HRS DOCUMENTATION RECORD- COVER SHEET

Name of Site:

SHAFFER EQUIPMENT/ARBUCKLE CREEK AREA

EPA ID No.:

WVD988768909

Date Prepared:

September 2018

Contact Person(s):

Lorie Baker

U.S. Environmental Protection Agency
Philadelphia, Pennsylvania
(215) 814-3355
Baker.Lorie Wepa. gov

Pathways. Components, or Threats Not Scored
Ground Water:

The Ground Water Migration Pathway was not scored because its inclusion would not significantly affect the site
score. In June 2017, groundwater samples were collected from the four monitoring wells located on the Shaffer
Equipment Co. property (References [Refs.] 12, p. 51; 30, pp. 12, 13; 52, pp. 1-3). Polychlorinated biphenyls (PCBs)
were detected in one sample above the U.S. Environmental Protection Agency (EPA) Maximum Contaminant Level
(MCL) for drinking water (Refs. 2, p. 3; 52, p. 2). However, Minden is supplied drinking water from the West Virginia
American Water Company whose source water is a surface water intake on the New River (Refs. 56, p. 1; 57, p. 16).

Soil Exposure Pathway and Subsurface Intrusion Pathway - Soil Exposure Component Nearby Population
Threat:

The Nearby Population Threat of the Soil Exposure and Subsurface Intrusion Pathway - Soil Exposure Component
was not scored because its inclusion would not significantly affect the site score.

Soil Exposure Pathway and Subsurface Intrusion Pathway - Subsurface Intrusion Component:

The Subsurface Intrusion Component of the Soil Exposure and Subsurface Intrusion Pathway was not scored because
PCBs are the contaminant of concern at the Shaffer Equipment /Arbuckle Creek Area site; therefore, the subsurface
intrusion component is not a concern at the site.

Air Migration Pathway:

The Air Migration Pathway was not scored because there is no documented observed release to the atmosphere, and
scoring the potential to release to air would not significantly affect the site score.

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HRS DOCUMENTATION RECORD

Name of Site:

Date Prepared:

EPA ID No.:

EPA Region:

Street Address of Site*:

City, State, and Zip Code:

General Location in the State:

Topographic Map:

Latitude*:

Shaffer Equipment/Arbuckle Creek Area
September 2018

WVD988768909
3

WV Route 17 (a.k.a. MindenRoad)

Minden, Fayette County, West Virginia 25879

Southcentral

Oak Hill, West Virginia

37.97651° North

Longitude*: -81.1265° West

Latitude/Longitude Reference Point: The latitude and longitude is the location of sample SEC-SS-SE-02, a sample
used to characterize Source 1, which was collected at the edge of the capped area on the Shaffer Equipment Company
property, in December 2017 (Figure 3; Refs. 3; 26, p. 7; 27, p. 32; 66, p. 15; 84, pp. 1, 2).

*The street address, coordinates, and contaminant locations presented in this Hazard Ranking System (HRS)
documentation record identify the general area where the site is located. They represent one or more locations the
U.S. Environmental Protection Agency (EPA) considers part of the site based on the screening information EPA used
to evaluate the site for inclusion on the National Priorities List (NPL). 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 an area where a hazardous substance has been "deposited, stored, disposed, or placed,
or has 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 the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA). Accordingly, EPA contemplates that the preliminary
description of facility boundaries at the time of scoring will be refined as more information is developed regarding
where the contamination has come to be located.

Scores

Ground Water Pathway1	Not Scored

Surface Water Pathway	100.00

Soil Exposure and Subsurface Intrusion Pathway	14.76

Air Pathway	Not Scored

HRS SITE SCORE

50.54

1 "Ground water" and "groundwater" are synonymous; the spelling is different due to "ground water"
being codified as part of the HRS, while "groundwater" is the modern spelling.

1

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WORKSHEET FOR COMPUTING HRS SITE SCORE
Shaffer Equipment/Arbuckle Creek Area



S

s!

1. Ground Water Migration Pathway Score (Sgw)
(from Table 3-1, line 13)

NS

NS

2a. Surface Water Overland/Flood Migration Component
(from Table 4-1, line 30)

100

10,000

2b. Ground Water to Surface Water Migration Component
(from Table 4-25, line 28)

NS

NS

2c. Surface Water Migration Pathway Score (Ssw)

Enter the larger of lines 2a and 2b as the pathway score.

100

10,000

3a. Soil Exposure Component Score (Sse)
(from Table 5-1, line 22)

14.76

217.8576

3b. Subsurface Intrusion Component Score (Sss0
(from Table 5-11, line 12)

NS

NS

3c. Soil Exposure and Subsurface Intrusion Pathway Score (Ssess0
(from Table 5-11, line 13)

14.76

217.8576

4. Air Migration Pathway Score (Sa)
(from Table 6-1, line 12)

NS

NS

5. Total of Sgw2 + Ssw2 + SSeSSi2 + Sa2

-

10,217.8576

6. HRS Site Score

Divide the value on line 5 by 4 and take the square root

50.54

Note:

NS= Not Scored

2

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HRS TABLE 4-1

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET
Shaffer Equipment/Arbuckle Creek Area

Factor Categories & Factors

MAXIMUM

VALUE

DRINKING WATER THREAT

VALUE

ASSIGNED

Likelihood of Release





1. Observed Release

550

550

2. Potential to Release by Overland Flow





2a. Containment

10

not scored

2b. Runoff

25



2c. Distance to Surface Water

25



2d. Potential to Release by Overland Flow

500



(lines 2a [2b + 2c])





3. Potential to Release by Flood





3 a. Containment (Flood)

10

not scored

3b. Flood Frequency

50



3c. Potential to Release by Flood

500



(lines 3a x 3b)





4. Potential to Release (lines 2d + 3c)

500



5. Likelihood of Release (higher of lines 1 and 4)

550

550

Waste Characteristics





6. Toxicity/Persistence

*



7. Hazardous Waste Quantity

*



8. Waste Characteristics

100

not scored

Targets





9. Nearest Intake

50

Not scored

10. Population





10a. Level I Concentrations

**



10b. Level II Concentrations

**



10c. Potential Contamination

**



lOd. Population (lines 10a + 10b + 10c)

**



11. Resources

5



12. Targets (lines 9 + lOd +11)

**



13 DRINKING WATER THREAT SCORE

100

Not scored

([lines 5 x 8 x 12]/82,500)





Maximum value applies to waste characteristics category.
Maximum value not applicable

3

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HRS TABLE 4-1

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET
Shaffer Equipment/Arbuckle Creek Area

Factor Categories & Factors

MAXIMUM

VALUE

HUMAN FOOD CHAIN THREAT

VALUE

ASSIGNED

Likelihood of Release





14. Likelihood of Release (same as line 5)

550

550

Waste Characteristics





15. Toxicity/Persistence/Bioaccumulation

*

5.00E+08

16. Hazardous Waste Quantity

*

100

17. Waste Characteristics

1,000

320

Targets





18. Food Chain Individual

50

20

19. Population





19a. Level I Concentrations

**

0

19b. Level II Concentrations

**

0

19c. Potential Human Food Chain Contamination

**

0.0000003

19d. Population (lines 19a + 19b + 19c)

**

0.0000003

20. Targets (lines 18 + 19d)

**

20.0000003

21 HUMAN FOOD CHAIN THREAT SCORE

100

42.66

([lines 14 x 17 x 20]/82,500)





Maximum value applies to waste characteristics category.
Maximum value not applicable

4

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HRS TABLE 4-1

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET
Shaffer Equipment/Arbuckle Creek Area

Factor Categories & Factors
ENVIRONMENTAL THREAT

MAXIMUM
VALUE

VALUE
ASSIGNED

Likelihood of Release





22. Likelihood of Release (same as line 5)

550

550

Waste Characteristics





23.	Ecosystem Toxicity/Persistence/Bioaccumulation

24.	Hazardous Waste Quantity

*
*

5.00E+08
100

25. Waste Characteristics

1,000

320

Targets





26. Sensitive Environments
26a. Level I Concentrations
26b. Level II Concentrations
26c. Potential Contamination
26d. Sensitive Environments (lines 26a + 26b + 26c)

**
**
**
**

0

200
not scored
200

27. Targets (line 26d)

**

200

28 ENVIRONMENTAL THREAT SCORE

([lines 22 x 25 x 27]/82,500)

60

60

29. WATERSHED SCORE (lines 13 + 21 + 28)

100

100

30. SURFACE WATER OVERLAND/FLOOD
MIGRATION COMPONENT SCORE (Sof)

100

100.00

SURFACE WATER MIGRATION PATHWAY
SCORE (Ssw)

100

100.00

Maximum value applies to waste characteristics category.
Maximum value not applicable

5

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HRS TABLE 5-1

SOIL EXPOSURE AND SUBSURFACE INTRUSION PATHWAY - SOIL EXPOSURE COMPONENT

Shaffer Equipment/Arbuckle Creek Area

Factor Categories & Factors

MAXIMUM

VALUE

RESIDENT POPULATION THREAT

VALUE

ASSIGNED

Likelihood of Exposure





1. Likelihood of Exposure

550

550

Waste Characteristics





2. Toxicity/Persistence

*

10,000

3. Hazardous Waste Quantity

*

10

4. Waste Characteristics

100

18

Targets





5. Resident Individual

50

50

6. Resident Population





6a. Level I Concentrations

**

60

6b. Level II Concentrations

**

13

6c. Resident Population (lines 6a + 6b)

**

73

7. Workers

15

0

8. Resources

5

0

9. Terrestrial Sensitive Environments



0

10. Targets (lines 5 +6c+ 7 + 8 +9)

**

123

11 RESIDENT POPULATION THREAT SCORE



1,217,700

(lines 1 x 4 x 10)





Maximum value applies to waste characteristics category.
Maximum value not applicable

6

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HRS TABLE 5-1

SOIL EXPOSURE AND SUBSURFACE INTRUSION PATHWAY - SOIL EXPOSURE COMPONENT

Shaffer Equipment/Arbuckle Creek Area

NEARBY POPULATION THREAT

MAXIMUM
VALUE

VALUE
ASSIGNED

Likelihood of Exposure





12. Attractiveness/Accessibility

100

NS

13. Area of Contamination

100

NS

14. Likelihood of Exposure

500

NS

Waste Characteristics





15.	Toxicity/Persistence

16.	Hazardous Waste Quantity

17.	Waste Characteristics

*

*

100

NS

Targets





18. Nearby Individual

1

NS

19. Population within 1 mile

**

NS

20. Targets (lines 18+19)

**

NS

21 NEARBY POPULATION THREAT SCORE

(lines 14 x 17 x 20)

**

NS

22 SOIL EXPOSURE COMPONENT SCORE (Se)
(lines [11 +21]/82,500)

100

14.76

7

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REFERENCES

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9

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10

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47.

48

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11

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31, 2018, Available from https://www.fws.gov/midwest/Endangered/mammals/inba/inbafctsht.html [3

12

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76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

REFERENCES (continued)

Description of the Reference
pages]

Reference Number Reserved.

U.S. Fish and Wildlife Service. Northern Long-eared bat (Mvotis sevtentrionalis). Information
Accessed	on	May	31,	2018,	Available	from

https://ecos.fws.gov/ecpO/profile/speciesProfile?spcode=AOJE [6 pages]

West Virginia Division of Natural Resources. Draft 2015 West Virginia State Wildlife Action Plan. June
10, 2015 [1,028 pages]

University of Michigan. About the State Wildlife Action Plans. Information Accessed on June 13,2018,
Available at http://seas.umich.edu/ecomgt/swap/About SWAPs.html [4 pages]

WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: Parcel Information
and Sample Locations: with attached Table of Parcel Information. June 27, 2018 [4 pages]

Reference Number Reserved.

McDonald, Brandon, EPA, Region III Environmental Services Assistance Team (ESAT) Regional
Program Officer (RPO). Memorandum with attachment to Lorie Baker. EPA. Subject: Region III Data
OA Review: with attached Data Validation Report for the Shaffer Equipment Co. Site - RAS # 47650
(SPG # C0AG81. June 26, 2018. [402 pages]

WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: Case # 47650.
Electronic Data Deliverable: with attached Table of EDD Data. June 28, 2018. [4 pages]

WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: December 2017 GPS
Data: with attached Table of GPS Data. July 18, 2018. [2 pages]

WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: March 2018 GPS
Data: with attached Table of GPS Data. July 18, 2018. [2 pages]

WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: May 2018 GPS Data:
with attached Table of GPS Data. July 18, 2018. [2 pages]

Alliance Consulting Incorporated. Federally Listed Bat Evaluation and Memo Report Shaffer
Equipment Company (Site 1D03D8). August 7, 2018. [32 pages]

WESTON. Final Field Sampling Plaa Shaffer Equipment Company. EPA Contract No. EP-S3-15-02,
Technical Direction Document No. W503-17-12-001. June 2018. [27 pages]

Farrish, Jessica. Former employee: "A lot of people died because I dumped that stuff Register-Herald.
Accessed Online on August 11, 2018. http://www.register-herald.com/news/former-emplovee-a-lot-of-
people-died-because-i-dumped/article 40534150-a730-5147-8532-f43687633213.html [4 pages].

EPA. EPA Bans PCB Manufacture: Phases Out Uses [EPA press release - April 19. 19791. Accessed
Online on August 11, 2018. https://archive.epa.gov/epa/aboutepa/epa-bans-pcb-manufacture-phases-
out-uses.html [3 pages]

Oregon Department of Environmental Quality (DEQ). Fact Sheet: Sources of Polvchlorinated
Biphenyls. PCB FACT SHEET.CP.8-6-03.DOC. Accessed Online on August 11, 2018.
https://www.oregon.gov/deq/FilterDocs/ph-SourcePCBs.pdf [11 pages]

WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: June 2018

13

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REFERENCES (continued)

Reference

Number Description of the Reference

Logbook Notes. July 18, 2018. [8 pages]

93.	WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: June 2018 GPS
Data: with Attached Table of GPS Data. July 18, 2018. [2 pages]

94.	Burman, Jarmael, EPA, CLP PO/RSCC/DDS. Electronic Mail Correspondence to Justin Bleiler
Regarding Case RAS 47707: with attached Unvalidated Sample Summary Report for SPG C0AJ5.
August 6, 2018. [18 pages]

95.	WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: Wetland Frontage
Located Along 15-Mile Surface Water Pathway Target Distance Limit (TDL). August 10, 2018 [3
pages]

96.	WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: New River Gorge
National River Park Boundary Memo. August 10, 2018 [1 page]

97.	WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: Fayette County
Tax parcel Database, with attached Parcel Map Information. August 12, 2018,
http://maps.agdmaps.com/wv/fayette/ [8 pages]

98.	WESTON. Project Note to Shaffer Equipment/Arbuckle Creek Area Site. Subject: Calculation of
Distances. August 14, 2018 [1 page]

99.	FEMA. Zone A Definition and Description. Accessed on August 28, 2018.
https://www.fema.gov/zone [1 page.]

14

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SS-Site Summary

SITE SUMMARY

The site as scored for HRS purposes consists of two sources: contaminated soil source located on the Shaffer
Equipment Company (SEC) property and contaminated soil source located on parcels along Arbuckle Creek
downstream of the SEC property (see Section 2.2) as well as contaminated sediments in Arbuckle Creek (see Section
4.1.2.1.1) that stretch between and downstream of the two soil sources. As presented in the Source Characterization
section, these sources have been documented to contain PCBs. A release of PCBs from sources to a Level II wetland,
as well as additional Level II sensitive environments, and the presence of Level I and Level II Resident Population
associated with the soil exposure component of the Soil Exposure and Subsurface Intrusion Pathway have been
documented (see Sections 4.1.4.3 and 5.1.1), Additionally, the presence of fishery (i.e. New River) located along the
15-mile Target Distance Limit (TDL) is subject to Potential Contamination (see Section 4.1.3.3).

The Shaffer Equipment/Arbuckle Creek Area site is located in Minden, Fayette County, West Virginia (Figure 1;
Ref. 4, p. 1). The town of Minden, West Virginia, encompasses approximately 0.49 square miles situated in a valley
between two ridges and has a population of approximately 242 people (Refs. 4, p. 1; 5, p. 1). Historically, the town
was founded in the 1800s as a mining town (Ref. 6, p. 9). The SEC built and serviced electrical substations for the
local coal mining industry from approximately 1970 to 1985 (Refs. 6, p. 5; 7, p. 8). The substations incorporated
various types of transformers, capacitors, switches, and related voltage regulation and distribution devices that utilized
cooling oil that contained PCBs (Refs. 6, p. 5; 7, p. 8). SEC stored nonessential, damaged or outdated transformers
and capacitors on the approximate 1-acre property (Ref. 7, p. 8). The former SEC is situated on the southern bank of
Arbuckle Creek within the creek's floodplain on the western end of the town of Minden (Figures 1 and 3; Refs. 8;
11, p. 10). Arbuckle Creek flows eastward through the center of Minden (Ref. 6, p. 21). Residential, commercial,
vacant, and undeveloped properties border the creek on both the north and south banks, primarily within the creek's
designated floodplain (Figures 1,3,4,5, and 6; Refs. 8; 40).

Historically, it has been reported that Arbuckle Creek floods on average about 7 times a year, and in recent years the
creek has been known to flood approximately 4 to 5 times a year (Refs. 7, p. 102; 14, p. 1). Additionally, historic
flood events occurred in the eastern portion of West Virginia in 1985, as well as specifically in Minden, WV in July
2001, June 2016, and June 2017 (Refs. 15, pp. 20-37; 16, pp. 1-16; 17, pp. 1-11; 18, pp. 1, 2; 19, pp. 1-4; 20, pp. 1-4;
21,pp. l-5;22,pp. 1-5). In the summer of 1984, prior to the discovery of PCB contamination on the Shaffer property,
in efforts to control the periodic flooding of Arbuckle Creek, the creek was dredged and the sediments were placed on
residential properties as fill and in abandoned mine piles (Refs. 6, p. 9; 23, p. 9).

In September 1984, West Virginia Department of Natural Resources (DNR) conducted an inspection of the SEC
property located at the western end of the town of Minden, bordering Arbuckle Creek to the south (Figures 2 and 3;
Refs. 7, p. 8; 9, p. 1). During the initial inspection in September 1984 and a subsequent visit in October 1984,
WVDNR and EPA observed hundreds of transformers and capacitors across the property and noted most of the
capacitors were resting on their side, several of which had broken insulators with surrounding heavy oil spillage
evident (Refs. 7, p. 218; 9, p. 1; 10, pp. 1-3). A four-point composite soil sample in the transformer area, a grab soil
sample from the main transformer area, a grab soil sample from a drainage ditch leading towards Arbuckle Creek, and
surface and subsurface soil samples from the capacitor spillage area were collected, as well as two sediment samples
from Arbuckle Creek (Refs. 7, pp. 218 and 219; 10, pp. 1-7, 10, 11). Analytical data indicated the presence of PCBs
at concentrations of 8,200 parts per million (ppm) (0.82%) in the composite sample, 33 ppm in the main transformer
area soil sample, 260 ppm in the soil sample collected from the drainage ditch, 260,000 ppm (26%) in the surface soil
sample collected from the capacitor spillage area, and 40,000 ppm (4 %) in the subsurface soil sample collected from
the capacitor spillage area and 4 ppm and 3 ppm in the sediment samples collected from Arbuckle Creek (Refs. 7, pp.
218, 219; 10, pp. 5, 6, 10, and 11).

Subsequently, EPA conducted several investigations and removal actions at the SEC property. From December 1984
to December 1987, EPA conducted a removal action at the SEC property, which consisted of the removal and offsite
disposal of 4,735 tons of soil from an approximate 1-acre area that contained PCBs at concentrations greater than 50
ppm and the removal and offsite disposal of capacitors, transformers, and numerous drums of transformer fluid (Ref.
7, pp. 4 and 74). Six inches of surface soil was removed from an area of the western end of the property along
Arbuckle Creek (Area I) and post-excavation sample analysis indicated PCB concentrations <50 ppm. An area just
west of the former building along Arbuckle Creek (Area II) was excavated 2 feet and the post-excavation samples
indicated PCB concentrations <50 ppm (Refs. 12, p. 8; 11, p. 21). The excavated contaminated soils were staged in a

15

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SS-Site Summary

clay-lined holding cell located in the flood plain of Arbuckle Creek on the SEC property until November 1987 when
offsite disposal was completed (Ref. 7, pp. 102 and 415). On several occasions it was noted that the cover over the
soil was partially off, ripped, deteriorated and exposed to the elements (Ref. 7, pp. 355, 359, 369). Additional soil and
sediment samples collected in January 1985 indicated soil at residential property approximately 1 mile downstream
of the Shaffer property contained PCBs as high as 15 ppm and in Arbuckle Creek as high as 73 ppm 300 feet
downstream (Ref. 7, p. 237).

