HRS DOCUMENTATION RECORD — REVIEW COVER SHEET

Name of Site:	Wright Chemical Corp.

NCD 024 766 719

Contact Persons:

U.S. Environmental Protection Agency, Region 4:

(Name)

Jennifer Wendel
NPL Coordinator

(Telephone)

(404) 562-8799

North Carolina Department of Environment and Natural Resources:

Site Investigation: (Name)

Jeanette Stanley

(Telephone)
(919) 508-8453

(919)

Documentation Record:

Jeanette Stanley

(919) 508-8453

Pathways, Components, or Threats Not Scored:

Ground Water Migration Pathway

The ground water pathway was not scored because scoring the ground water
pathway would have a minimal impact on the site score.

Surface Water Drinking Water threat/targets

The drinking water threat was not scored because there is no drinking water
intake within the 15-mile surface water pathway downstream of the site.

Surface Water Environmental Threat

Environmental targets/threats were not scored because scoring the observed
release to the fishery almost maximized the pathway score. The addition of the
surface water environmental threat score would have minimal impact on site
score.

Soil Exposure Pathway

The soil exposure pathway was not scored because the soil exposure pathway has
a minimal impact on the overall site score.

Air Migration Pathway

The air pathway was not scored because scoring the air pathway would have a
minimal impact on the site score.


-------
HRS DOCUMENTATION RECORD

Name of Site:

EPA Region:

Date Prepared:

Street Address of Site*:

City, County, State, and ZIP:

General Location in the State:

Wright Chemical Corp.

4

March 2010
State Rd. 1878

Riegelwood, Columbus County, NC 28456
Coastal Plain

Topographic Map:	Acme

Latitude*: 34.3284ฐ north latitude
Longitude*: 78.2051ฐ west longitude

Location is approximate center of

denuded area (Source 1)

(Ref. 4, pp. 1, 105, 106; Figs. 1, 4)

Scores

Air Pathway — Not Scored
Ground Water Pathway — Not Scored
Soil Exposure Pathway — Not Scored
Surface Water Pathway — 96.06

HRS SITE SCORE
48.03

* The street address, coordinates, and contaminant locations presented in this HRS documentation record identify
the general area the site is located. They represent one or more locations EPA considers to be part of the site based
on the screening information EPA used to evaluate the site for NPL listing. EPA lists national priorities among the
known "releases or threatened releases" of hazardous substances; thus, the focus is on the release, not precisely
delineated boundaries. A site is defined as where a hazardous substance has been "deposited, stored, placed, or
otherwise come to be located. " Generally, HRS scoring and the subsequent listing of a release merely represent the
initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EPA contemplates
that the preliminary description offacility boundaries at the time of scoring will be refined as more information is
developed as to where the contamination has come to be located.

1


-------
WORKSHEET FOR SITE SCORE

1. Ground Water Migration Pathway Score
2a. Surface Water Overland/Flood Migration
Drinking Water Threat

Not Scored

Not Scored

Food Chain Threat

96.06

Environmental Threat

Not Scored

Surface Water Overland/Flood Migration Component

(subject to maximum value of 100, Ref. 1, Section 4.1.5) 96.06

3.	Soil Exposure Pathway Score	Not Scored

4.	Air Migration Pathway Score	Not Scored

5.	Total of Sgw2 + Ssw2 + Ss2 + Sa2 =	9.227.52

6.	HRS Site Score: Value on line 5. divided by four,

then take the square root		48.03

S2

Not Scored

Not Scored

9227.52
Not Scored

9227.52

Not Scored

Not Scored

2


-------
1

2

3

4

5

6

7

8

9

1

2

3

4

5

6

7

8

WRIGHT CHEMICAL CORP.

RIEGELWOOD, COLUMBUS COUNTY, NC

LIST OF FIGURES

US Geological Survey, Acme Topographic Quadrangle Map, 1984

Sanborn Fire Insurance Map, 1889

Sanborn Fire Insurance Map, 1910

Source Detail Area with Wetland Boundaries

Oak Bark Holdings

Livingston Creek and Cape Fear River
2007 ESI Sample Location Map
Wetlands

Acme, NC Wetland Inventory Map

LIST OF TABLES
Source Soil and Background Soil Samples
Source Soil and Background Soil Results
Background Sediment Samples
Background Sediment Sample Results
Sediment Samples
Sediment Sample Results

Source 1 Contaminants Documented in Observed Release to Sediment in the Fishery

Source 1 Contaminants Documented in Source with Containment Factor of 10, not
documented in Observed Release to Fishery Sediment

3


-------
WRIGHT CHEMICAL CORP.

RIEGELWOOD, COLUMBUS COUNTY, NC
LIST OF REFERENCES

1.	US Environmental Protection Agency, Hazard Ranking System, Final Rule, 55 FR
51532, 1990.

http://www.epa.gOv/superfund/sites/npl/hrsres/index.htm#HRS%20Rule. Table of
Contents and Sections 1-6. Excerpt. 75 pages. A complete copy of the Hazard
Ranking System document is available in the Region 4 Docket.

2.	US Environmental Protection Agency, Superfund Chemical Data Matrix (SCDM).

Office of Solid Waste and Emergency Response. Directive 9345.1-13. 2004. Appendix
BI. Excerpt. 15 pages. A complete copy of SCDM is available at
http://www.epa. gov/ superfund/ sites/npl/hrsres/tool s/ scdm .htm.

3.	US Geological Survey, 7.5-minute (1:24,000) topographic quadrangle maps of North
Carolina; Acme, NC, 1984; point Caswell, NC, 1997; and Freeman, NC, 1986. 3 maps
merged and modified into one showing radii and target information.

4.	Expanded Site Inspection, Wright Chemical Corp. Site, NCD 024 766 719, Riegelwood,
Columbus Co., NC, Jeanette Stanley, NC Superfund Section, May 30, 2008. 579 pages.

5.	US EPA, Office of Solid Waste and Emergency Response, Multi-Media, Multi-
Concentration, Inorganic Analytical Service for Superfund (ILM05.3), February 2004. 4
pages.

6 US EPA, Office of Solid Waste and Emergency Response, Multi-Media, Multi-

Concentration, Organic Analytical Service for Superfund (SOM01.1), January 2006.
6 pages.

7.	Stanley, Jeanette S., Chemist, NC Superfund Section, Memo to File, December 9, 2009.
SUBJECT: Source of base maps and elements for Figures 4-9. 1 page.

8.	Stanley, Jeanette S., Chemist, NC Superfund Section, Memos (2) to File, December 17,
2009 and December 18, 2009. Bateson, James, Environmental Engineering Supervisor,
NC Superfund Section, Memo to File, January 29, 2010 8 pages.

9.	Parker, Stuart F. Geologist, NC Superfund Section, Kaiser Acme Farmarket Site Re-
Assessment Report, August 13, 2004. 12 pages.

10.	Pettergarrett, Stephanie, Environmental Scientist, NC DENR Water Quality Section,
email correspondence with Jeanette Stanley, December 17, 2009. 2 pages.

4


-------
MILES

api

NCDENR

Site: Wright Chemical Corp.

NCD 024 766 719

Columbus Co., NC

Figure 1: USGS Topographic Map, Acme

Scale: As Shown

Date: 09/18/08

Drawn By: JSS

Map date: 1984


-------
SOURCE: Sanborn Fire Insurance Maps, Wilmington, NC, sheet 16, 1889

Site: Wright Chemical Corp.

NCD 024 766 719

Columbus Co., NC

Figure 2: Sanborn Fire Insurance Map, 1889

Scale: As Shown

Date: 02/12/08

Drawn By: JSS


-------
ibers

SOURCE: Sanborn Fire Insurance Maps, Wilmington, NC, sheet 34, 1910

Site: Wright Chemical Corp.

