Superfund Record of Decision Fcx Inc. Statesville Plant Operable Unit 3 Statesville NC


                                    EPA/ROD/R04-96/276
                                    1996
EPA Superfund
     Record of Decision:
     FCX, INC. (STATESVILLE PLANT)
     EPA ID:  NCD095458527
     OU03
     STATESVILLE, NC
     09/30/1996

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FCX-STATESVILLE
SUPERFUND SITE

RECORD OF DECISION
OPERABLE UNIT THREE


U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA

SEPTEMBER 1996

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DECLARATION
FOR
THE RECORD OF DECISION

SITE NAME AND LOCATION

FCX-Statesville  (Operable Unit Three)
Statesville, Iredell County, North Carolina

STATEMENT OF BASIS AND PURPOSE

This decision document presents the Operable Unit Three Remedial Action for the FCX-Statesville
Superfund Site  (the "Site") in Iredell County, North Carolina, chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 and, to the extent practicable, the
National Contingency Plan.  This decision is based on the administrative record file for this
Site.

The Superfund Section of the North Carolina Department of Environment, Health, and Natural
Resources (NCDEHNR) concurs with the selected remedy for Operable Unit Three.  Comments from the
NCDEHNR on the Record of Decision, as well as EPA's responses to those comments, can be found in
Appendix A of this document.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this Record of Decision, may present an imminent
and substantial endangerment to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The Operable Unit Three Remedial Action addresses the portion of the soils and groundwater
contamination associated with the property currently owned and operated by Burlington
Industries.   Soil and groundwater contamination associated with the FCX property will be
addressed with the Operable Unit One and Two Remedial Actions.  The Remedial Designs for
Operable Units One and Two have been completed, and the Remedial Actions will be implemented as
soon as funding is made available.

The major components of the Operable Unit Three Remedial Action include:

SOIL

Treatment of soil contaminated with volatile organic compounds using the Soil Vapor Extraction
technology in order to reduce and minimize the potential adverse impacts to groundwater on and
around the property currently owned and operated by Burlington Industries.

GROUNDWATER

Treatment of groundwater contaminants of concern, mainly volatile organic compounds, using the
Air Sparging technology, to meet Federal Maximum Contaminant Levels  (MCLs) or the North Carolina
Groundwater Standards, whichever are more protective;

Monitoring of groundwater entering and exiting the treatment system, as well as monitoring of
the groundwater guality on and around the textile facility for evidence that natural attenuation

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is happening, for an estimated 30 years, or until the performance standards have been met; and

The use of institutional controls including deed restrictions in the affected area to prohibit
the consumption of contaminated groundwater associated with the property currently owned and
operated by Burlington Industries, will be determined during the Remedial Design.

ADDITIONAL SAMPLING AND MONITORING

The installation of additional monitoring wells will be reguired during the Remedial Design to
further characterize the nature and extent of groundwater contamination.  Additional aguifer
tests may also be needed in order to properly design the remedy described in this document.

In order to establish a broader database on groundwater guality and to maintain a level of
protection for private well users living downgradient from the Site, samples will be collected
and analyzed prior to implementation of the Remedial Action.

Periodic sampling of the surface water and sediment will be reguired to ensure that the guality
of the groundwater discharging into the seep meets North Carolina surface water standards.

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies with Federal and
State reguirements that are legally applicable or relevant and appropriate to the Remedial
Action, and is cost-effective.

This remedy utilizes permanent solutions and alternative treatment technologies to the maximum
extent practicable, and satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume of site-related contaminants as a principal element.

Since this remedy may result in hazardous substances remaining on-site above health-based
levels, a review will be conducted within five years after commencement of the Operable Unit
Three Remedial Action to ensure that the remedy continues to provide adeguate protection of
human health and the environment.  Subseguent five-year reviews will be conducted for the
duration of the Operable Unit Three Remedial Action.

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FCX-STATESVILLE
OPERABLE UNIT THREE

FINAL RECORD OF DECISION

TABLE OF CONTENTS

I.  SITE NAME, LOCATION, AND DESCRIPTION	   1
       A.     Introduction 	   1
       B.     Site Description	   1
       C.     Topography	   1
       D.     Geology/Hydrogeology 	   1
       E.     Surface Water	   4
       F.     Meteorology  	   5
       G.     Demography and Land Use	   5
       H.     Utilities	   5

II.  SITE HISTORY AND ENFORCEMENT ACTIVITIES 	   5
       A.     Site History	   5
       B.     Enforcement Activities	   6

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION	   6

IV.  SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY	   6

V.  SUMMARY OF SITE CHARACTERISTICS	   7
       A.     Soil Investigation	   8
              Soil Sample Results	11
       B.     Groundwater Investigation	14
              Groundwater Water Sample Results  	  14
       C.     Surface Water/Sediment Investigation 	  19
              Surface Water/Sediment Sample Results	19
       D.     Sludge Characterization	22

VI.  SUMMARY OF SITE RISKS	23
       A.     Chemicals of Potential Concern 	  23
       B.     Exposure Assessment	25
       C.     Toxicity Assessment	25
       D.     Risk Characterization	30
       E.     Ecological Assessment	31

VII.  APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS	34

VIII.  REMEDIAL ACTION OBJECTIVES   	  51
       A.     Soil Contamination	51
       B.     Ground Water Contamination 	  51

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IX.  DESCRIPTION OF ALTERNATIVES	52
       Alternatives to Address Ground Water Contamination 	   52
              Alternative GA-1:  No  Action	52
              Alternative GA-2:  Limited Action 	  52
              Alternative GA-3:  Air Sparging with Passive Venting	52
              Alternative GA-4:  Air Sparging with Active  Venting 	  54
              Alternative GA-5:  Ground Water Extraction and Treatment  with Chemical
                          Precipitation and Carbon Adsorption	54
              Alternative GA-6:  Ground Water Extraction and Treatment  with Chemical
                          Precipitation,  Air Stripping, Carbon Adsorption	54

       Alternatives to Address Soil Contamination 	   54
              Alternative SA-1:  No  Action	54
              Alternative SA-2:  Limited Action 	  54
              Alternative SA-3:  Capping	55
              Alternative SA-4:  Excavation and Off-site Disposal 	  55
              Alternative SA-5:  Soil Vapor Extraction	55

X.  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	56
       Overall Protection of Human  Health and the Environment  	   56
       Compliance with ARARs	56
       Long-term Effectiveness and  Permanence 	   56
       Reduction of Toxicity,  Mobility, or Volume 	   56
       Short-term Effectiveness 	   56
       Implementability 	   56
       Cost	56
       State Acceptance	57
       Community Acceptance	57
       Comparative Analysis of Ground Water and Soil  Alternatives 	   57

XI.  THE SELECTED REMEDY	61
       Ground Water Remediation 	   61
       Soil Remediation	67

XII.  STATUTORY DETERMINATION	67
       Protection of Human Health and the Environment 	   67
       Compliance with ARARs	67
       Cost Effectiveness	67
       Utilization of Permanent Solutions and Alternative Treatment Technologies or
              Resource Recovery Technologies to the Maximum Extent  Practicable  	     67
       Preference for Treatment as  a Principal Element	68

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                           LIST OF FIGURES

FIGURE        DESCRIPTION                                                              PAGE

1      Site Diagram	    2
2      Soil Gas Sample Locations	    9
3      Soil Sample Locations	10
4      Areas with PCE Soil Contamination at 5-15  Feet Below Land Surface	12
5      Ground Water Monitoring Well  Locations  	   15
6      TCE Ground Water Contamination in Shallow  Portion of Aguifer 	   16
7      PCE Contamination in Intermediate Portion  of Aguifer 	   18
8      Surface Water/Sediment Sample Locations	20
9      Location of Air Sparging/Soil Vapor Extraction Wells 	   66

                             LIST OF  TABLES

TABLE         DESCRIPTION                                                      PAGE

 6-1          Ground Water Contaminants  of Concern	24
 6-2          Model for Calculating  Doses  From Ingestion of Ground  Water	26
 6-3          FCX-Statesville,  Operable  Unit Three Toxicity Criteria	27
 7-1          Analysis of Federal ARARs  	  36
 7-2          Analysis of State of North Carolina ARARs  	  46
 8-1          Groundwater Remediation Levels	53
10-1          Summary of Costs  of Evaluated Ground Water Alternatives  	  59
10-2          Summary of Costs  of Evaluated Soil  Alternatives	60
11-1          Capital Cost Estimate  for  Air Sparging with Active Venting	62
11-2          O&M Cost Estimate for Air  Sparging  with Active Venting	63
11-3          Capital Cost Estimate  for  Soil Vapor Extraction  System	64
11-4          O&M Cost Estimate for  Soil Vapor Extraction System	65

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SITE DESCRIPTION

A. Introduction

The textile facility currently owned and operated by Burlington Industries, located on Phoenix
Street just to the north of the FCX property, is the subject of the Operable Unit Three Remedial
Investigation.

B. Site Description

The textile facility is approximately 15 acres in size. Two large buildings consisting of a
warehouse (approximately 60,000 sguare feet in size) and the main building (approximately
275,000 sguare feet in size) are present on-site. In addition, and underground storage tank
area with three 30,000-gallon tanks storing #6 fuel oil, a fire water supply tank, and two
pollution control units are present. The majority of the textile property is covered by either
buildings or paved areas. See Figure 1.

C. Topography

The Site is situated in the Piedmont physiographic province in western-central North Carolina.
The Piedmont physiographic province surrounding the Site is characterized as gently rolling and
sloping, with slopes on-site ranging up to 1.5 percent. Slopes in the immediate vicinity of the
Site range from 2 to 6 percent. Elevations within a four-mile radius of the Site range from 740
to 970 feet above mean sea level.

D. Geology/Hydrogeology

The Site lies within the geologic belt know as the Blue Ridge-Inner Piedmont Belt. The Blue
Ridge-Inner Piedmont Belt generally consists of metamorphic rocks including gneisses and
schists, as well as gradations of the two types. Most of these rocks near the surface have
weathered into a layer of "overburden" overlying the fractured but relatively unweathered
bedrock. In general, soils encountered during drilling activities at the OU 3 study areas were
predominantly red brown to tan clayey and sandy silts (ML) according to the Unified Soil
Classification System (ASTMD 2488-84).

Ground water in the Statesville area is found in the clayey and sandy soil which is residual
weathered material (saprolite), and in underlying weathered and fractured bedrock. The surface
of the water table usually occurs in the saprolite and is often a subdued replica of the
topography. Water table elevations are usually highest beneath hilltops, which are recharge
areas, and lowest in the stream valleys, which are discharge areas. There are noticeable
fluctuations in the water table with the changing seasonal climatic conditions. The water table
usually begins to decline in April or May with the onset of the plant growing season. This
decline in water levels continues until the end of the growing season in November and December.

Water enters the ground water system as percolating rain water in recharge areas and flows
through the system to discharge areas such as streams, ponds, and lakes. Ground water flow is
largely controlled by the hydraulic properties of the geologic strata, and occurs in response to
hydraulic head differentials. However, manmade structures such as utility lines, ditches and
culverts, roof drains, and paved surfaces can influence ground water flow. Ground water flows
from areas of high potential energy (high hydraulic head) to areas of low potential energy (low
hydraulic head). The regional and local ground water flow patterns are modified by local
topography and surface water features, particularly streams and lakes.

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Metamorphic rocks of the Inner Piedmont Geologic Province constitute the fractured bedrock and
competent bedrock hydrogeologic units with ground water in the bedrock occurring under semi
confined or artesian conditions. Water is stored in, and transmitted through fractures, bedding
planes, joints, and cleavage planes. Recharge to the bedrock units occurs as leakage from the
overlying saprolite. Ground water flow in the bedrock units is controlled by the distribution,
interconnection, and concentration of fractures and other openings in the rock unit.

Generally, the fractured bedrock unit is the portion of the aguifer that is developed for water
supply since the fractures extend out, effectively increasing the area available to receive
recharge from the overlying saprolite.

Fractures are often unevenly distributed, but their orientations usually follow the regional
stress orientation. In the North Carolina Piedmont, fractures tend to be oriented
northeast-southwest with a perpendicular secondary set trending northwest-southeast. The size
and numbers of fractures tend to decrease with increasing depth.

The ground water regime at the Site consists of the saprolite and underlying bedrock together
forming a single ground water reservoir. Saprolite forms the uppermost hydrogeologic unit at
the Site. Ground water occurs within the pore spaces of the saprolite under water table
conditions. The base of the saprolite hydrogeologic unit coincides with the fractured bedrock
surface at a depth ranging from 16 to 90 feet. The fractured bedrock hydrogeologic unit is in
turn underlain by the competent bedrock hydrogeologic unit, which was encountered at 82 feet in
W-8i and 80 feet in W-13i. Based on stream orientations and top of bedrock contouring, fracture
zones which may influence bedrock ground water flow at the Site appear to have north-south and
northwest-southeast orientations.