In March 1990, EPA conducted additional sampling on the SEC property, nearby residential properties, and from
Arbuckle Creek (Ref. 11, pp. 13, 15-19, and 21). Analytical data indicated PCBs on the SEC property as high 660,000
micrograms per kilograms (|ig/kg) in a sample collected from an on-property drainage ditch to Arbuckle Creek (SD-
8), 240,000 ng/kg in surface soil (S-l), 110,000 |ig/kg in subsurface soil (S-7), as high as 2,100 |ig/kg on residential
property (S-102), and as high as 5,200 |ig/kg in Arbuckle Creek sediment (SD-5) (Ref. 11, pp. 15-17^ 19, 21, 34, 36,
38, 40, and 43). Additional samples were collected from the SEC property in June 1990 with the highest
concentrations of PCBs detected at 40,302.8 ppm (Ref. 12, p. 8). In November 1990, EPA conducted a second removal
action at the SEC property that consisted of the excavation and off-property disposal soil from six areas at the property
at depths ranging from 1 inch to 4 feet below ground surface (bgs) (Refs. 12, pp. 8, 9; 13, p. 19). Post-excavation
samples collected from three areas were determined to be clean (Ref. 12, p. 8). Post-excavation samples collected
from a fourth area showed results of 772 ppm and less than 50 ppm (Ref. 12, p. 8). The remaining two areas indicated
PCB concentrations of 2,030 ppm and 10,500 ppm (Ref. 12, p. 9). Additional soil was excavated from these areas
(Ref. 12, p. 9). The excavated areas were backfilled with soil from a borrow area south of the SEC facility (Ref. 12,
p. 9). The backfilled area was resampled and PCB concentrations ranged from 0.1 to 1000 ppm (Ref. 12, p. 9).

Following the two soil excavation and off-property disposal removal actions conducted between 1984 and 1987 and
in 1990, in 1993 EPA collected 125 soil samples from the SEC property, eight soil samples from residential properties,
11 samples from a drainage ditch on the SEC property, and 24 sediment samples from Arbuckle Creek (Ref. 13, pp.
23-34, 36, 37, 39-50). Eleven samples indicated PCB concentrations greater than 50 ppm, 11 samples indicated PCB
concentrations between 10 ppm and 50 ppm, and 91 samples indicated PCB concentrations less than 10 ppm (Ref. 13,
pp. 13, 39-50). Twenty subsurface soil samples were collected from the SEC property and field-tested for PCBs (Ref.
13, p. 14). Two of the samples indicated PCB concentrations greater than 50 ppm and the remaining 18 indicated
PCB concentrations less than 10 ppm (Ref. 13, pp. 14, 39-41, 43-48).

From October 2001 through December 2001, the U.S. Army Corps of Engineers conducted a third removal action at
the SEC property that involved the installation of an impervious barrier/cap over a portion of the remaining
contaminated soil on the SEC property that consisted of a compacted clay layer and a 40-millimeter thick, high-density
polyethylene impervious cap/barrier placed over the compacted clay and installing metal sheet pilings along the bank
of Arbuckle Creek (Ref. 12, pp. 10, 12, 15, 16, 50-54). Excavated and capped areas at the SEC property are shown
on Figures 2 and 3.

EPA has investigated additional locations in Minden, WV as possible sources for PCBs detected in Arbuckle Creek
and in soil on residential properties. One location, known as Britt Bath House investigated in 1991 indicated limited
PCB soil contamination and is discussed in further detail in the Attribution Section of this HRS documentation record
(Ref. 53, pp. 63). Two other locations investigated in 1991 did not contain PCBs in the collected samples and thus
are not discussed further in this HRS documentation record (Refs. 54, pp. 8, 31, 32, 56, and 58, 60; Ref. 55, pp. 5, 28-
30,54-56,142,148,160,168,176,184,192,200,211,219). Residents have indicated to EPA that there are numerous
locations throughout the town where PCB oil was allegedly dumped as well as numerous locations where the
potentially PCB-contaminated sediments from Arbuckle Creek were placed. EPA and WVDEP are coordinating with
the local community to identify and evaluate these locations (Refs. 23, p. 9; 88, pp. 6, 9, 10, 22-24, 27).

16

-------
Oak Hiih

H/ib fca*c

MerrviPaf

Salem-

Hf^ak Hill

Wafer

Minden

Data Sources:
Ref. 84, pp. 1 and 2

USGS 7.5 Minute Quadrangle

Oakhiil, West Virginia, 1976. Revised 1978

Thurmond, West Virginia, 1976. Revised 1977

A

Coordinate System:
WGS84 UTM Zone 17N Feet

1,000

2,000

Feet

Shaffer Equipment/Arbuckle Creek Area
Minden, Fayette County, West Virginia

Figure 1
Site Location Map

TDD#: W503-17-12-001
Contract: EP-S3-15-02
Prepared: 8/9/2018

File: Y:\EPA_Region_lll\Shaffer\MXD\HRS\Resize\Site_Loc_Map.mxd, 8/9/20184:01:54 PM, ricksc

-------
Shaffer Equipment/Arbuckle Creek Area
Minden, Fayette County, West Virginia

Figure 2

Site Layout Map

TDD#: W503-17-12-001
Contract: EP-S3-15-02
Prepared: 8/20/2018

Legend

Approximate Shaffer Equipment
Company Boundary
|__| Sampling Areas
kVSI Capped Area Boundary

Excavation (6 inch)
I- I Excavation (2 ft)

			» New River Gorge

o=J National River Park Boundary
111 ] Source 2/AOC A
£Z3 Delineated Wetland Boundaries
	Arbuckle Creek

Data Sources:

Refs. 11, p. 10; 12, pp. 51-53; 32, pp. 1,2; 67,

p. 13; 84, pp. 1,2; 85, pp. 1, 2; 96

Section 2.2.2 of this HRS documentation record

Background: ESRI, Mapping Service
The source of this map image is Esri,
used by the EPA with Esri's permission

Coordinate System:
WGS84 UTM Zone 17N Feet

-------
File: Y:\EPA_Region_lll\Shaffer\MXD\HRS\Resize\Samp_Location_Area1_NP_85x14.mxd, 8/20/2018 3:10:39 PM, ricksc

Legend

| Approximate Shaffer Equipment
j Company Boundary
i~ ¦ Former Building

Capped Area Boundary
Excavation (6 inch)

Excavation (2 ft)

'.1*^1 FEMA Flood Zone A
Eza Delineated Wetland Boundaries
zone Sheet Pile Wall

- Current Drainage Ditch
Former Drainage Ditch
— Arbuckle Creek
(8> Sediment Sample Location
B Soil Sample Location
(8> Background Sediment Sample Location
¦ Background Soil Sample Location

PPE 1

Flow Direction

Background: ESRI, Mapping Service
The source of this map image is Esri,
used by the EPA with Esri's permission

Coordinate System:
WGS84 UTM Zone 17N Feet

Shaffer Equipment/Arbuckle Creek Area
Minden, Fayette County, West Virginia

Figure 3

Source 1 and

Background Soil and
Sediment Samples

TDD#: W503-17-12-001
Contract: EP-S3-15-02
Prepared: 8/20/2018

-------
SS14
-SS-I5'

[SBp

SEG.-SS^Ig@]
-SD03, \
SE©-SD-m03
*K8.'Q5 ^3sS42

¦SD04

SD05

r

r 1

-	V

-

SEC-SS-T?5-04 ¦

Legend

~ FEMA Flood Zone A

Delineated Wetland Boundaries
I 1 Source/AOC A
—- - Arbuckle Creek
PPE 2

® Sediment Sample Location
O Soil Sample Location
¦ Level I Target Soil Sample
H Level II Target Soil Sample

Farthest Upstream Point
M for PPE2

Flow Direction

Data Sources:

Refs. 8; 32, pp. 1,2; 84, pp. 1,2;

85, pp. 1, 2

Section 2.2.2 of this HRS documentation record.
Section 4.1.1.1 of the HRS documentation
record.

Section 5.1.1.3.2 of the HRS documentation
record.

Background: ESRI, Mapping Service
The source of this map image is Esri.
used by the EPA with Esri's permission

Coordinate System:
WGS84 UTM Zone 17N Feet

Shaffer Equipment/Arbuckle Creek Area
Minden, Fayette County, West Virginia

Figure 4

Source 2
and Sediment Samples

TDD#: W503-17-12-001
Contract: EP-S3-15-02
Prepared: 8/20/2018



File: Y:\EPA_Region_lll\Shaffer\MXD\HRS\Resize\Samp_Location_Area2_NP_85x14.mxd, 8/20/2018 3:10:49 PM, ricksc

-------
SB.06

SD09

SD.07

!mmmim

Legend

|__| FEMA Flood Zone A
IE3 Delineated Wetland Boundaries
{ Source Area/AOC A
—Arbuckle Creek
PPE 2

<8> Sediment Sample Location
~ Soil Sample Location
HI Level II Target Soil Sample
Flow Direction

'S013

SD08:

SS44

Data Sources:

Refs. 8; 32, pp. 1,2; 84, pp. 1,2.

Section 2.2.2 of this HRS documentation record.

Section 4.1.1.1 of the HRS documentation

record.

Section 5.1.1.3.2.2 of the HRS documentation
record.

Background: ESRI, Mapping Service
The source of this map image is Esri\
used by the EPA with Esri's permission

Coordinate System:
WGS84 UTM Zone 17N Feet

Shaffer Equipment/Arbuckle Creek Area
Minden, Fayette County, West Virginia

Figure 5

Source 2
and Sediment Samples

TDD#: W503-17-12-001
Contract: EP-S3-15-02
Prepared: 8/20/2018



Cila- V XETDA	IHlQhiffDriH/IVraUDODaciTolComr, I witinn A	MD R^vl /I mvfl ft/Oft/OHl R <*• 11 nO DM ri

-------
SD17

sd;i2

SD/I*5'

SD10

SD13

Legend

j~"ill FEMA Flood Zone A

— . New River Gorge

National River Park Boundary
I I Source Area/AOC A
—- Arbuckle Creek
PPE 2

(8> Sediment Sample Location
¦ Soil Sample Location
H Level II Target Soil Sample
—¦* Flow Direction

SEG-SSJ05-

= .D-55

¦SD-58

Data Sources:

Refs. 8; 32, pp. 1, 2; pp. 1, 2: 96.

Section 2.2.2 of this HRS documentation record.

Section 4.1.1.1 of the HRS documentation

record.

Background: ESRI, Mapping Service
The source of this map image is Esri,
used by the EPA with Esri's permission

Coordinate System:
WGS84 UTM Zone 17N Feet

Shaffer Equipment/Arbuckle Creek Area
Minden, Fayette County, West Virginia

SlHUfl

Figure 6

Source 2
and Sediment Samples

Cila- VXETDA	IHlQhiffDriH/IVraUDODaciTolComr, I witinn A A MD R^vl /I mvfl S/Oft/OrH R <*• 1 «¦ DM ri

TDD#: W503-17-12-001
Contract: EP-S3-15-02
Prepared: 8/20/2018

-------
Hopewell

Figure 7
Surface Water Pathway Map
Shaffer Equipment/Arbuckle Creek Area
Minden, Fayette County, West Virginia

Hawks Nest

Legend

Mile Marker

Bachman

Fifteen Mile Surface Water Pathway

NWI Wetlands

jngstoi

SOURCE: USGS 7.5 Minute Series (Topographic) Quadrangles:
Fayetteville, WV, 1977; Thurmond, WV, 1977;

Section 4.1.1.2 of the HRS documentation record.
Ref. 95

TDD#: W503-17-12-001
Contract: EP-S3-15-02
Prepared: 8/13/2018

Cunard

Water
Tank

KtOW

File: Y:\EPA_Region_lll\Shaffer\MXD\HRS\Resize\15Mile_85xl4.mxd, 8/13/2018 12:25:56 PM, ricksc

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Source Characterization
Source No.: 1

2.2

SOURCE CHARACTERIZATION

2.2.1

Source Identification

Number of the source:

Source No. 1

Name of source:

Shaffer Contaminated Soil

Source Type:

Contaminated Soil

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

Source No. 1 is located on the SEC property, as shown on Figure 3. Source No. 1, contaminated soil, consists of an
area of PCB-contaminated soil of an undetermined extent on the SEC property that has resulted from the migration,
deposition, or spillage of hazardous substances associated with the handling, storage, maintenance, and management
practices involving hundreds of PCB-containing transformers and capacitors (Refs. 7, pp. 8, 18, 32, 218, 219, and
231; 9, p. 1; 10, pp. 1-3; 11, pp. 7, 9, 10, 23, 24).

As discussed in the Site Summary Section, EPA has conducted numerous investigations and removal actions at the
SEC property since 1984, including the removal and offsite disposal of PCB-contaminated soil. During the initial
removal from 1984-1987, soils containing PCBs at concentrations less than 50 ppm were left in place and backfilled
(Ref. 7, p. 259). Additionally, post-excavation and post-backfill samples collected following the second removal in
1990 indicated PCB concentrations as high as 1,000 ppm in the backfilled area (Ref. 12, p. 9). Fifty ppm
(1 ppm = 1 mg/kg) in soil for PCBs exceeds the HRS soil exposure component benchmarks as well as the RSLs for
residential and industrial soil (Refs. 2, p. 3; 24, p. 10).

Source 1 is characterized by two soil samples collected in December 2017 from the SEC property; SEC-SS-SE-01
was collected from beyond the excavated and backfilled area adjacent to a demolished building reportedly used for
storage in the southwest corner of the former SEC property and SEC-SS-SE-02 was collected from a drainage channel
beneath a broken section of the capped wall in the northeast corner of the former SEC property (Figure 3; Refs. 26,
p. 7; 27, pp. 31-32; 66, p. 15; 84, p. 2).

As evidenced by the historical sampling following the removal actions as well as the analytical data collected as part
of this HRS investigation that show the presence of PCBs in soil on the SEC property at concentrations significantly
above background (see Section 2.2.2), all site-related waste has not been removed.

24

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Source Characterization - Hazardous Substances

Source No.: 1

2.2.2	Hazardous Substances Associated with Source

Though not required by the HRS, to document the presence of PCBs in the source at significant concentrations, the
analytical results of the soil/source samples collected in December 2017 were compared to background soil samples
collected in June 2017, December 2017, and March 2018 from properties located upstream from the SEC property at
locations not expected to have been impacted by surface water runoff or flooding from the source (Refs. 26, p. 7; 27,
p. 30, 31, 32; 30. p. 18; 31, p. 41; 32, pp. 1, 2; 44, p. 35; 47, pp. 5, 6, and 7; 64, p. 21; 84, pp. 1, 2; 85, pp. 1, 2; 1,
Section 2.2.2). All soil samples from the June 2017, December 2017, and March 2018 sampling events were submitted
to and analyzed by an EPA Contract Laboratory Program (CLP) laboratory for PCBs in accordance with CLP
Statement of Work (SOW) SOM02.4, and the analytical data were validated by EPA Region 3 Environmental Services
Assistance Team (ESAT) according to the National Functional Guidelines for Organic Superfund Methods Data
Review and applicable USEPA Region 3 modifications (Refs. 26, p. 7; 28, pp. 1, 2, 23; 30. p. 18; 31, pp. 1, 3, 4, and
41; 44, pp. 1,2, and 35; 47, pp. 5, 6, and 7; 64, pp. 1, 2, and 21). The background soil samples and source soil samples
are all grab samples consisting of similar matrices comprised of silt, silty-sand, and silty-clay with comparable percent
solids ranging from 65.2% to 79.6% (Refs. 26, p. 7; 27, pp. 30, 31, 32; 30, p. 18; 31, pp. 18, 19, 41; 28, pp. 13, 14,
23; 44, pp. 30, 35; 47, pp. 5,6,7; 64, pp. 10,12,13,14,15,21). The background soil and source soil samples collected
in June and December 2017 and March 2018 were documented as having been collected between 0 to 6 inches bgs (0
to 0.5 feet bgs) (Refs. 26, p. 14; 27, pp. 30, 31, 32; 47, p. 8; 35, p. 3; 48, pp. 10, 11).

The following table summarizes analytical results of background soil samples. If a background concentration was
reported at an estimated concentration below the adjusted EPA Contract Laboratory Program Contract Required
Quantitation Limit (CRQL), the higher of the adjusted CRQL, or three times the estimated concentration was used to
determine elevation over background (Ref. 1, Table 2-3). The highest of the background concentrations or the highest
adjusted CRQL is used for comparison against all the soil/source data. PCB concentrations at or above the highest
adjusted CRQL, 48 |ig/kg. are elevated above background. The background soil samples are shown on Figure 3.

Table 1

Source No. 1 -Background Soil Samples

CLP
Sample
ID

Field Sample
ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(ng/kg)

References

C0AD8

SS11

6/15/17

PCB -
Aroclor 1260

11 J1

44

30, p. 18; 31, pp. 1-5, 18, 41, 101; 35,
pp. 1 and 3

C0AD9

SS12

6/15/17

PCB -
Aroclor 1260

15J1

43

30, p. 18; 31, pp. 1-5, 19, 41, 106; 35,
pp. 1 and 3

C0AG6

SEC-SS-R5-01

12/13/17

PCB -
Aroclor 1260

41U

41

26, p. 7; 27, p. 30; 38, pp. 1 and 11;
44, pp. 1-4, 30, 35, 145

C0AE6

SS-150

3/20/18

PCB -
Aroclor 1260

48U

48

47, p. 5-6; 48, pp. 1 and 10; 64, pp. 1-
4, 10,21,56

C0AE8

SS-152

3/20/18

PCB -
Aroclor 1260

48U

48

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
12,21,64

C0AE9

SS-153

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
13,21,67

C0AF0

SS-154

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
14,21,70

C0AF1

SS-155

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 7; 48, pp. 1 and 11; 64, pp. 1-4,
15,21,73

Notes:

The Sample Adjusted CRQL is the CRQL adjusted for sample weight, volume, dilution, and percent solid (Refs. 36, pp. 134, 135, 503, 504).
CLP = Contract Laboratory Program

CRQL: EPA Contract Laboratory Program Contract Required Quantitation Limit
PCB = polychlorinated biphenyl
Hg/kg = micrograms per kilogram

J = The result is an estimated quantity. The associated numerical value is the approximate concentration of the analyte in the sample (Ref. 31, p.
4). Samples reporting concentrations of target analytes less than CRQLs are estimated and have been qualified J (Refs. 31, pp. 1-5; 49, pp. 246,
247).

25

-------
Source Characterization - Hazardous Substances

Source No.: 1

U= The analyte was analyzed for, but was not detected above the level of the reported sample quantitation limit

1 Qualified background data were used in accordance with EPA Fact Sheet Using Qualified Data to Document an Observed Release and Observed
Contamination, which states "The adjustment factors apply only to "J" qualified data above the CRQL"; therefore, the qualified data was not
adjusted (Ref. 37, pp. 4). Although the fact sheet was not intended for application to source data, it has been applied in this situation to demonstrate
the relative increase in contamination in the samples over background levels.

The following table summarizes analytical results of Source 1 soil samples. Source 1 soil sample locations are on
Figures 3.

Table 2
Source No. 1 -Soil Samples

CLP
Sample
ID

Field
Sampling
ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(lig/kg)

References

C0AG7

SEC-SS-
SE-01

12/13/17

PCB - Aroclor
1260

54,000

25,000

26, p. 7; 27, p. 31; 28, pp. 1-4, 13, 23,
80; 38, pp. 1 and 3

C0AG8

SEC-SS-
SE-02

12/13/17

PCB - Aroclor
1260

270

43

26, p. 7; 27, p. 32; 28, p. 1-4, 14, 23,
83; 38, pp. 1 and 3

Notes:

The Sample Adjusted CRQL is the CRQL adjusted for sample weight, volume, dilution, and percent solid (Refs. 36, pp. 134, 135, 503, 504).
CLP = Contract Laboratory Program

CRQL = EPA Contract Laboratory Program Contract Required Quantitation Limit
PCB = polychlorinated biphenyl
SEC = Shaffer Equipment Company
Hg/kg = micrograms per kilogram

26

-------
Source Characterization - Containment
Source No.: 1

2.2.3 Hazardous Substances Available to a Pathway

Source 1, which includes two samples that document concentrations of PCBs above background level as noted in
Section 2.2.2, is located within Arbuckle Creek's floodplain (Figure 3). Additionally, source sample SEC-SS-SE-02
was collected from a drainage channel beneath a broken section of the capped wall in the northeast corner of the
former SEC property that leads into Arbuckle Creek (Figure 3; Refs. 26, p. 7; 27, p. 32; 66, p. 15). Chemical analysis
of sediment samples collected from Arbuckle Creek downstream of the source document a release of attributable
hazardous substances to the surface water migration pathway (see Section 4.1.2.1.1),

As part of the 1984-1987 removal actions, EPA constructed a 3-foot high berm along Arbuckle Creek and the SEC
property in September 1985 (Ref. 7, p. 42, 74). However, it was noted in the 2003 Final Removal Action report that
extensive flooding had significantly eroded the bank of Arbuckle Creek and affected the berms constructed during the
previous removal actions (Ref. 12, pp. 5, 319-328). During the removal actions conducted between October and
December 2001, a metal sheet pile wall was constructed along the northern perimeter of the cap along a portion of
Arbuckle Creek, as shown on Figure 3 (Ref. 12, pp. 12, 15, 16, 52, and 53). The metal sheet piling extends between
approximately 1 and 3 feet above the elevation of the cap (Ref. 12, pp. 52, 53, 381). Additionally, a riprap drainage
ditch was constructed along the southern, western and eastern boundaries of the cap to divert surface water away from
the capped area (Ref. 12, pp. 10-12, 53). The cap was inspected in April and May 2002 with a final inspection
conducted in December 2002 by USEPA, WVDEP and US ACE; however, there is no documentation that any further
inspection or maintenance was conducted by the property owner, WVDEP, or EPA (Refs. 12, p. 16; 39, pp. 1-2).

