PB95-964003
EPA/ROD/R04-95/198
December 1994
EPA Superfund
Record of Decision:
FCX-Statesville Superfund Site,
Operable Unit 2, NC
11/22/1994
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FCX-STATESVILLE
SUPERFUND SITE
RECORD OF DECISION
OPERABLE UNIT TWO
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
NOVEMBER 1994
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DECLARATION
FOR
THE RECORD OF DECISION
SITE NAME AND LOCATION
FCX-Statesville
Statesville, Iredell County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Operable Unit Two Remedial
Action for the FCX-Statesville Superfund Site (the "Site") in
Statesville, Iredell County, North Carolina, chosen in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986 and, to the extent practicable, the
National Contingency Plan. The main objectives of the Operable
Unit Two Remedial Action will be to reduce the risks associated
with Site-related contamination in the surface soil, as well as
reduce the amount of total pesticides in the surface and subsurface
soil as a source of groundwater contamination. This decision is
based on the administrative record file for this Site.
The State of North Carolina concurs with the selected remedy for
Operable Unit Two. All comments submitted to EPA during the public
comment period, as well as EPA's responses to those comments, can
be found in Appendix A of this document.
ASSESSMENT OF THE SITE .
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Operable Unit Two Remedial Action addresses the soil
contamination at the Site. The major components of the Operable
Unit Two Remedial Action include:
* demolishing the existing buildings and structures, and
transporting, the demolition rubble to an appropriate
disposal facility;
* excavating approximately 6,945 cubic yards of
contaminated soil, and stockpiling the soil on-site in
preparation for treatment;
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* treating the contaminated soil on-site using thermal
desorption and base catalyzed decomposition;
* backfilling the excavated areas with the treated soil;
and
* regrading and seeding the Site with grass to minimize the
potential for erosion and to enhance the appearance of
the Site.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the Remedial
Action, and is cost-effective.
This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable, and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume of Site contaminants as a
principal element.
Richard D. Green, Associate Director Date
Office of Superfund and Emergency Response
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FCX-STATESVILLE
OPERABLE UNIT TWO
RECORD OF DECISION
TABLE OF CONTENTS
Description * Paffa
TABLE OF CONTENTS
I. SITE NAME, LOCATION, AND DESCRIPTION , 1
A. Introduction 1
B. Site Description 1
C. Topography .. 4
D. Geology/Hydrogeoloqy 4
E. Surface Water 4
F. Meteorology 5
G. Demography and Land Use 5
H. Utilities ..... 5
IX. SITE HISTORY AND ENFORCEMENT ACTIVITIES 5
A. Site History . 5
B. Enforcement Activities 6
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION ......... 6
IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY . 7
V. SUMMARY OF SOIL INVESTIGATION 8
Phase I Results -8
Phase II Results 10
VI. SUMMARY OF SITE RISKS 12
A. Chemicals of Concern 12
B. Exposure Assessment ... ..... 13
C. Toxicitv Assessment 13
D. Risk Characterization 14
Current Land Use 15
Future Land Use 15
E. Environmental (Ecological) Assessment 16
VII. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS . . 23
A. Action-Specific ARARs . . . 23
B. Location-Specific ARARs 23
C. Chemical-Specific ARARs . 23
VIII. REMEDIAL ACTION OBJECTIVES 24
IX. DESCRIPTION OF ALTERNATIVES 25
Alternative 1: No Action 25
Alternative 2: Limited Action 25
Alternative 3: Demolition of Buildings and Capping ... 25
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PCX-STATESVILLE
OPERABLE UNIT TWO
RECORD OP DECISION
TABLE OP CONTENTS
Description Page
Alternative 4: Soil Excavation and On-Site Treatment
Using Thermal Desorption and Base Catalyzed
Decomposition 25
Alternative 5: Soil Excavation and On-Site Treatment
Using Thermal Desorption and an alternate method
of treating off gases 25
Alternative 6: Soil Excavation and Off-Site Treatment
Using Incineration . . . 25
X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ..... 42
Threshold Criteria 43
Overall Protection of Human Health
and the Environment 43
Compliance with ARARs 43
Primary Balancing Criteria 43
Short-term Effectiveness 43
Long-term Effectiveness and Permanence 43
Reduction of Toxicity, Mobility, or Volume .... 43
Implement ability 43
Cost 43
Modifying Criteria . 44
State Acceptance 44
Community Acceptance 44
XI. THE SELECTED REMEDY 46
XII. STATUTORY DETERMINATION 47
Protection of Human Health and the Environment 49
Compliance with ARARs 49
Cost Effectiveness 49
Utilization of . Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable . . 49
Preference for Treatment as a Principal Element .... 49
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FCX-STATESVILLE
OPERABLE UNIT TWO
RECORD OF DECISION
TABLE OF CONTENTS
Description
LIST OF FIGURES
FIGURE DESCRIPTION PAGE NO.
1 Site Diagram (prior to the late 1960s) 2
2 Site Diagram (after the late 1960s) 1
3 Soil Sample Locations . «
4 DDT Distribution in Soil 11
5 Areas of Contaminated Soil to be Remediated . . . . . 3*-
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FCX-STATESVILLE
OPERABLE UNIT TWO
RECORD OF DECISION
TABLE OF CONTENTS
Description Papa
LIST OF TABLES
TABLE DESCRIPTION' PAGE NO.
1 Model for Calculating Doses, from
Dermal Contact with Soil 17
2 Model for Calculating Doses from Incidental
Ingestion of Soil. . . 19
3 Exposure Point Concentrations for
Chemicals of Concern (mg/kg) 20
4 Toxicity Values for Chemicals of Concern. ....... 21
5 Carcinogenic and Non-Carcinogenic Risk
Levels for Chemicals of Concern . .22
6 Analysis of Federal ARARs 26
7 Analysis of State of North
Carolina ARARs. 32
8 Soil Remediation Levels 35
9 Evaluation of Remedial Alternatives. 37
10 Cost Estimate for Alternative 4 48
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FCX-STATESVILLE OU2
PAGE 1
I. SITE NAME, LOCATION, AND DESCRIPTION
A. Introduction
The FCX-Statesville property is located at the intersection of
Phoenix Street and West Front Street (Highway 90) approximately 1.5
miles west of downtown Statesville. Beginning around 1940, Farmers
Cooperative Exchange (FCX) began operations as an agricultural
distribution center. These operations included the formulation,
repackaging, warehousing, and distribution of farm chemicals,
primarily pesticides and fertilizers, along with the milling and
sale of feed grains. The repackaging of liquid pesticides was
discontinued in 1966 and dust repackaging in 1969.
Testimony from previous employees indicates that 5,000-10,000
pounds of pesticides may have been buried on-site during the late
1960's or early 1970's. Pesticide contamination in the soil, as
well as pesticide and volatile organic compound (VOC) contamination
in the groundwater, have been identified at the Site since 1986.
B. Site Description
The Site is approximately 5.5 acres in size. The coordinates of
the Site are latitude 35° 47' 11" north, longitude 80° 54' 58" west.
The Site is bounded to the north by the Norfolk-Southern Railroad
and Burlington Industries (formerly Beaunit Mills), the Carnation
Milk Company property to the west, residential and small business
property along the south side of West Front Street, and a pre-
fabricated utility and sales lot on the east side of Phoenix
Street. Prior to the late 1960's, the main structures at the Site
included a U-shaped building used for pesticide operations, and
several buildings on the eastern half of the property used for the
milling and bagging of feed grains. A small office building was
also present near the southeastern corner of the property. Figure
1 shows the Site as it existed prior to the late 1960's.
During the late 1960's, most of the buildings on the property (with
the exception of the small office building) were demolished. Since
that time, several buildings and paved areas have been constructed
to replace the original structures. A large brick warehouse was
constructed around 1969-70, and a smaller, metal warehouse painted
blue was constructed in 1982. An asphalt parking lot was paved
between the warehouses and West Front Street. The majority of the
Site to the east of the- two warehouses is a gravelled area, and
contains a large reinforced concrete slab and smaller concrete
tractor trailor pads. Figure 2 shows the Site as it exists today.
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CARNATION /
MILK '
COMPANY
WAREHOUSE
AND DISTRIBUTION
RESIDENTIAL
AREA
FIOORB 1
SIT! DIAGRAM
(prior to lat* I960'*)
FCX-STATESV1LLE
STATESV1LLE. NORTH CAROLINA '»
APPROXIMATE SCALE
62.5 123
( IN fill )
I Inch - m II
&EPA
3
*
WO «PO
COO
loro A o
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CARNATION
COMPANY
COMPANY
RESIDENTIAL
AREA
FIOORE 2
SITB DIAGRAM
(after late 1960'a)
(SHOWING ON-SITE MONITORING WELLS)
FCX-STATESV1LLE
STATESVILLE. NORTH CAROLINA
APPROXIMATE SCALE
123 0 13.3 133
( IN ftET )
1 Inch - 1J5 ft.
o
HEX
9 - MONITORING NEUS
WAREHOUSE
OWER SECTION
C/l
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November 1994
FCX-STATESVILLE OU2
PAGE 4
C. Topography
The Site is situated in the Piedmont physiographic province in
western-central North Carolina. The Piedmont physiographic
province is characterized as gently rolling and sloping, with
slopes on-site ranging up to 1.5 percent. Slopes in the immediate
vicinity of the Site range from 2 to 6 percent. Elevations within
a four-mile radius of the Site range from 740 to 970 feet above
mean sea level.
D. Geology/Hydrocreolocrv
The Site lies within the geologic belt known as the Blue Ridge
Inner Piedmont Belt. The Blue Ridge-Inner Piedmont Belt generally
consists of metamorphic rocks including gneisses and schists, as
well as gradations of the two types. Most of. these rocks near the
surface have weathered into a layer of "overburden" overlying th-
fractured but relatively unweathered bedrock. The overburden
ranges in thickness from 15-40 feet at the Site, and consists et
saprolite and residual soils interspersed with unweathered
gneiss/schist, and to a lesser extent, alluvium. Graniti
intrusions are also common in the area of the Site. Soils in t:.--
general area of the Site belong to the Lloyd Association. The^-
soils, located along broad ridges with short side slopes, a:-
characterized as deep, well-drained soils with a subsoil of da:«
red clay.
Groundwater at the Site occurs in an unconfined-to-semiconf ir.- t
aquifer consisting of the overburden hydraulically interconnect '
with the underlying fractured bedrock: The saturated overburd.-:
serves as a groundwater reservoir which supplies water to tk
fractures, faults, and other secondary permeability features in t:...
bedrock. Approximate depth to groundwater in the saturat * '.
overburden in the vicinity of the Site generally ranges from 27
30 feet below land surface. During the wetter periods of the ye.i:
groundwater may intersect the ground surface and become overland
surface water flow.
E. Surface Water
On-site surface water drainage and flow patterns are genera:
controlled by topography and several man-made drainage structu:
constructed along West Front Street and Phoenix Street. Surf :
water flow is generally to the south into Free Nancy Creek, wh
converges with Third Creek approximately 1.5 miles southeast of
Site (two miles stream distance) . Third Creek flows in a easte:
direction for approximately 15 miles, where it empties into
South Yadkin River.
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FCX-STATESVILLE OU2
PAGE 5
F. Meteorology
The climate in Iredell County is classified as fairly mild, and is
influenced by the mountain ranges to the northeast, and the
Atlantic Ocean to the southeast. Prevailing winds are from the
southwest, although northeast winds do frequently occur in the
autumn. Relative humidity averages about 70 percent throughout the
year. Monthly total precipitation generally ranges from about 3
inches during October and November to about 5 inches during July
and August.
G. Demography and Land Use
The Site is located along an industrial corridor which stretches
along West Front Street. The area around the Site is characterized
by a combination of light/heavy industry, commercial, residential,
and institutional. The -estimated population within the five-mile
radius of the Site includes all of Statesville (18,622 in the 1980
census) and an estimated 9,500 living in Iredell County outside the
city limits. The population within the three-mile radius of the
Site includes about 90% of the city's population (about 17,000
people) and 2,440 county residents. .
H. Utilities
Electricity, telephone, as well as water and sewage connections
have been terminated since FCX declared bankruptcy in 1986.
Nevertheless, these utilities are available upon request.
II. SITE HISTORY AMD ENFORCEMENT ACTIVITIES
A. Site History
FCX began operating the Site as an agricultural supply distribution
center about 1940 and continued to operate the Site until declaring
bankruptcy in 1986. The Site served as a formulating, repackaging,
warehousing, and distribution center for pesticides, fertilizers,
and feed grains. The repackaging of liquid pesticides was
discontinued in 1966 and dust repackaging in 1969. As stated in
the Introduction, 5,000-10,000 pounds of the pesticides DDT, DDE,
and chlordane were allegedly disposed of on-site in two trenches,
buried under six feet of soil, and later covered with a reinforced,
8"-thick concrete slab and warehouse.
Previous investigations conducted prior to the Remedial
Investigation at the FCX Site have been conducted by Fred C. Hart
for Southern States Cooperative, by the North Carolina Department
of Human Resources (NCDHR) (now known as the North Carolina
Department of Environment, Health, and Natural Resources (NCDEHNR)
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FCX-STATESVILLE OU2
PAGE 6
Superfund Section), and by EPA-Region IV Emergency Response. The
following paragraphs briefly summarize the soil sample results of
these investigations.
The Fred C. Hart investigation in February 1986 resulted from a
pre-purchase environmental evaluation on behalf of Southern States
Cooperative. Five composite soil samples were collected to
investigate the soil for reported pesticide contamination.
Analytical results of the soil samples indicated the presence of
nine pesticides, most notably chlordane and DDT.
The NCDHR conducted a Site Inspection in May 1986. . Soil samples
were collected both on-site and off-site in the front yard of an
adjacent residence. Analytical results of the soil samples
indicated the presence of pesticides both on the FCX property as
well as on the adjacent property.
EPA-Region IV Emergency Response conducted emergency sampling
investigations at the Site in January 1989 and again in January
1990. Extensive exploratory borings were drilled through the main
warehouse concrete floor in an attempt to locate the alleged
pesticide trenches. Efforts to locate the pesticide trenches were
unsuccessful.