Groundwater at the Site occurs in an unconfined-to-semiconfined aguifer consisting of the
overburden hydraulically interconnected with the underlying fractured bedrock. The saturated
overburden serves as a groundwater reservoir which supplies water to the fractures, faults, and
other secondary permeability features in the bedrock. The ground water surface in the vicinity
of the OU 3 study areas occurs in the saprolite at depths ranging from approximately 4 feet
above land surface in the artesian well W-29i to 45 feet below the land surface. Subsurface
conditions encountered to date at the site are typical for the Piedmont Province.

Groundwater level measurements collected during the Operable Unit Three Remedial Investigation
were used to determine shallow, intermediate, and bedrock groundwater gradients and flow
directions on and around the textile property. The groundwater gradients indicate that
groundwater in the shallow, intermediate, and bedrock portions of the aguifer appears to be
flowing both to the north and to the south from the textile property.

The overburden ranges in thickness from 15-40 feet at the Site, and consists of saprolite and
residual soils interspersed with unweathered gneiss/schist, and to a lesser extent, alluvium.
Granitic intrusions are also common in the area of the Site. Soils in the general area of the
Site belong to the Lloyd Association. These soils, located along broad ridges with short side
slopes, are characterized as deep, well-drained soils with a subsoil of dark red clay.

E. Surface Water

On-site surface water drainage and flow patterns are generally controlled by topography and
several man-made drainage structures constructed along West Front Street and Phoenix Street.
The Site is gently sloping with elevations ranging from about 965 feet above mean sea level
(msl) at a residential pond and intermittent stream located approximately 1,900 feet to the
north of the Site.

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The intermittent stream flows into a residential pond. The pond then discharges into Gregory
Creek which is approximately 5,400 feet to the northeast. Another significant surface water
feature to the north is a seep located approximately 50 feet north of the textile plant property
line. The seep lies within the path of an intermittent stream which flows north from the
textile plant property approximately 10 feet to the north of the property boundary. Surface
runoff and storm water flow in the northern, eastern, and western portions of the study area are
directed to the north via a series of culverts and site topography.

Surface water runoff and storm water flow in the southern part of the study area appear to be
toward the south. Elevations south of the site decrease to about 895 msl at an intermittent
stream located approximately 1,300 feet southeast of the site. The intermittent stream flows
into Third Creek approximately 7,800 feet south of the site. Third Creek is defined as Class C
fresh waters by NCDEHNR Water Quality Section. Surface waters within this area discharge to the
South Yadkin River approximately 20 miles to the east. Intermittent streams lie to the north,
northwest, and south of the site.

F. Meteorology

The climate in Iredell County is classified as fairly mild, and is influenced by the mountain
ranges to the northeast, and the Atlantic Ocean to the southeast. Prevailing winds are from the
southwest, although northeast winds do freguently occur in the autumn. Relative humidity
averages about 70 percent throughout the year. Monthly total precipitation generally ranges
from about 3 inches during October and November to about 5 inches during July and August.

G. Demography and Land Use

The Site is located along an industrial corridor which stretches along West Front Street. The
area around the Site is characterized by a combination of light/heavy industry, commercial,
residential, and institutional. The estimated population within the five-mile radius of the
Site includes all of Statesville (18,622 in the 1980 census) and an estimated 9,500 living in
Iredell County outside the city limits. The population within the three-mile radius of the Site
includes about 90% of the city's population (about 17,000 people) and 2,440 county residents.

H. Utilities

Electricity, telephone, as well as water and sewage connections at the Burlington property exist
and are available upon reguest.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Site History

The original textile plant was constructed in 1927 on the property presently owned by Burlington
Industries. From 1955 to 1977, the plant was operated by Beaunit Mills, In 1967, Beaunit
became a subsidiary of the El Paso Natural Gas Company. In April 1977, Beaunit sold
substantially all of its assets, including the plant, to Beaunit II, Inc. As a part of the
transaction, Beaunit changed its name to the Beaunit Corporation. In July 1978, the plant was
sold by the Beaunit Corporation to Beaunit Fabrics Corporation. In 1981, Burlington Industries,
Inc. purchased certain assets, including the plant, from Beaunit Fabrics. Burlington Industries
operated the plant until its closure in May 1994.

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B. Enforcement Activities

On June 25, 1993, EPA-Region IV signed an Administrative Order on Consent with Burlington
Industries, as well as the former property owner El Paso Natural Gas Company, to conduct the
Operable Unit Three Remedial Investigation and Feasibility Study (RI/FS) to investigate the
contamination associated with the Burlington Industries property.

Pursuant to Section 113(K) (2) (B) (i-v) and Section 117 of CERCLA 42 U.S.C. § 9613 (k) (2) (B) (i-j),
and 42 U.S.C. § 9617, the Community Relations Plan, as well as the RI/FS Reports and Risk
Assessment for Operable Unit Three, were made available to the public in the Administrative
Record. The Administrative Record is housed both in the Information Repository maintained at
the EPA Docket Room in Region IV, and at the Iredell County Library in Statesville, North
Carolina. Fact sheets were sent out in September 1995 updating local citizens about the Site.
Fact sheets notifying local citizens about the availability of the RI/FS documents, explaining
the RI/FS process, and summarizing site-related activities were sent out in July 1996. A notice
of availability of these documents was also published in the Statesville Record and Landmark on
July 18, 1996. A 30-day public comment period was held from July 18, 1996 to August 18, 1996.
In addition, a public meeting was held on July 25, 1996 to inform citizens about EPA's preferred
alternative for Operable Unit Three.

IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY

As with many Superfund sites, the FCX-Statesville Site is complex. For this reason, EPA
currently believes that the remediation of the Site will be accomplished most effectively by
implementing three phases of cleanup, referred to as "operable units".

Each operable unit reguires a separate RI/FS, a separate Proposed Plan, and separate Record of
Decision (ROD). The objectives of the three operable units (OUs) at the Site are:

OU One: Address the groundwater contamination emanating from the FCX property
and migrating to the south of the FCX property.

OU Two: Address the soil contamination (mainly pesticides, polycyclic aromatic
hydrocarbons (PAHs), pentachlorophenol, and dioxin) at the FCX property.

OU Three: Address all other contamination (mainly on-site soil and groundwater, and
surface water/sediment in the seep area) , associated with the textile property
currently owned and operated by Burlington Industries.

The intent of the Operable Unit Three Remedial Action described in this ROD is to reduce the
risk associated with the groundwater contamination at and around the Burlington Industries
property, as well as to restore the groundwater aguifer to its beneficial use(s).

The Operable Unit Three Remedial Action will achieve these objectives by reducing the amount of
volatile organic compounds in the on-site soil as a source of ground water contamination, and by
treating the contaminated groundwater to meet all Federal MCLs or North Carolina Ground Water
Standards, whichever are more protective. As a result, the guality of the surface water at the
seep will be improved to meet State surface water standards.

V. SUMMARY OF REMEDIAL INVESTIGATION

The Remedial Investigation for Operable Unit Three was undertaken by the potentially responsible
parties (PRPs), and the fieldwork conducted by their contractor, Aguaterra, Inc, Raleigh, North
Carolina. The Remedial Investigation was conducted in three phases:

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! Phase I included a soil gas survey, sampling/analyzing soil at specific areas, and
sampling/analyzing surface water and sediment.

! Phase II included sampling/analyzing soil at specific areas, installing groundwater
monitoring wells and sampling/analyzing groundwater, and collecting geologic/hydrogeologic
information.

! Phase III included installing additional monitoring wells and sampling/analyzing
groundwater, additional soil and groundwater sampling/analysis using the direct push
technology, additional surface water sampling/analysis, and collecting additional
hydrogeologic information.

During the Phase I, the soil gas survey consisted of removing vadose zone vapor from depths
ranging from 2 to at least 15 feet below ground surface and analyzing the air using Level II
methods for volatile organic compounds (VOCs) using a van mounted laboratory grade
Hewlett-Packard Model 5890A gas chromatograph (GC) equipped with a flame ionization detector
operated by Philip Environmental Services Corporation, formerly Burlington Environmental, Inc.
The gas chromatograph allowed the determination of the particular substances present in the soil
vapor. A total of 152 soil gas samples were collected from 66 locations on-site. See Figure 2.
The results of the soil gas survey were used to select the locations that soil samples were to
be collected at during Phase I and Phase II activities.

A. Soil Investigation

Based on the results of the soil gas survey, the size of the study areas was expanded during
Phase I soil sampling. Figure 3 shows the soil sample locations. During June 1994, the RECON
van, hand augers, and a drilling rig equipped with hollow stem augers and split spoons were used
to collect soil samples in the saprolite. With the exception of the background soil sample
location, where 2 samples were collected at 15 feet in depth, one soil sample was collected at
each boring location in the upper 1 foot of soil with a second sample from up to at least 15
feet deep. During all Phase I soil sampling, (including soil samples collected with the RECON
van, hand auger, and drilling rig equipped with hollow stem augers and split spoons), at least
two samples per boring (one surface sample and one at highest TVA reading or at soil staining)
were submitted for laboratory analysis.

In order to characterize the analytes and potential source areas, one subsurface soil sample
from each study area with the highest soil gas concentration of with visible staining was
analyzed for the full target compound list (TCL)/target analyte list (TAL) parameters. Where
allowed by access and building clearance a gridded pattern of locations surrounding the study
areas was sampled and analyzed for TCL VOCs and SVOCs during Phase I. Including duplicates, a
total of 82 soil samples were collected during Phase I soil sampling. After evaluation of the
Phase I data, locations and depths for additional soil sampling were evaluated prior to
initiating Phase II soil sampling activities.

The Phase II soil assessment was initiated upon completion of the soil gas survey and the
receipt and review of the Phase I soil analytical results. The Phase II assessment was designed
to characterize and define the vertical and horizontal extent of any analytes detected in Phase
I. As part of the Phase II activities, soil samples were collected from each monitoring well
location and analyzed for TCL volatiles. All other Phase II soil samples were analyzed for TCL
SVOCs or TCL VOCs and SVOCs, because these were the parameters indicated to be of concern by the
Phase I analytical results.

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Phase II soil assessment activities utilized a hand auger and a drilling rig to collect soil
samples at various sampling locations. These samples assisted in defining the source area(s)
identified by Phase I analytical results and the concentration of analytes there. Soil borings
were also placed in areas where the survey indicated trace or no concentrations of analytes to
verify soil gas survey results. Soil samples were used to confirm that the extent of the
impacts had been properly defined. A total of 75 soil samples were collected during Phase II
soil sampling. During Phase III field activities, 11 soil samples were collected from 8
locations.

Soil Sample Results

A total of thirteen VOC compounds were detected in the 145 soil samples analyzed for VOCs.
Based on analytical results and data validation for constituents in soil, the distribution of
the compounds 1,2-Dichloroethane (DCE)(total), ethylbenzene, tetrachloroethane (PCE), toluene,
Trichloroethane (TCE), and xylenes are thought to be representative of the distribution of VOCs
in soils at the facility. Figure 4 shows PCE soil contamination in the soil horizon from 5-15
feet below land surface. The main areas with soil contaminated with PCE above 100 ppb include
the Mop Pit Area, the Tank Area, the Rail Spur Area, the Dry Cleaning Area, and the Storm Drain
Area. The highest levels of PCE were detected between the sewer line located west of the
textile plant in the Storm Drain Area, and the northeastern portion of the Rail Spur Area.
Significant areas of PCE contamination were also located in the northern portion of the Rail
Spur Area, and west of the Dry Cleaning Area.

Ethylbenzene and xylene contamination in the soil was identified in the Mop Pit Area.

Ethylbenzene and xylenes were also detected in soils located in the northern portion of the Rail
Spur Area.

A total of 26 semi-volatile compounds were detected in the 125 soil samples analyzed for SVOCs.
Based on comparison to analytical results from the PCU 1 Containment Area, comparison to
background soil sample results, and data validation results, the following semi-volatile
compounds were identified in soils at the textile facility:

2-methylnaphthalene ace naphthene
acenaphthylene anthracene
benzo(a)anthracene benzo(a)pyrene
benzo (b)fluoranthene benzo(g,h,i)perylene
benzo(k)fluoranthene carbazole
chrysene dibenz(a,h)anthracene
dibenzofuran fluoranthene
fluorene indeno(1,2,3-cd)pyrene
naphthalene phenanthrene
pyrene

These constituents are part of a group of compounds called polynuclear aromatic hydrocarbons
(PAHs). In the top five feet of soil, the areas identified with PAH contamination above 100
micrograms per kilogram (ug/kg) include the west side of the Tank Area, along the sewer line in
the Storm Drain Area on the west side of the textile facility, the northern portion of the Rail
Spur Area, along the Railroad Line, and northwest of the Mop Pit Area. From 5 to 15 feet below
the surface, the areas identified with PAH contamination in the soil included the PCU 2 Area,
the Rail Spur Area, and the Tank Area.

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Fifteen soil samples were analyzed for pesticide compounds during Phase I. The pesticide
4,4-DDT was detected at the Refuse Piles, at the southern boundary of the PCU 1 Area, and along
the Railroad Line. The 4,4-DDT is not considered to be site-related, and was only detected at
the southern boundary of the textile plant and off-site to the north of the textile facility.
The polychlorinated biphenyl (PCB) Aroclor-1254 was detected at the Mop Pit Area and PCU 2 Area.