In June 2016, a 1-in-1,000-year flood occurred in Fayette County, WV, with approximately 8 to 10 inches
(200-250 millimeter) of rain falling between 7 am and 8 pm (13 hours), Fayette County was declared a federal major
disaster (Refs. 18, pp. 1-2; 19, p. 1). In June 2017, severe flooding occurred in Minden, WV, with roadways closed
due to Arbuckle Creek flooding the streets (Refs. 20, p. 2; 21, pp. 1-3; 22, pp. 1-5).

As noted above, no maintained engineered cover or functioning and maintained run-on control system and runoff
management system is documented for soil sample/source sample SEC-SS-SE-02 and the complete absence of a
maintained engineered cover or functioning and maintained run-on control system and runoff management system is
documented for soil sample/source sample SEC-SS-SE-01 used to characterize Source 1 and the lack of a designed,
constructed, operated, and maintained source containment to prevent a washout of hazardous substances by flood. As
documented in Section 4.1.2.1.1, source-related contaminants are present in Arbuckle Creek. Based on lack of
overland flow/flood containment features, the containment factor for the surface water migration pathway is assigned
a value of 10 (Ref. 1, Table 4-2 and Table 4-8).

Containment Description

Containment Factor

References

Release via overland migration:

lack of a maintained engineered
cover, and any complete run-on and
runoff control management systems

10

1, Table 4-2

Release flood:

lack of a designed, constructed,
operated, and maintained source
containment to prevent a washout of
hazardous substances by flood

10

1, Table 4-8

27

-------
SD-Hazardous Waste Quantity
Source No.: 1

2.4.2.1 Hazardous Waste Quantity

2.4.2.1.1	Hazardous Constituent Quantity

The hazardous constituent quantity for Source No. 1 could not be adequately determined according to the HRS
requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the source
is not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.1). There are insufficient
historical and current data (e.g., manifests, Potentially Responsible Party (PRP) records, State records, permits, waste
concentration data, etc.) available to adequately calculate the total mass of all CERCLA hazardous substances in the
source and the associated releases from the source. Therefore, there is insufficient information to evaluate the
associated releases from the source to calculate the hazardous constituent quantity for Source No. 1 with reasonable
confidence. Scoring proceeds to the evaluation of Tier B, Hazardous Wastestream Quantity (Ref. 1, Section2.4.2.1.1).

Hazardous Constituent Quantity (C) Value: NS

2.4.2.1.2	Hazardous Wastestream Quantity

The hazardous wastestream quantity for Source No. 1 could not be adequately determined according to the HRS
requirements; that is, the mass of the hazardous wastestreams plus the mass of any additional CERCLA pollutants and
contaminants in the source and releases from the source is not known and cannot be estimated with reasonable
confidence (Ref. 1, Section 2.4.2.1.2). There are insufficient historical and current data (e.g., manifests, PRP records,
State records, permits, waste concentration data, annual reports, etc.) available to adequately calculate the total mass
or partial mass of the wastestream plus the mass of all CERCLA pollutants and contaminants for the source and the
associated releases from the source. Therefore, insufficient information is available to evaluate the associated releases
from the source to calculate or extrapolate the hazardous wastestream quantity for Source No. 1 with reasonable
confidence. Scoring proceeds to the evaluation of Tier C, Volume [Ref. 1, Section 2.4.2.1.2],

Hazardous Wastestream Quantity (W) Value: NS

2.4.2.1.3	Volume

The information available on the depth of Source No. 1 is not sufficiently specific to support an exact volume of the
contaminated soil with reasonable confidence; therefore, it is not possible to assign a volume (Tier C) for Source 1
(Ref. 1, Section2.4.2.1.3). Source 1 has been assigned a value of 0 for the volume measure (Ref. 1, Section2.4.2.1.3).
As a result, the evaluation of HWQ proceeds to the evaluation of Tier D, area (Ref. 1, Section 2.4.2.1.3).

Volume (V) Value: 0

2.4.2.1.4	Area

As presented in Section 2.2.2 of this HRS documentation record, contaminated soil has been documented at the site;
however, a definitive area of contamination has not been determined (Figure 3). An area of contaminated soil cannot
be quantified based on the soil sampling locations from the December 2017 sampling event. Because the information
available is insufficient to estimate the area and measure with reasonable confidence [as required in Section 2.4.2.1.4
of Reference 1], a value of greater than zero (>0) is established as the source hazardous waste quantity (HWQ) value
for Tier D - area. The source type is "Contaminated Soil," so the area value is divided by 34,000 to obtain the assigned
value of >0, as shown below (Ref. 1, Section 2.4.2.1.4, Table 2-5).

Area of source in square feet (ft2) = >0
Area (A) Assigned Value: >0/34,000 = >0

2.4.2.1.5	Source Hazardous Waste Quantity Value

The highest assigned source hazardous waste quantity value for Source No. 1 was assigned based on D - Area [Ref.
1, Table 2-5],

Source Hazardous Waste Quantity Value: >0

28

-------
Source Characterization
Source No.: 2

2.2

SOURCE CHARACTERIZATION

2.2.1

Source Identification

Number of the source:

Source No. 2

Name and description of the source:

Downstream Contaminated Soil

Source Type:

Contaminated Soil

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

Source No. 2, contaminated soil, is located on portions of numerous parcels within and adjacent to the floodplain of
Arbuckle Creek (see Figures 4,5, and 6) downstream of the SEC property. Source No. 2 is likely primarily a product
of the PCB-contaminated sediments within Arbuckle Creek being deposited onto the properties as a result of the
periodic and historic flooding of Arbuckle Creek (Refs. 7, p. 102; 12, pp. 5, 319-328; 14, p. 1; 16, pp. 1-15; 17, pp. 1-
11; 21, pp. 1-3; and 22, pp. 1-5). The separate areas of contaminated soil, as documented by the analytical results
presented in Table 4 of this HRS documentation record, are aggregated into a single source for this HRS scoring for
the following reasons: the same source type (i.e., contaminated soil), affects similar targets (i.e., sensitive
environments, see Section 4.1.4.3 and resident population, see Section 5.1.1.3), the same contaminant of concern (i.e.,
PCBs), is deposited in a similar manner (i.e., deposition by flooding).

Historically, soil samples collected from residential properties located along Arbuckle Creek up to 1 mile downstream
of the SEC property have contained concentrations of PCBs up to 15 ppm (Ref. 7, p. 237). Analytical data of soil
samples from March 1985 showed PCBs up to 7 ppm in a residential yard approximately 0.6 mile from the SEC
property and up to 7 ppm in a sediment sample collected from Arbuckle Creek approximately 0.6 mile downstream
from the SEC property (Ref. 7, p. 258). Additional soil sampling conducted on several occasions throughout the
1990s at the SEC property and sediment sampling of Arbuckle Creek continued to show the presence of PCBs (Refs.
11, pp. 15-17, 19, 21, 34, 36, 38, 40, and 43; 12, p. 8; 13, pp. 13, 14, 23-34, 36, 37, 39-50).

Arbuckle Creek is prone to annual periodic flooding and occasional significant flooding
(Refs. 7, p. 102; 12, pp. 5,319-328; 14, p. 1; 16, pp. 1-15; 17, pp. 1-11; 20, pp. 1-3; 21, pp. 1-3; and 22, pp. 1-5). Prior
to the initial Removal Action, EPA noted that recent past floods had fully engulfed the Shaffer property and there was
evidence of stream scouring and flood damage on the property (Ref. 7, p. 102). Prior to the third removal action,
which consisted of capping a portion of the contaminated soil, a major flood event occurred in July 2001. Photographs
taken of the SEC property in August, September, and October 2001 following the flood, document widespread damage
and drainage channels across the property (Ref. 12, pp. 13-16, 318-325). Additionally, it was noted that the extensive
flooding significantly eroded the bank of Arbuckle Creek and affected the berm constructed during the removal
activities in 1987 (Ref. 12, p. 5). The 2001 Flood event engulfed the entire town of Minden depositing large amounts
of sediment on residential property (Refs. 16, pp. 1-5; 17, 1-11). Two additional major flood events occurred in June
2016 and June 2017 that engulfed the entire town of Minden (Refs. 18, pp. 1-3; 19, p. 1; 20, pp. 1-3; 21, pp. 1-3; and
22, pp. 1-5). In June 2016, a 1-in-l,000-year flood occurred in Fayette County, WV, with approximately 8 to 10
inches (200-250 millimeter) of rain falling between 7 am and 8 pm (13 hours) and in June 2017, severe flooding
occurred in Minden, WV, with roadways closed due to Arbuckle Creek flooding the streets (Refs. 19, p. 1; 20, p. 2;
21, pp. 1-3; 22, pp. 1-5). Six additional flood events (i.e., 19 feet and above) have been recorded at the New River
gauging station at Thurmond, located near the confluence of Arbuckle Creek (Ref. 42, p. 1). At 19 feet, flooding of
low areas starts along the New River and up Dunloup Creek and Arbuckle Creek with portions of county routes 2, 25
and 17 starting to flood. At 20 feet, major flooding of low areas has occurred along the New River and up Dunloup
Creek and Arbuckle Creek with portions of county routes 2, 25 and 17 flooded (Ref. 42, p. 2).

Source 2 is characterized by soil samples collected from parcels within and adjacent to the creek's floodplain in June
2017, December 2017, and March 2018 (Figures 4, 5, and 6; Refs. 26, pp. 2, 4, 5, 8, and 10; 27, pp. 27, 34, 38, 41,
44, 49, 51, 55, 56; 28, pp. 22, 23; 30, pp. 14, 15, 17, 18; 31, pp. 39, 40; 43, pp. 37, 38, 39, 40; 44, pp. 34, 35; 45, pp.
32, 33, 34; 46, pp. 31, 32; 51, p. 16). The samples collected in June 2017 were collected 8 to 10 days following a
major flood event in the Town of Minden (Refs. 20, p. 2; 21, pp. 1-3; 22, pp. 1-5; 30, pp. 14, 15, 17, and 18).

29

-------
Source Characterization - Hazardous Substances

Source No.: 2

2.2.2	Hazardous Substances Associated with Source

Though not required by the HRS, to document the presence of PCBs in the source at significant concentrations, the
analytical results of the soil/source samples collected in June 2017, December 2017, and March 2018 were compared
to soil samples collected in June 2017, December 2017, and March 2018 from properties located upstream from the
SEC property at locations not expected to have been impacted by surface water runoff or flooding from the source
(Refs. 26, p. 7; 27, p. 30; 30. p. 18; 31, p. 41; 32, p. 1, 2; 44, p. 35; 47, pp. 5-7; 64, pp. 21; 84, pp. 1, 2; and 85, pp. 1,
2).

The soil samples from the June 2017, December 2017, and March 2018 sampling events were submitted to and
analyzed by an EPA Contract Laboratory Program (CLP) laboratory for Aroclors (i.e., PCBs) in accordance with CLP
Statement of Work (SOW) SOM02.4, and the analytical data were validated by EPA Region 3 Environmental Services
Assistance Team (ESAT) according to the National Functional Guidelines for Organic Superfund Methods Data
Review and applicable USEPA Region 3 modifications (Refs. 26, pp. 3,5,6, 7, 8, 10; 28, pp. 1, 2; 30, pp. 17, 18; 31,
pp. 1, 3; 43, pp. 1, 3; 44, pp. 1, 2; 45, pp, 1, 3; 46, pp. 1, 2; 47, pp. 6, and 7; 51, pp. 1, 3; 64. pp. 1, 2). The background
soil samples and source soil samples are all grab samples consisting of similar matrices comprised of top soil/organics,
silt, silty-sand, and silty-clay with comparable percent solids ranging from 68.9% to 79.6% for background samples
and 63.5% to 84.9% for source/soil samples with two exceptions; sample SS-22 had a percent solid of 44.3% and
sample SS-26 had a percent solid of 48.6% (Refs. 26, pp. 3, 5, 6, 7, 8, and 10; 27, pp. 27, 28, 30, 34, 38, 41, 44, 49,
51, 55, 56; 28, pp. 11, 22; 30, pp. 17, 18; 31, pp. 18, 19, 39; 43, pp. 10, 11, 12, 13, 17, 18, 19, 21, 24, 25, 26, 27, 28,
29, 37, 38, 39; 44, pp. 15, 22, 23, 26, 30, 34, 35; 45, pp. 8, 13, 16, 20, 26, 28, 32, 33, 34; 46, pp. 12, 28, 32; 47, pp. 5,
6, 7; 51, pp. 8, 16; 64, pp. 10, 12, 13, 14, 15, 21). The background soil and source soil samples collected in June and
December 2017 and March 2018 were documented as having been collected between 0 to 6 inches bgs (0 to 0.5 feet
bgs) (Refs. 26, p. 14; 27, pp. 27, 30, 34, 38, 41, 44, 49, 51, 55, and 56; 47, p. 8; 35, pp. 3, 12, 13, 14, 15, and 16; 48,
pp. 3,10, 11). The December 2017 and March 2018 soil samples were collected using a dedicated polyethylene scoop
and homogenizing the soil in a disposable aluminum pan (Refs. 26, p. 14; 47, p. 8).

The following tables summarize analytical results of background soil samples. If a background concentration was
reported at an estimated concentration below the adjusted CRQL, the higher of the adjusted CRQL, or three times the
estimated concentration was used to determine elevation over background (Ref. 1, Table 2-3). The highest of the
background concentrations or the highest adjusted CRQL is used for comparison against all the soil/source data. The
background concentration used for comparison is 48 |ig/kg. PCB concentrations at or above 48 |ig/kg. the highest
adjusted CRQL, are elevated above background. Background sample locations are on Figure 3.

30

-------
Source Characterization - Hazardous Substances

Source No.: 2

Table 3

Source No. 2 -Background Soil Samples

CLP
Sample
ID

Field
Sample
ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(ng/kg)

References

C0AD8

SS11

6/15/17

PCB -
Aroclor 1260

11 J1

44

30, p. 18; 31, pp. 1-5, 18, 41, 101; 35,
pp. 1 and 3

C0AD9

SS12

6/15/17

PCB -
Aroclor 1260

15 J1

43

30, p. 18; 31, pp. 1-5, 19, 41, 106; 35,
pp. 1 and 3

C0AG6

SEC-SS-
R5-01

12/13/17

PCB -
Aroclor 1260

41U

41

26, p. 7; 27, p. 30; 38, pp. 1 and 11;
44, pp. 1-4, 30, 35, 145

C0AE6

SS-150

3/20/18

PCB -
Aroclor 1260

48U

48

47, p. 5-6; 48, pp. 1 and 10; 64, 1-4,
pp. 10, 21, 56

C0AE8

SS-152

3/20/18

PCB -
Aroclor 1260

48U

48

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
12,21,64

C0AE9

SS-153

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
13,21,67

C0AF0

SS-154

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
14,21,70

C0AF1

SS-155

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 7; 48, pp. 1 and 11; 64, pp. 1-4,
15,21,73

Notes:

The Sample Adjusted CRQL is the CRQL adjusted for sample weight, volume, dilution, and percent solid (Refs. 36, pp. 134, 135, 503, 504).
CLP = Contract Laboratory Program

CRQL = EPA Contract Laboratory Program Contract Required Quantitation Limit
PCB = polychlorinated biphenyl
Hg/kg = micrograms per kilogram

J = The result is an estimated quantity. The associated numerical value is the approximate concentration of the analyte in the sample (Ref. 31, p.
4). Samples reporting concentrations of target analytes less than (CRQLs) are estimated and have been qualified J; no bias is associated (Ref. 31,
pp. 1-5; 49, pp. 246, 247).

U= The analyte was analyzed for, but was not detected above the level of the reported sample quantitation limit (Refs. 44, p. 4; 64, p. 4)
1 Qualified background data were used in accordance with EPA Fact Sheet Using Qualified Data to Document an Observed Release and Observed
Contamination, which states "The adjustment factors apply only to "J" qualified data above the CRQL"; therefore, the qualified data was not
adjusted (Ref. 37, pp. 4). Although the fact sheet was not intended for application to source data, it has been applied in this situation to demonstrate
the relative increase in contamination in the samples over background levels.

The following table summarizes analytical results of Source 2 soil samples. Source 2 soil sample locations are on
Figures 4,5, and 6.

Table 4
Source No. 2 - Soil Samples

CLP
Sample
ID

Field
Sample ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(lig/kg)

References

C0AE0

SS13

6/15/17

PCB -
Aroclor 1260

450

49

30, p. 18; 35, pp. 1 and 12; 43, pp.
1-5, 10,37,71

C0AE1*
(C0AE2)

SS14
(SS15)

6/15/17

PCB -
Aroclor 1260

91
(90)

50
(50)

30, p. 18; 35, pp. 1 and 12; 43, pp.
1-5, 11, 38, 76

(30, p. 18; 35, pp. 1 and 12; 43, pp.
1-5, 12,38,81)

C0AE3

SS16

6/15/17

PCB -
Aroclor 1260

260

42

30, p. 18; 35, pp. 1 and 12; 43, pp.
1-5, 13,38, 86

C0AE5

SS18

6/15/17

PCB -
Aroclor 1260

340

39

30, p. 18; 35, pp. 1 and 13; 43, pp.
1-5, 17, 38, 96

31

-------
Source Characterization - Hazardous Substances

Source No.: 2

Table 4
Source No. 2 - Soil Samples

CLP
Sample
ID

Field
Sample ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(lig/kg)

References

C0AE6

SS19

6/15/17

PCB -
Aroclor 1260

210

46

30, p. 18; 35, pp. 1 and 13; 43, pp.
1-5, 18,38, 101

C0AE7

SS20

6/15/17

PCB -
Aroclor 1260

160

40

30, p. 18; 35; pp. 1 and 13; 43, pp.
1-5, 19, 38, 106

C0AE9

SS22

6/15/17

PCB -
Aroclor 1260

200

74

30, p. 18; 35, pp. 1, 13; 43, pp. 1-5,
21, 39, 116

C0AF2

SS25

6/15/17

PCB -
Aroclor 1260

100

50

30, p. 18; 35, pp. 1, 14; 43, pp. 1-5,
24, 39, 132

C0AF3

SS26

6/15/17

PCB -
Aroclor 1260

660

67

30, p. 17; 35 pp. 1 and 14; 43, pp.
1-5,25,39, 137

C0AF4

SS27

6/15/17

PCB -
Aroclor 1260

350

47

30, p. 17; 35, pp. 1 and 14; 43, pp.
1-5, 26, 39, 142

COAMO

SS41

6/14/17

PCB -
Aroclor 1260

130

47

30, p. 15; 35, pp. 1, 14; 43, pp. 1-5,
27, 39, 147

C0AM7

SS42

6/15/17

PCB -
Aroclor 1260

230

41

30, p. 17; 35, pp. 1 and 14; 43, pp.
1-5, 28, 40, 152

C0AM8

SS43

6/15/17

PCB -
Aroclor 1260

1,300

49

30, p. 17; 35, pp. 1 and 15; 43, pp.
1-5, 29, 40, 157

C0AN1

SS44

6/15/17

PCB -
Aroclor 1260

1200

89

30, p. 18; 51, pp. 1-5, 8, 16, and
46; 35, pp. 1 and 16

C0AG4

SEC-SS-
TL-43C

12/13/17

PCB -
Aroclor 1260

58

47

26, p. 6; 27, p. 27; 38, pp. 1, 11;
44, pp. 1-4, 26,35, 139

COAGO

SEC-SS-
R3-01

12/13/17

PCB -
Aroclor 1260

310

49

26, p. 6; 38, pp. 1, 10; 44, pp. 1-4,
23, 35, 124

C0AC6

SEC-SS-
Rl-06

12/12/17

PCB -
Aroclor 1260

64

49

26, p. 3; 27, p. 56; 38, pp. 1 and 9;
44, pp. 1-4, 15, 34, and, 88

C0AF6

SEC-SS-
T8-04

12/13/17

PCB -
Aroclor 1260

220

44

26, p. 6; 27, p. 55; 28, pp. 1-4, 11,
22, 63; 38, pp. 1, 2

C0AF2

SEC-SS-
T8-05/
SEC-SD-
T8-05**

12/13/17

PCB -
Aroclor 1260

410

41

26, p. 6; 27, p. 51; 38, pp. 1, 15;
45, pp. 1-5,28,34, 146

C0AF9

SEC-SS-
R2-01

12/13/17

PCB -
Aroclor 1260

140

46

26, p. 6; 38, pp. 1, 10; 44, pp. 1-4,
22, 35, 118

C0AE4

SEC-SS-
T7-04

12/13/17

PCB -
Aroclor 1260

60

43

26, p. 5; 27, p. 44; 38, pp. 1, 14;
45, pp. 1-5,20,33, 119

C0AE9

SEC-SS-
T7-05

12/13/17

PCB -
Aroclor 1260

59

39

26, p. 5; 27, p. 49; 38, pp. 1, 15;
45, pp. 1-5,26,33, 137

COAEO

SEC-SS-
T6-05

12/13/17

PCB -
Aroclor 1260

140

46

26, p. 5; 27, p. 41; 38, pp. 1; 13;
45, pp. 1-5, 16,33, 104

C0AD2

SEC-SS-
T5-04

12/13/17

PCB -
Aroclor 1260

200

42

26, p. 5; 27, p. 34; 38, pp. 1, 12;
45, pp. 1-5, 8, 32, 63

C0AD7

SEC-SS-
T5-05

12/13/17

PCB -
Aroclor 1260

290

41

26, p. 5; 27, p. 38; 38, pp. 1, 13;
45, pp. 1-5, 13, 32, 92

C0AA5

SEC-SS-
105

3/20/18

PCB -
Aroclor 1260

67J1

47

26, p. 8; 46, pp. 1-4, 12, 32 70; 48,
pp. 1 and 3

32

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Source Characterization - Hazardous Substances

Source No.: 2

Table 4
Source No. 2 - Soil Samples

CLP
Sample
ID

Field
Sample ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(lig/kg)

References

C0AC5

SEC-SS-
125

3/20/18

PCB -
Aroclor 1260

58

52

26, p. 10; 46, pp. 1-4, 28,31, 123;
48, pp. 1 and 5

Notes:

The Sample Adjusted CRQL is the CRQL adjusted for sample weight, volume, dilution, and percent solid (Ref. 36, pp. 134, 135, 503, 504).
CLP = Contract Laboratory Program

CRQL = EPA Contract Laboratory Program Contract Required Quantitation Limit
PCB = polychlorinated biphenyl
SEC = Shaffer Equipment Company
Hg/kg = micrograms per kilogram

() = Data and information within parentheses indicates data and information for the field duplicate sample pair

J1 = The percent recoveries for the following surrogate were outside of the lower control limits. Detected concentrations in these samples are
estimated and have been qualified (Refs. 46, pp. 3, 12, 50, 152). In accordance with the EPA National Functional Guidelines for Organic
Superfiind Methods Data Review, low surrogate recoveries between 10% < %R < 30% should be qualified J- indicating a low bias (Ref. 49, pp.
233-235). In accordance with the EPA Fact Sheet, Using Qualified Data to Document an Observed Release and Observed Contamination, the
qualified concentration was not adjusted (Ref. 37, pp. 7 and 8).