B. Enforcement Activities
On September 17, 1986, FCX filed a voluntary petition under the
provisions of Chapter 11 of the United States Bankruptcy Code. The
EPA, NCDEHNR, and FCX entered into a settlement agreement, whereby
FCX established a trust to be used to remediate the Site.
The FCX-Statesville Site was evaluated using the Hazard Ranking
System (HRS) . The Site was proposed for inclusion on the National
Priorities List (NPL) on June 24, 1988, and was finalized on the
NPL on February 21, 1990. EPA-Region IV initiated RI/FS field
activities at the Site in June 1991 with the aid of EPA's
Environmental Services Division, and EPA's Alternative Remedial
Contract (ARCs) contractor, Roy F. Weston.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Pursuant to Section 113 (K) (2) (B) (i-v) and Section 117 of CERCLA 42
U.S.C. § 9613 (K) (2) (B) (i-j) , and 42 U.S.C. § 9617, the Community
Relations Plan and the RI/FS Reports were made available to the
public in the Administrative Record located both in the Information
Repository maintained at the EPA Docket Room in Region IV and at
the Iredell County Library in Statesville, North Carolina. Fact
sheets notifying local citizens about the availability of these
documents, explaining the RI/FS process, and summarizing site-
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FCX-STATESVILLE OU2
PAGE 7
related activities were sent out in May 1991 and April 1993. A
public meeting was held on May 31, 1991 to inform citizens about
upcoming RI activities.' Notices of the Proposed Plan public
meeting were published in the Record and Landmark and the Iredell
County News on July 5, 1994. A 30-day public comment period was
held from July 5, 1994 to August 4, 1994. The Proposed Plan public
meeting was held on, July 11, 1994 where representatives from EPA
answered questions about the Site and the remedial alternatives
under consideration. The public requested an extension of the
comment period during the meeting. Based on this request, EPA
extended the comment period through September 3, 1994.
Representatives from EPA have met with individual citizens and
citizen groups on numerous occasions over the past several years to
obtain their input and to keep them informed. The local citizens
group "Citizens for a Clean Environment" applied for and were
awarded a Technical Assistance Grant (TAG) on March 23, 1992.
IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
As with many Superfund sites, the FCX-Statesville Site is complex.
For this reason, EPA currently believes that the remediation of the
Site will be accomplished most effectively by implementing three
phases of cleanup, referred to as "operable units".
Each operable unit requires a separate RI/FS, Risk Assessment,
Proposed Plan, and Record of Decision. The objectives of the three
operable units (OUs) at the Site are:
OU One: Address the groundwater contamination beneath the
PCX property and to the south of the FCX property;
OU Two: Address the pesticide soil contamination on the FCX
property; and
OU Three: Address all other contamination associated with the
property which is currently owned and operated by
Burlington Industries.
The Record of Decision for OU One was signed by the EPA-Region IV
Acting Regional Administrator in September 1993. EPA is currently
developing the work plan to design the groundwater pump-and-treat
system for OU One. Once the Regional Administrator has signed the
Record of Decision for OU Two, EPA will hire a contractor to
develop a work plan to design the soil remediation system. On
April 25, 1994, EPA held a public meeting in Statesville to
initiate the Remedial Investigation field activities for OU Three.
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November 1994
FCX-STATESVILLE 002
PAGE 8
Once this investigation is complete, EPA will write the Record of
Decision for OU Three to address the contamination associated with
the property currently owned and operated by Burlington Industries.
V. SUMMARY OF SOIL INVESTIGATION
Soil samples were collected and analyzed throughout the Remedial
Investigation (RI) in order to fully characterize the nature and
extent of the soil contamination at the Site. All of the soil
samples collected during the RI were analyzed for Target Analyte
List (TAL) metals, cyanide, Target Compound List (TCL) VOCs, Semi-
Volatile Organic Compounds (SVOCs), poly-chlorinated biphenyls
(PCBs) , and pesticides. Numerous exploratory borings were also
drilled during the RI in an attempt to locate the alleged pesticide
burial trenches.
During the Phase I RI conducted in June 1991, one hundred and
eighty-seven (187) surface and subsurface soil samples were
collected from three areas on and around the PCX property. Area 1
includes the residential area south of Front Street, the Carnation
property, and locations adjacent to and east of Phoenix Street.
Area 2 includes those portions of the PCX property not covered by
the warehouses, as well as locations adjacent to the railroad
tracks. Area 3 includes those locations presently under the
warehouses. Figure 3 shows the soil sample locations. During the
Phase II RI conducted in June 1992, nine (9) soil samples were
collected and analyzed to provide additional information regarding
surface and subsurface soil contamination at the Site.
Phase I Results
A number of metals were detected in the soil samples during the
Phase I RI, most commonly aluminum, iron, chromium, lead, vanadium,
barium, magnesium, potassium, nickel, calcium, zinc, copper, and
cobalt. Most of these metals, based on their widespread occurrence
and geological/mineralogical associations, are probably present at
naturally-occurring concentrations. However, chromium and lead
were detected in several samples at concentrations significantly
higher than naturally-occurring or background concentrations. The
elevated levels of chromium and lead in these samples are not
thought to be associated with former FCX operations.
Thirteen pesticides were identified in surface and subsurface soil
samples collected and analyzed during the Phase I RI. These
pesticides included DDT, ODD, DDE, pentachlorophenol, alpha-
chlordane, gamma-chlordane, dieldrin, endrin, heptachlor,
heptachlor epoxide, alpha-BHC, gamma-BHC (lindane) , and aldrin.
The most widespread pesticides detected in the soil were the
compounds of the DDT family (4,4'-DDT and its degradation or
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SOIL SAMPLE LOCATIONS AND DEPTHS
FCX-STATESVILLE REMEDIAL INVESTIGATION
STATESVILLE. NORTH CAROLINA
JUNE 1991 TO SEPTEMBER 1991
( H rttr )
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November 1994
FCX-STATESVILLE OU2
PAGE 10
transformation products, 4, 4'-DDD and 4, 4'-DDE) . DDT (4,4'-DDT) was
detected in fifty-seven (57) out of one hundred eighty-seven (187)
samples collected. Figure 4 shows the distribution of DDT in the
soil, including the detection boundary, as well as the 1,000 ug/kg,
10,000 ug/kg, and the 100,000 ug/kg isoconcentration boundaries.
The highest concentration of DDT detected in the soil during the
Phase I RI, 830,000 ug/kg, was detected from 12-16 inches below the
surface at sample location FS-319-SLB.
The soil sample results from the Phase I RI indicated presumptive
evidence of dioxin and furans. As a result, an additional forty-
three (43) soil samples were collected from twenty-two sample
locations and analyzed for dioxin and furans. Dioxin was present
in the soil beneath the upper warehouse at Toxicity Equivalent
Quotient (TEQ) concentrations below one part-per-billion. EPA also
collected groundwater samples from a representative number of the
on-site monitoring wells to determine if dioxin or furans had
leached from the soil into the groundwater. None of the
groundwater samples revealed the presence of dioxin or furans.
A number of extractable organic compounds were identified in the
soil samples collected and analyzed during the RI. Nineteen (19)
of the twenty-one (2i) extractable organic compounds were
polycyclic aromatic hydrocarbons (PAHs) , including pyrene,
fluoranthene, anthracene, perylene, phenanthrene, benzo-
(b/k)fluoranthene, chrysene, benzo(a)anthracene, benzo(a)pyrene,
indeno(1,2,3-CD)pyrene, and dibenzo(A,H)anthracene. The elevated
levels of PAHs in the soil are not thought to be associated with
former PCX operations, but with the crossties underlying the
railroad tracks next to the Site. In addition to the extractable
organic compounds mentioned in the previous paragraphs, forty (40)
additional extractable compounds (listed as mostly unidentified
compounds) were detected'during the Phase I RI.
Twelve (12) purgeable organic compounds were also detected in soil
samples collected and analyzed during the Phase I RI. Of these
twelve compounds, trichloroethene and tetrachloroethene were the
most frequently detected in the soil. The distribution of these
two compounds in the soil appears to coincide with the plume of
trichloroethene and tetrachloroethene in the groundwater. Other
purgeable organic compounds identified at small concentrations in
the soil during the RI included acetone, 1,2-dichloroethene,
tetrahydrofuran, chloroform, total xylene, ethyl benzene,
chlorobenzene, pinene, trimethylcyclohexane, and ethylmethyl-
cyclohexane.
Phase II Results
Six of the nine soil samples collected during the Phase II RI were
analyzed to provide total organic carbon (TOO values for
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FCX-STATESVILLE OU2
PAGE 12
evaluating the fate and transport of the Site contaminants. Two
soil samples, FS2-T11-SLA and FS2-T11-SLB, were collected from the
20-25 foot depth interval and the 30-35 foot interval,
respectively. Both samples contained DDT, DDD, DDE, and gamma -
chlordane at concentrations up to 20 ug/kg, as well as several BHC
isomers, endrin, and heptachlor at concentrations below 20 ug/kg.
VI. SUMMARY OF SITE RISKS
The Baseline Risk Assessment (BRA) was developed to identify the
potential threats to public health and the environment posed by the
Site under current and future conditions, assuming that no remedial
actions take place, and that no restrictions are placed on future
use of the Site. The results of the BRA indicate that actual or
threatened releases from the Site, if not addressed, may present an
imminent and substantial endangerment to human health and the
environment.
The BRA evaluated the potential risks from exposure to contaminated
surface soil, surface "water, sediment, and groundwater. Any
potential risks associated with contaminated groundwater will be
addressed with Operable Units One and Three. However, the specific
objective of Operable Unit Two is to address contaminated soil on
the PCX property. The following sections summarize the Site-
related risks as they relate to the following topics: A) chemicals
of concern, B) exposure assessment, C) toxicity assessment, D) risk
characterization, and E) environmental (ecological) assessment.
A. Chemicals of Concern
In order to identify potential chemicals of concern for the Site,
the chemicals present in Site samples were screened using
comparisons with ambient or background concentrations, essential
nutrient concentrations, as well as concentration-toxicity
criteria. If a chemical of potential concern was determined to
contribute significantly to an unacceptable risk, and was not
screened out using these comparisons, then it was considered to be
a chemical of concern at the Site.
The chemicals of concern identified in the soil at the FCX-
Statesville Site included arsenic, beryllium, benzo(a)pyrene,
dibenzo(a,h)anthracene, benzo(b,k)fluoranthene, pentachlorophenol,
and dioxin. Several of these chemicals of concern, such as the
inorganics arsenic and beryllium, are not thought to be associated
with former FCX operations. Therefore, these inorganics will not
be targeted for remediation during Operable Unit Two. Likewise,
the following PAHs, benzo(b,k)fluoranthene, benzo(a)pyrene,
dibenzo(a,h)anthracene, are not thought to be associated with
former FCX operations. These PAHs are "creosote-related" compounds
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FCX-STATESVILLE OU2
PAGE 13
which are commonly found in the crossties which underly railroad
tracks. Therefore, these PAHs will not be targeted for remediation
during Operable Unit Two.
Dioxin was identified in the surface soil at levels less than one
part-per-billion (or 1.0 ug/kg) TEQ. The draft dioxin reassessment
document has recommended a minor relaxation of the Cancer Slope
Factor (CSF) for Dichloro-Diphsdyl-Trichloromethane (TCDD) and has
not recommended a RfD" for use in evaluation of non-cancer
endpoints. Using the new CSF and standard default daily exposure
assumptions, 1.0 ug/kg of dioxin TEQs in soil equates to an upper
bound risk estimate of about 10"4. The 1.0 ug/kg level will likely
continue to be considered by EPA as the residential protective
level during the reassessment finalization period to be completed
in September 1995. For this reason, dioxin will not be targeted
for remediation during Operable Unit Two.
B. Exposure Assessment
The exposure assessment uses the description of the Site and the
soil contamination characterized during the Remedial Investigation
to identify potential exposure pathways for the contaminants of
concern.
The exposure pathways that were evaluated under the current land
use conditions were: the dermal contact and incidental ingestion of
surface soil by children and adults living in Area 1; and the
dermal contact and incidental ingestion of surface soil by an
adolescent child trespassing into Areas 2 and 3.
The exposure pathways that were evaluated under the future land use
conditions were: the dermal contact and incidental ingestion of
surface soil by children and adults living on-site (assuming the
existing buildings and parking lots were removed); the dermal
contact and incidental ingestion of surface soil by the on-site
worker (assuming the existing buildings remain) ,- and the dermal
contact and incidental ingestion of surface soil by the on-site
worker (assuming the existing buildings were removed).
C. Toxicitv Assessment
Under current EPA guidelines, the likelihood of adverse effects to
occur in humans from carcinogens and noncarcinogens are considered
separately. Cancer slope factors have been developed by EPA for
estimating excess lifetime cancer risks asscociated with exposure
to potentially carcinogenic chemicals. Slope factors, which are
expressed in units of (kg-day/mg), are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to provide an
upperbound estimate of the excess lifetime cancer risk associated
with exposure at that intake level. The term "upperbound" reflects
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PAGE 14
factor. Use of this approach makes underestimation of the actual
cancer risk highly unlikely. Cancer potency factors are derived
from the results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals that are likely to be
without risk of adverse effect. Estimated intakes of chemicals
from environmental media can be compared to the RfD. RfDs are
derived from human epidemiological studies, or animal studies to
which uncertainty factors have been applied. These uncertainty
factors help ensure that the RfDs will not underestimate the
potential for adverse noncarcinogenic effects to occur.
D. Risk Characterization
The . risk characterization step of the risk assessment process
integrates the toxicity and exposure assessments into quantitative
and qualitative expressions of risk. The output of this process is
a characterization of the Site-related, potential carcinogenic and
noncarcinogenic health effects.
Carcinogenic risk is calculated using the following equation: Risk
= GDI X SF, where GDI = chronic daily intake averaged over 70 years
(mg/kg/day) , and SF = slope factor expressed as (mg/kg/day)-1.
Carcinogenic risk is expressed as the incremental probability of an
individual developing cancer over a lifetime as a result of
exposure to one or more cancer-causing substances. These
probabilities are'generally expressed in scientific notation (e.g.,.