Fifteen soil samples were analyzed for inorganic constituents during Phase I. Following
validation of the data, the results of the soils metals analysis were compared to values of two
times the background concentrations. The inorganic constituents with maximum concentrations
exceeding twice the background concentration included aluminum, arsenic, barium, calcium,
cobalt, lead, magnesium, manganese, mercury, potassium, and zinc. Inorganic concentrations were
highest at the sewer line west of the textile plant, at the USTs, at PCU 1, and near the Mop
Pit.

B. Ground Water Investigation

The wells sampled and analyzed for TCL VOCs during the Phase I included W-ls through W-5s, MW-1
through MW-4, MW-5s, MW-5d, MW-6s, MW-6d, MW-7 through MW-11, and the Carnation supply well.
Ground water elevations were also collected in all monitoring wells during Phase I. This
initial information was necessary because ground water samples from wells W-ls through W-5s had
only been analyzed once and additional ground water flow information was necessary prior to the
installation of wells in Phase II.

During Phase II, 12 shallow wells and 11 intermediate-depth wells were installed and sampled
across the textile plant and Carnation plant properties to investigate the extent of VOCs in
ground water identified beneath the textile plant property. Figure 5 shows the well locations.

During Phase III, additional shallow, intermediate, deep wells were installed and sampled on an
to the north of the textile facility to further characterize the VOC contamination in the ground
water.

A Hydrocone sampling device was used during the Phase III field activities to collect ground
water samples from the FCX property. The 6-foot sampling device was pushed to a depth ranging
from 10 to 35 feet using a hydraulic system. These samples were analyzed for VOCs by Method
8240.

A Geoprobe ground water sampling device was also used during Phase II for collecting ground
water samples at locations GP-1 through GP-6 to determine shallow ground water guality beneath
the FCX building. The ground water samples were collected from a depth of approximately 35
feet below grade.

Installation and sampling of shallow and intermediate wells south of the FCX facility to
continue VOC impact delineation and provide EPA with information regarding the Operable Unit One
Remedial Design.

Groundwater Sample Results

A total of thirty-two volatile organic compounds were identified in 114 samples collected from
36 shallow wells, 6 Geoprobe locations, and 32 Hydrocone locations. The VOCs most commonly
identified in the ground water during the Phase III included 1,1-DCA, 1,1-DCE, cis 1,2-DCE, PCE,
toluene, 1,1,1-TCA, TCE, and vinyl chloride.

TCE contamination in the shallow ground water is migrating south from the vicinity of the Rail
Spur Line, Mop Pit Area, PCU 2 Area, and PCU 1 Area. Figure 6 shows the TCE contamination

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Extending from the general vicinity of the Rail Spur Line and the Dry Cleaning Area. 1,1-DCE
contamination in the shallow ground water is migrating in a southerly direction from the general
area of the Mop Pit.

Five semivolatile organic compounds were identified in 23 samples from 19 shallow wells. Four
semivolatile organic compounds were identified in 14 samples from 12 intermediate depth wells.
Nine pesticide compounds were identified in 14 samples from 11 shallow wells. One pesticide
compound was identified in samples from 3 intermediate depth wells. The pesticide heptachlor
epoxide was detected in W-161 at 0.009JB ug/L.

A total of twenty-three volatile organic compounds, including carbon tetrachloride, chloroform,
1,1-DCA, cis 1,2-DCE, 1,1-DCE, PCE, toluene, 1,1,1-TCA, and TCE, were identified in 43 samples
collected from 20 intermediate-depth wells. Figure 7 shows the PCE contamination extending
northward from the Rail Spur Area, Dry Cleaning Area, and Storm Drain Area, and southward from
the Mop Pit Area, PCU 2 Area, and PCU 1 Area. The VOCs cis-l,2-DCE, 1,2-dichloropropane, PCE,
and TCE were also detected in the Carnation production well at the Carnation facility. Because
of the industrial setting of the well, the source of the VOCs in the Carnation well is difficult
to pinpoint.

The inorganic constituents identified in the ground water which exceeded twice the background
metals concentrations were aluminum, arsenic, barium, calcium, chromium, cobalt, copper, iron,
lead, magnesium, manganese, mercury, nickel, potassium, selenium, sodium, vanadium, and zinc.
The highest concentrations were detected in wells MW-9, W-5s, W-6s, W-7s, W-16s, and W-17s. The
elevated levels of inorganic constituents in the ground water during the Operable Unit Three
Remedial Investigation may be caused by suspended solids and not dissolved inorganic
constituents. The ground water velocity gradient in the immediate vicinity of a sampling well
slotted screen may be great enough during the acguisition of a sample to cause local solids to
become suspended in the moving ground water, where the suspended solids are transported into the
sampling well, and ultimately into the collected sample. Once collected, that total metals
analysis sample is immediately acidified with nitric acid to a pH of less than 2, which could
then leach insoluble metals out of the suspended solids.

Aguaterra has tested this hypothesis by collecting ground water samples from wells W-5s, W-6s,
W-7s, W-9s, W-16s, W-161, and W-17s at the textile plant on June 27, 1996, and splitting the
sample into two portions. The first portion was collected and preserved as a total metals
analysis sample. The other portion of the sample was filtered through a 0.45 micron gualitative
filter in the field prior to acidification and transport to the laboratory. The filtering step
is not typically employed in the collection of ground water samples for inorganic analysis. The
samples were analyzed for inorganics by SW-846 Methods.

In all cases the metals concentration in the filtered sample were substantially less than the
unfiltered sample, many metals showed greater than two orders of magnitude reduction between the
filtered and unfiltered samples. For example, the unfiltered concentration of aluminum from
sampling well W-9 was reported as 36,100 ug/1, while the filtered sample reported aluminum
concentration was 123 ug/1, a 99.66% reduction. All sampled wells showed significant reductions
in metal concentrations between filtered and unfiltered samples, and in many cases the filtered
metals concentration was below guantification limits (BQL).

The results of this test strongly support the conclusion that metals at the Site exist as
suspended solids or colloids which are easily removed by filtration of the ground water. It is
likely that in a ground water extraction well, fine suspended solids near the well would guickly

-------
be exhausted from the well and that after continuous pumping for a short period of time the
metals concentrations would be reduced to concentrations similar to the filtered sample
analytical results.

C. Surface Water/Sediment Investigation

The primary concern of the surface water/sediment investigation was to determine of ground water
discharge or spills and overflows had resulted in migration of analytes to surface water bodies
and sediment. The potential impact to the surface water bodies was evaluated during Phases I,
II, and III of the RI. The sources of this information were primarily field data generated from
the surface water/sediment sampling activities, laboratory analyses, ground water gradient maps
of the site, and ground water analytical testing result for wells on the northern boundary of
the textile plant.

During Phase I of the RI, surface water samples were collected at the pond, from the seep north
of the textile plant, from the intermittent stream north of the seep, and from the drainage area
northwest of the site. See Figure 8. The samples were collected as grab samples and analyzed
for the full TCL/TAL parameters. The TCL/TAL parameters include substances that are consistent
with textile operations and would indicate impact to surface water and sediments from the
textile operations. In order to verify Phase I surface water data, one additional surface water
grab sample was collected from the seep area during Phase 11+ field activities and analyzed for
TCL VOCs. Seven additional surface water samples were collected from the seep area and analyzed
for TCL VOCs during Phase III field activities.

Surface Water/Sediment Sample Results

Fourteen surface water samples were collected from six stations representing a seep and surface
water drainage north of the Site. Surface water samples SW-4, SW-5, SW-6, SW-7, SW-8, SW-9,
SW-10, SW-11, and SW-12 were collected around the seep area, while samples SW-2 and SW-1 were
collected along the creek to the north of the seep area. Sample SW-3 was collected from the
stream to the west of the seep area. A total of thirteen different VOCs were identified in the
fourteen samples. These VOCs include acetone, chloroform, 1,1,-DCA, 1,2-DCA, 1,1,-DCE,
cis-l,2-DCE, trans-l,2-DCE, 1,2-dichloropropane, methylene chloride, PCE, TCE, toluene, and
vinyl chloride.

Based on the elevation of the seep area, the ground water table elevation, the flow direction in
wells W-lOs, W-7s, W-6s, and W-8s, and the similarity between the VOC concentrations in the
ground water on-site and the VOCs at the seep, it appears that the seep is a ground water
discharge point. While VOC concentrations measured at the seep are elevated, surface water
samples collected to the north of the seep did not contain detectable levels of VOCs.

The semi-volatile compound (SVOC) bis(2-ethylhexyl) phthalate was detected in 4 of the 5 surface
water samples at concentrations ranging from 1 to 2 ug/L. No pesticides were detected in the
surface water samples. Five surface water samples were analyzed for inorganic constituents.
The inorganic constituents that exceeded twice the background concentrations for surface water
included barium, calcium, chromium, cobalt, iron, magnesium, manganese, nickel, potassium,
sodium, vanadium, and zinc.

The VOCs 1,2-DCE (total), 1,2-dichloropropane, TCE, and vinyl chloride were detected in the
sediment sample collected from the seep area. In addition, the compounds methylene chloride and
toluene were also detected in the sediment collected at the pond. VOCs were not detected in
sediment samples taken at the intermittent stream north of the seep, and the drainage area

-------
northwest of the site.

No SVOCs were detected in the sediment samples. However, of the 5 sediment samples analyzed,
one Polycarbonated Biphenyl, Aroclor-1254, was detected in SED-1 collected where the stream
enters the pond, at 350 ug/kg. Aroclor 1254 was also detected in the SED-1 duplicate sample at
220 ug/kg, and in SED-3 collected from the northwest drainage area at 37BJP ug/kg. The
pesticide 4,4-DDT was detected in SED-2 at 2.1 J ug/kg.

The inorganic constituents identified in each of the 5 sediment samples included aluminum,
arsenic, barium, beryllium, calcium, chromium, cobalt, copper, iron, lead, magnesium, manganese,
nickel, potassium, sodium, vanadium, and zinc. Calcium and zinc were the only inorganic
constituents which exceeded twice the soil background concentrations.

D. Sludge Characterization

Sludge samples were collected from the PCU 1 Containment Area and the surge tank located in the
sanitary sewer of the Storm Drain Area were analyzed for full TCL/TAL parameters. The only VOC
identified in the sludge from the PCU 1 containment area at an elevated concentration was
acetone at a concentration of 9.000 ug/kg. The SVOCs bis-2-ethylhexyl) phthalate and di-n-butyl
phthalate were detected in the sludge at concentrations of 54,000 ug/kg and 60,000 ug/kg,
respectively. The inorganic constituents detected in the sludge sample included aluminum,
chromium, copper, iron, lead, manganese, nickel, thallium, and zinc.

Analysis of the sludge sample from the surge tank detected the VOCs chlorobenzene and PCE at
42,000 ug/kg and 4,900 ug/kg, respectively. SVOCs detected included 1,2-dichlorobenzene,
1,3-dichlorobenzene, 1,4-dichlorobenzene, 2-methylnaphthalene, bis(2-ethylhexyl) phthalate, and
naphthalene. Aluminum, antimony, barium, cadmium, calcium, chromium, cobalt, copper, iron,
lead, magnesium, manganese, mercury, nickel, potassium, selenium, sodium, vanadium, and zinc
were the inorganic constituents present in the sludge sample from the surge tank.

Overflow from the PCU-1 Containment Area potentially may have contributed SVOC analytes to the
soil. The surge tank has not been demonstrated to have contributed analytes to the soil. Both
the PCU-1 and surge tank contents will be removed and the areas decontaminated during the
Remedial Action for Operable unit Three.

VI. SUMMARY OF SITE RISKS

The Baseline Risk Assessment Report presents the results of a comprehensive risk assessment that
addresses the potential threats to public health and the environment posed by the Site under
current and future conditions, assuming that no remedial actions take place, and that no
restrictions are placed on future use of the Site. Actual or threatened releases from the Site,
if not addressed, may present an imminent and substantial endangerment to public health,
welfare, or the environment. The Baseline Risk Assessment evaluated the potential risk from
exposure to contaminated groundwater, soil, surface water, and sediment associated with the
property currently owned and operated by Burlington Industries. Contaminated soil and
groundwater associated with the property currently owned and operated by Burlington Industries
are the media of concern addressed in this Record of Decision as the Operable Unit Three
Remedial Action. The Baseline Risk Assessment consists of the following sections:
identification of chemicals of potential concern; exposure assessment; toxicity assessment; risk
characterization; and remedial option goals. A separate evaluation of ecological risks was
conducted. All sections except the uncertainty analysis and remedial goal options, are
summarized below. Refer to the Baseline Risk Assessment for the uncertainty analysis and
remedial option goals.