*Reference 35, p. 12 lists the same sample identifier, SS15, for both CLP sample numbers C0AE1 and C0AE2. As shown on Reference 43, p.
38, CLP sample number C0AE1 is associated with SS14. As noted in Reference 30, p. 18, samples SS14 and SS15 are a duplicate pair.
** References 38, p. 15 and 45, pp. 28 and 34 incorrectly identify the sample identifier as SEC-SD-T8-05. The correct sample identifier for this
sample is recorded in References 26, p. 6 and 27, p. 51 as SEC-SS-T8-05.

33

-------
Source Characterization - Containment
Source No. 2

2.2.3 Hazardous Substances Available to a Pathway

Source 2 includes the soil/source samples that document PCB contamination significantly over background within
and adjacent to Arbuckle Creek's floodplain on numerous parcels as noted in Section 2.2.2 (Figures 4, 5, and 6).
Chemical analysis of sediment samples collected from Arbuckle Creek adjacent to and downstream of the source
document a release of attributable hazardous substances to the surface water migration pathway (see Section
4.1.2.1.1),

As noted previously, Arbuckle Creek is prone to annual periodic flooding and occasional significant flooding
(Refs. 7, p. 102; 12, pp. 5, 319-328; 14, p. 1; 16, pp. 1-15; 17, pp. 1-11; 21, pp. 1-3; and 22, pp. 1-5).

No maintained engineered cover or functioning and maintained run-on control system and runoff management system
or designed, constructed, operated, and maintained source containment to prevent a washout of hazardous substances
by flood is documented for Source No. 2 (Ref. 1, Table 4-2 and Table 4-8).

Containment Description

Containment Factor

References

Release via overland migration:

lack of a maintained engineered
cover, and any complete run-on and
runoff control management systems

10

1, Table 4-2

Release flood:

lack of a designed, constructed,
operated, and maintained source
containment to prevent a washout of
hazardous substances by flood

10

1, Table 4-8

34

-------
Source Characterization - Containment
Source No. 2

2.4.2.1 Hazardous Waste Quantity

2.4.2.1.1	Hazardous Constituent Quantity

The hazardous constituent quantity for Source No. 2 could not be adequately determined according to the HRS
requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the source
is not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.1). There are insufficient
historical and current data (e.g., manifests, PRP records, State records, permits, waste concentration data, etc.)
available to adequately calculate the total or partial mass of all CERCLA hazardous substances in the source and the
associated releases from the source. Therefore, there is insufficient information to evaluate the associated releases
from the source to calculate the hazardous constituent quantity for Source No. 2 with reasonable confidence. Scoring
proceeds to the evaluation of Tier B, Hazardous Wastestream Quantity (Ref. 1, Section 2.4.2.1.1).

Hazardous Constituent Quantity (C) Value: NS

2.4.2.1.2	Hazardous Wastestream Quantity

The hazardous wastestream quantity for Source No. 2 could not be adequately determined according to the HRS
requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and contaminants in the
source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Section

2.4.2.1.2).	There are insufficient historical and current data (e.g., manifests, PRP records, State records, permits, waste
concentration data, annual reports, etc.) available to adequately calculate the total or partial mass of the wastestream
plus the mass of all CERCLA pollutants and contaminants in the source and the associated releases from the source.
Therefore, there is insufficient information to evaluate the associated releases from the source to calculate the
hazardous wastestream quantity for Source No. 2 with reasonable confidence. Scoring proceeds to the evaluation of
TierC, Volume [Ref. 1, Section 2.4.2.1.2],

Hazardous Wastestream Quantity (W) Value: NS

2.4.2.1.3	Volume

The information available on the depth of Source No. 2 is not sufficiently specific to estimate a volume of the
contaminated soil with reasonable confidence; therefore, it is not possible to assign a volume (Tier C) for Source 3
(Ref. 1, Section2.4.2.1.3). Source 2 has been assigned a value of 0 for the volume measure (Ref. 1, Section2.4.2.1.3).
As a result the evaluation of hazardous waste quantity proceeds to the evaluation of Tier D, area (Ref. 1, Section

2.4.2.1.3).

Volume (V) Value: 0

2.4.2.1.4	Area

The area of Source No. 2 is not adequately determined. Source No. 2 is composed of contaminated soil on numerous
residential and non-residential (vacant lots and commercial) properties that contain concentrations of PCBs that are
equal to or greater than three times background levels (Table 4 and Figures 4, 5, 6). The approximate area of soil
contamination, excluding impervious surfaces, was not estimated because of the large number of properties and area
that comprise the source. Additionally, soil sample collection was focused towards occupied residential properties.
Contamination is inferred between sampling locations because the primary mechanism by which the hazardous
substances was deposited involves widespread dispersion of contaminants (i.e., depositional flooding of contaminated
sediments within Arbuckle Creek). Because the information available is insufficient to estimate the area and measure
with reasonable confidence [as required in Section 2.4.2.1.4 of Reference 1], a value of greater than zero (>0) is
established as the source hazardous waste quantity (HWQ) value for Tier D - area. The source type is "Contaminated
Soil," so the area value is divided by 34,000 to obtain the assigned value of >0, as shown below (Ref. 1, Section
2.4.2.1.4, Table 2-5).

Area of source in ft2 = >0
Area (A) Assigned Value: >0/34,000 = >0

35

-------
Source Characterization - Containment
Source No. 2

2.4.2.1.5 Source Hazardous Waste Quantity Value

The highest assigned source HWQ value for Source No. 2 was assigned based on D - Area [Ref. I, Table 2-5],

Source Hazardous Waste Quantity Value: >0

36

-------
Source Characterization
Summary

Table 5

Summary of Source Descriptions

Source No.

Source
HWQ
Value

Source

Hazardous

Constituent

Quantity

Complete?

(Y/N)

Containment Factor Value by Pathway

Ground
Water
(GW)
(Ref. 1,
Table 3-2)

Surface Water

(SW)
Overland/flood
(Ref. 1, Table
4-2)

Air

Gas

Particulate

Gas
(Ref. 1,
Table 6-3)

Particulate

(Ref. 1,
Table 6-9)

1

>0

N

NS

10

NS

NS

2

>0

N

NS

10

NS

NS

HWQ = Hazardous Waste Quantity
NS = Not Scored

Total Source Hazardous Waste Quantity Value: >0

Other Possible Sources Not Scored

Other possible sources include the hundreds of transformers and capacitors in deteriorating condition formerly
scattered around the SEC property on the ground surface (Ref. 7, p. 218; 9, p. 1; 10, p. 3) and several locations
throughout the Town of Minden previously assessed by EPA, such as additional areas of concern brought to EPA's
attention by local residents. EPA is collaborating with WVDEP to collect samples and evaluate these other possible
source areas.

Former Transformer and Capacitors

During the initial inspection of the former SEC property, hundreds of transformers and capacitors in deteriorating
condition were observed to be scattered around the SEC property on the ground surface (Refs. 7, p. 218; 9, p. 1; 10,
p. 3). Many of the transformers and capacitors were observed to be broken, cracked, or lying on their side and leaking
fluid onto the soil (Refs. 7, p. 218; 10. p. 3). Two of the transformers were labeled as containing PCBs; however,
many other transformers, capacitors, and drums were indicated to contain Chloroextol ™ and Pyranol™, which are
PCB-containing fluids (Refs. 7, pp. 32, 218, 231; 10, p. 3; 65, p. 2). Soil beneath transformers at one location was
saturated with oil to a depth of at least 12 inches bgs (Ref. 7, p. 218). Preliminary results of two samples collected at
this location contained PCBs at concentrations of 260,000 ppm at the surface and 40,000 ppm at 12 inches bgs (Ref.
7, p. 219). Rusty and leaking transformers were also observed inside the building located on the SEC property (Ref.
7, p. 231). It was noted that the floor drains in the building discharged directly into Arbuckle Creek (Ref. 7, p. 231).
The transformers and capacitors containing PCB fluids were removed from the SEC property during the 1984-1987
removal action conducted by EPA (Ref. 7, p. 4). However, prior to the removal, the leaking transformers on the
ground surface and in the building were likely sources of contamination to Arbuckle Creek.

37

-------
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

The hazardous substance migration path includes both the overland and in-water segments that hazardous substances
would take as they migrate away from sources at the site (Ref. 1, Section 4.1.1.1). Overland and in-water segments
for Sources 1 and 2 are described below. The surface water pathway is shown on Figures 3, 4,5,6, and 7. Arbuckle
Creek and the New River make up the surface water pathway along the TDL (Figures 2 and 7). Sources 1 and 2 are
located within Arbuckle Creek's floodplain, which is a Federal Emergency Management Agency (FEMA)-designated
Zone A Flood Hazard Area indicating the area is subject to inundation by the 1-percent-annual-chance flood event
(Figures 3, 4, 5, and 6; Refs. 8 and 99). Historically, it has been reported that Arbuckle Creek floods on average
about 7 times a year, and in recent years the creek has been known to flood approximately 4 to 5 times a year (Ref. 7,
p. 102; 14, p. 1). Additionally, historic flood events occurred in the eastern portion of West Virginia in 1985, as well
as specifically inMinden, WV in July 2001, June 2016, and June 2017 (Refs. 15, pp. 20-37; 16, pp. 1-16; 17, pp. 1-
11; 18, pp. 1, 2; 19, pp. 1-4; 20, pp. 1-4; 21, pp. 1-5; 22, pp. 1-5).

On July 8, 2001, Arbuckle Creek in Minden, WV, experienced an historic flood event that fully engulfed the town in
several feet of water (Refs. 16, pp. 1-16; 17, pp. 1-11). In June 2016, a 1-in-1,000-year flood occurred in Fayette
County, WV, with approximately 8 to 10 inches (200-250 millimeter) of rain falling between 7 am and 8 pm (13
hours) (Ref. 19, p. 1). In June 2017, severe flooding occurred inMinden, WV, with roadways closed due to Arbuckle
Creek flooding the streets (Ref. 20, p. 2; 21, pp. 1-3; 22, pp. 1-5). Six additional flood events (i.e., 19 feet and above)
have been recorded at the New River gauging station at Thurmond, located near the confluence of Arbuckle Creek
(Ref. 42, p. 1). At 19 feet, flooding of low areas starts along the New River and up Dunloup Creek and Arbuckle
Creek with portions of county routes 2, 25 and 17 starting to flood. At 20 feet, major flooding of low areas has
occurred along the New River and up Dunloup Creek and Arbuckle Creek with portions of county routes 2, 25 and 17
flooded (Refs. 4; 5, p. 2; 42, p. 2).

Source 1, contaminated soil, consists of two soil samples, SEC-SS-SE-01 and SEC-SS-SE-02, which show significant
concentrations of PCBs above background (see Table 2 in Section 2.2.1), Overland flow from sample point SEC-
SS-SE-01 would be approximately 22 feet to the northeast into the drainage ditch constructed in 2001 as part of the
EPA Removal Action to divert surface water runoff around the capped area and then another 512 feet to the drainage
ditch discharge into Arbuckle Creek at probable point of entry (PPE) PPE1 (Figure 3; Refs. 12, p. 12, 16, 53; 98).
Overland flow from sample point SEC-SS-SE-02 would be approximately 12 feet to the northeast into the same
drainage ditch that receives overland flow from SEC-SS-SE-01, then another 41 feet to the ditch discharge point into
Arbuckle Creek (PPE1) (Figure 3; Ref. 12, p. 53; 98). PPE 1 represents the location where overland flow for Source
1, contaminated soil, discharges to Arbuckle Creek on the former SEC via a drainage ditch constructed as part of the
2001 EPA removal Action as shown on Figure 3 (Ref. 12, pp. 10, 15, 53).

Source 2, contaminated soil, surface soil/source samples were collected from properties along both the north and south
side of Arbuckle Creek within the creek's floodplain [Figures 4,5, and 6]. Source No. 2 is likely primarily a product
of the documented PCB-contaminated sediments within Arbuckle Creek being deposited onto the properties along the
creek as a result of the periodic and historic flooding of Arbuckle Creek (Section 4.1.2.1; Refs. 7, pp. 102, 219; 11,
p. 43; 14, p. 1; 15, pp. 20-37; 16, pp. 1-16; 17, pp. 1-11; 18, pp. 1, 2; 19, pp. 1-4; 20, pp. 1-4; 21, pp. 1-5; 22, pp. 1-
5). The separate areas of contaminated soil, as documented by the analytical results presented in Table 4 Section 2.2.1
of this HRS documentation record, are aggregated into a single source for this HRS scoring package for the following
reasons: the same source type (i.e. contaminated soil), affect similar targets (i.e. sensitive environments, see Section
4.1.4.3 and resident population, see Section 5.1.1.3), same contaminant of concern (i.e., PCBs), deposited in a similar
manner (i.e., deposition by flooding). As shown on Figures 3,4,5, and 6, Source 2 abuts Arbuckle Creek along the
majority of the entire length of the source. Overland flow from Source 2 is sheet flow directly into Arbuckle Creek
as well as direct release from the source into the creek by means of flooding; therefore, PPE 2 is the contact boundary
between Source 2 and the creek along both sides of the banks, where applicable. The area on both sides of the creek,
which contain Source 2, gently slopes toward the creek (Figure 1; Ref. 67, p. 13). As shown on Figure 4, the most
upstream point for PPE 2 associated with Source 2 is at the westernmost end of Source 2.

38

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

4.1.1.2 Target Distance Limit

Arbuckle Creek flows from west to east through the town of Minden (Ref. 6, p. 21). The most upstream PPE for the
overland/flood component for the site is PPE 1 into Arbuckle Creek at the northeastern edge of the SEC property
where the drainage channel from Source 1 discharges surface water runoff into the creek (Figure 3). The farthest
downstream PPE is PPE 2, which is the contact boundary between Source 2 and the creek along both sides of the
banks, where applicable. From PPE1, Arbuckle Creek flows approximately 2.52 miles before its confluence with the
New River (Figure 7; Ref. 98). Based on sampling outlined in Section 4.1.2.1.1 of this evaluation, the farthest
downstream sediment sample collected from Arbuckle Creek documenting an observed release of hazardous
substances attributable to the site is sediment sample SD-61, documenting a zone of actual contamination of
approximately 1 mile; from PPE 1 to SD-61 (Figures 3,4,5, 6, and 7; Ref. 98). Because observed contamination is
not documented more than 15 miles downstream of PPE 1, the TDL extends 15 miles downstream of the most
downstream PPE, PPE 2, for the site (Ref. 1, Section 4.1.1.2). The total TDL for the site, as measured from PPE 1 to
15 miles downstream from the most downstream point of PPE-2, is 15.95 miles and terminates in the New River
(Figure 7; Ref. 98).

Table 6

15-Mile Target Distance Limit

Surface Water
Body

Descriptor3

Distance
Measured from
PPE 1

(miles)

Flow
Characteristics
(cfs)b

Reference(s)

Arbuckle Creek

Minimal

0

8.9

Figures 3, 4, 5, 6, and 7;
Refs. 1, Table 4-13; 58, pp.
1, 11, 12

New River

Large River

2.52

18,300

Figures 3, 4, 5, 6, and 7;
Refs. 1, Table 4-13; 59, p.
2; 98

a Minimal stream: <10 cfs. Small to moderate stream: 10-100 cfs. Moderate to large stream: >100-1,000 cfs. Large stream to river:

>1,000-10,000 cfs. Large river: >10,000-100,000 cfs. [Ref. 1, Table 4-13]
b Cubic feet per second

39

-------
SWOF - Likelihood of Release

4.1.2.1 Likelihood of Release

4.1.2.1.1 Observed Release
Direct Observation

During the 1984 Removal Actions, it was observed that the floor drains within the building located on the SEC
property discharged directly to Arbuckle Creek. Capacitors in the building were observed to be rusted and leaking
fluid onto the floor (Ref. 7, p. 231). These rusted and leaking capacitors were identified as containing Chloroextol ™
and Pyranol™, which are PCB-containing fluids (Refs. 7, pp. 32, 218, 231; 10, p. 3; 65, p. 2).

Arbuckle Creek is prone to annual periodic flooding and occasional significant flooding (Refs. 7, p. 102; 12, pp. 5,
319-328; 14, p. 1; 16, pp. 1-15; 17, pp. 1-11; 20, pp. 1-3; 21, pp. 1-3; and 22, pp. 1-5). As presented in Section 2.2.2,
both Source 1 and 2 have flood containment factor values greater than 10. Prior to the initial Removal Action, EPA
noted that recent past floods had fully engulfed the Shaffer property and there was evidence of stream scouring and
flood damage on the property (Ref. 7, p. 102). As noted in the Site Summary Section and Section 2.2.2, Source 1,
PCB-contaminated soil has remained on the Shaffer property following numerous removal actions. Prior to the third
removal action, which consisted of capping a portion of the contaminated soil, a major flood event occurred in July
2001. Photographs taken of the SEC property in August, September and October 2001 following the flood, document
widespread damage and drainage channels across the property (Ref. 12, pp. 10, 318-325). Additionally, it was noted
that the extensive flooding significantly eroded the bank of Arbuckle Creek and affected the berm constructed during
the removal activities in 1987 (Ref. 12, p. 5). Flood waters would therefore have come into direct contact with PCB-
contaminated soils at the Shaffer property. The 2001 Flood event engulfed the entire town of Minden depositing large
amounts of sediment on residential property (Refs. 16, pp. 1-5; 17,1-11). Two additional major flood events occurred
in June 2016 and June 2017 that engulfed the entire town of Minden (Refs. 18, pp. 1-3; 19, p. 1; 20, pp. 1-3; 21, pp.
1-3; and 22, pp. 1-5).

Chemical Analysis

Sediment samples were collected from Arbuckle Creek in June and December 2017 and in March, May 2018 (Refs.
26, pp. 2-6, 10 and 13; 27, pp. 1-3, 6-8, 16-19, 23, 24, 35-37, 39, 40, 43, 45-48, 50, 52-54; 30, pp. 15-17; 45, pp. 32
and 34; 47, pp. 1-2; 60, pp. 38-41; 61, p. 16; 62, pp. 31-32; 64, p. 21; 82, p. 26). Sediment samples were submitted to
EPA-assigned CLP laboratories and analyzed for Aroclor target analytes in accordance with CLP SOW SOM02.4
(Refs. 45, p. 3; 60, p. 2; 61, p. 2; 62, p. 2; 63, p. 2; 64, p. 2; 82, p. 2). All analytical data were validated by EPA
Region 3 ESAT according to the National Functional Guidelines for Organic Superfund Methods Data Review and
applicable USEPA Region 3 modifications (Refs. 45, p. 3; 60, p. 2; 61, p. 2; 62, p. 2; 63, p. 2; 64, p. 2; 82, p. 2).

