EPA Superfund
Record of Decision:
PB98-964020
EPA 541-R98-085
November 1998
Flanders Filters, Inc. Site
Washington, NC
9/18/1998
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
FLANDERS FILTERS, Inc. SITE
WASHINGTON, BEAUFORT COUNTY
NORTH CAROLINA
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA, GEORGIA
September 1998
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DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
Flanders Filters, Inc.
Flanders Filters Road, Washington, Beaufort County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Remedial Action for the Flanders Filters, Inc. Site in
Washington, North Carolina, chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended by the Superfund
Amendments and Reauthorization Act of 1986 and, to the extent practicable, the National Oil
and Hazardous Substances Contingency Plan. This decision is based on the Administrative
Record file for this Site.
The State of North Carolina concurs with the selected remedy. The State's concurrence
on this Record of Decision can be found in Appendix A of this document.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not addressed
by implementing the response action selected in this Record of Decision, may present an
imminent and substantial endangerment to public health, welfare, or the environment.
Presently, no unacceptable current risks are associated with the Flanders Filters, Inc. Site as
the contaminated groundwater beneath the Site is discharging into on-site drainage ditches
and Mitchell Branch. The principle risk pertains to the potential future use of the adversely
impacted groundwater beneath the Site.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy relies on natural degradation processes to reduce the level of
contaminants in the groundwater. The following activities are also incorporated into this
Remedial Action: confirmation that private wells in the Shad Bend subdivision have not been
adversely impacted, institutional controls, abandonment of inactive public supply wells, and
removal of the aboveground storage tanks in Area of Concern #5. In the event that natural
degradation fails to result in a significant reduction in groundwater concentrations within three
years of the signing of this Record of Decision, the contingency remedy will be implemented.
The contingency remedy, which is one of the alternatives presented in this Record of Decision,
involves the installation of an air sparging/soil vapor extraction system along with institutional
controls, abandonment of the inactive public supply wells, and removal of the aboveground
storage tanks in Area of Concern #5. Based on current conditions, no air emission controls will
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be necessary for the soil vapor extraction system. However, if the contingency remedy is
implemented, this determination will need to be re-evaluated.
The major components of the selected remedial alternative include:
• Monitored Natural Attenuation - The quality of the groundwater and surface
water/sediment will be monitored on a periodic basis. Monitoring of the wetlands
between the Site and Mitchell Branch shall also be included in this monitoring plan.
• Sample Private Wells - Sample all private wells in the Shad Bend subdivision to insure
that these wells have not been adversely impacted by Site activities and incorporate
these wells into the long-term monitoring plan.
• Institutional Controls - Institutional controls shall include "land use restrictions" and
"deed recordation" under appropriate North Carolina regulations.
• Abandonment of Inactive Supply Wells - Four inactive supply wells will be abandon
to prevent the migration of contaminants into the lower aquifer. These wells will be
abandoned in accordance to North Carolina regulations.
• Remove Aboveground Storage Tanks From Area #5 -- The tanks in this area of the
Site will be emptied, cleaned, and disposed of in accordance to the appropriate
regulations. Underlying soils will be inspected and sampled if warranted.
• Five-Year Review Reports - Prepare and submit Five-Year Review Reports until the
specified groundwater performance standards are achieved throughout the entire
contaminated plume.
The major components of the contingent remedial alternative include:
• Air Sparging/Soil Vapor Extraction System - An air sparging/soil vapor extraction
system will be installed in two areas. Due to the low levels of emissions expected, the
vapors would be discharged directly into the atmosphere and no air discharge permit is
expected to be required.
• Sample Private Wells - Sample all private wells in the Shad Bend subdivision to insure
that these wells have not been adversely impacted by Site activities.
• Five-Year Review Reports - Prepare and submit Five-Year Review Reports until the
specified groundwater performance standards are achieved throughout the entire
contaminated plume.
If the following components have not been completed as part of the selected remedy
described above, the following components shall be completed as part of the contingent
remedial alternative:
• Institutional Controls - Institutional controls shall include "land use restrictions" and
"deed recordation" under appropriate North Carolina regulations.
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Abandonment of Inactive Supply Wells - Four inactive supply wells will be abandon
to prevent the migration of contaminants into the lower aquifer. These wells will be
abandoned in accordance to North Carolina regulations.
Remove Aboveground Storage Tanks From Area #5 - The tanks in this area of the
Site will be emptied, cleaned, and disposed of in accordance to the appropriate
regulations. Underlying soils will be inspected and sampled if warranted.
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. The physical, chemical, and/or
biological processes encapsulated under monitored "natural attenuation" satisfy the statutory
preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a
principal element. Since this remedy may result in hazardous substances remaining in the
groundwater on-site above the chemical-specific applicable requirements, a review will be
conducted within five years after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment.
Richard D. Green, Director Date
Waste Management Division
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DECISION SUMMARY
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
FLANDERS FILTERS, Inc. SITE
WASHINGTON, BEAUFORT COUNTY
NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA, GEORGIA
SEPTEMBER 1998
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INDEX
SECTION PAGE
1.0 SITE NAME, LOCATION, AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY 7
5.0 SUMMARY OF SITE CHARACTERISTICS 7
5.1 AREAS OF CONCERN 9
5.2 SUMMARY OF SOIL CONTAMINATION 10
5.3 SUMMARY OF GROUNDWATER CONTAMINATION 11
5.4 SUMMARY OF SURFACE WATER AND SEDIMENT CONTAMINATION 12
5.5 HYDROGEOLOGICAL SETTING 12
5.6 EXTENT OF CONTAMINATION 13
5.7 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCES USES 14
6.0 SUMMARY OF SITE RISKS 15
7.0 REMEDIAL ACTION OBJECTIVES 42
7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 43
7.2 PERFORMANCE STANDARDS 45
8.0 DESCRIPTION OF ALTERNATIVES 46
8.1 REMEDIAL ALTERNATIVES 46
8.1.1 ALTERNATIVE RAA1: NO ACTION 53
8.1.2 ALTERNATIVE RAA2: MONITORED NATURAL ATTENUATION,
SAMPLE PRIVATE WELLS IN SHAD BEND COMMUNITY
INSTITUTIONAL CONTROLS, ABANDONMENT OF INACTIVE
PUBLIC SUPPLY WELLS, & REMOVAL OF ABOVEGROUND
STORAGE TANKS IN AOC #5 54
8.1.3 ALTERNATIVE RAA3: LIMITED GROUNDWATER
EXTRACTION WITH DISCHARGE TO MITCHELL CREEK
VIA A NPDES PERMIT, SAMPLE PRIVATE WELLS IN
SHAD BEND COMMUNITY, MONITORING, ABANDONMENT
OF INACTIVE PUBLIC SUPPLY WELLS, & REMOVAL OF
ABOVEGROUND STORAGE TANKS IN AOC #5 55
8.1.4 ALTERNATIVE RAA4: AIR SPARGING WITH SOIL
VAPOR EXTRACTION, SAMPLE PRIVATE WELLS IN
SHAD BEND COMMUNITY, MONITORING, & ABANDONMENT
OF INACTIVE PUBLIC SUPPLY WELLS, & REMOVAL OF
ABOVEGROUND STORAGE TANKS IN AOC #5 56
ii
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INDEX
SECTION PAGE
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 57
9.1 THRESHOLD CRITERIA 57
9.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 57
9.1.2 COMPLIANCE WITH APPLICABLE OR RELEVANT
AND APPROPRIATE REQUIREMENTS 58
9.2 PRIMARY BALANCING CRITERIA 58
9.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE 58
9.2.2 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME 63
9.2.3 SHORT-TERM EFFECTIVENESS 63
9.2.4 IMPLEMENTABILITY 63
925 COST 63
9.3 MODIFYING CRITERIA 64
9.3.1 STATE OF NORTH CAROLINA ACCEPTANCE 64
9.3.2 COMMUNITY ACCEPTANCE 64
10.0 DESCRIPTION OF THE SELECTED REMEDY 65
10.1 PERFORMANCE STANDARDS TO BE ATTAINED 65
10.2 DESCRIPTION OF SELECTED REMEDIAL ACTION 65
10.3 DESCRIPTION OF CONTINGENT REMEDIAL ACTION 67
10.4 COST 67
11.0 STATUTORY DETERMINATION 67
11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 67
11.2 COMPLIANCE WITH ARARS 67
11.3 COST-EFFECTIVENESS 68
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE TECHNOLOGIES
TO THE MAXIMUM EXTENT PRACTICABLE 68
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT 68
12.0 SIGNIFICANT CHANGES 68
ill
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INDEX
APPENDICES
APPENDIX A CONCURRENCE LETTER FROM THE STATE OF NORTH CAROLINA AND
RESPONSE FROM THE AGENCY
APPENDIX B FLANDERS FILTERS, INC. MARCH 18, 1998 LETTER REGARDING THE
FUTURE OF THE FACILITY
APPENDIX C PROPOSED PLAN FACT SHEET
APPENDIX D RESPONSIVENESS SUMMARY
IV
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INDEX
FIGURE
TITLE
PAGE
FIGURE 1 SITE LOCATION MAP 4
FIGURE 2 LOCATION OF FACILITIES 5
FIGURE 3 LOCATION OF THE NINE AREAS OF CONCERN 8
FIGURE 4 SURFACE SOIL SAMPLING LOCATIONS AND ASSOCIATED ANALYTICAL
RESULTS 16
FIGURE 5 SUBSURFACE SOIL SAMPLING LOCATIONS AND ASSOCIATED ANALYTICAL
RESULTS 17
FIGURE 6 SHALLOW GROUNDWATER SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS FOR SAMPLES COLLECTED IN SEPTEMBER 1996 18
FIGURE 7 SHALLOW GROUNDWATER SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS FOR SAMPLES COLLECTED IN OCTOBER 1997 19
FIGURE 8 INTERMEDIATE GROUNDWATER SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS FOR SAMPLES COLLECTED IN SEPTEMBER 1996 20
FIGURE 9 ON-STE SURFACE WATER SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS 21
FIGURE 10 ON-SITE SEDIMENT SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS 22
FIGURE 11 OFF-SITE SURFACE WATER SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS 23
FIGURE 12 OFF-SITE SEDIMENT SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS 24
FIGURE 13 Wetland SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS 25
FIGURE 14 DISTRIBUTION OF 1 J-DICHLOROETHANE IN THE SHALLOW
GROUNDWATER AQUIFER 35
FIGURE 15 DISTRIBUTION OF I.I-DICHLOROETHENE IN THE SHALLOW
GROUNDWATER AQUIFER 36
FIGURE 16 DISTRIBUTION OF TETRACHLOROETHENE IN THE SHALLOW
GROUNDWATER AQUIFER 37
FIGURE 17 SHALLOW GROUNDWATER CONTOUR MAP BASED ON
SEPTEMBER 1996 DATA 39
FIGURE 18 SHALLOW GROUNDWATER CONTOUR MAP BASED ON
OCTOBER 1997 DATA 40
FIGURE 19 INTERMEDIATE GROUNDWATER CONTOUR MAP BASED ON
SEPTEMBER 1996 DATA 41
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INDEX
TABLE
TITLE
PAGE
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS
AND INORGANIC CONSTITUENTS DETECTED IN THE SOILS 26
TABLE 2 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANT
AND INORGANIC CONSTITUENTS DETECTED IN THE GROUNDWATER 28
TABLE 3 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS
AND INORGANIC CONSTITUENTS DETECTED IN THE SURFACE WATER 30
TABLE 4 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS
AND INORGANIC CONSTITUENTS DETECTED IN THE SEDIMENT 31
TABLE 5 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS
AND INORGANIC CONSTITUENTS DETECTED IN THE WETLANDS 32
TABLE 6 SUMMARY OF SOIL TESTING RESULTS FOR AOC#1 33
TABLE 7 HISTORICAL LEVELS OF VOLATILE ORGANIC COMPOUNDS FOR WELLS
AROUND FORMER SPRAY FIELD 34
TABLE 8 GROUNDWATER LEVEL DATA 38
TABLE 9 CURRENT AND FUTURE EXPOSURE PATHWAYS CONSIDERED IN THE
BASELINE RISK ASSESSMENT 44
TABLE 10 SUMMARY OF CUMULATIVE HEALTH RISK BASED ON THE BASELINE
RISK ASSESSMENT 45
TABLE 11 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 47
TABLE 12 GROUNDWATER PERFORMANCE STANDARDS AND CORRESPONDING RISKS 51
TABLE 13 SURFACE WATER PERFORMANCE STANDARDS AND CORRESPONDING RISKS 52
TABLE 14 FINAL SET OF REMEDIAL ACTION TECHNOLOGIES AND PROCESS OPTIONS 53
TABLE 15 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES 59
VI
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LIST OF ACRONYMS
AOC
ARARs
CERCLA
cm/sec
1,1-DCA
1,1-DCE
e.g.
EPA
ESI
FS
gpd
i.e.
MCLs
mg/kg
NCAC
NCDEM
NCDENR
NCP
ND
NPDES
NPL
O&M
ppb
ppm
POTW
PRP
PW
RA
RCRA
RD
RD/RA
Rl
Rl/FS
ROD
SARA
SSI
SVOCs
TBC
1,1,1-TCA
TCLP
TMV
VOCs
Area of Concern
Applicable or Relevant and Appropriate Federal, State or Local
Requirements
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (Superfund)
centimeter per second
1,1-Dichloroethane
1,1-Dichloroethene
for example
Environmental Protection Agency
Expanded Site Inspection
Feasibility Study
gallons per day
that is
Maximum Contaminant Levels
milligrams per kilogram
North Carolina Administrative Code
North Carolina Department of Environment Management
North Carolina Department of Environment and Natural Resources
National Oil and Hazardous Substances Pollution Contingency Plan
Not Detected
National Pollution Discharge Elimination System
National Priority List
Operation and Maintenance
parts per billion
parts per million
Publicly Owned Treatment Works
Potentially Responsible Party
Present Worth
Remedial Action
Resource Conservation and Recovery Act
Remedial Design
Remedial Design/Remedial Action
Remedial Investigation
Remedial Investigation/Feasibility Study
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
Site Screening Inspection
Semi-volatile Organic Compounds
To Be Considered
1,1,1-Trichloroethane
Toxicity Characteristic Leaching Procedure
Toxicity, Mobility, or Volume
micrograms per kilogram
micrograms per liter
Volatile Organic Compounds
vii
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
FLANDERS FILTERS, Inc. SITE
WASHINGTON, BEAUFORT COUNTY, NORTH CAROLINA
1.0 SITE NAME. LOCATION. AND DESCRIPTION
The Flanders Filters, Inc. Site (the "Site") is located on Flanders Filters Road in
Washington, Beaufort County, North Carolina and occupies 65 acres. The Site is
approximately 4 miles northwest of Washington, in the Coastal Plain of North Carolina, at 35°
35' 14" N latitude and 77° 06' 23" W longitude. Figure 1 shows the location of the Site with
respect to Washington as well as the surrounding topographical characteristics. The Flanders
Filters facility, refer to Figure 2, includes the following features: the main plant building, four
warehouses, a metal shop, a maintenance shop, a paint shop, a water treatment plant, a
chemical storage shelter, a nitrification field (leach field) for the septic system, two former
spray fields, aboveground storage tank area, and other support structures.
Presently, land use immediately adjacent to the Site is a mixture of agricultural and
residential. The Site is bordered to the north, northwest, and west by agricultural land and an
abandoned railroad right of way. A stream, called Mitchell Branch, and it's associated wetland
area is adjacent to the east. Land to the south is occupied by the Shad Bend subdivision.
Natural features include a relatively flat topography, two streams, and two on-site
drainage ditches. The topography elevation changes slightly. The Site slopes from northwest
to southeast towards Mitchell Branch. The elevation ranges from about 25 feet above mean
sea level to approximately sea level (refer to Figure 1). The two streams are Mitchell Branch
and Tranters Creek. No natural springs or seeps exist on the Flanders Filters' property.
The climate is fairly mild throughout the year. Precipitation averages 51 inches annually
with a net rainfall amount of 9 inches per year. The portion of the Site adjacent to Mitchell
Branch lies in the 100-year flood plain.
Precipitation runoff from the Site flows into storm drains which empty into 1) a drainage
ditch along the northern property line, 2) directly into this drainage ditch, or 3) to the drainage
ditch that runs between the leach field and former Spray Field #2. These two drainage ditches
join together prior to leaving the Site (refer to Figure 2). The combined drainage ditch empties
into Mitchell Branch that meanders south and then turns west until joining Tranters Creek. In
turn, Tranters Creek flows southeast for about 3.5 miles until it joins the Tar River near the
upper reaches of the Pamlico River. Large wetland areas border both Mitchell Branch and
Tranters Creek for the majority of their lengths. The December 1990 Site Screening Inspection
(SSI) report and the 1993 Expanded Site Inspection (ESI) report, both prepared by EPA,
stated there was reportedly a surface water intake approximately 3.5 miles downstream on
Tranters Creek. The 1997 Rl report states there are no active surface water intakes located
within 15 miles downstream of the Site.
Recreational fishing occurs on Tranters Creek, however, no recreational swimming was
observed, but private docks were present at nearly every residence along the creek. No
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Flanders Filters Site
Record of Decision
September 1998
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recreational fishing was observed on Mitchell Branch but, near where it joins Tranters Creek, it
appeared to be suitable. The upstream reach of Mitchell Branch is very shallow.
The 1990 census indicated the population within a one-mile radius of the Site is
approximately 615 and about 6,600 within a four-mile radius. The nearest residences are
located about 300 feet south of the facility in Shad Bend subdivision (see Figure 2). Other
private residences are located to the west and southwest along Flanders Filters Road.
The City of Washington supplies water to the Flanders Filters facility and to the majority
of residents in Shad Bend community. A house-to-house survey of the nineteen residences in
the Shad Bend community confirmed that one family uses their private well for their source of
potable water and another resident drinks bottled water and uses their well water for irrigation.
Other private supply wells are in use in the surrounding area. A survey within the 0.5-mile
radius of the Site boundaries identified approximately 141 residences, two businesses, a Head
Start Center, and the Deeper Life Ministries. The Deeper Life Ministries and three residences
are on city water. The remaining 137 structures are supplied by 77 private potable wells.
None of these wells are considered directly hydraulically downgradient of the Flanders Filters
facility. Consequently, contamination detected in the groundwater and originating from the
Site will not impact these wells.
Three classifications of vegetation were identified at the Site. The predominant type
(around Spray Field #2 and at the western property boundary) is a sandy/dry oak hickory
forest. The wetlands along Mitchell Branch are classified as a gum cypress swamp and there
is small stream swamp vegetation along the drainage ditches.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1969, Flanders Filters developed this property and has since used this facility for the
manufacturing of high-efficiency, borosilicate glass micro-filters and air filter framing systems.
Currently, Flanders Filters, Inc. employs about 300 personnel working three shifts, five days
per week. The property is partially fenced and has gates at the three entrances to the plant.
In April 1969, North Carolina Division of Environmental Management (NCDEM) issued to
Flanders Filters a permit (#1590) to construct and operate a facility to handle 1,000 gallons of
wastewater from the manufacturing process per day. The wastewater facility included two
retention ponds which had a total storage capacity of 330,000 gallons. From 1969 to 1978, an
estimated 500 to 700 gallons of untreated wastewater were transported daily to the Old
Beaufort County landfill for disposal. No records or manifests were kept of these shipments.
In April 1977, NCDEM issued Flanders Filters permit #4276 for a 4,500 gallons per day
(gpd) wastewater treatment system and the use of a 2.75-acre spray field (Spray Field #1) for
the discharge of the treated wastewater. This spray field is now partially covered by the metal
shop (refer to Figure 2). A clay-lined by-pass pond was part of this treatment system. The
use of this facility began in February 1978. No records are available pertaining to the
estimated daily volume discharged to Spray Field #1. Permit #4276 was renewed in March
1982. As a condition of this renewal, Flanders Filters was required to install three monitoring
wells and monitor the groundwater for aluminum and zinc.
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Flanders Filters Site
Record of Decision
September 1998
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In May 1984, Flanders Filters received authorization (permit # 4276-R) to open a 4.08-
acre spray field (Spray Field #2) located southeast of the plant area. This permit required that
additional monitoring wells be installed. The metal shop area was expanded in 1984 and
Spray Field #1 was closed. Also in May 1984, Flanders Filters requested approval to use the
existing wastewater treatment system for the disposal of treated wastewater from a newly
installed metal cleaning system. This system was used for removing mild surface
contaminants and weld oxidation from stainless steel and aluminum filter frames.
During 1986 and 1987, Flanders Filters maintained their permit and obtained approval to
increase flow to Spray Field #2 from 4,500 gpd to 10,000 gpd. No records are available
pertaining to the estimated daily volume discharged to Spray Field #2 during this time. In April
1988, Flanders Filters requested approval to increase the size of Spray Field #2. In response,
the State expressed concern about elevated groundwater levels of nitrate, total dissolved
solids, phenol, and aluminum. Consequentially, the State required the installation of three
additional monitoring wells. In August 1988, permission was granted to expand the spray field
to 8.24 acres with an increase in flow to 20,000 gpd.
In February 1989, the State allowed an increase in flow to 30,000 gpd (under permit #
WQ0000628). As before, no discharge records are available for this time frame, but it has
been reported that the estimated daily volume of treated wastewater discharged to Spray Field
#2 was 2,000 gallons per hour for 8 hours per day, five days per week. Spray Field #2 was
operated for about 10 years and is no longer in operation.
In December 1990, EPA issued the SSI report. Based on the analytical results from the
environmental samples collected as part of the SSI, the following contaminants were detected
in the groundwater: 1,1-dichloroethane (1,1-DCA), 1,1-dichloroethene (1,1-DCE), and 1,1,1-
trichloroethane (1,1,1-TCA).
During June and July 1993, EPA conducted an ESI at the Flanders Filters site. This
study documented the presence of the following contaminants at the Site: chromium, copper,
nickel, zinc, bis (2-ethylhexyl) phthalate, pyrene, and arsenic. No contaminants of concern
were identified in a sample collected from a nearby private well. Bis (2-ethylhexyl) phthalate
and 1,1-DCA were found above detectable levels in one on-site public supply well.
The Flanders Filters site has not been proposed for the National Priorities List (NPL),
however, it is considered a NPL caliber site as the groundwater contamination at the Site is the
caliber of contamination found at sites listed on the NPL. Since there has only been one
owner/operator of this property after being developed into an industrial complex, no
"Responsible Party Search" was performed. Flanders Filters, Inc. has been and remains the
sole owner/operator of the facility. A special notice letter was sent to Flanders Filters, Inc. on
October 10,1995 to provide Flanders Filters an opportunity to conduct the remedial
investigation/feasibility study (RI/FS). A good faith offer was submitted and negotiations were
concluded with Flanders Filters, Inc. signing an Administrative Order on Consent in February
1996 to conduct a Remedial Investigation (Rl) and Feasibility Study (FS) at the Site. It is
anticipated that Flanders Filters will also implement the selected remedy. In addition to
conducting the RI/FS, Flanders Filters has also taken the following actions at the Site in an
effort to eliminate future adverse impacts to the environment as well as minimize their
generation of hazardous waste. The use of the spray fields has been discontinued and
wastewater is now discharged to the City of Washington publicly owned treatment works
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UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
X*t:v3»
. N. C.
SE/4 CHOCOWINtTY IS1 QUADRANGLE
35077-E1-TF-024
1951
PHOTOREVISED 1983
DMA 3333 II 8E- SERIES V842
FIGURE 1 SITE LOCATION MAP
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FIGURE 2 LOCATION OF FACILITIES
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Flanders Filters Site
Record of Decision
September 1998
-6-
(POTW). The facility has virtually eliminated the use of chlorinated solvents. The acid dip
pickling process that generated waste sludge and water has been eliminated. And a new
hazardous waste storage area has been constructed under roof on a diked concrete pad.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
In 1996, community relations activities for this Site were initiated in conjunction with the
development of the RI/FS Work Plan. In developing the June 1996 Community Involvement
Plan, the issues and concerns expressed by local citizens from the Site area were compiled
and an overview of these issues and concerns was prepared. A copy of the Community
Relations Plan was placed in the Information Repository located at the Brown Public Library in
Washington. A mailing list was developed based upon people interviewed, citizens living
around the Site, and people attending Site related public meetings. The mailing list also
includes local, State, and Federal public servants and elected officials.
A public kick-off meeting was held on June 27, 1996. During the RI/FS process, two fact
sheets were mailed and several public meetings were held with respect to the Site.
The public was informed of the June 23, 1998 Proposed Plan Public Meeting through the
Proposed Plan Fact Sheet and ads published on June 20, 21, 22, and 23,1998, in the
Washington Daily News newspaper. The Proposed Plan Fact Sheet was mailed to the public
on June 19,1998. The basis of the information presented in the Proposed Plan was the July
1997 Rl Report and the March 1998 FS document. The Proposed Plan also informed the
public that the public comment period would run from June 23,1998 to July 23,1998.
Prior to the Proposed Plan Public Meeting, representatives from EPA met with City and
County officials to present to them a summary of information to be shared with the public
during the evening public meeting. This meeting provided locally elected officials the
opportunity to ask questions and make comments concerning the Agency's proposed activities.
The goals of the Proposed Plan meeting were to review the findings of the Rl (including
the Baseline Risk Assessment), summarize the remedial alternatives developed, identify the
Agency's preferred alternative as well as the contingent alternative, present the Agency's
rationale for the selection of the preferred alternative, encourage the public to voice its own
opinion with respect to the remedial alternatives evaluated and the remedial alternative
proposed by the Agency, and inform the public that the public comment period on the
Proposed Plan would conclude on July 23, 1998. The public was also informed that a 30 day
extension to the public comment period could be requested and that all comments received
during the public comment period would be addressed in the Responsiveness Summary
section of the Record of Decision (ROD.) No request for the 30-day extension was made.
Pursuant to Section 113(k)(2)(B)(i-v) and 117 of Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), all documents associated with
the development of the Proposed Plan and the selection of the remedial alternative specified
in this ROD were made available to the public in the Administrative Record located both in the
Information Repository maintained at the EPA Docket Room in Region 4's office and at the
Brown Public Library in Washington, North Carolina. A copy of all literature distributed at each
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Flanders Filters Site
Record of Decision
September 1998
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public meeting, as well as a transcript of meeting proceedings, were also placed in the
Information Repositories.
4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
This ROD has been prepared to summarize the remedial selection process and to
present the selected remedial alternative for the entire Flanders Filters site. The source of the
principle threat at the Site was the contaminated soil. Neither surface nor subsurface soils
pose an unacceptable current or future risk to either public health or the environment. Due to
the concentration of chemicals from the source (i.e., soil) found in the underlying groundwater,
the groundwater does pose an unacceptable risk.
The purpose of this response is to prevent exposure to the contaminated groundwater.
Since this Site is not as complex as other NPL sites, all work will be accomplished under one
operable unit, therefore this is expected to be the only ROD for this Site. An operable unit is
assigned for each separate activity undertaken as part of a Superfund site cleanup.
5.0 SUMMARY OF SITE CHARACTERISTICS
In developing the June 1996 RI/FS Work Plan, nine (9) areas of concern (AOC) (i.e.,
potential sources of contamination or areas that may have already been adversely impacted)
were identified (refer to Figure 3). The nine AOC include:
AOC #1 - Vat/Hazardous Waste/Drum Storage Area
AOC #2 - Retention Ponds
AOC #3 - Spray Field #1/Metal Shop Area
AOC #4 - Spray Field #2
AOC its - Aboveground Storage Tanks and By-pass Pond
AOC #6 - Abandoned Railroad Track
AOC #1 - Drainage Ditches (Collectively)
AOC #8 - Mitchell Branch
AOC #9 - Groundwater Underlying the Site
To investigate these potential areas of contamination and to determine the extent of any
contamination at the Site, seventy (70) environmental samples were collected as part of the Rl.
The Rl Report, dated July 28, 1997, (which includes the December 15, 1997 revised
Baseline Risk Assessment) was approved by the Agency on January 26, 1998. The Rl Report
identified the sources, characterized the nature, and defined the probable extent of the
uncontrolled hazardous wastes in the soil, groundwater, and surface water/sediment at the
Site. The Baseline Risk Assessment defined the risk posed by the hazardous contaminants
present in the areas investigated. The Proposed Plan Fact Sheet provided the public with a
summary of the detailed analysis of the four (4) remediation alternatives evaluated in the
March 1998 FS document.
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-8-
Uftnd
Storm Dram Lma
Sir tarn
Property!.**
TIM Lin*
E'KIIng Monitoring Wain H6I
Soil Boring Location nw
Sediment Location
AOC I : Formar AC id Val/Ha>ardouf Wail* Storage/Drum Slora
AOC 2 . P4*l*nllon Pondl
AOC 3 . farm* Sot ay Flak! 'I
AOC 4 . Formar Spray Flald *2
AOC 6 : Abovegfownd Sloraga Tank A/*a
AOC 6 •• Raifroad Lin* ano Oih*r Polaniia' OH.Sito Sourca
AOC 7 : On-Sll* urainac* F*ati/rs to Mltchall Branch
AOC 6 . MilchaU &ancn
AOC 0 . Shallow Ground Walar Aauirar IFnlva Su«. rto $p«rilic
FIGURE 3 LOCATION OF THE NINE AREAS OF CONCERN
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Flanders Filters Site
Record of Decision
September 1998
-9-
The overall nature and extent of contamination associated with the Site is based upon
analytical results of environmental samples collected from the surface and subsurface soils,
the groundwater, surface water and sediment from Mitchell Branch, and sediment from
Tranters Creek, and the chemical/physical and geological/hydrogeological characteristics of
the area.
Environmental samples were collected over a period of time and activities. The majority
of the samples collected were analyzed for volatile organic compounds (VOCs), semi-volatile
organic compounds (SVOCs), and inorganics (i.e., metals and cyanide). The Rl identified the
following contaminants of concern across the Site:
VOCs Inorganics
chloroform aluminum
1,1 -DCA antimony
1,1-DCE chromium
tetrachloroethene
1,1,1-TCA
trichloroethene
vinyl chloride
Figures 4 and 5 show the surface and subsurface soil sampling locations along with the
analytical results of the samples collected, respectively. Figures 6 and 7 show the shallow
groundwater sampling locations along with the analytical results for samples collected in
September 1996 and in October 1997, respectively. Figure 8 shows the intermediate
groundwater sampling locations along with the analytical results for samples collected in
September 1996. Figures 9 and 10 show the on-site surface water and sediment sampling
locations along with the analytical results of the samples collected, respectively. Figures 11
and 12 show the off-site surface water and sediment sampling locations along with the
analytical results of the samples collected, respectively. And Figure 13 shows the wetland
sampling locations along with the analytical results of the samples collected.
Table 1 provides a summary of the RI/FS soil data, Table 2 summarizes the RI/FS
groundwater data, Tables 3 and 4 list the surface water and sediment data, respectively, and
Table 5 encapsulates the wetland data.
5.1 AREAS OF CONCERN
VOCs, SVOCs, and metals were detected in the Acid Vat/Hazardous Waste/Drum
Storage Area (AOC #1). The presence of VOCs and SVOCs in the surface and subsurface
soils as well as the underlying groundwater are consistent with spills and leaks that have
occurred in this area over the years. The probable cause of the elevated metal levels in this
area was the accidental release of approximately 440 gallons of an acidic solution in 1992
from the acid pickling operation.
The analytical data for soil samples collected from the Retention Ponds (AOC #2) and
the Spray Field #1/Metal Shop area (AOC #3) indicate that neither of these areas are sources
of contamination. The source of the contaminants being detected in the groundwater
downgradient of AOC #2 is from the soil associated with AOC #1. The soils in AOC #1 were
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Flanders Filters Site
Record of Decision
September 1998
-10-
contaminated by past activities which included storing and/or handling hazardous waste in this
area.
Trace levels of VOCs and SVOCs were detected in the soils at Spray Field #2 (AOC #4).
Consequently, neither VOCs nor SVOCs are a concern in the soils in this particular area.
Several inorganics were detected at concentrations twice their background level. Of these,
only zinc can be traced back to past Site operations. As with the groundwater beneath AOC
#2, based on groundwater flow directions, it was surmised that the VOCs being detected in the
groundwater beneath AOC #4 have migrated from AOC #1.
Xylenes, numerous semi-volatile polycyclic aromatic hydrocarbons, #2 fuel oil, varsol,
antimony, arsenic, copper, and zinc were detected in the soils associated with the
Aboveground Storage Tanks and By-pass Pond area (AOC #5). Any adverse impact to the
underlying groundwater in this area has been minimized due to the by-pass pond being clay-
lined as clay impedes the migration of most contaminants.