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A. Chemicals of Potential Concern

In order to identify chemicals of potential concern for the Site, the chemicals present in Site
samples were screened using comparisons with ambient or background concentrations, essential
nutrient concentrations, as well as concentrations-toxicity criteria. If a chemical of
potential concern was determined to contribute significantly to an unacceptable risk, and was
not screened out using these comparisons, then it was considered to be a chemical of concern for
the Site.

The chemicals of concern identified in the ground water during the Operable Unit Three RI
include aluminum, arsenic, barium, iron, lead, manganese, bis(2-ethylhexyl)phthalate, carbon
tetrachloride, chloroform, 1,1-DCE, cis 1,2-DCE, 1,2-Dichloropropane, methylene chloride, PCE,
1,1,2-TCA, TCE, and vinyl chloride. Several of these chemicals, such as the inorganics
aluminum, arsenic, barium, iron, lead, and manganese, are not thought to be associated with
former textile operations. Therefore, these inorganics will not be targeted for remediation
during Operable Unit Three. Table 6-1 shows the contaminants of potential concern identified
during the Operable Unit Three RI/FS with the exposure point concentrations. Chemicals were
included in this discussion of the Site risk assessment indicated that a contaminant might pose
a significant current of future risk, or contribute to a cumulative risk which is significant.
On-site groundwater discharges into the seep to the north of the textile facility. In the
surface water at the seep, concentrations of tetrachloroethane, iron, lead, and zinc exceeded
federal chronic Ambient Water guality Criteria (AWQC). Tetrachloroethane and zinc also exceeded
acute AWQC, and iron exceeded the North Carolina Fresh Surface Water Quality Standards (FSWQS).
While these criteria were useful in selecting COPCs, their applicability is limited because they
were not developed for use at a groundwater discharge point such as a seep. None of the COPCs
except iron were found to present a potential ecological risk based on

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TABLE 6-1
GROUND WATER CONTAMINANTS OF CONCERN

              CHEMICALS               EXPOSURE POINT
                                   CONCENTRATIONS  (ug/1)

       Aluminum                          34,100
       Arsenic                                   9.1
       Barium                                    292
       Iron                              260,000
       Lead                               71.1
       Manganese                         2,520
       Bis(2-ethylhexyl)phthalate                 67
       Carbon Tetrachloride                       68
       Chloroform                          44
       1,1-Dichloroethane                         73
       cis 1,2-Dichloroethane                    1000
       1,2-Dichloropropane                        24
       Methylene Chloride                         32
       Tetrachloroethane                  57000
       1,1,2-Trichloroethane                      11
       Trichloroethane                           480
       Vinyl Chloride                              1

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B. Exposure Assessment

The exposure assessment evaluates and identifies complete pathways of exposure to human
populations on or near the Site. Current exposure scenarios include the ingestion and dermal
contact of soils, surface water, and sediment. Current land use assumptions include off-site
residential and on-site child trespasser scenarios. Groundwater usage was not evaluated using
the current land use assumptions because if has not been determined that the northward or
southward-moving plumes have reached any private wells around the Site. Furthermore, the
textile property is currently being used for industrial purposes, and the textile facility does
not have a ground water drinking well in use.

Ground water usage was evaluated under the future land use scenario. Future exposure scenarios
consider construction of water supply wells within the ground water contamination plume, as well
as the incidental ingestion and dermal contact of soils, surface water, and sediment as
reasonable maximum exposures. Exposure scenarios evaluate exposure to chemicals of concern from
the ground water plume in drinking water and through inhalation of volatile organic compounds
evolved from water in household use(s). Inhalation from showering was evaluated to account for
doses of VOCs received from non-ingestion uses of water. The dose from inhalation of VOCs from
showering was assumed to be eguivalent to the ingestion of 2 liters of water. Once these
contaminants of concern were identified, exposure concentrations in the ground water were
estimated. The maximum concentrations detected were compared to the average of select samples
in the contaminated area of the plume, and the lower of these values was chosen as the estimated
exposure concentration. Table 6-2 shows the model used for calculating doses from the ingestion
of contaminated ground water, including the exposure assumptions associated with ground water
usage at the Site. Further detail and mathematical calculations can be viewed in the Final
Baseline Risk Assessment, prepared by Philip Environmental in July 1996.

C. Toxicity Assessment

Under current EPA guidelines, the likelihood of adverse health effects occurring in humans from
carcinogens and noncarcinogens are considered separately. These are discussed below. Table 6-3
summarizes the carcinogenic and noncarcinogenic toxicity criteria for the ground water
contaminants of concern at the textile facility. Cancer sloper factors have been developed by
EPA for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. Slope factors, which are expressed in units of (kg-day/mg), are
multiplied by the estimated intake of a potential carcinogen, in mg/kg-day, to provide an
upperbound estimate of the excess lifetime cancer risk associated with exposure at that intake
level. The term "upperbound" reflects the conservative estimate of the risks calculated from
the slope factor. Use of this approach makes underestimation of the actual cancer risk highly
unlikely. Cancer potency factors are derived from the results of human epidemiological studies
or chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors have
been applied.

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TABLE 6-2

MODEL FOR CALCULATING DOSES FROM
INGESTION OF GROUNDWATER

       Groundwater Ingestion Dose = CW x IR x EF x ED
           (mg/kg-day)                         BW x AT

Where:
CW   =  Chemical concentration in groundwater (mg/L)
IR   =  Ingestion rate  (L/day)
EF   =  Exposure frequency  (days/year)
ED   =  Exposure duration  (years)
BW   =  Body weight  (kg)
AT   =  Averaging time  (days)

Assumptions:

CW   =  Average concentration of select groundwater samples.
IR   =  2 liters/day, for the adult resident.
EF   =  350 days/year for the adult residents.
ED   =24 years for the adult resident.
BW   =  70 kg for the adult resident.
AT   =  Exposure duration  (years) x 365 days/year for evaluating noncancer risk.
     =  70 years x 365 days/year for evaluating cancer risk.

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TABLE 6-3
FCX STATESVILLE SITE,
OPERABLE UNIT THREE
TOXICITY CRITERIA
                            Oral  Slope
                              Factor
                            (mg/kg/day) -1
                                          Ref.   Oral RfD
                                                 (mg/kg/day)
                             1.5E+0
                             1992
INORGANICS

Aluminum

Arsenic

Barium

Iron
Lead
Manganese

VOLATILE ORGANICS

Vinyl Chloride        1.9E+0
                      1993
1,1-Dichloroethane  6.00E-01
                       1992
1,2-Dichloropropane 6.8E-02
                       1993
                                                                            Ref.
NTV

IRIS,

NTV

NTV
NTV
NTV

l.OE+0
1992
3.0E-4
1993
7E-02
1992


1.40E-01
1992
EPA,

IRIS

IRIS

NTV
NTV
IRIS

                                                HE AST,                      NTV

                                                IRIS,   9.00E-03            IRIS,
                                                       1992
                                                HE AST,           NTV

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TABLE 6-3

FCX STATESVILLE SITE,
OPERABLE UNIT THREE
TOXICITY CRITERIA
                            Oral  Slope
                              Factor
                            (mg/kg/day) -1
    Ref.    Oral RfD     Ref.
           (mg/kg/day)
       Chloroform             6.10E-03    IRIS,   l.OOE-02     IRIS,
                                         1992                 1992
       1,1,2-Trichloroethane         5.7E-02    IRIS,    4.0E-03     IRIS,
                                         1992                 1992
       Trichloroethene3        1.1E-2     Ref 3       6E-3      Ref3
       Tetrachloroethane       5.2E-2     EPA,     l.OOE-02    IRIS,
                                         1993
       cis 1,2-DCE               NTV               l.OE-02
       Methylene Chloride

       Carbon Tetrachloride
7.5E-03
    1992
1.3E-01
    1992
IRIS,

IRIS,
    1992
    HEA
    ST,
    1993
6.0E-02
    1992
7.0E-04
    1992
IRIS,

IRIS,

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TABLE 6-3

FCX STATESVILLE SITE,
OPERABLE UNIT THREE
TOXICITY CRITERIA
                            Oral  Slope    Ref.   Oral RfD      Ref.
                              Factor              (mg/kg/day)
                            (mg/kg/day)-1

       SEMI-VOLATILE ORGANICS

       Bis(2-Ethylhexy)Phthalate   1.40E-02            IRIS,   3.00E-02     IRIS
                                         1992                 1992

1  Converted from a unit risk assuming the ingestion of 2 liters of drinking water per day and a
body weight of 70kg  (EPA, 1992)

2  Calculated from the current drinking water standard, assuming the consumption of 2 liters of
water per day and a body weight of 70 kg.

3  Guidance from Superfund Technical Support Center.

NTV = No Toxicity Value

Dermal RfDs/SFs are derived

Absorption Factors  (ABS):
0.2 - Inorganics
0.8 - Volatile Organics
0.5 - Semi-volatile Organics/Pesticides/PCBs

Dermal RfD = Oral RfD x ABS

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Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of chemicals from environmental media can be
compared to the RfD that are likely to be without risk of adverse effect. RfDs are derived from
human epidemiological studies or animal studies to which uncertainty factors have been applied.
These uncertainty factors help ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur.

D. Risk Characterization

The risk characterization step of the risk assessment process integrates the toxicity and
exposure assessments into guantitative and gualitative expressions of risk. The output of this
process is a characterization of the Site-related, potential carcinogenic and noncarcinogenic
health effects. Potential concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as the hazard guotient (HQ), or the ratio of the ingestion dose
derived from the contaminant concentration in a given medium to the contaminant's Reference Dose
(RfD).

To assess the overall potential for non-carcinogenic effects posed by more than one COPC, a
hazard index ("HI") approach was used for each receptor scenario. The HI is egual to the sum of
the HQs. When the total HI for a receptor exceeds unity (one), the approach utilized indicates
that there may be concern for potential non-cancer health effects. This method assumes that the
cumulative effect of multiple subthreshold exposures is additive, and may result in an adverse
health effect to a particular target organ. His were calculated in a phased approach.
Initially, all HQs were summed within each exposure scenario, and one HI was calculated for each
receptor scenario. If the HI exceeded unity, COPCs then were grouped by target organ effect,
and His were calculated for each target organ.

For carcinogens, risks are expressed as the incremental probability of an individual developing
cancer over a lifetime as a result of exposure to the carcinogen. These probabilities are
generally expressed in scientific notation (e.g., 1X10-6 or 1E-6). An excess lifetime cancer
risk of 1 X 10-6 indicates that, as a reasonable maximum estimate, an individual has a 1 in
1,000,000 chance of developing cancer as a result of site-related exposure to a carcinogen over
a 70-year lifetime under the specific exposure conditions at a site.

Carcinogenic risks for future hypothetical residents living on-site were determined from
potential exposure due to the ingestion and inhalation of contaminated groundwater. The total
carcinogenic risk due to the ingestion and inhalation of all volatile organic compounds present
in on-site ground water by a future hypothetical resident is 7 x 10-3, or the risk that seven
residents-out-of-one thousand residents would be at risk of developing cancer due to long-term
exposure. With the exception of the hypothetical future on-site resident, all other current and
future risks are within the Superfund Site risk range specified in the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), which is 10-4 to 10-6 (a potential excess
cancer risk of one-in-10,000 to one-in-a-million).

Noncarcinogenic risk exceeded a Hazard Quotient (HQ) value of 1.0 for the future hypothetical
on-site resident due to the ingestion and inhalation of contaminated ground water affecting the
bloodstream. The HQ value for this future scenario is 1.2. Furthermore, the HQ value for the
future on-site resident due to the ingestion and inhalation of contaminated ground water
affecting the liver as the target organ is 37. With the exception of the hypothetical Site
resident, all of these His are within the Superfund Site remediation goal specified in the NCP
(an HI of less than 1.0).

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E. Ecological Assessment

Surface water and sediment in the intermittent stream, and surface water and sediment at the
seep, were considered the media of ecological concern at the Site due to the fact that potential
receptors may experience direct contact with volatile organic compounds identified in the
surface water and sediment. To assess surface water exposure, it was assumed that aquatic biota
would experience continuous, prolonged exposure to the surface water ecological COPCs. To
assess sediment exposure, it was assumed that aguatic biota would experience continuous,
prolonged exposure to the sediment COPCs. Potential risks to environmental receptors at or near
the Site were evaluated based on Site sampling data and a review of the toxicity of the
chemicals of potential concern to ecological receptors.

Use of the Site by terrestrial receptors such as birds and small mammals, particularly the areas
covered by the buildings and paved areas, was considered unlikely given the lack of trees or
other vegetative cover on the textile facility. Based on a qualitative analysis, terrestrial
wildlife communities in the upland and lowland areas around the textile facility are not likely
to be significantly impacted. No threatened and endangered (T&E) or sensitive species of plants
or animals were observed during the reconnaissance survey. This is consistent with U.S. Fish &
Wildlife service and North Carolina Department of Environment, Health, and Natural Resources
findings that few threatened or endangered species were know to occur within a 4-mile radius of
the Site.