In June 2017, two background sediment samples, SD24 and SD25, were collected from Arbuckle Creek upstream of
the former SEC property (Figure 3; Refs. 30, p. 17; 32, p. 2; 60, p. 39). The background sediment samples were used
to establish background conditions and chemical compositions of the sediment materials upstream of the Shaffer
Equipment Co. property. Analytical results of the background sediment samples are presented to establish
representative background concentrations for PCBs, which are used to demonstrate that significant concentrations of
hazardous substances have been detected in the release sediment samples collected from Arbuckle Creek downstream
of the SEC property. The background sediment samples and sediment samples collected to document an observed
release are all grab samples consisting of comparable percent solids as shown in Tables 7 and 8, with a few exceptions
which had percent solids more than 10% difference than the lowest percent solid in background sample SD24 (Refs.
45, pp. 10, 14, 27, 32, and 34; 60, pp. 12, 13, 14, 15, 16, 17, 18, 19, 24, 25,26,31,32, 38, 39, and 40; 61, pp. 6, 7, 8,
9, 10, and 16; 62, pp. 9, 13, 14, 18, 24, 31, 32; 64, pp. 7, 8, and 21; 82 p. 10, 12, 14).

The tables below present the analytical results for the substances that meet observed release criteria in Arbuckle Creek
in accordance with the HRS (Ref. 1, Table 2-3). If the background concentration was reported as not detected, the
associated adjusted CRQL was used as the background concentration. If the background concentration was detected
at a concentration equal to or greater than the adjusted CRQL, the background concentration was multiplied by three
to calculate the background concentration. If a background concentration was reported at an estimated concentration
below the adjusted CRQL, the higher of the adjusted CRQL or three times the estimated concentration was used as
the background concentration (Ref. 1, Table 2-3). The background concentration used for comparison is 39 ng/kg.

40

-------
SWOF - Likelihood of Release

PCB concentrations at or above 39 |ig/kg. the highest adjusted CRQL, are significant above background.

Table 7

Background Sediment Samples

CLP
Sample
ID

Field
Sample
ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(lig/kg)

Percent
Solids

References

C0AM5

SD24

6/14/2017

PCB-Aroclor
1260

6.4J1

48

67.8

30, p. 17; 35, pp. 1 and 10; 60, pp.
1-4,31,39, 201

C0AM6

SD25

6/14/2017

PCB-Aroclor
1260

39U

39

83.9

30, p. 17; 35, pp. 1 and 10; 60, pp.
1-4, 32, 39, 206

Notes:

The Sample Adjusted CRQL is the CRQL adjusted for sample weight, volume, dilution, and percent solid (Ref. 36, pp. 134, 135, 503, 504).
CLP = Contract Laboratory Program

CRQL: EPA Contract Laboratory Program Contract Required Quantitation Limit
Hg/kg = milligrams per kilogram

J = The result is an estimated quantity. The associated numerical value is the approximate concentration of the analyte in the sample (Ref. 60, p.
4). Samples reporting concentrations of target analytes less than (CRQLs) are estimated and have been qualified J (Ref. 60, pp. 3; 49, pp. 246,
247).

U = The analyte was analyzed for, but was not detected above the level of the reported sample quantitation limit (Ref. 60, p. 4)

1 Qualified background data were used in accordance with EPA Fact Sheet Using Qualified Data to Document an Observed Release and Observed
Contamination, which states "The adjustment factors apply only to "J" qualified data above the CRQL"; therefore, the qualified data was not
adjusted (Ref. 37, p. 4).

Table 8

Observed Release Sediment Samples

CLP
Sample ID

Field
Sample
ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(lig/kg)

Percent
Solids

References

C0AA1

SD02

6/14/2017

PCB-Aroclor
1260

140

49

65.9

30, p. 16; 35, pp. 1 and 6; 60, pp.
1-4, 12, 38, 78

C0AA2

SD03

6/14/2017

PCB-Aroclor
1260

6,200

580

56.4

30, p. 16; 35, pp. 1 and 6; 60, pp.
1-4, 13, 38, 88

C0AA3

SD04

6/14/2017

PCB-Aroclor
1260

350

52

62.7

30, p. 16; 35, pp. 1 and 6; 60, pp.
1-4, 14, 40, 93

C0AA4

SD05

6/14/2017

PCB-Aroclor
1260

230

45

71.7

30, p. 16; 35, pp. 1 and 6; 60, pp.
1-4, 15, 40, 98

C0AA5

SD06

6/14/2017

PCB-Aroclor
1260

50,000C

3,400

48

30, p. 16; 35, pp. 1 and 7; 60, pp.
1-4, 16, 40, 108

C0AA6

SD07

6/14/2017

PCB-Aroclor
1260

85

43

74.4

30, p. 16; 35, pp. 1 and 7; 60, pp.
1-4, 17, 40, 136

C0AA7
(C0AB7)

SD08
(SD18)

6/14/2017

PCB-Aroclor
1260

120
(86)

41
(41)

78.6
(78)

30, p. 16; 35, pp. 1 and 7; 60, pp.
1-4, 18,41, 141

(30, p. 16; 35, pp. 1 and 11*; 61,
pp. 1-3, 10, 16, 58*)

C0AA8

SD09

6/14/2017

PCB-Aroclor
1260

130

50

64.7

30, p. 16; 35, pp. 1 and 7; 60, pp.
1-4, 19,41, 146;

41

-------
SWOF - Likelihood of Release

Table 8

Observed Release Sediment Samples

CLP
Sample ID

Field
Sample
ID

Date

Hazardous
Substance

Concentration
(ng/kg)

Adjusted
CRQL
(ng/kg)

Percent
Solids

References

C0AA9

SD10

6/14/2017

PCB-Aroclor
1260

300

54

60.5

30, p. 16; 35, pp. 1 and 11; 61,
pp. 1-3,6, 16,38;

C0AB1

SD12

6/14/2017

PCB-Aroclor
1260

130

43

76.6

30, p. 16; 35, pp. 1 and 11; 61,
pp. 1-3,7, 16, 43;

C0AB3

SD14

6/14/2017

PCB-Aroclor
1260

340

42

77.8

30, p. 15; 35, pp. 1 and 11; 61,
pp. 1-3, 8, 16, 48

C0AB4

SD15

6/14/2017

PCB-Aroclor
1260

61

43

76.4

30, p. 15; 35, pp. 1 and 9; 60, pp.
1-4, 24, 40, 166

C0AB5

SD16

6/14/2017

PCB-Aroclor
1260

70

42

77.7

30 p. 15. 35, pp 1 and 11; 61, pp.
1-3, 9, 16, 53

C0AB6

SD17

6/14/2017

PCB-Aroclor
1260

190

52

62.1

30, p. 15; 35, pp. 1 and 9; 60, pp.
1-4, 25,40, 171;

C0AB8

SD19

6/14/2017

PCB-Aroclor
1260

50

44

75.3

30, p. 17; 35, pp. 1 and 9; 60, pp.
1-4, 26, 40, 176

C0AA2

SEC-SD-
Tl-03

12/12/201
7

PCB-Aroclor
1260

50

45

72.6

26, p. 2; 27, p. 3; 38, pp. 1 and 4;
62, pp. 1-4, 9, 31, and 71

C0AA6

SEC-SD-
T2-02

12/12/201
7

PCB-Aroclor
1260

55

41

79.7

26, p. 2; 27, p. 7; 38, pp 1 and 5;
62, pp. 1-4, 13,31,94

C0AA7

SEC-SD-
T2-03

12/12/17

PCB-Aroclor
1260

160

40

81.6

26, p. 3; 27, p. 8; 38, pp 1 and 5;
62, pp. 1-4, 14, 31, and 97

C0AB1

SEC-SD-
T3-02

12/12/201
7

PCB-Aroclor
1260

55

40

82.8

26, p. 4; 27, p. 18; 38, pp. 1 and
6; 62, pp. 1-4, 18,32, 112

C0AB5

SEC-SD-
T4-01

12/12/201
7

PCB-Aroclor
1260

1800

230

70.7

26, p. 4; 27, p. 23; 38, pp. 1 and
7; 62, pp. 1-4, 24, 32, 130

C0AD4

SEC-SD-
T5-01

12/13/17

PCB-Aroclor
1260

440J1

46

72.4

26, p. 5; 27, p. 35; 38, pp. 1 and
12; 45, pp. 1-5, 10, 32, 72

C0AD8

SEC-SD-
T6-01

12/13/17

PCB-Aroclor
1260

78

43

76.7

26, p. 5; 27, p. 39; 38, pp. 1 and
13; 45, pp. 1-5, 14, 32, 95

COAFO

SEC-SD-
TL-06

12/13/17

PCB-Aroclor
1260

180

40

81.8

26, p. 6; 27, p. 50; 38, pp. 1 and
15; 45, pp. 1-5, 27, 34, 143

CO ADO

SD-53

3/20/2018

PCB-Aroclor
1260

100

43

77.3

47, p. 2; 48, pp. 1 and 10; 64, pp.
1-4, 7, 21, 47

C0AD1

SD-54

3/20/2018

PCB-Aroclor
1260

52

45

73.6

47, p. 2; 48, pp. 1 and 10; 64, pp.
1-4, 8, 21, 50

C0AG9

SD-57

5/15/2018

PCB-Aroclor
1260

45

41

79.5

26, pp. 10 and 13; 82, pp. 1-4,
10, 26, 66; 83, pp. 1, 2

C0AH1

SD-59

5/15/2018

PCB-Aroclor
1260

140

37

89.3

26, pp. 10 and 13; 82, pp. 1-4,
12, 26, 78; 83, pp. 1,2

C0AH3

SD-61

5/15/2018

PCB-Aroclor
1260

71

53

61.9

26, pp. 10 and 13; 82, pp. 1-4,
14, 26, 90; 83, pp. 1, 3

42

-------
SWOF - Likelihood of Release









Table 8













Observed Release Sediment Samples







Field







Adjusted





CLP

Sample



Hazardous

Concentration

CRQL

Percent



Sample ID

ID

Date

Substance

(ng/kg)

(ng/kg)

Solids

References

C0AH7

SD-65

5/15/2018

PCB-Aroclor







26, pp. 10 and 13; 82, pp. 1-4,







1260

70

43

76.2

18, 26, 114; 83, pp. 1,3

Notes:

The Sample Adjusted CRQL is the CRQL adjusted for sample weight, volume, dilution, and percent solid (Ref. 36, pp. 134, 135, 503, 504)
CRQL: EPA Contract Laboratory Program Contract Required Quantitation Limit
Hg/kg = milligrams per kilogram

() = Data and information within parentheses indicates data and information for the field duplicate sample pair

J1 = The percent recoveries for the following surrogate were outside of the lower control limits. Detected concentrations in these samples are
estimated and have been qualified (Refs. 45, p. 4, 58, 180). In accordance with the EPA National Functional Guidelines for Organic Superfiind
Methods Data Review, low surrogate recoveries between 10% < %R < 30% should be qualified J- indicating a low bias (Ref. 49, pp. 233-235).
In accordance with the EPA Fact Sheet, Using Qualified Data to Document an Observed Release and Observed Contamination, the qualified
concentration was not adjusted (Ref. 37, pp. 7 and 8).

C = The target Pesticide or Aroclor analyte identification has been confirmed by Gas Chromatography/Mass Spectrometry (GC/MS). This
qualifier may be added to other qualifiers (Ref. 60, pp. 4). No other qualifier was applied to this value; therefore, the result was not adjusted
based on the EPA Fact Sheet, Using Qualified Data to Document an Observed Release and Observed Contamination, the qualified concentration
was not adjusted (Ref. 37).

* As noted in Reference 30, p. 16, SD08 and SD18 are duplicate pairs. As shown on page 41 of Reference 60, CLP Sample Number C0AB7 was
assigned to Sample ID SD18; however, a station location of SD05 is shown. On Page 10 of Reference 61 and on page 11 ofReference 35, the
location identifier shown (SD-05) is shown, not the Sample Identifier (SD-18).

43

-------
SWOF - Likelihood of Release

Additional Sediment Samples Not Evaluated

Though not included as part of the site score, soil/sediment samples (SS-21, SS-28, SS-29, SS-30, SS-31, SS-BH-01)
collected in June 2017 from the delineated Wetland Areas 5 and 10 indicate concentrations of PCBs (Figure 4; Ref.
32, p. 3). Soil/sediment samples collected in this area in June 2017 contained concentrations of PCBs as high as 680
Hg/kg (Refs. 26, p. 6; 30, p. 14, 17, 18; 28, p. 16; 31, pp. 20, 21, 22, 23, 39,40; 38, p. 3; 43, pp. 20, 25, 38, 39). These
samples were collected prior to the area being delineated as a wetland (Ref. 67).

44

-------
SWOF - Likelihood of Release

Attribution

The SEC built and serviced electrical substations for the local coal mining industry from approximately 1970 to 1984.
The substations incorporated various types of transformers, capacitors, switches, and related voltage regulation and
distribution devices. Oil containing PCBs was used in the electrical transformers (Refs. 90, pp. 1-3; 91, pp. 1-3). SEC
stored nonessential, damaged or outdated transformers and capacitors on the approximate 1-acre property (Ref. 7, pp.
4 and 8). During the initial and subsequent investigations conducted by WVDEP and EPA, hundreds of transformers,
capacitors, and drums in deteriorating condition were observed scattered around the SEC property on the ground
surface (Refs. 7, pp. 218; 9. p. 1; 10, p. 3). Many of the transformers, capacitors, and drums were observed to be
broken, cracked, or lying on their side and leaking fluid onto the soil (Refs. 7, p. 218; 10. p. 3). Two of the transformers
were labeled as containing PCBs; however, many other transformers, capacitors, and drums were indicated to contain
Chloroextol ™ and Pyranol™, PCB containing fluids (Refs. 7, pp. 32, 218, 231; 10, p. 3; 65, p. 2). Soil beneath
transformers at one location was saturated with oil to a depth of at least 12 inches bgs (Ref. 7, p. 218). Preliminary
results of two samples collected at this location contained PCBs at concentrations of 260,000 ppm at the surface and
40,000 ppm at 12 inches bgs (Ref. 7, p. 219). Rusty and leaking transformers were also observed inside the building
located on the SEC property (Ref. 7, p. 231). It was noted that the floor drains in the building discharged directly into
Arbuckle Creek (Ref. 7, p. 231).

Removal actions conducted between 1984 and 1987, in 1990, and in 2001 have not completely removed PCB-
contaminated soil from the Shaffer property (Section 2.2.2, Source 1). A portion of the contaminated soil on the SEC
property has been capped; however, the cap has not been maintained and has compromised edges (Refs. 12, p. 16; 39,
pp. 1-2; 66, p. 15). Additionally, samples collected from the backfilled area following the 1990 removal action showed
the presence of PCBs ranging from 0.1 to 1,000 ppm (Ref. 12. p. 9).

Source 1 consists of PCB contaminated soil located on the SEC property that resulted from the migration, deposition,
or spillage of hazardous substances associated with the handling, storage, maintenance, and management practices
involving hundreds of PCB-containing transformers and capacitors (Section 2.2.2, Source 1). Source 1 is
characterized by two soil samples collected in December 2017 from the SEC property; SEC-SS-SE-01 was collected
from beyond the excavated and backfilled area adjacent to a demolished building reportedly used for storage in the
southwest corner of the former SEC property and SEC-SS-SE-02 was collected from a drainage channel beneath a
broken section of the capped wall in the northeast corner of the former SEC property (Figure 3; Refs. 26, p. 7; 27,
pp. 31-32; 66, p. 15; 84, p. 2). There are no maintained engineering structures to prevent the contaminated soil from
flowing off-site via overland flow or flooding (Section 2.2.3, Source 1). Overland flow from Source 1 is into a
drainage channel constructed in 2001 that discharges into Arbuckle Creek (see Figure 3; Ref. 12, pp. 10, 15, 53).

Source 2 consists of PCB contaminated soil located on portions of numerous parcels within and adjacent to the
floodplain of Arbuckle Creek that resulted from PCB-contaminated sediments within Arbuckle Creek being deposited
onto the properties as a result of the periodic and historic flooding of Arbuckle Creek (Section 2.2.2, Source 2). No
maintained engineered cover or functioning and maintained run-on control system and runoff management system or
designed, constructed, operated, and maintained source containment to prevent a washout of hazardous substances by
flood is documented for Source No. 2 (Section 2.2.3, Source 2). Overland flow from Source 2 is directly into
Arbuckle Creek; additionally, as Arbuckle Creek is prone to annual periodic flooding and occasional significant
flooding, Source 2 is in direct contact with Arbuckle Creek (Refs. 7, p. 102; 12, pp. 5, 319-328; 14, p. 1; 16, pp. 1-16;
17, pp. 1-11; 20, pp. 1-3; 21, pp. 1-3; and 22, pp. 1-5; Figures 4,5, and 6).

PCBs are not known to be naturally occurring. PCBs have been used as coolants and lubricants in transformers,
capacitors, and other electrical equipment. The manufacture of PCBs was halted in the United States in 1977 because
of evidence they build up in the environment and can cause harmful health effects (Refs. 90, pp. 1-3; 91, pp. 1-11).

Possible other facilities and/or sources of PCB contamination that could potentially contribute to the PCB
contamination detected in Arbuckle Creek are the Britt Bath House and the use of PCB-laden oil used to spray the
roadways in Minden as a form of dust suppression.

In 1991, EPA assessed the Britt Bath House property located on the western end of the Town of Minden off Old
Minden Road on the north side of Arbuckle Creek across from the SEC property (Ref. 53, pp. 1, 10, 12). The Britt

45

-------
SWOF - Likelihood of Release

Bath House consists primarily of a large brick building (i.e., bathhouse) located on approximately 3 acres of land that
was used by the coal miners of New River and Pocahontas Coal Company (Ref. 53, pp. 5, 10, 12). Berwind Land
Company owned the property until 1980 when it was sold (Ref. 53, p. 13). The purchaser stated that the SEC Company
used the brick building for storage of equipment until 1978 or 1979 during the time the property was owned by the
Berwind Land Company (Ref. 53, p. 13). The purchaser used the building as a garage to repair trucks and other
equipment and infrequently refurbished transformers on the property (Ref. 53, p. 13). During the assessment, an
abandoned transformer was observed on the property (Ref. 53, p. 35). EPA collected soil samples from the site,
including near the transformer and from observed drainage ditches that discharge to Arbuckle Creek (Ref. 53, pp. 31-
33). Two soil samples contained concentrations of PCBs at 2.6 ppm near a 55-gallon drum and 0.3 ppm at the end of
a drainage ditch leading from the 55-gallon drum to Arbuckle Creek (Ref. 53, pp. 33 and 63). The remaining samples,
including the samples collected near the abandoned transformer, did not contain PCBs (Ref. 53, pp. 33, 61, 63).

A former SEC employee has stated that throughout the 1960s he spread the PCB containing oil from SEC onto the
roadways throughout Minden as a means of dust suppression, which was a common practice at that time (Refs. 89,
pp. 1-3; 90, p. 2; 91, p. 4). Preliminary analytical results of a sediment sample (SD-71) collected in June 2018 from
Arbuckle Creek immediately downstream of a road overpass contained an estimated concentration of 38 ng/kg PCB
(Refs. 92, p. 3; 93, p. 2; 94, p. 17). Preliminary analytical results of a second sediment sample (SD-72) collected
upstream of the SEC property but downstream of sample SD-71 was nondetect for PCBs (Refs. 92, p. 2; 93, p. 2; 94,
p. 8).

Due to the lack of containment features associated with Sources 1 and 2 and the presence of site-attributable
contamination (PCBs) in sediment samples which provide evidence that observed release being evaluated for the
Shaffer Equipment/ Arbuckle Creek Area site is due, at least in part, to the Shaffer Equipment Company and not
another facility or source of PCBs.

Hazardous Substances Released:

PCBs - Aroclor 1260

Observed Release Factor Value: 550

46

-------
SWOF-Drinking Water Threat Targets

4.1.2.3 Drinking Water Threat Targets

The Drinking Water Threat was not scored because there are no surface water intakes along the 15-mile TDL. The
West Virginia American Water Company New River Water System source water is an intake on the New River located
outside the 15-mile TDL (Figure 7; Ref. 57, pp. 6 and 16).

47

-------
SWOF-Human Food Chain Threat Waste Characteristics

4.1.3.2 Human Food Chain Threat - Waste Characteristics

4.1.3.2.1 Toxicitv/Persistence/Bioaccumulation

Table 10

Toxicity/Persistence/Bioaccumulation

1 la/.ardous
Suhslaiu'i'

Shu in-
No.