The abandoned railroad track (AOC #6) was not sampled as no creosote related
contaminants were detected in the adjacent drainage ditch. The two drainage ditches,
collectively, were designated as AOC #7. VOCs, SVOCs, and numerous metals were detected
in these drainage ditches. The impact to surface water and sediment in these drainage
ditches is the result of surface water runoff from the plant and parking lot and groundwater
recharge to the these ditches.
Based on surface water and sediment samples collected from Mitchell Branch (AOC #8),
it has been documented that Site related VOCs are being released into this stream. These
contaminants are reaching Mitchell Branch either through the discharge of groundwater into
Mitchell Branch or from surface water flowing through drainage ditches and discharging into
Mitchell Branch, or from a combination of the two. No elevated levels of metals were detected
in the sediment samples collected from Tranters Creek.
The groundwater underlying the Site and migrating towards Mitchell Branch is defined as
AOC #9. Numerous contaminants have been detected in the groundwater at the Site. They
include: chloroform, 1,1-DCA, 1,1 -DCE, tetrachloroethene, 1,1,1-TCA, trichloroethene, vinyl
chloride, aluminum, antimony, and chromium. Refer to Sections 5.3 and 5.5 for more details.
5.2 SUMMARY OF SOIL CONTAMINATION
Organics (fuel oil and varsol SVOC constituents) and inorganics were detected in the
surface soils in AOC #5, adjacent to fuel aboveground storage tanks. In addition, levels of
organic and inorganic compounds were found above background levels in the surface soils in
AOC #1. VOCs and nickel were detected in the subsurface soils at AOC #1. The identified
VOCs include: 1,1-DCE, PCE, 1,1,1-TCA, and TCE. The greatest VOC concentration in the
subsurface soils at AOC #1 was 0.59 milligram/kilogram (mg/kg) or parts per million (ppm) of
1,1,1-TCA (see Table 1).
Antimony was found above the health-based remedial goals, specified in North Carolina
Department of Environment and Natural Resources (NCDENR) Registered Environmental
Consultant Program Implementation Guidance promulgated in 15A North Carolina
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Flanders Filters Site
Record of Decision
September 1998
•11-
Administrative Code (NCAC) 13C.0300, in one surface soil sample collected in AOC #1.
However, antimony was not detected in two additional surface soil samples collected from
AOCn.
These two additional samples were collected from AOC #1 to evaluate whether or not
soils at AOC #1 require remediation. First, contaminant levels in the soils were compared to
NCDENR remedial goals to determine if a threat was posed to human health. Secondly, these
soils were tested to determine if the contaminants present would leach out of the soil resulting
in levels of contaminants that would adversely impact the quality of the groundwater. The
toxicity characteristic leaching procedure (TCLP) was used to evaluate the potential for soils to
leach residual contamination.
None of the contaminants of concern concentrations in the soils in AOC #1 exceed
health-based remedial goals established by NCDENR. Therefore, it was determined that the
soils in AOC #1 do not require remediation to be protective of human health. The data showed
that concentrations of COCs in the leachate were not above groundwater standards.
Therefore, based on NCDENR guidance, the soils in AOC #1 are not considered a threat to
groundwater quality and further support the decision that these soils do not need remediation.
5.3 SUMMARY OF GROUNDWATER CONTAMINATION
The highest levels of contaminants in the groundwater were found downgradient of the
hazardous waste storage area (AOC #1) with trace levels extending across portions of the Site
(refer to Figures 6, 7, and 8). The presence of trace levels of VOCs and elevated
concentrations of metals were found in two of the four former public supply wells (Well-2A and
Well-2B). When operational, these wells created a cone of depression in the groundwater
table. Impacted groundwater from the surficial aquifer may have entered the intermediate
aquifer through the single-cased Well-2B. These wells were taken out of service in 1995.
Data from an October 1997 sampling effort indicates that Well-2A does not contain VOC or
metals concentrations above the performance standards.
Two shallow monitoring wells (OW-1 and OW-2) were installed on the other side of
Mitchell Branch as part of the Rl. The rationale for the installation of these wells was 1) to
determine if Mitchell Branch is a hydrogeologic divide for groundwater and 2) to insure
residents with private potable wells on the other side of Mitchell Branch (i.e., off-site) that the
source of their drinking water (i.e., the groundwater) has not been adversely impacted by Site
activities. Neither well contained volatile nor semi-volatile organic compounds above trace
levels. Concentrations of metals were also below levels of concern. The only organic
contaminant detected in either off-site monitoring well was toluene and it was detected at a
trace level. This data along with groundwater level measurements, verify that Mitchell Branch
is a hydrogeologic divide and that any contaminants that do migrate off-site via groundwater
will discharge into Mitchell Branch and will not travel east of Mitchell Branch via groundwater!
These wells will now act as sentinel wells and will be sampled periodically to insure these
residents that their drinking water has not been adversely impacted by Site activities.
Data collected over time indicates contaminant levels in the groundwater are decreasing
across the site (see Table 7). This observation is supported by the results of the Bioscreen®
model which was performed as part of the FS.
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Flanders Filters Site
Record of Decision
September 1998
-12-
Figures 6, 7, and 8 map the analytical data for groundwater samples collected in
September 1996 and October 1997. Figures 14,15, and 16 show the extent of migration for
the contaminants 1,1-DCA, 1,1-DCE, and PCE in the shallow aquifer, respectively. In Figure
14, the curved line that mimics the tree line in the southern portion of the Site that runs from
monitoring well #4 (MW-4) easterly to monitoring well #10 (MW-10) identifies the extent of 1,1-
DCE migration at the Site. As can be seen in Figures 15 and 16, the other contaminants in
the groundwater either mimic this depiction of migration or have not migrated as far as 1,1-
DCE.
5.4 SUMMARY OF SURFACE WATER AND SEDIMENT CONTAMINATION
The Rl/FS concluded that the groundwater from the surficial aquifer beneath the Site is
discharging into the on-site drainage ditches and Mitchell Branch. Trace levels of VOCs were
detected in surface water samples from Mitchell Branch (Table 3 and Figure 9). As can be
seen in comparing the concentrations of the contaminants between on-site and off-site surface
water samples, the concentrations of the contaminants drop significantly prior to this surface
water commingling with Mitchell Branch. Acetone, methyl ethyl ketone, arsenic, and zinc were
detected in the sediment samples (Table 4 and Figure 10).
Low levels of VOCs and metals water were also detected in the wetlands adjacent to
Mitchell Branch (refer to Figure 13). None of these constituents, at the concentrations
detected, will result in an adverse impact to the environment. The presence of these
contaminants are attributed to surface water flow and groundwater discharge from the shallow
aquifer. No elevated levels of metals were detected in the Tranters Creek sediments which
indicates that Tranters Creek has not and should not be adversely impact by past Site
activities.
5.5 HYDROGEOLOGICAL SETTING
The Site is located in the North Carolina Coastal Plain Physiographic Province. This
region is underlain by Quaternary to Cretaceous age sedimentary deposits composed mostly
of sand with lesser amounts of gravel and limestone. Regional Coastal Plain aquifer units and
their related confining layers are the surficial aquifer, the Yorktown, the Pungo River, the
Castle Hayne, the Beaufort, the Peedee, the Black Creek, the Upper Cape Fear, and the
Lower Cape Fear.
The Site is underlain by Quaternary sediments, the Yorktown Formation, the Castle
Hayne Limestone, the Beaufort Formation, the Peedee Formation, and the Upper and Lower
Cape Fear Formations. The surficial or Quartemary aquifer consists of a yellow-orange to light
brown or tan silty sand to a depth of approximately 14 to 23 feet. The surficial sand layer is an
unconfined aquifer with relatively high hydraulic conductivity and a shallow hydraulic gradient.
In general, groundwater was encountered approximately 1.75 feet below grade.
The underlying Yorktown Formation is a fossiliferous green-gray silty clay stratum about
28 to 30 feet in thickness. The Yorktown clay is a confining layer that impedes downward
movement of groundwater to the underlying aquifers. The estimated hydraulic conductivity of
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Flanders Filters Site
Record of Decision
September 1998
-13-
the Yorktown clay is on the order of ia3 to 10" feet/day (3.5 x 10-7 to 3.5 x 10*
centimeters/second (cm/sec)).
Below the Yorktown clay, a layer of greenish-gray to light brown silty fine sand with some
limestone, 13 to 16 feet thick, was encountered. Based on published literature and soil
conditions, this stratum was determined to be the upper unit of the Castle Hayne Formation.
Below this unit, the porous limestone of the Castle Hayne Formation was encountered to a
depth of about 63 feet.
Based on a literature review, it is estimated that the hydraulic conductivity is 29 feet per
day (0.6 cm/sec) for the surficial aquifer and that wells installed in this formation will yield
anywhere between 2 to 30 gpm. Based on the water level measurements collected from the
shallow wells, the hydraulic gradient for the surficial aquifer ranges between 0.002 to 0.004
feet/feet to the southeast.
December 1996 and July 1997 water levels, Table 8, were used to generate the water
level contour maps for the shallow aquifer (Figures 17 and 18) and for the intermediate aquifer
(Figure 19). Based on these measurements, groundwater in both the surficial and
intermediate aquifers is generally flowing towards the southeast in the direction of Mitchell
Branch. There are two topographical high points near the southern property boundary
between the Site and the Shad Bend subdivision (see Figure 1) which also exert influence.
The groundwater level data collected establishes that the Site is hydraulically downgradient
from the Shad Bend community as well as the houses/businesses on Flanders Filters Road.
Based on the above discussions, it is evident that private wells in the Shad Bend
community have not been adversely impacted by Site activities. This will be verified during the
Remedial Design phase as these wells will be sampled and analyzed for Site related
contaminants.
5.6 EXTENT OF CONTAMINATION
Figures 4 and 5, discussed in Sections 5.0 and 5.2, provide a visual depiction of the
extent of contaminants detected in the surface and subsurface soils, respectively. Figures 6
and 7, discussed in Sections 5.0 and 5.3, provide a visual depiction of the extent of
contaminants detected in the shallow groundwater aquifer based on samples collected in
September 1996 and October 1997, respectively. Figure 8,also discussed in Sections 5.0 and
5.3, provides a visual depiction of the extent of contaminants detected in the intermediate
groundwater aquifer in September 1996. Figures 9 and 11 provide a visual depiction of the
dispersion of contaminants in surface water and Figures 10 and 12 provide a visual depiction
of the distribution of contaminants in sediment. The data presented in these figures is based
on samples collected in September 1996. Figure 13 shows the wetland sampling locations
along with the analytical results of the samples collected. Figures 9,10,11,12, and 13 are
discussed in Sections 5.0 and 5.4.
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Flanders Filters Site
Record of Decision
September 1998
.14.
5.7 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCES USES
Mitchell Branch is not specifically classified due to the low flow conditions within the
stream, however, it is considered as a Class "C" stream under North Carolina Administrative
Code, Title 15A, Subchapter 2B (NCAC 15A-2B.02) because the receiving stream, Tranters
Creek, is classified as a Class C stream. A Class C stream is defined as being suitable for
secondary recreation and the "propagation of natural trout and maintenance of trout".
The groundwater beneath the Site is designated as Class GA in accordance with North
Carolina's water classification system and Class HA under EPA Groundwater Classification
Guidelines (December 1986). The Class GA classifications means that the groundwater is an
existing or potential source of drinking water supply for humans as specified under North
Carolina Administrative Code, Title 15, Subchapter 2L (NCAC 15-2L02). EPA classifies the
groundwater as Class IIA since the aquifer is currently being used as a source of drinking
water in the vicinity of the Flanders Filters facility. Therefore, the groundwater needs to be
remediated to a level protective of public health and the environment as specified in Federal
and State regulations governing the quality and use of drinking water.
Four inactive public supply wells are located on Flanders property. When the presence
of trace levels of VOCs and elevated concentrations of metals were detected in two of these
wells, all of the wells were taken out of service in 1995. Now a public water supply from the
City of Washington is available to all future developments in this area.
Future development may occur in the agricultural land north and northwest. No
development is anticipated in the agricultural land to the west due the presence of the old
Beaufort County Landfill. A March 1998 (Appendix B) letter from Flanders Filters, Inc. strongly
indicates that Flanders Filters, Inc. plans to remain at this location indefinitely.
Private potable wells in the area are completed in the Castle Hayne Formation which is
protected by a confining layer, the Yorktown Formation. No potable wells are located directly
hydrogeologically downgradient of the Site.
6.0 SUMMARY OF SITE RISKS
In order to assess the current and future risks for the Flanders Filters site, a baseline risk
assessment was conducted in conjunction with the Rl. This section of the ROD summaries the
findings concerning the impact to human health and the environment if contaminated media
(i.e., the soils, groundwater, surface water, or sediment) at the Site are not remediated. The
revised December 1997 Baseline Risk Assessment document was incorporated into the July
1997 Rl report which can be found in the Flanders Filters Administrative Record.
Since use of the land surrounding the Flanders Filters facility is a mixture of residential
and agricultural/industrial, two scenarios and their associated pathways were evaluated in the
baseline risk assessment. Under the first scenario, the property remains as an industrial area
(i.e., current conditions). Under the second scenario, the property was transformed into a
residential area (i.e., future conditions).
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Flanders Filters Site
Record of Decision
September 1998
-15-
An exposure pathway is the route or mechanism by which a chemical agent goes from a
source to an individual or population (i.e., the receptor). Each exposure pathway must include
(1) a source or mechanism of chemical release to the environment, (2) a transport medium
(e.g., soil, groundwater, air, etc.), (3) an exposure point (where a receptor will contact the
medium), and (4) an exposure route (i.e., ingestion, inhalation, or dermal contact). A pathway
is considered complete when all of these elements are present.
The exposure pathways evaluated in the Flanders Filters' Baseline Risk Assessment
under current conditions included ingestion, dermal contact, and inhalation of contaminated
groundwater; ingestion and dermal contact to contaminated surface water and stream
sediment; and ingestion and dermal contact to contaminated surface and subsurface soils.
The future risk scenario developed in the Baseline Risk Assessment were for residential
conditions and the same exposure pathways were examined as listed above. For
groundwater, the risk assessment considered only a residential scenario as the Flanders
Filters facility receives its potable water from the City of Washington. For surface water,
sediment, and soil exposure scenarios, the risk assessment evaluated risks for on-site workers
and trespassers. The pathways considered in the Baseline Risk Assessment are summarized
in Table 9.
The Baseline Risk Assessment takes a very conservative approach in calculating risk.
Table 10 summarizes the accumulative effect of all potential exposure pathways/risk scenarios
identified at the Flanders Filters. Under current conditions, the only unacceptable risk is
associated with current residents. However, this unacceptable risk is in conjunction with using
contaminated groundwater for potable purposes. In a facsimile dated August 31, 1998,
Flanders Filters identified that one resident in the Shad Bend community uses a private well for
potable water. However, based on hydrogeologic data (presented in Figures 17,18, and 19)
contaminated groundwater is flowing eastwardly towards Mitchell Branch and not southemly
towards the Shad Bend community. Therefore, it is not anticipated that this well has been
adversely impacted. As specified in the Declaration, this well will be sampled during the
Remedial Design (RD) phase to confirm its status.
Three future risk scenarios were identified which could result in an unacceptable risk to
people if these scenarios became reality. These future risk scenarios entail residents living in
homes built on the Site. The first two scenarios involve residential adults and residential
children using the contaminated groundwater beneath the Site as their source for potable
water. The third scenario that could result in another unacceptable future risk involves a child,
living on-site, ingesting surface soils. The potential for any one of these three exposure
scenarios to occur is extremely small, as no adults or children live on the Site nor is this a
possibility in the near future.
It is the Agency's position that due to the current situation at the Flanders Filters facility
that the future risk scenarios evaluated in the Baseline Risk Assessment will not come to
fruition (i.e., future on-site residents). This position is supported by a March 18, 1998
correspondence from Flanders Filters, Inc. which can be found in Appendix B. This letter
states that Flanders Filters, Inc. is planning is to remain at this location and keep
manufacturing at this "site for the long term foreseeable future". This statement is bolstered by
the fact that Flanders Filters, Inc. is currently investing over $1,000,000 in capital
improvements at the facility. However, if the use of this property is changed prior to the
performance standards (clean-up goals) being achieved, the Agency will re-evaluate this
position.
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-16-
\
o
w
. i
no> I -o j ,—-—
si I ;i.. srM-
• ••» i •
\
FIGURE 4 SURFACE SOIL SAMPLING LOCATIONS AND ASSOCIATED ANALYTICAL RESULTS
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-17-
TfMUM
• 8oiBo(|Loc«uon«(IOt
IOL Inttrunwm CXUebon LMI
SUBSURFACE SOIL SAMPLING LOCATIONS AND ASSOCIATED ANALYTICAL RESULTS
FIGURE 5
-------
-18-
FIGURE6
SHALLOW GROUNDWATER SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS FOR SAMPLES COLLECTED IN SEPTEMBER 1996
-------
-19-
-I
I
\'-\
h
'*aM 1*1 IM«l
UOCI ««/l 1*ft
UOCA »*A W*A.
I.UItA M«A P*«A.
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•*«i ««n
.-?1" .SlSft "*l
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ici
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uoc. <«i »»a
mi^ UITCA l<«/t »«ft
.-. —. l«l »«l
\ \ - ..
i y H« > ••
1.1 Wi
1.1 Ul*
I.UK*
w w*
•\ ....
FIGURE 7 SHALLOW GROUNDWATER SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS FOR SAMPLES COLLECTED IN OCTOBER 1997
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-20-
— PraptnyUn*
^"*» TIM Lin*
v Exiti>ngManloaigW«b(i5)
IDL Imuwion) OMCtian Unit
FIGURE 8 INTERMEDIATE GROUNDWATER SAMPLING LOCATIONS AND ASSOCIATED
ANALYTICAL RESULTS FOR SAMPLES COLLECTED IN SEPTEMBER 1996
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-21-
IOL
SurtKt W«*r LouUon
AOC 7 : On-SM
Inunjrunl O««ctnn Ljna
>« 10 MKfiH Bnncti
FIGURE 9 ON-SITE SURFACE WATER SAMPLING LOCATIONS AND ASSOCIATED ANALYTICAL RESULTS
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-22-
._
Snxm Drain \jf»
SUtun
Prepwty L»
IOL IrauunM 0««chon Limil
FIGURE 10 ON-SITE SEDIMENT SAMPLING LOCATIONS AND ASSOCIATED ANALYTICAL RESULTS
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-23-
Lmnd
SVMHI
- — Propmy Lkw
•-v^-^ Tn*Lin«
SutlK* W«« LouHon
AOC t: Mfcfm Bnnch
liuuuntnt Ddtccion Limil
FIGURE 11 OFF-SITE SURFACE WATER SAMPLING LOCATIONS
AND ASSOCIATED ANALYTICAL RESULTS
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-24-
FIGURE 12 OFF-SITE SEDIMENT SAMPLING LOCATIONS AND ASSOCIATED ANALYTICAL RESULTS
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-25-
Ltgtnd
Skxm Orati Un*
- SbMm
PrapwtyUn*
TiwUn*
FIGURE 13 Wetland SAMPLING LOCATIONS AND ASSOCIATED ANALYTICAL RESULTS
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•26-
Flanders Filters Site
Record of Decision
September 1998
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS DETECTED IN THE SOILS
Analytes
Surface Soils
Frequency
of Detection
Range of
Concentrations
Subsurface Soils
Frequency of
Detection
Range of
Concentrations
Volatile Organic Compounds .
1,1-Dichloroethene
Methylene Chloride
1,1,1 -Trichloroethane
Trichloroethene
Tetrachloroethene
Xylene (total)
0/12
1/12
1/12
0/12
0/12
1/12
ND
ND - 4.0
ND - 6.0
ND
ND
ND - 93.0
1/14
0/12
2/14
2/14
2/14
0/14
ND - 12.0
ND
150 - 590
4.0 - 16.0
29.0 - 74.0
ND
Semi-Volatile Organic Compounds
Acenaphthene
Anthracene
Benzo(a)Anthracene
Benzo(g,h,i)Perylene
Bis(2-Ethylhexyl)Phthalate
Bis(2-Chloroethoxy)Methane
Chrysene
Diethylphthalate
Di-n-Butylphthalate
Fluoranthene
Fluorene
Fuel Oil #2
Gasoline
lndeno(1 ,2,3-cd)Pyrene
Kerosene
2-Methylnaphthalene
Naphthalene
N-Nitrosodiphenylamine
1/12
1/12
1/12
1/12
4/12
1/12
2/12
1/12
1/12
2/12
1/12
1/1
0/1
1/12
0/1
1/12
1/12
1/12
ND - 91.0
ND - 74.0
ND - 57.0
ND - 46.0
76.0 - 9,400
ND - 200
49.0 - 400
ND - 610
ND - 400
63.0 - 1,100
ND - 110
380
ND
ND - 39.0
ND
ND - 2.200
ND - 290
ND - 150
0/14
0/14
0/14
0/14
1/14
0/14
0/14
1/14
1/14
0/14
0/14
0/1
0/1
0/14
0/1
0/14
0/14
0/14
ND
ND
ND
ND
ND - 370
ND
ND
ND - 42.0
ND - 3,000
ND
ND
ND
ND
ND
ND
ND
ND
ND
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Flanders Filters Site
Record of Decision
September 1998
-27-
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS DETECTED IN THE SOILS
Analytes
Phenanthrene
Pyrene
Varsol
Inorganics
Aluminum
Arsenic
Chromium
Copper
Iron
Lead
Manganese
Zinc
Surface Soils
Frequency
of Detection
2/12
2/12
1/1
13/13
11/13
13/13
9/13
13/13
12/13
13/13
9/13
Range of
Concentrations
180 - 440
140 - 890
580
1,100 - 4,770
ND - 2.5.0
1.4 - 43.1
ND - 4.4
892 - 2,450
ND - 16.1
5.3 - 33.9
ND - 159
Subsurface Soils
Frequency of
Detection
0/14
0/14
0/1
Range of
Concentrations
ND
ND
ND
14/14
6/14
14/14
6/14
14/14
11/14
14/14
1/14
576 - 3,680
ND - 1.0
1.1 - 3.2
ND - 1.4
216 - 2.590
ND - 3.6
2.0.0 - 12.2
20.1
SAMPLES COLLECTED DURING Rl
ALL REPORTED CONCENTRATIONS IN MICROGRAMS/KILOGRAM (/ug/kg)
ND - No Detection
-------
-28-
Flanders Filters Site
Record of Decision
September 1998
TABLE 2 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND INORGANIC CONSTITUENTS DETECTED IN THE
GROUNDWATER
Analytes
Shallow Aquifer Sampling
Locations
Frequency of
Detection
Range of
Concentrations
On-site Intermediate
Well Sampling Locations
Frequency of
Detection
Range of
Concentrations
Off-site Monitoring Well
Sampling Locations
Frequency
of Detection
Vti^le0wi<& '"-,-'" " ,
Acetone
Benzene
Carbon Disulfide
Chloroethane
Chloroform
1,4-Dichlorobenzene
1,1-Dlchloroefhane
1,1-Dtehloroethene
cis-1 , 1 -Dichloroethene
Tetrachloroethene
Toluene
1.1,1-Trlchloroethane
Trichloroethene
Vinyl Chloride
1/21
3/21
2/21
2/21
471
0/21
18/21
19/21
4/21
13/21
0/21
18/21
11/21
3/21
ND - 8.0
NO - 5.0
ND - 9.0
ND - 6.0
ND - 0.3
ND
ND - 120
ND - 73.0
ND - 2.0
ND - 5.0
ND
ND - 600
ND - 14.0
ND - 6.0
2/7
3/7
3/7
3/7
3/7
3/7
3/7
3/7
3/7
1/7
3/7
1/7
417
Of?
ND - 21.0
ND - 0.3
ND - 0.5
ND - 0.5
ND -. 0.4
ND - 0.2
ND - 11.0
ND - 5.0
ND - 0.2
ND - 1.0
ND • 4.0
ND - 0.2
ND - 0.2
ND
0/2
012
0/2
012
012
0/2
0/2 '
0/2
0/2
0/2
1/2
0/2
0/2
0/2
Range of
Concentrations
Private Well Sampling
Locations
Frequency of
Detection
Range of
Concentrations
, ' , , ,..
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND - 2.8
ND '
ND
ND
076
0/6
0/6
0/6
0/6
0/6
0/6
0/6
0/6
0/6
0/6
0/6
0/6
0/6
ND
ND
ND
ND
ND.
ND
ND
ND
ND
ND
ND
ND
ND
ND
Semt- Volatile Organic Compounds
Di-n-Butylphthalate
2-Methylphenol
4-Methylphenol
Phenol
2/14
0/14
0/14
1/14
ND - 0.8
ND
ND
ND - 1.0
0/7
1/7
1/7
3/7
ND
ND - 1.0
ND - 1.0
ND - 4.0
0/2
0/2
0/2
0/2
ND
ND
ND
ND
0/6
0/6
0/6
0/6
ND
ND
ND
ND
-------
-29-
Flanders F
Record of Decision
September 1998
TABLE 2 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND INORGANIC CONSTITUENTS DETECTED IN THE
GROUNDWATER
Analytes
Shallow Aquifer Sampling
Locations
Frequency of
Detection
Range of
Concentrations
On-site Intermediate
Well Sampling Locations
Frequency of
Detection
Range of
Concentrations
&ttfd*rtie$ •
Aluminum
Antimony
Arsenic
Chromium
Copper
Iron
Lead
Manganese
Zinc
14/14
1/14
2/14
11/14
5/14
14/14
8/14
14/14
0/14
188 - 12.100
ND - 21.1
ND - 6.5
ND - 36.9
ND - 5.0
279 - 9.840
ND -5.6
30.6 -207
ND
417
0/7
1/7
4/7
1/7
7/7
6/7
6/7
4/7
ND - 550
ND
ND-
ND - 7.9
ND -2.2
64.9-116.000
ND • 42.9
ND - 508
ND - 2,310
Off-site Monitoring Well
Sampling Locations
Frequency
of Detection
Range of
Concentrations
Private Well Sampling
Locations
Frequency of
Detection
Range of
Concentrations
f *
212
012
0/2
0/2
0/2
2/2
1/2
212
0/2
763 - 4,160
ND
ND
ND
ND .