Due to the complete exposure pathways that may be present, surface water and sediment in the
intermittent stream and seep north of the site were included as the aquatic media of ecological
concern for OU-3. The highly conservative assumption that the intermittent stream and seep were
conducive to support fish and aquatic invertebrates over a prolonged period of time, and
amphibians were intermittently exposed, was used during this initial assessment. Due to the
shallow depth in the seep and stream (typically only a few inches or less), it is unlikely that
edible fish (by humans) and other fish are present in the stream.

The assessment endpoint for surface water was the health of aquatic biota. The measurement
endpoint was health effects to aquatic biota, where data were available. The selected
assessment endpoints for sediment were the health of aquatic biota based on potential metals
toxicity and VOC toxicity. The measurement endpoint for VOCs was health effects to aquatic
biota from bioavailable organic chemical stressors, based on an equilibrium-partitioning
approach because direct toxicological information was not available.

In addition to direct exposure, possible impacts via food-chain effects were also considered.
However, none of the VOCs or metals are of ecological concern due to bioaccumulation and
subsequent food-chain effects. Therefore, no food-chain effect analysis was performed. No
other media at the site provide significant complete pathways. The North Carolina Department of
Environment, Health, and Natural Resources claims that few T&E species were known to occur
within a 4-mile radius of the site.

Zinc concentrations in the eastern intermittent stream exceeded federal acute and chronic AWQC,
but was below the background surface water concentration. Of the chemicals detected, only
cis-1,2-dichloroethene was considered an ecological COPC because there are no screening values
developed for it. The maximum chemical concentration for cis-1,2-DCE detected was below toxic
effect levels obtained on AQUIRE. Also, all chemical concentrations downstream at the inlet to
the pond north of the site were below background or screening values. Hence potential
ecological impacts caused by site-related analytes in the intermittent stream surface water and
pond should be insignificant.

In the seep water north of the site, concentrations of tetrachloroethane, iron, lead, and zinc

-------
exceeded federal chronic AWQC. Iron concentrations exceeded the North Carolina FSWQS, and zinc
also exceeded federal acute AWQC. Of the analytes detected, 17 (7 VOCs and 10 inorganics) were
considered ecological COPCs. Based on the potential aguatic receptors, only iron concentrations
in seep water presented a potential ecological risk. However, it should be noted that these
groundwater seep concentrations were compared to stream surface water background concentrations
(not seep water background concentrations). If the concentrations of iron, lead, and zinc are
compared to background groundwater concentrations, all chemicals are well below average
background concentrations.

All of the other ecological COPCs in seep water were detected at concentrations which were below
toxic effect levels obtained on AQUIRE. However, no toxicological information was available for
1,1-dichloroethane; therefore, no ecological impacts from this analyte could be ascertained.
The lack of toxicological information and the relatively low maximum concentration (1.0
micrograms per liter [ug/L], detection limit 3 ug/L) suggest that ecological impacts are
unlikely.

In the eastern intermittent stream, the concentration of zinc in surface water exceeded the
federal AWQC. However, the maximum concentration was below the background screening level.
Based on information gathered from the AQUIRE database, the COPC (cis-1,2-dichloroethene) was
not found to present an ecological risk. In the stream sediment, the concentration of methylene
chloride was not found to present an ecological risk based on information gathered from the
AQUIRE database.

On-site ground water discharges to the seep north of the site. In the surface water at the
seep, the concentrations of tetrachloroethane, iron, lead, and zinc exceeded federal chronic
AWQC. Tetrachloroethane and zinc also exceeded acute AWQC, and iron exceeded North Carolina
FSWQS. While these criteria were useful in selecting COPCs, their use and meaning are minimized
because they were not developed for use at a seep. None of the COPCs except iron were found to
present a potential ecological risk based on information gathered from the AQUIRE database and
the types of aguatic organisms that may be exposed to seep water that is, at most, 2 in. deep,
the iron concentration was found to present a potential ecological risk since the HQ = 5.26.

Once the surface water at the seep discharges into the stream, the concentration of iron in the
stream surface water and in the sediment was below site background screening concentrations, and
the concentration of iron in the seep sediment was below background screening concentrations.
In seep sediment, none of the COPCs were found to present an ecological risk.

VII. Applicable or Relevant and Appropriate Reguirements (ARARs)

The identification of ARARs is site-specific; since, each site has unigue characteristics.
ARARs as defined from the preamble to the final rule establishing the NCP (55 FR 8666) and the
text of the regulations are:

"Applicable reguirements means those cleanup standards, standards of control, and other
substantive reguirements, criteria, or limitations promulgated under federal environmental or
state environmental or facility siting laws that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA site.
Only those standards that are identified by a state in a timely manner and that are more
stringent than federal reguirements may be applicable."

Substantive reguirements generally involve a guantitation limitation or performance objective as
opposed to administrative reguirements such as record keeping and reporting. In addition, only
standards or reguirements that have been promulgated before the record of decision (ROD) is
signed are applicable for the compounds identified prior to the ROD.

-------
"Relevant and appropriate requirements means those cleanup standards, standards of control, and
other substantive requirements, criteria, or limitations promulgated under federal environmental
or state environmentally or facility siting laws that, while not 'applicable' to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA
site, address problems or situations sufficiently similar to those encountered at the CERCLA
site that their use is well suited to the particular site. Only those state standards that are
identified in a timely manner and are more stringent than federal requirements may be relevant
and appropriate."

If a regulation or a portion of a regulation is identified as relevant and appropriate, it is
applied just as strictly as an "applicable" requirement. As with applicable requirements, only
substantive requirements promulgated before the ROD is signed can be relevant and appropriate.

"First to determine relevance a comparison is made between the action, location, or chemicals
covered by the requirement and related conditions of the site, release, or remedy; a requirement
is relevant if the requirement generally pertains to these conditions. Second to determine
whether the requirement is appropriate, the comparison is further refined by focusing on the
nature of the substances, the characteristics of the site, the circumstances of the release, and
the proposed remedial action; the requirement is appropriate if, based on such comparison, its
use is well-suited to the particular site. Only those requirements that are determined to be
both relevant and appropriate must be complied with." (53 FR 51436)

ARARs are classified into three general groups:

! Chemical-specific ARARs: Health or risk-based concentration limits or ranges in
various environmental media for specific hazardous substance, pollutants, or
contaminants. These limits may take the form of action levels or discharge levels.

! Location-specific ARARs: Restrictions on activities that are based on the
characteristics of a site or its immediate environment. An example would be
restrictions on wetlands development.

! Action-specific ARARs: Controls or restrictions on particular types of activities
such as hazardous waste management or wastewater treatment. An example would be
RCRA incineration standards. Such requirements are triggered by the particular
remedial action selected.

Federal ARARs are summarized in Table 7-1 and North Carolina ARARs are summarized in Table 7-2.

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TABLE 7-1

                                         ANALYSIS OF FEDERAL ARARs

Standard, Requirement,                   Regulatory              Description             Potential
Criteria, or Limitation                  Citation                                            ARAR

Resource Conservation  and  Recovery Act

Location-Specific ARARs  under  RCRA

Seismic considerations           40 CFR                  Restricts  location  of TSD         No            No known  faults  within or in the
                                 264.18(a)                facilities within  200 ft  of a                   vicinity  of  the  Site.
                                                         fault that has  had  a displacement
                                                         within Holocene time.

Floodplains                      40 CFR                  Requires TSD  facility located  No               The  Site  or  the  remedial actions
                                                         within a 100-year  floodplainto                arenot located  in the 100-year
                                                         be designed,  constructed,                        flood plain.
                                                         operated,  and maintained  to
                                                         prevent washout of  any
                                                         hazardous  wastes by a 100-year
                                                         flood.

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
Action-Specific ARARs  under  RCRA
                                                                                                          Potentially  applicable  to
                                                                                                          remedial actions  involving
                                                                                                          removal of hazardous  waste
                                                                                                          (e.g., spent  carbon from carbon
                                                                                                          adsorption process).
Establishes standards which    Yes
apply to transporters of
hazardous waste within  the
United States if the
transportation requires a
manifest under 40 CFR Part 262.
                                                                                                          Potentially  applicable  to
                                                                                                          remedial actions  involving
                                                                                                          transportation  of hazardous
                                                                                                          waste  from the  Site  to  disposal
                                                                                                          facility
Requirements for owners  and
operators of hazardous waste
treatment, storage,  and
disposal  (TSD)  facilities
Establishes minimum  national    Y
standards which define  the
acceptable management of
hazardous wastes  for owners and
operators of facilities which
treat, store, or  dispose  of
hazardous wastes.
Potentially applicable to
remedial actions involving
treatment,  storage, and disposal
of hazardous waste.
Land Disposal Restrictions  40  CFR Part
                                 268
                                                 Potentially applicable  to
                                                 remedial actions involving
                                                 removal of hazardous wastes
                                                 (e.g., spent carbon  from carbon
                                                 adsorption process.)

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
Clean Water Act  (CWA)

Action-Specific ARARs

National Pollutant Discharge
Elimination System  (NPDES)
requirements
CWA Part 402
40 CFR Part
125
Requires permit  for  effluent
discharge from any point  source
into surface waters  of  the  United
States.
Effluent guidelines  and
standards for the point
source category

National pretreatment  standard
for indirect discharge to  a
POTW
Technology-based effluent
limitations
40 CFR Part
401
Requires sped fie  effluent
characteristics  for  discharge
through NPDES system.

Establishes standards  to  control
pollutants which pass  through  or
interfere with treatment
processes in public  treatment
works which may  contaminate
sewage sludge.

Establishes guidelines to
determine effluent standards
based on the Best  Available
Technology  (BAT) economically
achievable.
                                                                                  Potentially applicable to
                                                                                  current discharge of
                                                                                  groundwater into local POTWs.

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
National Emission  Standards
for Hazardous Air  Pollutants
(NESHAP)

Safe Drinking Water Act  (SDWA)

Chemical-Specific  ARARs

National Primary Drinking
Water Standards
40 CFR Part
141
                Establishes  ambient  air quality
                standards  for  classes  of
                pollutants.

                Stipulates monitoring
                requirements  for  emissions of
                sped fie contaminants .
Establishes health-based
enforceable standards  for  public
water systems  (maximum
supply.
contaminant levels  (MCLs).
Future potential use of
groundwater as potable water
contaminant levels  (MCLs)).

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
National Secondary Drinking
Water Standards
40 CFR Part
143
                                         40 CFR Part
                                         141
Establishes aesthetic-based,  non-
enforceable guidelines  for  public
water systems  (secondary
maximum contaminant  levels
(SMCLs)).

Establishes non-enforceable
drinking water quality  goals
(MCLGs) set at levels that  cause
no known or anticipated adverse
health effects with  an  adequate
margin of safety without
consideration of available
treatment technology or cost.
Future potential use of
groundwater as a potable water
supply.
                                                                                  Future  potential use of
                                                                                  groundwater as a potable water
                                                                                  supply.
Toxic Pollutant Effluent
Standards
                                         40 CFR 129
                        Establishes  effluent standards or
                        prohibitions for certain toxic
                        pollutants:  aldrin/dieldrin,  DDT,
                        endrin,  toxaphene,  benzidine,
                        PCBs
                                                         These pollutants  have  not  been
                                                         identi fied as  chemicals of
                                                         concern at the Site.
Point Sources

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
Identification and Listing  of
hazardous Waste
 40 CFR 261
Subparts C and
 D
Defines those solid wastes  that
are subj ect to and regulated  as
Potentially applicable  to
remedial actions involving  solid
waste removal in the
identi fication of wastes and
application of other  action-
sped fie ARARs.
                                                                 Standards  for  14  hazardous
                                                                 constituents as  a part of RCRA
                                                                 ground water protection
                                                                 standards.
                                                                                   For  RCRA permitted facilities Limits
                                                                                   with regulated waste untis.
Action-Specific ARARs

Underground Injection  Control
(UIC) Regulations
 40 CFR Parts
 144-147
                                                                 Treatment  standards for
                                                                 hazardous  wastes  or hazardous
                                                                 waste  extracts  before land
                                                                 disposal is  allowed.
Provides for protection  of
underground sources of drinking
water.
Potentially applicable  to
groundwater remediation i f
injection of treated  groundwater
is selected as a discharge
technology.

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TABLE 7-1
ANALYSIS OF FEDERAL ARARs

Clean Air Act  (CAA)
National Ambient Air  Quality
Standards  (NAAQS)
Establishes ambient  air  quality
standards for classes  of
pollutants - carbon  monoxide,
hydrocarbons, lead,  nitrogen
dioxide, particulate matter,
ozone, and sulfur  oxides.
Standards of not apply directly
to source-sped fie emissions ,  but
are ambient concentration
limitations.
No      Only "maj or  sources"  (emissions
        exceeding  100-250  tons  per year
        of regulated pollutants)  are
        subj ect to NAAQS attainment
        requirements.
National Emission  Standards  of
Hazardous Air Pollutants
(NESHAP)
                                         40 CFR Part 61
Establishes emission  standards
for seven contaminants  -  benzene,
mercury, arsenic,  asbestos,
beryllium, vinyl chloride,  and
radionuclides.
        Not applicable  to  the  Site as
        benzene and  vinyl  chloride are
        not contaminants of  concern at
        the Site.