NCD 024 766 719

Columbus Co., NC

Figure 3: Sanborn Fire Insurance Map, 1910

Scale: As Shown

Date: 02/12/08

Drawn By: JSS


-------
Site: Wright Chemical Corp. NCD 024 766 719

Aerial Photo date 2007

NCDENR

See Ref. 7 of HRS Doc Record for figure source information

Date: 01/27/2010

Coiumbus Co., NC

Drawn By: JTB

Figure 4: Source Area Detail with Wetland Boundaries


-------
M

•+

International Paper,
aka Federal Paper Board

OWNER

ACRES

OAK BARK CORPORATION

23.61

OAK BARK CORPORATION

3.53

OAK BARK CORPORATION

37.62

OAK BARK CORPORATION

81

OAK BARK CORPORATION

78.54

OAK BARK CORPORATION

145

OAK BARK CORPORATION

21.99

OAK BARK CORPORATION

0.95

OAK BARK CORPORATION

34

OAK BARK CORPORATION

15

OAK BARK CORPORATION

60.47

OAK BARK CORPORATION

58.58

OAK BARK CORPORATION

24,15

OAK BARK CORPORATION

137,8

OAK BARK CORPORATION

17.65

Total

739.9

Oak Bark properties shown
in yellow (color) or medium
grey (black & white)

1 1

. kaisEURCiT' s?

i

~ 1/4 mile

See Ref. 7 of HRS Doc Record
for figure source information

Site: Wright Chemical Corp.

m

NCDENR

NCD 024 766 719

Columbus Co., NC

Figure 5: Oak Bark Holdings

Aerial Photo date - 2007

Date: 02/12/08; rev. 12/09/09

Drawn By: JSS


-------
See Ref. 7 of HRS Doc Record for figure source information

Site: Wright Chemical Corp.

ncdInr

NCD 024 766 719

Columbus Co., NC

Figure 6: Livingston Creek and Cape Fear River

Aerial Photo Date: 2004

Date: 05/21/08; rev. 12/09/09

Drawn By: JSS


-------
-500'

- Sediment
= Samples

H Soil

Samples

See Ref. 7
of HRS Doc
Record for
figure source
information

Site: Wright Chemical Corp.

m

NCDENR

NCD 024 766 719

Columbus Co., NC

Figure 7: 2007 ESI Sample Location Map

Aerial Photo Date:

Date: 03/27/08; rev. 12/08/09

Drawn By: JSS / HZ


-------
m

NCDENR

Site: Wright Chemical Corp.

NCD 024 766 719

Columbus Co., NC

Figure 8: Wetlands

Aerial Photo date - 2007

Date: 02/12/08; rev. 12/09/09

Drawn By: JSS


-------
. :x. :	. PUE^

V , PEMIFhiC^*

>/p FOt/V^

ft ; 			/ V '	 /

"^ฆpUBHn	* - - /

- 'V' •

ฆ BM - .j

I	J' V

"iWฎ ' "^UBHhU

'\*yDelufcX

t'-'iMA

s, Pfoi/Zf' ฆ. y—PFOIC

< /	PFOIA-

FOIA •/

f^lOOO' ' '

* BM> //

NCDENR

Site: Wright Chemical Corp.

NCD 024 766 719

Columbus Co., NC

Figure 9: Acme , NC Wetland Inventory Map

Scale: As Shown

Date: 12/14/09

Drawn By: JSS

Map Date: 1994


-------
2.0 Site Description

Wright Chemical Corp is located in Columbus County, NC in an industrial / rural area.
The facility and Riegelwood are served potable water by a surface water intake on the Cape Fear
River upstream of the site (Ref. 4, pp. 128; Fig. 1). This area of Columbus County is the home
of several large industrial facilities surrounded by residential properties, agricultural fields and
wetlands. The portion of the facility being evaluated drains to Livingston Creek and
subsequently to the Cape Fear River (Ref. 7, p. 1, Figs. 1, 4, 6, 8, 9).

The original business on the Wright Chemical Corp. property was Acme Chemical.

Acme Chemical was a fertilizer and sulfuric acid manufacturing facility founded in 1883 (Ref. 4,
pp. 244, 401; Figs. 2, 3) and was a family-owned company for four generations (Ref. 4, p. 401).
The original Acme sulfuric acid plant was a lead-lined "chamber-process" plant which thermally
extracted sulfur from pyrite. Pyrite ore commonly contains traces of arsenic, selenium, nickel,
cobalt, and thallium. (Ref. 4, pp. 109, 186). "Lead Acid Chambers" are marked on the 1898 and
1910 Sanborn Fire Insurance maps (Ref. 4, pp. 173-179; Fig 3). A comparison of early Sanborn
Fire Insurance Maps with 1961, 1965, 1994, 2004 and 2007 aerial photographs confirms the
location of the lead chambers (Ref. 4 pp. 115-117; Figs. 2, 3, 4, 5).

The second acid plant on the Wright Chemical Corp facility property was a "contact-
process" plant, which metal-catalyzed a refined sulfur feedstock. However, due to the
corrosivity of sulfuric acid, lead-lined components were typically used in both processes (Ref. 4,
pp. 109, 115-117, 161-162). Wright Chemical constructed several surface impoundments on the
northern property during the 1970s (Ref. 4, pp. 109, 117, 120, 128). Acid manufacturing
occurred on this property until 1991, and the buildings have since been demolished (Ref. 4, p.
109; Ref. 8, pp. 3-5). The Wright Chemical Corp facility property was sold to Oak Bark
Corporation in 2004 (Ref.4, pp. 397, 453, 454).

The Wright Chemical Corp. site contains denuded, magenta-colored soil primarily on two
parcels totaling about 80 acres (Ref. 4, pp. 29-32, 88, 92, 115, 116, 453, 454; Ref. 8, pp. 3-8;

Figs. 4, 5). Aerial photos indicate stressed or absent vegetation extending to the creek channel
(Ref. 4, pp. 109, 115-117, 180-182; Fig. 4). The magenta soil coloration is characteristic of
former lead chamber sulfuric acid manufacturing facilities (Ref. 4, pp. 215). Primary
contaminants are lead and arsenic, but numerous other inorganics and some pesticides were
detected in this area of denuded magenta colored soil (Ref. 4, pp. 72-81, 215; Ref. 9, pp. 1-12).

The HRS score is based on one source — denuded, contaminated soil, and a release of site
contaminants to sediment in the fishery. While there are extensive wetlands along the surface
water pathway (Ref. 7. p. 1; Fig. 9), the environmental threat was not scored because it does not
make a significant additional contribution to the site score. Samples used for this documentation
were collected on April 10, 2007 and were collected according to the Sampling and Analysis
Plan and Quality Assurance Project Plan (SAP/QAPP) (Ref. 4, pp. 99-104).

14


-------
SD -Characterization and Containment

Source No.: 1

SOURCE DESCRIPTION

2.2 Source Characterization

Number of the Source: 1

Name and description of the source:

In the 1880s, Acme Manufacturing began operating a lead chamber sulfuric acid and
fertilizer manufacturing facility on the property, which operated until the 1960s or 1970s (Ref. 4,
pp. 3, 9, 10, 108, 109, 173 - 179, 244). The Wright Chemical Corp. facility includes an area of
stressed vegetation and magenta-colored soil (Ref. 4, pp. 3, 88, 92, 116, 117; Fig. 4)
characteristic of former lead chamber sulfuric acid manufacturing facilities (Ref. 4, pp. 213 -
215). This magenta-colored soil is primarily on two parcels totaling about 80 acres owned by
Oak Bark Corporation (Ref. 4, pp. 453, 454; Figs. 4, 5). A comparison of an early Sanborn Fire
Insurance Map with recent aerial photography confirms the former lead chambers location (Ref.
4, pp. 4-7, 173 - 179; Figs. 2, 3, 4, 5). Numerous other chemical operations have been and
continue to be conducted on adjacent property (Ref. 4, pp. 9, 10); however, the focus of this
documentation record is the past lead chamber sulfuric acid manufacturing facility.

