RECORD OF DECISION
WARD TRANSFORMER
SUPERFUND SITE
OPERABLE UNIT 2
Raleigh, Wake County, North Carolina
EPA ID: NCD003202603
Prepared By:
U. S. Environmental Protection Agency
Region 4
SUPERFUND AND EMERGENCY MANAGEMENT DIVISION
Atlanta, Georgia
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
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RECORD OF DECISION
Table of Contents
PART 1: DECLARATION
1.0 SITE NAME AND LOCATION
2.0 STATEMENT OF BASIS AND PURPOSE
3.0 Assessment of Site
4.0 Description of Selected Remedy
5.0 Statutory Determinations 2
6.0 Data Certification Checklist 3
7.0 Authorizing Signature 3
PART 2: THE DECISION SUMMARY 4
1.0 Site Name, Location and Brief Description 4
2.0 Site History and Enforcement Activities 4
2.1 History of Site Activities 4
2.2 History of Investigations and Cleanup Actions 5
2.3 History of CERCLA Enforcement Activities 7
3.0 Community Participation 7
4.0 Scope and Role of the Operable Unit or Response Action 8
5.0 Site Characteristics 9
5.1 Conceptual Site Model (CSM) 9
5.2 Overview of the Site 9
5.3 Sampling Strategy 10
5.4 Known or Suspected Sources of Contamination 10
5.5 Nature and Extent of Contamination 1 1
5.6 Location and Potential Routes of Migration 14
6.0 Current and Potential Future Uses 15
6.1 Land Use 15
6.2 Groundwater and Surface Water Uses 15
7.0 Summary of Site Risks 15
7.1 Human Health Risk Assessment 15
7.2 Ecological Risk Assessment 18
7.3 Basis for Action 19
8.0 Remedial Action Objectives 19
8.1 Cleanup Levels 20
9.0 Description of Alternatives 21
9.1 Alternative 1: No Further Action 22
9.2 Alternative 2: Institutional Controls and MNA 22
9.3 Alternative 3: Institutional Controls and Enhanced Aerobic Treatment 23
9.4 Alternative 4: Institutional Controls and PRB with PlumeStop® Liquid Activated
Carbon™ 24
9.5 Common Elements and Distinguishing Features of Each Alternative 26
9.6 Expected Outcomes of Each Alternative 26
10.0 Comparative Analysis of Alternatives 26
10.1 Overall Protection of Human Health and the Environment 28
10.2 Compliance with ARARs 28
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10.3 Long-Term Effectiveness and Permanence 29
10.4 Reduction of Toxicity, Mobility and Volume 29
10.5 Short-Term Effectiveness 29
10.6 Implementability 29
10.7 Cost 30
10.8 State Acceptance 30
10.9 Community Acceptance 31
11.0 Principal Threat Wastes 31
12.0 Selected Remedy 31
12.1 Summary of the Rationale for the Selected Remedy 31
12.2 Detailed Description of the Selected Remedy 31
12.3 Cost Estimate for the Selected Remedy 32
12.4 Estimated Outcomes of Selected Remedy 33
13.0 Statutory Determinations 33
13.1 Protection of Human Health and the Environment 33
13.2 Compliance with ARARs 33
13.3 Cost Effectiveness 34
13.4 Five-Year Review Requirements 35
14.0 Documentation of Significant Changes from Preferred Alternative of Proposed
Plan 35
15.0 References 35
PART 3: RESPONSIVENESS SUMMARY 36
Tables
Table 1: Engineering Controls in Place 38
Table 2: Groundwater EPCs 39
Table 3: Deep Soil EPCs 39
Table 4: OlJ-2 Risks 39
Table 5: Groundwater Cleanup Levels 40
Table 6: Relative Comparison of Alternatives 1, 2, 3 and 4 40
Table 7: Cost Summary, Alternatives 2 through 4 40
Table 8: Cost Estimate Breakdown for Alternative 3a - Institutional Controls and Enhanced
Aerobic Treatment - iSOC® / Waterloo Emitter™ 41
Table 9: Cost Estimate Breakdown for Alternative 3b - Institutional Controls and Enhanced