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
Occupational Safety  and Health
Administration
                                                                  Regulates workers'  health and
                                                                  safety.
                                                         Applicable  to remedial actions
                                                         at  the  Site.
Department of  Transportation (DOT)
Hazardous Materials  Transportation Act
Hazardous Materials
Transportation Regulations
Regulates transportation  of
Department to  Transportation
(DOT)-defined  hazardous
materials.
Potentially applicable  to  any
remedial action involving
transportation of DOT-defined
hazardous materials off-site.

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
Regulations Protecting  Landmarks,  Historical,  and Archaeological  Sites

Location-Sped fie ARARs

National natural landmarks
Historic, architectural,
archaeological, and  cultural
sites
Historic, rehistoric  and
archaeological data
Historic Sites
        Act of 1935, 16
        USC 461,
        40 CFR 6.301(a)

        National
        Historic
        Preservation
        Act of 1966, 16
        USC 470, 36
        CFR 800,
        Executive order
        11593
        40 CFR 6.301(b)

        Archaeological
        Preservation
        Act of 1974, 16
        USC 469 et seq.
        Executive
        Order 11593
        O CFR 6.301
Establishes regulations  to
protect national natural
landmarks during remedial
actions.

Establishes regulations  to
protect historic, architectural,
archaeological, and cultural  sites
during remedial actions.
                                                                                                                           Site  is not located in an area
                                                                                                                           with  natural landmarks.
Site is not located  in  an  area
with historic, architectural,
archaeological or cultural sites
Establishes regulations  to
protect historic, prehistoric,
and archaeological data  during
remedial actions.
                                                                                                             No
Site is not located  in  an  area
with prehistoric or
archaeological data.

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
Clean Water Act
Dredge or Fill Requirements
Wilderness Act
National Wildlife  Refuge  Act
Requires action to conserve
endangered species and/or
critical habitats upon which
endangered species depend.

Requires permits for  discharge of
dredged or fill material into
navigable waters as part of any
alternative.

Administers federally owned
wilderness area to leave in
unimpacted.

Restricts activities  within a
National Wildlife Refuge
Potentially applicable as
endangered and threatened
species have been identi fled  in
the Onslow County.

There will be no discharge  of
dredged or fill material into
navigable waters
                                         16 USC 1451
                                                                                                                           Site is not in a coastal zone.

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TABLE 7-1

ANALYSIS OF FEDERAL ARARs
Regulations to Protect Wetlands
Requires consideration  of  the
adverse impacts associated with
the destruction or  loss of
wetlands and to avoid support  of
new construction in wetlands  i f £
practical alternative exists.
Portion of the Site may be  in a
wetland.  Area may be  less  than
1/3 acre, which is a threshold
value.
Fish and Wildlife  Coordination Act

Action-Specific ARARs

Protection of  fish and wildlife
due to any modifications  of
water bodies.
Requires adequate provision for
protection of  fish  and wildlife
resources when any  modification
of any stream  or other water body
is proposed.
Potentially applicable  if  the
remedial action involves
discharge of treated water to
Third Creek.

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TABLE 7-2

Analysis of State of North  Caroline ARARs

Chemical-Specific ARARs
                                                                 Defines  those  solid wastes which
                                                                 are  subj ect  to state regulation
                                                                 and  as a hazardous waste.
                                                                 Consistent with corresponding
                                                                 federal  standards (characteristic
                                                                 and  listed hazardous waste
                                                                 designations).
Potentially applicable  to
remedial actions involving  solid
waste removal.
North Carolina Water  and  Air  Resources Act
Laws to achieve and  to
maintain a total
environment with
superior quality.
                                                                 State  equivalent  of the Federal
                                                                 CWA  and  CAA
Potentially applicable  for
remedial action involving
cleanup of groundwater  and
emissions to the atmosphere.

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TABLE 7-2
Analysis of State of North  Caroline ARARs

North Carolina Drinking Water  Act

Action-Sped fie ARARs
Regulations on drinking
water
North Carolina Water  Pollution Control Regulations

Action-Specific ARARs
Wastewater Treatment
Requirements
Requires permit for discharge  of
effluent from point sources  into
surface waters.  State-level
version of federal NPDES program.

Establishes basic wastewater
treatment requirements  for
effluent discharge.
                                                         Current limited use  and
                                                         potential  future  use of
                                                         groundwater as a  potable  water
                                                         supply.
Potentially applicable  to
remedial actions involving  point
source discharges to  surface
waters.

Potentially applicable  to
remedial actions involving  point
source discharges.

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TABLE 7-2

Analysis of State of North  Caroline  ARARs

North Carolina Drinking Water  and Groundwater Standards

Chemical-Specific ARARs

                                 NCAC Title 15,                   Establishes groundwater  and                Yes          Potentially applicable  to
                                 Chapter 2,                      drinking water  standards based                          groundwater remediation based
                                 Subchapter 2L                   ontheusage.                                            onanticipated  future usage.
                                 Sections .0200nd 0.0201

North Carolina Surface Water Quality Standards

Chemical-Specific ARARs

Class!fication and water         NCAC Title 15A,                  Establishes a series  of                     Yes          Potentially applicable  to  surface
quality standards                Subchapter 2B,                   class!fications and water quality                       water and to  discharge  of
applicable to surface            Sections .0100                   standards  for surface waters.                            treated groundwater  to  a
water                            and  . 0200                                                                                surface water body.

Technology-based effluent        NCAC Title 15A,                  Establishes guidelines for                 Yes          Potentially applicable  to  surface
limitations                      Subchapter 2B                   effluent limitations  based on  BAT                       water and groundwater
                                 Section .0400                   economically achievable.                                 treatment.

                                 Title  15A NCAC
                                 Subchapter 2D,  2H

Chemical/Action-Specific ARARs

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TABLE 7-2

Analysis of State of North  Caroline ARARs
Ambient Air Quality
Standards
Establishes ambient  air  quality
standards
and methods for sulfur dioxide,
suspended
particulates, PM10,  carbon
monixide, ozone, nitrogen
dioxide, etc.
                                                                                                  total
Potentially applicable if  air
emissions are involved in  soil  or
ground water treatment
technology.
Regulations dealing with
stripping operations
NCDEHNR is in the process  of
promulgating regulations dealing
with air stripping operations.
These regulations, when
promulgated, may subj ect air
stripping operations  to toxic
regulations.  Currently,
registration of air strippers
is required.
Potentially applicable if  air
stripping is used as a treatment
technology.

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Under CERCLA, if a standard or requirement from state or federal environmental or public health
laws can reasonable be applied to a site cleanup or the development and evaluation of remedial
actions, that standard should establish the cleanup level. In accordance with the NCP
requirements under CERCLA, the selected remedial action must meet all ARARs unless a waiver from
a specific ARAR is qranted by EPA or the state of North Carolina. Typically waivers have been
qranted for one or more of the followinq situations:

! When interim measures are beinq considered or implemented, and will be followed by a
permanent or final remedial action that meets all ARARs.

! When compliance with an ARAR would create qreater threat to public health or the
environment than other options.

! When compliance with the ARAR is technically impractical.

! When a different or alternate method can meet the standard for an ARAR that specifies a
particular desiqn or operatinq standard.

! When a more strinqent state standard has not been applied consistently throuqhout the
state, the state standard may be waived.

! For EPA-lead CERCLA-funded cleanups, ARARs may be waived if their cost compared to the
deqree of protection or risk reduction qreatly reduce the availability of funds for other
sites.

VIII. REMEDIAL ACTION OBJECTIVES

Based on the results of the Operable Unit Three RI/FS and Baseline Risk Assessment, the textile
facility is comprised of several contaminated media. The Remedial Investiqation indicates that
on-site soil is contaminated with inorqanics, PAHs, and most notable VOCs. The second medium
consists of qroundwater contaminated primarily with VOCs. Surface water and sediment at the
seepintermittentttant stream to the north of the textile facility also reveal some contamination
with inorqanics, PCBs, and VOCs.

A. Soil Contamination

The analytical results of the Operable Unit Three Remedial Investiqation indicate that elevated
levels of several contaminants, mainly volatile orqanic compounds, are present at elevated
levels in the shallow and intermediate depth soil at the textile facility. No cleanup levels
have been established for on-site contaminated soil; however, the objective of a soil remedial
action would be to minimize the potential for infiltration of VOCs from the soil into the qround
water.

B. Groundwater Contamination

The vertical extent of VOC qroundwater contamination has been identified in the shallow and
intermediate portions of the aquifer, and is assumed to extend into the fractured bedrock
portion of the aquifer. The extent to which each of the VOCs has miqrated from the source areas
depends on a number of factors, includinq the location and depth of the source area(s), and the
physical properties affectinq the flow and transport of each compound (i.e., density,
solubility, viscosity, and surface tension). Table 8-1 contains the qroundwater remediation
levels, or the chemical-specific ARARs for the qroundwater contaminants of concern.

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IX. DESCRIPTION OF ALTERNATIVES

ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION

The following section describes the technologies considered for remediating the groundwater
associated with the textile facility. The section also provides the rationale as to why certain
technologies were not retained for further consideration after the initial screening. The
following alternatives were evaluated to address groundwater contamination.

Alternative GA-l:No Action

CERCLA reguires that the No Action Alternative be evaluated at every site to establish a
baseline for comparison. Under this alternative, no further action would be taken at the Site
to remove or treat groundwater contamination. A review of the remedy would be conducted every
five years in accordance with the reguirements of CERCLA. Five-year reviews would be conducted
for a period of 30 years; the total present worth costs of the five-year reviews $55,240.

Alternative GA-2:Limited Action

This alternative, like the No Action Alternative, would not involve actual remediation of
contaminated groundwater. This alternative would utilize deed restrictions to restrict access
to contaminated groundwater on-site. This alternative would also reguire the long-term
monitoring of Site groundwater based upon 30 years of monitoring. Sampling and analysis of
groundwater would be conducted semiannually for a period of 30 years. The total present worth
cost of Alternative GA-2, including establishing deed restrictions, monitoring the ground water
for 30 years, and conducting 5-year reviews for a 30-year period, is estimated to be $2,826,940.

Alternative GA-3:Air Sparging with Passive Venting

Air sparging is an in-situ remedial technology where air is introduced into the aguifer under
pressure through a number of wells, thereby causing the organic compounds in the groundwater to
volatilize. Alternative GA-3 would permanently reduce the amount of VOCs in the groundwater.
Passive venting means that no vacuum would be applied to the wells to actively remove the
volatilized compounds from the wells. Therefore, once the organic compounds have volatilized,
the vapors would discharge from the wells into the atmosphere. However, modeling would be
conducted during the Remedial Design to ensure that the North Carolina Air Emission Standards
would not be violated utilizing the passive venting. The total present worth costs for
Alternative GA-3 are estimated to be $2,944,700.

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TABLE 8-1
GROUNDWATER REMEDIATION LEVELS  (ug/1)

              CHEMICALS            REMEDIATION LEVELS (UG/L)

       Aluminum                           50-200  (1)
       Arsenic                                    50  (2)
       Barium                                     2000  (2)
       Iron                                 300 (2)
       Lead                                15  (3)
       Manganese                           50  (2)
       Bis(2-ethylhexyl)phthalate                 3  (2)
       Carbon Tetrachloride                       .3  (2)
       Chloroform                          .19 (2)
       1,1-DCE                                    7  (2,3)
       cis 1,2-DCE                         70  (2,3)
       1,2-Dichloropropane                         .5  (3)
       Methylene Chloride                          5  (3)
       Tetrachloroethane  (PCE)                     .7  (2)
       1,1,2-Trichloroethane                       5  (3)
       Trichloroethane                            2.8  (2)
       Vinyl Chloride                              .015  (2)

(1)  National Secondary Drinking Water Standards
(2)  North Carolina Ground Water Quality  Standards  (NCGWQS)  NCAC 2L.0202
(3)  Maximum Contaminant Levels  (MCLs)

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Alternative GA-4:Air Sparging with Active Venting

Air sparging is an in-situ remedial technology where air is introduced into the aguifer under
pressure through a number of wells, thereby causing the organic compounds in the groundwater to
volatilize. Alternative GA-4 would permanently reduce the amount of VOCs in the groundwater
on-site. Active venting means that positive vacuum would be applied to the wells to help induce
the volatilization of the organic compounds, as well as actively remove the volatilized
compounds from the wells. However, modeling would be conducted during the Remedial Design to
ensure that the North Carolina Air Emission Standards would not be violated utilizing the active
venting. The total present worth costs for Alternative GA-4 are estimated to be $3,030,200.

Alternative GA-5:Groundwater Extraction and Treatment by Chemical Precipitation and Carbon
Adsorption

This alternative would involve installing eight shallow and one deep bedrock recovery well for
the recovery and treatment of contaminated groundwater. A piping system would also be installed
to transport the groundwater from the wells to a holding tank and the treatment system.
Precipitation/filtration and carbon adsorption would be used to treat contaminated groundwater
for all site-related contaminants of concern. The treated groundwater would then be discharged
to either a nearby drainage ditch or to the publicly-owned treatment works. Long-term
monitoring of the groundwater around the site would be implemented. Institutional controls such
as deed restrictions would also be implemented. The total present worth costs for Alternative
GA-5 are estimated to be $8,451,560.