HRS Source Type: Contaminated Soil

The source is contaminated soil as defined by samples WC-011-SS, WC-012-SS and
WC-013-SS documented in the Table 1. These samples were collected near the former lead
chambers and in the area where both 1) waste materials were placed and 2) overland flow from
the former lead/acid chambers on the facility was received (Ref. 8, p. 7; Fig. 4). This area of
denuded soil has a purplish/magenta coloration and appears fairly consistent between the three
samples (Ref. 8, pp. 1, 3-5). This area remains unfenced and is outside any runoff control
features. (Ref. 8, pp. 1, 3-5) It is accessible but there are no signs of recreation. (Ref. 8, pp. 1, 3-

5)

The source area was observed to consist of three contiguous subareas. These areas are,
from south to north: Area a) an upland area of denuded soils where the former lead chambers had
been located, Area b) a wooded slope covered at least in part with bulldozed material similar to
that observed in the former lead chamber area a), and Area c) a lowland area of contaminated
soils. Source soil sample WC-012-SS was collected from Area a) while source soil samples
WC-011-SS and WC-013-SS were collected from Area c), which extends to the probable point
of entry (PPE) into Livingston Creek, and coincides, generally, with an area classified as non-
HRS qualifying wetland type PUBH (Ref. 8, p. 7; Fig. 4).

Area a) was void of vegetation and generally flat, with a discontinuous low berm on its
northern edge. Parts of the flat areas and all of the berm area contained bricks, bits of wood,
concrete and mortar, and pieces of clinker or slag. Soils in this area were of a magenta color
characteristic of lead contaminated soils observed by NC Superfund and EPA project staff at

15


-------
SD -Characterization and Containment

Source No.: 1

similar phosphate fertilizer sites under CERCLA assessment or remediation in the southeastern
United States (Ref. 8, p. 7; Fig. 4).

Area b) borders area a) and is sloped to the north, toward the floodplain of Livingston
Creek. Debris and soil similar to that observed in the berm above was visible on parts of the
slope. The slope is traversed by a roadbed leading west-northwest down to the floodplain. The
slope is not wooded on the east-northeast side of this road. The shadow line of the woods makes
the road location visible on Figure 4, located midway between sample locations WC-011-SS and
WC-012-SS (Ref. 8, p. 7; Fig. 4). However, there were no samples collected from this area to
confirm the presence of site hazardous substances.

Area c) contains a roughly circular area completely devoid of vegetation, approximately
200 feet across, visible on Figure 4 as a lighter colored area extending northwest from samples
WC-011-SS and WC-013-SS. The lighter colored ground appeared to consist of a number of
overlapping or coalescing low waste piles. The material consists of a mix of these larger
fragments with magenta colored sand and clay-sized material. It appears this material was
trucked down the road and dumped in place (Ref. 8, p. 7).

Location of the source, with reference to a map of the site:

North of railroad tracks and west of chemical manufacturing facility (Figs. 1, 4, 7)

Containment

Release via overland migration and/or flood —

Contaminated soil is outside any controlled runoff feature and is available for continuous
and ongoing overland flow (Ref. 1, Table 4-2; Ref. 8, pp 1. 3-5).

An observed release of site contaminants to Livingston Creek (Ref. 1; Ref. 4, pp. 34, 36,
41,47, 65, 66; Table 4-9)

Containment factor: 10

16


-------
SD-Hazardous Substances
Source No.: 1 (Contaminated soil)

2.4.1 Hazardous Substances

On April 10, 2007 NC Superfund Section collected three source surface soil samples and
one background surface soil sample, as summarized in Tables 1 and 2 below (Fig. 4). Samples
were collected according to the Sampling and Analysis Quality Assurance Project Plan
(SAP/QAPP) (Ref. 4, pp. 99-104), which was developed in accordance with the NC Superfund
Section Quality Assurance Program Plan (QAPP) and Quality Assurance Standard Operating
Procedures (QASOP). The QASOP adopts by reference the Field Branches Quality System and
Technical Procedures, U. S. Environmental Protection Agency, Region 4. The Program Plan is
derived directly from the EPA-Approved NC Department of Environmental and Natural
Resources QA Plan for Data, 2004 (Ref. 4, pp. 99-104). Samples were shipped to a Contract
Laboratory Program (CLP) laboratory (A4 Scientific) and analyzed for total metals by ICP-AES
and cyanide analysis by Statement of Work (SOW) ILM05.3 and they were analyzed for
pesticides per method SOM01.1 (Ref. 4, pp. 34; Refs. 5, pp. 2-4; Ref. 6, pp. 1-6). A US EPA
Region 4 Science and Ecosystem Support Division Quality Assurance Chemist reviewed and
validated this data for performance according to the Statement of Work (Ref. 4, pp. 33, 34, 67-
69).

The depths of the background and source soil samples were all similar (Table 1). The
source area was observed to be denuded and the level of contamination in the source area likely
prevented growth of any vegetation for years (Refs. 8, pp. 1, 3-5). The purple/magenta
coloration in the source samples is indicative of the lead / arsenic contamination (Ref. 4, pp.
215). Tables 1 and 3 contain summary of field observations and references to these
observations.

17


-------
SD-Hazardous Substances
Source No.: 1 (Contaminated soil)

Table 1. Source Soil and Background Soil Samples

Source
Samples

Date; Time

Description

WC-011-SS

4/10/07; 1410

(Ref. 4, pp. 35, 70, 88, 92,

95, 97)

Surface soil sample (0-9") in denuded
area in a wetland with purple soils.
Purple sand was encountered until 2"
- 6" when wet sand was found
(Ref. 4, pp. 88, 92; Fig. 7)

WC-012-SS

4/10/07; 1345

(Ref. 4, pp. 35, 70, 88, 92,

96, 98)

Surface soil sample (0-9") collected on
top level by plant area. Purple soils
encountered. (Ref. 4, pp. 88, 92; Fig.
7)

WC-013-SS

4/10/07; 1420

(Ref. 4, pp, 35, 70, 88, 93,

96, 98)

Surface soil sample (0-6") in area of
purple soil in wetland area. All purple
sand. (Ref. 4, pp. 88, 93; Fig. 7)

WC-014-SS

4/10/07; 1200

(Ref. 4, pp. 35, 70, 87, 91,

96, 98)

Background surface soil (0-9"), Root
& organics (0 - 3", silty sand 3 - 6",
fine sandy loam 6-9". Refusal at 9"
(Ref. 4, pp. 87, 91; Fig. 7)

18


-------
SD-Hazardous Substances
Source No.: 1 (Contaminated soil)
Table 2. Source Soil and Background Soil Results 	

Units









WC-014-SS*

mg/kg

CRQL

WC-011-SS

WC-012-SS

WC-013-SS

(Background)



(Ref. 5)

Ref. 4, pp. 34,

36, 57,

Ref. 4, pp. 34,

36, 59

Ref. 4, pp. 34, 36,
61,62

Ref. 4, pp. 34, 36,

63











8.3 UJ

Antimony**

6

69 J [34.8]

63 J [31.8]

86 J [43.4]

(8.3 U)

Arsenic**

1

430 J [2471

700 J [4021

900 J [5171

1.4 J*

Cadmium

0.5

42

31

40

0.69 U

Copper**

2.5

210 J [172]

720 J [590]

890 J [730]

1.9 J* (3.5 U)





3500 J

7800 J

10000 J



Lead**

1

[2430]

[5417]

[6944]

16 J [23]

Manganese

1.5

32

27

27

8.9











0.056 J* (0.50

Mercury

0.1

2.4

2.4

35

U)

Nickel

4

20

17

19

1.9 J* (5.5 U)

Silver

1

18

29

43

1.4 U

Thallium

2.5

16

22

28

3.5 U

Zinc

6

7500

4700

6700

14 J

J = estimated value

"U" indicates non-detect. The number adjacent to the "U" or inside () is the MRL.