1.410 - 4.500
ND - 3.2
129 - 131
ND
0/6
0/6
0/6
0/6
0/6
5/6
0/6
1/6
5/6
ND
ND
ND
ND
ND
ND - 282
ND
ND - 20.5
ND - 113
SAMPLES COLLECTED DURING Rl AND FS
ALL REPORTED CONCENTRATIONS IN MICROGRAMS/LITER (^g/l)
ND - No DETECTION
-------
-30-
Flanders Filters Site
Record of Decision
September 1998
TABLE 3 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS DETECTED IN THE SURFACE WATER
Analytes
On-site Sampling Locations
Frequency
of Detection
Range of
Concentrations
Off-site Sampling Locations
Frequency
of Detection
Range of
Concentrations
Volatile Organic Compoamfe
Acetone
Benzene
Chloroethane
Chloroform
1,1-Dichloroethane
1,1-Dichloroethene
cis-1 ,2-Dichloroethene
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
Trichloroethene
Vinyl Chloride
5/8
2/8
5/8
3/8
5/8
5/8
1/8
1/8
2/8
3/8
1/8
4/8
• ND - 20.0
ND - 0.1
ND - 0.5
ND - 0.2
ND - 15.0
ND - 13.0
ND - 0.1
ND - 0.04
0.2 - 0.4
1.0 - 22.0
ND - 0.3
0.1 - 0.5
0/5
0/5
0/5
0/5
2/5
2/5
0/5
0/5
0/5
0/5
0/5
0/5
ND
ND
ND
ND
ND - 0.5
ND - 0.4
ND
ND
ND
ND
ND
ND
Semi-Volatile Organic Compounds
2,4-Dimethylphenol
4-Methylphenol
Phenol
1/8
1/8
1/8
ND - 6.0
ND - 4.0
ND - 2.0
Inorganics -' ,
Aluminum
Arsenic
Chromium
Copper
Iron
Lead
Manganese
Zinc
5/8
1/8
2/8
2/8
5/8
2/8
5/8
4/8
ND - 4,210
ND - 2.2
ND - 14.3
ND - 41.1
ND - 7,060
ND - 41.5
ND -314
ND - 298
0/5
0/5
0/5
ND
ND
ND
f :••
5/5
1/5
2/5
2/5
5/5
2/5
5/5
4/5
81.1 - 3,130
ND - 2.8
ND - 3.3
ND - 4.1
837 - 4,360
ND - 4.2
24.4 - 664
ND - 25.1
SAMPLES COLLECTED DURING Rl
ALL REPORTED CONCENTRATIONS IN MICROGRAMS/LITER (^g/l)
ND — No DETECTION
-------
Flanders Filters Site
Record of Decision
September 1998
-31-
TABLE 4 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS DETECTED IN THE SEDIMENT
Analytes
On-site Sampling Locations
Frequency of
Detection
Range of
Concentrations
Off-site Sampling Locations
Frequency of
Detection
Range of
Concentrations
Volatile Organic Compounds
Acetone
2-Butanone
1,1-Dichloroethane
5/8
1/8
1/8
ND - 130
ND - 37.0
ND - 4.0
5/6
2/6
0/6
ND - 220
ND - 39.0
ND
Semi-Voiatite Organic Compounds
Acenaphthene
Anthracene
Benzo(a)Anthracene
Benzo(a)Pyrene
Benzo(b)Fluoranthene
Benzo(k)Fluoranthene
Bis(2-Ethylhexyl)Phthalate
Chrysene
Di-n-Butylphthalate
Fluoranthene
lndeno(1 ,2,3-cd)Pyrene
Phenanthrene
Pyrene
Inorganics
Aluminum
Arsenic
Chromium
Copper
Iron
Lead
Manganese
Zinc
0/8
0/8
0/8
0/8
0/8
0/8
1/8
0/8
4/8
0/8
0/8
0/8
0/8
8/8
3/8
8/8
8/8
8/8
8/8
8/8
7/8
ND
ND
ND
ND
ND
ND
ND - 210
ND
ND - 2,000
ND
ND
ND
ND
-
285 - 12,100
ND - 1.9
1.1 - 15.8
0.98 - 17.0
207 - 3.940
2.0 - 29.6
1.0 - 62.3
ND - 56.8
1/6
1/6
2/6
1/6
2/6
2/6
0/6
2/6
0/6
2/6
1/6
1/6
2/6
8/8
7/8
8/8
8/8
8/8
8/8
8/8
7/8
ND - 75.0
ND - 81.0
ND - 200
ND - 140
ND - 280
ND - 250
ND
ND - 430
ND
ND - 860
ND - 89.0
ND - 280
ND - 780
139 - 13,400
ND - 5.2
0.26 - 11.9
0.39 - 8.8
107 - 10,100
0.86 - 28.2
15.9 - 140
ND - 294
SAMPLES COLLECTED DURING Rl
ALL REPORTED CONCENTRATIONS IN MICROGRAMS/KILOGRAM Gug/kg)
ND ~ No DETECTION
-------
Flanders Filters Site
Record of Decision
September 1998
-32-
TABLE 5 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS DETECTED IN THE WETLANDS
Analytes
Frequency of Detection
Range of Concentrations
Volatile Organic Compounds
Acetone
Benzene
2-Butanone
1,1-Dichloroethane
1,1-Dichloroethene
Methyl Chloride
Inorganics
Aluminum
Arsenic
Chromium
Copper
Iron
Lead
Manganese
Zinc
3/3
2/3
2/3
2/3
1/3
1/3
120 - 1,000
ND - 1,200
ND - 250
ND - 230
ND - 100
ND - 41.0
3/3
3/3
3/3
3/3
3/3
3/3
3/3
2/3
9,340 - 10,600
4.5 - 6.7
7.6 - 9.9
9.6 - 10.5
3,190 - 6,820
28.5 - 59.6
43.4 - 141
ND - 129
SAMPLES COLLECTED DURING Rl
ALL REPORTED CONCENTRATIONS IN MICROGRAMS/KILOGRAM (^9/kg)
ND - No DETECTION
-------
-33-
Flanders Filters Site
Record of Decision
September 1998
TABLE 6 SUMMARY OF SOIL TESTING RESULTS FOR AOC#1
Compounds of Concern
Sampling Location
B-1
B-2
B-2
(duplicate)
B-3
HA-1B
Surface Soils
Total Antimony
Antimony in TCLP Extract
NT
NT
NT
NT
NT
NT
NT
NT
2.2B
0.0092B
Subsurface Soils '
Totals by 8260 and 8270 BN
Acetone
Benzoic Acid
Bis(2-ethylhexyl)Phthalate
1,1-Dichloroethene
Methyl Chloride
Tetrachloroethene
1,1,1 -Trichloroethane
Trichloroethene
0.030U
0.1 7J
0.074J
0.006U
0.004JB
0.006U
0.006U
0.012U
0.013JB
2.2U
0.2J
0.006U
0.005JB
0.006U
0.006U
0.012U
0.017JB
2.2U
0.056J
0.006U
0.005JB
0.006U
0.006U
0.012U
0.056B
2.2U
0.16J
0.006U
0.005JB
0.006U
0.006U
0.01 1U
NT
NT
NT
NT
NT
NT
NT
NT
TCLP Extract by 8260 and 8270 BN
Acetone
Bis(2-ethylhexyl)Phthalate
Chloroform
1,1-Dichloroethene
Methyl Chloride
Tetrachloroethene
1,1,1 -Trichloroethane
Trichloroethene
0.008JB
0.012U
0.001 U
0.0008U
0.097B
0.001 U
0.0009U
0.0009U
0.016B
0.012U
0.001 U
0.00008U
0.077B
0.001 U
0.0009U
0.0009U
0.012B
0.012U
0.001 U
0.0008U
0.11B
0.001 U
0.0009U
0.0009U
0.012B
0.012U
0.003J
0.0008U
0.085B
0.001 U
0.0009
0.0009U
NT
NT
NT
NT
NT
NT
NT
NT
All Reported Concentrations in micrograms/liter (^g/l)
NT - Sample Not tested for this Analyte
TCLP - Toxicity Characteristic Leaching Procedure
B - Compound Detected in Laboratory Blank
J ~ Detected Below Laboratory Detection Level, Estimated Value
U - Result Below Method Quantitation Limits
-------
-34-
Flanders Filters Site
Record of Decision
September 1998
TABLE 7 HISTORICAL LEVELS OF VOLATILE ORGANIC COMPOUNDS FOR WELLS AROUND
FORMER SPRAY FIELD
Well
MW-8
MW-9s
MW-10
MW-11s
Sampling Date
November '88
July '92
February '95
September '96
October '97
November '88
July '92
February '95
September "96
October '97
November '88
July '92
February '95
September '96
October "97
November '88
July '92
February "95
September '96
October '97
Contaminant of Concern
1,1-Dichloroethene
140J
97
33
21
12
35
36
6.6
10
NA
NA
10
0.8
2
2
NA
190
8.8
9
6
1,1-Dichloroethane
170J
90
14
26
14
54
49
3.1
8
NA
NA
9J
< 0.5
3
4
NA
110
11
9
6
1,1,1-Trichloroethane
1,400
170
18
15
6
74
58
4
12
NA
NA
10
< 0.5
2
1
NA
340
2.8
4
2
ALL CONCENTRATIONS REPORTED MICROGRAM/LITER (//G/L)
NA - No AVAILABLE, WELL WAS NOT SAMPLED
J - ESTIMATED VALUE
-------
-35-
FIGURE 14 DISTRIBUTION OF 1 ,I-DICHLOROETHANE IN THE SHALLOW GROUNDWATER AQUIFER
-------
-36-
Ugtrut
Sloan OfBki Un»
flrmmm
DvWn
Property Un*
TrMUn*
ExMIng Monitoring W«tl* (15)
Itocanecnlmtton Cemour Unt (UQ\)
(DMtMd WMT* Appro0n«l«»
FIGURE 15 DISTRIBUTION OF I.I-DICHLOROETHENE IN THE SHALLOWGROUNDWATER AQUIFER
-------
Ugtnd
Storm Drain lira
StrMm
PropwtyUrw
TrMUrw
ExWng Montertng Writ* (IS)
l«ooone«itmtlon ContowUrw (ugAJ
FIGURE 16 DISTRIBUTION OF TETRACHLOROETHENE IN THE SHALLOW GROUNDWATER AQUIFER
-------
-38-
Flanders Filters Site
Record of Decision
September 1998
TABLE 8 GROUNDWATER LEVEL DATA
Well*
MW-4
MW-8
MW-9S
MW-9i
MW-10
MW-11s
MW-11J
MW-12s
MW-12J
MW-13
MW-14
MW-15
MW-16
MW-17
OW-1
OW-2
Top of Casing
Elevation
(Above MSL)
19.72
17.15
17.18
19.12
15.92
19.45
21.03
17.19
17.14
16.14
16.75
22.01
10.02
18.05
14.84
9.05
Screen
Interval
13 to 18
-11 to 16
-11 to 16
59.2 to 69.2
-12 to 1.7
-10 to 15
64.5 to 74.5
4 to 14
65 to 75
4 to 14
4.5 to 14.5
6 to 16
6 to 16
6 to 16
5 to 15
5 to 15
Depth to Water
12/1 0/96 or
1/9/97
8.77
10.43
9.21
14.27
9.59
9.47
5.72
4.3
8.32
4.433
5.92
13.57
NI/NM
NI/NM
5.67
2.38
Depth to
Water
7/8/97
10.19
11.21
10.10
15.52
10.34
10.64
16.71
7.13
9.58
6.10
7.41
14.88
NI/NM
NI/NM
NI/NM
NI/NM
Depth to
Water
10/22/97
11.30
11.80
Dry at 10.35
15.05
11.21
11.86
16.43
8.10
9.7
6.83
8.14
16.24
6.85
10.57
7.38
3.99
ALL MEASUREMENTS IN FEET
ALL ELEVATIONS IN FEET ABOVE MEAN SEA LEVEL (MSL)
Nl - WELL NOT INSTALLED AS OF THIS DATE
NM - NOT MEASURED ON THIS DATE
-------
* ExMingMon!toftigWril*(1S)
(7.131 Oreund WM*r ElcvDion
Ground WM«r Contour
Ground W»I«r Flow Direction
FIGURE 17 SHALLOW GROUNDWATER CONTOUR MAP BASED ON SEPTEMBER 1996 DATA
-------
-40-
FIGURE 18 SHALLOW GROUNDWATER CONTOUR
MAP BASED ON OCTOBER 1997 DATA
-------
Uytnd
Storm Drain Un*
Stracm
PropwtyUn*
TrMUn*
ExMng Mentoring W«l* (IS)
(4.32^ Ground Wll«rEI»wlion
—- •- Oround Walir Contour (0«rft«f Whcrt M*rr«d)
FIGURE 19 INTERMEDIATE GROUNDWATER CONTOUR MAP BASED ON SEPTEMBER 1996 DATA
-------
Flanders Filters Site
Record of Decision
September 1998
-42- ^_
Based on the above discussion, there are no unacceptable current risks associated with
the Flanders Filters site and the only unacceptable future risks are associated with residents
living on the Site or using the adversely impacted groundwater as their source of potable
water.
The following factors were considered as part of this Ecological Risk Assessment:
• assess the components of biological communities on-site and in the vicinity, including
vegetation, mammals, birds, reptiles, amphibians, and the aquatic biota;
• determine the location, extent, and characteristics of ecological resources on-site and in
the vicinity that could serve as wildlife habitat or provide other ecological functions; and
• identify overt effects of contamination on biological communities.
The ecological assessment identified the following contaminants as potential
environmental stressors:
acetone aluminum copper
benzene arsenic iron
bis (2-ethylhexyl) phthalate chromium lead
zinc
These environmental stressors are present in on-site surface and subsurface soils,
groundwater, and surface water and sediments; surface water and sediments found in Mitchell
Branch; and in the wetlands located between the Site and Mitchell Branch. Of the constituents
listed above, aluminum and zinc were identified as potential metals that could bioaccumulate in
the aquatic ecosystem.
No metals were detected in Mitchell Branch or Tranters Creek above twice background
concentrations. And no levels of volatile organics were detected above performance goals in
Mitchell Branch. Due to the low levels of contaminants detected in the environment, only a
slight potential exists that these contaminants would cause an adverse affect to the ecology.
This determination is supported by the following observations 1) the diverse benthic
macroinvertebrates inhabiting Mitchell Branch, 2) a wide variety of animal species on and
around the Site, and 3) the lack of a visually stressed vegetation. The habitat around the Site
has a high ecological value. Therefore, it is the Agency's determination that an active
remediation in or around Mitchell Branch is not warranted.
7.0 REMEDIAL ACTION OBJECTIVES
Section 5.0 defined the extent and characterized the contamination and the
environmental setting. Section 6.0 highlighted the human health and environmental risks
posed by the Site. This Section specifies the remedial action objectives to protect human
health and the environment. These remedial action objectives are warranted as 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. Remedial action
-------
Flanders Filters Site
Record of Decision
September 1998
•43-
objectives are established to protect human health and the environment from each
environmental media of concern by preventing exposures to concentrations of contaminants
above risk-based human health or environmental standards. Protecting human health is
achieved by either reducing exposure or reducing contaminant levels. Protection of the
environment includes protection of natural resources for future uses.
In identifying the remedial action objectives, the findings of the Baseline Risk
Assessment were used as well as an examination of all potential Federal and State
environmental applicable or relevant and appropriate requirements (ARARs). ARARs are
discussed in Sections 7.1 and 7.2.
The specific remedial action objectives and general response actions for the Flanders
Filters site are:
• Remediate groundwater to the specified remediation levels;
• Limit the exposure of receptors to impacted groundwater; and
• Monitor contaminant levels in groundwater, surface water, and sediment to ensure the
remedial action is protective of human health and the environment.
7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
Section 121 (d) of CERCLA, as amended by Superfund Amendments and
Reauthorization Act of 1986 (SARA), requires that remedial actions comply with requirements
or standards set forth under Federal and State environmental laws. The requirements that
must be complied with are those laws that are applicable or relevant and appropriate to the (1)
remedial action, (2) site location, and (3) media-specific contaminations at the Site.
"Applicable" requirements defined in 40 C.F.R. § 300.400(g)(1) are those requirements
applicable to the release or remedial action contemplated based upon an objective
determination of whether the requirements specifically addresses a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA
site. These requirements would have to be met under any circumstance. "Relevant and
Appropriate" requirements defined in 40 C.F.R. § 300.400(g)(2) are those requirements that
address problems or situations sufficiently similar to the circumstances of the release or
removal action contemplated, and whether the requirement is well suited to the Site.
ARARs are categorized as chemical-specific, action-specific, or location-specific.
Chemical-specific ARARs are acceptable exposure levels to particular chemicals and is the
limit that must be met for that contaminant within an environmental medium (i.e., water, soil, or
air) at a specific compliance point. Action-specific requirements are controls or restrictions for
particular activities related to the implementation of the remedial alternative. Location-specific
ARARs address site-specific aspects such as a critical habitat upon which endangered species
or threatened species depend, the presence of a wetland, or a historically significant feature.
-------
-44-
Flanders Filters Site
Record of Decision
September 1998
TABLE 9 CURRENT AND FUTURE EXPOSURE PATHWAYS CONSIDERED IN THE BASELINE RISK ASSESSMENT
RELEASE MEDIA
ENVIRONMENTAL PATHWAY
EXPOSED POPULATION
EXPOSURE PATHWAY
CURRENT EXPOSURE PATHWAYS
Groundwater
Groundwater
Groundwater
Surface Water
Surface Water
Soil (Surface + Subsurface)
Soil (Surface + Subsurface)
Sediment
Sediment
Groundwater Transport
Groundwater Transport
Volatilization
Groundwater Transport
Groundwater Transport
Direct Contact with Impacted Soils
Direct Contact with Impacted Soils
Direct Contact with Impacted
Sediment
Direct Contact with Impacted
Sediment
Child + Adult Resident
Child * Adult Resident
Child + Adult Resident
On-site Worker, Site Trespasser
On-site Worker, Site Trespasser
On-site Worker, Site Trespasser
On-site Worker, Site Trespasser
On-site Worker, Site Trespasser
On-site Worker, Site Trespasser
Ingestion of Impacted Groundwater
Dermal Contact with Groundwater
Inhalation of VOCs
Ingestion of Impacted Surface Water
Dermal Contact with Surface Water
Incidental Ingestion of Impacted Soils
Dermal Contact With Impacted Soils
Incidental Ingestion of Impacted
Sediments
Dermal Contact with Impacted
Sediments
FUTURE EXPOSURE PATHWAYS
Groundwater
Groundwater
Groundwater
Surface Water
Surface Water
Soil (Surface + Subsurface)
Soil (Surface + Subsurface)
Sediment
Sediment
Groundwater
Groundwater
Volatilization
Groundwater Transport
Groundwater Transport
Direct Contact with Impacted Soils
Direct Contact with Impacted Soils
Direct Contact with Impacted
Sediment
Direct Contact with Impacted
Sediment
Child + Adult Resident
Child + Adult Resident
Child + Adult Resident
Child + Adult Resident
Child + Adult Resident
Child + Adult Resident
Child + Adult Resident
Child + Adult Resident
Child + Adult Resident
Ingestion of Impacted Groundwater
Dermal Contact with Groundwater
Inhalation of VOCs
Ingestion of Impacted Surface Water
Dermal Contact with Surface Water
Incidental Ingestion of Impacted Soils
Dermal Contact with Impacted Soils
Incidental Ingestion of Impacted
Sediments
Dermal Contact with Impacted
Sediments
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Flanders Filters Site
Record of Decision
September 1998
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TABLE10 SUMMARY OF CUMULATIVE HEALTH RISK BASED ON THE BASELINE RISK
ASSESSMENT
CARCINOGENIC RISK
NON-CARCINOGENIC RISK
ON-SITE
WORKER
Within Acceptable Risk Range
Risk - 8.2 x 10-6
Within Acceptable Risk Range
HQ = 0.62
SITE
TRESPASSER
Within Acceptable Risk Range
Risk - 9.5 x10'7
Within Acceptable Risk Range
HQ = 0.04
CHILD RESIDENT
• (CURRENT)
Just Within Acceptable Risk Range
Risk - 5.9 x 10'5
Risk due to Contaminants in
Groundwater
Unacceptable Risk
HQ = 5.7
Risk due to Contaminants in
Groundwater
ADULT RESIDENT
(CURRENT)
Just Within Acceptable Risk Range
Risk - 8.5x10"
Risk due to Contaminants in
Groundwater
Unacceptable Risk
HQ =7.6
Risk due to Contaminants in
Groundwater
CHILD RESIDENT
(FUTURE)
Just Within Acceptable Risk Range
Risk - 6.2 x 10"4
Risk due to Contaminants in
Groundwater
Unacceptable Risk
HQ = 2.4
Risk due to Contaminants in
Groundwater
ADULT RESIDENT
(FUTURE)
Just Within Acceptable Risk Range
Risk - 8.6X10-4
Risk due to Contaminants in
Groundwater
Unacceptable Risk
HQ = 2.6
Risk due to
Contaminants in Groundwater
HQ - Hazardous Quotient
The chemical-, action-, and location-specific ARARs for the selected and contingent
remedial alternatives are listed in Table 11. The chemical-specific ARARs are further
discussed in Section 7.2 PERFORMANCE STANDARDS.
7.2 PERFORMANCE STANDARDS
Based on the discussions in Sections 5.2 and 6.0, it is evident that Site soils do not need
to be remediated. Section 6.0 also provides the rationale, taken from the Ecological Risk
Assessment, supporting the Agency's decision not to implement an active remediation
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Flanders Filters Site
Record of Decision
September 1998
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alternative for addressing the limited contamination in Mitchell Branch and its associated
wetlands. Table 12 provides the groundwater performance standards. Because the
concentration of 1,1-DCE in on-site surface water exceeds North Carolina's surface water
standard, 1,1-DCE was incorporated into Table 13 which provides the surface water
performance standard for the Flanders Filters site. These performance standards are based
on the identified ARARs.
8.0 DESCRIPTION OF ALTERNATIVES
Table 14 presents the results of the final screening of the remediation technologies.
Effectiveness, implementability, and relative capital and operation and maintenance costs are
the criteria used in the evaluation.
The four (4) remediation alternatives retained are described below.
8.1 REMEDIAL ALTERNATIVES
Alternative RAA1: No Action
Alternative RAA2: Monitored Natural Attenuation, Sample Private Wells in the Shad
Bend Community, Institutional Controls, Abandonment of Inactive
Supply Wells, & Removal of Aboveground Storage Tanks in AOC
#5
Alternative RAA3: Limited Groundwater Extraction with Discharge to Mitchell Branch
via an NPDES Permit, Sample Private Wells in the Shad Bend
Community, Monitoring, Institutional Controls, Abandonment of
Inactive Supply Wells, & Removal of Aboveground Storage Tanks in
AOC #5
Alternative RAA4: Air Sparging with Soil Vapor Extraction, Sample Private Wells in the
Shad Bend Community, Monitoring, Institutional Controls,
Abandonment of Inactive Supply Wells, & Removal of Aboveground
Storage Tanks in AOC #5
The cost information below represents the estimated Total Present Worth of each
alternative. Total present worth was calculated by combining the capital cost plus the present
worth of the annual operating and maintenance costs. Capital cost includes construction,
engineering and design, equipment, and site development. Operating costs were calculated
for activities that continue after completion of construction, such as routine operation and
maintenance of treatment equipment, and monitoring. The present worth of an alternative is
the amount of capital required to be deposited at the present time at a given interest rate to
yield the total amount necessary to pay for initial construction costs and future expenditures,
including operation and maintenance (O&M) and future replacement of capital equipment. A 7
percent discount rate was used to calculate the Present Worth Operation & Maintenance
Costs.
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IteliRe
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Flanders FiltelVPHe
Record of Decision
September 1998
TABLE 1 1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
REQUIREMENTS
CODIFICATION
DESCRIPTION
ARAR EVALUATION
Applicable
Relevant +
Appropriate
To Be
Considered
FEDERAL Chamtoal-SpecificARARs
CERCLA
Safe Drinking Water Act
National Primary Drinking
Water Standards
Maximum Contaminant
Level Goals
Clean Water Act
Water Quality Criteria
RCRA
Clean Air Act
National Primary +
Secondary Ambient Air
Quality Standards
National emissions
Standards for Hazardous Air
Pollutants
42 USC 9605 et. seq.
40 CFR Part 141
40 CFR Part 131
42 USC 6905 et seq.
40 USC 1857
40 CFR Part 50
40 CFR Part 61
Establishes response program to remediate
release of hazardous substances to the
environment from inactive disposal units
Established maximum contaminant levels which
are health-based standards for public water
systems
Maximum contaminant level goals represent
drinking water quality goals that do not cause
known or anticipated adverse health effects
Water quality criteria based on toxicity to
aquatic life + human health
Establishes requirements for the identification +
management of solid and hazardous wastes,
includes regulation of soil and groundwater
impacted with hazardous wastes
Establishes air quality standards protective of
public health
Establishes emissions standards for air
pollutants that have no ambient air quality
standard
Yes
Yes
Yes
Yes
Yes-
Yes'
Yes*
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Flanders Filters Site
Record of Decision
September 1998
TABLE 1 1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
REQUIREMENTS
OSHA
CODIFICATION
29CFR 1910.120
DESCRIPTION
Establishes health •»• safety rules for site
workers in handling contaminated media during
remediation activities
ARAR EVALUATION
Applicable
Yes
Relevant +
Appropriate
To Be
Considered
STATE C!w»l
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Flanders F
Record of Decision
September 1998
TABLE 1 1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
REQUIREMENTS
CODIFICATION
DESCRIPTION
ARAR EVALUATION
Applicable
Relevant +
Appropriate
To Be
Considered
STATEAdttort-SpecificARARs
Natural Attenuation
North Carolina Groundwater
Quality Standards
North Carolina Water
Quality Standards
Land Use Restrictions
Deed Recordation
Well Abandonment
Groundwater Treatment
North Carolina Air Pollution
Control Requirements
Land Use Restrictions
Deed Recordation
Well Abandonment
15ANCAC2L
15ANCAC2B
15ANCAC13C 130A-
310.3(f)
15ANCAC 2C-0108
15ANCAC2C.0108
15ANCAC2D
15ANCAC13C130A-
310.8
15ANCAC13C 130A-
310.8
15ANCAC2C.0108
Requirements for groundwater standards based
on aquifer classifications
Requirements for surface water quality
Statute allowing State to accept land use
restrictions
Statute allowing deed Recordation
Statute regulating well construction +
abandonment
Emission standards that may apply to remedial
systems
Statute allowing State to accept land use
restrictions
Statute allowing deed recordation
Statue regulating well construction +
abandonment
Yes
Yes
Yes
Yes
Yes
Yes'
Yes
Yes
Yes
LOCAL Action-Specific ARAR$
Deed Recordation
Deed recordation by Register of Deeds
Yes
FEDERAL Location-Specific ARARs
Federal Endangered Species
Act
50 CAR 200 + 402
Establishes actions to avoid jeopardizing the
existence of listed endanger species or their
habitats
Yes
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Flanders Filters Site
Record of Decision
September 1998
TABLE 1 1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
REQUIREMENTS
Fish * Wildlife Coordination Act
Protection of Wetlands
CODIFICATION
16 USC 661-666
40 CAR 6
DESCRIPTION
Lists actions to protect wildlife + fish from
actions modifying streams or adjacent areas
Requirements to avoid the destruction of
wetlands
ARAR EVALUATION
Applicable
Relevant +
Appropriate
Yes
Yes
To Be
Considered
* - Pertains to the contingent remedial action
t - Would be applicable .if soils beneath aboveground storage tanks are contaminated
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Flanders F
Record of Decision
September 1998
TABLE 12 GROUNDWATER PERFORMANCE STANDARDS AND CORRESPONDING RISKS
CHEMICAL OF
CONCERN
RANGE AND
FREQUENCY ( ) OF
DETECTION
(^g/l)
PERFORMANCE
STANDARDS
(CLEANUP GOALS)
POINT OF COMPLIANCE
BASIS OF
STANDARD
CORRESPONDING RISK LEVEL
CARCINOGENIC
RISK
NON-CARCINOGENIC
RISK
VOLATILE; ORGANJC COMPOUNDS ,
Chloroform
(Trihalomethanes)
1.1-Dichloroethene
Tetrachloroethene
1,1,1 -Trichloroethane
Trichloroethene
Vinyl Chloride
ND - 0.4 (7/36)
ND - 73.6 (22/36)
ND - 5.0 (3/36)
ND - 600 (9/36)
ND - 14(15/36)
ND - 6.0 (3/36)
0.19
7.0
0.7
200
2.8
0.015
Throughout Entire Plume
Throughout Entire Plume
Throughout Entire Plume
Throughout Entire Plume
Throughout Entire Plume
Throughout Entire Plume
NCAC 2L
MCL/NCAC 2L
NCAC 2L
MCL/NCAC 2L
NCAC 2L
NCAC 2L
1.54x10-*
5.67x10-*
4x10'7
NA
4x107
3x10r
HQ = 0.001
HQ = 0.05
HQ = 0.004
HQ = 0.56
HQ = 0.03
NA
INOROANICS ,.,.-' ' , ,,,, - ' ..
Aluminum
Antimony
Arsenic
Iron
Manganese
ND - 12,100(20/29)
ND - 21.1 (1/29)
ND - 6.5 (3/29)
ND - 9,840 (28/29)
ND - 508 (23/29)
15,714
6
50
300
50
Throughout Entire Plume
Throughout Entire Plume
Throughout Entire Plume
Throughout Entire Plume
Throughout Entire Plume
HQ
MCL
MCL/NCAC 2L
MCL/NCAC 2L
MCL/NCAC 2L
NA
NA
7.05x10^
NA
NA
HQ = 1
HQ = 1
HQ = 10.5
HQ = 0.06
HQ = 0.15
^g/l - microgram per liter or parts per billion
HQ - Hazard Quotient
N/ICL - Maximum Contaminant Level as specified in the Safe Drinking Water Act
NCAC 2L -- North Carolina Administrative Code specifying State Groundwater Classification & Standards
NA - Not Applicable
ND - Not Detected
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Flanders Filters Site
Record of Decision
September 1998
TABLE 13 SURFACE WATER PERFORMANCE STANDARDS AND CORRESPONDING RISKS
CHEMICAL OF
CONCERN
RANGE AND
FREQUENCY () OF
DETECTION
PERFORMANCE
STANDARDS
(CLEANUP GOALS)
POINT OF
COMPLIANCE
BASIS OF
STANDARD
CORRESPONDING RISK LEVEL
CARCINOGENIC
RISK
NON-
CARCINOGENIC
RISK
VOLATILE ORGANIC COMPOUNDS
1,1-Dichloroethene
ND - 13.0 (7/13)
3.2
At Surface Water
Sampling
Locations SW-5
and SW-11
NCAC 2B
1.28x105
HQ = 0.007
g/l - microgram per liter or parts per billion
HQ - Hazard Quotient
NCAC 2B -- North Carolina Administrative Code specifying State Surface Water Classifications & Standards
ND - Not Detected
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Flanders Filters Site
Record of Decision
September 1998
Table 14 FINAL SET OF REMEDIAL ACTION TECHNOLOGIES AND PROCESS OPTIONS
Environmental Media
Groundwater
General Response
No Action
Institutional Controls
Collection Actions
Ex-situ Treatment
In-situ Treatment
Discharge Actions
Remediation
Technology
No Action with
Monitoring
Deed controls
Monitoring
Limited Groundwater
Extraction
Physical/Chemical
Treatment
Air Sparging
Monitored Natural
Attenuation
Off-site
Process Option
Not applicable
Deed restriction and
recordation
Surface water
monitoring
Extraction wells
Air stripping
Air sparging with soil
vapor extraction
Natural Attenuation
Surface water
(NPDES)
8.1.1 ALTERNATIVE RAA1: No Action
The No Action alternative is included, as required by CERCLA, to establish a baseline for
comparing the benefits achieved by the other remediation alternatives. Under this alternative,
no cleanup activities would be implemented (i.e., the Site is left "as is"). Because this
alternative does not actively remove or destroy contaminants, hazardous materials would
remain on Site requiring a review of the Site's remedy every five years in accordance with
CERCLA Section 121 (c). Therefore, semi-annual groundwater and surface water monitoring
would be performed in preparation to develop the Five-Year Review document. The analytical
results would also be compared to the predicted plume behavior produced by Bioscreen®
model which was performed as part of the FS. This review process will continue every five
years until the performance standard (cleanup goal) for the identified contaminants (Table 12)
in the groundwater are achieved. The implementation of this remedy could begin immediately
and would have no negative impact on future remedial actions.
Since no action is taken, migration of contaminants in the groundwater will continue.
This migration results from the natural movement of precipitation (e.g., rain and melted snow)
moving through the overlying formation and the natural movement of groundwater in the
aquifer. Although Alternative RAA1 does not actively reduce or eliminate contamination, it is
anticipated that the levels of the contaminants will decrease over time due to the process of
natural attenuation. Based on the Bioscreeri* model, using a first order of decay, it was
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Flanders Filters Site
Record of Decision
September 1998
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estimated to take approximately 9 years for the levels of organic contaminants in the
groundwater to decline to their clean-up levels.
There is a minimal capital cost associated with Alternative RAA1. The capital cost is for
the development of a work plan for preparing Five-Year Review Reports and the monitoring
activities necessary for the preparation of these reports. Operating & Maintenance Costs are
associated with periodic monitoring of the Site in order to prepare the Five-Year Review
Reports. As part of the five year review, groundwater and surface water samples will be
initially collected for chemical analyses on a semi-annual basis, however, as the data base
builds, the sampling frequency may be modified.
Capital Costs: $ 8,000
Present Worth Operating & Maintenance Costs: $256.000
Total Present Worth Costs: $264,000
Time to Design: None
Construction Time: None
8.1.2 ALTERNATIVE RAA2: Monitored Natural Attenuation. Sample Private Wells in
Shad Bend Community. Institutional Controls. Abandonment of Inactive Supply
Wells. & Removal of Aboveqround Storage Tanks in AOC #5
"Monitored natural attenuation" relies on natural attenuation processes to achieve site-
specific remedial objectives within a time frame that is reasonable compared to that offered by
other more active methods. The "natural attenuation processes" that are at work in a
remediation approach include a variety of physical, chemical, and/or biological processes that,
under favorable conditions, act without human intervention to reduce the mass, toxicity,
mobility, volume, or concentration of contaminants in soil or groundwater. These in-situ
processes include biodegradation; dispersion; dilution; sorption; volatilization; and chemical or
biological stabilization, transformation, or destruction of contaminants.
Groundwater and surface water quality will be initially monitored, at a minimum, on a
semi-annual basis. In addition to analyzing the groundwater for VOCs, SVOCs, and inorganics
(as needed), the groundwater will also be monitored on a periodic basis for natural attenuation
parameters. The Draft EPA Region 4 Suggested Practices for Evaluation of a Site For Natural
Attenuation (Biological Degradation) of Chlorinated Solvents, November, 1997, Version 3.0 is
to be used for guidance, as amended. The data generated from this monitoring effort will be
used to 1) insure that the contaminants are not migrating further than predicted (Bioscreen*
model), 2) develop and maintain a data base that confirms and verifies that natural attenuation
is occurring, and 3) compare the testing results to the predicted plume behavior generated by
a fate and transport model. Water levels will be measured in all monitoring wells on a quarterly
basis until any seasonal perturbations in the groundwater flow direction have been
established. As a part of this remedy and to confirm the time frame (estimated to be 9 years)
to achieve the groundwater performance standards across the entire Site, a fate and transport
model, using Bioplume II, RT3D, or equivalent, will be conducted to predict plume behavior
over time. To assist with this modeling effort, an additional groundwater monitoring well will be
installed downgradient of MW-14, approximately 400 feet to the southeast.
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Flanders Filters Site
Record of Decision
September 1998
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Flanders Filters, Inc. verified the week of August 24,1998 that one of the residents in the
Shad Bend community use their private well as their source of potable water. Consequently,
to confirm that the groundwater underlying the Shad Bend community has not been adversely
impacted by Site activities, all existing wells in the Shad Bend community need to be sampled.
The sampling of these wells shall be incorporated into the overall groundwater monitoring
strategy to be developed during the Remedial Design phase.
The institutional controls to be implemented as part of this alternative include "land use
restrictions" and "deed recordation". The ability to implement these two institutional controls is
codified under 15A NCAC 13C 130A-310.3(f) and 15A NCAC 13C 130A-310.8, respectively.
The land use restriction will contain language to accomplish the following three objectives: 1)
restrict future land use which would decrease the likelihood of human exposure to
contaminants in the soils, 2) prevent the installation of a potable well at the Site until the levels
of contamination in the groundwater under the Site are deemed safe, and 3) prevent
excavation in contaminated soils without sufficient personal protection for the workers. The
deed recordation will contain language that will inform any potential buyer of the property of
the contamination present. The suitable land use restrictions and deed recordation shall be
recorded in the appropriate state, county, and/or local office(s).
In an effort to prevent any migration of contaminants into the lower aquifer, the four
inactive supply wells will be abandoned in accordance to North Carolina regulation NCAC, Title
15A, Subchapter 2C, Section .0100, Subsection .0113 - Abandonment of Wells. To reduce
future liability, all of the aboveground storage tanks in area AOC#5 will be removed. After their
removal, the surrounding and underlying soils will be visually inspected and sampled.
As with Alternative RAA1, Five-Year Review Reports will be prepared until all
performance standards are obtained across the entire Site.
Capital Costs: $ 88,000
Present Worth Operating & Maintenance Costs: $298,000
Total Present Worth Costs: $386,000
Time to Design: 3 months
Construction Time: N/A
Duration to Achieve Clean-up: 9 years
8.1.3 ALTERNATIVE RAA3: Limited Groundwater Extraction with Discharge to
Mitchell Branch via an NPDES Permit. Sample Private Wells in Shad Bend
Community. Monitoring. Institutional Controls. Abandonment of Inactive Supply
Wells. & Removal of Aboveqround Storage Tanks in AOC #5
This alternative employs extraction wells in two areas of the Site to remove contaminated
groundwater from the shallow aquifer. It was estimated that two extraction wells would be
installed in the vicinity of AOC #1 and a row of six extraction wells would be installed between
the Former Ponds 1 & 2 and the leach field. Extracted groundwater would be piped to an on-
site air stripping unit and discharged to Mitchell Branch in accordance with an National
Pollutant Discharge Elimination System (NPDES) permit. Additional treatment of extracted
groundwater, such as pH adjustment and metals removal, may be necessary in order to the
achieve discharge limits established in the NPDES permit. Due to the low levels of emissions
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Record of Decision
September 1998
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expected from the air stripping unit, the vapors would be discharged to the atmosphere and no
air discharge permit is expected to be required. These details would be confirmed during the
RD phase.