SuhslaiHi' in
Ohsi-I'M-ll
Riliasi'.'

lu\iiii\

Tailor
Yalm-

Kiwr
IVrsisu-iui-
Tailor Yalm-

I ikkI Chain
liioaii'iimiilalion

Yalm-

To\iiii\/
IVrsisk-iuv/
liioaii'iimiilalion
Tailor Yalm-

Kl'I'lTl'llll'

PC Lis

1,2

Y CS

1 () 000

1

SO ()()()

5 x 10'

hi, Section 2.4.1.1;
1 Table 4-16; 2, p. 2

Notes:

PCB = polychlorinated biphenyl

4.1.3.2.2

Source Number

Hazardous Waste Quantity

Source Hazardous

Waste Quantity

Value (HRS Section 2.4.2.1.51

>0
>0

Is source hazardous
constituent quantity
data complete? (ves/no)

No
No

Sum of Values: >0, rounded to 1

A hazardous waste quantity of >0 is estimated for sources at the site. This yields a hazardous waste quantity of 1 based
on Table 2-6 of the HRS Final Rule (Ref. 1, Section 2.4.2.2). However, as documented in Section 2.4.2.2 of the HRS
Final Rule, if the hazardous constituent quantity is not adequately determined for one or more sources and any target
for the migration pathway is subject to Level I or Level II concentrations, a value of 100 can be assigned as the
hazardous waste quantity factor value for that pathway. As demonstrated in Section 4.1.4.3.1.2, wetlands and other
sensitive environments are subject to Level II concentrations in the surface water pathway, and a minimum value of
100 can be assigned for the hazardous waste quantity factor value (Ref. 1, Section 2.4.2.2).

Hazardous Waste Quantity Factor Value = 100

48

-------
SWOF-Human Food Chain Threat Waste Characteristics

4.1.3.2.3 Waste Characteristics Factor Category Value

PCBs, associated with Sources 1 and 2, which have surface water pathway containment factor values greater than 0
for the watershed, corresponds to a toxicity/persistence factor value of 10,000 and bioaccumulation potential factor
value of 50,000.

Toxicity/Persistence Factor Value = 10,000
Hazardous Waste Quantity (HWQ) Factor Value = 100
Bioaccumulation Potential Factor Value (BPFV) = 50,000

(Toxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 10,000 x 100 = 1,000,000

subject to a maximum of 1 x 108

(Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value)
x (Bioaccumulation Potential Factor Value) = (1,000,000) x (50,000) =5 x 1010

Subject to a maximum of 1 x 1012

The value of 5 x 1010 corresponds to a Waste Characteristics Factor Category Value of 320 (Ref. 1, Table 2-7).

Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108
Hazardous Waste Quantity Factor Value: 100
Waste Characteristics Factor Category Value: 320

49

-------
SWOF/Human Food Chain Targets

4.1.3.3

Human Food Chain Threat - Targets

There are Human Food Chain Threat Targets due to the presence of a potentially contaminated fishery located within
the surface water pathway, and previous documentation of contaminated sediments (Section 4.1.2.1.1), Arbuckle
Creek is not a known fishery (Ref. 23, pp. 1, 2, and 4). The creek is known to contain high levels of fecal coliform
(Ref. 69, pp. 6 and 10). However, the New River is a popular fishery along its entire length (Ref. 70, p. 2). Fish
species present in the river include bass (smallmouth, largemouth, striped, and rock), walleye, muskellunge, crappie,
bluegill, carp, flathead, and channel catfish (Ref. 70, pp. 2, 4).

4.1.3.3.1

Food Chain Individual

As noted in Sections 4.1.2.1.1 and 4.1.3.2.1, an observed release of hazardous substances associated with Sources 1
and 2 and having a bioaccumulation factor value of 500 or greater has been documented in Arbuckle Creek. As noted
in Section 4.1.3.3, Arbuckle Creek is not a fishery; however, the New River located within the TDL is a documented
fishery (Figure 7; Ref. 70, p. 2). No Level I or II fisheries are documented between the PPEs and the most downstream
observed release sampling point. Therefore, a value of 20 was assigned as the food chain individual factor value (Ref.
1, Section4.1.3.3.1).

Food Chain Individual Factor Value: 20

4.1.3.3.2
4.1.3.3.2.1

Population

Level I Concentrations

Level I concentrations are not established because Actual Contamination of a fishery has not been documented.

Level I Concentrations Human Food Chain Population Value: 0

4.1.3.3.2.2	Level II Concentrations

Level II concentrations are not established because Actual Contamination of a fishery has not been documented.

Level II Concentrations Human Food Chain Population Value: 0

4.1.3.3.2.3	Potential Contamination

As documented in Section 4.1.3.3, the New River is fished for consumption within the 15-mile TDL. The fish
consumption rate for the downstream fishery is not documented; therefore, the fishery is assigned to the category
"Greater than 0 to 100 pounds per year," which corresponds to the assigned Human Food Chain Population Value of
0.03 in Table 4-18 of the HRS [Ref. 1],

Identity of
Fishery

New River

Annual

Production

(pounds)

>0

Type of
Surface
Water
Body

Large River

Average
Annual
Flow
£cfe)	

18,300

Population
Value (P,)

0.03

Dilution
Weight (D)

0.0001

P. xD.

0.000003

SumofPixDi: 0.000003
(Sum ofP, x DO/10: 0.0000003
(Ref. 1, Table 4-13, Table 4-18; 59, p. 2)

Potential Human Food Chain Contamination Factor Value: 0.0000003

50

-------
SWOF/Environment-Waste Characteristics

4.1.4.2 Environmental Threat - Waste Characteristics

4.1.4.2.1 Ecosystem Toxicitv/Persistence/Bioaccumulation

Table 11

Ecosystem Toxicity/Persistence/Bioaccumulation

1 la/.ardous
Suhslaiue

Sonne
No.

Suhslanie ill
Ohseneil
Release'.'

Feoloxicilv
Factor
Value

River
Persistence
Factor Value

Kin iromiK-nl
liioai'i'iiiiiulalion
Value

l'.iiilii\iiil\/

IVrsisleiue/
liioai'i'iimiilali
on Kai'lor
Value

Rel'erellie

PCBs

1,2

Y

10,000

1

50,000

5 x 108

1; Table 4-21; 2, p. 2

Notes:

PCB = polychlorinated biphenyl

4.1.4.2.2

Hazardous Waste Quantity

Source Number

1

2

Source Hazardous

Waste Quantity

Value (HRS Section 2.4.2.1.51

>0
>0

Is source hazardous
constituent quantity
data complete? (ves/no)

No
No

Sum of Values: >0, rounded to 1

A hazardous waste quantity of >0 is estimated for sources at the site. This yields a hazardous waste quantity of 1
based on Table 2-6 of the HRS Final Rule (Ref. 1, Section 2.4.2.2). However, as documented in Section 2.4.2.2 of the
HRS Final Rule, if the hazardous constituent quantity is not adequately determined for one or more sources and any
target for the migration pathway is subject to Level I or Level II concentrations, a value of 100 can be assigned as the
hazardous waste quantity factor value for that pathway. As demonstrated in Section 4.1.4.3.1.2, wetlands and other
sensitive environments are subject to Level II concentrations in the surface water pathway, and a minimum value of
100 can be assigned for the hazardous waste quantity factor value (Ref. 1, Section 2.4.2.2).

Hazardous Waste Quantity Factor Value = 100

4.1.4.2.3 Waste Characteristics Factor Category Value

One hazardous substance, PCBs, associated with Sources 1 and 2, which have a surface water pathway containment
factor values greater than 0 for the watershed, correspond to an Ecotoxicity/Persistence Factor Value of 10,000 and
Bioaccumulation Potential Factor Value of 50,000.

(Ecotoxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 10,000 x 100 = 1 x 106

(Ecotoxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value)

x (Bioaccumulation Potential Factor Value) = (1 x 106) x (50,000) = 5 x 1010

Subject to a maximum of 1 x 1012

The product corresponds to a Waste Characteristics Factor Category Value of 320 (Ref. 1 Table 2-7)

Hazardous Waste Quantity Factor Value: 100
Waste Characteristics Factor Category Value: 320

51

-------
SWOF/Environment-Targets

4.1.4.3 Environmental Threat - Targets

Arbuckle Creek within the area of actual contamination is evaluated as a habitat for a Federal designated endangered
species, the Indiana Bat (myotis sodalis) and a Federal designated threatened species, the Northern Long-eared Bat
(myotis septentrionalis) (Refs. 72, pp. 1 and 4; 75, p. 1; 77, p. 1; 87, pp. 7 and 9). The area of Actual Contamination
is located within 5 miles of a known roosting, swarming, and foraging zone of a Priority 3 or 4 winter hibernaculum
for the Indiana bat (Refs. 72, pp. 1 and 4; 87, p. 9). The Indiana bats have a home range territory of approximately
255 hectares in the spring to 625 hectares in the fall and can travel up to thousands of kilometers from their winter
hibernacula to their summer foraging ground (Refs. 73, pp. 4 and 5; 87, p. 9). In 2003 and 2004, a survey of bat
communities within the New River Gorge National River park conducted by the National Park Service (NPS)
confirmed the presence of the Indiana bat within the park based on acoustic survey (Ref. 74, pp. 21, 24, 28). The
Indiana bat was recorded at 53 of the 453 acoustic survey locations (approximately 11.7% of the total locations) (Ref.
74, p. 28). While the NPS report does not provide the specific locations where the Indiana bat was identified, based
on the acoustic survey and the fact that it was conducted solely within the park boundary, the survey provides
additional support that the Indiana bat is within current range of the area of actual contamination. The area of actual
contamination, which consists of a forested riparian buffer zone, would provide a suitable habitat for the Indiana bat
due to the presence of high quality foraging habitat over Arbuckle Creek and good to fair roosting habitat over the
stream and adjacent riparian areas (Refs. 73, pp. 1, 5 and 6; 74, pp. 13, 30; 75, pp. 1 and 2; 87, pp. 7, 8, and 9).

Additionally, the Northern Long-eared bat was live captured within the New River Gorge Park as recently as 2017
(Ref. 87, p. 9). The 2003 and 2004 survey of bat communities within the New River Gorge National River live captured
49 Northern Long-eared bats and recorded 107 by acoustical survey (Ref. 74, pp. 24, 25, and 28). The Northern Long-
eared bat was the most commonbat species found during the survey, which was expected given the habitat association
of the species and that which is found at the park (Refs. 74, p. 29; 77, p. 5). The 2003 and 2004 survey of bat
communities stated in general that although bat foraging activity occurs over much of the park landscape, riparian
areas, such as those found along large portions of the area of actual contamination, are the most critical component of
bat foraging habitat (Refs. 74, p. 50; 87, pp. 7, 8 and 9).

West Virginia Department of Natural Resources drafted a State Wildlife Action Plan (SWAP) in 2005 and revised in
2015 in response to a 2001 request by Congress for each state to submit a comprehensive wildlife conservation strategy
to U.S. Fish and Wildlife National Advisory Acceptance Team, in order to qualify for state wildlife grant funds (Refs.
78 and 79, p. 1). The objective of the SWAP is to address both species of greatest conservation need as well as the
full array of wildlife by focusing on identifying species in need, then on habitats associated with those species and
geographic areas of the state with concentrations of species and the habitats that they require. To identify
species/habitat associations, known locations of species were matched with data from habitat mapping in the state.
High-densities of species and habitat occurrences were used to identify a series of Conservation Focus Areas (CFA's)
(Ref. 78, p. 7). Arbuckle Creek within the area of actual contamination is located within the state identified Gorge
CFA (Ref. 78, p. 327). The Gorge CFA provides a "particular area, relatively small in size, important to maintenance
of unique biotic communities" because the floodplains include some of the most extensive river scour prairies and
woodlands in the eastern United States. The area supports many rare plant species including the globally rare
Monongahela Barbara's-Buttons (Marshallia grandiflora). Upland and riparian habitats in the CFA support a high
number of species of greatest conservation need plants (109), and the forest of the CFA is recognized as a globally
significant example of the Appalachian cove hardwood/mixed mesophytic forest (Ref. 1, Table 4-23; 78, p. 329).

As depicted on Figures 3, 4 and 5, a total of 933 feet of HRS-eligible palustrine emergent wetlands along Arbuckle
Creek on both the north and south banks as documented by a wetland delineation conducted in May 2018 (Refs. 67,
p. 2, 3, 4, 13, 61-81). Frontage 1 consists of 334 feet of HRS-eligible wetlands located along the southern bank of
Arbuckle Creek, Frontage B consists of 79 feet, Frontage C consists of 135 feet, Frontage 4 consists of 175 feet and
Frontage 5 consists of 210 feet (Ref. 67, p. 13). Frontages 6 and 10 depicted on the wetland delineation map were not
included in this HRS evaluation because frontage 6 is not along the surface water migration pathway, it is located
along a drainage channel that flows into Arbuckle Creek, and frontage 10 is an isolated wetland located within the
floodplain but not adjacent to or hydraulically connected to Arbuckle Creek.

52

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SWOF/Environment-Targets

Most Distant Level I Sample

Level I Concentrations are not established, because benchmarks are not available for sediment, and surface water was
not collected.

Most Distant Level II Sample

The most distant Level II observed release attributable to the site and within the TDL extends 5,295 feet
(approximately 1 mile) from the most upstream PPE in Arbuckle Creek, PPE1 to the farthest downstream sample
location that meets the criteria for an observed release, SEC-SD-61 (Figures 3, 4, 5, and 6; Section 4.1.2.1.1; Ref.
98).

53

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SWOF/Environment-Level I/Level II Contamination

4.1.4.3.1 Sensitive Environments

4.1.4.3.1.1	Level I Concentrations

Sensitive environments that are determined to be actual contamination targets based on sediment sample analytical
results, but for which no ecological-based benchmarks are applicable, are evaluated as subject to actual contamination
at Level II (Ref. 1, Section4.1.4.3.1). Therefore, there are no sensitive environments subject to Level I concentrations
and the Level I Concentrations Factor Value is 0 (Ref. 1, Section 4.1.4.3.1).

Level I Concentrations Factor Value: 0

4.1.4.3.1.2	Level II Concentrations

Sensitive environments other than wetlands that have been identified within the zone of actual contamination include
habitat known to be used by two Federal designated or proposed endangered or threatened species and particular areas,
relatively small in size, important to maintenance of unique biotic communities (Section 4.1.4.3),

Table 12
Level II Sensitive Environments

Sensitive Environment

Reference(s)

Sensitive Environment Value
(Ref. 1, Table 4-23)

Habitat known to be used by Federal
designated or proposed endangered or
threatened species (Indiana bat)

72, pp. 1 and 4; 73, pp. 4, 5, 6; 74,
pp. 13,21,24, 30; 75, pp. land 2

75

Habitat known to be used by Federal
designated or proposed endangered or
threatened species (Northern Long-eared
bat)

72, pp. 1 and 4; 74, pp. 24, 25, 26,
29, and 50; 77, pp. 1, 5

75

Particular areas, relatively small in size,
important to maintenance of unique biotic
communities
(Gorge CFA)

78, p. 7, 327, and 329

25

Sum of Level II Sensitive Environments: 175

Table 13
Level II wetlands

Wetland

Frontage
(feet/mi.)

Reference

Wetland 1

334/0.063

67, pp. 4, 13,61-63

Wetland B

79/0.014

67, pp. 4, 13,79-81

Wetland C

135/0.025

67, pp. 4, 13, 82-84

Wetland 4

175/0.031

67, pp. 4, 13, 67-69

Wetland 5

210/0.037

67, pp. 4, 13, 70-72

Sum of Level II Wetland Frontages: 0.17 miles
Wetlands Value (Ref. 1, Table 4-24): 25

Sum of Level II Sensitive Environments Value (175) + Wetlands Value (25): 200

54

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SWOF/Environment-Potential Contamination

4.1.4.3.1.3 Potential Contamination

Since a maximum score of 100.00 was achieved for the surface water migration pathway, the Potential Contamination
Factor Value was not scored (NS).

55

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Soil Exposure
General Consideration

5.0 SOIL EXPOSURE AND SUBSURFACE INTRUSION PATHWAY
5.1 SOIL EXPOSURE COMPONENT

According to the HRS, evaluation of the soil exposure component of the soil exposure and subsurface intrusion
pathway is based on areas of observed contamination (Ref. la, Section 5.1.0).

5.1.0 GENERAL CONSIDERATIONS

Letter by which this area is to be identified: A

Name of area: Area of Observed Contamination A (AOC A)

Location and description of the area, with reference to a map : The area of observed soil contamination is defined
for HRS scoring purposes based on analytical results for soil samples collected in June 2017, December 2017, and
March 2018 from parcels within and adjacent to Arbuckle Creek's floodplain (Figures 4, 5, and 6; Tables 16 and
17; Refs. 26, p. 7; 27, p. 30; 30. p. 18; 31, p. 41; 32, p. 1, 2; 44, p. 35; 47, pp. 5-7; 64, pp. 21, 84, pp. 1,2; and 85, pp.
1,2). AOC A is likely primarily a product ofthePCB-contaminated sediments within Arbuckle Creek being deposited
onto the properties as a result of the periodic and historic flooding of Arbuckle Creek (Refs. 7, p. 102; 12, pp. 5,319-
328; 14, p. 1; 16, pp. 1-15; 17, pp. 1-11; 21, pp. 1-3; and 22, pp. 1-5). The separate areas of contaminated soil, as
documented by the analytical results presented in Table 17 of this HRS documentation record, are aggregated into a
single AOC for this HRS scoring package for the following reasons: the same source type (i.e. contaminated soil),
same contaminant of concern (i.e., PCBs), and deposited in a similar manner (i.e. deposition by flooding). The
approximate area of soil contamination, excluding impervious surfaces, was not estimated because of the large number
of properties and area that comprise the AOC. Additionally, soil sample collection was focused towards occupied
residential properties. Contamination can reasonably be inferred between sampling locations within the AOC because
the mechanism by which the hazardous substances migrated to the area of observed contamination involves wide
dispersion of contaminants (i.e., depositional flooding of contaminated sediments within Arbuckle Creek).

Soil samples that meet observed contamination criteria were used to delineate AOC A, as shown in Figures 4,5, and
6 (Ref. 1, Table 2-3). To document the presence of PCBs in AOC A at significant concentrations, the analytical results
of the soil samples collected in June 2017, December 2017, and March 2018 were compared to soil samples collected
in June 2017, December 2017, and March 2018 from properties located upstream from the SEC property at locations
not expected to have been impacted by surface water runoff or flooding from the sources and/or would be only
minimally impacted (Tables 14 and 15; Refs. 26, p. 7; 27, p. 30; 30, p. 18; 31, p. 41; 32, p. 1, 2; 44, p. 35; 64, pp. 21,
22). The background soil samples and source soil samples are all grab samples consisting of similar matrices
comprised of top soil/organics, silt, silty-sand, and silty-clay with comparable percent solids ranging from 68.9% to
79.6% for background samples and 63.5% to 84.9% for source/soil samples with two exceptions; sample SS-22 had
a percent solid of 44.3% and sample SS-26 had a percent solid of 48.6% (Refs. 26, pp. 3,5,6, 7, 8, and 10; 27, pp. 27,
28, 30, 34, 38, 41, 44, 49, 51, 55, 56; 28, pp. 11, 22; 30, pp. 17, 18; 31, pp. 18, 19, 39; 43, pp. 10, 11, 12, 13, 17, 18,
19, 21, 24, 25, 26, 27, 28, 29, 37, 38, 39; 44, pp. 15, 22, 23, 26, 30, 34, 35; 45, pp. 8, 13, 16, 20, 26, 28, 32, 33, 34;
46, pp. 12, 28, 32; 47, pp. 5, 6, 7; 51, pp. 8, 16; 64, pp. 10, 12, 13, 14, 15, 21). The background soil and AOC soil
samples collected in June and December 2017 and March 2018 were documented as having been collected between 0
to 6 inches bgs (0 to 0.5 feetbgs) (Refs. 26, p. 14; 27, pp. 27, 30, 34, 38, 41, 44, 49, 51, 55, and 56; 47, p. 8; 35, pp.
3, 12, 13, 14, 15, and 16; 48, pp. 3, 10, 11). The December 2017 and March 2018 soil samples were collected using a
dedicated polyethylene scoop and homogenizing the soil in a disposable aluminum pan (Refs. 26, p. 14; 47, p. 8).

The soil samples from the June 2017, December 2017, and March 2018 sampling events were submitted to and
analyzed by an EPA Contract Laboratory Program (CLP) laboratory for Aroclors (i.e., PCBs) in accordance with CLP
Statement of Work (SOW) SOM02.4, and the analytical data were validated by EPA Region 3 Environmental Services
Assistance Team (ESAT) according to the National Functional Guidelines for Organic Superfund Methods Data
Review and applicable USEPA Region 3 modifications (Refs. 26, pp. 3, 5-8, 10; 28, pp. 1, 2, 23; 30, pp. 14, 17, 18;
31, pp. 1-4, 41; 39, pp. 1, 2; 43, pp. 1, 2; 44, pp. 1-2, 35; 45, pp, 1,2; 46, pp. 1, 2; 47, pp. 5-7; 51, pp. 1, 2; 64. pp. 1-
2,21).