1X1CT6 or IE'6).' An excess lifetime cancer risk of 1 X 10'6
indicates that, as a reasonable maximum estimate, an individual has
a 1 in 1,000,000 chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions at a site.
EPA has developed guidelines for carcinogen risk characterization.
These guidelines discuss weighing the evidence that a substance is
a carcinogen and classifying the suspect chemical into one of the
five groups:
* Group A - Human Carcinogen
* Group B - Probable Carcinogen
* Group C - Possible Human Carcinogen
* Group D - Not Classified as a Human Carcinogen
* Group E - Evidence of Noncarcinogeneity for Humans
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The potential risk for noncarcinogens, better known as the hazard
quotient or HQ, is presented as the ratio of the GDI to the
reference dose (RfD) for each chemical. A hazard index or HI is
the sum of the HQs for a particular exposure pathway, or the sum of
the HQs across multiple exposure pathways for an individual
receptor. The HI is useful as a reference point for gauging if the
potential exists for adverse health effects to occur from a
particular exposure pathway (s) . When the calculated HI exceeds 1.0
for multiple contaminants or multiple exposure pathways, there may
be concern for potential adverse health effects.
Table 1 shows the model used for calculating doses from the dermal
contact of contaminated surface soil, including the exposure
assumptions associated with the surface soil at the Site. Table 2
shows the model used for calculating doses from the incidental
ingestion of contaminated surface soil, including the exposure
assumptions associated with the surface soil at the Site. Table 3
shows the exposure point concentrations for the chemicals of
concern for the Site. Table 4 summarizes the carcinogenic and
noncarcinogenic toxicity criteria for the Site-related contaminants
of concern in the soil.
Current Land Use
For current residents living in close proximity to the Site, no
carcinogenic or noncarcinogenic risks were identified at levels
greater than 1E-4 (l-in-10,000) or with an HI greater than 1.0.
This means that the probability of a current resident (child or
adult) having adverse 'health effects from dermal contact or
ingestion of cancer-causing contamination in the soil in areas 1,
2, or 3 is less than one-in-ten-thousand (1E-4).
Future Land Use
For future residents living on-site in areas 1 and 2, carcinogenic
risks were identified for both child and adult residents at levels
which were equal to or in excess of 1E-4. Hazard Index values for
noncarcinogenic contaminants were also identified for the future
resident (both child aged 1-6 and adult) in excess of 1.0. These
risk values mean that the probability of a future resident having
adverse health effects from cancer-causing contamination at the
Site is greater than 1-in-ten-thousand. The next two paragraphs
summarize the risks to future residents living on the Site.
The total carcinogenic risk for the future child and adult resident
from the dermal contact and ingestion of contaminated surface soil
was 4E-4 (4-in-lO,000). A 4E-4 risk level exceeds the risk range
from 1E-4 to 1E-6, which EPA-Region IV considers to be acceptable
for most hazardous waste sites. The carcinogenic risk for the
child resident aged 1-6 from dermal contact and ingestion of
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contaminated surface soil was 2E-4 (2-in-10,000) . The carcinogenic
risk for the .child resident aged 7-12 from dermal contact and
ingestion of contaminated surface soil was 1E-4. The carcinogenic
risk for the adult resident from dermal contact and ingestion of
contaminated surface soil was 1E-4.
The carcinogenic risk for the future on-site worker (assuming the
existing buildings remain) from the dermal contact or ingestion of
contaminated surface soil at the Site was 1E-5 (l-in-100,000).
The carcinogenic risk for the on-site worker (assuming the
buildings are removed) from the dermal contact and ingestion of
contaminated surface soil at the Site was 4E-5 (4-in-100,000).
In evaluating potential risks to future on-site workers working
within the existing warehouses, air monitoring was conducted in
three locations within the warehouses during two consecutive 24-
hour periods. The results were evaluated against the Occupational
Safety and Health Administration (OSHA) established limits. These
federal limits are referred to as permissible exposure limits
(PELs) determined with the time weighted average (40 hr/week, 8
hr/day scenario), which are referenced criteria for any EPA
remedial activity. None of the air sample data collected and
analyzed from the Site exceeded the PELs.
The total noncarcinogenic risk for the future child and adult
resident living on-site (assuming the existing buildings are
removed) was 3.6. The noncarcinogenic risk for the future child
resident aged 1-6 from the dermal contact and ingestion of
contaminated soil was 1.4. The noncarcinogenic risk for the future
child resident aged 7-12 from the dermal contact and ingestion of
contaminated surface soil was 5.3. The noncarcinogenic risk for
the future resident living on-site from dermal contact and
ingestion of contaminated surface soil was 1.4. Table 5 shows the
carcinogenic and non-carcinogenic risk levels for the exposure
pathways evaluated.
E. Environmental (Ecological) Assessment
Potential risks to environmental receptors at or near the Site were
evaluated based on Site sampling data and a review of the toxicity
of the chemicals of potential concern to ecological receptors. Use
of the Site by terrestrial receptors such as birds and small
mammals, particularly the area presently covered by the brick
warehouses and paved parking lot, was considered unlikely given the
lack of trees or other vegetative cover at the Site.
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TABLE 1
Model for Calculating Doses from
Dermal Contact with Soil
Soil Dermal Absorption Dose CS x CF x SA x AF x ABS x EF x ED
(mg/kg-day) = BW x AT
Where:
CS = Chemical concentration in soil (mg/kg)
CF = Conversion factor (10~6 kg/mg)
SA = Skin surface area available for contact' (cmVday)
AF = Soil to skin adherence factor (mg/cm2)
ABS = Dermal absorption factor (unitless)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
BW = Body weight (kg)
AT = Averaging time (days)
Assumptions:
CS = Upper 95% confidence limit of the mean concentration
in soil.
SA = 2,125 cmVday for the child (1-6) resident. It
represents the 50th percentile surface area of the
arms, hands, lower legs, and feet (50% of the
exposure events) and forearms and hands (50% of the
exposure events) of a 1-6 year old (Anderson, 1985) .
= 4,453 cmVday for the child (7-12). It represents
the 50th percentile surface area of the arms, hands,
lower legs, and feet (100% of the exposure events)
(Anderson, 1985) .
= 4,145 cm2/day for the adult resident. It represents
the 50th percentile surface area of the arms, hands,
lower legs, and feet (50% of the exposure events) and
forearms and hands (50% of the exposure events) of an
adult male (EPA, 1992) .
= 1,980 cm2/day for the future worker. It represents
the 50th percentile surface .area of the forearms and
hands of an adult male (EPA, 1992) .
AF = 1 mg/cm2, soil adherence factor (EPA, 1992b)
ABS = 0.01 - Organic compounds (EPA, 1992a)
0.001 - Inorganic compounds (EPA, 1992a).
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TABLE 1 (Continued)
Model for Calculating Doses from
Dermal Contact with Soil
Soil Dermal Absorption Dose CS x CF x SA x AF x ABS x EF x ED
(mg/kg-day) = BW x AT
Where:
CS = Chemical concentration in soil (mg/kg)
CF = Conversion factor (10~6 kg/mg)
SA = Skin surface area available for contact (cm2/day)
AF = Soil to skin adherence factor (mg/cm2)
ABS = Dermal absorption factor (unitless)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
BW = Body weight (kg)
AT = Averaging time (days)
EF = 45 days/year for trespasser (approximately once a
week).
320 days/year for child (7-12) trespasser/resident.
350 days/year for the child and adult residents (EPA,
1991a) .
250 days/year for the future worker (EPA, 1991a) .
ED 6 years for the child (1-6) resident (EPA, 1991a).
6 years for the current child (7-12)
trespasser/resident (EPA, 1991a).
25 years for the on-site worker (EPA, 1991a).
= 18 years for the adult resident (EPA, 1991a).
BW = 15 kg for the child resident (EPA, 1991a) .
27 kg for the current child (7-12)
trespassers/resident (EPA, 1991a)
70 kg for the adult resident (EPA, 1991a) .
70 kg for the future worker (EPA, 1991a).
AT = Exposure duration (years) x 365 days/year for
evaluating noncancer risk.
= 70 years x 365 days/year for evaluating cancer, risk
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TABLE 2
Model for Calculating Doses from
Incidental Zngestion of Soil
Soil Ingestion Dose CS x IR x CF x EF x ED
(mg/kg-day) = BW x AT
Where:
CS = Chemical concentration in soil (mg/kg)
IR = Soil ingestion rate (mg/day)
CF = Conversion factor (10~6 kg/mg)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
BW = Body weight (kg)
AT = Averaging time (days)
Assumptions:
CS = Upper 95% confidence limit of the mean concentration
in soil.
IR = 200 mg/day for the child (1-6) resident (EPA, 1991a!
100 mg/day far the child (7-12) (EPA, 1991a).
100 mg/day for the adult resident (EPA, 1991a).
50 mg/day for the future worker (EPA, 1991a).
EF = 45 days/year for trespasser (EPA, 1991a)
320 days/year for the child (7-12) offsite resident
(EPA, 1991a)
350 days/year for the children and adult residents
(EPA, 1991a).
250 days/year for the future worker (EPA, 1991a)..
ED 6 years for the child (1-6) resident (EPA, 1991a).
6 years for the current child (7-12) (EPA, 1991a).
18 years for the adult resident (EPA, 1991a).
= 25 years for the future on-site worker (EPA, 1991a!
BW = 15 kg for the child resident (EPA, 1991a).
27 kg for the current child (7-12) trespassers (EPA.
1995)
70 kg for the adult resident (EPA, 1991a).
70 kg for the future worker (EPA, 1991a).
AT = Exposure duration (years) x 365 days/year for
evaluating noncancer risk.
= 70 years x 3&5 days/year for evaluating cancer risk
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TABLE 3
EXPOSURE POINT CONCENTRATIONS
FOR CHEMICALS OF CONCERN (MG/KG)
CHEMICAL OF
CONCERN
ARSENIC
BERYLLIUM
BENZO(A)PYRENE
DIBENZO(A,H)-
ANTHRACENE
BENZO(B,K)-
FLUORANTHENE
PENTACHLORO-
PHENOL
DIOXIN (TEQ)
EXPOSURE POINT CONCENTRATIONS (MG/KG)
AREA 1
2.7
0.7
0.8
0.6
I'.l
.000026
AREA 2
6.6
0.7
1.2
0.5
2.4
.000045
AREA 3
0.5
.....
0.6
34
.00071
) - None Detected
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PAGE :
TABLE 4
TOXICITY VALUES FOR
CHEMICALS OF CONCERN
Arsenic
Beryllium
Benzo(B «nd/or K)Fluoranthene
Benzo-A-Pyrene
Dibenzo(A,H)Anthracene
Penlachlorophenol
Oral Slope
Factor
(ing/kg/day)-1
1.75E+00
4.30E+00
7.3E+00
7.3E+00
7.3E-fOO
I.20E-OI
Dermal Slope
Factor
8.75
2.15E+01
1.46E+1
1.46E+1
1.46E+1
2.4E-1
Ref.
IRIS,
1992
IRIS,
1992
mis.
1992
IRIS,
1992
Oral HID
(mg/kg/day)
3.00E-04
5.00E-03
NTV
NTV
NTV
3.00E-02
Dermal
RfD
6E-5
1E-3
1.5E-2
Ref.
IRIS,
1992
IRIS,
1992
IRIS,
1992
Inhalation Slope
Factor (me/kg/day)
1.50E+01
8.40E+001
NTV
NTV
NTV
NTV
Ref.
mis,
1992
mis,
1992
Inhalation RfD
(mg/kg/day)
NTV
NTV
NTV
NTV
NTV
Ref.
'Converted from a unit risk assuming the ingestion of 2 liters of drinking water per day and a body weight of 70kg (EPA, 1992)
NTV = No Toxicity Value
Dermal RfDi/SFs are derived
Absorption Factors (ABS): U.2 - Inorganics, 0.8 - Volatile Organics, 0.5 - Semi-volatile Organics/Pesticides/PCBs
Dermal RfD = Oral RfD x ABS
Dermal Slope Factor = Oral SF/ABS
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TABLE 5
CARCINOGENIC AND NON-CARCINOGENIC RISK
LEVELS FOR CHEMICALS OF CONCERN
LAND USE
CURRENT
FUTURE
EXPOSURE PATHWAY
CHILD AGED 1-6
CHILD AGED 7-12
ADULT
CHILD AGED 1-6
CHILD AGED 7-12
ADULT
CARCINOGENIC
RISK
3x1 0"5'
IxlCT5
ixi
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Remedial Investigation. Due to the presence of the volatile
organic compounds in the surface water and sediment, additional
sampling of the surface water pathways around the Site is currently
underway as part of the Operable Unit Three Remedial Investigation
to determine if remedial action is warranted.
VIZ. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Section 121(D) of CERCLA, as amended by SARA, requires that
remedial actions comply'with requirements or standards set forth
under Federal and State environmental laws. The applicable or
relevant and appropriate requirements (ARARs) that must be complied
with are those that are (A) action-specific, (B) location-specific,
or (C) chemical-specific at the Site.
ARARs are used to determine the appropriate extent of Site cleanup,
to scope and formulate remedial action alternatives, and to govern
the implementation and operation of the selected action. "To be
considered" materials (TBCs) are non-promulgated, non-enforceable
advisories, guidelines, or criteria issued by federal or state
governments (e.g., reference doses and carcinogenic potency
factors) that may be useful for developing remedial action
alternatives or for determining what is protective to human health
and the environment. This section examines the cleanup criteria
associated with the contaminants identified during the RI/FS and
the environmental media contaminated.
A. Action-Specific ARARs
Action-specific requirements set controls or restrictions on the
design, performance, and other aspects of implementation of
specific remedial activities. A retained alternative must conform
with all ARARs unless a statutory waiver is invoked.
B. Location-Specific ARARs
Location-specific ARARs are design requirements or activity
restrictions based on the geographical or physical positions of the
Site and its surrounding area.
