephalopathy


   ZPP = Zinc  Protoporphrin             Source: ATSDR,  1937c.
 ALA-D » Delta-aminolevulinic  Acid
         Dehydratase
   ALA » Delta-aminolevulinic  Acid

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