[ ] provides the adjusted value for the estimated (J'd) value as adjusted for bias (Ref. 4, pp. 266 - 283).

*() = Minimum Reporting Limit (MRL) is shown in parentheses when a trace value is reported below the MRL.

The MRL is the analyte concentration which corresponds to the lowest quantitative point on the calibration curve or

the lowest demonstrated level of acceptable quantitation (Ref. 4, p. 36).

Trace levels below reporting limits are treated as non-detect (Ref. 1, Table 2-3; Ref. 4, p. 269).

** Flagging of data in the data reports (Ref. 4, pp 37 - 86) is inconsistent with statements in the data report (Ref. 4,
pp. 34, 68). Generally, the narrative indicates some data should be J-qualified while data sheets did not show a J.
Where a conflict appeared, the data was treated as J'd and subsequently adjusted as appropriate. Data were adjusted
per "Using Qualified Data to Document an Observed Release and Observed Contamination", to illustrate the relative
increase of hazardous substance concentrations of background levels (Ref. 4, pp. 266-283). This is a conservative
approach.

**Arsenic and copper results are J'd due to high bias (Ref. 4, p. 34). Background is not adjusted; source/release
results are adjusted downward by correction factor of 1.74 for arsenic and 1.22 for copper (Ref. 4, pp. 270, 283).
Antimony and lead results are J'd due to uncertain bias. Because matrix spike sample recovery for antimony and
lead were low, and because performance evaluation sample recovery were "action high" (Ref. 4, p. 34), data was
adjusted based on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is adjusted upward and source/release
results are adjusted downward by correction factor of 1.98 for antimony and 1.44 for lead (Ref. 4, pp. 270, 283).

BOLD = Observed contamination, which is greater than or equal to 3 times background when detected in
background, or greater than background quantitation limit (aka MRL) and CRQL if background is non-detect (Ref.
1, Table 2-3; Ref. 4, p. 266). Note that source samples were compared to background soil sample in Table 2.

19


-------
SD-Hazardous Substances
Source No.: 1 (Contaminated soil)

Soil background hazardous substance and concentration summary

Level shown without "U" is level detected above MRL. J'd levels below MRL are treated as
non-detect (Ref. 1, Table 2-3; Ref. 4, p. 269). The number shown in parentheses is the higher of MRL or
CRQL.

Antimony

non-detect (8.3 UJ, [8.3 U] mg/kg)

Arsenic

1.4 J mg/kg

Cadmium

non-detect (0.69 U mg/kg)

Copper

non-detect (3.5 U mg/kg)

Lead

23 mg/kg

Manganese

8.9 mg/kg

Mercury

non-detect (0.5 U mg/kg)

Nickel

non-detect (5.5 U mg/kg)

Silver

non-detect (1.4 U mg/kg)

Thallium

non-detect (3.5 U mg/kg)

Zinc

14 J mg/kg

Source hazardous substances and concentration summary (estimated concentrations adjusted for bias,
where appropriate)

Antimony

ranging from 31.8-43.4 mg/kg

Arsenic

ranging from 247 - 517 mg/kg

Cadmium

ranging from 31 - 42 mg/kg

Copper

ranging from 210 - 730 mg/kg

Lead

ranging from 2,430 - 6,944 mg/kg

Manganese

ranging from 27-32 mg/kg

Mercury

ranging from 2.4-35 mg/kg

Nickel

ranging from 17-20 mg/kg

Silver

ranging from 18-43 mg/kg

Thallium

ranging from 16-28 mg/kg

Zinc

ranging from 4,700 - 7,500 mg/kg

20


-------
SD-Hazardous Waste Quantity
Source No.: 1 (Contaminated Soil)

2.4.2 Hazardous Waste Quantity

2.4.2.1.1	Hazardous Constituent Quantity —

Sufficient evidence does not exist to evaluate Hazardous Constituent Quantity

2.4.2.1.2	Hazardous Waste stream Quantity —

Sufficient evidence does not exist to evaluate Hazardous Waste stream Quantity

2.4.2.1.3	Volume —

Sufficient evidence does not exist to evaluate Volume

2.4.2.1.4	Area

Three points were collected in the former lead chamber / surface impoundment
area; the area of contaminated soil is determined to be >0 (Ref. 4, pp. 108, 109,
115-117, 120, 128, 161 173-179, 180-182, 186; Figure 3)

Area assigned value (Ref. 1, Table 2-5)

= A/34,000 = > 0

2.4.2.1.5 Source Hazardous Waste Quantity Value = >0

21


-------
SD-Summary

SITE SUMMARY OF SOURCE DESCRIPTIONS

Containment

Source Hazardous Waste Quantity Ground Surface Air

No. Value	Water	Water	Gas Particulate

1 >0	NS	10	NS	NS

Sum of Source Hazardous Waste Quantity Values = >0
(Rounded to nearest integer, per Ref. 1, Section 2.4.2.2)

22


-------
SWOF — Surface Water Overland Flow/Flood Migration Pathway

4.0	SURFACE WATER MIGRATION PATHWAY

4.1	OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1.1 DEFINITION OF HAZARDOUS SUBSTANCE MIGRATION PATH FOR
OVERLAND/FLOOD COMPONENT

Source 1 drains northward to Livingston Creek. Historically, there could have been
several Probable Points of Entry (PPEs) to the perennial surface water pathway into Livingston
Creek (Ref. 4, pp. 18, 228-231); however, the precise location of former PPEs cannot now be
determined because buildings and old impoundments have been removed (Ref. 4, pp. 109, 117)
Two of the three source samples (WC-011-SS and WC-013-SS) (Ref. 4, pp. 88, 93; Ref. 7, p. 1;
Figs. 7, 9) were collected within an area described as a wetland area adjacent to Livingston
Creek (Ref. 8, p. 6); however, this area does not meet the 40 CFR 230.3 definition of a wetland
due to the lack of hydrophytes, therefore, the source lies along the overland flow pathway and
the PPE is the point where the overland flow enters Livingston Creek (Fig. 4). A portion of this
source area appeared to consist of low overlapping piles (Ref. 8, p.7) in the wetland area. From
Source 1, the overland drainage route flows downgradient approximately 100 feet northward to
Livingston Creek, a perennial water body, marking the start of the in-water segment of the
surface water migration pathway and the 15-mile target distance limit (TDL) (Figs. 1, 4).

Livingston Creek is about 29 feet wide and about 3 feet deep in most locations (Ref. 4, pp. 18,
350). Livingston Creek's flow below the Wright Chemical Corp. facility property is slightly
greater than 100 cfs, making it a moderate-to-large stream (Ref. 1, Table 4-13; Ref. 4, pp. 18,
250, 259, 260, 262). Below the PPE, Livingston Creek meanders in a generally northerly
direction for three miles through extensive wetlands, and then flows into the Cape Fear River
(Ref. 4, pp. 2, 124; Figs. 1, 6, 8, 9). Livingston Creek flows past landfills associated with the
International Paper facility (Figs. 6, 8). There is tidal flow reversal in Livingston Creek (Ref.
10, pp. 1, 2).

Mill Creek is upgradient and to the northeast of Source 1 and enters Livingston Creek
downstream of the PPE from the source. Mill Creek flows past the adjacent Hexion property
before entering Livingston Creek and does not receive runoff from Source 1 (Fig. 4, 7).

Mill Creek flows from the east, past a road and an iron pipe near the sewer line (as observed
during the sample collection event (Ref. 4, pp 88, 92; Figs. 4, 6, 7), and where it is indicated as a
pipeline on the USGS topographic map (Fig. 1) then along the northern edge of the Hexion
property. The lower part of the source area, the PPE, and the confluence of Livingston Creek
with Mill Creek has alternately been mapped as a pond and a wetland (Ref. 7, p. 1; Figs. 1, 8, 9).