56

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Soil Exposure
General Consideration

Background Concentrations

Table 14

Background Soil Sample Descriptions

CLP
Sample
ID

Field
Sample
ID

Date

Sample Description

Sample
Depth
(inches)

References

C0AD8

SS11

6/15/17

top soil; sand

0-6

30, p. 18; 31, p. 41; 35, p. 3

C0AD9

SS12

6/15/17

top soil; silty sand

0-6

30, p. 18; 31, p. 41; 35, p. 3

C0AG6

SEC-SS-
R5-01

12/13/17

brown to dark tan; mostly
silt with some sand

0-6

26, p. 7; 27, p. 30; 44, p. 35

C0AE6

SS-150

3/20/18

brown silt

0-6

47, p. 5; 48, pp. 1 and 10; 64, pp. 10, 21, 56

C0AE8

SS-152

3/20/18

black silt

0-6

47, p. 6; 48, pp. 1 and 11; 64, pp. 12, 21, 64

C0AE9

SS-153

3/20/18

medium brown silty clay

0-6

47, p. 6; 48, pp. 1 and 11; 64, pp. 13,21,67

C0AF0

SS-154

3/20/18

medium brown silty clay

0-6

47, p. 6; 48, pp. 1 and 11; 64, pp. 14, 21, 70

C0AF1

SS-155

3/20/18

medium brown silty clay

0-6

47, p. 7; 48, pp. 1 and 11; 64, pp. 15, 21, 73

Table 15

Background Soil Sample Analytical Data

CLP
Sample
ID

Field
Sample
ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(ng/kg)

References

C0AD8

SS11

6/15/17

PCB -
Aroclor 1260

11 J1

44

30, p. 18; 31, pp. 1-5, 18, 41, 101; 35,
pp. 1 and 3

C0AD9

SS12

6/15/17

PCB -
Aroclor 1260

15 J1

43

30, p. 18; 31, pp. 1-5, 19, 41, 106; 35,
pp. 1 and 3

C0AG6

SEC-SS-
R5-01

12/13/17

PCB -
Aroclor 1260

41U

41

26, p. 7; 27, p. 30; 38, pp. 1 and 11;
44, pp. 1-4, 30, 35, 145

C0AE6

SS-150

3/20/18

PCB -
Aroclor 1260

48U

48

47, p. 5-6; 48, pp. 1 and 10; 64, pp. 1-
4, 10,21, 56

C0AE8

SS-152

3/20/18

PCB -
Aroclor 1260

48U

48

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
12,21,64

C0AE9

SS-153

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
13,21,67

C0AF0

SS-154

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 6; 48, pp. 1 and 11; 64, pp. 1-4,
14,21,70

C0AF1

SS-155

3/20/18

PCB -
Aroclor 1260

46U

46

47, p. 7; 48, pp. 1 and 11; 64, pp. 1-4,
15,21,73

Notes:

The Sample Adjusted CRQL is the CRQL adjusted for sample weight, volume, dilution, and percent solid (Refs. 36, pp. 134, 135, 503, 504).
CLP = Contract Laboratory Program

CRQL = EPA Contract Laboratory Program Contract Required Quantitation Limit
PCB = polychlorinated biphenyl
SEC = Shaffer Equipment Company
Hg/kg = micrograms per kilogram

J = The result is an estimated quantity. The associated numerical value is the approximate concentration of the analyte in the sample (Refs. 31, p.
1-5; 64, p. 4). Samples reporting concentrations of target analytes less than (CRQLs) are estimated and have been qualified J (Ref. 31, pp. 1-5; 49,
pp. 246, 247).

U= The analyte was analyzed for, but was not detected above the level of the reported sample quantitation limit (Refs. 44, p. 4; 64, p. 4)
1 Qualified background data were used in accordance with EPA Fact Sheet Using Qualified Data to Document an Observed Release and
Observed Contamination, which states "The adjustment factors apply only to "J" qualified data above the CRQL"; therefore, the qualified data
was not adjusted (Ref. 37, pp. 4).

57

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Soil Exposure
General Consideration

Contaminated Samples - AOC A

Table 16

Contaminated Soil Sample Descriptions

CLP
Sample
ID

Field
Sample
ID

Date

Sample Description

Sample
Depth
(inches)

References

COAEO

SS13

6/15/17

sandy, silty top soil

0-6

30, p. 18; 35, p. 12; 43, p. 37

C0AE1*
(C0AE2)*

SS14*
(SS15)*

6/15/17

top soil; clay

0-6
0-6

30, p. 18; 35, p. 12; 43, p. 38
(30, p. 18; 35, p. 12; 43, p. 38)

C0AE3

SS16

6/15/17

top soil; silty sand,
gravel

0-6

30, p. 18; 35, p. 12; 43, p. 38

C0AE5

SS18

6/15/17

top soil; sand

0-6

30, p. 18; 35, p. 13; 43, p. 38

C0AE6

SS19

6/15/17

top soil; some gravel

0-6

30, p. 18; 35, p. 14; 43, p. 38

C0AE7

SS20

6/15/17

sand, some silt

0-6

30, p. 18; 35; p. 13; 43, p. 38

C0AE9

SS22

6/15/17

fine sand with some silt

0-6

30, p. 18; 35, p. 13; 43, p. 39

C0AF2

SS25

6/15/17

top soil, silt with some
organics



30, p. 18; 43, p. 39

C0AF3

SS26

6/15/17

Silt with fine sand

6 inches

30, p. 17; 43, p. 39

C0AF4

SS27

6/15/17

silt, sand, clay, some
organics



30, p. 17; 43, p. 39

COAMO

SS41

6/14/17

sand; brick and coal

0-6

30, p. 15; 35, p. 14; 43, p. 39

C0AM7

SS42

6/15/17

sand, silt

0-6

30, p. 17; 35, p. 14; 43, p. 40

C0AM8

SS43

6/15/17

silty sand

0-6

30, p. 17; 35, p. 15; 43, p. 40

C0AN1

SS44

6/15/17

sandy silt

0-6

30, p. 18; 51, p. 16; 35, p. 16

C0AG4

SEC-SS-
TL-43C

12/13/17

dark brown silt with
some sand

0-6

26, p. 6; 27, p. 27; 44, p. 35

COAGO

SEC-SS-
R3-01

12/13/17

very dark brown silt
with some organics



26, p. 6; 44, p. 35

C0AC6

SEC-SS-
Rl-06

12/12/17

silt with organics

0-6

26, p. 3; 27, p. 56; 44, p. 34

C0AF6

SEC-SS-
T8-04

12/13/17

Dark brown silt,
organics

0-6

26, p. 6; 27, p. 55; 28, p. 22

C0AF2

SEC-SS-
T8-05

12/13/17

brown sand

0-6

26, p. 6; 27, p. 51; 45, p. 34**

C0AF9

SEC-SS-
R2-01

12/13/17

brown silt with some
organics



26, p. 6; 44, p. 35

C0AE4

SEC-SS-
T7-04

12/13/17

brown silt with some
organics

0-6

26, p. 5; 27, p. 44; 45, p. 33

C0AE9

SEC-SS-
T7-05

12/13/17

brown silt with gravel

0-6

26, p. 5; 27, p. 49; 45, p. 33

COAEO

SEC-SS-
T6-05

12/13/17

brown sand and silt,
some organics

0-6

26, p. 5; 27, p. 41; 45, p. 33

C0AD2

SEC-SS-
T5-04

12/13/17

brown with gravel and
organics

0-6

26, p. 5; 27, p. 34; 45, p. 32

58

-------
Soil Exposure
General Consideration

Table 16

Contaminated Soil Sample Descriptions

CLP
Sample
ID

Field
Sample
ID

Date

Sample Description

Sample
Depth
(inches)

References

C0AD7

SEC-SS-
T5-05

12/13/17

brown, sandy silt

0-6

26, p. 5; 27, p. 38; 45, p. 32

C0AA5

SEC-SS-
105

3/20/18

silty sand

0-6

26, p. 8; 46, p. 32; 48, p. 3

C0AC5

SEC-SS-
125

3/20/18

clay with some organics

0-6

26, p. 10; 46, p. 31; 48, p. 5

*Reference 35, p. 12 lists the same sample identifier, SS15 for both CLP sample numbers C0AE1 and C0AE2. As shown on Reference 43, p. 38,
CLP sample number C0AE1 is associated with SS14. As noted in Reference 30, p. 18, samples SS14 and SS15 are a duplicate pair.

() = Data and information within parentheses indicates data and information for the field duplicate sample pair

Table 17

Contaminated Soil Sample Analytical Results

CLP
Sample
ID

Field
Sample
ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(lig/kg)

References

C0AE0

SS13

6/15/17

PCB -
Aroclor 1260

450

49

30, p. 18; 35, pp. 1 and 12; 43, pp.
10,37,71

C0AE1*
(C0AE2)*

SS14
(SS15)

6/15/17

PCB -
Aroclor 1260

91
(90)

50
(50)

30, p. 18; 35, pp. 1 and 12; 43, pp. 1-
4, 11, 12, 38, 76, 81)

C0AE3

SS16

6/15/17

PCB -
Aroclor 1260

260

42

30, p. 18; 35, pp. 1 and 12; 43, pp. 1-
4, 13,38, 86

C0AE5

SS18

6/15/17

PCB -
Aroclor 1260

340

39

30, p. 18; 35, pp. 1 and 13; 43, pp. 1-
4, 17, 38, 96

C0AE6

SS19

6/15/17

PCB -
Aroclor 1260

210

46

30, p. 18; 35, pp. 1 and 13; 43, pp. 1-
4, 18,38, 101

C0AE7

SS20

6/15/17

PCB -
Aroclor 1260

160

40

30, p. 18; 35, pp. 1 and 13; 43, pp. 1-
4, 19, 38, 106

C0AE9

SS22

6/15/17

PCB -
Aroclor 1260

200

74

30, p. 18; 35, pp. 1 and 13; 43, pp. 1-
4,21,39, 116

C0AF2

SS25

6/15/17

PCB -
Aroclor 1260

100

50

30, p. 18; 35, pp. 1 and 14; 43, pp. 1-
4, 24, 39, 132

C0AF3

SS26

6/15/17

PCB -
Aroclor 1260

660

67

30, p. 17; 35 pp. 1 and 14; 43, pp. 1-

4, 25,39, 137

C0AF4

SS27

6/15/17

PCB -
Aroclor 1260

350

47

30, p. 17; 35, pp. 1 and 14; 43, pp. 1-
4, 26, 39, 142

C0AM0

SS41

6/14/17

PCB -
Aroclor 1260

130

47

30, p. 15; 35, pp. 1 and 14; 43, pp. 1-
4, 27, 39, 147

C0AM7

SS42

6/15/17

PCB -
Aroclor 1260

230

41

30, p. 17; 35, pp. 1 and 14; 43, pp. 1-
4, 28, 40, 152

C0AM8

SS43

6/15/17

PCB -
Aroclor 1260

1,300

49

30, p. 17; 35, pp. 1 and 15; 43, pp. 1-
4, 29, 40, 162

C0AN1

SS44

6/15/17

PCB -
Aroclor 1260

1200

89

30, p. 15, 18; 51, pp. 1-5, 8, 16, and
46; 35, pp. 1 and 16

C0AG4

SEC-SS-
TL-43C

12/13/17

PCB -
Aroclor 1260

58

47

26, p. 6; 27, p. 27; 38, pp. 1, 11; 44,
pp. 1-4, 26, 35, 139

59

-------
Soil Exposure
General Consideration

Table 17

Contaminated Soil Sample Analytical Results

CLP
Sample
ID

Field
Sample
ID

Date

Hazardous
Substance

Concentration
(lig/kg)

Adjusted
CRQL
(lig/kg)

References

C0AG0

SEC-SS-
R3-01

12/13/17

PCB -
Aroclor 1260

310

49

26, p. 6; 38, pp. 1, 10; 44, pp. 1-4,
23, 35, 124

C0AC6

SEC-SS-
Rl-06

12/12/17

PCB -
Aroclor 1260

64

49

26, p. 3; 27, p. 56; 38, pp. 1 and 9;
44, pp. 1-4, 15, 34, and 88

C0AF6

SEC-SS-
T8-04

12/13/17

PCB -
Aroclor 1260

220

44

26, p. 6; 27, p. 55; 28, pp. 1-4, 11,
22, 63; 38, pp. 1,2

C0AF2

SEC-SS-
T8-05

12/13/17

PCB -
Aroclor 1260

410

41

26, p. 6; 27, p. 51; 38, pp. 1, 15**;
45, pp. 1-5,28, 34, 146**

C0AF9

SEC-SS-
R2-01

12/13/17

PCB -
Aroclor 1260

140

46

26, p. 6; 38, pp. 1, 10; 44, pp. 1-4,
22,35, 118

C0AE4

SEC-SS-
T7-04

12/13/17

PCB -
Aroclor 1260

60

43

26, p. 5; 27, p. 44; 38, pp. 1, 16; 45,
pp. 1-5,20,33, 119

C0AE9

SEC-SS-
T7-05

12/13/17

PCB -
Aroclor 1260

59

39

26, p. 5; 27, p. 49; 38, pp. 1, 15; 45,
pp. 1-5, 26, 33, 137

C0AE0

SEC-SS-
T6-05

12/13/17

PCB -
Aroclor 1260

140

46

26, p. 5; 27, p. 41; 38, pp. 1, 13; 45,
pp. 1-5, 16, 33, 104

C0AD2

SEC-SS-
T5-04

12/13/17

PCB -
Aroclor 1260

200

42

26, p. 5; 27, p. 34; 38, pp. 1, 12; 45,
pp. 1-5, 8, 32, 63

C0AD7

SEC-SS-
T5-05

12/13/17

PCB -
Aroclor 1260

290

41

26, p. 5; 27, p. 38; 38, pp. 1, 13; 45,
pp. 1-5, 13, 32, 92

C0AA5

SEC-SS-
105

3/20/18

PCB -
Aroclor 1260

67J1

47

26, p. 8; 46, pp. 1-4, 12, 32 70; 48,
pp. 1 and 3

C0AC5

SEC-SS-
125

3/20/18

PCB -
Aroclor 1260

58

52

26, p. 10; 46, pp. 1-4, 28,31, 123;
48, pp. 1 and 5

Notes:

The Sample Adjusted CRQL is the CRQL adjusted for sample weight, volume, dilution, and percent solid (Ref. 36, pp. 134, 135, 503, 504).
CLP = Contract Laboratory Program

CRQL = EPA Contract Laboratory Program Contract Required Quantitation Limit
PCB = polychlorinated biphenyl
SEC = Shaffer Equipment Company
Hg/kg = micrograms per kilogram

() = Data and information within parentheses indicates data and information for the field duplicate sample pair

J1 = The percent recoveries for the following surrogate were outside of the lower control limits. Detected concentrations in these samples are
estimated and have been qualified (Ref. 46, pp. 3, 12, 50, 152). In accordance with the EPA National Functional Guidelines for Organic
Superfiind Methods Data Review, low surrogate recoveries between 10% < %R < 30% should be qualified J- indicating a low bias (Ref. 49, pp.
233-235). In accordance with the EPA Fact Sheet, Using Qualified Data to Document an Observed Release and Observed Contamination, the
qualified concentration was not adjusted (Ref. 37, pp. 7 and 8).

*Reference 35, p. 12 lists the same sample identifier, SS15 for both CLP sample numbers C0AE1 and C0AE2. As shown on Reference 43, p. 38,
CLP sample number C0AE1 is associated with SS14. As noted in Reference 30, p. 18, samples SS14 and SS15 are a duplicate pair.
** References 38, p. 15 and 45, pp. 28 and 34 incorrectly identify the sample identifier as SEC-SD-T8-05. The correct sample identifier for this
sample is recorded in References 26, p. 6 and 27, p. 51.

60

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Soil Exposure
General Consideration

Attribution

The SEC built and serviced electrical substations for the local coal mining industry from approximately 1970 to 1984.
The substations incorporated various types of transformers, capacitors, switches, and related voltage regulation and
distribution devices. Oil containing PCBs was used in the electrical transformers (Refs. 90, pp. 1-3; 91, pp. 1-3). SEC
stored nonessential, damaged or outdated transformers and capacitors on the approximate 1-acre property (Ref. 7, pp.
4 and 8). During the initial and subsequent investigations conducted by WVDEP and EPA, hundreds of transformers,
capacitors, and drums in deteriorating condition were observed scattered around the SEC property on the ground
surface (Ref. 7, pp. 218; 9. p. 1; 10, p. 3). Many of the transformers, capacitors, and drums were observed to be
broken, cracked, or lying on their side and leaking fluid onto the soil (Refs. 7, p. 218; 10. p. 3). Two of the transformers
were labeled as containing PCBs; however, many other transformers, capacitors, and drums were indicated to contain
Chloroextol ™ and Pyranol™, PCB containing fluids (Ref. 7, pp. 32, 218, 231; 10, p. 3; 65, p. 2). Soil beneath
transformers at one location was saturated with oil to a depth of at least 12 inches bgs (Ref. 7, p. 218). Preliminary
results of two samples collected at this location contained PCBs at concentrations of 260,000 ppm at the surface and
40,000 ppm at 12 inches bgs (Ref. 7, p. 219). Rusty and leaking transformers were also observed inside the building
located on the SEC property (Ref. 7, p. 231). It was noted that the floor drains in the building discharged directly into
Arbuckle Creek (Ref. 7, p. 231).

Removal actions conducted between 1984 and 1987, in 1990, and in 2001 have not completely removed PCB-
contaminated soil from the Shaffer property (Section 2.2.2, Source 1) upstream of AOC A. A portion of the
contaminated soil on the SEC property has been capped; however, the cap has not been maintained and has
compromised edges (Refs. 12, p. 16; 39, pp. 1-2; 66, p. 15). Additionally, samples collected from the backfilled area
following the 1990 removal action showed the presence of PCBs ranging from 0.1 to 1,000 ppm (Ref. 12. p. 9).

PCB contaminated soil located on the SEC property resulted from the migration, deposition, or spillage of hazardous
substances associated with the handling, storage, maintenance, and management practices involving hundreds of PCB-
containing transformers and capacitors (Section 2.2.2, Source 1). Soil samples were collected in December 2017
from the SEC property; SEC-SS-SE-01 was collected from beyond the excavated and backfilled area adjacent to a
demolished building reportedly used for storage in the southwest corner of the former SEC property and SEC-SS-SE-
02 was collected from a drainage channel beneath a broken section of the capped wall in the northeast corner of the
former SEC property (Figure 3; Refs. 26, p. 7; 27, pp. 31-32; 66, p. 15; 84, p. 2). There are no maintained engineering
structures to prevent the contaminated soil from flowing off-site via overland flow or flooding (Section 2.2.3),
Overland flow from the location of SEC-SS-SE-01 and SEC-SS-SE-02 is into a drainage channel constructed in 2001
that discharges into Arbuckle Creek (see Figure 3; Ref. 12, p. 10, 12, 53).

AOC A, which corresponds with Source 2 evaluated for the surface water migration pathway, consists of PCB
contaminated soil located on portions of numerous parcels within and adjacent to the floodplain of Arbuckle Creek.
AOC A is located along both sides of the PCB-contaminated portion of Arbuckle Creek downstream of the SEC
property and Source 1, and likely resulted primarily from PCB-contaminated sediments within Arbuckle Creek being
deposited onto the properties as a result of the periodic and historic flooding of Arbuckle Creek (Section 2.2.2, Source
2). AOC A samples were collected at a depth of 0 to 6 inches bgs (Table 16). PCB contamination was documented in
AOC A at concentrations significantly above background (Table 17). No maintained engineered cover or functioning
and maintained run-on control system and runoff management system or designed, constructed, operated, and
maintained source containment to prevent a washout of hazardous substances by flood is documented for Source No.
2 (Section 2.2.3, Source 2). Overland flow from Source 2 is directly into Arbuckle Creek; additionally, as Arbuckle
Creek is prone to annual periodic flooding and occasional significant flooding, Source 2 is in direct contact with
Arbuckle Creek (Refs. 7, p. 102; 12, pp. 5, 319-328; 14, p. 1; 16, pp. 1-16; 17, pp. 1-11; 20, pp. 1-3; 21, pp. 1-3; and
22, pp. 1-5; Figures 4,5,6).

PCBs are not known to be naturally occurring. PCBs have been used as coolants and lubricants in transformers,
capacitors, and other electrical equipment. The manufacture of PCBs was halted in the United States in 1977 because
of evidence they build up in the environment and can cause harmful health effects (Refs. 90, pp. 1-3; 91, pp. 1-11).

Possible other facilities and/or sources of PCB contamination that could potentially contribute to the PCB
contamination detected in Arbuckle Creek are the Britt Bath House and the use of PCB-laden oil used to spray the
roadways in Minden as a form of dust suppression.