Alternative GA-6:Groundwater Extraction and Treatment with Chemical Precipitation, Air
Stripping, and Carbon Adsorption

This alternative would include all of the components of Alternative GA-5, plus a low-profile
tray-aeration air stripper. The carbon vessels used in this alternative would be smaller than
those used in Alternative GA-5. The total present worth costs for Alternative GA-6 is estimated
to be $7,288,710.

ALTERNATIVES TO ADDRESS SOIL CONTAMINATION

The following section describes the technologies considered for remediating the soil
contamination associated with the textile facility. The section also provides the rationale as
to why certain technologies were not retained for further consideration after the initial
screening.

Alternative SA-l:No Action

By law, EPA is reguired to evaluate a No Action Alternative to serve as a basis against which
other alternatives can be compared. No remedial action would be implemented under the No Action
Alternative. Contaminated soil would be left in place as a source of groundwater contamination.
Any reduction in contaminant concentrations in the soil would result from natural dispersion,
attenuation, and degradation processes. The present worth cost for Alternative SA-1 is
estimated to be $0.

Alternative SA-2:Limited Action

As with the No Action Alternative SA-1, no active remedial action would be conducted under the
Limited Action Alternative SA-2. The existing buildings and paved areas would be left intact.
The property deed would be amended to prohibit future uses of the site that would uncover or
expose contaminated soil beneath the buildings and paved areas. The deed restrictions would

-------
also specify that the property is only to be used for commercial and industrial purposes, and is
not suitable for residential or recreational purposes. Groundwater monitoring would be
conducted semi-annually for 30 years. The total present worth costs for Alternative SA-2 is
estimated to be $5,000.

Alternative SA-3:Capping

Capping the area(s) consists of covering an area with Low-permeability materials. As a result,
the infiltration of precipitation and surface water is reduced and the leaching of soil
contaminants is limited. Most of the textile facility is already covered by low permeability
materials such as buildings, concrete, and asphalt. Emplacement of new capping materials would
be considered in the event that soil contamination is discovered that has the potential for
threatening the ground water guality in an uncapped area of the textile facility. The total
present worth costs for Alternative SA-3 is estimated to be $12,500,000.

Alternative SA-4:Excavation and Off-site Disposal

Excavation reguires the physical removal of contaminated soils from the textile facility, and
disposing of the soils in an appropriate manner in compliance with Federal, state, and local
regulations. This process could be used in conjunction with an ex-situ remedial alternative
whereby the cleaned soil would be returned to the excavated areas, or a soil removal whereby the
excavated soils would be evaluated for waste characterization and disposed of at a properly
permitted facility. If off-site disposal were used, the excavated areas would be backfilled
with clean fill material from an off-site source. Due to the extremely large volume of
contaminated soil on the textile facility, the total present worth costs for Alternative GA-4 is
estimated to be $115,000,000.

Alternative SA-5:Soil Vapor Extraction

Soil Vapor Extraction (SEE) is an established technology for in-place soil treatment. It is
primarily applicable to treatment of VOC-contaminated soils. SEE treatment removes VOCs from
the soil by mechanically drawing air through the soil pore spaces. VOCs volatilize as the air
moves through the soil. The VOC-laden air is then collected and discharged or is subjected to
further treatment, depending on the amount and types of contaminants present.

SEE is accomplished by installation of an array of vapor extraction wells in the contaminated
portion of the unsaturated (vades) zone. The wells are manifolded to the suction side of air
blowers (vacuum pumps), creating a negative pressure in the wells and piping to draw air from
the soil. Each well is valved and can be adjusted to the desired air flow rate. Using these
valves, a SEE system has the flexibility to withdraw air from the most contaminated areas
(thereby maximizing the mass removal rate) or to operate at a lower mass emission rate as may be
reguired by the emissions treatment system. The total present worth costs for Alternative GA-4
is estimated to be $1,076,920.

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X.  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The remedial alternatives to address soil and groundwater contamination of the textile facility
using the none evaluation criteria as set forth in the NCP, 40 CFR 300,430 (e) (9) .   A brief
description of each of the nine evaluation criteria is provided below.

THRESHOLD CRITERIA

1.  Overall Protection of Human Health and the Environment addresses how an alternative as a
whole will protect human health and the environment.  This includes an assessment of how the
public health and the environment risks are properly eliminated, reduced, or controlled through
the treatment, engineering controls, or controls placed on the property to restrict access and
(future) development.  Deed restrictions are examples of controls to restrict development.

2.  Compliance with Applicable or Relevant and Appropriate Reguirements  (ARARs) addresses
whether or not a remedy complies with all state and federal environmental and public health laws
and reguirements that apply or are relevant and appropriate to the conditions and cleanup
options at a specific site.  If an ARAR cannot be met, the analysis of the alternative must
provide the grounds for invoking a statutory waiver.

PRIMARY BALANCING CRITERIA

3.  Long-term Effectiveness and Permanence refers to the ability of an alternative to maintain
reliable protection of human health and the environment over time once the cleanup levels have
been met.

4.  Reduction of Toxicity, Mobility, or Volume are the three principal measures of the overall
performance of an alternative.

The 1986 amendments to the Superfund emphasize that, whenever possible, EPA should select a
remedy that uses a treatment process to permanently reduce the level of toxicity of contaminants
at the site; the spread of contaminants away from the source of contaminants; and the volume, or
amount, of contamination at the site.

5.  Short-term Effectiveness refers to the likelihood of adverse impacts on human health or the
environment that may be posed during the construction and implementation of an alternative until
cleanup levels are achieved.

6.  Implementability refers to the technical and administrative feasibility of an alternative,
including the availability of materials and services needed to implement the alternative.

7.  Cost includes the capital (up-front) cost of implementing an alternative, as well as the
cost of operating and maintaining the alternative over the long-term, and the net present worth
of both the capital and operation and maintenance costs.

MODIFYING CRITERIA

8.  State Acceptance addresses whether, based on its review of the RI/FS and Proposed Plan, the
State concurs with, opposes, or has no comments on the alternative EPA is proposing as the
remedy for the Site.  The State's concurrence letter is attached as Appendix A.

9.  Community Acceptance addresses whether the public concurs with EPA's Proposed Plan.
Community acceptance of the Proposed Plan were be evaluated based on verbal comments received at
the public meetings and those written comments received during the public comment period.

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These evaluation criteria relate directly to requirements in Section 121 of CERCLA, 42 U.S.C. §
9621, which determine the feasibility and acceptability of the remedy. Threshold criteria must
be satisfied in order for a remedy to be eligible for selection. Primary balancing criteria are
used to weigh major trade-offs between remedies. State and community acceptance are modifying
criteria formally taken into account after public comment is received on the Proposed Plan.
Once the potential remedial alternatives to address soil and groundwater were developed and
screened, each alternative was subjected to detailed comparative analysis.

COMPARATIVE ANALYSIS OF GROUND WATER AND SOIL ALTERNATIVES

Threshold Criteria

Overall Protection of Human Health and the Environment

Each alternative was evaluated to determine whether it is likely to effectively mitigate and
minimize the long-term risk of harm to public health and the environment currently presented at
the Site. Alternatives GA-1 would not be effective in protecting human health and the
environment, while GA-2 would be somewhat protective as long as the deed restrictions were
implemented effectively. Alternatives GA-3, Ga-4, GA-5, and GA-6 would all be protective of
human health and the environment by reducing levels of all site-related contaminants to meet all
State and federal requirements.

Compliance with ARARs

Alternatives GA-1 and GA-2 would not reduce contaminant levels; therefore, they would not meet
the State Standards and Federal MCLs. EPA believes Alternatives GA-3, GA-4, GA-5 and GA-6 would
reduce contaminant levels to meet all State and Federal ARARs.

Primary Balancing Criteria

Short-term Effectiveness

Alternatives 1 and 2 would not reduce the site-related contamination on a short-term basis.

restrictions would be placed on future land use at the Site; therefore, Alternative GA-1 would
not eliminate any exposure pathways or reduce the level of risk. Deed restrictions implemented
under Alternatives GA-2, GA-3, GA-4, GA-5, or GA-6 would provide protection to nearby well users
as long as the restrictions are implemented effectively. Alternatives GA-3 and GA-4 offer a
greater amount of protection by reducing VOC concentrations on-site. Alternatives 3 and 4 could
be implemented without significant risks to on-site workers or the community, and without
adverse environmental impacts. Neither alternative GA-3 or GA-4 is effective at reducing levels
of inorganics in ground water. Alternatives GA-5 and GA-6 would offer greater protection to
human health and the environment than GA-1 and GA-2, and similar protection to GA-3 and GA-4.

Long-term Effectiveness and Permanence

Alternatives GA-1 and GA-2 would have no effect on the contaminant concentrations contributing
to the risks identified in the Baseline Risk Assessment. Therefore, any reduction in
contaminant concentrations in the long-term would be due to natural dispersion, attenuation, and
degradation processes. It is questionable whether remedial action objectives can be met through
natural processes in the foreseeable future. Groundwater contamination would continue to be of
potential risk to human health and the environment. The long-term effectiveness and permanence
of GA-2 would depend on how effectively the deed restrictions can be implemented. For GA-3 and
GA-4, effective and reliable performance would be expected from either air sparging system for

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VOC removal. For GA-5 and GA-6, effective and reliable performance would be expected from
either pump-and-treat system for the removal of VOCs and inorganics.

Reduction of Toxicity, Mobility, or Volume

Since Alternatives GA-1 and GA-2 provide no active treatment process, contaminants would degrade
only by passive, natural processes. The toxicity and mobility of the contaminated groundwater
may remain at current levels for an extended period of time. Both air sparging alternative
(GA-3 and GA-4) and both pump-and-treat system alternatives (GA-5 and GA-6) would effectively
reduce the toxicity, mobility, and volume of the contaminant plume.

Implementability

No implementation of Alternative GA-1 is needed. However, Alternatives GA-2, GA-3, GA-4, GA-5,
and GA-6 would reguire extensive coordination between State and local agencies in order to
implement the deed restrictions effectively. Alternatives GA-5 and GA-6 would reguire detailed
planning as well as coordination with local agencies to determine the most viable discharge
option.

Aguifer tests and additional characterization of the groundwater guality in the bedrock portion
of the aguifer would be needed prior to implementation of the pump-and-treat systems for GA-5
and GA-6. Alternatives GA-5 and GA-6 are technically feasible, but following installation of
the system, would reguire monitoring of the influent and effluent to determine the effectiveness
of the system.

Cost

The wide range of estimated costs for the groundwater and soil alternatives are presented below
in Tables 10-1 and 10-2, respectively.

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                           TABLE  10-1

Summary of Costs for Evaluated Ground Water Remedial Alternatives
Remedial Alternative

GA-l:No Action

GA-2:Limited Action

GA-3:Air sparging with
     passive venting

GA-4:Air Sparging with
Active Venting

GA-5:Recovery,
Precipitation/Filtration,
& Carbon Absorption
GA-6:Recovery,
Precipitation/Filtration, Air
Stripping, & Carbon
Absorption
Capital Costs

0

$5,000


$1,032,500


$1,063,260



$914,500



$934,950
Total Project
O&M Costs

$55,240

$2,826,940


$1,912,200


$1,966,940



$7,537,060



$6,353,260
Cost

$55,240

$2,826,940


$2,944,700


$3,030,200



$8,451,560



$7,288,710

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TABLE 10-1

Summary of Costs for Evaluated Ground Water Remedial Alternatives


Remedial Alternative

SA-l:No Action

SA-2:Limited Action

SA-3:Capping (entire site)

SA-4:Excavation and Disposal
(entire site)

SA-5:Soil Vapor Extraction
System2
Capital Costs
0
$5,000
$12,500,000
$115,000,000
$121,250
Total Project
O&M Costs
0
$0
$0
$0
$955,670
Cost
0
$5,000
$12,500



,000
$115,000,000
$1,076,
920

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1. On-going monitoring costs are not considered to be O&M costs for soil remediation since
these costs are already included in all GA options.

Modifying Criteria

State Acceptance

The NCDEHNR has reviewed and provided EPA-Region IV with comments on the Remedial Investigation
and Feasibility Study reports. The NCDEHNR also reviewed this Record of Decision and EPA's
preferred alternative and concurs with EPA's selection.

Community Acceptance

EPA received no comments during the 30-day comment period; therefore, there is no Responsiveness
Summary.