Below the confluence with Livingston Creek, the Cape Fear flows in an easterly direction
for about 6 miles, where the river splits to Lyon Thoroughfare. Lyon Thoroughfare flows
easterly and joins with the Black River. The Cape Fear continues to flow in a general
southeasterly direction, and 15-mile surface water pathway ends near the confluence of the Black

23


-------
River and the Cape Fear. The entire surface water pathway is within the Cape Fear River basin
(which includes the Black River), and is a large stream-to-river system from the point where
Livingston Creek enters the Cape Fear River to the end of the surface water pathway (>1000 -
10,000 cfs) (Ref. 1, Table 4-13; Ref. 4, pp. 250 - 265). At the point where Livingston Creek
flows into the Cape Fear River, the river is about 300 feet wide and 26 feet deep (Ref. 4, pp. 18,
349).

When some of the fisheries being evaluated are in fresh water and some are in salt water
or any are in brackish water, the HRS instructs to use the bioconcentration factor (BCF) data that
yield the higher factor value to assign the bioaccumulation potential factor value to the hazardous
substance (Ref. 1, Section 4.1.3.2.1.3). For this reason, the surface water pathway was
researched to determine if any part of the 15-mile surface water pathway is brackish or salt
water.

Lock 1 is about 9 1/2 river miles upstream from where Livingston Creek flows into the
Cape Fear River and 37 miles upstream of Wilmington (Ref. 4, pp. 18, 19, 286). The point
where Livingston Creek flows into the Cape Fear River is 27 1/2 miles upstream from
Wilmington. The point where the Cape Fear joins the Black River is the upstream intrusion limit
(200 mg/L chloride), having a 50% chance of being equaled or exceeded in any one year (Ref. 4,
pp. 296, 309). Saltwater intrusion may affect water quality as far as 20 miles upstream from
Wilmington (Ref. 4, p. 300). Therefore, the first 10 1/2 miles of the surface water pathway is
fresh, and the last 4 1/2 miles of the surface water pathway is brackish/salt.

24


-------
SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

4.1.2.1	LIKELIHOOD OF RELEASE

4.1.2.1.1 OBSERVED RELEASE

Chemical Analysis — Sediment

On April 10, 2007 NC Superfund Section collected five background sediment samples
from either Mill Creek or Livingston Creek and six (including one duplicate) downstream
sediment samples from Livingston Creek, as summarized in Tables 3-6 below (Fig. 7).

Samples were collected according to the Sampling and Analysis Quality Assurance Project Plan
(SAP/QAPP) (Ref. 4, pp. 99-104), which was developed in accordance with the NC Superfund
Section Quality Assurance Program Plan (QAPP) and Quality Assurance Standard Operating
Procedures (QASOP). The QASOP adopts by reference the Field Branches Quality System and
Technical Procedures, U. S. Environmental Protection Agency, Region 4. The Program Plan is
derived directly from the EPA-Approved NC Department of Environmental and Natural
Resources QA Plan for Data, 2004 (Ref. 4, pp. 99-104). Samples were shipped to a Contract
Laboratory Program (CLP) laboratory (A4 Scientific) and analyzed for total metals by ICP-AES
and cyanide analysis by Statement of Work (SOW) ILM05.3 and they were analyzed for
pesticides per method SOM01.1 (Ref. 4, pp. 34, 68). A Quality Assurance Chemist with the US
EPA Region 4 Science and Ecosystem Support Division reviewed and validated this data for
performance according to the Statement of Work (Ref. 4, pp. 33, 34, 67-69).

25


-------
SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Background concentration — Sediment

Only those compounds found in a source and a release sample at levels greater than three
times background (or greater than background reporting limits when not detected in background)
are listed below in the background data. For the listed compounds not detected in the
background, only the Minimum Reporting Limit (MRL) (Ref. 4, p. 36) and the Contract-
Required Quantitation Limit (CRQL) (Ref. 5) values are given. When samples are analyzed by
the EPA Contract Laboratory Program, the Hazard Ranking System Final Rule (Ref. 1, Table 2-
3) instructs that when the background concentration is not detected or is less than the
quantitation limit, an observed release is established when the sample measurement equals or
exceeds either the Sample Quantitation Limit (SQL), or if this can not be determined, the
Contract-Required Quantitation Limit (CRQL) (Ref. 1, Table 2-3; Ref. 4, p. 266; Ref. 5). For
inorganic compounds, Reference 5 provides the Contract Required Quantitation Limit (CRQL)
(Ref. 1, Section 1.1, see definition for CRQL).

Table 3. Background Sediment Samples

Sample
number

Date; time

Description

WC-001-SD

4/10/07; 1250

(Ref. 4, pp. 35, 70, 88,

91,95, 97; Fig. 7)

Grab sediment sample upstream of Old
Highway 87 on Livingston Creek;
background sample (MS/MSD);
Tan sand, no layer or organics
(Ref. 4, pp. 88, 91)

WC-002-SD

4/10/07; 1310

(Ref. 4, pp, 35, 70, 88,

92, 95, 97; Fig. 7)

Grab sediment sample downstream of
railroad on Livingston Creek; background
sample (Ref. 4, pp. 88, 92)

WC-008-SD

4/10/07; 1145

(Ref. 4, pp, 35, 70, 87,

95, 97; Fig. 7)

Grab sediment sample downstream of Neils
Eddy Road on Mill Creek; background
sample (Ref. 4, pp. 87, 90)

WC-009-SD

4/10/07; 1120

(Ref. 4, pp, 35, 70, 87,

90, 95; Fig. 7)

Grab sediment sample upstream of iron pipe
near sewerline and roads on Mill Creek;
background sample (Ref. 4, pp. 87, 90)

WC-010-SD

4/10/07; 1515

(Ref. 4, pp, 35, 70, 88,

93, 95, 97; Fig. 7)

Grab sediment sample upstream of
confluence of Mill Creek and Livingston
Creek on Mill Creek; background/attribution
(Ref. 4, pp. 88, 93; Ref. 8, p. 1)

26


-------
SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Table 4. Background Sediment Sample Results



CRQL

WC-001-SD

WC-002-SD

WC-008-SD

WC-009-SD

WC-010-SD

Analyte (mg/kg)

Ref. 5

Ref. 4, pp. 36,

37

Ref. 4, pp.

36, 39

Ref. 4, pp.
36, 51

Ref. 4, pp.

36, 53

Ref. 4, pp.
36, 55





bkg

bkg

bkg

bkg

bkg

Arsenic**

1

1.5 U

3.7 U

1.6 U

2.4 U

2.4 J* (1.7)

Cadmium

0.5

0.77 U

1.2 J (1.9 U)

0.78 U

1.2 U

0.86 U

Copper**

2.5

29 J

63 J

10 J

13 J

8.6 J

Lead**

1

3.7 J [5.3]

26 J [37]

2.4 J [3.5]

5.7 J [8.2]

10 J

Zinc

6

18J

130

5.4 J

21 J

38

J = an estimated quantity

"U" indicates non-detect, and the number adjacent to U is the MRL.

[ ] provides the adjusted value for the estimated (J'd) value as adjusted for bias (Ref. 4, pp. 266 - 283).

*() = Minimum Reporting Limit (MRL) is shown in parentheses when a trace value is reported below the
MRL. The MRL is the analyte concentration which corresponds to the lowest quantitative point on the
calibration curve or the lowest demonstrated level of acceptable quantitation (Ref. 4, p. 36).

**Note that the flagging of some data in the data tables (Ref. 4, pp 37 - 86) is inconsistent with
statements at beginning of the data report (Ref. 4, pp. 34, 68). Generally, the narrative indicates some
data should have been J-qualified while data sheets did not show a J. Where a conflict appeared, the data
was treated as J'd and subsequently adjusted as indicated.

**Arsenic and copper results are J'd due to high bias (Ref. 4, p. 34). Background is not adjusted;
source/release results are adjusted downward by correction factor of 1.74 for arsenic and 1.22 for copper
(Ref. 4, pp. 270, 283).