C. Chemical-Specific ARARs
Chemical-specific ARARs include those laws and regulations
governing the release of materials possessing certain chemical cr
physical . characteristics, or containing specified chemical
compounds. These requirements generally set health or risk-based
concentration limits or discharge limitations in various
environmental media for specific hazardous substances,
contaminants, and pollutants.
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VIZI. REMEDIAL ACTION OBJECTIVES
The Remedial Investigation and Baseline Risk Assessment indicate
that elevated levels of the Site-related contaminants DDT, ODD,
gamma-BHC (lindane), endrin, dieldrin, chlordane, and penta-
chlorophenol are present in the soil at the Site. The Operable
Unit Two Remedial Action will address this pesticide contamination
by: 1) reducing levels of pentachlorophenol in the surface soil
(top one foot) to 3.2 parts per million based on the 10"6 risk level
for dermal contact and ingestion, and 2) to reduce the amount of
total pesticides in the surface and subsurface soil to one parts
per million as a source of groundwater contamination.
Elevated levels of arsenic, beryllium, benzo(a)pyrene,
dibenzo(a,h)anthracene, and benzo (b,k) f luoranthene were identified
in the soil at the Site; however, EPA does not believe that these
chemicals are associated with former PCX operations. Dioxin was
also identified in the soil at levels below EPA's- normal
remediation level of one part per billion (ppb). Therefore, EPA
does not plan to remediate these chemicals.
EPA has established the remediation level for pentachlorophenol in
the surface soil based on the 10"6 risk level." EPA has established
a cleanup level for total pesticides in the surface and subsurface
soil based on the following rationale. Pesticide application has
been a widespread activity for a number of years because North
Carolina is a heavily agricultural state. Normal agricultural
pesticide usage has resulted in observed background pesticide
levels in the one part per million (ppm) range.
These field observations are also supported by suggested
application rates. For example, the Water Resources and Research
Institute (WRRI) Report No. 60, "Contamination of Surface and
Ground Water with Pesticides Applied to Cotton" indicates that in
1972 the standard application rate for DDT and methyl parathion was
1 Ib/acre and for toxaphene was 2 Ibs/acre. These applications
were made twelve (12) times per growing season. Assuming an
application rate of 2 Ibs/acre and a till depth of 6 inches (and
uniform mixing) this would result in a concentration of 1 ppm (soil
density of 4,000,000 Ibs. weight for one acre of soil one ft. deep
was also assumed). Considering this and the fact that, for this
Site, any direct contact to soil at this level is well within EPA's
acceptable risk range, a total-pesticides concentration of one ppm
is being used as a performance standard for this ROD.
EPA acknowledges that an estimated 1.6 percent of the total
pesticides in the surface and subsurface soil at the Site are not
targeted for excavation, and may leach into the groundwater at
levels above the remediation levels established in the Operable
Unit One Record of Decision. For this reason, EPA and the State
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believe it is important to install a groundwater pump-and-treat
system, as well as continue monitoring the groundwater as part of
the Operable Unit One Remedial Action.
XX. DESCRIPTION OF ALTERNATIVES
The six remedial alternatives developed to address soil
contamination on the FCX property are shown listed below with a
brief summary.
Alternative 1: No Action
Alternative 2: Limited Action - includes property deed
restrictions and limited paving of areas around the
warehouses.
Alternative 3: Demolition of buildings and paving of all areas
with soil contamination. Property deed restrictions would be
imposed.
Alternative 4: Demolition of buildings, contaminated soil is
excavated, stockpiled, and treated on-site using Thermal
Desorption and Base Catalyzed Decomposition. Treated soil is
backfilled on-site.
Alternative 5: Demolition of buildings, contaminated soil is
excavated, stockpiled, and treated on-site using Thermal
Desorption and alternate method of treating offgases. Treated
soil is backfilled -on-site.
Alternative 6: Demolition of buildings, contaminated soil is
excavated, stockpiled, and transported off-site for treatment
at an approved RCRA incineration facility. Clean soil would
be brought to the site to replace excavated soil.
An analysis of the potential Federal action-, location-, and
chemical-specific ARARs is provided in Table 6. An analysis of the
potential State action-, location-, and chemical-specific ARARs is
provided in Table 7.
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TABLE 6
Analysis of Federal ARARs
Standard, Requirement,
Criteria, or Limitation
Regulatory
Citation
Description
Justification
Comments
Resource Conservation and Recovery Act
Chemical-Specific ARARs
Identification and Listing of
Hazardous Waste
40 CFR Part 261
Defines those solid wastes which are subject to
regulation as hazardous waste under 40 CFR
Parts 262-270.
Applicable to remedial actions
involving solid waste (soil) removal in
the identification of wastes and
application of other action specific
ARARs.
Resource Conservation and Recovery Act (continued)
Action-Specific ARARs
Requirements for hazardous
waste generators
Requirements for transporters of
hazardous waste
40 CFR Part 262
Subparts A,B,C,D
40 CFR Part 263
Subparts A.B.C
Establishes standards for generators of hazardous
wastes.
Establishes standards which apply to transporters
of hazardous waste within the United States if
the transportation requires a manifest under 40
CFR Part 262.
Applicable to remedial actions
involving removal of hazardous waste.
Applicable to remedial actions
involving removal of hazardous waste.
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TABLE 6 (Continued)
Analysis of Federal ARARs
Standard, Requirement,
Criteria, or Limitation
Requirements for hazardous
waste treatment, storage, and
disposal (TSD) facilities
Land Disposal Restrictions
Clean Water Act (CWA)
Chemical-Specific ARARs
Water quality criteria
Action-Specific ARARs
Regulatory
Citation
40 CFR Part 264
Subpart L
Subpart M
Subpart N
Subpart X
40 CFR Part 268
CWA Part 303
40 CFR Part 131
Description
Regulates owners and operators of facilities that
store or treat hazardous waste in piles.
Regulates owners and operators of facilities that
treat or dispose of hazardous waste in land
treatment units.
Regulates owners and operators of facilities that
dispose of hazardous waste in landfills.
Regulates owners and operators of facilities that
treat, store, or dispose of hazardous waste in
miscellaneous units.
Identifies hazardous wastes that are restricted
from land disposal
Establishes water quality criteria based on the
protection of human health and aquatic life.
Justification
Comments
Applicable to remedial activities
requiring the formation of waste piles.
Applicable to remedial activities
requiring the formation of land
treatment units.
Applicable to remedial activities
requiring the disposal of hazardous
waste in landfills.
Applicable to remedial activities
requiring thermal treatment of
hazardous waste in a miscellaneous
unit.
Applicable to remedial actions
involving removal of hazardous wastes
(e.g., soil excavation)
Applicable to remedial actions
involving discharge of water to a
surface water body.
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TABLE 6 (Continued)
Analysis of Federal ARARs
Standard, Requirement,
Criteria, or Limitation
National Pollutant Discharge
Elimination System (NPDES)
requirements
National pietreatment standard
for indirect discharge to a
POTW
Technology-based effluent
limitations
Regulatory
Citation
CWA Part 402
40 CFR Part 125
CWA Part 307(b)
40 CFR Part 403
CWA Part 301(b)
Description
Requires permit for effluent discharge from any
point source into surface waters of the United
States.
Establishes standards to control pollutants which
pass through or interfere with treatment processes
in public treatment works which may
contaminate sewage sludge.
Establishes guidelines to determine effluent
standards based on the best available technology
(BAT) economically achievable.
Justification
Comments
Applicable to remedial actions
involving discharges to surface waters.
Applicable to discharge of water into
local POTW.
Applicable to aqueous effluent from
remedial processes.
Safe Drinking Water Act (SDVVA)
Chemical-Specific ARARs
National Primary Drinking
Water Standards
National Secondary Drinking
Water Standards
40 CFR Part 141
40 CFR Part 143
Establishes health-based enforceable standards
for public water systems (maximum contaminant
levels (MCLs)).
Establishes aesthetic-based, non-enforceable
guidelines for public water systems (secondary
maximum contaminant levels (SMCLs)).
Applicable to remedial actions
involving in-place treatment of soils.
Applicable to remedial actions
involving in-place treatment of soils.
Clean Air Act (CAA)
Chemical-Specific ARARs
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TABLE 6 (Continued)
Analysis of Federal ARARs
Standard, Requirement,
Criteria, Or Limitation
National Ambient Air Quality
Standards (NAAQS)
National Emission Standards for
Hazardous Air Pollutants
(NESHAP)
Regulatory
Citation
40 CFR Part 50
40 CFR Part 61
Description
Establishes ambient air quality standards for
classes of pollutants - carbon monoxide,
hydrocarbons, lead, nitrogen dioxide, paniculate
matter, ozone, and sulfur oxides. Standards do
not apply directly to source-specific emissions,
but are ambient concentration limitations.
Establishes emission standards for seven
contaminants - benzene, mercury, arsenic,
asbestos, beryllium, vinyl chloride, and
radionuclides.
Justification
Comments
Only "major sources" (emissions
exceeding 100-250 tons per year of
regulated pollutants) are subject to
NAAQS attainment requirements.
Not applicable to the site as benzene
and vinyl chloride are not produced as
a result of manufacturing operations.
Occupational Safety and Health Act
Action-Specific ARARs
Safety of workers
29 USC 651-678
29 CFR 1910
Regulates workers' health and safety.
Applicable to remedial actions at the
site.
Hazardous Materials Transportation Act
Action-Specific ARARs
Hazardous Materials
Transportation Regulations
49 USC 1801-1813
49 CFR 107, 171-
177
Regulates transportation of Department to
Transportation (DOT)-defined hazardous
materials.
Applicable to remedial action involving
transportation of DOT-defined
hazardous materials off-site.
Protection of Wetlands (Executive Order 11990)
Location-Specific ARARs
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TABLE 6 (Continued)
Analysis of Federal ARARs
Standard, Requirement,
Criteria, or Limitation
Regulations to protect wetlands
Regulatory
Citation
Executive Order
No. 11990
49 CFR 6\302(a)
and Appendix A.
Description
Requires consideration of the adverse impacts
associated with the destruction or loss of
wetlands and to avoid support of new
construction in wetlands if a practical alternative
exists.
Justification
Comments
Site is not located in a wetland area.
Floodplain Management (Executive Order 11988)
Location-Specific ARARs
Regulations to protect
floodplains
Executive Order
No. 11988
40 CFR 6,
Appendix A
Requires evaluation of the potential effects of
actions which may be taken in a floodplain to
avoid the adverse impacts associated with direct
and indirect development of a floodplain.
Site is not located in the 100-year
floodplain.
Regulations Protecting Landmarks, Historical, and Archeological Sites
Location-Specific ARARs
National natural landmarks
Historic, architectural,
archeological, and cultural sites
Historic Sites Act
of 1935, 16 USC
461,
40 CFR 6.301(a)
National Historic
Preservation Act of
1966, 16 USC 470,
36 CFR 800,
Executive order
11593
40 CFR 6.30 l(b)
Establishes regulations to protect national natural
landmarks during remedial actions.
Establishes regulations to protect historic,
architectural, archeological, and cultural sites
during remedial actions.
Site is not located in an area with
natural landmarks.
Site is not located in an area with
historic, architectural, archeological or
cultural sites.
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TABLE 6 (Continued)
Analysis of Federal ARARs
Standard, Requirement,
Criteria, or Limitation
Historic, prehistoric and
archeological data
Regulatory
Citation
Archeological
Preservation Act of
1974, 16 USC 469
etseq.
Executive Order
11593
4O CFR 6.301(c)
Description
Establishes regulations to protect historic,
prehistoric, and archeological data during
remedial actions.
Justification
Comments
Site is not located in an area with
prehistoric or archeological data.
Endangered Species Act
Action-Specific ARARs
Protection of endangered
species
16 USC 1531
50 CFR Part 200
50 CFR Part 402
Requires action to conserve endangered species
and/or critical habitats upon which endangered
species depend.
Potentially applicable as endangered
and threatened species have been
identified as candidate species in Iredell
Onslow County.
Fish and Wildlife Coordination Act
Action-Specific ARARs
Protection of fish and wildlife
due to any modifications of
water bodies.
16 USC 661-666
Requires adequate provision for protection of fish
and wildlife resources when any modification of
any stream or other water body is proposed.
Potentially applicable if the remedial
action involves discharge of treated
water to New River.
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TABLE 7
Analysis of State of North Carolina ARARs
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Justification
Comments
North Carolina Waste Management Rules and Solid Waste Management Law
Chemical-Specific ARARs
Identification and listing of
hazardous waste.
15 A NCAC
13 A (.0006-.0014)
Defines those solid wastes which are subject to
state regulation and as a hazardous waste.
Consistent with corresponding federal standards
(characteristic and listed hazardous waste
designations).
Potentially applicable to remedial
actions involving solid waste (soil)
removal.'
North Carolina Water and Air Resources Act
Action-Specific ARARs
Laws to achieve and to
maintain a total environment
with superior quality.
General Statutes,
Chapter 143 Article
21B
State equivalent of the Federal CWA and CAA
Potentially applicable for remedial
action involving discharge of water and
air emissions.
North Carolina Drinking Water Act
Action-Specific ARARs
Regulations on drinking water
General Statutes
Chapter 130A,
Article 10
Establishes criteria for protection of state public
water supplies.
Potentially applicable to remedial
actions involving in-place treatment of
soils.
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TABLE 7 (Continued)
Analysis of State of North Carolina ARARs
Standard, Requirement,
Criteria, or Limitation
North Carolina Solid Waste
Disposal Regulations
North Carolina Air Pollution
Control Requirements
North Carolina
Sedimentation Control
Rules
Citation
NCAC Tide ISA,
Chapter 13B
NCAC Title ISA,
Chapter 2
Subchapter 2D
Subchapter 2H
NCAC Title ISA,
Chapter 4
Description
Provides design, operation, and closure
requirements for solid waste ^disposal facilities
Regulates air pollution, air quality, and emissions
standards
Requires permit for discharge of effluent from
point sources into surface waters. State-level
version of federal NPDES program.
Provides requirements for the prevention of
sedimentation pollution.
Justification
Comments
Potentially applicable to remedial
actions involving point source
discharges b surface waters.