As other impacted areas of the aquifer would be allowed to naturally attenuate, all of the
requirements/activities incorporated into Alternative RAA2 (i.e.. sampling of wells in the Shad
Bend community, institutional controls, the abandonment of the inactive public supply wells,
and preparation of Five-Year Review reports) would also be implemented as part of Alternative
RAA3 with the exception of running a fate and transport model. The estimated time frame to
achieve the performance standards for this alternative is 8 years.
Capital Costs: $ 441,000
Present Worth Operating & Maintenance Costs: $ 763,000
Total Present Worth Costs: $1,204,000
Time to Design: 10 months
Construction Time: 8 months
Duration to Achieve Clean-up: 8 years
8.1.4 ALTERNATIVE RAA4: Air Sparging with Soil Vapor Extraction. Sample Private
Wells in Shad Bend Community. Monitoring. Institutional Controls. Abandonment
of Inactive Supply Wells. & Removal of Aboveqround Storage Tanks in AOC #5
This alternative involves the installation/operation of an air sparging/soil vapor extraction
system in the same two areas identified in Alternative RAA3. Air sparging technology injects
air into the saturated zone through air sparging point wells in order to transfer the volatile
organic compounds from the liquid phase to the gaseous phase. The vapors are then
removed by the pull of a vacuum created in the vadose zone soils through the soil vapor
extraction points. Due to the low levels of emissions expected, the vapors would be
discharged to the atmosphere and no air discharge permit is expected to be required. These
details would be confirmed during the RD phase. The estimated time frame to achieve the
performance standards for this alternative is 8 years.
As other impacted areas of the aquifer would be allowed to naturally attenuate, all of the
requirements/activities incorporated into Alternative RAA2 (i.e.. sampling of wells in the Shad
Bend community, institutional controls, the abandonment of the inactive public supply wells,
and preparation of Five-Year Review reports) would also be implemented as part of Alternative
RAA4 with the exception of running a fate and transport model. The estimated time frame to
achieve the performance standards for this alternative is 8 years.
Capital Costs: $ 419,000
Present Worth Operating & Maintenance Costs: $ 584,000
Total Present Worth Costs: $1,003,000
Time to Design: 10 months
Construction Time: 8 month
Duration to Achieve Clean-up: 8 years
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Flanders Filters Site
Record of Decision
September 1998
-57-
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 8.0 describes the remedial alternatives set forth in the March 1998 FS document.
This section summarizes the detailed evaluation of the four remediation alternatives in
accordance with the nine (9) criteria specified in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), 40 CFR Section 300.430(e)(9)(iii). This evaluation, in
accordance with the nine criteria, is summarized in Table 15.
9.1 THRESHOLD CRITERIA
In order for an alternative to be eligible for selection, it must be protective of both human
health and the environment and comply with ARARs. However, the requirement to comply
with ARARs can be waived in accordance to 40 CFR Section 300.430(0(1 )(ii)(C).
9.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the alternatives to determine whether they can adequately
protect human health and the environment from unacceptable risks posed by the
contamination at a Site. This assessment considers both the short-term and long-term time
frames.
As stated in Section 6.0, under both current and future conditions, the contaminants in
the soils at the Site do not pose an unacceptable risk to human health. Based on the findings
of the Ecological Risk Assessment, the Site has not caused any visible harm to the
environment. Use of the groundwater as a source of potable water under both current and
future resulted in unacceptable risks. The risks associated with these two scenarios (for
children) are 5.9 x 10"4 and 6.2 x 10"4, respectively. The Hazardous Quotients for these two
scenarios are 5.7 and 7.6, respectively. However, the Site is an active industrial facility and
since contaminated groundwater has not migrated beyond Site boundary's, except for the
groundwater discharging into surface water, the current risk does not apply. The Flanders
Filters facility and all residents but one in the Shad Bend community received their potable
water from the City of Washington. Therefore, the remedial decision is based on protecting
groundwater for current and future use.
Alternatives RAA1 and RAA2 rely on natural attenuation processes exclusively.
Alternatives RAA3 and RAA4 utilize established groundwater remediation technologies,
groundwater extraction and air sparging/soil vapor extraction, respectively, to augment the
passive natural attenuation process.
The extent of the groundwater impact is believed to have been reached at the Site. The
plume has migrated to the edge of Mitchell Branch, which is acting as a discharge boundary or
hydraulic divide to the groundwater flowing from the Site to the east. Therefore, the
groundwater plume will not migrate beyond Mitchell Branch. When comparing the estimated
time frames to achieve performance standards (cleanup goals), all four alternatives, are
expected to provide long-term protection for human health and the environment. To insure
that each alternative is protective, each alternative includes a monitoring program.
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Flanders Filters Site
Record of Decision
September 1998
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Under Alternatives RAA1, RAA2, and to some degree Alternatives RAA3 and RAA4,
contaminant levels are anticipated to decrease as a result of natural attenuation. Alternatives
RAA3 and RAA4 may be considered more protective of the environment by removing
contaminants from the soil/groundwater, thereby reducing the potential for migration of
contaminants to groundwater and eventually to Mitchell Branch. However, because of Site
conditions and technology limitations, Alternatives RAA3 and RAA4 are only projected to
remediate the Site in a slightly shorter time frame than either Alternative RAA1 or Alternative
RAA2. Therefore, Alternatives RAA3 and RAA4 do not provide significant additional protection
to human health and the environment than Alternative RAA1 or Alternative RAA2.
Alternatives RAA2, RMS, and RAA4 include deed restriction and recordation. These
institutional controls are designed to restrict the aquifer to non-potable use and record areas of
the aquifer above groundwater standards until such time as groundwater standards are
achieved. These three alternatives also include abandonment of the inactive public supply
wells which will keep additional contamination from migrating into the lower aquifer.
9.1.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
This criterion assesses the alternatives to determine whether they attain ARARs under
federal and state environmental laws, or provide justification for waiving an ARAR. No waiver
for an ARAR is currently anticipated. Site specific ARARs are identified in Table 11.
MCLs and State groundwater quality standards are ARARs for Site groundwater. It is
anticipated that all of the alternatives will obtain performance standards for groundwater and
surface water at the point of compliance specified in Tables 12 and 13, respectively. All four
RAAs are expected to comply with State and Federal chemical-, location-, and action-specific
ARARs that were established for this Site.
9.2 PRIMARY BALANCING CRITERIA
These criteria are used to evaluate the overall effectiveness of a particular remedial
alternative.
9.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE
This criterion assesses the long-term effectiveness and permanence an alternative will
afford as well as the degree of certainty to which the alternative will prove successful.
All of the alternatives are designed to accomplish long-term effectiveness and
permanence and rely, to some degree on natural attenuation. Alternatives RAA2, RAA3, and
RAA4 include monitoring as part of natural attenuation. Alternatives RAA3 and RAA4
augment natural attenuation with active cleanup systems at the two areas with the highest
VOC concentrations in the groundwater. Each alternative includes a ground water and surface
water testing program to gather data on the effectiveness and permanence of the remedy.
The estimated time frame to meet the performance standards with Alternatives RAA1 and
-------
-59-
Flanders F
Record of Decision
September 1998
TABLE 1 5 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
EVALUATION
CRITERIA
REMEDIAL ACTION ALTERNATIVES
RAA1: No ACTION
RAA2. MONITORED NATURAL
ATTENUATION
RAA3: Limited Groundwater
Extraction
RAA4:AlR SPARGING WITH SOIL VAPOR
EXTRACTION
ovs wit PwreetMNen
HUMAN HEALTH
ENVIRONMENT
Natural attenuation is
expected to continue to
reduce COC levels, VOC
monitoring of groundwater
and surface water to
ensure protection of
human health
Natural attenuation is
expected to continue to
reduce COC levels, VOC
monitoring of surface
water to ensure protection
of the environment
Natural attenuation is
expected to continue to
reduce COC levels, and
reduce exposure; periodic
monitoring of groundwater
and surface water to ensure
protection of human health;
deed restriction and
recordation to limit land use to
industrial with no aquifer use
Natural attenuation is
expected to continue to
reduce COC levels and
reduce impacts to ecological
receptors; periodic
monitoring of surface water to
ensure protection of the
environment
Is protective of human
health by reducing levels of
COCs in groundwater;
groundwater monitoring to
ensure protection of human
health
Is protective of the
environment by containing
plume and reducing levels
of COCs in groundwater;
surface water monitoring to
ensure protection; VOCs
emitted to atmosphere
Is protective of human health by reducing
levels of COCs in groundwater;
groundwater monitoring to ensure
protection of human hearth
Is protective of the environment by
reducing levels of COCs in groundwater;
surface water monitoring to ensure
protection; VOCs emitted to atmosphere
cow»t.iANee WITH AWJCA«^ OR RKUVAW AW> AwopRunReouiRSWiNn
CHEMICAL-
SPECIFIC ARARs
ACTION-SPECIFIC
ARARS
.OCATION-
SPECIFIC ARARs
ARARs are expected to be
met over time, monitoring
of VOCs to ensure
compliance with ARARs
N/A
N/A
ARARs are expected to be
met based on natural
attenuation, monitoring of
attenuation indicator
parameters and VOCs to
ensure compliance with
ARARs
Can be designed to meet
these ARARs
Can be designed to meet
these ARARs
The use of pump and treat
in the areas of greatest
groundwater impact and
natural attenuation in other
areas of the Site will meet
ARARs
Can be designed to meet
these ARARs
Can be designed to meet
these ARARs
The use of air sparging/SVE in the areas
of greatest groundwater impact and
natural attenuation in other areas will
meet the ARARs
Can be designed to meet these ARARs
Can be designed to meet these ARARs
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-60-
Flanders Filters Site
Record of Decision
September 1998
TABLE 15 DE
EVALUATION
CRITERIA
TAILED ANALYSIS OF REMEDIAL ALTERNATIVES
REMEDIAL ACTION ALTERNATIVES
RAA1: No ACTION
RAA2: MONITORED NATURAL
ATTENUATION
RAA3: Limited Groundwater
Extraction
RAA4: AIR SPARGING WITH SOIL VAPOR
EXTRACTION
LOHa-Tei^eFFecttvi^iis^AWPc^M^eMCg
ADEQUACY AND
RELIABILITY OF
CONTROLS
NEED FOR FIVE-
YEAR REVIEW
High; groundwater and
surface water will be
monitored in accordance
to an approved work plan
for monitoring activities in
preparation of the Five
Year Review Report
Would be required to
ensure adequate
protection of human health
and the environment
High; groundwater and
surface water will be
monitored in accordance to
an approved work plan, deed
recordation and restrictions
will document plume and
prevent aquifer use
Would be required to ensure
adequate protection of human
health and the environment
until remediation goals are
achieved
High; groundwater and
surface water will be
monitored in accordance to
an approved work plan,
deed recordation and
restrictions will document
plume and prevent aquifer
use
Only needed until
remediation goals are
achieved
High; groundwater and surface water will
be monitored in accordance to an
approved work plan, deed recordation and
restrictions will document plume and
prevent aquifer use
Only needed until remediation goals are
achieved
REDWTWNcffToxKrrv.MoBaj^
TREATMENT
TECHNOLOGY/
PROCESS USED
AMOUNT OF
CONTAMINANTS
TREATED OR
DESTROYED
Natural attenuation by
physical, chemical, and/or
biological processes
COCs removed from
aquifer by natural
attenuation processes
Natural attenuation by
physical, chemical, and/or
biological processes
COCs removed from aquifer
by natural attenuation
processes
Active groundwater
extraction, treatment, and
discharge via NPDES
permit for areas of greatest
impact, natural attenuation
for remainder of shallow
aquifer
Contaminants removed
from aquifer, treated by air
stripping tower; residual
and fringe areas to be
degraded in-situ by natural
attenuation
Active AS/AVE for extraction of VOCs and
discharge to atmosphere in areas of
greatest impact, natural attenuation for
remainder of shallow aquifer
Contaminants transferred to atmosphere
through AS/SVE process or degraded in-
situ by natural attenuation
-------
FH JR
-61-
Flanders FiltSBeite
Record of Decision
September 1998
TABLE 1 5 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
EVALUATION
CRITERIA
TREATMENT
RESIDUALS
REDUCTION OF
Toxicrnr,
MOBILITY. OR
VOLUME
REMEDIAL ACTION ALTERNATIVES
RAA1: No ACTION
None
Parameters of concern will
decline over time via
natural attenuation
SHORT.TJRM EwscTtv£we*&
COMMUNITY
PROTECTION
WORKER
PROTECTION
IMPACT TO
ENVIRONMENT
TIME FRAME FOR
COMPLETION
No increase in exposures
by this alternative
Potential risk to monitoring
personnel, reduced by
proper health and safety
procedures
No additional impacts
expected by
implementation
Estimated to be 9 years
RAA2: MONITORED NATURAL
ATTENUATION
None
Parameters of concern will
decline over time via natural
attenuation
No increase in exposures by
this alternative
Potential risk to monitoring
personnel, reduced by proper
health and safety procedures
No additional impacts
expected by implementation
Estimated to be 9 years
RAA3: Limited Groundwater
Extraction
Some water treatment
sludge generated by air
stripping, VOCs
discharged to atmosphere,
no residuals from naturally
attenuated areas
Mobility of COCs in most
contaminated areas is
reduced more than other
methods, all parameters
will decline over time
RAA4: AIR SPARGING WITH SOIL VAPOR
EXTRACTION
VOCs discharged to the atmosphere, no
residuals from naturally attenuated areas
Removal of VOCs from most
contaminated zones relatively quickly,
parameters in other areas attenuate over
time
-
Potential increase in
exposure during
construction and operation
Risks to workers will be
increased by invasive
nature of system and the
construction and operation
of groundwater treatment
system
No additional impacts
expected by
implementation
Estimated to be 8 years
Potential increase in exposure during
construction and operation
Risks to workers will be increased by
invasive nature of system and the
construction and operation of the
groundwater treatment system
No additional impacts expected by
implementation
Estimated to be 8 years
-------
-62-
Flanders Filters Site
Record of Decision
September 1998
TABLE 1 5 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
EVALUATION
CRITERIA
REMEDIAL ACTION ALTERNATIVES
RAA1: No ACTION
RAA2: MONITORED NATURAL
ATTENUATION
i«»^tt£»»tA0
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Flanders Filters Site
Record of Decision
September 1998
-63-
RAA2 is nine years. For Alternatives RAA3 and RAA4, the expected time frame is eight years.
Five-year CERCLA mandated reviews will be required for all of the alternatives.
9.2.2 REDUCTION OF TOXICITY. MOBILITY. OR VOLUME
This criterion assesses the degree to which the alternative employs recycling or
treatment to reduce the Toxicity, Mobility or Volume of the contaminants present at the Site.
Alternatives RAA3 and RAA4 actively reduce the toxicity, mass, and volume of
contaminants in the groundwater and satisfy the statutory preference for treatment. However,
natural attenuation processes will also reduce the toxicity, mobility, or volume of the plume
through natural processes. In addition, no treatment residuals are generated by Alternatives
RAA1 and RAA2, as there could be with Alternatives RAA3 and RAA4.
9.2.3 SHORT-TERM EFFECTIVENESS
This criterion assesses the short-term impact of an alternative to human health and the
environment. The impact during the actual implementation of the remedial action is usually
centered under this criterion.
Alternatives RAA1 and RAA2 pose fewer short-term risks to Site workers and the
community than either Alternative RAA3 or RAA4. Alternatives RAA3 and RAA4 may create
more short-term risk due to the invasive nature of the system installation. Alternatives RAA3
and RAA4 also pose risks to receptors due to the long-term operation and maintenance of the
active remediation systems.
9.2.4 IMPLEMENTABILITY
This criterion assesses the ease or difficulty of implementing the alternative in terms of
technical and administrative feasibility and the availability of services and materials.
Alternative RAA1 requires no implementation. Alternative RAA2 will be easy to
implement as minimal construction is required. Both Alternatives RAA3 and RAA4 are
projected to require approximately 12 months to design and construct, and approximately 8
years of operation. Alternative RAA3 will require the acquisition of a NPDES permit. The
design of the treatment system for Alternative RAA3 cannot be completed until the discharge
requirements of the NPDES permit are established. The design for Alternative RR4 cannot be
completed until after a pilot study is performed. The pilot study is necessary to determine the
radius of influence around each air sparging and vapor extraction well. This typically occurs
during the RD.
9.2.5 COST
This criterion assesses the cost of an alternative in terms of total present worth cost
(PW). Calculation of the total PW is described in Section 8.1. The total present worth costs
for the alternatives are presented below:
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Flanders Filters Site
Record of Decision
September 1998
-64-
Alternative RAA1 - No Action: $ 264,000
Alternative RAA2 - Monitored Natural Attenuation, Sample Private Wells in Shad Bend
Community, Institutional Controls, Abandonment of
Inactive Public Supply Wells, & Removal of Aboveground
Storage Tanks in AOC #5: $ 386,000
Alternative RAA3 - Limited Groundwater Extraction with Discharge to Mitchell
Creek via a NPDES Permit, Sample Private Wells in
Shad Bend Community, Monitoring, Abandonment of
Inactive Public Supply Wells, & Removal of Aboveground
Storage Tanks in AOC #5: $1,204,000
Alternative RAA4 - Air Sparging with Soil Vapor Extraction, Sample Private
Wells in Shad Bend Community, Monitoring, &
Abandonment of Inactive Public Supply Wells, &
Removal of Aboveground Storage Tanks in AOC #5: $1,003,000
9.3 MODIFYING CRITERIA
State and community acceptance are modifying criteria that shall be considered in
selecting the remedial action.
9.3.1 STATE OF NORTH CAROLINA ACCEPTANCE
The State of North Carolina has reviewed and provided EPA with comments on the
reports and data from the Rl and the FS. NCDENR has also reviewed the Proposed Plan and
EPA's preferred alternative as well as this ROD and conditionally concurs with the selected
remedy as described in Section 10. The State's correspondence providing conditional
concurrence, along with the specific conditions, and the Agency's response to the stipulated
conditions can be found in Appendix A.
9.3.2 COMMUNITY ACCEPTANCE
The Proposed Plan Fact Sheet was distributed to interested residents, to local
newspapers and radio and TV stations, and to local, State, and Federal officials on June 19,
1998. The Proposed Plan public meeting was held in the evening of June 23,1998. The
public comment period on the Proposed Plan began June 23, 1998 and dosed on July 23,
1998.
The only written comments received during the public comment period were from
Duncklee & Dunham, P.C., Flanders Filters, Inc.'s contractor. The questions asked during the
June 23, 1998 public meeting and the Agency's response to the written comments are
summarized in the Responsiveness Summary, Appendix C. No input was received from the
community at large, therefore it is not feasible to assess the community's acceptance of the
proposed remedy.
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Flanders Filters Site
Record of Decision
September 1998
-65-
10.0 DESCRIPTION OF THE SELECTED REMEDY
Alternative RAA2 is the selected remedial alternative for the Flanders Filters site with
Alternative RAA4 as the contingent remedial alternative. In the event data collected from the
Site cannot substantiate the occurrence of natural attenuation, the contingency remedy will be
immediately implemented. This decision will be made within three years after the issuance of
this Record of Decision.
10.1 PERFORMANCE STANDARDS TO BE ATTAINED
Table 11 lists the action-specific, chemical-specific, and location-specific Site specific
ARARs. Tables 12 and 13 list the performance standards for the groundwater and surface
water, respectively. The select remedial alternative or the contingent remedial alternative will
achieve all ARARs.
Table 12 provides the remediation goals to be achieved in the groundwater at the Site.
This table also highlights the range and frequency of detection for the contaminants of concern
detected at the Site. This table also lists the risk level associated with each remediation goal.
These risks were calculated in the Baseline Risk Assessment.
10.2 DESCRIPTION OF SELECTED REMEDIAL ACTION
The remedial alternative selected for the Flanders Filters site is RAA2 - Monitored
Natural Attenuation, Sampling of Private Wells in the Shad Bend Community, Institutional
Controls, Abandonment of Inactive Public Supply Wells, & Removal of Aboveground Storage
Tanks in AOC #5. Alternative RAA2 satisfies the statutory requirement of Section 121 (b) of
CERCLA, 42 USC Section 9621 (b), which provides that the selected alternative be protective
of human health and the environment, comply with ARARs, be cost effective, and utilize
permanent solutions and treatments to the maximum extent practicable. A description of the
selected remedial alternative can be found in Section 8.1.2. A list of all activities incorporated
into the Flanders Filters' remedial action is specified below.
The selection of natural attenuation as the remedy for this Site is based on the following
facts:
1. As stated in Section 9.1.1, based on available information, it is believed that the extent
of the groundwater impact has been reached. The plume has migrated to the edge of
Mitchell Branch, which is acting as a discharge boundary or hydraulic divide to the
groundwater flowing from the Site to the east. Therefore, the groundwater plume will
not migrate beyond Mitchell Branch.
2. The data in Table 7 clearly show that the levels of contaminants in the groundwater
have dropped significantly since 1988.
3. Based on the Bioscreen9 model, using a first order of decay, it was estimated to take
approximately 9 years for the levels of organic contaminants in the groundwater to
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Flanders Filters Site
Record of Decision
September 1998
-66-
decline to their clean-up levels. The time frame for the active remediation alternatives
(i.e., pump and treat and air sparging/soil vapor extraction) was 8 years.
Groundwater and surface water quality will be monitored on a semi-annual basis.
Initially, all samples collected will be analyzed for VOCs, SVOCs, and inorganics.
Groundwater samples will be collected from on-site monitoring wells, off-site monitoring wells,
and off-site private wells. As the data base increases, the frequency the samples are collected
and the comprehensiveness of the chemical analyses conducted on each sample may be
modified with the Agency's concurrence. In addition to analyzing the groundwater for VOCs,
SVOCs, and inorganics, selected groundwater samples will also be monitored on a periodic
basis for natural attenuation parameters. For guidance, the requirements set forth in the Draft
EPA Region 4 Suggested Practices for Evaluation of a Site For Natural Attenuation (Biological
Degradation) of Chlorinated Solvents, November, 1997, Version 3.0, as amended, shall be
followed.
To confirm the estimated time frame as to when the performance standards will be
achieved across the entire Site, developed in the FS, a fate and transport model using
Bioplume II, RT3D, or equivalent will be completed with two years of the issuance of this ROD.
To assist with the modeling, an additional groundwater monitoring well will be installed
downgradient of MW-14, approximately 400 feet to the southeast.
Water levels will be measured in all monitoring wells on a quarterly basis until any
seasonal perturbations in the groundwater flow direction have been established.
The following institutional controls will be implemented: "land use restrictions" and "deed
recordation". The land use restriction will contain language to accomplish the following three
objectives:
1) restrict future land use which would decrease the likelihood of human exposure to
contaminated soils;
2) prevent the installation of a potable well at the Site until the levels of contamination in the
groundwater under the Site are deemed safe; and
3) prevent excavation in contaminated soils without sufficient personal protection for the
workers.
The deed recordation will contain language that will inform any potential buyer of the
property of the contamination present. The suitable land use restrictions and deed recordation
shall be recorded in the appropriate state, county, and/or local office(s).
In an effort to prevent any migration of contaminants into the lower aquifer, the four
inactive supply wells will be abandoned in accordance to North Carolina regulation NCAC, Title
15A, Subchapter 2C, Section .0100, Subsection .0113-Abandonment of Wells.
To reduce future liability, all of the aboveground storage tanks in area AOC#5 will be
removed. After their removal, the surrounding and underlying soils will be visually inspected
and sampled.
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Flanders Filters Site
Record of Decision
September 1998
•67-
Because this alternative leaves hazardous materials on Site, a review of the Site's
remedy every five years is required. This review process will continue every five years until the
performance standard (cleanup goal) for the identified contaminants (Table 12) in the
groundwater are achieved.
10.3 DESCRIPTION OF CONTINGENT REMEDIAL ACTION
Section 10.0 specifies under what condition the contingent remedial action will be
implemented. Section 8.1.4 describes the components of the contingent remedial action.
10.4 COST
The total present worth costs for the selected alternative is
Capital Costs: $ 88,000
Present Worth Operating & Maintenance Costs: $298,000
TOTAL PRESENT WORTH COST: $386,000
The total present worth costs for the contingent alternative is
Capital Costs: $419,000
Present Worth Operating & Maintenance Costs: $584,000
TOTAL PRESENT WORTH COST: $1,003,000
11.0 STATUTORY DETERMINATION
Based on available information, the selected remedy satisfies the requirements of
Section 121 of CERCLA, as amended by SARA, and the NCR. The remedy provides
protection of human health and the environment, is cost-effective, utilizes permanent solutions
to the maximum extent practicable, and satisfies the statutory preference for remedies
involving treatment technologies.
11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Through natural attenuation processes, the selected remedy will remediate the
groundwater. Institutional controls will be implemented to protect against the use of
contaminated groundwater as potable water until the adversely impacted groundwater is
deemed safe.
11.2 COMPLIANCE WITH ARARS
The selected remedy will be designed to meet all Federal or more stringent State
environmental laws. A complete list of the ARARs which are to be attained is included in
Table 11. No waivers of Federal or State requirements are anticipated.
-------
Flanders Filters Site
Record of Decision
September 1998
-68-
11.3 COST-EFFECTIVENESS
The selected remedial action is more cost-effective than the other acceptable
alternatives considered. The selected remedy will provide greater benefit for the cost.
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE
The selected remedy represents the maximum extent to which permanent solutions and
treatment can be practicably utilized for this action. Of the alternatives that are protective of
human health and the environment and comply with ARARs, EPA and the State have
determined that the selected remedy provides the best balance of trade-offs in terms of:
long-term effectiveness and permanence; reduction in mobility, toxicity, or volume achieved
through treatment; short-term effectiveness, implementability, and cost; State and community
acceptance; and the statutory preference for treatment as a principal element.
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The selected remedial alternative does not require the implementation of an active
remediation system to treat the contaminants at the Site. However, based on Site specific
data, it has been documented that the processes which comprise natural attenuation will result
in treatment of the contaminants present at the Site leading to a reduction in their toxicity,
mobility, or volume.
11.6 FIVE-YEAR REVIEW REQUIREMENTS
Because this remedy will result in hazardous substances remaining on-site above levels
that allow for unlimited use and unrestricted exposure, a review will be conducted within five
years after initiation of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
12.0 SIGNIFICANT CHANGES
CERCLA Section 117(b) requires an explanation of any significant changes from the
preferred alternative originally presented in the Proposed Plan (Appendix C). Below are the
specific changes made in the ROD as well as the supporting rationale for making those
changes. The Proposed Plan was disseminated to the public on June 19, 1998.
Two changes were made between the Proposed Plan and the ROD. The first change
involves correcting the number of inactive supply wells that need to be abandoned. The
Proposed Plan specified three (3), however, there are four (4) inactive supply wells that need
to be abandoned.
-------
Flanders Filters Site
Record of Decision
September 1998
-69-
The second change involves incorporating private wells located in the Shad Bend
community in the long-term groundwater monitoring scheme to be implemented at the Site.
Therefore, the long-term monitoring plan will include on-site monitoring wells, off-site
monitoring wells, and off-site private wells.
-------
APPENDIX A
CONCURRENCE LETTER FROM THE STATE OF NORTH CAROLINA
AND RESPONSE FROM THE AGENCY
-------
. -i / ?»iinuj 1
"*? VT'' ''VTv • •'•"i.'.' ''•'• • i!
•L..M* ;•;•; -v ••<.: v--.
IMWUMI
Ttl/yi9 733 4811
P. 001
'.' JAMM •. HUNTJitf-''--^
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION or WABTE MAKAGBMENT
September 17.1998
Mr. Jon Bornholm
Remedial Project Manager
North Superfund Remedial Branch
100 Alabama Street, SW
Atlanta, Georgia 30303-3104
PotHt* Fax Note
7671
Co/Diet
PQ**
733
fwr
RE: State Concurrence with the Recoro 01 uecisioo
for the Flanders Filters, Inc. Site
NCD 045 922 986
Washington, Beaufort County, NC
Dear Mr. Bomholm:
The State of North Carolina has reviewed the attached Record of Decision
for the Flanders Filters, Inc. Site received by mail from you on September) 5,
1998. The State of North Carolina concurs with the selected remedy and the
Record of Decision, subject to the following conditions.
1. State concurrence on this Record of Decision (ROD) and the
selected remedy for this site is based solely on the information
contained in the attached ROD. 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 commit* the State to participate, financially
or otherwise, in the clean up of the site. The State reserves the
right 0 review, overview, Comment, and make independent
assessment of all future work related to this site.
3. If, after remediation is complete, the total recjdual riek level
exceeds 10*, the State may require deed recordation/restriciion to
document the presence of residual contamination and possibly limit
future use of the property as specified in NCOS 130A-310.8.
401 DBCKUIN MOAO. SUIT* f BO, fULtmx, NC *7«Q6
»UOMF>|».7»-«BM BAJC»1»-71C »*0«
AN EQUAL OVPOMTUNtrv / AFFIMM4TIVC ACTION EMPLOYER • OO% RCCYcktP't OK rotT-CONtUUKR PA»tK
-------
4H11 P. 002
? ° "m aPPreciatcs ^e opportunity to comment on the
fCt SUC> 3nd ^ 10°k fonvard to workine wi* EPA on the final
. It you have any questions, please contact me at (919) 733-2801 ext 353
Sincerely,
Bruce Nicholson
Special Remediation Branch Head
NC Superfund Section
cc: Phil Vorsatz, EPA Region IV
Jack Butler, DWM
I/Harry Zinn,DWM
-------
APPENDIX B
Flanders Filters March 1998 Letter
-------
FLANDERS FILTERS, INC. TEL: 919-9464081
531 Flanders Filters Road FAX: 919-946-3425
Washington, North Carolina (USA) 27889
Duncklee318.doc
18 March 1998
Duncklee & Dunham, P.C.
PO Box 33366
Raleigh, NC 27636
attn: Dave Duncklee
Dear Dave:
This letter is provided to assure you and the regulatory agencies that Flanders filters
Incorporated intends to use the site at 531 Flanders Filters Road, Washington NC as an
industrial manufacturing site for the long term foreseeable future. This site is a key site for the
corporation and includes centralized corporate functions and approximately 300 employees.
Flanders has just completed phase one of a 50,000 square foot warehouse addition to the
main plant building so that we may build more product to inventory and level our work load. The
second phase is underway now. Roof renovations on the main plant were completed last year
and over $1,000,000 has been invested in capital equipment and facilities over the past few
years. We will continue to invest in plant improvements throughout this year to obtain an
efficient manufacturing facility here.
Flanders corporation has made a public commitment to expand into new markets and products
and we are looking to build many of these products at the Washington site to maximize use of
the assets there.
Sincerely,
Stephen D. Klocke
Vice President Engineered Products
cc: Robert Amerson
The Foremost Designer* ind Manufacturers of High Efficiency Air Filtration Systems For Science and Industry
-------
APPENDIX C
PROPOSED PLAN FACT SHEET
-------
SUPERFUND PROPOSED PLAN FACT SHEET
SITE REMEDIATION
FLANDERS FILTERS, INC. SITE
JUNE 1998 Washington, Beaufort County, North Carolina
Terms in bold face print are defined in a glossary located at the end of this publication. This fact sheet is not to be considered
a technical document but has been prepared to provide a better understanding to the public.
INTRODUCTION
The goals of this Proposed Plan are 1) to summarize the
Remedial Investigation Report and Feasibility Study
document, 2) to inform the public that the Agency is
proposing to issue a Record of Decision (ROD) for this
Site which includes a contingent alternative, 3) to
highlight the Agency's preferred remedial alternative for
the Flanders Filters Site, and 4) to identify the contingent
remedial alternative. The Agency's preferred remedial
alternative and the contingency remedial alternative are
presented in the section entitled "EPA's PREFERRED
ALTERNATIVE", on page 13.
The Environmental Protection Agency (EPA), lead
Agency for Site activities, prepared this Proposed Plan
with the assistance of the North Carolina Department of
Environment and Natural Resources (NCDENR), the
support agency. The source of data and information
presented in this Proposed Plan Fact Sheet comes from
the Remedial Investigation Report, dated July 28,1997,
(which includes the December 15,1997 revised Baseline
Risk Assessment) and the revised Feasibility Study
document, dated March 25,1998. EPA, in consultation
with NCDENR, will select a remedy only after the public
comment period ends and all information submitted to
EPA during this time has been reviewed and considered.