** Antimony and lead results are J'd due to uncertain bias. Because matrix spike sample recovery for
antimony and lead were low, and because performance evaluation sample recovery were "action high"
(Ref. 4, p. 34), data was adjusted base on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is
adjusted upward and source/release results are adjusted downward by correction factor of 1.98 for
antimony and 1.44 for lead (Ref. 4, pp. 270, 283).

27


-------
SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Contaminated Samples — Sediment

The following sediment samples were collected on April 10, 2007. .

Table 5. Sediment Samples



Distance from PPE
(ft.) Fig. 7



Description

wc-

003-SD

250

4/10/07; 1440

(Ref. 4, pp, 35, 70, 88,

93, 95, 97; Fig. 7)

Grab sediment sample upstream of confluence
of Livingston Creek and Mill Creek; sample
collected at bend, 0-9", sandy material, all tan
(Ref. 4, pp. 88, 93)

WC-
013-SD*

Same as above

4/10/07; 1440

(Ref. 4, pp, 35, 70, 88,

93, 96, 98; Fig. 7)

Duplicate of WC-003-SD. See discussion
below regarding WC-103-SD / WC-013-SD
(Ref. 4, pp. 88, 93)

WC-
004-SD

750

4/10/07; 1540

(Ref. 4, pp, 35, 70, 88,

93, 95, 97; Fig. 7)

Grab sediment sample downstream of
confluence of Livingston Creek and Mill Creek,
approximately 75 yards downstream of
confluence. Grey silty sand, 0 - 6"

(Ref. 4, pp. 88, 93)

WC-
005-SD

2650

4/10/07; 1055

(Ref. 4, pp, 35, 70, 87,

90, 95, 97; Fig. 7)

Grab sediment sample 30' upstream of second
pipeline (36" iron). Little organic on top, mix of
sand, clay and organics. (Ref. 4, pp. 87, 90)

WC-
006-SD

2800

4/10/07; 1040

(Ref. 4, pp, 35, 70, 87,

89, 95, 97; Fig. 7)

Grab sediment sample collected 50' downstream
of sewer pipeline, sandy clay material under 2"
organic layer. (Ref. 4, pp. 87, 89)

WC-
007-SD

4000

4/10/07; 1010

(Ref. 4, pp, 35, 70, 87,

89, 95, 97; Fig. 77)

Grab sediment sample on Livingston Creek;
release sample 0.1 mile wetland frontage,
upstream of wooden pier. 0 - 6", grey clay with
tan sand (Ref. 4, pp. 87, 89)

* Note that field log notes discuss the collection of WC-003-SD (Ref. 4, pp. 88, 93) but do not
specifically discuss the collection of the duplicate WC-103-SD. However, the sample plan (Ref.
4, p. 102) lists sample WC-103-SD and the chain of custody shows that WC-103-SD was sample
collected at same time as WA-003-SD (Ref. 4, pp. 96, 98). Note also that the laboratory report
did not contain results for WC-103-SD, but did show results for WC-013-SD, a sample not listed
on the chain of custody. WC-013-SD (as reported by the lab), shows the same date, time and
CLP sample ID number as that indicated for WC-103-SD on the chain of custody (Ref. 4, pp. 35,
65, 66, 70, 86).

28


-------
SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Table 6. Sediment Sample Results





WC-003-

WC-013-

WC-004-

WC-005-

WC-006-

WC-007-

mg/kg

CRQL

SD

SD

SD

SD

SD

SD

Reference

Ref. 5

(Ref. 4, pp.
34, 36, 41,)

(Ref. 4, pp.34,
36, 65, 66)

(Ref. 4, pp.
34, 36, 43)

(Ref. 4, pp.
34, 36, 45)

(Ref. 4, pp.
34, 36, 47)

(Ref. 4, pp.
34, 36, 49)

Sample
purpose



release

release/dup

release

release

release

release











2.9 J

320 J

0.95 J (1.3

Arsenic**

1

31 J [17.81

29 J [16.61

1.3 U

(3.1 U)

[183.9]

U)















0.28J

Cadmium

0.5

3.5

3.6

0.30 U, J

1.1 U.J

2.4 U, J

(0.65 U)





190 J







770 J



Copper**

2.5

[155]

150 J [122]

5.4J

73 J [59]

[631]

22





520 J**

430 J**

8.2 J**

130 J**

1200 J**

25 J**

Lead

1

[360]

[300]

[5.7]

[90]

[830]

[17]

Zinc

6

660

780

5.9J

160

380

36

J = estimated quantity

"U" indicates non-detect, and the number adjacent to U is the MRL.
[ ] = value adjusted for bias (Ref. 4, pp. 266 - 283).

*() = Minimum Reporting Limit (MRL) is shown in parentheses when a trace value is reported below the
MRL. When an estimated level is reported below Contract Required Reporting Limit (CRQL) / MRL,
this value is considered non-detect (Ref. 1, Table 2-3)

**Note that the flagging of some data in the data tables (Ref. 4, pp 37 - 86) is inconsistent with
statements at beginning of the data report (Ref. 4, pp. 34, 68). Generally, the narrative indicates some
data should have been J-qualified while data sheets did not show a J. Where a conflict appeared, the data
was treated as J'd and subsequently adjusted as indicated.

**Arsenic and copper results are J'd due to high bias (Ref. 4, p. 34). Background is not adjusted;
source/release results are adjusted downward by correction factor of 1.74 for arsenic and 1.22 for copper
(Ref. 4, pp. 270, 283).

** Lead results are J'd due to uncertain bias. Because matrix spike sample recovery for lead was low,
and because performance evaluation sample recovery were "action high" (Ref. 4, p. 34), data was
adjusted base on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is adjusted upward and
source/release results are adjusted downward by correction factor of 1.44 for lead (Ref. 4, pp. 270, 283).

BOLD indicates an observed release

An observed release must be either greater than background CRQL / MRL (when non-detect) or three
times the level detected in background (Ref. 1, Table 2-3; Ref. 4, pp. 266 - 283). To determine an
Observed Release, the highest detect / CRQL of the five background sediment samples was used.

29


-------
SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Background sediment concentration summary (highest detected level or the highest quantitation
limit of the five background samples)

Arsenic	3.7 U mg/kg

Cadmium	1.9 U mg/kg

Copper	63 J mg/kg

Lead	37 mg/kg (adjusted upward due to uncertain bias)

Zinc	130 mg/kg

Hazardous substances in observed release to sediment summary.

Sample WC-003-SD and its duplicate WC-013-SD serve to document the observed release of
arsenic, cadmium, copper, lead, and zinc into the fishery. While samples just downstream of the
site (WC-004-SD and WC-005-SD) did not show site contaminants, sample WC-006-SD showed
higher levels of site contaminants. Given the passage of time since operations ceased, it can be
anticipated that various storm and erosion events could cause uneven distribution and migration
of contaminants downstream from the source.

Arsenic

Cadmium

Copper

Lead

Zinc

320 mg / kg
3.6 mg/kg
770 mg/kg
830 mg/kg
780 mg/kg

30


-------
SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Further discussion:

There appears to be some pesticide contamination at this site; however, this information was not
used to produce the site score. A nearby upgradient facility manufactured chlorinated pesticides
(Ref. 9, pp. 1-12).

4.1.2.1.1.1 ATTRIBUTION

The Wright Chemical Corp site was a fertilizer and sulfuric acid manufacturing facility
founded in 1883 (Ref. 4 pp. 397, 401). The original Acme plant was a lead-lined "chamber-
process" plant that thermally extracted sulfur from pyrite (Ref. 4 pp. 109). Sanborn Fire
Insurance Maps dated from 1898 and 1910 confirm that "Lead Acid Chambers" were previously
present on the property where Source 1 has been identified (Ref. 4 pp. 173-179; Fig. 3).