North Carolina Drinking Water and Groundwater Standards
Chemical-Specific ARARs
Groundwater Classifications and
Standards
NCAC Title ISA,
Chapter 2,
Subchapters
2L.0100, 2L.0200,
and 0.0201
Establishes groundwater and drinking water
standards based on the usage.
Potentially applicable to remedial
actions involving in-place treatment of
soils.
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TABLE 7 (Continued)
Analysis of State of North Carolina ARARs
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Justification
Comments
North Carolina Surface Water Quality Standards
Chemical-Specific ARARs
Classification and water quality
standards applicable to surface
water
Technology-based effluent
limitations
NCAC Title ISA,
Chapter 2,
Subchapters 2L.0100
and 2L.0200
NCAC Title 15A,
Subchapter 2B.0400
Establishes a series of classifications and water
quality standards for surface waters.
Establishes guidelines for effluent limitations
based on BAT economically achievable.
Potentially applicable to discharge of
water to a surface water body.
Potentially applicable to discharge of
water.
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Each of the six alternatives is briefly described below. Table 8
shows the soil remediation levels for the Site-related chemicals of
concern. The estimated total extent of pesticide soil
contamination is shown on Figure 5. The vertical extent of the
soil contamination ranges from the ground surface to depths of 7 to
10 feet below land surface. Table 9 also shows how the six
alternatives either meet or do not meet the nine evaluation
criteria.
Alternative 1: No Action
By law, EPA is required to evaluate a No Action Alternative to
serve as a basis against which other alternatives can be compared.
No remedial action of the contaminated soil would take place under
the No Action Alternative. Therefore, the existing structures
(i.e., buildings and parking areas) would remain intact. There are
no capital costs associated with Alternative 1. However, five-year
reviews of the remedy would be conducted for an estimated period of
30 years to determine if the No Action alternative remained
protective of human health and the environment. The estimated
present worth cost for the five-year reviews is $55,640.
Capital Costs $ 0
Present Worth 0 & M Costs $ 55.640
Total Present Worth Costs $ 55,640
Alternative 2: Limited Action
As with the No Action Alternative, no remediation of the
contaminated soil would take place under the Limited Action
Alternative. The Limited Action Alternative would not reduce
contaminants in the surface soil to levels that are considered
protective of human health and the environment.
TABLE 8
Soil Remediation Levels
Total Pesticides3
Pentachlorophenplb
Remedial Goal (mg/kg)
1.0
3.2
aDefined as gamma-BHC (Lindane), endrin, dieldrin, chlordane, DDT.
and DDD.
bApplies only to the top one foot of soil.
The existing structures (i.e., buildings and payed areas) would
remain intact. However, the areas of contaminated soil not
presently covered by a warehouse or a paved surface would be
capped. Additional capping or paving of those contaminated areas
would reduce the possibility of future residents or on-site workers
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Ibl«. «tCA: 3I«BO 30. n.
0 J 50 300
SCALE FEET
jouwu CPA an UAP OMIIIMI
RDY F. WESTDH INC.
FIGURE 5
Areas of Contaminated Soil
to be Remediated
a
i»
3°<
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TABLE 9
Evaluation of Remedial Alternatives
Criteria
Overall Protection of
Human Health and the
Environment
Alternative 1
No Action
Does not mitigate-
risks or achieve
remediation goals.
Alternative 2
Limited Action
Capping
Would limit direct
exposure and
protect human
health. Meets
criterion.
Alternative 3
Building Removal/
Capping
Higher degree of
protection against
exposure than .
Alternative 2. Meets
criterion.
Alternative 4
Thermal
Desorption with
BCD
Eliminates the risk of
exposure to soil
contaminants by
human receptors.
Exceeds criterion.
Alternative 5
Thermal Desorption
Same as Alternative
4. -
Alternative 6
Off-Site Incineration
Same as Alternative 4.
Compliance with ARARs
Chemical-Specific
(Cleanup Goals)
Action-Specific
Location-Specific
Does not meet.
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Expected to meet
Requires special
handling, storage,
treatment, and dis-
posal of hazardous
waste
N/A
Expected to meet
Same as Alternative
4.
N/A
Expected to meet
Must meet RCRA
land disposal
restrictions and DOT
manifesting
procedures.
N/A
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TABLE 9 (Continued)
Evaluation of Remedial Alternatives
Criteria
Short-Term Effectiveness
Protection of
Community During
Implementation
Protection of
Workers
Environmental
Impact
Long-Term
Effectiveness
Alternative 1
No Action
N/A
N/A
N/A
Questionable
whether soil
remediation goals
can be met through
natural degradation.
Five-year review
required.
Alternative 2
Limited Action
Capping
N/A
No significant risk
to workers.
Minimal
Reduces continued
infiltration and
leaching of
contaminants into
groundwater.
Eliminates direct
contact risks. Five-
year review
required.
Alternative 3
Building Removal/
Capping
Alternative 4
Thermal
Desorption with
BCD
Alternative 5
Thermal Desorption
Alternative 6
Off-Site Incineration
Dust control
measures would be
required during
building demolition.
Physical hazards
associated with
building demolition.
Minimal
Same as 'Alternative
2.
Controls required to
protect against dust
generation during
excavation and
building demolition.
Protection required
against dermal
contact and inhalation
of contaminated dust
during excavation,
demolition, and
treatment
Minimal
Provides permanent
and effective means
of eliminating source
for groundwater
contamination.
Controls required to
protect against dust
generation during
excavation and
building demolition.
Protection required
against dermal
contact and inhalation
of contaminated dust
during excavation,
demolition, and
treatment
Minimal
Same as Alternative
4.
Controls required to
protect against dust
generation from
excavation, building
demolition, and truck
traffic.
Protection required
against dermal
contact and inhalation
of contaminated dust
during excavation,
demolition, and
trucking.
Minimal
Same as Alternative 4.
Reduction of Toxicity, Mobility, and Volume
Treatment Process
Used and Materials
Treated
None
None
None
Achieves treatment
Achieves treatment
Achieves treatment
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TABLE 9 (Continued)
Evaluation of Remedial Alternatives
Criteria
Amount of
Hazardous
Materials
Destroyed or
Treated
Degree of expected
reduction in
toxicity, mobility,
and volume.
Degree of
Irreversibility
Type and quantity
of residuals
remaining.
Alternative 1
No Action
None
Does not meet
CERCLA
preference for
treatment remedies.
N/A
N/A
Alternative 2
Limited Action
Capping
None
Does not meet
CERCLA
preference for
treatment remedies.
Cap and buildings
could be removed.
N/A
Alternative 3
Building Removal/
Capping
None
Does not meet
CERCLA preference
for treatment
remedies.
Cap could be
removed.
N/A
Alternative 4
Thermal
Desorption with
BCD
6,945 cubic yards of
contaminated soil
treated.
Reduction of soil
contamination below
soil remediation
goals.
Process would be
irreversible.
Residual soil
contamination below
remediation goals
would be delisted and
backfilled.
Alternative 5
Thermal Desorption
6,945 cubic yards of
contaminated soil
treated.
Reduction of soil
contamination below
soil remediation
goals.
Process would be
irreversible.
Same as Alternative
4.
Alternative 6
Off-Site Incineration
6,945 cubic yards of
contaminated soil
destroyed.
Greater than 99.99%
destruction of organic
contaminants through
incineration.
Process would be
irreversible.
Ash residual disposed
of by incineration
facility.
ImplementabUity
Ability to
Construct and
Operate the
Technology.
Ease of Site
Preparation
N/A
N/A
Road paving
equipment easily
operated.
Only minor grading
required.
Road paving
equipment operated
easily. Building
demolition requires
additional planning
but easily performed.
Would require
decontamination and
demolition of
buildings.
Mobile unit
commercially
available to handle
the expected soil
volumes. Demolition
and excavation
implementable.
Would require
warehouse demolition
and decontamination
facilities.
Mobile units are
available to handle
the expected soil
volumes. Demolition
and excavation
implementable.
Same as Alternative
4.
Permitted incinerators
are available with the
capacity to handle the
expected soil volumes.
Demolition and
excavation
implementable.
Same as Alternative 4.
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TABLE 9 (Continued)
Evaluation of Remedial Alternatives
Criteria
Ease of
Undertaking
Additional
Remedial Actions
Ability to Monitor
Effectiveness
Ability to Obtain
Approval from
Other Agencies
Availability of
Materials
Availability of
Unusual or Special
Services
Alternative 1
No Action
N/A
N/A
N/A
N/A
N/A
Alternative 2
Limited Action
Capping
Would not interfere
with any future
actions.
Pavement would be
inspected for
cracks.
N/A
All materials
obtained easily.
None needed.
Alternative 3
Building Removal/
Capping
Would not interfere
with any future
actions.
Same as Alternative
2.
N/A
All materials
obtained easily.
Building demolition
equipment obtained
easily.
Alternative 4
Thermal
Desorption with
BCD
Would not interfere
with any future
actions.
Confirmation soil
sampling easily
performed.
Community may
express concern over
thermal treatment on-
site.
All materials obtained
easily.
Building demolition.
equipment obtained
easily.
Alternative 5
Thermal Desorption
Would not interfere
with any future
actions.
Same as Alternative
4.
Same as Alternative
3.
All materials obtained
easily.
Building demolition
equipment obtained
easily.
Alternative 6
Off-Site Incineration
Would not interfere
with any future
actions.
Same as Alternative 4.
State may object to
sending materials out
of state.
All materials obtained
easily.
Building demolition
equipment obtained
easily.
Estimated Cost (1994 $)
Capital Cost
Annual O&M Cost
(Years 1-30)
Present Worth **
0
$20,000*
$ 55,640
$139,844
$ 4,000
$20,000*
$255,640
$1,084,881
$ 8,000
$ 20,000*
$1,345,640
$4,840,000
$ 0
$4,840,000
$6,150,000
$ 0
$6,150,000
$17,100,000
$ 0
$17,100,000
* Review performed every 5 years.
** Present worth calculated using a discount rate of 5% and 30-year life where O&M costs are included.
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PAGE 41
from coming into dermal contact or ingesting contaminated soil.
Property deed restrictions would also be established to put
limitations on the future use(s) of the property, thereby further
reducing the possibility of future residents or workers coming into
dermal contact or ingesting contaminated soil. The capital costs
as well as the operation and maintenance costs associated with
Alternative Two are shown below.
Capital Costs $ 0
Present Worth O & M Costs $ 255.640
Total Present Worth Costs $ 255,640
Alternative 3: Demolition of Buildings and Capping
As with Alternatives 1 and 2, Alternative 3 would not involve
remediation of contaminated soil. However, the existing structures
(i.e., buildings and paved areas) would be demolished and
transported off-site to 'an appropriate disposal facility. The
areas known to have surface soil contamination would then be capped
or paved to reduce the possibility of future residents or workers
coming into dermal contact or ingesting contaminated soil. Capping
would also reduce the possibility of contaminants leaching from the
soil into the groundwater. Property deed restrictions would be
established to place limitations on the future use(s) of the
property. The capital costs as well as the operation and
maintenance costs associated with Alternative Three are shown
below.
Capital Costs $ 0
Present Worth O & M Costs $ 1.345.640
Total Present .Worth Costs $ 1,345,640
Alternative 4: Demolition of Buildings, Soil Excavation «r»fl On-site
Treatment Using Thermal Desorption and Base Catalyzed Decomposition
Alternative 4 would involve demolishing the existing buildings,
then excavating and treating approximately 6,945 cubic yards of
contaminated soil qn-site with Thermal Desorption and Base
Catalyzed Decomposition (BCD). Thermal Desorption is a process
which uses either direct or indirect heat exchange to heat organic
contaminants to a temperature high enough to separate them from a
contaminated solid medium such as soil. After being condensed and
treated in the BCD process, all organic residuals would be
transported off-site for further treatment and disposal.
Particulate matter is removed by conventional air pollution control
methods. . '
The treated soil would be backfilled into the excavated areas,
after which the Site would be regraded and seeded with grass.
Trenches would also be dug in areas currently beneath the
warehouses in an attempt to locate the alleged pesticides burial
pit. A treatability study may be needed to evaluate the process
viability of the contaminated soil, as well as to establish design
and operating parameters for the optimization of the treatment
system. A determination will be made during the remedial design
phase as to the need of the treatability study. The capital and
operation and maintenance costs for Alternative 4 are shown below.
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Capital Costs $ 4,840,000
Present Worth O & M Costs $ 0
Total Present Worth Costs $ 4,840,000
Alternative 5: Demolition of Buildings, Soil Excavation, and On-
site Treatment Using Thermal Desorption and an alternate method of
treating offgases
Alternative 5 would involve demolishing the existing buildings,
then excavating and treating approximately 6,945 cubic yards of
contaminated soil on-site using Thermal Desorption and an alternate
method of treating the offgases. Organics in the offgases may be
collected and recovered on-site by condensation and adsorption.
Any concentrated and condensed organic contaminants remaining after
the process would be stored for shipment to recycling centers or
off-site treatment facilities, such as incinerators. Particulate
matter would be removed by conventional air pollution control
methods.
The treated soil would be backfilled into the excavated areas,
after which the Site would be regraded and seeded with grass.
Trenches would be dug beneath the existing warehouses in an attempt
to locate the alleged pesticide burial pit. As with Alternative
Four, a treatability study may be needed as part of Alternative
Five to evaluate the process viability of the contaminated soil, as
well as to establish design and operating parameters for the
optimization of the treatment system. The capital and operation
and maintenance costs associated with Alternative 5 are shown
below.
Capital Costs $ 6,150,000
Present Worth O & M Costs $ 0
Total Present Worth Costs $ 6,150,000
Alternative 6: Demolition of Buildings, Soil Excavation, and Off-
site Treatment Using Incineration
Alternative 6 would involve demolishing the existing buildings,
then excavating and transporting approximately 6,945 cubic yards of
contaminated soil offsite to an EPA-approved incineration facility
for treatment. Clean soil would be transported to the Site and
backfilled into the excavated areas. The Site would then be
regraded and seeded with grass.
Trenches would be dug beneath the existing warehouses in an attempt
to locate the alleged pesticide burial pit. The capital and
operation and maintenance costs associated with Alternative 6 are.
shown below.