EPA is issuing this Proposed Plan as part of its public
participation responsibilities in accordance with Section
117(a) of the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA), also known as Superfund. This Proposed
Plan Fact Sheet summarizes information presented in the
July 1997 Remedial Investigation Report, the March 1998
revised Feasibility Study document, and other pertinent
documents contained in the Information
Repository/Administrative Record for this Site. EPA
and the State encourages the public to review these
documents to better understand the Site and the
Superfund activities conducted. The Administrative
Record is available for public review locally at the
Brown Public Library, 122 Van* Norden Street,
Washington, North Carolina.
EPA, in consultation with NCDENR. may modify the
preferred alternative or select another response action
presented in this Plan and the Remedial Investigation
and the Feasibility Study Reports based on new
information and/or public comments. Therefore, the
public is encouraged to review and comment on all
alternatives discussed below. This Proposed Plan:
1. Includes a brief background of the Site and the
principal findings of the Remedial Investigation;
2. Presents the remedial (cleanup) alternatives
considered by EPA;
3. Outlines the evaluation criteria used to recommend
a remedial alternative;
4. Summarizes the analysis based on the evaluation
criteria;
5. Presents EPA's rationale for its recommended
remedial alternative; and
6. Explains the opportunities for the public to comment
on the remedial alternatives and become involved
in the process.
PROPOSED PLAN PUBLIC MEETING:
DATE: TUESDAY, June 23,1998
LOCATION: Washington City Council Chambers
Washington, North Carolina
TIME: 7:00 PM - 9:00 PM
PUBLIC COMMENT PERIOD: June 23,1998 - July 23,1998
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-2-
SITE BACKGROUND
The Flanders Filters facility occupies approximately 65
acres on Flanders Filters Road four miles northwest of
Washington, North Carolina (refer to Figure 1).
Presently, land use immediately adjacent to the Site is
a mixture of agricultural and residential. The Site is
bordered to the north, northwest, and west by
agricultural land and an abandoned railroad. A stream
called, Mitchell Branch, and a wetlands area are
adjacent to the east. Land to the south is occupied by
the Shad Bend subdivision.
Mitchell Branch empties into Tranters Creek, which in
turn empties into the Tar River near the upper extent of
the Pamlico River. Mitchell Branch and Tranters Creek
are bordered by extensive wetlands and reported to be
recreational fisheries. Tranters Creek meanders and
passes within about 2,000 feet of the Site to the west
and to the south. No active surface water intakes are
located within 15 miles downstream of the Site.
In 1969, Flanders Filters developed this property and
has since used this facility for the manufacturing of high-
efficiency, borosilicate glass micro-filters and air filter
framing systems. Currently, the facility includes the
main plant building, four warehouses, a metal shop, a
maintenance shop, a paint shop, a water treatment
plant, a chemical storage shelter, a nitrification field
(leach field) for the septic system, two former spray
fields, and other support structures (refer to Figure 2).
The property is partially fenced and has gates at the
three entrances to the plant.
In April 1969, North Carolina Division of Environmental
Management (NCDEM) issued to Flanders Filters a
permit (#1590) to construct and operate a facility to
handle 1,000 gallons of wastewater from the
manufacturing process per day. The wastewater facility
included two retention ponds which had a total storage
capacity of 330.000 gallons. From 1969 to 1978, an
estimated 500 to 700 gallons of untreated wastewater
were transported daily to the Old Beaufort County
landfill for disposal. No records or manifests were kept
of these shipments.
In April 1977, NCDEM issued Flanders Filters permit
#4276 fora 4,500 gallons per day wastewater treatment
system and the use of a 2.75-acre spray field (spray
field #1) for the discharge of the treated wastewater.
This spray field is now partially covered by the metal
shop. A clay-lined by-pass pond was part of this
treatment system. The use of this facility began in
February 1978. No records are available pertaining to
the estimated daily volume discharged to spray field #1.
Permit #4276 was renewed in March 1982. As a
condition of this renewal, Flanders Filters was required
to install three monitoring wells and monitor the
groundwater for aluminum and zinc.
In May 1984, Flanders Filters received authorization
(permit # 4276-R) to open a 4.08-acre spray field (spray
field #2) located southeast of the plant area. This permit
required that additional monitoring wells be installed.
The metal shop area was expanded in 1984 and spray
field #1 was closed. Also in May 1984, Flanders Filters
requested approval to use the existing wastewater
treatment system for the disposal of treated wastewater
from a newly installed metal cleaning system. This
system was used for removing mild surface
contaminants and weld oxidation from stainless steel and
aluminum filter frames.
During 1986 and 1987, Flanders Filters maintained their
permit and obtained approval to increase flow to spray
field #2 from 4,500 gallons per day to 10,000 gallons per
day. No records are available pertaining to the
estimated daily volume discharged to spray field #2
during this time. In April 1988, Flanders Filters
requested approval to increase the size of spray field #2.
In response, the State expressed concern about elevated
groundwater levels of nitrate, total dissolved solids,
phenol, and aluminum. Consequentially, the State
required the installation of three additional monitoring
wells. In August 1988, permission was granted to
expand the spray field to 8.24 acres with an increase in
flow to 20,000 gallons per day.
In February 1989, the State allowed an increase in flow
to 30,000 gallons per day (under permit # WQ0000628).
As before, no discharge records are available for this
time frame, but it has been reported that the estimated
daily volume of treated wastewater discharged to this
spray field was 2,000 gallons per hour for 8 hours per
day, five days per week. Spray field #2 was operated for
about 10 years and is no longer in operation.
During June and July 1993, EPA conducted an expanded
site inspection at the Flanders Filters site. This study
documented the presence of the following contaminants
at the Site: chromium, copper, nickel, zinc, bis (2-
ethylhexyl) phthalate, pyrene, and arsenic. No
contaminants of concern were identified in a sample
collected from a nearby private well. Bis (2-ethylhexyl)
phthalate and 1,1-dichloroethane were found above
detectable levels in one public supply well. Flanders
Filters, Inc. entered into an Administrative Order on
Consent with the Agency in February 1996 to conduct a
Remedial Investigation and Feasibility Study at the Site.
Since the Site is not as complex as other Sites, all work
was accomplished under one operable unit.
-------
-3-
RESULTS OF THE REMEDIAL INVESTIGATION
In developing the June 1996 Remedial
Investigation/Feasibility Study Work Plan, nine (9) areas
of concern (AOC) (i.e., potential sources of
contamination) were identified (refer to Figure 2). To
investigate these potential areas of contamination and
to determine the extent of any contamination at the Site,
seventy (70) environmental samples were collected as
part of the Remedial Investigation/ Feasibility Study
effort. These environmental samples were collected
from surface and subsurface soils, surface water and
sediment from Mitchell Branch, sediment from Tranters
Creek, and groundwater.
The Remedial Investigation identified the following
contaminants of concern across the Site:
1,1-dichIoroethane
1,1-dichloroethene
trichloroethene
vinyl chloride
antimony
1,1,1-trichloroethane
tetrachloroethene
chloroform
aluminum
chromium
Volatile organic compounds, semi-volatile organic
compounds, and metals were detected in the Acid
Vat/Hazardous Waste/Drum Storage Area (AOC #1).
The presence of volatile and semi-volatile organic
compounds in the surface and subsurface soils as well
as the underlying groundwater are consistent with spills
and leaks that have occurred in this area over the years.
The probable cause of the elevated metal levels in this
area was the accidental release of approximately 440
gallons of an acidic solution in 1992 from the acid
pickling operation.
Analytical data for samples collected from the Retention
Ponds (AOC #2) and (the Spray Field #1 /Metal Shop
area (AOC #3) indicate that neither of these areas are
sources of contamination. The source of the
contaminants being detected in the groundwater
downgradient of AOC #2 is AOC #1.
Numerous environmental samples were collected from
(Spray Field #2 (AOC #4). Only trace levels of volatile
and semi-volatile organic compounds were detected in
the soils in this area, therefore neither volatile nor semi-
volatile organic compounds are a concern in the soils in
this particular area. Several inorganics were detected at
concentrations twice their background level. Of these,
only zinc can be traced back to past Site operations. As
with the groundwater beneath AOC #2, based on
groundwater flow directions, it is surmised that the
volatile organic compounds being detected in the
groundwater beneath AOC #4 have migrated from AOC
#1.
Xylenes, numerous semi-volatile polycyclic aromatic
hydrocarbons, #2 fuel oil, varsol, antimony, arsenic,
copper, and zinc were detected in the soils associated
with the (Aboveground Storage Tanks and By-pass Pond
(AOC #5). Any adverse impact to the underlying
groundwater in this area has been minimized due to the
by-pass pond being clay-lined as clay impedes the
migration of most contaminants.
The abandoned railroad track (AOC #6) was not sampled
as no creosote related contaminants were detected in the
adjacent drainage ditch. The drainage ditches,
collectively, were designated as AOC #7. Volatile and
semi-volatile organic compounds as well as numerous
metals were detected in the drainage ditches. This
impact to surface water and sediment is the result of
surface water runoff from the plant and parking lot and
groundwater recharge to the these ditches.
Based on surface water and sediment samples collected
from Mitchell Branch (AOC #8). it has been documented
that Site related volatile organic compounds are being
released into this stream. These contaminants are
reaching Mitchell Branch either through the discharge of
groundwater into Mitchell Branch or from surface water
flowing through drainage ditches and discharging into
Mitchell Branch, or from a combination of the two. No
metals were detected from sediment samples collected
from Tranters Creek.
The groundwater underlying the Site and migrating
predominantly towards Mitchell Branch is defined as
AOC #9. Numerous contaminants have been detected
in the groundwater at the Site. The list presented at the
beginning of this section inventories the significant
contaminants detected in the groundwater. Figure 3
shows the extent of the migration of the contaminant 1,1-
dichloroethene at the Site. The curved line that mimics
the tree line in the southern portion of the Site that runs
from monitoring well #4 (MW-4) easterly to monitoring
well #10 (MW-10) identifies the extent of 1,1-
dichloroethene migration at the Site. Other Site related
contaminants in the groundwater either mimic this
depiction of migration or has not migrated as far as 1,1-
dichloroethene.
The highest levels of contaminants in the groundwateras
were found downgradient of the hazardous waste storage
area and the manufacturing area with trace levels
extending across portions of the Site. Trace levels of
volatile organic compounds and elevated levels of
metals have been documented in the former Shad Bend
supply wells. These wells were taken out of service in
1995.
-------
UNITED STATES
DEPARTMENT OF THE INTERIOR .
GEOLOGICAL SURVEY
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Figure 1 Site Location/Area Topography
-------
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AOC } : Ralanllon Ponoi
AOC 3 •. f(*a*r Spray Flalo4 II
AOC 4 : Former Spray Flak) It
AOC 6 : Abovaoround Sioraoa Tank Area
AOC a : Railroad Lin* end dinar Polannai OI'-SMa Sourc*
7 : On.SHa Orainao* Fealixet Io MHcnaii Branch
a ; uiicne> Brancn
AOC V : Sneltow Qround Walar Agullar (Enlt, $ll>. No 5 DOC 111C Shacwl
Figure 2 Areas of Concern
-------
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Figure 3 Extent of 1,1-DCE Migration in Groundwater
-------
-7-
Two shallow monitoring wells were installed on the other
side of Mitchell Branch as part of the Remedial
Investigation. The rationale for the installation of these
wells was 1) to determine if Mitchell Branch is a
hydrogeologic divide for groundwater and 2) to insure
residents with private potable wells on the other side of
Mitchell Branch (i.e., off-site) that the source of their
drinking water (i.e., the groundwater) has not been
adversely impacted by Site activities. These wells will
now act as sentinel wells and will be sampled periodically
to insure the public that their drinking water has not been
adversely impacted by Site activities. Neither well
contained volatile nor semi-volatile organic compounds
above trace levels. Concentrations of metals were also
below levels of concern. The only organic contaminant
detected in either off-site monitoring well was toluene and
it was detected at a trace level. This data along with
groundwater level measurements, verify that Mitchell
Branch is a hydrogeologic divide and that any
contaminants that do migrate off-site via groundwater will
discharge into Mitchell Branch and will not travel east of
Mitchell Branch via groundwater.
SUMMARY OF SITE RISKS
A goal of the Remedial Investigation/Feasibility Study
process is to analyze and estimate the human health and
environmental problems that could result at a Site if the
contamination is not cleaned up. This analysis is called
a Baseline Risk Assessment. In calculating risks to a
population if no remedial action is taken, EPA evaluates
reasonable maximum exposure levels undercurrent and
potential future exposure scenarios to Site contaminants.
In order to calculate a risk, an uninterrupted exposure
pathway must be present. An exposure pathway is the
route or mechanism by which a chemical agent travels
from a source to an individual or population. In order for
an exposure pathway to be considered complete, all of
the following factors must be present:
• A source of chemical and mechanism for its release
to the environment;
• A transport medium (e.g., soil, groundwater, air,
etc.);
• An exposure point (where a receptor will contact the
medium); and
• An exposure route Q.e., ingestion, inhalation, or
dermal contact).
The risk scenarios evaluated in the Flanders Filters'
Baseline Risk Assessment under current conditions
included ingestion, dermal contact, and inhalation of
contaminated groundwater; ingestion and dermal contact
to contaminated surface water and stream sediment; and
ingestion and dermal contact to contaminated surface
and subsurface soils. For groundwater, the risk
assessment considered only a residential scenario as
the Flanders Filters facility receives its potable water
from the City of Washington. For surface water,
sediment, and soil exposure scenarios, the risk
assessment evaluated risks for on-site workers and
trespassers. The future risk scenarios developed in the
Baseline Risk Assessment were for residential
conditions and the same environmental pathways were
examined as listed above.
The residential use of groundwater considered residents
using the contaminated groundwater as their source of
potable water (i.e., water used for drinking, cooking,
bathing, etc.). In conducting this assessment. EPA
focuses on the adverse human health effects that could
result from long-term daily, direct exposure as a result
of ingestion, inhalation, or dermal contact to
carcinogenic chemicals (cancer causing) as well as the
adverse health effects that could result from long-term
exposure to non-carcinogenic chemicals present at the
Site.
EPA's goal at Superfund sites is to 1) reduce the excess
lifetime cancer risk and 2) reduce the excess lifetime
non-carcinogenic health effects due to being exposed to
chemicals present at the Site. For carcinogens, the
Agency has established that the risk of developing
cancer due to this exposure of chemicals at the Site
should not exceed one in ten thousand. For
non-carcinogens, which is represented by the term,
Hazardous Quotient, the additional risk due to the Site
related chemicals should not exceed a value of one (1).
Typically, if either situation exists at a Site, the Agency
is encouraged to select a remedy other than *No
Action*.
Table 1 summarizes the accumulative effect of all
potential exposure pathways/risk scenarios identified at
the Flanders Filters. Undercurrent conditions, the only
unacceptable risk is associated with current residents.
However, this unacceptable risk is in conjunction with
using contaminated groundwater for potable purposes
and since no residents are using contaminated
groundwater as their potable water source, this concern
can be disregarded.
The Baseline Risk Assessment takes a very
conservative approach in calculating risk. Although the
carcinogenic risk for on-site workers is within the
acceptable risk range, it is the Agency's judgment that
an on-site worker would not be exposed to all the
potential exposure pathways while working at the
Flanders Filters facility, and therefore, the Site poses
even a smaller risk to on-site workers than calculated.
-------
-8-
Three future risk scenarios were identified which could
result in an unacceptable risk to people if these scenarios
became reality. These future risk scenarios entail
residents living in homes built on the Site. The first two
scenarios involve residential adults and residential
children using the contaminated groundwater beneath the
Site as their source for potable water. The third scenario
that could result in another unacceptable future risk
involves a child, living on-site, ingesting surface soils.
Currently, the potential for is exposure is non-existent for
either, as no adults or children live on the Site nor is this
a possibility in the future.
It is the Agency's position that due to the current situation
at the Flanders Filters facility that the future risk
scenarios evaluated in the Baseline Risk Assessment will
not come to fruition (i.e.. future on-site residents). This
position is based on a March 18,1998 correspondence
from Flanders Filters, Inc. stating that their plan is to
remain at this location and keep manufacturing filters at
this "site for the long term foreseeable future". This
statement is bolstered by the fact that Flanders Filters,
Inc. is currently investing over $1,000,000 in capital
improvements at the facility. However, if the use of this
property is changed prior to the performance standards
(clean-up goals) being achieved, the Agency will re-
evaluate this position.
The following factors were considered as part of this
Ecological Risk Assessment:
• assess the components of biological communities
on-site and in the vicinity, including vegetation,
mammals, birds, reptiles, amphibians, and the
aquatic biota;
• determine the location, extent, and characteristics of
ecological resources on-site and in the vicinity that
could serve as wildlife habitat or provide other
ecological functions; and
• identify overt effects of contamination on biological
communities.
Based on observations made during the ecological risk
assessment Site visit, no endangered or threatened
species were identified and no evidence of any visible
stress to habitat or animal life was observed.
The ecological assessment identified the following
contaminants as potential environmental stressors:
acetone benzene
bis (2-ethylhexyl) phthalate aluminum
arsenic chromium
copper _ iron
lead " zinc
These environmental stressors are present in on-site
surface and subsurface soils, groundwater, and surface
water and sediments; surface water and sediments
found in Mitchell Branch; and in the wetlands located
between the Site and Mitchell Branch. Of the
Constituents listed above, aluminum and zinc were
identified as potential metals that could bioaccumulate
in the aquatic ecosystem.
Due to the low levels of contaminants detected in the
environment, only small to slight potential exists that
these contaminants would cause an adverse affect to
the ecology. Therefore, because of the high ecological
value of the habitat around the Site, it is the Agency's
opinion that enacting a remediation in or around Mitchell
Branch would pose a greater risk to the health of this
habitat than the presence of the current levels and types
of contaminants.
TABLE 1 - SUMMARY OF HEALTH EFFECTS
CARCINOGENIC
RISK
NON-
CARCINOGENIC
RISK
ON-SITE
WORKER
Within
Acceptable
Risk Range
No
Unacceptable
Risk
SITE
TRESPASSER
No
Unacceptable
Risk
No
Unacceptable
Risk
CHILD
RESIDENT
(CURRENT)
Just Within
Acceptable
Risk Range
Unacceptable
Risk
ADULT
RESIDENT
(CURRENT)
Just Within
Acceptable
Risk Range
Unacceptable
Risk
CHILD
RESIDENT
(FUTURE)
Just Within
Acceptable
Risk Range
Unacceptable
Risk
ADULT
RESIDENT
(FUTURE)
Just Within
Acceptable
Risk Range
Unacceptable
Risk
-------
-9-
REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives are cleanup goals
established to protect human health and the
environment from each environmental media of concern
by preventing exposures to concentrations of
contaminants above risk-based human health or
environmental standards. Protecting human health may
be achieved by either reducing exposure or reducing
contaminant levels. Protection of the environment
includes protection of natural resources for future uses.
In identifying the Remedial Action Objectives, the
findings of the Baseline Risk Assessment were used as
well as an examination of all potential Federal and State
environmental Applicable or Relevant and
Appropriate Requirements (ARARs). ARARs can be
categorized as chemical-specific, location-specific, or
action-specific. Chemical-specific ARARs are
acceptable exposure levels to particular chemicals and
is the limit that must be met for that contaminant within
an environmental medium (i.e., water, soil, or air) at a
specific compliance point. Table 2 lists the chemical-
specific ARARs that pertain to this Site. Location-
specific ARARs address site-specific aspects such as a
critical habitat upon which endangered species or
threatened species depend, the presence of a wetland,
or a historically significant feature. Action-specific
requirements are controls or restrictions for particular
activities related to the implementation of the proposed
remedial alternative.
In summary, the Remedial Action Objectives for the
Flanders Filters site are:
#1: Remediate groundwaterto the specified remediation
levels and
#2: Limit the exposure of receptors to impacted
groundwater.
SUMMARY OF REMEDIAL ALTERNATIVES
The following section summarizes the cleanup
technologies and alternatives developed in the Flanders
Filters Feasibility Study document for addressing the
contamination at the Site. Descriptions of the clean-up
alternatives are summarized below.
The cost information below represents the estimated
total present worth of each alternative. Total present
worth was calculated by combining the capital cost plus
the present worth of the annual operating and
maintenance costs. Capital cost includes construction,
engineering and design, equipment, and site
development. Operating costs were calculated for
activities that continue after completion of construction,
such as routine operation and maintenance of treatment
equipment and monitoring. The present worth of an
alternative is the amount of capital required to be
deposited at the present time at a given interest rate
(7%) to yield the total amount necessary to pay for initial
construction costs and future expenditures, including
operation and maintenance and future replacement of
capital equipment.
For more information about the Remedial Action
Objectives and alternatives, please refer to the March
25, 1998 Feasibility Study document and other
documents available in the information repository in the
Brown Public Library.
REMEDIAL ALTERNATIVES
Four remedial alternatives were evaluated in detail in the
Feasibility Study for the Flanders Filters site. In addition
to the information presented in the Feasibility Study,
Flanders Filters also developed cost estimates for two
additional remediation technologies in a letter dated May
1,1998 which will be incorporated into this section. The
four primary remedial alternatives include:
Alternative RAA1: No Action
Alternative RAA2: Monitored Natural Attenuation,
Institutional Controls, Abandonment of Inactive
Public Supply Wells, & Removal of Aboveground
Storage Tanks in AOC #5
Alternative RAA3: Limited Groundwater Extraction
with Discharge to Mitchell Creek via a NPDES
Permit, Monitoring, Abandonment of Inactive
Public Supply Wells, & Removal of Aboveground
Storage Tanks in AOC #5
Alternative RAA4: Air Sparging with Soil Vapor
Extraction, Monitoring, & Abandonment of
Inactive Public Supply Wells, & Removal of
Aboveground Storage Tanks in AOC #5
ALTERNATIVE RAA1: NO ACTION
Capital Costs:
Present Worth Operating &
Maintenance Costs:
Total Present Worth Costs:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 8,000
$256.000
$264.000
None
None
9 years
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-10-
TABLE 2 - CHEMICAL-SPECIFIC ARARs
Chemical of Concern
Chloroform
(Trihalomethanes)
1,1-Dichloroethene
Tetrachloroethene
1,1,1-Trichloroethane
Trichloroethene
Vinyl Chloride
Aluminum
Antimony
Arsenic
Iron
Manganese
Highest Concentration
Detected On-site
0.2
73
5
600
14
5
12.100
21.1
6.5
9,840
207
#of
Detections
7/36
22/36
14/36
20/36
15/36
3/36
20/36
1/36 '
3/36 •
28/36
26/36
Federal
MCL
100
7
5
200
5
2
NS
6
50
Secondary
Federal MCL
50-200
300
50
North Carolina
Groundwater 2L Standards
0.19
7
0.7
200
2.8
0.015
NS
NS
50
300
50
All concentrations reported in micrograms/liter 0/g/l) or parts per billion (ppb)
CERCLA requires that the "No Action" alternative be
evaluated at every Superfund Site to establish a
baseline for comparison. No remediation activities
would occur at the Site under this alternative (i.e.. the
Site is left "as is"). Because this alternative neither
removes nor destroys the contamination (i.e.,
contamination is left on-site), a review of the remedy will
need to be conducted every five years (i.e., Five-Year
Review Report) in accordance with CERCLA Section
121(c). This review process will continue every five
years until the cleanup goals for the identified
contaminants are achieved across the entire Site.
If no action is taken migration of contaminants will
continue. This migration results from the natural
movement of precipitation (e.g.. rain and melted snow)
moving through the soils and carrying the contamination
downward as the precipitation recharges the aquifer.
Although Alternative RAA1 does not actively reduce or
eliminate Site contamination, it is anticipated that the
levels of contaminants will decrease over time due to
the process of natural attenuation. Natural attenuation
is defined in Alternative RAA2 description.
There is a minimal capital cost associated with
Alternative RAA1. The capital cost is for the
development of a work plan for preparing Five-Year
Review Reports and the monitoring activities necessary
for the preparation of these reports. Operating &
Maintenance Costs are associated with periodic
monitoring Of the Site in order to prepare the Five-Year
Review Reports. As part of the five year review.
groundwater and surface water samples will be collected
for chemical analyses on a semi-annual basis. Based on
some simple modeling, using a first order of decay, it has
been estimated that it will take approximately 9 years for
the levels of organic contaminants to drop to their clean-
up goals.
ALTERNATIVE RAA2: MONITORED NATURAL
ATTENUATION, INSTITUTIONAL CONTROLS, ABANDONMENT
OFPUBUCSUPPLYWELLS,&REMOVALOFABOVEGROUND
STORAGE TANKS INAOCXS .
Capital Costs:
Present Worth Operating &
Maintenance Costs:
Total Present Worth Costs:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 88,000
$298.000
$386,000
3 months
N/A
9 years
"Monitored natural attenuation" relies on natural
attenuation processes (within the context of a carefully
controlled and monitored site cleanup approach) to
achieve site-specific remedial objectives within a time
frame that is reasonable compared to that offered by
other more active methods. The "natural attenuation
processes" that are at work in a remediation approach
include a variety of physical, chemical, or biological
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-11-
processes that, under favorable conditions, act without
human intervention to reduce the mass, toxicity,
mobility, volume, or concentration of contaminants in
soil or groundwater. These in-situ processes include
biodegradation; dispersion; dilution; sorption;
volatilization; and chemical or biological stabilization,
transformation, or destruction of contaminants.
Groundwater and surface waterquality will be monitored
on a semiannual basis. In addition to analyzing the
groundwater for volatile, semi-volatile, and inorganic
contaminants (as needed), groundwater will also be
monitored on a periodic basis for natural attenuation
parameters. The data generated from these monitoring
efforts will be used to 1) insure that the contaminants are
not migrating further than predicted and 2) develop and
maintain a data base that confirms and verifies that
natural attenuation is occurring.
Institutional controls include "land use restrictions" and
"deed recordation" under North Carolina regulations.
The ability to implement these two institutional controls
is codified under 15A NCAC13C130A-310.3(0 and 15A
NCAC 13C 130A-310.8, respectively. The land use
restriction will contain language to accomplish the
following three objectives: 1) restrict future land use
which would decrease the likelihood of human exposure
to contaminated soils, 2) prevent the installation of a
potable well at the Site until the levels of contamination
in the groundwater under the Site are deemed safe, and
3) prevent excavation in contaminated soils without
sufficient personal protection for the workers. The deed
recordation will contain language that will inform any
potential buyer of the property of the contamination
present. The suitable land use restrictions and deed
recordation shall be recorded in the appropriate state
and/or county office.
In an effort to prevent any migration of contaminants
into the lower aquifer, Flanders Filters will abandon the
three inactive supply wells. These wells will be
abandoned in accordance to North Carolina regulation
NCAC, Title 15A, Department of Environment, Health &
Natural Resources, Division of Environmental
Management, Subchapter2C, Section .0100, Subsection
.0113 - Abandonment of Wells.
Although the contamination detected in AOC #5 does
not warrant cleanup under CERCLA, Flanders Filters, as
part of house keeping efforts, will remove the
aboveground storage tanks from this area. After their
removal, the surrounding and underlying soils will be
visually inspected and sampled.
^s with Alternative RAA1, Five-Year Review Reports
would be prepared until all performance standards are
Obtained across the entire Site.
ALTERNATIVE RAA3. LIMITED GROUNDWATER
EXTRACTION WITH DISCHARGE TO MITCHELL CREEK VIA AN
NPDES PERMIT, MONITORING, ABANDONMENT OF
INACTIVE PUBLIC SUPPLY WELLS, & REMOVAL OF
ABOVEGROUND STORAGE TANKS IN AOC MS
Capital Costs:
Present Worth Operating &
Maintenance Costs:
Total Present Worth Costs:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 441.000
$ 763.000
$1,204,000
10 months
8 months
8 years
This alternative employs extraction wells in two areas of
the Site to remove the contaminated groundwater from
the aquifer. It was estimated that two extraction wells
would be installed in the vicinity of AOC #1 and a row of
six extraction wells would be installed between the
Former Ponds 1 &2 and the leach field (refer to Figure 2).
Extracted groundwater would be piped to an on-site air
stripping unit and discharged to Mitchell Branch in
accordance with an National Pollutant Discharge
Elimination System (NPDES) permit. Additional
treatment of extracted groundwater, such as pH
adjustment and metals removal, may be necessary in
order to the achieve discharge limits established in the
NPDES permit. Due to the low levels of emissions
expected from the air stripping unit, the vapors would be
discharged to the atmosphere and no air discharge
permit is expected to be required. These details would
be confirmed during the Remedial Design phase.
As part of this alternative, Flanders Filters will be
required to enact the institutional controls, the
abandonment of the inactive public supply wells, and
prepare the Five-Year Review reports as discussed
under Alternative RAA2. The Feasibility Study estimated
that ft would take 8 years for this alternative to achieve
the performance standards.
ALTERNATIVE RAA4: AlR SPARGING WITH SOIL VAPOR
EXTRACTION, MONITORING, & ABANDONMENT OFINACTIVE
PUBLIC SUPPLY WELLS, & REMOVAL OF ABOVEGROUND
STORAGE TANKS IN AOC ns
Capital Costs:
Present Worth Operating &
Maintenance Costs:
Total Present Worth Costs:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 419,000
$ 584.000
$1,003,000
10 months
8 month
8 years
This alternative is a combination of natural attenuation
with an air sparging/soil vapor extraction system. The air
sparging/soil vapor extraction system would be installed
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in the same two areas identified in Alternative RAA3.
Air sparging technology injects air into the saturated
zone through air sparging point wells in order to transfer
the volatile organic compounds from the liquid phase the
gaseous phase. The vapors are then removed by the
pull of a vacuum created in the vadose zone soils
through the soil vapor extraction points. Due to the low
levels of emissions expected, the vapors would be
discharged to the atmosphere and no air discharge
permit is expected to be required. These details would
be confirmed during the Remedial Design phase.
As part of this alternative, Flanders Filters will be
required to enact the institutional controls, the
abandonment of the inactive public supply wells, and
prepare the Five-Year Review reports as discussed
under Alternative RAA2. The Feasibility Study
estimated that it would take 8 years for this alternative to
achieve the performance standards.
CRITERIA FOR EVALUATING REMEDIAL
ALTERNATIVES
The selection of the preferred alternative for the
Flanders Filters site, as described in this Proposed Plan,
is the result of a comprehensive screening and
evaluation process. The Feasibility Study identified and
analyzed appropriate alternatives for addressing the
contamination at the Site. The Feasibility Study and
other documents describe, in detail, the alternatives
considered, as well as the process and criteria EPA used
to narrow the list of the potential remedial alternatives to
address the contamination at the Site. As stated
previously, all of these documents are available for
public review in the Information Repository/
Administrative Record.
EPA always uses the following nine criteria to evaluate
alternatives identified in the Feasibility Study. The
remedial alternative selected for a Superfund site must
achieve the two threshold criteria as well as attain the
best balance among the five evaluation criteria. EPA's
Proposed Alternative may be altered or changed based
on the two modifying criteria. The nine criteria are as
follows:
THRESHOLD CRITERIA
1. Overall protection of human health and the
environment: The degree to which each
alternative eliminates, reduces, or controls
threats to public health and the environment
through treatment, engineering methods or
institutional controls.
2. Compliance With Applicable or Relevant and
Appropriate Requirements (ARARs): The
alternatives are evaluated for compliance with all
state and federal environmental and public health
laws and requirements that apply or are relevant
and appropriate to the site conditions.
EVALUATING CRITERIA
3- Cost: The benefits of implementing a particular
remedial alternative are weighed against the cost of
implementation. Costs include the capital (up-front)
cost of implementing an alternative over the long
term, and the net present worth of both capital and
operation and maintenance costs.
4. Implementability: EPA considers the technical
feasibility (e.g., how difficult the alternative is to
construct and operate) and administrative ease (e.g.,
the amount of coordination with .other government
agencies that is needed) of a remedy, including the
availability of necessary materials and services.
5. Short-term effectiveness: The length of time
needed to implement each alternative is considered,
and EPA assesses the risks that may be posed to
workers and nearby residents during construction and
implementation.
6. Long-term effectiveness: The alternatives are
evaluated based on their ability to maintain reliable
protection of public health and the environment over
time once the cleanup goals have been met.
7. Reduction of contaminant toxicitv. mobility, and
volume: EPA evaluates each alternative based on
how it reduces (1) the harmful nature of the
contaminants, (2) their ability to move through the
environment, and (3) the volume or amount of
contamination at the site.