Denuded, magenta-colored soil characteristic of former lead chamber sulfuric acid
manufacturing facilities (Ref. 4 pp. 214-215) has been documented in the vicinity of the former
process areas on the property (Ref. 8, pp. 1-8). This magenta colored soil typically contains lead
in the 4,000 - 20,000 mg/kg range and depending on the raw materials used in the processes, it
can also contain substantial amounts of other metals and contaminants (Ref. 4 p. 215). Source 1
has been documented to contain elevated concentrations of metals including arsenic, cadmium,
copper, lead, and zinc (see Table 2 of this HRS documentation record) (Ref. 4, pp. 34, 36, 57-59,
61-63; Fig. 4).

Source 1 drains north, downgradient into Livingston Creek (Figs. 1, 4). Sediment
samples taken from Livingston Creek directly downgradient from source 1 show elevated
concentrations of metals analogous to those found in source 1 (Ref. 4, pp. 35-56, 87-93; Fig. 7).

Additionally, sediment samples WC-011-SS and WC-013-SS have been documented as
being located in a wetland contiguous to Livingston Creek (Ref. 8, p. 6, Fig. 4). Since samples
WC-011-SS and WC-013-SS are located in a wetland contiguous with Livingston Creek,
evidence of direct deposition of hazardous chemicals directly into the Creek from source 1 is
present.

There are three current/former facilities/sites that are upgradient from this site - Hexion,
Kaiser Agricultural, and Kaiser Acme Farmarket (Ref. 4, pp. 108, 109-110, 117; Ref. 9, 1-12).
There are two nearby facilities/sites that are downgradient from Wright Chemical - International
Paper (aka Federal Paperboard) and Holtrachem (Ref. 4, p. 3, Figs. 5, 6). The neighboring
Hexion facility was at one time owned and operated by the Wright Chemical Corp. The history
of chemical manufacturing on this adjacent 20-acre Hexion parcel included formaldehyde,
hexamine, chloropicrin, silicon compounds and pharmaceuticals. There is no history of work
with metals (Ref. 4, pp. 9, 129, 397-404). One sample (WC-010-SD; Tables 3, 4) was collected
downgradient of Hexion and up gradient from Livingston Creek. This sample documents any

31


-------
impact to Mill Creek that may have occurred from runoff from the Hexion site prior to it entering
Livingston Creek.

The archived Kaiser Agricultural Chemical site (NCD 980 842 470) adjacent to and south
of the lead chamber properties was once part of Acme Chemical and was owned by Wright
Chemical. This parcel housed the fertilizer portion of the operation, it was investigated under
CERCLA, and was archived from CERCLA in 1989 (Ref, 4, p. 110, 111). The former Kaiser
Acme Farmarket (NCD 980 557 847) pesticide facility is about Vi mile to the south. This facility
was associated with chlorinated pesticide manufacturing from 1967 - 1971 and subsequently for
pesticide retail sales. There is no evidence it had metal contamination (Ref. 9, pp. 1-12).

To the north and across Livingston Creek is the 978-acre parcel owned by Federal Paper
Board Co., Inc. (aka International Paper) (Ref. 4, p. 452.3; Fig. 5). Adjacent to and east of
Federal Paper Board, bordering the Cape Fear River is the former Holtrachem (aka LCP
Chemicals; Honeywell; Allied Signal) mercury cell chlor-alkali plant site (NCD 991 278 631),
currently owned by Honeywell International (Ref. 4, pp. 452.4, 452.5; Fig. 6). Both of these
sites are downgradient from the Wright Chemical Corp site. There is some flow reversal on
Livingston Creek (Ref. 10, pp. 1, 2); however, neither the Holtrachem nor the International Paper
site are associated with any lead, arsenic, cadmium, copper, or zinc contamination (Ref. 8, p. 2).
Holtrachem has high contamination with mercury and PCBs (Ref. 8, p. 2).

4.1.2.1.2 POTENTIAL TO RELEASE TO SURFACE WATER—

Not scored because observed release to surface water sediment documented by
chemical analysis

Surface Water Sediment Observed Release Factor Value— 550
(Ref. 1, Section 4.1.2.1.1)

32


-------
SWOF Human Food Chain Threat

4.1.3 HUMAN FOOD CHAIN THREAT

The human food chain threat is evaluated based on three factor categories: likelihood of
release, waste characteristics, and targets.

4.1.3.1 HUMAN FOOD CHAIN THREAT-LIKELIHOOD OF RELEASE

The human food chain threat likelihood of release is the same as that for the drinking
water threat (Ref. 1, Section 4.1.3.1). Level II contamination in Livingston Creek from the PPE
downstream 2800 feet to Sample WC-006-SD has been documented as a part of a fishery. (Ref.
4, pp.35, 70, 87, 531-533, Fig. 7).

550

4.1.3 .2 HUMAN FOOD CHAIN THREAT-WASTE CHARACTERISTICS

The waste characteristics factor category for each watershed is based on two factors:
toxicity/persistence/bioaccumulation and hazardous waste quantity (Ref. 1, Section 4.1.3.2).

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

The HRS instructs to evaluate the waste characteristics factor category based on two
factors: toxicity/persistence and hazardous waste quantity. And, to evaluate only those hazardous
substances that are available to migrate from the sources at the property to surface water in the
watershed via the overland/flood hazardous substance migration path for the watershed. Such
hazardous substances include hazardous substances that meet the criteria for an observed release
to surface water in the watershed, and all hazardous substances associated with a source that has
a surface water containment factor value greater than 0 for the watershed (Ref. 1, Section 4.1.2.2,
also see sections 2.2.2, 2.2.3, 4.1.2.1.2.1.1, and 4.1.2.1.2.2.1). Tables 7 and 8 of this HRS
documentation record present those substances documented in the observed release to the
fishery, and those substances documented in the source with a containment factor value greater
than 0.

As discussed above, Livingston Creek (3 miles) and the first 7 V2 miles in the Cape Fear
River is fresh, and the last 4 1/2 miles of the surface water pathway is brackish/salt. (See
discussion in 4.1.1.1 above; Ref. 4, pp. 296, 300, 309).

The Hazard Ranking System (HRS) instructs that if bioconcentration factor (BCF) data
are available for both fresh water and salt water for the hazardous substance, use the BCF data
that corresponds to the type of water body (that is, fresh water or salt water) in which the
fisheries are located to assign the bioaccumulation potential factor value to the hazardous
substance. If, however, some of the fisheries being evaluated are in fresh water and some are in
salt water, or if any are in brackish water, use the BCF data that yield the higher factor value to

33


-------
SWOF - Human Food Chain Threat

assign the bioaccumulation potential factor value to the hazardous substance (Ref. 1, Section
4.1.3.2.1.3). Because the fishery is located in fresh water, only fresh water bioaccumulation
values will be used as per the HRS.