Capital Costs $17,100,000
Present Worth O & M Costs $ 0
Total Present Worth Costs $17,100,000
X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives to address soil contamination were each
evaluated using the nine evaluation criteria as set forth in the
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NCP, 40 CFR 300.430(e) (9) . A brief description of each of the nine
evaluation criteria is provided below.
The nine evaluation criteria summarized above relate directly to
requirements in Section 121 of CERCLA, 42 U.S.C. § 9621, which
determine the feasibility and acceptability of the remedy.
Threshold criteria must be satisfied in order for a remedy to be
eligible for selection.' Primary balancing criteria are used to
weigh major tradeoffs between remedies. State and community
acceptance are modifying criteria formally taken into account after
public comment is received on the Proposed Plan. The following
paragraphs provide brief summaries of the nine evaluation criteria,
followed by a summary of how each of the six alternatives was
evaluated against the nine criteria.
THRESHOLD CRITERIA
Overall Protection of Human Health and the Environment addresses
how an alternative as a .whole will protect human health and the
environment. This includes an assessment of how any unacceptable
risk to human health and the environment is properly eliminated,
reduced, or controlled through the treatment of hazardous waste, or
with engineering controls or property deed restrictions placed on
the property to restrict access and (future) development.
Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) addresses whether or not a remedy complies with all state
and federal environmental and public health laws and requirements
that apply or are relevant and appropriate to the conditions and
cleanup options at a specific site. If an ARAR cannot be met/ the
analysis of the alternative must provide the grounds for invoking
a statutory waiver.
PRIMARY BALANCING CRITERIA
Short-term Effectiveness refers to the likelihood of adverse
impacts on human health or the environment that may be posed during
the construction and implementation of an alternative until cleanup
levels are achieved.
Long-term Effectiveness and Permanence refers to the ability of
an alternative to maintain reliable protection of human health and
the environment over time once the cleanup levels have been met.
Reduction of Toxicitv, Mobility, or Volume are the three principal
measures of the overall performance of an alternative. The 1986
amendments to the Superfund emphasize that, whenever possible, EPA
should select a remedy that uses a treatment process to permanently
reduce the level of toxicity of contaminants at the site; the
spread of contaminants away from the source of contaminants; and
the volume, or amount, of contamination at the site.
Implementabilitv refers to the technical and administrative
feasibility of an alternative, including the availability of
materials and services needed to implement the alternative.
Cost includes the capital (up-front) cost of implementing an
alternative, as well as "the cost of operating and maintaining the
alternative over the long-term, and the net present worth of both
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PAGE 44
the capital and operation and maintenance costs.
MODIFYING CRITERIA
State Acceptance addresses whether, based on its review of the
RI/FS and Proposed Plan, the State concurs with, opposes, or has no
comments on the alternative EPA is proposing as the remedy for the
Site.
Community Acceptance addresses whether the public concurs with
EPA's Proposed Plan. Community acceptance of the Proposed Plan is
evaluated based on verbal comments received at the public meetings
and those written comments received during the public comment
period.
Overall Protection of Human Health and the Environment
Each alternative was evaluated to determine whether it would
effectively mitigate and minimize the long-term risks to public
health and the environment due to dermal contact and ingestion of
contaminated soil at the Site. Alternative 1 would not be
protective of human health or the environment since soil
contamination would not be addressed; therefore, unacceptable risks
would not be mitigated and the contaminated soil would continue to
exist as a source of groundwater contamination. Furthermore, no
deed restrictions would be implemented to restrict the future land
use of the Site.
Alternative 2 would be partially protective of human health and the
environment because the capping of contaminated soil around the
warehouses would help reduce the possibility of dermal contact and
ingestion of contaminated surface soil, as well as the potential
leaching of contaminants from the soil into the groundwater.
However, Alternative 2 would be protective over the long term only
if the deed restrictions were effectively implemented on the PCX
property. Furthermore, since no active remediation of the soil
would take place .under Alternative 2, the contaminated soil would
continue to exist as a source of groundwater contamination.
Alternatives 4, 5, and 6 would be protective of human health and
the environment because the unacceptable risks associated with the
contaminated soil would be reduced to acceptable levels. Total
pesticides in the surface and subsurface soil would also be reduced
by an estimated 98.4 % as an existing source of groundwater
contamination.
Compliance with ARARs
There are no chemical-specific ARARs for the soil at the Site.
However, the remediation levels established for Site-related
contaminants in the surface soil at the FCX-Statesville Site are
based on 10"6 risk. The pesticide penta-chlorophenol is the only
Site-related contaminant identified in the surface soil at the Site
at concentrations which exceed 10"6 risk. EPA has established a
remediation level of 3.2 parts per million for pentachlorophenol in
the surface soil. This remediation level reduces the risk
associated with dermal contact and ingestion of pentachlorophenol
in the surface soil to 10"6.
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PAGE 45
EPA has established the remediation level for total pesticides in
the surface and subsurface soil at the Site at the one part per
million. EPA believes that remediating total pesticides in the
surface and subsurface soil to the one part per million level will
effectively remove approximately 98.4 % of the total pesticides in
the soil as a source of groundwater contamination. Combined with
the Operable Unit One groundwater pump-and-treat system, EPA
believes this 98.4 % reduction of total pesticides in the surface
and subsurface soil will be protective of human health and the
environment.
Short-term Effectiveness
Alternatives 1 and 2 could be easily implemented because both
alternatives involve conducting 5-year reviews, and limited capping
for alternative 2. Alternatives 1 and 2 would not reduce the site-
related contamination on a short-term basis.
Alternatives 3, 4, 5, or 6 would involve potential physical hazards
to workers during warehouse demolition and remedial action
activities. For this reason, EPA will require a Health and Safety
Plan (following OSHA guidelines) to be developed and followed by
all remedial workers throughout the Operable Unit Two Remedial
Action. Alternatives 3, 4, 5, and 6 would also involve the
generation of dust. However, these alternatives will be designed
so that dust would be minimized and controlled with water sprayers.
Long-term Effectiveness and Permanence
Alternatives 1, 2, and 3 would have no effect on the contaminant
concentrations contributing to the risks identified in the Baseline
Risk Assessment. Capping of portions of the Site under
Alternatives 2 and 3 would help mitigate the potential for dermal
contact and ingestion of contaminated surface soil, as well as the
leaching of contaminants from the soil into the groundwater.
However, the long-term effectiveness of these two alternatives
would depend on the effectiveness of the property deed
restrictions. On the other hand, Alternatives 4, 5, and 6 are
permanent remedies, and therefore would be effective over the long-
term.
Reduction of Toxicitv. Mobility, or Volume
Since Alternatives 1, 2, and 3 provide no active treatment of the
contaminated soil, contaminants would degrade only by passive.
natural processes. On the other hand, Alternative 4, 5, and 6
would effectively reduce the volume of pesticides in the soil by an
estimated 98.4 %, thereby reducing the toxicity, mobility, and
volume of the contaminants in the soil.
Implementabilitv
The five-year reviews would be easily implemented as part of
Alternatives 1, 2, and 3; however, extensive coordination is needed
between the State and local agencies in order to implement the deed
restrictions necessary for the effective implementation of
Alternatives 2 and 3. Alternatives 4, 5, and 6 are implement able,
but would require both detailed design preparation and
coordination.
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DRAFT ROD
November 14, 1994
FCX-STATESVILLE OU2
PAGE 46
coordination.
Cost
Estimated total present worth costs for the five soil alternatives
for Operable Unit Two are presented below; the costs assume a 5%
interest rate.
Alternative 1: $55,640
Alternative 2: $255,640
Alternative 3: $1,345,640
Alternative 4: $4,840,000
Alternative 5: $6,150,000
Alternative 6: $17,100,000
State Acceptance
The NCDEHNR has reviewed and provided EPA-Region IV with comments
on the Remedial Investigation and Feasibility Study reports. The
NCDEHNR also reviewed this Record of Decision and EPA's preferred
alternative and concurs with EPA's selection.
Community Acceptance
Each comment has been included in the Responsiveness Summary, and
is included as Appendix B of this Record of Decision (ROD) .
XI. THE SELECTED REMEDY
Based on consideration of the requirements of CERCLA, the NCP, the
detailed analysis of alternatives, as well as state and public
comments, EPA has selected Alternative Four for the Operable Unit
Two Remedial Action at the FCX-Statesville Superfund Site.
Alternative Four will involve treating approximately 6,945 cubic
yards of contaminated soil on-site using Thermal Desorption and
Base Catalyzed Decomposition (BCD) . Thermal Desorption and BCD
have proven effective in the treatment of halogenated volatile
organic compounds, halogenated semi volatile organic compounds,
pesticides, herbicides, and dioxin/furans in soil. Implementation
of the Operab" e Unit Two Remedial Action must be in compliance with
all ARARs listed in Tables 6 and 7.
The total present worth cost of Alternative Four (assuming a 5%
interest rate) is approximately $4,840,000. Table 10 shows the
capital costs and the operation and maintenance costs associated
with Alternative Four.
Alternative Four will involve a number of activities. Following the
completion of the Remedial Design, equipment will be transported to
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 47
the Site. The existing buildings and asphalt parking lot will be
demolished and the demolition rubble transported off-site to an
appropriate disposal facility. An estimated 6,945 cubic yards of
contaminated soil will then be excavated and stockpiled on-site in
a manner which minimizes dust emissions and runoff. Soil samples
will be collected beneath the excavated areas and analyzed to
ensure that soil remaining on the PCX property contains less than
the risk-based remediation level for pentachlorophenol (3.2 parts-
per-million in the top one foot of soil) ,. and the remediation level
for total pesticides (one part-per-million in surface and
subsurface soil) . Trenches will also be dug beneath, the areas
presently covered by the' warehouses in an attempt to locate the
alleged pesticide burial pit.
EPA believes the contaminated soil is not RCRA Listed Hazardous
Waste because the contamination is thought to have resulted from
spillage and not from deliberate dumping. However, if EPA obtains
evidence during the Remedial Action which indicates that the soil
is RCRA Listed Hazardous Waste, then all ARARs listed in this
document regarding the storage, treatment, and disposal of RCRA
Listed Hazardous Waste will be met.
During the Remedial Design Phase, EPA will determine if the
contaminated soil is RCRA Characteristic Hazardous Waste by
collecting and analyzing soil samples using the Toxicity
Characteristic Leaching Procedure (TCLP). Only if the TCLP
indicates that the soil is RCRA Characteristic Hazardous Waste,
will the ARARs listed in this document regarding the storage,
treatment, and disposal of RCRA Characteristic Hazardous Waste be
met.
The contaminated soil will be treated on-site with Thermal
Desorption and the Base Catalyzed Decomposition (BCD) process.
Once the soil has passed through the treatment system, verification
samples will be collected and analyzed to ensure the treated soil
contains levels of pentachlorophenol and total pesticides equal to
or below 3.2 parts per million and one part per million,
respectively. The treated soil will then be backfilled into the
excavated areas, and the Site will be regraded and seeded with
grass. Regrading and seeding the Site will reduce the possibility
of erosion and help to enhance the appearance of the FCX property.
XIX. STATUTORY DETERMINATION
Based on available information, the selected remedy satisfies the
remedy selection requirements under CERCLA, as amended by SARA, and
the NCP. The selected remedy provides protection of human health
and the environment, complies with all ARARs, is cost-effective,
utilizes permanent solutions to the maximum extent practicable, and
satisfies the statutory preference for remedies involving treatment
technologies.
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 48
TABLE 10
Cost Estimate
for Alternative 4
W^^^^^'^^^^'^co^ '# WiS^ * %* J
CAPITAL COSTS
PROJECT PLANS
EROSION CONTROLO.IN.FT.)
MOBILIZATION
WAREHOUSE DEMOLITION
TREATABILITY STUDY
EXCAVATION AND MTTD
WITH BCD
EXCAVATION (CY)
MTTD WITH BCD (TONS)
TRANSPORTATION (TONS)
VERIFICATION SAMPLES
BACKFILL (CY)
REGRADE/RESEED(ACRES)
0 & M COSTS
SUBTOTAL CAPITAL
ENGINEERING, ADMINISTRATION
CONTINGENCY (%)
^^p^^FFrAf;r/ "w '»*"*" v
1
2,000
0
1
1
6,945
9376
0
50
6,945
2
(%)
£?#£''* ' 'S,
40,000
3
0
650,000
40,000
0
250
0
350
0
1,500
25
25
ff
40,000
6,000 SITE PERIMETER (5 ACRES)
0
650,000 INCLUDES DECON AND DISPOSAL
40,000 LAB BENCH SCALE STUDY
0 INCLUDED IN TURNKEY PRICE
2343,938 100 PCF (TURNKEY PROJECT PRICE)
0
17,500 PESTICIDES, PCP, DIOXINS ANALYSIS
0 INCLUDED IN TURNKEY PRICE
3,000 2 AC
0
3,100,438
775,109
968,887
-'-' - 4j$44«434 "'- * ' "+ ''>WiyW'/?z'#%9j&P ?%,'*$ ' "W'%%, '"'>"?
"JJiRlSSElWWCIRTtt^sr
- '-,}
* * ^ f, '
t >
<"' ' , ' , ',''«» ' '{<>&£* '" " ' $4i(8
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FINAL ROD
November 1994
FCX-STATESVILLE OU2
PAGE 49
Protection of Human Health and the Environment
The selected remedy will permanently treat the contaminated soil,
reduce the risks associated with the dermal contact and incidental
ingestion of contaminated surface soil, and reduce the amount of
total pesticides in the surface and subsurface soil as a source of
groundwater contamination.
Compliance with ARARs
The selected remedy will comply with all Federal and State ARARs.
No waivers of Federal or State requirements are anticipated for
Operable Unit Two at this Site.
Cost Effectiveness
The selected soil treatment technologies are more cost-effective
than the other acceptable alternatives considered. The selected
remedy provides greater benefit for the cost because it permanently
treats the waste and is acceptable to both the regulatory and local
communities.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
The selected remedy represents the maximum extent to which
permanent solutions and treatment can be practicably utilized for
this Remedial Action.