MODIFYING CRITERIA
8. State acceptance: EPA requests state comments
on the Remedial Investigation and Feasibility Study
reports, as well as the Proposed Plan, and must take
Into consideration whether the state concurs with,
opposes, or has no comment on EPA's preferred
alternative.
9. Community acceptance: To ensure that the public
has an adequate opportunity to provide input, EPA
holds a public comment period and considers and
responds to all comments received from the
community prior to the final selection of a remedial
action.
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EVALUATION OF ALTERNATIVES
The following summary profiles the comparative
analysis of the four alternatives in terms of the nine
evaluation criteria:
Overall Protection; Alternatives RAA1 and RAA2 rely
on attenuation processes exclusively. Alternatives
RAA3 and RAA4 utilize established groundwater
remediation technologies, groundwater extraction and
air sparging/soil vapor extraction, respectively, to
augment the passive attenuation process.
The extent of the groundwater impact is believed to
have been reached at the Site. The plume has migrated
to the edge of Mitchell Branch, which is acting as a
discharge boundary or hydraulic divide to the
groundwater flowing from the Site to the east.
Therefore, the groundwater plume will not migrate
beyond Mitchell Branch. When comparing the
estimated time frames to achieve performance
standards (cleanup goals), all four alternatives, are
expected to provide long-term protection for human
health and the environment. To insure that each
alternative is protective, each alternative includes a
monitoring program.
Under Alternatives RAA1, RAA2, and to some degree
RAA3 contaminant levels are anticipated to decrease as
a result of natural attenuation. Alternatives RAA3 and
RAA4 may be considered more protective of the
environment by removing contaminants from the
soil/groundwater, thereby reducing the potential for
migration of contaminants to groundwater and
eventually off-site. However, because of Site conditions
and technology limitations, RAA3 and RAA4 are only
projected to remediate the Site in a slightly shorter time
frame than RAA1 or RAA2. Therefore, RAA3 and RAA4
do not provide significant additional protection to human
health and the environment than RAA1 or RAA2.
RAA2, RAA3, and RAA4 include deed restriction and
recordation. These institutional controls are designed to
restrict the aquifer to non-potable use and record areas
of the aquifer above groundwater standards until such
time as groundwater standards are achieved. These
three alternatives also include abandonment of the
inactive public supply wells which will keep additional
contamination from migrating into the lower aquifer.
Compliance with ARARs: All four RAAs are expected
to comply with State and Federal chemical-, location-,
and action-specific ARARs that are established for this
Site.
!-term Effectiveness and Permanence: All of the
are designed to accomplish long-term
effectiveness and permanence. All of the alternatives
rely on monitored natural attenuation, however. RAAS
and RAA4 augment attenuation with active cleanup
systems. As identified in the remedial alternative
description section, it is anticipated that each alternative
will achieve the performance standards in nearly the
same time frame.
Reduction of Toxicitv. Mobility or Volume:
Alternatives RAA3 and RAA4 actively reduce the toxicity,
mass, and volume of contaminants in the groundwater
and satisfy the statutory preference for treatment.
However, natural attenuation processes will also reduce
the toxicity, mobility, or volume of plume through natural
processes. In addition, no treatment residuals are
generated by Alternatives RAA1 or RAA2, as there could
be with Alternatives RAAS and RAA4.-
Short-term Effectiveness: Alternatives RAA1 and
RAA2 pose fewer short-term risks to Site workers and the
community than either Alternative RAA4 or RAA4.
Alternative RAAS and RAA4 may create more short-term
risk due to the invasive nature of the system installation.
Alternatives RAAS and RAA4 also pose risks to receptors
due to the long-term operation and maintenance of the
active systems.
Implements bilitv: Alternative RAA1 requires no
implementation. Alternative RAA2 will be easy to
implement because little to no construction is required.
Both Alternatives RAAS and RAA4 are projected to
require approximately 12 months to design and construct,
and approximately 8 years of operation. Both RAAS and
RAA4 will require the acquisition of a NPOES permit.
Cost: Total present worth costs for the alternatives are
presented below:
Alternative RAA1 - No Action: $ 264.000
Alternative RAA2 - Monitored Natural Attenuation,
Institutional Controls, Abandonment of Inactive
Public Supply Wells, & Removal of Aboveground
Storage Tanks in AOC #5: $ 386,000
Alternative RAAS - Limited Groundwater Extraction with
Discharge to Mitchell Creek via a NPOES Permit,
Monitoring, Abandonment of Inactive Public Supply
Wells, & Removal of Aboveground Storage Tanks in
AOC #5: $1,204,000
Alternative RAA4 - Air Sparging with Soil Vapor
Extraction, Monitoring, & Abandonment of Inactive
Public Supply Wells, & Removal of Aboveground
Storage Tanks in AOC #5: $1,003,000
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EPA'S PREFERRED ALTERNATIVE
As stated in the Introduction, the Agency is proposing to issue a contingency Record of Decision for the
Flanders Filters site. Alternative RAA2 is the Agency's preferred alternative and Alternative RAA4 is the
contingency alternative.
ALTERNATIVE RAA2: MONITORED NATURAL ATTENUATION, INSTITUTIONAL CONTROLS, ABANDONMENT
OF INACTIVE PUBLIC SUPPLY WELLS, & REMOVAL OF ABOVEGROUND STORAGE TANKS IN AOC #5
Based on current information, this alternative appears to provide the best balance of trade-offs with respect
to the seven criteria that EPA used to evaluate these alternatives. EPA believes the preferred alternative
will satisfy the statutory requirement of Section 121 (b) of CERCLA. 42 USC 9621 (b), which provides that the
selected alternative be protective of human health and the environment, comply with ARARs, be cost
effective, and utilize permanent solutions and treatments to the maximum extent practicable. The selection
of Alternative RAA2 is preliminary and could change in response to public comments.
As this alternative relies on monitored natural attenuation to clean the soils and groundwater, Flanders Filters
will be required to substantiate that natural degradation is occurring and continue to verify that natural
attenuation continues to occur. The frequency of this monitoring will be established in the Remedial Design.
In the event the data collected cannot substantiate the occurrence of natural attenuation, beyond doubt, a
contingency remedy, Alternative RAA4, will be implemented. It is anticipated that this decision will be made
within three years of the signing of the Record of Decision.
Institutional controls to be implemented are "land use restrictions" and "deed recordation". Flanders Filters
will record, in the appropriate county and/or State registrar's office, a deed restriction in which Flanders
Filters, and any subsequent owner of the Site, would be prohibited from utilizing the groundwater for drinking
water purposes until such time as the contaminated plume meets drinking water standards. Flanders Filters
will also develop a plan that will protect any worker that needs to work below ground surface on-site.
In addition to the work specified above, Flanders Filters shall also implement the following action items:
1) Abandon the three inactive supply wells in an effort to inhibit the migration of contaminants into the
lower aquifer;
2) Conduct house keeping activities in AOC #5 - these activities shall include the removal the
aboveground storage tanks and the visual inspection and sampling of the underlying soil; and
3) As hazardous waste will remain on the Site, Flanders Filters is required to prepare and submit every
five years the "Five-Year Review Report". These reports will be required until all performance standards
are obtained across the entire Site.
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COMMUNITY PARTICIPATION
EPA has developed a community relations program as mandated by Congress under Superfund to respond to
citizen's concerns and needs for information, and to enable residents and public officials to participate in the
decision-making process. Public involvement activities undertaken at Superfund sites consist of interviews with local
residents and elected officials, a community relations plan for each site, fact sheets, availability sessions, public
meetings, public comment periods, newspaper advertisements, site visits, and any other actions needed to keep the
community informed and involved.
EPA is conducting a 30-day public comment period from June 23, 1998 to July 23, 199ft, to provide an
opportunity for public involvement in selecting the final cleanup method forthis Site. Public input on all alternatives,
and on the information that supports the alternatives is an important contribution to the remedy selection process.
During this comment period, the public is invited to attend a public meeting on June 23, 1998, in the
Washington City Council Chambers, Washington, North Carolina beginning at 7:00 p.m. at which EPA will
present the Remedial Investigation/Feasibility Study and Proposed Plan describingthe preferred remedial alternative
for the Flanders Filters site and to answer any questions. Because this Proposed Plan Fact Sheet provides only a
summary description of the cleanup alternatives being considered, the public is encouraged to consult the Information
Repository for a more detailed explanation.
During this 30-day comment period, the public is invited to review all site-related documents housed at the
Information Repository located at the Brown Public Library, 122 Van Norden Street, Washington, North Carolina and
offer comments to EPA either orally at the public meeting or in written form during this time period. The actual
remedial action could be different from the preferred alternative, depending upon new information or statements EPA
may receive as a result of public comments. If you prefer to submit written comments, please mail them postmarked
no later than midnight July 23,1998 to:
Diane Barrett
NC Community Involvement Coordinator
U.S.E.P.A., Region 4
North Site Management Branch
€1 Forsyth Street, SW
Atlanta, GA 30303-3014
All comments will be reviewed and a response prepared in making the final determination of the most appropriate
alternative for cleanup/treatment of the Site. EPA's final choice of a remedy will be issued in a Record of Decision
(ROD). A document called a Responsiveness Summary summarizing EPA's response to all public comments will
also be issued with the ROD. Once the ROD is signed by the Regional Administrator it will become part of the
Administrative Record (located at the Library) which contains all documents used by EPA in making a final
determination of the best cleanup/treatment for the Site. Once the ROD has been approved, EPA will begin
negotiations with the Potentially Responsible Party to allow them the opportunity to design, implement and absorb
all costs of the remedy determined in the ROD in accordance with EPA guidance and protocol. Or EPA may issue
a unilateral administrative order or directly file suit to force Flanders Filters to conduct the remedial activity. Once
an agreement has been reached, the design of the selected remedy will be developed and implementation of the
remedy can begin. The preceding actions are the standard procedures utilized during the Superfund process.
A Community Advisory Group (CAG) is made up of volunteer members of the community and is designed to serve
as the focal point for the exchange of information among the local community and EPA, State regulatory agency,
and other pertinent Federal agencies involved in cleanup of the Superfund site.
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INFORMATION REPOSITORY LOCATION:
Brown Public Library
122 Van Norden Street
Washington, NC 27889
(919) 975-9356
Business Hours: Monday-Friday 8 am - 9 pm
Saturday 8 am -1 pm
Sunday Noon - 5 pm
FOR MORE INFORMATION ABOUT SITE ACTIVITIES, PLEASE CONTACT:^
Mr. Jon Bornholm, Remedial Project Manager or
Ms. Diane Barrett, NC Community Involvement Coordinator
North Site Management Branch
Waste Management Division
U.S. Environmental Protection Agency, Region IV
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
Toll Free No.: 1-800-435-9233
MAILING LIST
If you are not already on our mailing list and would like to be placed on the list to receive future information on the
Flanders Filters Site, or if you want your name removed from the list, or if you have a change of address, please
complete this form and return to Diane Barrett, Community Relations Coordinator at the above address:
NAME:
ADDRESS:
CITY. STATE, ZIP CODE:.
PHONE NUMBER:
Addition D Change of Address D Deletion D
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GLOSSARY OF TERMS USED IN THIS FACT SHEET
Aquifer: An underground geological formation, or group of formations, containing usable amounts of groundwaler
that can supply wells and springs.
Administrative Order on Consent A legal document signed by EPA and an individual, business, or other entity
through which the violator agrees to pay for correction of violations, take the required corrective or cleanup actions,
or refrain from an activity. It describes the actions to be taken, may be subject to a comment period, applies to civil
actions, and can be enforced in court.
Administrative Record: A file which is maintained and contains all information used by the lead agency to make
its decision on the selection of a method to be utilized to clean up/treat contamination at a Superfund site. This file
is held in the information repository for public review.
Applicable or Relevant and Appropriate Requirements (ARARs): The federal and state requirements that a
selected remedy must attain. These requirements may vary among sites and various alternatives.
Baseline Risk Assessment A means of estimating the amount of damage a Superfund site could.cause to human
heath and the environment. Objectives of a risk assessment are to: help determine the need for action; help
determine the levels of chemicals that can remain on the site after cleanup and still protect health and the environ-
ment; and provide a basis for comparing different cleanup methods.
Carcinogen: Any substance that can cause or contribute to the production of cancer; cancer-producing.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): A federal law passed
in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization Act (SARA). The Acts created
a special tax paid by producers of various chemicals and oil products that goes into a Trust Fund, commonly known
as Superfund. These Acts give EPA the authority to investigate and clean up abandoned or uncontrolled hazardous
waste sites utilizing money from the Superfund Trust or by taking legal action to force parties responsible for the
contamination to pay for and clean up the site.
/
Feasibility Study. Refer to Remedial Investigation/Feasibility Study.
Groundwater: Water found beneath the earth's surface that fills pores between materials such as sand, soil, or
gravel (usually in aquifers) which is often used for supplying wells and springs. Because groundwater is a major
source of drinking water there is growing concern over areas where agricultural and industrial pollutants or
substances are getting into groundwater.
Hazard Quotient: The numerical representation of the potential of noncarcinogenic health effects due to the
exposure to a chemical.
Hazardous Ranking System (MRS): The principle screening tool used by EPA to evaluate risks to public health
and the environment associated with hazardous waste sites. The HRS calculates a score based on the potential of
hazardous substances spreading from the site through the air, surface water, or groundwater and on other factors
such as nearby population. This score is the primary factor in deciding if the site should be on the National Priorities
List and, if so, what ranking it should have compared to other sites on the list.
Hydraulic Divide: A geologic formation (ocean, lake, river, stream, mountain range, etc.) That groundwater does
not flow underneath.
Information Repository: A file containing accurate up-to-date information, technical reports, reference documents,
information about the Technical Assistance Grant, and any other materials pertinent to the site. This file is usually
located in a public building such as a library, city hall or school, that is accessible for local residents.
National Pollutant Discharge Elimination System (NPDES): A provision of the Clean Water Act which prohibits
the discharge of pollutants into waters of the linked States unless a special permit is issued by EPA, a state or (where
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delegated) a tribal government on an Indian reservation allowing a controlled discharge of liquid after it has
undergone treatment.
Metals (Inorganics): Chemical substances of mineral origin, not of basically carbon structure.
National Priorities List (NPL): EPA's list of the most serious uncontrolled or abandoned hazardous waste sites
identified for possible long-term remedial action under Superfund. A site must be on the NPL to receive money from
the Trust Fund for remedial action. The list is based primarily on the score a site receives from the Hazard Ranking
System (HRS). EPA is required to update the NPL at least once a year.
Operable Unit Term for each of a number of separate activities undertaken as part of an overall Superfund site
cleanup.
Polycyclic Aromatic Hydrocarbon: Polycyclic aromatic hydrocarbons (PAHs) are a group of over 100 different
chemicals that are formed during the incomplete burning of coal, oil and gas. garbage, or other organic substances
like tobacco or charbroiled meat. PAHs are usually found as a mixture containing two or more of these compounds,
such as soot. Some PAHs are manufactured. PAHs are found in coal tar, crude oil. creosote, and roofing tar. A few
are used in medicines, dyes, plastics and pesticides.
Potentially Responsible Parties (PRP): Any individual or company - including owners, operators, transporters, or
generators - potentially responsible for, or contributing to, the contamination problems at a Superfund site. When-
ever possible, EPA requires Potentially Responsible Parties, through administrative and legal actions, to clean up
hazardous waste sites Potentially Responsible Parties have contaminated.
Remedial Action Objectives: These are specific objectives which are identified to protect both human health and
the environment that take into consideration the environmental media contaminated (i.e., groundwater, soil, surface
water, sediment, or air) and the contaminants present in each medium. The main goal of the objectives is to prevent
exposure to contaminants in groundwater, soil, surface water, sediment, or air in excess of risk-based human health
or environmental standards.
Remedial Investigation/Feasibility Study (RI/FS): The Remedial Investigation is an in-depth, extensive sampling
and analytical study to gather data necessary to determine the nature and extent of contamination at a Superfund
site; to establish criteria for cleaning up the she; a description and analysis of the potential cleanup alternatives for
remedial actions; and support the technical and cost analyses of the alternatives. The Feasibility study also usually
recommends selection of a cost-effective alternative.
Record of Decision (ROD): A public document that announces and explains which method has been selected by
the Agency to be used at a Superfund site to clean up the contamination.
Responsiveness Summary: A summary of oral and written public comments received by EPA during a public
comment period and EPA's responses to those comments. The responsiveness summary is a key part of the Record
of Decision.
Semi-Volatile Organic Compounds (SVOCs): Carbon-containing chemical compounds that, at a relatively low
temperature, fluctuate between a vapor state (a gas) and a liquid state.
Vadose Soil Zone: Is the unsaturated zone of soil starting at the surface and ending at the water table (i.e., the
space between the soil particles contains both water and air).
Volatile Organic Compounds (VOCS): Any organic compound that evaporates readily into the air at room
temperature.
Water Table: The level below which the soil or rock is saturated with water, sometimes referred to as the upper
surface of the saturated zone. The level of groundwater.
-------
U.S. Environmental Protection Agency
North Site Management Branch
Diane Barrett, Community Involvement Coordinator
Jon Bornholm, Remedial Project Manager
61 Forsyth Street, SW
Re_,'on4 Atlanta. Georgia 30303-3104
Official Business
Penalty for Private Use $300
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APPENDIX D
RESPONSIVENESS SUMMARY
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FLANDERS FILTERS SITE
WASHINGTON, BEAUFORT COUNTY, NORTH CAROLINA
REGION 4
PROPOSED PLAN PUBLIC MEETING
TUESDAY, JUNE 23, 1998 AT 7:00 P.M.
WASHINGTON CITY COUNCIL CHAMBERS
COURT REPORTER: GAYE H. PAUL
CAROLINA COURT REPORTERS, INC.
102 Oakmont Professional Plaza
Greenville, North Carolina 27858
TEL: (919) 355-4700 (800) 849-8448
FAX: (919) 355-2100
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1 MS. DIANE BARRETT: TONIGHT WE'RE GOING TO
2 PRESENT THE RESULTS OF A FIELD INVESTIGATION AND THEN GIVE
3 ALL THE TREATMENT OPTIONS TO HANDLE THE CONTAMINANTS AT THE
4 SITE. MY NAME IS DIANE BARRETT, AND I'M THE COMMUNITY
5 INVOLVEMENT COORDINATOR FOR EPA FOR THIS SITE IN NORTH
6 CAROLINA. MR. JON BORNHOLM IS THE PROJECT MANAGER FOR THE
7 SITE FOR EPA. HE TAKES CARE OF ALL THE TECHNICAL ASPECTS, SO
8 HE'S THE ONE THAT WILL ANSWER ALL THE QUESTIONS. MR. DAVID
9 ZEROKI IS ALSO ASSISTING THE EPA; HE IS THE COMMUNITY
10 OUTREACH COORDINATOR. BEFORE WE GET TO THE HEART OF THIS
11 MEETING, I WOULD LIKE TO TAKE A MOMENT TO RECOGNIZE ANY
12 OFFICIALS, STATE OR LOCAL OFFICIALS. BRUCE NICHOLSON IS HERE
13 WITH THE STATE OF NORTH CAROLINA. THANK YOU. AGAIN, I WANT
14 TO THANK ALL OF YOU FOR TAKING YOUR TIME TO ATTEND THIS
15 MEETING. SUPERFUND, SUPERFUND IS THE LAW WHICH CONGRESS
16 ENACTED IN 1980 WHICH GAVE THE ENVIRONMENTAL PROTECTION
17 AGENCY THE AUTHORITY TO CLEAN UP HAZARDOUS WASTE SITES. WITH
18 THIS NEW PROGRAM, WITH THIS NEW LAW, THIS AGENCY HAS BEEN
19 WORKING TOWARD DEVELOPING SUPERFUND INVESTIGATIVE PROCESSES
20 AND METHODS FOR CLEANING UP CONTAMINANTS AT DIFFERENT SITES,
21 SUCH AS THE GROUNDWATER, THE SURFACE WATER, THE STREAMS, THE
22 SEDIMENTS IN THE SOIL AND THE AIR. THE SUPERFUND PROGRAM IS
23 FINANCED THROUGH A TAX THAT IS LEVIED AGAINST CHEMICAL
24 COMPANIES AND PETROLEUM MANUFACTURERS. THESE FUNDS HAVE BEEN
25 PUT IN A SET-AS IDE FUND, AND THEY ARE USED WHENEVER THERE IS
Carolina Court Reporters, Inc.
Greenville, North Carolina
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1 NO VIABLE PARTY TO PAY FOR THE CONTAMINATION OR TO SEE TO THE
2 CLEANUP. IN THE CASE OF THIS PARTICULAR SITE, FLANDERS
3 FILTERS HAS THUS FAR PAID FOR ALL THE WORK THAT IS BEING DONE
4 AND IS EXPECTED TO CONTINUE TO PAY FOR THE REST OF IT.
5 FEATURED ON THIS OVERHEAD CHART HERE IS JUST THE SUPERFUND
6 PROCESS ITSELF AND THE MAJOR STEPS OF THE PROCESS;
7 THROUGHOUT, YOU WILL NOTICE THAT WE HAVE THE VARIOUS
8 ACTIVITIES FOR COMMUNITY OUTREACH. IN ADDITION TO THIS WE
9 ALSO HAVE WHAT THE AGENCY CALLS A TECHNICAL ASSISTANCE GRANT.
10 THIS GRANT IS PROVIDED FOR AN ORGANI2ED COMMUNITY GROUP THAT
11 WANTS TO HIRE A CONSULTANT TO HELP THEM GO OVER ALL THE
12 TECHNICAL DOCUMENTS AND PROVIDED COMMENTS AND SO FORTH, AND
13 EXPLAIN MORE IN LAYMAN TERMS WHAT WE'RE SAYING THROUGH ALL
14 THE TECHNICAL DOCUMENTS. ALSO, THERE IS A COMMUNITY ADVISORY
15 GROUP WHICH CAN BE FORMED; HOWEVER, THIS PARTICULAR GROUP
16 DOES NOT HAVE ANY FUNDING. THIS WOULD BE A VOLUNTARY
17 PROGRAM. SO IF ANYBODY IS INTERESTED IN EITHER ONE OF THESE,
18 PLEASE LET ME KNOW AND WE'LL TALK ABOUT THOSE. FLANDERS
19 FILTERS BEGAN OPERATING IN 1969. IN 1978 THE FACILITY BEGAN
20 TO SPRAY TREATED WASTE WATER FROM THE PRODUCTION PROCESS ONTO
21 THE SPRAY FIELD THAT'S LOCATED ON THE SITE. THEN IN 1984 A
22 SECOND SPRAY FIELD WAS OPENED FOR OPERATION. IN ORDER FOR
23 FLANDERS TO OPERATE THESE SPRAY FIELDS, THEY WERE REQUIRED BY
24 THE STATE OF NORTH CAROLINA TO HAVE A PERMIT AND ALSO TO
25 INSTALL MONITORING WELLS SO THAT THEY COULD KEEP TABS ON THE
Carolina Court Reporters, Inc.