XI. THE SELECTED REMEDY

Based on consideration of the reguirements of CERCLA, the NCP, the detailed analysis of
alternatives and public and state comments, EPA has selected groundwater Alternative GA-4 and
soil Alternative SA-5 for the Operable Unit Three Remedial Action at the FCX-Statesville
Superfund Site. At the completion of this remedy, the risk associated with the Site is
projected to be within 10E-4 to 10E-6, the risk range generally accepted by EPA to be protective
of human health and the environment. The total present worth cost of Alternatives GA-4 and SA-5
is estimated to be $4,107,120 (assuming a 5% interest rate). Table 11-1 shows the capital costs
associated with Alternative GA-4 and Table 11-2 shows the annual operating and maintenance costs
associated with Alternative GA-4. Table 11-3 shows the capital costs associated with
Alternative SA-5 while Table 11-4 shows the operating and maintenance costs for Alternative
SA-5.

Ground Water Remediation

Ground water remediation will address the contaminated ground water at the Site. Ground water
treatment will continue at the Site until the performance standards have been met. Ground water
remediation will include designing and constructing a network of air sparging wells at and
around the textile facility. Figure 11-1 shows the proposed location of the air sparging wells.
The wells will be designed for maximum effectiveness. The system will be designed to operate 24
hours a day. System controls will allow complete automatic operation with minimal operator
attention. The installation of a piping system will be necessary to transport the air into the
aguifer.

The air sparging treatment system will reguire monitoring and maintenance. The performance
standards for the air sparging system include meeting all state and federal ARARs. Long-term
ground water monitoring will include sampling and analysis of the groundwater from the permanent
monitoring wells on a semi-annual basis for 30 years or until groundwater remediation levels are
met. Additional groundwater samples (unfiltered) will be collected and analyzed during the
remedial design to ensure that levels of inorganics are not of concern. Groundwater samples
will be analyzed for VOCs (EPA Method 8240), pesticides (EPA Method 8080), metals (EPA Method
6010), as well as a phthalate scan (EPA Method 8270) for cleanup verification purposes.
Long-term groundwater monitoring will also be used to track contaminant plume migration, and to
evaluate the progress of natural attenuation.

Groundwater contamination may be especially persistent in the immediate vicinity of the
contaminants' source where concentrations are high. The ability of the air sparging treatment

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system to meet the groundwater remediation levels throughout the affected area, or the
groundwater contamination plume, cannot be determined until the air sparging treatment system
has been implemented, modified if necessary, and plume response monitored over time.  If the
selected treatment system cannot meet the specified performance standards, at any or all of the
monitoring points during implementation, contingency measures and goals will be needed to
supplement or replace the selected remedy.  Such contingency measures, at a minimum, will
prevent further migration of the plume, and include a combination of containment technologies
and institutional controls, including deed restrictions.  These measures are considered to be
protective of human health and the environment, and are technically practicable under the
corresponding circumstances.

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TABLE 11-1
Cost Estimate for Air Sparging with Active Venting
Item
1
2

3
5

6


7
8
9

10

11


12

13
       Description
       Pilot Study
       Installation of Sparge Points
Quantity
       1
      20
       Piping installation!
       !   Trenching for air distribution piping  4,090
       !   Distribution pipe                           8,180
       !      Vent pipe                                400
       !      Cuttings disposal                         820 yd3
       Blower multistage centrifugal,  35 psi
       output @ 150 scfm,  w/ stand and                 2
       ancillary eguip.2
       Vacuum blower,  rotary lobe,  positive            2
       displacement,  5 Hp
       Air distribution manifold with control
       valves,  sample ports, and flowmeter            20
       connections
       Blower eguipment shed                          2
       Eguipment shed concrete pad                    2
       Deed Restriction                              1
              Subtotal
       Mobilization/demobilization,
       construction management (20%)
       Designs, specifications,  regulatory
       approval, and permits (20%)
       Subtotal
       Administration (15%)
       Subtotal
 Total
Unit Cost ($)
lump sum
7,250
                     25/ft
                     4.00/ft
                     4.00/ft
                     185.00/yd3

                     20,000

                     7,500


                     1,500

                     2,500
                     3,000
                     5,000
Cost ($)
40,000
145,000
                     102,250
                     32,720
                     1, 600
                     151,700

                     40,000

                     15,000


                     30,000

                     5,000
                     6,000
                     5,000
                     574,270

                     114,850

                     114,850
                     803,970
                     120,600
                     924,570
                     138,690
       Contingency (15%)

       Total Capital  Cost (rounded)                                                       1,063,260

Quantity of pipe reguired and length of trench based on tentative placement of sparge points and treatment system eguipment pad.

1.  Final blower sizing will depend on the results of the pilot study.

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TABLE 11-2
O&M Cost Estimate for Air Sparging with Active Venting

                                                                     Total
Item   Description                              Annual               Unit Cost  ($)        Cost/yr
                                                Quantity                                  ($)
1      Labor (est. at 5% of Capital Eguipment                        lump sum            28,700
       cost)
2      Maintenance (est. at 2% of Capital Cost)                       lump sum            11,480
3      Semi-annual Ground water monitoring
       (see GA-2)                                                                         125,420

4      Utilities
       !   electricity (40 Hp eguivalent)                             262,800              0.06/KWHR
                                                KWHR                 15,770
       Subtotal                                                                          181,370
5      Administrative (15%)                                                               27,200
       Subtotal                                                      208,580
6      Contingency (15%0                                             31,300
       Total O&M Cost per year                                                           239,880
7      Site Review by EPA,  every 5 years                                                 55,640
       Present Worth Cost (rounded)1                                                     1,966,940
       Total Alternative Cost                                                            3,030,200

1.  Present worth costs assume total O&M cost per year for 10 years and a money discount rate of 5%.

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TABLE 11-3
Capital Cost Estimate for Soil Vapor Extraction Systeml
Item   Description
1      Pilot Study
2      Installation of Extraction Points
Quantity
   1
   3
Unit Cost($)
lump sum
5,000
Total
Cost ($)
7,500
15,000
3      Piping,  linearl
       !   Trenching for air distribution piping
       !   Distribution pipe
4      Blower,  rotary lobe type,  capable of 10
       inch Hg vacuum at 100 scfrm,  w/ stand
       and ancillary eguip.2
5      Air collection manifold with control
       valves,  sample ports, and flowmeter
       connections
6      Vacuum blower eguipment shed
7      Eguipment shed concrete pad
8      Deed Restriction
                     Subtotal
9      Mobilization/demobilization,
       construction management (20%)
10     Designs,  specifications,  regulatory
       approval, and permits (20%)
                     Subtotal
14     Administration (15%)
                     Subtotal
15     Contingency (25%)

       Total Capital Cost (rounded)
  250
  600
25/ft
4.00/ft

10,000
              1,500
6,350
2,400

10,000
                     13,500
1
1
0







2,500
3,000
5,000
60,250


84,350

97,000
24,250
2,500
3,000
0

12,050
12,050

12, 650


                            121,250
1.  These costs assume installation of a VES system independently of air sparging.  If GA-4 is the selected remediation option,  essentially all costs for the VES
system are contained within that option and additional VES points will only minimally impact total project costs.
2.  Final blower sizing will depend on the results of the pilot study.

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TABLE 11-3
Capital Cost Estimate for Soil Vapor Extraction System

                                                                                  Total
Item   Description                              Quantity      Unit Cost($)         Cost  ($)
1      Labor  (est.  at 5% of Capital                          lump sum            4,220
       Equipment cost)
2      Maintenance (est.  at 2% of Capital                     lump sum            1,700
       Cost)
3      Semi-annual Ground water
       monitoring (see GA-2)                                                       125,420

4      Utilities
       !   electricity (7 Hp equivalent)                        46,000               0.06/KWHR     2,760
       Subtotal                                                                    134,100
6      Continqency (25%)                                                           38,500
       Total O&M Cost per year                                                    192,715
       Present Worth of O&Mcost                                                   834,420
       Total Alternative Cost                                                     955,670

1.  Present worth costs assume total O&M cost per year for 5 years and a money discount rate of 5%.

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In order to address areas of the ground water contamination plumes with low levels of VOCs,
ground water will be collected and evaluated during the remedial design to determine if natural
attenuation is taking place. Long-term monitoring of the groundwater entering and exiting the
air sparging system will also be reguired. Monitoring of the ground water discharging as
surface water at the seep will be reguired to ensure that no future unacceptable risks occur.
The following analytical parameters should be added to the current list of analytes to be
monitored for natural attenuation: dissolved oxygen, nitrate, iron (II), sulfate, sulfide,
methane, oxidation reduction potential, pH, temperature, chloride, and all other daughter
products of perchloroethene (trichloroethene, dichloroethene, vinyl chloride, ethene/ethane, and
chloroethane. Additional parameters may be added to accurately determine if biodegradation is
occurring. These parameters include dissolved organic carbon, carbon dioxide, alkalinity,
hydrogen, and volatile fatty acids. Once the information is collected, simulating natural
attenuation using a fate and transport model is needed to predict the migration and attenuation
of the contaminant plume through time. If it is determined that natural attenuation will not
result in the attainment of the remediation levels or performance standards, it may be necessary
to reopen the remedy.

The Remedial Action shall comply with all ARARs shown in Tables 7-1 and 7-2, including the
ground water remediation levels shown in Table 8-1. The presence of contamination in the ground
water will reguire deed restrictions to document their presence and could limit future use of
any area(s) known to be affected by the contaminated groundwater. The extent of the property
restrictions and limitations will be determined during the Remedial Design.

Soil Remediation

Soil remediation will address the VOC contamination in the soil at the Site. Soil remediation
will
continue until VOC concentrations have been reduced such that the ground water performance
standards have been met. Soil remediation will include designing and constructing a network of
vapor extraction wells in the contaminated portion of the unsaturated zone on and around the
textile facility. Figure 9 shows the proposed locations for the soil vapor extraction wells.
The
system is designed to operate 24 hours a day. System controls will allow complete automatic
operation with minimal operator attention. Refer to the Feasibility Study and the Upcoming
Remedial Design for details.

The soil vapor extraction treatment system will reguire monitoring and maintenance. The
objective of the soil vapor extraction system is to reduce the amount of volatile organic
compounds in the soil as a source of groundwater contamination. Periodic sampling of the soil
will be reguired to monitor the progress of the soil vapor extraction system

XII. STATUTORY DETERMINATION

Based on available information, the selected remedy satisfies the remedy selection reguirements
under CERCLA, as amended by SARA, and the NCP. The selected 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.

Protection of Human Health and the Environment

The selected remedy will permanently treat the ground water and remove the potential risk

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associated with the ground water contamination. The ingestion and inhalation contact with Site
contaminants would be eliminated. The selected remedy will also permanently treat the
contaminated soil, thereby reducing the source of groundwater contamination.

Compliance with ARARs

The selected remedy will comply with all Federal and State ARARs. No waivers of Federal or
State reguirements are anticipated for this Site at this time.

Cost Effectiveness

The selected groundwater technologies are more cost-effective than the other acceptable
alternatives considered. The selected remedies provide greater benefit for the cost because
they permanently treat the waste.

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

The selected remedy represents the maximum extent to which permanent solutions and treatment can
be practicably utilized for this Remedial Action.

Of the alternatives that are protective of human health and the environment and comply with
ARARs, EPA and the State have determined that the selected remedy provides the best balance of
trade-offs in terms of long-term effectiveness and permanence; reduction in toxicity, mobility,
or volume achieved through treatment; short-term effectiveness, implementability, and cost;
State and community acceptance, and the statutory preference for treatment as a principal
element.

Preference for Treatment as a Principal Element

The preference for treatment is satisfied by the use of air sparging with active venting for
treatment of contaminated ground water, and soil vapor extraction for treatment of contaminated
soil. The principal threats at the Site will be mitigated by the use of these treatment
technologies.

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Appendix A

State of North Carolina
Department of Environment
Health and Natural Resources
Division of Waste Management

James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director

26 September 1996
Mr. Ken Mallary
Superfund Branch
US EPA Region IV
100 Alabama Street
Atlanta, Georgia 30303

RE: Conditional State Concurrence with the Record of Decision (ROD)
FCX, Inc. (Statesville) OU-3
Statesville, Iredell County

Dear Mr. Mallary,

The North Carolina Superfund Section has received and reviewed the attached Record of Decision
(ROD) for the FCX, Inc. (Statesville) OU-3 Superfund Site and concurs with the selected remedy
subject to the following conditions:

1. Our concurrence on this ROD and of the selected remedies for the site is based solely on
the information contained in the attached ROD and to the conditions listed here. Should we
receive additional information that significantly affects the conclusions or remedies contained
in the ROD, we may modify or withdraw this concurrence with written notice to EPA Region IV.

2. Our concurrence on this ROD in no way binds the State to concur in future decisions or
commits the State to participate, financially or otherwise, in the cleanup of the Site. The
State reserves the right to review, comment, and make independent assessments of all future work
relating to this Site.

3. If, after remediation is complete, the total residual risk level exceeds 10-6, the State
may reguire deed recordation/restriction to document the presence of residual contamination and
possibly limit future use of the property as specified in NCGS 130A-310.8.

We appreciate the opportunity to comment on this ROD and look forward to continuing to work with
the EPA to remediate this Site.

Sincerely,

Jack Butler, PE
Section Chief
Superfund Section
Attachment
cc: Mike Kelly
Philip A. Vorsatz

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