Of the alternatives that are protective of human health and the
environment and comply with ARARs, EPA-Region IV and the State have
determined that the selected remedy provides the best balance of
trade-offs in terms of long-term effectiveness and permanence;
reduction in toxicity, mobility, or volume achieved through
treatment; short-term effectiveness, implementability, and cost;
State and community acceptance; and the statutory preference for
treatment as a principal element.
Preference for Treatment as a Principal Element
The preference for treatment is satisfied by the use of Thermal
Desorption and Base Catalyzed Decomposition on the contaminated
soil. The principal ri'sk associated with the contaminated soil
will be mitigated by the use of these treatment processes.
-------
APPENDIX A
STATE CONCURRENCE LETTER
-------
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
November 2, 1994
Mr. Ken Mallary
Remedial Project Manager
US EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: State Concurrence with the Record of Decision
FCX Statesville NPL Site Operable Unit 2, Soil
NCD 024 644 494
Statesville, Iredell County, NC
Dear Mr. Mallary:
The State of North Carolina has reviewed the Record of
Decision (ROD) for the FCX Statesville NPL Site for operable unit
2 (Soil) and concurs with the selected remedy, subject to the
following conditions.
1. State concurrence on this Draft Record of Decision (ROD)
and the selected remedy for the site is based solely on
the information contained in the Draft Final Record of
Decision dated October 1994. Should the State receive
new or additional information which significantly affects
the conclusions or remedy selection contained in the ROD,
it may modify or withdraw this concurrence with written
notice to EPA Region IV.
2. State concurrence on this ROD in no way binds the State
to concur in future, decisions or commits the State to
participate, financially or otherwise, in the clean up of
the site. The State reserves the right to review,
overview, comment, and make independent assessment of all
future work relating to this site.
3. The last paragraph on page 15 of the referenced ROD
indicates the EPA risk range of 1E-4 to 1E-6 as the
standard used for establishing the risk based clean-up
goals for the site. The risk level accepted in North
Carolina is 1E-6. Therefore, if after remediation is
complete, the total residual risk level exceeds 1E-6, the
State may reguire deed recordation/restriction to
document the presence of residual contamination and
possibly limit future use of the property as specified in
NCGS 130A-310.8.
P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605
An Cm ml Onnortl initw Affirmi-iti\/» Action Cmnlrwar QX. ro.-wr-la'-" 1 f"Wt r-N~c».~-,Qi imor ^r,-^ar
-------
Mr. Mallary
11-2-94
Page 2
4. The soil clean-up goals established in this ROD may leave
concentrations of pesticides which continue to leach to
groundwater at levels which exceed NC Groundwater
Standards. Continuous monitoring and tracking of the
plume over time will be required under these conditions
along with well permit restrictions within the plume.
The State of North Carolina appreciates the opportunity to
comment on the Draft Record of Decision for the subject site, and
we look forward to working with EPA on the final remedy.
Sincerely,
Jack Butler, PE
Remediation Branch Head
Superfund Section
cc: Curt Fehn, NC Remedial Section Chief
Michael Kelly, Deputy Division Director
Randy McElveen, NC Superfund Section
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APPENDIX B
RESPONSIVENESS SUMMARY
-------
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
RESPONSIVENESS SUMMARY
FCX-STATESVILLE SUPERFUND SITE
OPERABLE UNIT TWO
STATESVILLE, IREDELL COUNTY, NORTH CAROLINA
NOVEMBER 1994
-------
TABLE OF CONTENTS
1.0 PREFACE
2 .0 COMMENTS FROM NORTH CAROLINA SUPERFUND SECTION AND EPA
RESPONSES
3 . 0 COMMENTS FROM TECHNICAL ASSISTANCE GRANT CONSULTANT AND
EPA RESPONSES
4.0 PUBLIC MEETING COMMENTS AND EPA RESPONSES
-------
1.0 PREFACE
The United States Environmental Protection Agency (EPA) held a
60-day public comment period from Jul 5, 1994 to September 3,
1994 to provide an opportunity for interested parties to comment
on the Remedial Investigation (RI), Risk Assessment (RA),
Feasibility Study (FS) , and the EPA Proposed Plan for Operable
Unit Two at the FCX-Statesville Superfund Site in Statesville,
North Carolina. The FS evaluated various options, or remedial
alternatives, to address contaminated spil on the FCX property.
In the Proposed Plan issued in June 1994, EPA identified its
preferred alternative to address the soil contamination on the
FCX property. All of the documents for Operable Unit Two were
placed in the Administrative Record for review. The Record is a
collection of all the documents considered by EPA when choosing
the remedy for a site. The Record was made available at the EPA
Records Center located in the EPA-Region IV office building
located at 345 Courtland Street, NE., Atlanta, Georgia, and at
the Information Repository located in the Richard H. Thornton
Public Library located in Statesville/ North Carolina.
The purpose of this Responsiveness Summary is to document EPA
responses to the questions raised and comments submitted durim
the public comment period. EPA considered all of these questi
and comments before selecting the final remedial alternative f .-
Operable Unit Two to address the soil contamination on the FCX
property.
-------
2.0 COMMENTS FROM STATE SUPERFUND SECTION AND EPA RESPONSES
Comment #1
The Feasibility Study (FS) for Operable Unit 2, soils, dated June
1994 includes excavation, in area 1 around sample 107. Table 6-1
of the FS also indicates the total pesticide concentration in the
soil at area l/FS-107 is 1.35 ppm which is slightly above the 1
ppm cleanup level and PCP concentrations range up to 3.5 ppm
which also exceeds the clean-up goal for PCP in soil. However,
Figure 4 of the ROD only includes this area as a detect level
below the 1 mg/kg (ppm) clean-up goal. This area should be
included in the 1 ppm pesticide boundary on Figure 4 rather than
the detect boundary.
EPA Response
The pesticide concentration for sample location FS-107 listed in
Table 6-1 and shown on Figure 6-3 of the FS Report represents a
total pesticide concentration. In other words, the 1.35 ppm
total pesticide concentration equals 180 ug/kg DDD, 480 ug/kg
DDE, and 690 ug/kg DDT. On the other hand, Figure 4 (DDT
Distribution in Soil) only shows the concentration of DDT at
sample location FS-107 (690 ug/kg).
-------
3.0 COMMENTS FROM TECHNICAL ASSISTANCE GRANT CONSULTANT
AND EPA RESPONSES
Comment #1
Contaminants of concern are present in groundwater at
concentrations greater than would generally be expected. The
Feasibility Study assumes the this is due to past spillage and
leakage onto soils that were not covered with the asphalt and
concrete that currently caps most of the site.
EPA Response
EPA has developed several groundwater models which indicate that
pesticide groundwater contamination exists at levels which can
not be fully accounted for based on the concentrations of
pesticides Identified in the soil. However, EPA acknowledges in
the Feasibility Study Report that not only spillage and leakage
onto soils may contribute to the pesticide groundwater
contamination, but also the alleged burial of 5,000 to 10,000
pounds of pesticides.
Comment #2
Although metals contaminate both soils and groundwater at the FCX
site, these constituents are not addressed in either the Risk
Assessment or the Feasibility Study because no connection can be
made to past site operations as the source of these contaminants.
Again, because the operational history of this site goes back to
the early 1940's, and is necessarily somewhat sketchy, we do not
believe that metals present on-site should be discounted. At a
minimum some discussion of the safety and efficacy of the
proposed treatment in relation to metals contamination should be
included in the Feasibility Study.
EPA Response
EPA believes the metals were adequately addressed in the Risk
Assessment. The Risk Assessment does evaluate the risks
associated with potential direct contact with metals in soil,
surface water, sediment, and groundwater.
Comment #3
The Feasibility Study adopts a 1 ppb soil remediation goal for
PCDD on the basis of that level resulting in an acceptable 10'4
to 10"6 risk. We would be interested in seeing some discussion
of the validity of that soil remedial goal as risk acceptable if
the EPA re-evaluation of PCDD toxicity, now in draft format, is
considered.
EPA Response
The Draft dioxin reassessment document has recommended a minor
relaxation of the Cancer Slope Factor (CSF) for TCDD and has not
recommended a RfD for use in evaluating non-cancer endpoints.
Using the new CSF and standard default daily exposure
-------
assumptions, 1.0 ug/kg of dioxin TEQs in soil equates to an upper
bound risk estimate of about 1E-4. The 1.0 ug/kg level will
likely continue to be considered as the Agency residential soil
protective level during the reassessment finalization period to
be completed in September, 1995.
Comment #4
We remain concerned that groundwater flow direction has been
inadequately characterized. The Feasibility Study admits that
the presence at this time of Lindane in an off-site well, not
directly down gradient of the site is difficult to explain.
Again it appears that contaminants are moving into groundwater at
rates considerably greater than predicted, and contaminant plumes
are being located in directions not previously thought to be
downgradient. Obviously, this anomaly raises questions about the
sufficiency of both the planned pump and treat groundwater
remediation, and the operable unit 2 soil remediation goals.
Additional investigation and discussion is required to ensure
that pumping wells are correctly sited and installed, and that
soil remediation goals will be adequate to prevent further
mobilization and migration of contaminants off-site. Some plan
should be included in the Feasibility Study or the Record of
Decision describing the additional work that will be undertaken
to resolve these issues.
EPA Response
Lindane was detected in off-site temporary monitoring well T-5 at
a concentration of 0.61 ppb in a direction which is downgradient
from the FCX property. EPA disagrees that pesticides are moving
at rates greater than predicted. EPA also disagrees that a
contaminant plume was located in a direction not previously
thought to be downgradient. EPA agrees that additional
investigation is needed during the Remedial Design Phase to
ensure that both extraction and monitoring wells are properly
sited, and the OUl ROD requires such investigation. Details of
the additional work to be performed will be included in the OUl
Remedial Design Report, not in the ROD or FS for OU2.
Comment #5
The community's acceptance of Alternative 4 is conditional based
on the closed loop, on-site BCD treatment of desorption off-
-gases. Because this is a residential area, even incidental
emissions from the desorption unit will be unacceptable, as were
the potential emissions from the proposed air stripping unit
suggested for groundwater treatment.
EPA Response
EPA agrees with the comment. For this reason, EPA will require
stringent air emissions standards for the on-site thermal
desorption treatment unit. The unit will be monitored at all
times during its operation.
-------
Comment #6
The inclusion of Pentach'lorophenol in remedial soil goals,
although not directly attributable to on-site operations, seems
inconsistent when metal/BNA contamination was excluded from
consideration on the same basis.
EPA Response
Pentachlorophenol is classified as a pesticide, and as such can
not be discounted as being a site-related contaminant. It is
important to note that the sample locations to be remediated
based on total pesticide concentrations of DDT, chlordane, etc.
exceeding one part-per-million, are the same sample locations
which revealed the presence of pentachlorophenol.
On the other hand, there is no indication that metals were ever
used by PCX. Unlike the pesticides, the metals were detected a.t
similar concentrations in both on-site and off-site soil samples.
These widespread concentrations seem to indicate that the metals
may be present as naturally-occurring elements and not as site-
related contaminants.
Comment #7
Has there been any contingency made for keeping the treatment
unit on-site for use in -remediating Operable Unit 3 soils? It
would be efficient to utilize a standing unit for required
treatment, rather than incur the time and expense of shut down
and dismantling of the unit, only to re-mobilize at some future
point.
EPA Response
At this point in time, there has been no proposed plan for
remediating the contamination associated with the property
currently owned and operated by Burlington Industries. In fact,
the field work for the Operable Unit Three Remedial Investigation
is still on-going. EPA agrees that it would be efficient to use
the on-site thermal treatment system for remediating
contamination associated with Operable Unit Two and Operable Unit
Three. EPA recommends that this alternative be evaluated during
the development of the Feasibility Study for Operable Unit Three.
COMMENTS ON RISK ASSESSMENT REPORT, REVISION 3
General Comment #1
This Revision 3 of the Risk Assessment represents, a significant
improvement in treatment of human exposure assessment.
EPA Response
EPA agrees with and appreciates the comment.
-------
General Comment #2
The methodology of the Ecological Assessment Section (6), which
has been the most rigorous, part of risk calculations in Revision
0, has been completely changed, resulting in a weaker and less
useful presentation. There is no exposure assessment to diverse
media or explicit calculation of hypothetical risk, only
comparison of selected contaminant - levels with Ambient Water
Quality standards. Thus, all consideration of dioxin/furan
exposure of ecological species is precluded.
EPA Response
EPA evaluated each of the contaminants which were identified in
the surface water and sediment. There was no evidence of
dioxin/furans in the surface water and sediment; therefore, these
contaminants were not evaluated in the Ecological Assessment
Section.
General Comment #3
Table 3-6, Contaminants of Concern, for organic analytes,
represents mostly a summary of which media were tested for a
given substance, rather than substances remaining in the analysis
after a screening process. Several compounds at significant
concentrations were removed from quantitative evaluation at the
stage of the Toxicity Assessment, for lack of compound-specific
reference dose or cancer slope factor data, with no comment abc'..'
the affect on the conservativeness of the resulting cumulative
risk calculations. The Remedial Design phase must be used to d
comprehensive testing for contaminants in all media.
EPA Response
Table 3-6 not only shows which media were tested for a given
substance, but it also shows the concentrations of those
substances in each of the media. The Risk Assessment does
explain which substances were eliminated from the Toxicity
Assessment and why. EPA agrees with the 2nd comment. Those
substances eliminated from the Toxicity Assessment due to a lac*
of compound-specific reference dose or cancer slope factor data
could have been carried forward through the risk assessment. Ef*
could then have mentioned the potential affects that these
deletions may have had on the qualitative risk analysis. EPA
does not believe the deletion of these particular substances
would have made a substantive impact on the quantitative risk
-analysis.
General Comment #4
Although it is clear that dioxins/furans contribute at least 8
of the calculated cumulative chronic and carcinogenic risk for
the surface soil dermal and Ingestion pathways in the Future C;
Site Resident scenario, no testing for dioxins and furans was
done in other media. In particular, inclusion of a groundwatei
ingestion pathway, with concentrations on dioxins/furans sever.i.
orders of magnitude lower than were found in surface soil, wou. :
-------
cause dramatic increases in the total chronic and lifetime risk
calculated, and thus could change the degree of treatment
required for groundwater.