Greenville, North Carolina
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1 GROUNDWATER, SO THAT IF ANY CONTAMINATION SHOWED UP WE COULD
2 TAKE THE NECESSARY ACTIONS. THEY ALSO HAD SEVERAL RETENTION
3 PONDS THAT WERE USED FOR HOLDING WATER THAT WAS TREATED.
4 WHEN THE STATE WAS NOTIFIED THAT THERE WAS SOME CONTAMINATION
5 PRESENT, THEY DID A MINI INVESTIGATION AND THEN LATER ON EPA
6 WAS NOTIFIED. THEN AS A MATTER OF OUR STANDARD PROCEDURES WE
7 BEGAN OUR INVESTIGATION. THEN IN 1996, FLANDERS FILTERS
8 AGREED TO WORK WITH EPA TO GET THE SITE CLEANED UP. THAT'S
9 WHAT BRINGS US TO THIS POINT IN TIME. THE REMEDIAL
10 INVESTIGATION HAS BEEN COMPLETED AND JOHN WILL PRESENT THE
11 RESULTS OF THAT REPORT. THEN HE WILL ALSO PRESENT THE
12 RESULTS OF THE VARIOUS OPTIONS THAT CAN BE USED TO TREAT THE
13 CONTAMINATION, AND WE ARE ASKING FOR YOUR INPUT. THE
14 PROPOSED PLAN FACT SHEET WHICH YOU RECEIVED WHEN YOU CAME
15 INTO THE ROOM, WE WANT YOU TO READ THAT AND CONSIDER THE
16 VARIOUS OPTIONS THERE, THE INFORMATION THAT IS THERE AND GIVE
17 US YOUR COMMENTS. A THIRTY DAY TIME FOR COMMENTS HAS BEEN
18 GIVEN FOR THIS PROPOSED PLAN. IT BEGINS TODAY AND ENDS ON
19 JULY 23RD. IT CAN BE EXTENDED ANOTHER THIRTY DAYS IF
20 SOMEBODY ASKS FOR IT; IF YOU NEED THAT, WE'LL BE GLAD TO
21 EXTEND THAT. BUT AT THIS MOMENT, THE COMMENT PERIOD ENDS
22 JULY 23RD. WE HAVE GONE THROUGH THE PROCESS NOW OF THE SITE
23 DISCOVERY, THE REMEDIAL INVESTIGATION, THE FEASIBILITY STUDY
24 AND THE PUBLIC COMMENTS PERIOD, SO THIS IS WHERE WE ARE RIGHT
25 NOW. AFTER THE PUBLIC COMMENT PERIOD HAS ENDED, ALL THE
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1 COMMENTS THAT WE RECEIVE FROM THE PUBLIC BASED ON--AND ALSO
2 ALL THE TECHNICAL INFORMATION THAT WE HAVE DEVELOPED SO FAR
3 WILL BE REVIEWED, AND THEN A REMEDY WILL BE SELECTED. THAT
4 WILL BE THE RECORD OF DECISION, NUMBER 6. THEN ONCE THE
5 RECORD OF DECISION HAS BEEN FINALIZED, A COPY OF THAT WILL BE
6 PUT IN OUR INFORMATION REPOSITORY HERE WHICH IS THE BROWN
7 PUBLIC LIBRARY ON VAN NORDEN STREET. THE DOCUMENTS IN THE
8 LIBRARY WILL PROVIDE ALL THE TECHNICAL INFORMATION THAT EPA
9 HAS AVAILABLE FOR US, AS WELL AS YOU, TO REVIEW AND MAKE A
10 DECISION. ALSO ON THE TABLE AS YOU CAME IN, AT THE ENTRANCE,
11 THERE IS VARIOUS LITERATURE ON THE CLEANUP OPTIONS THAT WE'RE
12 CONSIDERING; WE'D LIKE YOU TO REVIEW THAT TOO. AFTER THE
13 PUBLIC COMMENT PERIOD ENDS, AS I SAID, ALL THE DOCUMENTS WILL
14 BE PUT INTO--WELL, THEY SHOULD BE PUT INTO THE REPOSITORY
15 TOMORROW. WE'VE HAD A LITTLE DELAY IN GETTING THE
16 DOCUMENTATION OUT, SO IT SHOULD ARRIVE AND BE IN THE LIBRARY
17 TOMORROW IF YOU WANT TO REVIEW IT. TONIGHT'S MEETING IS ONE
18 OF THE MEETINGS THAT IS REQUIRED BY OUR SUPERFUND LAW. IT IS
19 BEING RECORDED AND A TRANSCRIPT WILL BE MADE AND PLACED IN
20 REPOSITORY FOR YOUR REVIEW. I WOULD LIKE TO ASK, TOO, THAT
21 AFTER JON MAKES HIS PRESENTATION AND WE OPEN IT UP FOR
22 COMMENTS, IF YOU WOULDN'T MIND STANDING AND GIVING YOUR NAME
23 SO THAT THE COURT REPORTER CAN GET YOUR COMMENT ACCURATELY.
24 IF FOR ANY REASON SHE CAN'T UNDERSTAND YOU, SHE'S GOING TO
25 WAVE AT YOU AND SAY STOP; PLEASE REPEAT IT, SO THAT SHE CAN
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1 GET THAT. WE DO THIS TOO, SO THAT WE WILL HAVE A RECORD OP
2 EVERYTHING THAT IS SAID SO THAT WE CAN MAKE SURE THAT WE
3 PROPERLY RESPOND TO ALL THE COMMENTS THAT ARE OFFERED HERE IN
4 THE MEETING AS WELL AS IN WRITING. SO I THANK YOU FOR YOUR
5 ATTENTION. DOES ANYBODY HAVE ANY QUESTIONS THUS FAR? OKAY,
6 JON, I'M GOING TO TURN IT OVER TO YOU. THANK YOU FOR YOUR
7 ATTENTION; WE APPRECIATE IT.
8 MR. JON BORNHOLM: THANK YOU, DIANE. FIRST OF
9 ALL, I HOPE THAT EVERYBODY HAS PICKED UP A WHITE PACKAGE THAT
10 HAS A COVER SHEET. THIS IS BASICALLY A COPY OF ALL THE
11 OVERHEADS THAT I WILL BE GOING THROUGH TONIGHT, SO THAT IN
12 CASE YOU WANT TO REFER TO THEM LATER ON YOU HAVE A COPY OF
/
13 THEM. AS DIANE HAS POINTED OUT, MY FIRST COUPLE OF MINUTES
14 WILL BE TO QUICKLY GO THROUGH THE REMEDIAL INVESTIGATION,
15 WHICH ALSO INCLUDES THE BASELINE RISK ASSESSMENT, AND THEN
16 MOVE INTO THE FEASIBILITY STUDY WHERE WE EVALUATED THE
17 ALTERNATIVES, THEN BASICALLY GO THROUGH IN MORE DETAIL WHAT
18 THE AGENCY'S PREFERRED ALTERNATIVE IS. FOR THOSE WHO DON'T
19 KNOW WHERE FLANDERS FILTERS SITE IS, IT'S LOCATED BASICALLY
20 OFF OF 264. DIANE GAVE YOU SOME OF THE HISTORY, SO WE'LL
21 QUICKLY GO THROUGH THIS. BASICALLY THEY STARTED OPERATIONS
22 IN '69. THEY USED THE LOCAL LANDFILL FOR DISPOSAL OF THE
23 WASTE BETWEEN '69 AND '78, AND THEN THEY STARTED USING
24 ON-SITE TREATMENT TO TREAT THEIR WASTE WATER AND USED A SPRAY
25 FILED TO GET RID OF THAT TREATED WATER. AND THAT FIRST SPRAY
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1 FIELD WE CALL SPRAY FIELD NUMBER 1. IN '82, AS DIANE HAS
2 ALLUDED TO, THEY WERE REQUIRED TO PUT IN SOME MONITORING
3 WELLS TO KEEP TRACK OF THE QUALITY OF GROUND WATER AND MAKE
4 SURE THAT WAS NOT BEING IMPACTED. ALSO IN '82 THEY CLOSED
5 SPRAY FIELD NUMBER 1 BECAUSE THEY WERE EXPANDING THE SITE.
6 THEY OPENED UP A SECOND SPRAY FIELD WHICH IS DESIGNATED AS
7 SPRAY FIELD NUMBER 2. AND BECAUSE THEY MOVED THAT SPRAY
8 FIELD, THEY HAD TO PUT ADDITIONAL MONITORING WELLS INTO THE
9 GROUND TO AGAIN MONITOR THE GROUNDWATER QUALITY. BECAUSE
10 SOME CONTAMINANTS DID SHOW UP IN THOSE MONITORING WELLS, AS
11 WELL AS IN THE INACTIVE SUPPLY WELLS ON THE FLANDERS
12 PROPERTY, THE AGENCY STARTED IT;S PRELIMINARY REMEDIAL
13 INVESTIGATIONS. FIRST WE DO A SITE SCREENING; AND IF IT
14 PASSES A CERTAIN TEST, IT MOVES ON TO THE NEXT STEP. WE LOOK
15 AT IT IN A LITTLE BIT GREATER DETAIL TO SEE IF THERE IS A
16 CONCERN OUT THERE. THE REASON WHY WE'RE HERE IS IT KEPT ON
17 PASSING THIS TEST, THAT THERE IS A CONCERN OUT THERE, WHICH
18 LED US TO NEGOTIATE WITH FLANDERS FILTERS IN '96; AND THEY
19 SIGNED AN ADMINISTRATIVE ORDER TO DO A REMEDIAL INVESTIGATION
20 AND FEASIBILITY STUDY AT THEIR PROPERTY. ONE OF THE FIRST
21 THINGS WE DID WAS TO PUT WHAT WE CALL A REMEDIAL
22 INVESTIGATION FEASIBILITY STUDY WORK PLAN; THAT'S LIKE OUR
23 MAP; IT KIND OF GUIDES US AS TO HOW WE--WE'RE GOING TO STUDY
24 THAT SITE. THE FIRST THING WE DID WAS TO IDENTIFY AREAS OF
25 CONCERN, WHICH I'VE HIGHLIGHTED IN GREEN HERE. THERE.WERE
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1 NINE OF THEM. THIS USED TO BE THE HAZARDOUS WASTE STORAGE
2 AREA, AREA OF CONCERN NUMBER 1; AREA OF CONCERN NUMBER 2 ARE
3 THE RETENTION PONDS, THIS AREA RIGHT HERE, THOSE TWO
4 RETENTION PONDS ON SITE. THE THIRD AREA OF CONCERN WAS THE
5 FIRST SPRAY FIELD, WHICH IS THIS GREEN BOX HERE; AREA NUMBER
6 4 IS THIS BIG AREA HERE WHICH IS SPRAY FIELD NUMBER 2; AREA
7 OF CONCERN NUMBER 5 WAS THE ABOVE GROUND STORAGE TANK AREA
8 WHICH IS LOCATED RIGHT IN THIS AREA. NUMBER 6 IS THE
9 ABANDONED RAILROAD TRACK THAT IS NORTH OF THE PROPERTY. AREA
10 OF CONCERN NUMBER 7 ARE THOSE DRAINAGE DITCHES THAT DRAIN THE
11 PROPERTY, BASICALLY RIGHT THROUGH HERE. AREA OF CONCERN
12 NUMBER 8 WAS MITCHELL BRANCH ITSELF, WHICH FLOWS DOWN THIS
13 WAY; AND THEN AREA OF CONCERN NUMBER 9 IS THE GROUNDWATER
14 THAT FLOWS UNDERNEATH THE PROPERTY. AND THEN THERE IS A LIST
15 IN THE PACKAGE THAT LISTS ALL OF THOSE AREAS CONCERNED.
16 BASICALLY WHAT THE REMEDIAL INVESTIGATION ITSELF ENTAILED WAS
17 COLLECTING OVER 70 ENVIRONMENTAL SAMPLES, AND THAT'S
18 COLLECTING SAMPLES FROM THE GROUNDWATER, FROM THE SURFACE
19 SOILS, FROM THE SUBSURFACE SOILS, AS WELL AS FROM SURFACE
20 WATER AND SEDIMENT SAMPLES FROM THE DRAINAGE DITCHES, SURFACE
21 WATER AND SEDIMENT SAMPLES FROM MITCHELL BRANCH AND THEN
22 SEDIMENT SAMPLES FROM TRANTERS CREEK. BASICALLY THE MAIN
23 FOCUS OR THE OBJECTIVES OF THE REMEDIAL INVESTIGATION IS
24 FIRST TO DETERMINE WHAT TYPE OF CONTAMINANTS ARE OUT THERE AT
25 THE SITE; TWO, AT WHAT CONCENTRATION; AND THEN BASICALLY THE
8
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1 THIRD OBJECTIVE IS TO DETERMINE HOW FAR AND WHERE THOSE
2 CONTAMINANTS HAVE MIGRATED. AS TO THE FIRST OBJECTIVE,
3 BASICALLY THE CONTAMINANTS OF CONCERN THAT WE DETECTED OUT AT
4 THE SITE, ON THE LEFT-HAND SIDE ARE BASICALLY WHAT WE CALL
5 VOLATILE ORGANIC COMPOUNDS. THEY'VE ALL GONE EASILY AND
6 QUICKLY INTO THE AIR. AND THEN ON THE RIGHT-HAND SIDE THOSE
7 ARE METALS OR WHAT WE CALL, I'LL USE THE TERM INORGANICS;
8 METALS AND INORGANICS ARE BASICALLY INTERCHANGEABLE. WHERE
9 IS THE CONTAMINATION? BASICALLY WE FOUND TWO SOURCES OUT
10 THERE. AREA OF CONCERN NUMBER 1,_WHICH IS THE HAZARDOUS
11 WASTE STORAGE AREA; AREA NUMBER 4 WHICH IS SPRAY FIELD NUMBER
12 2; AND THEN AREA OF CONCERN NUMBER 5 WHICH IS THE ABOVE
13 GROUND STORAGE TANK AREA. THE NEXT COUPLE OF OVERHEADS
14 BASICALLY JUST HIGHLIGHT--YOU MIGHT NOT BE ABLE TO SEE THE
15 NUMBERS--HIGHLIGHT THE CONTAMINANTS THAT WE DID DETECT IN
16 EACH OF THESE ENVIRONMENTAL AREAS.
17 BARNEY KANE: ARE THOSE THE ONLY THREE PLACES
18 THAT WERE CONTAMINATED AT THE SCENE? THE OTHER 5 AND 6 AND
19 3--
20 JON BORNHOLM: BASICALLY--
21 BARNEY KANE: SO THE SITES NOT SHOWN THERE--
22 JON BORNHOLM: I'M SORRY?
23 BARNEY KANE: THE SITES NOT SHOWN THERE, THAT IS
24 2 AND 3--
25 JON BORNHOLM: 2, 3--
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1 BARNEY KANE: AND 6, 7, 8 AND 9 WERE NOT
2 CONTAMINATED?
3 . JON BORNHOLM: NO, SOURCES OF CONTAMINATION;
4 THAT MEANS--
5 BARNEY KANE: OH, SOURCES OF CONTAMINATION.
6 JON BORNHOLM: OUTSIDE SOURCES OF CONTAMINATION.
7 BASICALLY I'M JUST GOING TO TRY TO GO THROUGH THE OVERHEADS.
8 THIS IS THE SURFACE SOIL SAMPLING. THIS IS A BLOWUP OF AREA
9 NUMBER 1, AREA OF CONCERN NUMBER 1, WHICH IS OVER HERE
10 (INDICATING) . WE DID FIND SOME CONTAMINANTS THERE. HERE IS
11 AREA NUMBER 5, WHICH IS THE ABOVE GROUND STORAGE TANK
12 (INDICATING), AND THEN AREA NUMBER 4, WHICH IS THE SPRAY
13 FIELD. WE DID FIND SOME CONTAMINANTS IN THE SURFACE SOILS
14 THERE. MOVING ON TO THE SURFACE WATER, AREA OF CONCERN
15 NUMBER 7, THE DRAINAGE DITCHES, AND WE DID FIND CONTAMINANTS
16 AND THE VOLATILE ORGANICS THAT I HAVE LISTED UP ABOVE AS WELL
17 AS SOME OF THE METALS--WHICH IS THESE STRANGE PICTURES WE
<
18 SEE, SURFACE RUNOFF FROM THE SITE AS WELL AS GROUNDWATER
19 DISCHARGING INTO THOSE STREAMS AS WELL. THE NEXT PICTURE
20 SHOWS THE CONTAMINANTS; AGAIN IN THE SURFACE DRAINAGE
21 FEATURES OF THE SITE WOULD BE THE SEDIMENTS OF THE SITE,
22 AGAIN IN WHICH WE FIND HAS BASICALLY THE SAME TYPES OF
23 CONTAMINANTS. MOVING ON TO THE SURFACE WATER OF MITCHELL
24 BRANCH, AND WE ARE SEEING SOME LOW LEVELS OF CONTAMINANTS IN
25 THIS STREAM RIGHT HERE; AND PARTS PER BILLION ARE THE LEVELS
10
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1 OP CONCENTRATIONS AND THEN IN SEDIMENT. WE ALSO SAMPLED--OR
2 FLANDERS FILTERS SAMPLED THE WETLANDS AREA, WHICH WE TREATED
3 AS A SOIL SAMPLE; AND AGAIN THERE WAS CONTAMINANTS WHICH
4 MAKES SENSE, BECAUSE AS GROUNDWATER PASSES THROUGH THE
5 WETLANDS TOWARDS MITCHELL BRANCH, WE WOULD FIND CONTAMINANTS
6 THERE. MOVING INTO THE GROUNDWATER, WE DID FIND CONTAMINANTS
7 IN THE SHALLOW AQUIFER, WHICH IS BASICALLY THE TOP 20 FEET,
8 FROM GROUND SURFACE DOWN 20 FEET; THEN WE RUN INTO THE
9 YORKTOWN LAYER, WHICH IS A'CONFINING LAYER, WHICH ACTS AS A
10 BOUNDARY FOR THE MOVEMENT OF GROUNDWATER SO IT WON'T MOVE
11 MORE VERTICALLY; IT WON'T MOVE FURTHER INTO THE DEEPER
12 AQUIFER THAT UNDERLIES THAT YORpOWN FORMATION. WE FOUND
13 SOME CONTAMINANTS HERE; THERE'S ALSO TWO MONITORING WELLS,
14 ONE RIGHT HERE, ONE HERE AND ONE HERE (INDICATING) WHICH IS
15 THE NEXT TWO SLIDES, POINT 2; AND THESE ARE DOWNSTREAM OF
16 AREA OF CONCERN NUMBER 1, WHICH IS WHERE WE FOUND BOTH
17 CONTAMINANTS. SO IN MONITORING WELL NUMBER 13 WE HAD SOME
18 HIGH LEVELS, HIGHER LEVELS THAN WE HAD SEEN ACROSS ANY OF THE
19 OTHER PARTS OF THE SITE. THEN IN MONITORING WELL NUMBER 14,
20 WHICH IS AGAIN PRETTY MUCH DOWN RADIANT OF AREA OF CONCERN
21 NUMBER 1. THEN WE'RE SEEING SOME HIGH LEVELS OF THE VOLATILE
22 ORGANICS. AREA OF CONCERN NUMBER 1 WAS UP IN THIS AREA
23 (INDICATING). NOW, I'LL TRY TO TIE ALL THIS INFORMATION
24 TOGETHER WITH ONE MORE PIECE OF INFORMATION BEFORE WE MOVE
25 ON. THIS PICTURE SHOWS THE DIRECTION THE GROUNDWATER IS
11
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1 FLOWING IN THE SURPACIAL AQUIFER, AND IT'S BASICALLY
2 EVENTUALLY FLOWING TOWARDS MITCHELL BRANCH. THE NEXT TWO
3 FIGURES KIND OF TRY TO DELINEATE THE EXTENT OF GROUNDWATER
4 CONTAMINATION. AGAIN, WE HAVE HIGH LEVELS OF CONTAMINATION
5 UP HERE; WE CAN SEE THE SEDIMENT AROUND WELL DESIGNATED NW-
6 14. THEN AS WE MOVE FURTHER AWAY FROM THE SOURCE, EACH OF
7 THESE LINES REPRESENTS A LEVEL OF NON-DETECT; AND THIS LEVEL
8 HERE, THIS LINE RIGHT HERE REPRESENTS BASICALLY NON-
9 CONTAMINANTS IN THE GROUNDWATER, IN THE SHALLOW GROUNDWATER.
10 DAN EDWARDS: THAT LAST LINE REPRESENTS WHAT?
11 MR. BORNHOLM: NO CONTAMINANTS WERE DETECTED
12 BEYOND THIS POINT. j
13 DAN EDWARDS: NONE DETECTED?
14 MR. BORNHOLM: NONE DETECTED IN THE SHALLOW
15 GROUNDWATER. AND THAT'S FOR A CONTAMINANT OF 1,1-
16 DICHLOROETHENE AND PRETTY MUCH--VERY SIMILAR TO CONTAMINANT
17 1,1,1,-TRICHLOROETHANE WHICH HAS THAT ACRONYM, 1,1,1,-TCA.
18 AGAIN, THIS IS BASICALLY THE SAME RESULTS. AS WE MOVE CLOSER
19 TO THE SITE BOUNDARY, THE LEVELS OF CONTAMINANTS IN THE
20 SHALLOW GROUNDWATER GO TO NON-DETECT. BECAUSE WE DID FIND
21 CONTAMINANTS IN THE INACTIVE DRINKING--PUBLIC WATER SUPPLY
22 WELLS, WHICH ARE RIGHT HERE, WE DID LOOK INTO THE
23 INTERMEDIATE AQUIFER WHICH IS BELOW THE CLAY LAYER; AND WE
24 DID FIND SOME LOW LEVELS OF CONTAMINANTS, BUT THEY'RE ALL
25 BELOW EITHER STATE GROUNDWATER STANDARDS OR FEDERAL DRINKING
12
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1 WATER STANDARDS.
2 BARNEY KANE: WHICH AQUIFER DID YOU FIND IT TO
3 BE BELOW--YOU SAID BELOW THE CLAY LAYER--IS IT THE YORKTOWN
4 OR BELOW THE YORKTOWN?
5 JON BORNHOLM: BELOW THE YORKTOWN.
6 BARNEY KANE: IN THE YORKTOWN THERE WAS
7 CONTAMINANTS IN THE DRINKING WATER?
8 JON BORNHOLM: WHAT THEY'RE THINKING IS THAT
9 THESE WELLS ARE NOT--THE WELL CASING IS NOT A VERY GOOD WELL
10 CASING AND CONTAMINANTS HAVE SLIPPED DOWN ALONG THE CASING,
11 IS WHAT WE WERE ANTICIPATING HAS HAPPENED.
12 BARNEY KANE: SO YOU'RE SAYING THE VERY WELL YOU
13 PUT IN THE MONITOR CAUSED THE--
14 JON BORNHOLM: NO, THESE LEVELS ARE ALREADY IN--
15 BARNEY KANE: OKAY. THE DRINKING WATER.
16 JON BORNHOLM: THOSE WERE THE INACTIVE DRINKING
17 WATER. AND THAT WAS THE MAIN REASON, I GUESS, WHY THOSE
18 WELLS WERE SHUT DOWN, BECAUSE CONTAMINANTS WERE DETECTED IN
19 THEM. I'LL JUST--NOT TO BELABOR THE POINT AND TRY TO GO OVER
20 THESE QUICKLY. AGAIN, I'VE HIGHLIGHTED WHAT WE FOUND FOR
21 EACH AREA OF CONCERN; NUMBER 1 AGAIN IS A HAZARDOUS WASTE
22 STORAGE AREA; AGAIN, WE DID DETECT CONTAMINANTS THERE. AREA
23 2, WHICH WERE THE RETENTION PONDS, WE DID NOT DETECT ANY
24 CONTAMINANTS IN THAT AREA--IN THOSE PONDS, I SHOULD SAY.
25 AREA NUMBER 3, WHICH IS SPRAY FIELD NUMBER 1, WE DID NOT FIND
13
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1 ANY CONTAMINANTS. AREA OF CONCERN NUMBER 4, WHICH IS SPRAY
2 FIELD NUMBER 2, WE DID FIND SOME TRACE LEVEL OF VOLATILE AND
3 SEMI-VOLATILE COMPOUNDS AS WELL AS ZINC. WE ALSO FOUND
4 VOLATILES IN THE GROUNDWATER UNDERNEATH SPRAY FIELD NUMBER 2.
5 AREA OF CONCERN NUMBER 5, WHICH IS THE ABOVE GROUND STORAGE
6 TANK AREA, WE FOUND VOLATILES AND MOST OF THOSE SEMI-
7 VOLATILES ARE FUEL RELATED, BECAUSE THEY DO HAVE A FUEL TANK
8 THERE--OR DIESEL FUEL. AREA NUMBER 6, WHICH WAS THE RAILROAD
9 TRACK, THAT WAS NEVER SAMPLED BECAUSE THE THOUGHT PROCESS
10 THERE WAS IF THERE WERE CONTAMINANTS ASSOCIATED WITH THE
11 RAILROAD TRACK, WE WOULD FIND THEM IN THE DRAINAGE DITCH; AND
12 WE DIDN'T FIND ANY CONTAMINANTS, THAT WE COULD TRACE BACK TO
13 THE RAILROAD TRACK AND BASICALLY, THAT WOULD BE CREOSOTE •
14 COMPOUNDS. SO THE RAILROAD TRACK WAS NOT SAMPLED. AREA OF
15 CONCERN NUMBER 7, WHICH IS THE DRAINAGE DITCH AREA, WE DID
16 FIND VOLATILE AND SEMI-VOLATILE INORGANIC COMPOUNDS AS WELL
17 AS METALS. IN AREA OF CONCERN NUMBER 8, WHICH IS MITCHELL
18 BRANCH, AGAIN WE DID FIND SOME VOLATILE COMPOUNDS, AS WELL AS
19 SOME METALS. AREA 9, WHICH IS THE UNDERLYING AQUIFER, WE
20 FOUND VOLATILES, SEMI-VOLATILES AS WELL AS METALS. THAT KIND
21 OF JUST RECAPS EVERYTHING I'VE SAID BEFORE. THIS
22 (INDICATING) PUTS IT IN A TABLE FORM, AND THEN THIS IS THE
23 LIST OF CONTAMINANTS I'VE SHOWN YOU BEFORE AT THE VERY
24 BEGINNING, THE CONTAMINANTS WE FOUND AT THE SITE THAT WERE
25 IDENTIFIED AS CONTAMINANTS OF CONCERN EITHER DUE TO THEIR
14
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1 CONCENTRATION OR THEIR TOXICITY. THAT'S TWO REASONS WHY
2 THEY'RE DEEMED CONTAMINANTS OF CONCERN. EVERYTHING, I THINK,
3 IS SELF EXPLANATORY; THE FIRST COLUMN REPRESENTS THE HIGHEST
4 LEVEL OF CONTAMINANTS DETECTED, AND THEN THE THIRD COLUMN--OR
5 SECOND COLUMN IS NUMBER OF DETECTIONS. WE TOOK 36
6 GROUNDWATER SAMPLES OUT AT THE SITE, AND THAT TELLS US HOW
7 MANY TIMES WE FOUND THE CONTAMINANTS. FEDERAL MCL IS THE
8 FEDERAL DRINKING WATER STANDARD; SO IT IF EXCEEDS THIS
9 NUMBER, THEN IT EXCEEDS THE FEDERAL DRINKING WATER STANDARD
10 AND BECOMES A CONTAMINANT OF CONCERN AUTOMATICALLY. THIS
11 LAST COLUMN IS THE STATE GROUNDWATER STANDARDS, WHICH ARE
12 TYPICALLY MORE STRINGENT; AND W,E ARE REQUIRED TO SELECT THE
13 MOST STRINGENT CLEANUP STANDARD. SO WHAT I'VE TRIED TO DO IN
14 THIS TABLE IS WHERE IT'S SHADED IN, IT IDENTIFIES--THAT WOULD
15 BE THE NUMBER THAT WOULD BE INCLUDED IN THE RECORD OF
16 DECISION AS THE CONCENTRATION THAT NEEDS TO BE MET IN THE
17 GROUNDWATER. AND WHERE THE NUMBERS ARE LOWEST IS THE NUMBERS
18 THAT ARE OF COURSE SELECTED. SO WHERE FEDERAL DRINKING WATER
19 STANDARDS FOR CHLOROFORM IS 100 PARTS PER BILLION, THE STATE
20 STANDARD IS .19; SO THAT'S WHY THAT NUMBER WILL BE SELECTED,
21 BECAUSE IT'S A SMALLER NUMBER, AND IT'S MORE STRINGENT AND
22 THEREFORE, MORE PROTECTIVE. YOU'VE SEEN THE INFORMATION AND
23 THAT'S BASICALLY THE MEAT OF THE REAL INVESTIGATION. THE
24 USES OF--THAT INFORMATION AGAIN, WE'VE IDENTIFIED WHAT
25 CONTAMINANTS ARE OUT AT THE SITE, WHAT CONCENTRATIONS OF
15
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1 THOSE CONTAMINANTS AND WHERE THOSE CONTAMINANTS HAVE GONE.
2 WE USE THAT INFORMATION INTO WHAT WE CALL A BASELINE RISK
3 ASSESSMENT. IN ORDER FOR THERE TO BE A RISK OR FOR A
4 CHEMICAL TO POSE A RISK, FIRST YOU HAVE TO HAVE A COMPLETE
5 PATHWAY FROM THE SOURCE TO THE RECEPTOR. IF YOU DON'T HAVE A
6 COMPLETE PATHWAY, THERE CAN'T BE A RISK. SO THAT'S THE FIRST
7 THING THAT WE DO IN BASELINE RISK ASSESSMENT, IS TO IDENTIFY
8 ALL THOSE COMPLETE PATHWAYS. THEN WE USE BASICALLY TWO
9 TERMS, WHETHER OR NOT THE CONTAMINANTS ARE CARCINOGEN OR
10 NONCARCINOGEN. FOR SUPERFUND, WHEN WE DO OUR CALCULATIONS,
11 IF THE RISK IS GREATER THAN 1 OUT OF 10,000, THEN IT BECOMES
12 AN UNACCEPTABLE RISK. WHEN IT)S NONCARCINOGEN, WE USE THE
13 TERM HAZARD INDEX; AND IF IT'S GREATER THAN 1, IT'S
14 IDENTIFIED AS AN UNACCEPTABLE RISK; AND THAT'S BASICALLY WHAT
15 RISK ASSESSMENT DOES. WHEN WE DO THOSE MAGIC--WITH OUR MAGIC
16 CALCULATIONS WE USE BODY WEIGHT, YEARS OF EXPOSURE, AND
17 LEVELS OF EXPOSURE TO DETERMINE THE RISK. WHAT THE FLANDERS
18 FILTERS SITE TRIED TO SUMMARIZE WITH THE RISK ASSESSMENT
19 TELLS US IN THE TOP ROW THE CARCINOGENIC RISK AND THE BOTTOM
20 ROW TALKS ABOUT THE NONCARCINOGENIC RISK. THESE ARE ALL THE
21 SCENARIOS THAT WE LOOKED AT THAT AGAIN DEEM COMPLETE PATHWAYS
22 WHERE THERE IS A SOURCE AND A RECEPTOR WHO COULD BE EXPOSED
23 TO THAT SOURCE. WE LOOKED AT THE ON-SITE WORKER, A SITE
24 REPASTS AS EPA SUPERFUND TAKES A VERY CONSERVATIVE APPROACH
25 IN THIS PROCESS, SO WE ALSO LOOKED AT WHETHER OR NOT WE HAD A
16
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1 CHILD RESIDENT AND ADULT RESIDENT ACTUALLY LIVING ON THAT
2 PROPERTY TODAY, WHAT WOULD BE THE RISK. BECAUSE WE DON'T
3 KNOW WHAT THE FUTURE IS FOR THAT SITE, WE ALSO LOOKED AT
4 THOSE TWO SCENARIOS, THE ADULT AND THE CHILD RESIDENT FOR THE
5 FUTURE. IF FLANDERS FILTERS GOES OUT OF BUSINESS TOMORROW
6 AND A SUBDIVISION GETS BUILT THERE, WE HAVE TO TAKE THAT INTO
7 CONSIDERATION.
8 DAN EDWARDS: DAN EDWARDS AGAIN; IN THE
9 MAILING--THERE'S A NEW FORM. THIS SEEMS TO VARY FROM WHAT
10 YOU'VE PRESENTED THERE. IS THIS UPDATED?
11 JON BORNHOLM: I JUST WANT TO GO THROUGH THOSE
12 CORRECTIONS; I HAD SOME MISTAKES THERE. FOR THE BASIC--THE
13 ONLY RISKS POSED BY THE SITE WOULD BE FOR RESIDENTS, EITHER
14 CURRENT OR FUTURE RESIDENTS. SUPERFUND IS GOVERNED BY RISK;
15 IF THERE IS NO RISK IDENTIFIED, NO CLEANUP IS NECESSARY.
16 BECAUSE WE HAVE POTENTIAL RISK, THAT CAN TRIGGER THE NEED FOR
17 A CLEANUP AND THAT'S THE CASE HERE. FOR AN ON-SITE WORKER
18 THERE IS NO RISK FOR--UNACCEPTABLE RISK; FOR TRESPASSERS, THE
19 SAME THING AND THEN FOR THE RESIDENTS THE ONLY RISK WOULD BE
20 USING THE GROUNDWATER; THAT'S THE ONLY SOURCE OUT THERE THAT
21 WOULD CREATE A NON-ACCEPTABLE RISK--OR UNACCEPTABLE RISK--GET
22 RID OF THOSE DOUBLE NEGATIVES. MY FIRST TIME I PUT THAT
23 TOGETHER I SAID "WITHIN ACCEPTABLE RISK" AND IT'S ACTUALLY
24 OUTSIDE THE ACCEPTABLE RISK. ARE THERE ANY QUESTIONS ON THIS
25 TABLE?
17
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1 BARNEY KANE: WHEN YOU SAY "OUTSIDE" YOU MEAN