61

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Soil Exposure
General Consideration

In 1991, EPA assessed the Britt Bath House property located on the western end of the Town of Minden off Old
Minden Road on the north side of Arbuckle Creek across from the SEC property (Ref. 53, pp. 1, 10, 12). The Britt
Bath House consists primarily of a large brick building (i.e., bathhouse) located on approximately 3 acres of land that
was used by the coal miners of New River and Pocahontas Coal Company (Ref. 53, pp. 5, 10, 12). Berwind Land
Company owned the property until 1980 when it was sold (Ref. 53, p. 13). The purchaser stated that the SEC Company
used the brick building for storage of equipment until 1978 or 1979 during the time the property was owned by the
Berwind Land Company (Ref. 53, p. 13). The purchaser used the building as a garage to repair trucks and other
equipment and infrequently refurbished transformers on the property (Ref. 53, p. 13). During the assessment, an
abandoned transformer was observed on the property (Ref. 53, p. 35). EPA collected soil samples from the property,
including near the transformer and from observed drainage ditches that discharge to Arbuckle Creek (Ref. 53, pp. 31-
33). Two soil samples contained concentrations of PCBs at 2.6 ppm near a 55-gallon drum and 0.3 ppm at the end of
a drainage ditch leading from the 55-gallon drum to Arbuckle Creek (Ref. 53, pp. 33 and 63). The remaining samples,
including the samples collected near the abandoned transformer, did not contain PCBs (Ref. 53, pp. 33, 61, 63).

A former SEC employee has stated that throughout the 1960s he spread the PCB-containing oil from SEC onto the
roadways throughout Minden as a means of dust suppression, which was a common practice at that time
(Refs. 89, pp. 1-3; 90, p. 2; 91, p. 4). As shown in Tables 15 and 17, the concentrations of PCBs detected in soil
samples within the floodplain of Arbuckle Creek downstream of the SEC property are at significant concentrations
above the concentrations detected in the background soil samples, which were collected near and adjacent to roadways
in Minden, upstream of the SEC property as shown on Figure 3.

The presence of site-attributable contamination (PCBs) in soil samples provide evidence that the AOC being evaluated
for the Shaffer Equipment/Arbuckle Creek Area site is due, at least in part, to the Shaffer Equipment Company and
not another facility or source of PCBs.

Hazardous Substances Released:

PCBs - Aroclor 1260

62

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Soil Exposure
Hazardous Waste Quantity

5.1.1.2.2 Hazardous Waste Quantity

Hazardous Constituent Quantity

The hazardous constituent quantity for AOC A could not be adequately determined according to the HRS
requirements; that is, the total mass of all CERCLA hazardous substances in the AOC is not known and cannot be
estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.1). There are insufficient historical and current data
(e.g., manifests, PRP records, State records, permits, waste concentration data, etc.) available to adequately calculate
the total or partial mass of all CERCLA hazardous substances in the AOC. Therefore, there is insufficient information
to evaluate the associated releases from the source to calculate the hazardous constituent quantity for AOC A with
reasonable confidence. Scoring proceeds to the evaluation of Tier B, Hazardous Wastestream Quantity (Ref. 1, Section
2.4.2.1.2, Table 5-2).

Hazardous Constituent Quantity (C) Value: NS

Hazardous Wastestream Quantity

The hazardous wastestream quantity for AOC A could not be adequately determined according to the HRS
requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and contaminants in the
AOC is not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.2). There are
insufficient historical and current data (e.g., manifests, PRP records, State records, permits, waste concentration data,
annual reports, etc.) available to adequately calculate the total or partial mass of the wastestream plus the mass of all
CERCLA pollutants and contaminants in the AOC. Therefore, there is insufficient information to calculate the
hazardous wastestream quantity for AOC A with reasonable confidence. Scoring proceeds to the evaluation of Tier
C, Volume (Ref. 1, Section 2.4.2.1.3, Table 5-2).

Hazardous Wastestream Quantity (W) Value: NS

Volume

The information available on the depth of AOC A is not sufficiently specific to support the volume of the contaminated
soil with reasonable confidence; therefore, it is not possible to assign a volume (Tier C) for AOC A (Ref. 1, Section
2.4.2.1.3). AOC A has been assigned a value of 0 for the volume measure (Ref. 1, Section 2.4.2.1.3). As a result the
evaluation of hazardous waste quantity proceeds to the evaluation of Tier D, area (Ref. 1, Section 2.4.2.1.4, Table 5-
2).

Volume (V) Value: 0

Area

The area of AOC A is not adequately determined. AOC A is composed of contaminated soil on numerous residential
and non-residential (vacant lots and commercial) properties that contain concentrations of PCBs that are equal to or
greater than three times background levels. The approximate area of soil contamination, excluding impervious
surfaces, was not estimated because of the large number of properties and area that comprise the AOC. Additionally,
soil sample collection was focused towards occupied residential properties. Contamination can be inferred between
sampling locations, however, because the area of observed contamination is a result of depositional flooding of
contaminated sediments within Arbuckle Creek. Because the information available is insufficient to estimate the area
and measure with reasonable confidence [as required in Section 2.4.2.1.4 of Reference 1], avalue of greater than zero
(>0) is established as the source hazardous waste quantity (HWQ) value for Tier D - area. The source type is
"Contaminated Soil," so the area value is divided by 34,000 to obtain the assigned value of >0, as shown below (Ref.
1, Section 2.4.2.1.4, Table 5-2).

Area of AOC in ft2 = >0
Area (A) Assigned Value: >0/34,000 = >0

63

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Soil Exposure
Hazardous Waste Quantity

AOC Hazardous Waste Quantity Value

The highest assigned hazardous waste quantity value for AOC A was assigned based on D - Area [Ref. I, Table 5-2],

AOC Hazardous Waste Quantity Value: >0

64

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SE - Resident Population Threat

5.1.1 RESIDENT POPULATION THREAT
5.1.1.1 LIKELIHOOD OF EXPOSURE

Surface soil samples collected in June 2017, December 2017, and March 2018 are used to establish observed
contamination at Level I and Level II concentrations; these samples were collected from within the property
boundaries of occupied residential properties within AOC A and within 200 feet of each residence (Figures 4,5, and
6; Refs. 23, pp. 2, 3, 4, and 6; 26, p. 6; 80, pp. 1-4; 97, pp. 1-8). Therefore, a value of 550 is assigned to the likelihood
of exposure factor category (Ref. la, Section 5.1.1.1).

The properties affected by PCB contamination are listed below.

Table 18

Resident Population Threat Likelihood of Exposure Factor

CLP
Sample
ID

Field
Sample
ID

Hazardous
Substance

Concentration
(lig/kg)

References

C0AE1*
(C0AE2)

SS14
(SS15)

PCB - Aroclor
1260

91
(90)

Figure 4; 23, p. 2; 30, p. 18; 97, pp. 1 and 2;
43, pp. 1-5,11,38, 76; 80, pp. 1 and 4; 23, p.
2; 30, p. 18; 43, pp. 1-5, 12, 38, 81)

C0AF2

SS25

PCB - Aroclor
1260

100

Figure 5; 23, p. 4; 30, p. 18; 97, pp. 1 and 7;
43, pp. 1-5, 24, 39, 132; 80, pp. 1 and 3

C0AF3

SS26

PCB - Aroclor
1260

660

30, p. 17; 97, pp. 1 and 8; 46, pp. 28, 31, 123;
48, pp. 1 and 6; 80, pp. 1 and 4

C0AC5

SEC-
SS-125

PCB - Aroclor
1260

58

26, p. 10; 97, pp. 1 and 8; 46, pp. 1-4, 28, 31,
123; 48, pp. 1 and 5; 80, pp. 1 and 4

C0AF4

SS27

PCB - Aroclor
1260

350

Figure 4; 23, p. 4; 30, p. 17; 97 pp. 1 and 6;
43, pp. 1-5, 26, 39, 142; 80, pp. 1 and 4

C0AM0

SS-41

PCB - Aroclor
1260

130

Figure 6; 23, pp. 4 and 6; 30, p. 15; 35, pp. 1
and 14; 43, pp. 1-5, 27, 39, 147; 80, pp. 1 and
2

C0AA5

SEC-
SS-105

PCB - Aroclor
1260

67J1

Figure 6; 23, pp. 4 and 6; 26, p. 8; 97, pp. 1
and 3; 46, pp. 1-4, 12, 32 70; 80, pp. 1 and 2

C0AM7

SS-42

PCB - Aroclor
1260

230

Figure 4; 23, pp. 4; 30, p. 17; 97, pp. 1 and 5;
43, pp. 1-5, 28, 40, 152; 80, pp. 1 and 4

C0AF9

SEC-
SS-R2-
01

PCB - Aroclor
1260

140

Figure 4; 23, pp. 3; 26, p. 6; 97, pp. 1 and 5;
44, pp. 1-4, 22, 35, 118; 80, pp 1 and 4

C0AM8

SS43

PCB - Aroclor
1260

1,300

Figure 4; 23, p. 3; 30, p. 17; 97, pp. 1 and 4;
43, pp. 1-5, 29, 40, 162; 80, pp. 1 and 4

C0AG0

SEC-
SS-R3-
01

PCB - Aroclor
1260

310

Figure 4; 23, p. 3; 26, p. 6; 97, pp. 1 and 4;
44, pp. 1-5, 23, 35, 124; 80, pp 1 and 4

C0AF6

SEC-
SS-T8-
04

PCB - Aroclor
1260

220

Figure 4; 23, p. 3; 28, pp. 1-4, 11, 22, 63; 97,
pp. 1 and 4; 80, pp. 1 and 4

Notes:

J1 = The percent recoveries for the following surrogate were outside of the lower control limits. Detected concentrations in these samples
are estimated and have been qualified (Refs. 46, pp. 3, 50, 152). In accordance with the EPA National Functional Guidelines for Organic
Superfiind Methods Data Review, low surrogate recoveries between 10% < %R < 30% should be qualified J- indicating a low bias (Ref.
49, pp. 233-235). In accordance with the EPA Fact Sheet, Using Qualified Data to Document an Observed Release and Observed
Contamination, the qualified concentration was not adjusted (Ref. 37, pp. 7 and 8).

65

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SE - Resident Population Threat

*Reference 35, p. 12 lists the same sample identifier, SS15 for both CLP sample numbers C0AE1 and C0AE2. As shown on Reference
43, p. 38, CLP sample number C0AE1 is associated with SS14. As noted in Reference 30, p. 18, samples SS14 and SS15 are a duplicate
pair.

Resident Population Threat Likelihood of Exposure Factor Category Value: 550

66

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SE - Waste Characteristics/HWQ

5.1.1.2 WASTE CHARACTERISTICS

5.1.1.2.1 Toxicity



Table 19





Toxicity



Toxicity Hazardous Substance

Toxicity Factor Value

References

PCBs

10,000

Ref. la, Section 2.4.1.1; Ref. 2, p. 2

Toxicity Factor Value: 10,000

5.1.1.2.2 Hazardous Waste Quantity

The Hazardous Waste Quantity Factor Value is assigned as specified inHRS Sections 2.4.2 and 5.1.1.2.2, based on
the Area Factor Value for AOC A.

Table 20
Hazardous Waste Quantity

Hazardous Waste
Quantity Area
Letter

Source Type

Area Hazardous Waste Quantity

A

Contaminated Soil

>0

Sum of Values:

>0

Sum of Values: >0

Based on HRS Section 2.4.2.2, if the Hazardous Constituent Quantity is not adequately determined for one or more
areas of observed contamination, a factor value is assigned from Table 2-6 or a value of 10, 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 (Ref. 1, Section 2.4.2.2, Table 2-6): 10

5.1.1.2.3 Calculation of Waste Characteristics Factor Category Value

The Toxicity Factor Value for PCBs (10,000) is multiplied by the Hazardous Waste Quantity Factor Value for the site
(10) in order to determine the Waste Characteristics Product, subject to a maximum value of 1 x io8
(Ref. 1, Section2.4.3.1).

10,000 x 10 = 1 x io5

Toxicity Factor Value: 10,000
Hazardous Waste Quantity Factor Value: 10
Toxicity Factor Value x Hazardous Waste Quantity Factor Value: 1 x io5

From HRS Table 2-7, a Waste Characteristics Product of 1 x io5 is assigned a Waste Characteristics Factor Category
Value of 18 (Ref. 1, Section 2.4.3.1, Table 2-7).

Waste Characteristics Factor Category Value: 18

67

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SE - Targets

5.1.1.3 TARGETS

Although contamination within the AOC can be inferred between sampling points, only those individuals whose
residence is both on the property and within 200 feet of documented contamination that meets observed contamination
criteria are included as resident population threat targets for this evaluation. Parcels within the AOC that were vacant,
or contained unoccupied residences or buildings, such as garages, were not evaluated as targets in accordance with
Section 5.1.1.3 oftheHRS (Refs. 23, pp. 1-10; 80, pp. 1-8).

Table 21
Resident Population

CLP
Sample
ID

Field
Sample
ID

Hazardous
Substance

Concentration
(^g/kg)

Benchmark

References

C0AE1*
(C0AE2)

SS14
(SS15)

PCB -
Aroclor 1260

91
(90)

Cancer Risk
(300 ng/kg)

Figure 4; 2, p. 3; 23, p. 2;
30, p. 18; 97, pp. 1 and 2;
43, pp. 1-5, 11,38, 76; 80,
pp. 1 and 4

(23, p. 2; 30, p. 18; 43, pp.
12,38,81)

C0AF2

SS25

PCB -
Aroclor 1260

100

Cancer Risk
(300 ng/kg)

Figure 5; 2, p. 3; 23, p. 4;
30, p. 18; 97, pp. 1 and 7;
43, pp. 1-5,24,39, 132;
80, pp. 1 and 3

C0AC5

SEC-
SS-125

PCB -
Aroclor 1260

58

Cancer Risk
(300 ng/kg)

Figure 4; 2, p. 3; 26, p. 10;
97, pp. 1 and 8; 46, pp. 28,
31, 123; 48, pp. land 6;
80, pp. 1 and 4

C0AF3

SS26

PCB -
Aroclor 1260

660

Cancer Risk
(300 ng/kg)

Figure 4; 2, p. 3; 23, p. 4;
30, p. 17; 97, pp. 1 and 8;
46, pp. 28,31, 123; 48, pp.
1 and 6; 80, pp. 1 and 4

C0AF4

SS27

PCB -
Aroclor 1260

350

Cancer Risk
(300 ng/kg)

Figure 4; 2, p. 3; 23, p. 4;
30, p. 17; 97, pp. 1 and
643, pp. 1-5, 26, 39, 142;
80, pp. 1 and 4

C0AM0

SS41

PCB -
Aroclor 1260

130

Cancer Risk
(300 ng/kg

Figure 6; 2, p. 3; 23, pp. 4
and 6; 30, p. 15; 35, pp. 1
and 14; 43, pp. 1-5, 27, 39,
147; 80, pp. 1 and 2

C0AA5

SEC-
SS-105

PCB -
Aroclor 1260

67 J1

Cancer Risk
(300 ng/kg)

Figure 6; 2, p. 3; 23, pp. 4
and 6; 26, p. 8; 97, pp. 1
and 3; 46, pp. 1-4, 12, 32
70; 80, pp. 1 and 2

C0AM7

SS-42

PCB -
Aroclor 1260

230

Cancer Risk
(300 ng/kg)

Figure 4; 2, p. 3; 23, pp. 3
and 4; 97, pp. 1 and 5; 43,
pp. 1-5, 28, 40, 152; 80,
pp. 1 and 4

C0AF9

SEC-
SS-R2-
01

PCB -
Aroclor 1260

140

Cancer Risk
(300 ng/kg)

Figure 4; 2, p. 3; 23, pp. 3
and 4; 26, p. 6; 97, pp. 1
and 5; 44, pp. 1-4, 22, 35,
118; 80, pp 1 and 4

C0AM8

SS43

PCB -
Aroclor 1260

1,300

Cancer Risk
(300 ug/kg)

Figure 4; 2, p. 3; 23, p. 3;
30, p. 17; 97, pp. 1 and 4;

68

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SE - Targets

Table 21
Resident Population

CLP
Sample
ID

Field
Sample
ID

Hazardous
Substance

Concentration
(lig/kg)

Benchmark

References











43, pp. 1-5,29, 40, 162;
80, pp. 1 and 4

C0AG0

SEC-
SS-R3-
01

PCB -
Aroclor 1260

310

Cancer Risk
(300 ng/kg)

Figure 4; 2, p. 3; 23, p. 3;
26, p. 6; 97, pp. 1 and 4;
44, pp. 1-4, 23,35, 124;
80, pp 1 and 4

C0AF6

SEC-
SS-T8-
04

PCB -
Aroclor 1260

220

Cancer Risk
(300 ng/kg)

Figure 4; 2, p. 3; 23, p. 3;
28, pp. 1-4, 11,22, 63; 44,
1-5; 97, pp. 1 and 4; 80,
pp. 1 and 4

Notes:

J1 = The percent recoveries for the following surrogate were outside of the lower control limits. Detected concentrations in these samples are
estimated and have been qualified (Refs. 46, pp. 3, 12, 50, 152). In accordance with the EPA National Functional Guidelines for Organic
Superfiind Methods Data Review, low surrogate recoveries between 10% < %R < 30% should be qualified J- indicating a low bias (Ref. 49, pp.
233-235). In accordance with the EPA Fact Sheet, Using Qualified Data to Document an Observed Release and Observed Contamination, the
qualified concentration was not adjusted (Ref. 37, pp. 7 and 8).

*Reference 35, p. 12 lists the same sample identifier, SS15 for both CLP sample numbers C0AE1 and C0AE2. As shown on Reference 43, p. 38,
CLP sample number C0AE1 is associated with SS14. As noted in Reference 30, p. 18, samples SS14 and SS15 are a duplicate pair.

Hg/kg - micrograms per kilogram

69

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SE - Resident Individual

5.1.1.3.1 Resident Individual

Area Letter: A

Level of Contamination: Level I

According to the HRS, hazardous constituents that meet the criteria for an observed release (or observed
contamination) and equal or exceed media-specific benchmark values meet the criteria for Level I contamination (Ref.
1, Sect. 2.5). Based on results as shown in Table 17, Level I concentrations of PCBs (i.e., at or above the lowest
applicable benchmark value of 300 ng/kg) exist on occupied residential properties. A value of 50 is assigned to resident
individual because there is at least one resident individual subject to Level I concentrations (Ref. la, Sections 2.5.2,
5.1.1.3.1).

Resident Individual Factor Value: 50

70

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SE - Resident Population

5.1.1.3.2 Resident Population
5.1.1.3.2.1 Level I Concentrations

Level I Resident Population Targets

Observed contamination has been documented at residences in AOC A (see Section 5.1.0). The population of the
residences was obtained during interviews conducted by an EPA representative (Refs. 23, pp. 3 and 4; 80, pp. 1-4).

Table 22
Level I Targets

Sample ID*

Number of
Residents

References

SS26

2

Figure 4; 23, p. 4; 97, pp. 1 and 8;
80, pp. 1 and 4

SS27

3

Figure 4; 23, p. 4; 97, pp. 1 and 6;
80, pp. 1 and 4

SS43
SEC-SS-R3-01
SEC-SS-T8-04

1

Figure 4; 23, p. 3; 26, p. 6; 97, pp. 1
and 4; 80, pp. 1 and 4

* As shown in Tables 17 and 21, these sample locations exceed the benchmark value of 300 ng/kg for
PCBs.

SEC = Shaffer Equipment Company

Sum of individuals subject to Level I concentrations: 6
Sum of individuals subject to Level I concentrations x 10: 60

Level I Concentrations Factor Value: 60

-------
SE - Resident Population

5.1.1.3.2.2 Level II Concentrations

Observed contamination has been documented at residences in AOC A (see Section 5.1.0), The population of the
residences was obtained during interviews conducted by an EPA representative (Refs. 23, pp. 2, 3, and 4; 97, p. 1-2;
80, pp. 1-4). The following populations are subject to Level II concentrations:

Sample ID*

Number of
Residents

References

5514

5515

6

Figure 4; 23, p. 2; 97, pp. 1 and 2; 80,
pp. 1 and 4

SS25

2

Figure 5; 23, p. 4; 97, pp. 1 and 7; 80,
pp. 1 and 3

SS-105

1

Figure 6; 23, p. 4; 97, pp. 1 and 3; 80,
pp. 1 and 2

SS42
SEC-SS-R2-01

4

Figure 4; 23, pp. 3, 4; 26, p. 6; 97, pp. 1
and 5; 80, pp. 1 and 4

* As shown in Tables 17 and 21, these sample locations do not exceed the benchmark value of 300 ng/kg
for PCBs.

SEC = Shaffer Equipment Company

Sum of individuals subject to Level II concentrations: 13

Level II Concentrations Factor Value: 13

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SE - Resident Population

5.1.1.3.3	Workers

Several parcels within the AOC are owned by businesses that occupy a former residential structure. The number of
persons who work in these buildings is not known, but is believed to be minimal (significantly less than 100); therefore,
because the number of target workers would not significantly affect the site score, the workers factor value is not
scored and is assigned a value of 0 (Ref. la, Section 5.1.1.3 and 5.1.1.3.3).

5.1.1.3.4	Resources

No known commercial agriculture, silviculture, or livestock production or grazing is known to be conducted within
the area of observed contamination attributable to the Shaffer Equipment/Arbuckle Creek Area site. Therefore, the
resources factor is assigned a value of 0 (Ref. la, Section 5.1.1.3.4).

5.1.1.3.5	Terrestrial Sensitive Environments

There are no known terrestrial sensitive environments within the area of observed contamination attributable to the
Shaffer Equipment/Arbuckle Creek Area site. Therefore, the terrestrial sensitive environments factor is assigned a
value of 0 (Ref. la, Section 5.1.1.3.5).

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