Table 7. Source 1 Contaminants Documented in O

^served Release to Sediment in the Fishery

Hazardous
Substance

Tox. Factor
value

PF#

BPFV*
Fresh
Food**

BPFV*

Salt
Food**

T/P value
(Ref. 1, Table
4-12)

T/P/BPFV
(fresh) (Ref. 1,
Table 4-16)

T/P/BPFV
(salt) (Ref. 1,
Table 4-16)

Arsenic

10,000

1

5

500

10,000

5 x 10 E4

5 x 10 E6

Cadmium

10,000

1

5,000

50,000

10,000

5 x 10 E7

5 x 10 E8

Copper

0

1

500

50,000

0

0

0

Lead

10,000

1

5

5,000

10,000

5 x 10 E4

5 x 10 E7

Zinc

10

1

5

50,000

10

50

5 x 10 E5

Table 8. Source 1 Contaminants Documented in Source with Containment Factor of 10, not
documented in Observed Release to Fishery Sediment

Hazardous
Substance

Tox. Factor
value

PF#

BPFV*
Fresh
Food**

BPFV*

Salt
Food**

T/P value
(Ref. 1, Table
4-12)

T/P/BPFV
(fresh) (Ref. 1,
Table 4-16)

T/P/BPFV
(salt) (Ref. 1,
Table 4-16)

Antimony

10,000

1

5

5

10,000

5 x 10 E4

5 x 10 E4

Manganese

10,000

1

50,000

50,000

10,000

5 x 10 E8

5 x 10 E8

Mercury

10,000

1

50,000

50,000

10,000

5 x 10 E8

5 x 10 E8

Nickel

10,000

1

0.5

500

10,000

5 x 10E3

5 x 10 E6

Silver

100

1

50

50,000

100

5 x 10E3

5 x 10E6

Thallium

100

1

500

50

100

5 x 10E4

5 x 10E3

T/P/BPFV = Toxicity/Persistence/Bioaccumulation Potential Factor (Ref. 1, Table 4-16) **Ref.
2, Appendix BI, pp. 1-15

BPFV = Bioaccumulation Potential Factor Value

#PF = Persistence Factor Value, Ref. 1, Section 4.1.3.2.1.2; Ref. 2

*Ref. 1, Section 4.1.3.2.1.3; Ref. 2.

Of those contaminants documented in the observed release to the fishery, cadmium has
the highest T/P/BPFV freshwater value. Of those contaminants documented in the source but
not in fishery sediment, manganese and mercury have the highest freshwater values.
Manganease and mercury were used to assign the toxicity/persistence/bioaccumulation factor
value as per Section 4.1.3.2.1.4 of the HRS.

Toxicity/Persistence/Bioaccumulation Factor Value: = 5 x 10

34


-------
SWOF - Human Food Chain Threat

4.1.3.2.2 Hazardous Waste Quantity

HRS (Ref. 1), Section 4.1.3.2.2 instructs that if any target for that migration pathway is
subject to Level I or Level II concentrations, assign either the value from Table 2-6 or a value of
100, whichever is greater, as the hazardous waste quantity factor value for that pathway. (Ref. 1,
Section 2.4.2.2)

Hazardous Waste Quantity Factor Value = 100

4.1.3.2.3 Human Food Chain Threat Waste Characteristics Factor Category Value:

Toxicity/Persistence Value = 10,000
Bioaccumulation Potential Factor Value = 50,000

Toxicity/Persistence Value x Hazardous Waste Quantity Factor Value:

10,000 x 100 = 1,000,000 (1 x 106)

(Toxicity/Persistence x Hazardous Waste Quantity) x Bioaccumulation Potential
Value:

(1 x 106) x 50,000 = 5 x IP10

Human Food Chain Hazardous Waste Quantity Assigned Value/

Human Food Chain Waste Characteristics Factor Category Value	320

(Ref. 1, Table 2-7; Sections 4.1.3.2.3 and 2.4.3.1):

35


-------
SWOF - Human Food Chain Threat

4.1.3 .3 HUMAN FOOD CHAIN THREAT - TARGETS
Actual Human Food Chain Contamination

Observed Release to Surface water sediment (Level II) was documented in Section

4.1.3.1.

Livingston Creek, from WC-001-SD upstream of Old Highway 87 until its confluence
with the Cape Fear River is a fishery. Brim, bass and catfish are caught in the creek, and catches
are cooked and consumed on the creek banks (Ref. 4, pp. 88, 91, 531 - 533). The Cape Fear
River is an important fishery (Ref. 4, pp. 291 - 293; 490 - 502; 531 — 533). Atlantic Sturgeon,
Striped Bass and American Shad catches are three of the seven anadromous species found in the
Cape Fear River system, along with several nonnative species (Ref. 4, pp. 490 - 502). The Cape
Fear River is a commercial fishery (Ref. 4, pp. 289, 291, 293). The estimated 1981 harvest was
1.3 million pounds for the entire basin downstream of Lock 1 (Ref. 4, p. 292); however, the
fishery has experienced a decline (Ref. 4, 492). Commercial off-shore shad fishing has been
phased out, making the inshore Cape Fear River shad fishery even more important (Ref. 4, p.
492). The Atlantic Sturgeon is a threatened species and the shortnose sturgeon is an endangered
species; there is a reproducing population of these two species in this drainage basin (Ref. 4, p.
495).

Researchers at the University of North Carolina Wilmington's Center for Marine Science
performed a pilot study in 2003-2004 to assess metals and organic contaminant concentrations at
three areas in the Lower Cape Fear River system (Ref. 4, p. 476). One of these areas was
Livingston Creek, about 40 meters upstream of the confluence with the Cape Fear River (LVC)
(Ref. 4, pp. 475, 476; Fig. 6). The clam and bottom-feeding fish tissue concentrations of arsenic,
cadmium, mercury, selenium, and Dieldrin exceeded their respective recommended
concentration range, indicating potential human health problems (Ref. 4, pp. 476, 480 — 484).

4.1.3.3.1 Food Chain individual	(Ref. 1, Section 4.1.3.3.1)

Level II contamination in Livingston Creek from the PPE downstream 2800 feet to Sample WC-
006-SD has been documented as a part of a fishery. (Ref. 4, pp. 35, 70, 87, 531-533, Fig. 7).

"If any fishery (or portion of a fishery) is subject to Level II concentrations, assign a
value of 45.

Food Chain Individual Factor Value = 45

36


-------
SWOF - Human Food Chain Threat

4.1.3.3.2 Population

4.1.3.3.2.1 Level I Concentrations — not scored

4.1.3.3.2.2 Level II Concentrations

Arsenic, cadmium, copper, lead, and zinc contamination have been documented in source
1 and in sediment in the fishery. The level of contaminants is summarized below:

mg/kg

WC-003-SD

WC-013-SD

WC-006-SD

Arsenic

31 J [17.81

29 J [16.61

320 J [183.91

Cadmium

3.5

3.6

2.4 U, J

Copper

190 J [155]

150 J[122]

770 J [631]

Lead

520 J** [360]

430 J** [300]

1200 J** [830]

Zinc

660

780

380

Given the active fishing occurring in Livingston Creek (Ref. 4, p. 531) >0 pounds of fish are
caught in Livingston Creek and consumed. A Food Chain Population value of 0.03 is assigned
(Ref. 1, Table 4-18).

Level II Concentrations Factor Value = 0.03

4.1.3.3.2.3 Potential Human Food Chain Contamination - not scored

4.1.3.3.3 Calculation of Human Food chain threat - targets factor category value (Ref. 1.
Section 4.1.3.3.3)

Human food chain threat-targets factor category value =

Human Food Chain Individual + Level II concentrations =

45 + (0.03) = 45.03

4.1.3.4 Calculation of human food chain threat score

Likelihood of release x waste characteristics x targets / 82,500 =

550x320x45.03 / 82,500 = 96.06

Human Food Chain Threat Score = 96.06

37


-------
SWOF/Environment

4.1.4 ENVIRONMENTAL THREAT

Even though there are extensive wetlands along the surface water pathway (Ref. 7, p. 1,
Fig. 9), the environmental threat was not scored because it would have had a minimal additional
impact on the surface water pathway score.

38


-------
Table 4-1 Surface Water Overland/Flood Migration Component Scoresheet
Human Food Chain Threat

Maximum Value Value Assigned

Likelihood of Release:	550	550

Waste Characteristics:

Toxicity/Persistence/Bioaccumulation	(a)	5 x 108

Hazardous Waste Quantity	(a)	100

Waste Characteristics	1,000	320

Targets: Food Chain Individual Factor Value	50	45

Level I Concentrations	(b)

Level II Concentrations	(b)	0.03

Potential Human Food Chain Contamination	(b)

Population (Level I + Level II + Potential)	(b)	45.03

Human Food Chain Threat Score:

[550x320x45.03]/82,500=	100	96.06

(a)Maximum	value applies to waste characteristics category

(b)Maximum	value not applicable

39


-------