EPA Response
EPA disagrees that no dioxin/furans testing was performed in
media other than the surface soil. Based on the presence of
dioxin/furans in the soil at the Site, groundwater samples were
collected from on-site monitoring wells and analyzed for
dioxin/furans. The analytical results of these groundwater
samples did not indicate the presence of dioxin or furans.
None of the surface water and sediment samples collected and
analyzed during the Remedial Investigation indicated the
presumptive evidence of dioxin or furans. Therefore, no
additional .samples were collected and analyzed specifically for
dioxin and furans.
Section 2; Site History
Section 2.1.3
This hole, filled in with pesticide waste by workers, may be a
former well and, thus, a direct route to groundwater, with a
potential major increase in contaminated soil and water volume.
Despite this possibility, there has not been comprehensive
testing of monitoring well samples for pesticides and limited
deep sampling of the aquifer, even in the areas of highest DDT
concentrations.
EPA Response
EPA has received information from a number of former employees
about the day-to-day operations and disposal practices at the PCX
facility on West Front Street. Most of the information sources
centered around a large pesticide disposal pit. One person
claimed that waste from PCX may have been disposed in an old,
abandoned well. To this point, EPA has not been able to verify
this claim. However, EPA does feel that comprehensive testing of
the groundwater across the FCX-Statesville property has been
performed. Additional testing of the aquifer during the Remedial
Design phase will help to further characterize groundwater
conditions at the Site prior to designing and implementing the
Operable Unit One pump-and-treat system.
-Section 2.2.2
Caprolactum had been reported detected in all on-site monitoring
wells, with some fairly -high concentrations observed (Rev. 0).
This compound appears to have been eliminated from relevant
figures in Rev. 3, and was not included in any risk calculations.
EPA Response
EPA agrees with the comment. As a clarification, caprolactum was
identified in most of the on-site monitoring wells in the NCDHR
1986 study. The levels of caprolactum reported in the wells were
-------
all below 18,000 ug/1, which is EPA-Region IVs screening value
for caprolactum. The 18,000 ug/1 level equals a non-carcinogenic
risk factor or Hazard Index value of one.
Section 2.2.3
In results given in the text for the Weston-SPER Emergency
Response of January 1989, it is stated that "no pesticides were
detected in any of the samples collected outside of the warehouse
building", but no figure is presented with concentration data for
pesticide analysis. This statement appears to conflict with the
1986 NCDHR study results reported.
EPA Response
Eight surface soil samples were collected and analyzed for
pesticides .during the Weston-SPUR Emergency Response
investigation in 1989; the minimum detection- limit used by the
laboratory was 35 parts per billion. None of the samples
indicated the presence of pesticides above the minimum detection
limit.
Section 2.2.8.1
No analyses are reported of groundwater samples for DDT, DDE, ODD
or dioxins/furans, though there is reason to predict the presence
of both in on-site or near off-site wells. No result, are given
for analyses of the Nelson Brown well.
EPA Response
EPA did analyze the groundwater for DDT, DDE, DDD, and
dioxins/furans; however, none of these contaminants were present
at levels which exceeded the detection limit. The Risk
Assessment did not report the analytical results of the Nelson
Brown water supply system; however, as stated in the RI Report,
the Nelson Brown sample 'did not reveal any site-related
contaminants.
Section 2.2.8.3
No samples of sediment or surface water were analyzed for
dioxins/furans. PAHs found in Phase I sediment analyses were
said to be "not sufficient to demonstrate that the presence of
these compounds was predominantly a function of proximity to the
treated cross-ties...or possibly related to past site-related
contamination" . Total PAHs are reported for only two samples in
-figure 2-6. Where are the results reported for the two Phase II
samples collected (FS2-03-SD, FS2-04-SD) and how would two more
samples, close to the tracks resolve the question of railroad-
contaminated or site-associated contamination, as no other on-
site samples were tested? Why were there no analyses for PAH's
in water or subsoil?
EPA Response
As stated in EPA's response to General Comment #4, there was no
presumptive evidence of dioxins/furans in the surface water and
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sediment samples collected and analyzed during the Phase I
Remedial Investigation. Therefore, EPA did not believe it was
necessary to collect additional surface water and sediment
samples and analyze them specifically for dioxins and furans.
The analytical results of samples FS2-03 SD and FS2-04-SD are
provided in the Phase II RI Report. These results did not prove
what the source of the PAHs is. Every soil, sediment, surface
water, and groundwater sample collected a the Site was analyzed
for PAHs. PAHs were reported for every sample in which they
occurred.
Section 2.2.9
Figure 2.2.1 - dioxin/furan sample locations, is not included
here.
EPA Response
EPA agrees with the comment. As stated on page 2-31 of the Risk
Assessment, Figure 2-21 should be included to show the
dioxin/furan sample locations. The figure was mistakenly left
out of the report.
Figure 2-11
No results are presented for the EPA-installed wells nearest the
highest DDT concentrations on the north side of the site. Was no
DDT analysis of groundwater done on this round?
EPA Response
All groundwater samples collected at the Site were analyzed for
the full target compound/target analyte list constituents,
including DDT. DDT was not identified in any of the groundwater
samples.
Section 3.2.1.1 and 3.2.1.2
Toxicity screening methodology is more explicitly described in
this revision. However, screening the average contaminant
concentration against a single background sample value is of very-
questionable reliability.
EPA Response
Section 3.2.1.1, titled "Screening Against Background", states
that the maximum on-site concentration of each constituent had to
be at least two times greater than the arithmetic average of the
-of the respective background samples.
Table 3-1. and Section 3.2.2.1
Monitoring well MW-4 is clearly not an appropriate source of
background samples for screening of groundwater analytical
values. The concentration of trichloroflouromethane reported is
99 mg/1, indicative that this well is within the plume of
halogenated organics perhaps originating from Burlington
Industries.
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EPA Response
EPA agrees with the comment. However, since this Site falls
within an industrial corridor, it is. not likely to locate a
background well close to the Site which will provide "true"
background conditions. As an example, the Carnation well was
sampled during 1986 to provide a background sample. As it turned
out, the Carnation well contained VOCs.
Section 3.2.1.4
For lack of "health criteria", five metals including lead and
four pesticides were eliminated from quantitative evaluation of
ground water exposures in this report, with no discussion as to
the effect on the uncertainty of the cumulative risk. Use of the
Lead Model Version 5.0 is a significant improvement over
elimination of this contaminant from consideration.
EPA Response
Page 3-26 of the Risk Assessment identifies a total of nine (9)
substances which were eliminated from the quantitative evaluation
due to a lack of health criteria.
Table 3-6
For organic compounds, this table is functionally a chart of
which media were tested for which compounds, rather than an
indication of the media in which these compounds present a
possible hazard. The most glaring examples .of this are the
absence of data for most PAH's and other semi-volatile organics
from groundwater and subsurface soil analysis, the absence of
DDT, DDE, and DDD from groundwater analyses, and, probably most
grave of all, no testing of dioxins in any media except for three
samples in Area 3.
EPA Response
EPA disagrees with the comment. Table 3-6 shows each site-
related contaminant which presents unacceptable risk in the
different media. All available data are shown for the PAHs and
other semi-volatile organics. DDT, DDE, DDD data is not
presented for groundwater analyses because none of these
compounds were identified in the groundwater. Thirty-eight (38)
dioxin samples were collected from nineteen (19) locations in
areas 1, 2, and 3, and evaluated in the risk assessment.
-Section 4.3
One of the functions of the Conceptual Site Model is to "aid in
identifying data gaps". However, this information was not used
to recommend further data collection.
EPA Response
EPA agrees with the comment.
Section 4.4
It is assumed that a residence time of 30 years represents the
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90th percentile for this area. However, this is probably a
figure derived from national census data and probably does not
accurately represent residency patterns in southeastern U.S.
rural areas and small cities, use of more local residency data is
recommended for determining a conservative estimate of exposure
time of future on-site residents.
EPA Response
It is standard practice to use a residence time of 30 years
as representing 90 percent of the people living across the
country.
Section 4.5
Uncertainties in exposure assessment are discussed here with a
much improved justification of conservative assumptions. A semi-
quantitative treatment of the sensitivity of the calculated
hypothetical risk to major parameters should be included.
EPA Response
EPA does not quantify u% confidence" as it relates to the
uncertainty in a exposure assessment.
Section 5.1
"The potential for carcinogenic effects is limited to substances,
that have been shown to be carcinogenic in animal and/or humans*
This statement is misleading and should be clarified; the
cumulative risks may only be calculated for known carcinogens,
but there is undoubtedly the potential for carcinogenic effects.
from as yet undemonstrated carcinogens.
EPA Response
EPA does not think this statement is misleading. Although it 13
true that the potential exists for carcinogenic effects from
undemonstrated carcinogens, it is unreasonable to think that the
cumulative risks from undemonstrated carcinogens can be
quantified until carcinogenic affects for those substances are
first qualified with laboratory data.
Section 5.1.1
There remain several imprecise and unclear statements in this
section, such as: "the range of risks, defined as the upper lir,.-
as determined by the model and the lower limit of zero needs to
-be understood by the appropriate decision makers." A more usef ..
and interpretable statement would be that assumptions and
parameters used in the model, including measured concentrations
of contaminants, were chosen to yield a cumulative risk figure
with -% confidence that the actual risk is below this number. :
order to make such a statement, there must be some information
given about the distribution of these parameters and the
sensitivity of the calculated risk to each of them.
EPA Response
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EPA does not quantify % confidence in risk assessments.
Section 5.4
Acknowledging the uncertainties associated with extrapolating
from oral to dermal pathways, the method used for approximating
dermal reference doses and dermal cancer slope factors seems a
reasonable one. Here is a case, however, where the confidence
that a calculated cumulative risk is below a certain level would
be increased by using a safety factor in transforming to another
pathway.
EPA Response
Safety or "uncertainty" factors are already included in the oral
values. EPA agrees the dermal adjustments add to the uncertainty
in the risk assessment process, but EPA believes this is a
conservative adjustment.
Uncertainty Analysis
This section more clearly enumerates the major contributors to
uncertainty in the risk calculations, but should include at least
a semiquantitative statement about the magnitude and direction of
the contribution made by each (i.e., a sketchy sensitivity
analysis). It should be pointed out that exclusion of substances
whose specific RfD's and CSFs are not determined is a potentially
significant source of error in the direction of underestimation
of cumulative risk.
EPA Response
EPA does not quantify uncertainty in the Risk Assessment process.
EPA agrees with the second comment that the exclusion of
substances whose RfDs and CSFs are not determined is a potential
source of error in the direction of underestimation of cumulative
risk.
Section 6: Ecological Risk Assessment
This section, the most rigorous of the Rev. 0 Risk Analyses, has
been completely transformed, with the elimination of a detailed
and rational exposure model for the American Robin. Instead, a
limited selection of water contaminants is screened against
Ambient Water Quality standards, altogether eliminating
assessment of exposure to the most toxic on site contaminants,
dioxins and furans.
EPA Response
Each of the substances identified in surface water and sediment
samples during the RI were first screened against background and
concentration-toxicity data. EPA then evaluated each of
substances identified in surface water and sediment against the
Ambient Water Quality Standards. The reason why dioxin/furans
were not evaluated in the Ecological Risk Assessment was because
there was no presumptive evidence of dioxin/furans in the surface
water and sediment samples collected and analyzed during the
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RI/FS; therefore, no samples were collected and analyzed
specifically for dioxin/furans.
Tables 6-6 and 6-7
Contaminants of Concern. As in Section 3, this list is based
less on a rational screening process for analyzed substances than
on which chemicals were analyzed in a given medium.
EPA Response
EPA would like to point out that, unlike Table 3-7 in Section 3,
the titles for Tables 6-6 and 6-7 do not mention "Contaminants of
Concern", but "Contaminants in Surface Water" and "Contaminants
Detected in Sediment", respectively.
Section 7; Risk Characterization
This Risk Characterization suffers from the non-evaluation of.
several contaminants, either because toxicity data were not
available for the particular compound or because analysis was not
performed for toxic compounds which should have been expected in
all media. Given the presence of chlorinated solvents,
polyaromatics and pesticides, dioxins/furans should have been
analyzed extensively in all media. Air monitoring data described
qualitatively here should have been included in tabular form in
section 2 of this risk analysis.
The uncertainty analysis for this section is completely
inadequate (see comments 'on other uncertainty subsections) and
fails to mention the non-conservative effect of removal of all
contaminants lacking health criteria from the risk calculations.
EPA Response
EPA evaluated all site-related substances that were identified
during the Remedial Investigation, including dioxins/furans.
Soil was the only medium in which presumptive evidence of
dioxin/furans was identified. As a result, EPA collected soil
and groundwater samples and analyzed them specifically for
dioxin/furans. Although dioxin and furans were identified in the
soil at levels below 1 ppb (TEQ), no dioxin or furans were
identified in the groundwater.
EPA agrees with the comment regarding the uncertainty section.
EPA should have included a discussion in the Risk Charac-
terization Section regarding the lack of toxicity values for
certain contaminants, and the potential affects of excluding
these contaminants from the risk evaluation.
Section 8: Remedial Goal Options
Tables 8-1 and 8-2. This explicit presentation of the clean-up
goals for individual contaminants in order to achieve various
hypothetical risk levels is informative, and, in the case of
Table 8-2, provides a helpful comparison with state and federal
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regulatory levels for drinking water. AS analysis for several
compounds, was not carried out comprehensively in all media (most
importantly, for dioxins/furans in ground water), this table can
only be used for preliminary guidance in estimated soil and water
volumes requiring treatment. Only if far more comprehensive
testing occurs during the Remedial Design phase, especially for
dioxins/furans, will such calculations rationally guide clean-up
level decisions.
EPA Response
As stated in previous responses, EPA believes that a
comprehensive evaluation of all site-related substances was
carried out. EPA does not believe that additional testing for
dioxins/furans in groundwater is necessary due to the fact that
neither of these constituents was identified in on-site
monitoring wells during the Remedial Investigation.
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