2 UNACCEPTABLE?
3 JON BORNHOLM: YES, UNACCEPTABLE.
4 BARNEY KANE: SOMETIMES YOU SAY OUTSIDE AND
5 SOMETIMES YOU SAY UNACCEPTABLE. IS THERE A DIFFERENCE
6 BETWEEN WHEN YOU SAY "OUTSIDE ACCEPTABLE" AND "UNACCEPTABLE"?
7 FOR EXAMPLE, CHILD RESIDENT, YOU HAVE "OUTSIDE ACCEPTABLE" IN
8 ONE PLACE AND "UNACCEPTABLE" IN OTHERS; DO YOU MEAN
9 UNACCEPTABLE?
10 JON BORNHOLM: I'M SORRY, THAT'S TERMINOLOGY--IN
11 SUPERFUND WE USE 1 TO THE 10TH OF THE 4TH, TO 1 TO THE 10TH
12 OF THE MINUS 6 AS THE ACCEPTABLE RANGE; IF IT FALLS WITHIN
13 THAT RANGE 1 OUT OF 10,000 TO 1 OUT OF A MILLION, IT'S
14 ACCEPTABLE; BUT IF YOU'RE OUTSIDE THAT RANGE, IT'S DEEMED NOT
15 ACCEPTABLE.
16 BARNEY KANE: SO "OUTSIDE ACCEPTABLE" MEANS
17 UNACCEPTABLE?
18 JON BORNHOLM: YES.
19 BARNEY KANE: WHY DON'T YOU SAY UNACCEPTABLE;
20 WHY DO YOU USE OUTSIDE ACCEPTABLE WHEN YOU MEAN UNACCEPTABLE?
21 JON BORNHOLM: THAT'S JUST MY TERMINOLOGY. NOW
22 THAT YOU MENTION IT, IT IS CONFUSING. I APOLOGIZE. GOOD
23 POINT, WE'LL CORRECT THAT. SO BASICALLY WHAT THIS TABLE
24 TELLS US IS WE NEED TO MOVE--WHEN WE GO INTO THE FEASIBILITY
25 STUDY, WE HAVE TO GO BEYOND A NO ACTION ALTERNATIVE.
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1 BASICALLY ALL THE FEASIBILITY STUDY IS IS A PROCESS OP
2 ELIMINATION. WE START WITH A LARGE COOKBOOK OR LIST OF
3 TECHNOLOGIES OR TYPES OF REMEDIES, AND THROUGH A PROCESS OF
4 EVALUATION WE KEEP ON NARROWING THAT LIST DOWN TO A
5 MANAGEABLE NUMBER THAT WE CAN DO A DETAILED ANALYSIS ON.
6 BASICALLY THE PARAMETERS THAT WE USE TO START NARROWING THAT
7 LIST DOWN IS IMPLEMENTABILITY, EFFECTIVENESS OF THE REMEDY OR
8 THAT TECHNOLOGY AND THE COST. THE FIRST STEP WORKS ON
9 SCREENING TECHNOLOGIES. IF A CERTAIN TECHNOLOGY ONLY WORKS
10 ON METALS IN GROUNDWATER, THEN IT WON'T HELP US IF WE HAVE
11 VOLATILES; AND THAT'S THE IDEA. AS FAR AS THAT GOES, THOSE
12 TECHNOLOGIES THAT AREN'T APPLICABLE TO THE PROBLEM AT THE
i
13 SITE. THEN ONCE WE HAVE THAT LIST OF TECHNOLOGIES DOWN TO A
14 MANAGEABLE NUMBER, WE START TO COMBINE THEM, IF WE NEED TO,
15 INTO WHAT WE CALL REMEDIES--TREATMENT, A TRAIN OF TREATMENT,
16 A TREATMENT TRAIN. A TREATMENT OF TECHNOLOGIES TO ADDRESS
17 THE CONTAMINANTS AT THE SITE. AND THEN WE NARROW THAT LIST
18 DOWN USING THE SAME PARAMETERS AS BEFORE, IMPLEMENTABILITY,
19 EFFECTIVENESS, AND COST. AT THE FLANDERS FILTERS SITE WE
20 WENT THROUGH THAT PROCESS AND WE ENDED UP WITH BASICALLY FOUR
21 ALTERNATIVES, WHICH I'LL GET TO RIGHT AFTER THIS SLIDE. WE
22 HAD FOUR ALTERNATIVES AND IT'S THOSE FOUR ALTERNATIVES THAT
23 WE DID A DETAILED ANALYSIS ON USING THESE PARAMETERS. THE
24 FIRST TWO, THE REMEDY HAS TO ACCOMPLISH THE THRESHOLD
25 CRITERIA. IT HAS TO BE PROTECTIVE, AND IT HAS TO COMPLY WITH
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1 WHAT WE CALL APPLICABLE AND RELATIVE AND APPROPRIATE
2 REQUIREMENTS, BASICALLY STATE GROUNDWATER STANDARDS, DRINKING
3 WATER STANDARDS, SURFACE WATER CLEANUP NUMBERS. IF WE
4 DEVELOP CLEANUP GOALS UNDER OUR RISK PROCESS, WE HAVE TO MEET
5 THOSE. SECOND GROUP OF PARAMETERS USED ARE CALLED THE
6 EVALUATING CRITERIA; WE KIND OF RANK THEM USING THESE
7 PARAMETERS. AND THEN THE LAST TWO--AND THIS IS ONE OF THE
8 REASONS WHY WE'RE HERE TONIGHT, IS TO GAIN COMMUNITY
9 ACCEPTANCE ON THE IDENTIFIED, OR THE PREFERRED ALTERNATIVE,
10 AS WELL AS THE STATE'S; WE NEED THE STATE'S ACCEPTANCE TOO.
11 THIS LISTS THE FOUR ALTERNATIVES THAT WE DID A DETAILED
12 ANALYSIS ON. AGAIN, WE ARE REQUIRED TO KEEP THE NO ACTION
13 ALTERNATIVES THROUGHOUT THE PROCESS, JUST SO THAT WE HAVE A
14 BASELINE. THE SECOND ALTERNATIVE, THE NEW ALTERNATIVE WAS
15 CALLED MONITORED NATURAL ATTENUATION WITH INSTITUTIONAL
16 CONTROLS; ABANDON THE INACTIVE SUPPLY WELLS AND THEN REMOVE
17 THE STORAGE TANKS, THE ABOVE GROUND STORAGE TANKS IN AREA
18 NUMBER 5. THE THIRD ALTERNATIVE IS TO PUMP THE CONTAMINATED
19 GROUNDWATER OUT OF THAT ONE PARTICULAR AREA, TREAT IT TO THE
20 LEVELS NECESSARY TO BE ABLE TO DISCHARGE IT INTO MITCHELL
21 BRANCH UNDER AN NPDS DISCHARGE PERMIT, WHICH STANDS FOR
22 NATURAL POLLUTION DISCHARGE ELIMINATION SYSTEM. THEN TO DO
23 MONITORING TO MAKE SURE THAT WE'RE PUMPING THE RIGHT AMOUNT
24 OF GROUNDWATER. INSTITUTIONAL CONTROLS, ABANDON INACTIVE
25 SUPPLY WELLS AND REMOVE THE TANKS. THE THEN FOURTH
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1 ALTERNATIVE IS BASICALLY AN INSITU PROCESS WHERE WE WOULD PUT
2 WELLS IN THE AREA OF CONTAMINATION, PUMP AIR INTO THE SHALLOW
3 AQUIFER AND THEN WE'D ALSO HAVE SOME OTHER WELLS THAT WE
4 WOULD TRY TO SUCK THAT AIR OUT. THAT AIR WOULD BE DISCHARGED
5 INTO THE ATMOSPHERE AND THEN MONITORED, HAVE INSTITUTION
6 CONTROLS, ABANDON THOSE INACTIVE SUPPLY WELLS AND AGAIN
7 REMOVE THE STORAGE TANKS. BASICALLY THIS IS THE ESTIMATED
8 COST FOR EACH OF THOSE ALTERNATIVES. WHAT THE AEC IS
9 IDENTIFYING AS ITS PREFERRED ALTERNATIVE--AND AGAIN, IT'S THE
10 PREFERRED ALTERNATIVE; IT HAS NOT BEEN SELECTED BECAUSE WE
11 CANNOT SELECT THE ALTERNATIVE UNTIL AFTER THE PUBLIC COMMENT
12 PERIOD; WE ARE PROPOSING ALTERNATIVE NUMBER 2 AS THE
13 AGENCY'S PREFERRED ALTERNATIVE. IN THE EVENT THAT EITHER
14 NATURAL ATTENUATION STOPS OR THE CONTAMINANTS CONTINUE TO
15 MIGRATE BEYOND WHERE WE HAVE IDENTIFIED THEM NOW, OR FOR
16 WHATEVER REASON, WE ARE INCLUDING A CONTINGENT REMEDY IN THE
17 ROD, IN YOUR RECORD OF DECISION, IN THE EVENT THAT THE
18 PREFERRED ALTERNATIVE DOESN'T WORK BASICALLY. THAT'S GOING
19 TO BE OUR FALL-BACK POSITION. NOW JUST QUICKLY--NOT QUICKLY
20 BUT--NATURAL ATTENUATION IS A VERY NEBULOUS TERM WE SAY, AND
21 I TRIED TO DEFINE IT, DESCRIBE WHAT THE ACTION MEANS.
22 BASICALLY IT'S A NUMBER OF PROCESSES WHICH INCLUDE BY
23 REGULATION BACTERIA FUNGUS FEEDING ON THE CONTAMINANTS IN THE
24 GROUND OR IN THE GROUNDWATER, DISPERGENT DILUTION,
25 ABSORPTION; AS THE CONTAMINANTS MOVE TO THE GROUND, THEY
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1 ADHERE TO THE SOIL PARTICLES AND THEREFORE ARE TAKEN OUT OF--
2 BASICALLY OUT OF CIRCULATION, OUT OF THE ENVIRONMENT IN A
3 SENSE. VOLATILIZATION, IN THAT MOST OF THE CONTAMINANTS OUT
4 AT THE SITE ARE VOLATILES AND THEY ARE VOLATILIZING. THE
5 CONTAMINANTS AS THEY ARE MOVING DOWN MITCHELL BRANCH ARE
6 VOLATILIZING OUT OF THE SURFACE WATER. THEN ALSO IN THE
7 ENVIRONMENT THERE IS ALSO BIOLOGICAL CHEMICAL CHANGES THAT
8 JUST THE ENVIRONMENT DOES TO THE CONTAMINANTS AND EITHER
9 TRANSFORMS CONTAMINANTS INTO A LESS TOXIC, OR SOMETIMES A
10 MORE TOXIC COMPOUND OR EITHER DESTROYS THE CONTAMINANTS.
11 BASICALLY THAT ATTENUATION IS A WHOLE GAMUT OF ACTIVITIES,
12 BUT THEY'RE ALL NATURAL BASICALLY, NATURALLY INCURRED. THE
13 LAST--I THINK IT'S THE LAST TWO PAGES--UNFORTUNATELY I
14 COULDN'T SQUEEZE IT DOWN INTO ONE PAGE--THIS IS BASICALLY THE
15 RATIONALE AS TO WHY THE AGENCY IS SELECTING THIS ALTERNATIVE.
16 THE KEY TERM IS MONITOR; IT'S GOING TO BE LOOKED AT FROM THE
17 SIGNING OF THE RECORD OF DECISION UNTIL THOSE CLEANUP GOALS
18 ARE ACHIEVED. ONE OF THE FIRST THINGS THAT FLANDERS FILTERS
19 WILL BE REQUIRED TO DO IS BASICALLY TO CONFIRM THAT NATURAL
20 ATTENUATION IS OCCURRING AS THEY ANTICIPATED, AS THEY HAD
21 PREDICTED. THAT WILL BE DONE BASICALLY WITH A LONG TERM
22 MONITORING PLAN. AGAIN, AS I MENTIONED BEFORE, THEY DID A
23 VERY ELEMENTARY MODELING; THEY'RE GOING TO BE REQUIRED AS
24 PART OF THE REMEDIAL DESIGN TO DO A MORE SOPHISTICATED MODEL
25 WHICH THIS DATA WILL BE USED TO FEED INTO SO THEY WILL HAVE A
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1 LARGER DATABASE TO MODEL FROM. BECAUSE CONTAMINANTS WILL
2 REMAIN ON SITE, THEY WILL BE REQUIRED TO DO A FIVE YEAR
3 REVIEW UNTIL THOSE CONTAMINANTS DO MEET--UNTIL THEY DO
4 ACHIEVE CLEANUP GOALS. THEY WILL BE REQUIRED TO CONTINUE TO
5 DO A FIVE YEAR REVIEW WHICH IS REQUIRED BY SUPERFUND.
6 INSTITUTIONAL CONTROLS UNDER--THE STATE NOW HAS SOME
7 REGULATIONS WHERE WE CAN RESTRICT LAND USE, SO WE WILL
8 REQUIRE FLANDERS FILTERS TO--BRUCE MIGHT BE ABLE TO ADD
9 INFORMATION TO THIS AS TO HOW THEY DO IT--BUT THEY WILL BE
10 PREVENTED FROM PUTTING POTABLE WELLS ON THE PROPERTY.
11 BASICALLY, THIS IS THE INITIAL EMPHASIS BEHIND THIS EFFORT.
12 FOR DEED RECORDATION, AGAIN JUST TO INFORM ANY POTENTIAL
13 FUTURE BUYER OF THE PROPERTY, FLANDERS FILTERS WILL BE
14 REQUIRED TO PUT ON THEIR DEED THAT THERE IS CONTAMINATION OUT
15 THERE; AND THAT REQUIREMENT, THAT NOTICE WILL REMAIN THERE
16 UNTIL AGAIN, THE CLEANUP LEVELS ARE ACHIEVED. JUST TO
17 PREVENT ANY FURTHER ADDITIONAL CONTAMINATION FROM MIGRATING
18 FROM THE SHALLOW AQUIFER DOWN TO THE DEEPER AQUIFER IN THIS
19 PARTICULAR AREA WHERE THERE ARE INACTIVE SUPPLY WELLS, THEY
20 ARE GOING TO ABANDON THOSE WELLS, UNDER THE STATE REGULATION
21 FOR ABANDONMENT OF WELLS. THAT'S BASICALLY PULL OUT THE
22 CASING AND GROUT THE HOLE SO NO GROUNDWATER CAN LEAK DOWN IN
23 THE HOLE. THEN BASICALLY JUST AS HOUSEKEEPING ISSUES,
24 FLANDERS HAS INDICATED THEY WERE PLANNING ON MOVING THOSE
25 ABOVE GROUND STORAGE TANKS, SO I'M JUST INCLUDING THAT INTO
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1 THE RECORD OP DECISION. WITH THAT, THAT'S MY PRESENTATION
2 AND I'M MORE THAN HAPPY TO ANSWER ANY QUESTIONS I CAN.
3 FIRST, I WANT TO REMIND YOU TO STATE YOUR NAME SO WE CAN GET
4 THAT FOR THE RECORD. SIR?
5 BRYAN HARRIS: YES, MY NAME IS BRYAN HARRIS. I LIVE
6 ON MITCHELL BRANCH, JUST ABOUT 100 YARDS FROM MITCHELL
7 BRANCH. I THINK YOU'VE DONE A GOOD JOB SHOWING US THAT THE
8 FLANDERS FILTERS SITE IS GOING TO BE TAKING CARE OF IT. I
9 WONDER IF YOU'VE DONE ADEQUATE SITE SUPPORT FOR MITCHELL
10 BRANCH, BECAUSE EVERYTHING IS DOWN RADIANT FROM FLANDERS
11 FILTERS INTO MITCHELL BRANCH; AND I'M SIMPLY POINTING OUT
12 THAT BOTH TRANTERS CREEK AND MITCHELL BRANCH ARE TIDAL AREAS;
13 THEY CHANGE IN BOTH DIRECTIONS AT LEAST TWICE A DAY AND
14 OBVIOUSLY VARIATION AND DEPTH OF THOSE TO A DEGREE. ALSO,
15 PERIODICALLY DURING THE YEAR THERE IS THERMAL CLIMATE
16 DIVERSION WITH THE TEMPERATURE CHANGE AND VARIOUS SURFACE--
17 MATERIAL TO THE TOP OF THE CREEK. THIS COMES WITH CHANGES IN
18 THE DEPTH, WHICH IN FACT WASHES SOME OF THE SEDIMENT TO BOTH
19 SIDES OF THE CREEK UP INTO THE SWAMP AREAS ON BOTH SIDES.
20 I'M CONCERNED BECAUSE MITCHELL BRANCH RUNS THROUGH MY
21 BACKYARD, AND WE USE THE CREEK FOR RECREATIONAL PURPOSES. I
22 THINK THE STUDY IS INTERESTING; I'M NOT CONVINCED THAT--YOU
23 HAVE NOT SHOWN THAT YOU HAVE ADEQUATELY INVESTIGATED THE
24 PROBLEM WITH MITCHELL BRANCH, BECAUSE IT'S CLEAR TO ME THAT
25 REMEDIATION OF FLANDERS FILTERS, IT STILL WOULD REMAIN IN
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1 MITCHELL BRANCH A PROBLEM FOR THOSE OF US WHO LIVE THERE NOW
2 AND WILL BE LIVING THERE IN THE FUTURE; I WONDER IF YOU WOULD
3 ADDRESS THAT FOR US?
4 JON BORNHOLM: BASICALLY THE RISK ASSESSMENT--
5 AGAIN, LOOKING AT THE LEVELS OF CONTAMINANTS IN MITCHELL
6 BRANCH AND LOOKING AT THE LEVELS OF CONTAMINANTS THAT WERE
7 THERE DID NOT IDENTIFY IT AS A RISK, AN UNACCEPTABLE SOURCE
8 OR UNACCEPTABLE RISK TO THE PUBLIC. IN THAT SENSE--MAYBE
9 YOUR QUESTION CENTERS TO, DO WE HAVE ENOUGH DATA TO EVALUATE
10 THAT. THAT QUESTION IS ASKED QUITE A BIT AT LOTS OF THESE
11 MEETINGS. THERE IS A LIMITED SOURCE OF MONEY AND TIME TO DO
12 THESE TYPES OF STUDIES; NOT THAT ADDRESSES YOUR QUESTION, BUT
I
13 WE DO THE BEST JOB THAT WE CAN. AND YOU KNOW IT'S A WINDOW,
14 JUST ONE SNAP OF A PICTURE--A TIME FRAME. IF WE CAN ADDRESS
15 THAT WITH ADDITIONAL SAMPLING OF THE CREEK, WE MAY ABLE TO DO
16 THAT.
17 BRYAN HARRIS: BRYAN HARRIS ONCE AGAIN. YOU DO
18 HAVE A TEST WELL ON MY PROPERTY, AND I WAS VERY HAPPY TO
19 PERMIT THE EPA THE OPPORTUNITY TO PUT THAT TEST WELL. THIS
20 IS ONE OF THE TWO TEST WELLS EAST OF MITCHELL BRANCH--EITHER
21 FLANDERS FILTERS THOUGHT IT WAS NECESSARY OR THE EPA. SO I
22 STILL MAKE THAT OFFER, BUT I STILL AM CONCERNED ABOUT WHAT
23 WILL HAPPEN TO THOSE TWO, TEST OF THOSE. ARE YOU CONFIDENT
24 THE TWO TEST WELLS IS ENOUGH. AND I NOTICE WITH THE TIDAL
25 FLOW, YOU HAVE NO TEST WELLS ABOVE THE FLANDERS FILTERS SITE.
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1 YOU HAVE ONE DIRECTLY ACROSS FROM ME, DOWN STREAM; BUT AS YOU
2 KNOW, THAT TIDAL RANGE HAS A LOT OF MOVEMENT AND IS QUITE
3 SENSITIVE AND AS THE WATER AND ITS CONTENTS SLOSH BACK AND
4 FORTH, TWICE A DAY; SO IF THERE IS MOVEMENT THERE, THAT'S NOT
5 SIMPLY DIRECT DOWN RADIANT OF MOTION; THERE'S A MOVEMENT BACK
6 AND FORTH THAT WASHES THAT MATERIAL.
7 JON BORNHOLM: ARE YOU TALKING ABOUT THE
8 GROUNDWATER OR THE SURFACE WATER?
9 BRYAN HARRIS: I'M TALKING ABOUT THE SURFACE
10 WATER.
11 JON BORNHOLM: UP SURFACE OR UP RADIANT SAMPLES
12 DID NOT PICK UP ANY OF THE VOLATILE ORGANICS THAT--DIDN'T
13 PICK UP ANY VOLATILE ORGANICS. THERE WERE TWO TAKEN ABOVE;
14 ONE RIGHT AFTER THE TRAIN TRESTLE AND THEN ONE FURTHER ABOVE
15 THE TRAIN TRESTLE WHICH DIDN'T SHOW ANY.
16 BRYAN HARRIS: THESE WERE BOTH ON MITCHELL
17 BRANCH.
18 JON BORNHOLM: WHERE ON MITCHELL BRANCH?
19 BRYAN HARRIS: THAT'S GOOD NEWS. HOW ABOUT DOWN
20 STREAM IN TRANTERS CREEK; WHAT'S THE INFLUENCE AT TRANTERS
21 CREEK.
22 JON BORNHOLM: WE DIDN'T LOOK AT VOLATILES, WE
23 ONLY LOOKED AT METALS, AND WE DID NOT FIND ANY METALS THAT
24 COULD BE TRACED BACK TO FLANDERS FILTERS. THERE'S NATURALLY
25 OCCURRING METALS, BUT YET, THE FIRST THING THAT THE EPA DOES
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1 IS THAT IT HAS TO BE TWICE THE BACKGROUND LEVEL; AND IF IT
2 DOESN'T EXCEED THAT FIRST STEP, WE DON'T EVEN LOOK AT IT. WE
3 DIDN'T FIND ANY METALS TWICE ABOVE BACKGROUND LEVEL.
4 BRYAN HARRIS: AND THOSE TWO TEST WELLS THEY
5 WILL REMAIN PART OF THE MONITORING PROCEDURE?
6 JON BORNHOLM: YES.
7 BRYAN HARRIS: AND THEY WILL BE MAINTAINED AND
8 PAID FOR BY FLANDERS FILTERS?
9 JON BORNHOLM: YES.
10 BRYAN HARRIS: AND WILL REPORTS BE GIVEN TO THE
11 COMMUNITY FROM THOSE?
12 JON BORNHOLM: EVERYTHING THE SUPERFUND DOES.IS
13 PUBLIC INFORMATION. SO WHEN THAT DATA BECOMES AVAILABLE, IT
14 WILL BE SHARED.
15 BRYAN HARRIS: THAT WOULD BE IMPORTANT FOR
16 PEOPLE LIVING EAST OF MITCHELL BRANCH IN THE FUTURE. THANK
17 YOU.
18 DAN EDWARDS: DAN EDWARDS, AGAIN. IN SOME OF
19 YOUR SLIDES YOU MENTIONED THAT THERE WILL BE A CLEANUP GOAL
20 IN NINE YEARS. COULD YOU DEFINE WHAT THOSE CLEANUP GOALS
21 ARE. OBVIOUSLY IT DOESN'T MEAN THE TOTAL ABSENCE OF ANY
22 CONTAMINANTS. WHAT WOULD YOU IDENTIFY THAT--
23 JON BORNHOLM: BASICALLY THE TABLE--
24 SOILS DO NOT CREATE AN UNACCEPTABLE RISK; SURFACE WATER OR
25 SEDIMENTS DO NOT CREATE AN UNACCEPTABLE RISK; THE ONLY THING
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1 THAT IS CAUSING UNACCEPTABLE RISK, AGAIN, IT IS A SCENARIO
2 THAT IS NOT HAPPENING RIGHT NOW, WHICH IS RESIDENTS LIVING
3 ON-SITE, WHICH IS NOT THE CASE, OR RESIDENTS LIVING ON THE
4 SITE IN THE FUTURE. BECAUSE OF THOSE RISKS, BECAUSE OF THOSE
5 TWO THINGS, THOSE TWO RISKS, WE'VE LISTED THESE CONTAMINANT
6 SOURCES AS THE CONTAMINANTS ARE CONCERNED; AND THESE SHADED
7 BOXES WILL BE THE CLEANUP GOALS FOR THOSE CONTAMINANTS. AND
8 UNTIL THESE LEVELS ARE REACHED, THE SITE WON'T BE DEEMED
9 CLEAN.
10 DAN EDWARDS: AND THAT'S PREDICTED TO HAPPEN IN
11 NINE YEARS?
12 JON BORNHOLM: YES; ON MODELING THAT HAS BEEN
13 DONE.
14 DAN EDWARDS: THESE ARE--FEDERAL MCL'S--
15 SECONDARY MCL IS THE STATE?
16 JON BORNHOLM: SECONDARY MCL IS FOR AESTHETIC
17 PURPOSES OUT OF PER SE HEALTH.
18 DAN EDWARDS: AND THE THIRD COLUMN IS STATE?
19 JON BORNHOLM: THE THIRD COLUMN IS STATE
20 GROUNDWATER STANDARDS.
21 DAN EDWARDS: ONE OTHER QUESTION. ALL OF YOUR
22 SAMPLING SEEMS TO MAKE A RECORD OF HOW THINGS ARE NOW?
23 JON BORNHOLM: YES.
24 DAN EDWARDS: AND THE THIRD ALTERNATIVE IS THAT
25 ATTENUATION IS GOING TO OCCUR. IS THERE--HOW DO WE KNOW
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1 THERE'S NOT GOING TO BE MOVEMENT OF THIS POLLUTANT?
2 JON BORNHOLM: THERE COULD BE AND THAT'S WHY
3 THIS PART OF THE REMEDIAL DESIGN, ALTHOUGH IT WON'T BE FOR AN
4 ACTIVE REMEDIATION PER SE, THEY WILL BE REQUIRED TO DEVELOP A
5 LONG TERM MONITORING PLAN AND IMPLEMENT THAT. BASICALLY, THE
6 FIRST YEAR OUR REGION, FOR GUIDANCE, REQUIRED BIMONTHLY
7 SAMPLING.
8 DAN EDWARDS: BIMONTHLY MEANS EVERY TWO MONTHS?
9 JON BORNHOLM: NO, TWICE A MONTH FOR THE FIRST
10 YEAR; AND BASED ON THAT INFORMATION IT COULD STAY THE SAME OR
11 BE REDUCED. AGAIN, UNTIL CLEANUP LEVELS ARE ACQUIRED, THEY
12 WILL BE REQUIRED TO DO A FIVE YEAR REVIEW, WHICH REQUIRES
13 SAMPLING SO THAT THEY KNOW WHAT'S GOING ON. THEY CAN SHOW
14 THAT THE PUBLIC IS STILL BEING—THE WHOLE PURPOSE BEHIND FIVE
15 YEAR REVIEW IS TO SHOW THE PUBLIC THAT THEY'LL BE PROTECTED
16 BY THE DEED, THE DEED THAT WAS IMPLEMENTED. THAT'S THE WHOLE
17 PURPOSE OF THAT REVIEW.
18 BARNEY KANE: IN ONE OF YOUR--THE MAPS YOU HAD
19 SOME--I GUESS IT WAS SOIL--YOU HAD A REFERENCE "HA" TO THE
20 LEADING SITES; WHAT DOES THE "HA" STAND FOR; I GUESS THAT'S
21 NOTING SURFACE WATER AND "SD" I DETERMINE TO MEAN SEDIMENT,
22 BUT WHAT DOES "HA" STAND FOR?
23 JON BORNHOLM: HAND ARK.
24 BARNEY KANE: ONE THING I THOUGHT ABOUT,
25 CONTAMINATION IN THE SURFACIAL AQUIFER OR IN THE SURFACE
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1 SOIL, WOULD THAT BE ABOUT 6 INCHES OR MAYBE DOWN DEEPER?
2 JON BORNHOLM: WE TYPICALLY, AT LEAST AT THIS
3 SITE, SURFACE SOILS AT ANY SUPERFUND SITE, SURFACIAL SOILS IS
4 FROM 0 TO 12 INCHES.
5 BARNEY KANE: IS THAT WHAT THE "HA" IS FOR?
6 JON BORNHOLM: NO, THAT'S THE LOCATION OF--WELL,
7 TYPICALLY HOW WE DO OUR BORING, WE TAKE OUR SAMPLES, WE TAKE
8 THE FIRST 12 INCHES; WE CONSIDER THAT A SURFACE SOIL SAMPLE,
9 AND WE CONTINUE THE BORING, SAME HOLE AND COLLECT DEEPER
10 SAMPLES. AT FLANDERS FILTERS, WHERE WE WERE RUNNING INTO
11 GROUNDWATER AT THREE FEET. SO BASICALLY, MOST OF THE SAMPLES
12 WERE DEEMED SURFACIAL SAMPLES, /SURFACE SOIL SAMPLES, BECAUSE
13 GROUNDWATER IS SO SHALLOW WE WERE RUNNING INTO IT. AND
14 BASICALLY THE AGENCY'S APPROACH IS ONCE YOU HIT THE
15 GROUNDWATER, IT'S NO LONGER SOIL; IT'S GROUNDWATER. SO IF
16 YOU FIND CONTAMINANTS THERE, IT'S CONSIDERED A GROUNDWATER
17 CONTAMINANT AND NOT A SOIL CONTAMINANT. THAT'S JUST HOW WE
18 INTERPRET THOSE.
19 BARNEY KANE: IF THE ACETONE OR KETONE WAS IN
20 THAT TOP THREE FEET OF SOIL IN THE "HA" SITES THAT WERE ALONG
21 MITCHELL BRANCH, I'M WONDERING IF YOU GUYS HAVE A PROPOSED
22 MECHANISM BY WHICH YOU--IT GOT THERE. THAT SURELY DIDN'T
23 MIGRATE UP FROM THE GROUNDWATER UNDERNEATH IT, WHICH IS
24 CLEANER THAN THAT.
25 JON BORNHOLM: NO, WE'RE ASSUMING THAT THE
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1 SOURCE IS GROUNDWATER, AS GROUNDWATER IS MOVING IN--MITCHELL
2 BRANCH IS THE GROUNDWATER BODY FOR THAT AREA. SO GROUNDWATER
3 IS FLOWING UNDERNEATH FLANDERS FILTERS AND IS DISCHARGING
4 INTO MITCHELL BRANCH; SO AS IT IS COMING UP TOWARDS THE CREEK
5 SO ARE THE CONTAMINANTS. THIS IS NOT A SCIENCE; I'LL BE THE
6 FIRST ONE TO ADMIT THAT. SO WE MAY HAVE DETECTION HERE; WE
7 MIGHT PARTICIPATE IN DETECTION RIGHT DOWN STREAM OF IT; YOU
8 WON'T SEE IT, BUT FURTHER DOWNSTREAM YOU MAY SEE THE
9 CONTAMINANTS.
10 BARNEY KANE: MY PROBLEM IS THAT IF YOU CONTINUE
11 THE MONITORING WELLS IN--AT THAT VICINITY WHEN THERE IS NO
12 METHELELTHYL KETONE OR ACETONE /IN THE GROUNDWATER THAT YOU
13 SAY IS A SOURCE OF IT'S SORT OF--SO I'M THINKING THAT THE
14 SPRAY IRRIGATION RAN OVERLAND AND SOAKED IN THE SOIL. AND I'M
15 WONDERING IF YOU'RE GOING TO MAKE A MODEL TO SHOW US HOW IT'S
16 GOING TO ALLEVIATE IN NINE YEARS. SOMEHOW IT WILL BE
17 INTERESTING TO SEE WHAT HAPPENS WHEN YOU'RE SHOWING A VERY
18 HIGH CONCENTRATION OF ACETONE IN SOIL ABOVE THE GROUNDWATER,
19 WHICH YOU THINK IT'S COMING FROM, AND THAT TECHNICALLY CAN'T
20 BE--I'M THINKING THAT IF WE HAD A MODEL FOR GROUNDWATER AND
21 ITS MOVEMENT IN MITCHELL CREEK, BUT YOU DIDN'T HAVE A MODEL
22 FOR THE SURFACIAL--
23 JON BORNHOLM: ANOTHER THING, AND I WON'T SAY
24 THIS IS WHAT HAS OCCURRED--THAT YOU HAD A SLUDGE WITH THE
25 CONTAMINANTS MOVE WITH GROUNDWATER AND AT THAT POINT NOW
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1 WE'VE SAMPLED.
2 BARNEY KANE: 70 SAMPLES DOESN'T MAKE--I DON'T
3 THINK YOU CAN--BUT JUST THAT IP YOU HAD ACETONE IN THE SOIL
4 ABOVE GROUNDWATER, AND GROUNDWATER WOULD PROBABLY BE THE
5 SOURCE OF THAT ACETONE.
6 BRUCE NICHOLSON: WHEN THOSE ORDERS WERE TAKEN
7 AND YOU'VE GOT GROUNDWATER DISCHARGING FROM BELOW UP INTO THE
8 CREEK. IT'S NOT GOING DOWN THE WELL. FOR WHATEVER REASON
9 THAT'S JUST THE CONTAMINANTS THAT ARE IN THAT LAYER OF SOIL
10 THAT'S IN THE ZONE THAT WOULD BE CONSIDERED TO BE AT RISK TO
11 THE FLOW DOWN THE CREEK, BUT NOT TO THE GROUNDWATER BECAUSE
12 THE GROUNDWATER IS DISCHARGING JNTO THE CREEK AT THAT POINT.
13 JON BORNHOLM: AS PART OF--THE BASELINE
14 ASSESSMENT WAS DONE AND BASICALLY THE EVIDENCE OF CONCLUSION
15 WAS NO ADVERSE--NO VISIBLE OR MEASURABLE ADVERSE IMPACT WAS
16 SEEN IN THE WETLANDS. SO YOU COULD PROBABLY DO MORE HARM
17 TRYING TO ADDRESS THAT--THOSE WETLANDS, RATHER THAN LETTING
18 MOTHER NATURE TAKE CARE OF ITSELF, IS BASICALLY WHAT THE
19 CONCLUSION IS. ANY OTHER QUESTIONS?
20 BARNEY KANE: AT ONE TIME LOOKING AT THAT SITE
21 WAS I RECALL SOMETHING--THAT BECAUSE OF THE ACETONE; WHAT DO
22 THEY THINK THAT IS?
23 JON BORNHOLM: I'M NOT EVEN SURE WHAT AREA
24 YOU'RE REFERRING TO.
25 BARNEY KANE: THE SPRAY FIELD.
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1 JON BORNHOLM: WHEN I WAS AT THE SITE, I DIDN'T
2 SEE THAT.
3 BARNEY KANE: THAT WAS YEARS AND YEARS AGO.
4 DAN EDWARDS: BACK TO THE GOLDEN NINE YEARS, IF
5 THE LEVELS ARE GOING TO DECREASE FROM NOW 'TIL THEN, THAT
6 WOULD APPLY TO SOME KIND OF A CLOCK, SOME KIND OF PREVIOUS
7 MEASUREMENT OR A PRINCIPAL FOR HOW THAT OCCURS. HOW DO YOU
8 KNOW THAT THE LEVELS ARE GOING TO DROP TO THAT LEVEL IN NINE
9 YEARS?
10 JON BORNHOLM: DAVID, DO YOU KNOW WHEN THOSE
11 FIRST SAMPLES WERE TAKEN?
12 DAVID DUNCKLEE: THE SAMPLES WE TOOK--WHAT WAY
13 BACK, YES.
14 JON BORNHOLM: UNFORTUNATELY, I DIDN'T BRING
15 THAT TABLE. ALL OF THOSE ARE IN THAT. ANY OTHER QUESTIONS?
16 JON BORNHOLM: THANK YOU FOR ATTENDING. I
17 APPRECIATE YOUR TIME.
18 BRUCE NICHOLSON: JON, CAN I SAY A WORD OR TWO.
19 I'M BRUCE NICHOLSON WITH THE STATE OF NORTH CAROLINA, AND AS
20 JON HAS SHOWN YOU THERE, A COUPLE OF THE MODIFYING CRITERIA
21 FOR DECISION MAKING ON THIS SITE--COMMUNITY--STATE
22 ACCEPTANCE--OBVIOUSLY WE'LL BE LOOKING AT THE DATA WE'VE HAD
23 ALL ALONG FOR STATE ACCEPTANCE, AND WE'LL BE LOOKING ALSO IF
24 THERE ARE ANY COMMENTS COMING FROM YOU ALL PERTAINING TO THE
25 SITE BEFORE STATE ACCEPTANCE AS WELL; OBVIOUSLY WHAT WE WANT
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1 TO UNDERSTAND IS WHAT THE COMMUNITY THINKS ABOUT THE SITE
2 BEFORE WE ACCEPT THE RECOMMENDATION. SO IF THERE'S ANYBODY
3 WHO WOULD LIKE TO MAKE COMMENTS TO DIRECTLY TO ME, THAT WILL
4 BE FINE TOO.
5 JON BORNHOLM. BRUCE CAME FROM VACATION AT CAPE
6 HATTERAS JUST FOR THIS MEETING. HE TAKES HIS JOB SERIOUS.
7 DIANE BARRETT: ONE THING BEFORE WE FINISH THIS.
8 I WANT TO ENCOURAGE YOU TO GET MORE INFORMATION; ALL THE
9 TECHNICAL DOCUMENTS WILL BE IN THE REPOSITORY TOMORROW. SO
10 IF YOU HAVE SOME CONCERNS ABOUT THINGS, IF YOU CAN REVIEW
11 THAT INFORMATION, ALL OF THAT WILL BE IN THERE AND I
12 ENCOURAGE YOU TO DO THAT. WE DO WANT TO HEAR FROM YOU, SO
13 GET YOUR COMMENTS IN TO US. IF YOU WANT AN EXTENSION ON THE
14 COMMENT PERIOD OF TIME, IF YOU FEEL THAT IT'S NOT ADEQUATE,
15 LET US KNOW AND WE'LL EXTEND IT ANOTHER THIRTY DAYS.
16 BARNEY KANE: ARE THE COSTS, THE WHOLE COSTS
17 BEING BORN BY FLANDERS FILTERS?
18 JON BORNHOLM: THEY HAVE TO DATE AND WE
19 ANTICIPATE THAT THE REST OF THE COSTS WILL BE BORNE BY THEM.
20 DIANE BARRETT: IS THAT IT? THANKS, WE
21 APPRECIATE YOUR COMING AND APPRECIATE YOUR COMMENTS AND
22 QUESTIONS.
23
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1 STATE OF NORTH CAROLINA )
2 ) C-E-R-T-I-F-I-C-A-T-I-O-N
3 COUNTY OF BEAUFORT )
4
5 I, GAYE H. PAUL, A COURT REPORTER AND NOTARY PUBLIC
6 IN AND FOR THE AFORESAID COUNTY AND STATE, DO HEREBY CERTIFY
7 THAT THE FOREGOING PAGES ARE AN ACCURATE TRANSCRIPT OF THE
8 „ PROPOSED. PLAN PUBLIC MEETING. WHICH WAS TAKEN BY ME BY
9 STENOMASK, AND TRANSCRIBED UNDER MY DIRECT PERSONAL
10 SUPERVISION.
11 I FURTHER CERTIFY THAT NEITHER I NOR THE SAID
12 TRANSCRIPTIONIST, IS FINANCIALLY INTERESTED IN THE OUTCOME OF
13 THIS ACTION, A RELATIVE, EMPLOYEE, ATTORNEY OR COUNSEL OF ANY,
14 OF THE PARTIES.
15 WITNESS, MY HAND AND SEAL, THIS DATE: JULY 8, 1998.
16
17 MY COMMISSION EXPIRES JUNE 26, 2000.
18
20 ^'i <^~~ S
21
22 GAYE W. PAUL
23 COURT REPORTER AND NOTARY PUBLIC
24 CAROLINA COURT REPORTERS, INC.
25 105 OAKMONT PROFESSIONAL PLAZA
26 GREENVILLE, NC 27858
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Author: C16cats@aol.com at IN
Date: 9/22/98 2:29 PM
Priority: Normal
BCC: jon bornholm at REGION4
TO: Bornholm.Jon at IN
Subject: Re: 2L Standards
Dear Mr. Bornholm,
Do you have access to Buncombe County's Consent Agreement/Order with the
state of NC? I would like to review this agreement in detail if you can
direct me to a source.
Mr. Bornholm, who specifically must approve the reopening and subsequent
investigation of the Buncombe County Landfill? Since I e-mailed Ms. Gurley and
you responded, I assume you must make the initial assessment and forward
information to Ms. Gurley. Is this a correct assumption?
Cynthia Edmonds
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