Aerobic Treatment - Oxidant Candle® 42
Table 10: Cost Estimate Breakdown for Alternative 3c - Institutional Controls and Enhanced
Aerobic Treatment - Regenesis Oxygen Socks® 43
Table 11: Chemical-Specific ARARs and TBCs for Ward Transformer Superfund Site - OlJ-2
Record of Decision 44
Table 12: Action-Specific ARARs and TBCs for Ward Transformer Superfund Site - OlJ-2
Record of Decision 45
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Figures
Figure 1: Site Location 76
Figure 2: Removal Extent and Maximum Excavation Depths 77
Figure 3: Extent of Treated Soil Backfill and Cover 78
Figure 4: PCBs Left in Place After the OU-2 Removal Action 79
Figure 5: Human Health Conceptual Site Exposure Model for OlJ-2 80
Figure 6: Ecological Conceptual Site Exposure Model for Exposure to PCBs in OlJ-2 81
Figure 7: Groundwater Sampling Results and Potentiometric Surface, February 2016 82
Appendices
State of North Carolina Concurrence A-1
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Acronyms and Abbreviations
AOD
Airport Overlay District
ARAR
Applicable or Relevant and Appropriate Requirement
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
COC
Chemical of Concern
CO PC
Chemical of Potential Concern
CSM
Conceptual Site Model
CTE
Central Tendency Exposure
EPA
U.S. Environmental Protection Agency
EPC
Exposure Point Concentration
Estes
Estes Express Lines
FAA
Federal Aviation Administration
FFS
Focused Feasibility Study
FS
Feasibility Study
IRIS
Integrated Risk Information System
iSOC®
In-Situ Submerged Oxygen Curtain
MCL
Maximum Contaminant Level
Hg/L
Micrograms per Liter
mg/kg
Milligrams per Kilogram
MNA
Monitored Natural Attenuation
NC
North Carolina
NCAC
North Carolina Administrative Code
NCDEQ
North Carolina Department of Environmental Quality
NCDOT
North Carolina Department of Transportation
NCP
National Oil and Hazardous Substances Contingency Plan
NPL
National Priorities List
O&M
Operation and Maintenance
ORG
Oxygen Release Compound
OU
Operable Unit
PCB
Polychlorinated Biphenyl
PFAS
Per- and Polyfluoroalkyl Substances
PRB
Permeable Reactive Barrier
PRP
Potentially Responsible Party
RAO
Remedial Action Objective
RDU
Raleigh Durham International Airport
RI
Remedial Investigation
RME
Reasonable Maximum Exposure
ROD
Record of Decision
ROW
Right of Way
RPZ
Runway Protection Zone
SARA
Superfund Amendments and Reauthorization Act
SBRA
Supplemental Baseline Risk Assessment
SHOD-2
Special Highway Overlay District
SRI
Supplemental Remedial Investigation
TSCA
Toxic Substances Control Act
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UCL Upper Concentration Limit
U.S.C. United States Code
VOC Volatile Organic Compound
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PART 1: DECLARATION
1.0 SITE NAME AND LOCATION
Ward Transformer Superfund Site
Raleigh, Wake County, North Carolina
Superfund Site Identification Number NCD003202603
2.0 STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the U.S. Environmental Protection Agency's (EPA)
selected remedy for Operable Unit 2 (OlJ-2) at the Ward Transformer Superfund site (the Site) in
Wake County, North Carolina. The selected remedy was chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) as set forth
in 42 United States Code (U.S.C.) §§ 9601-9675 and, to the extent practicable, the National Oil
and Hazardous Substances Contingency Plan (NCP), 40 Code of Federal Regulations (CFR)
Part 300. This decision is based on the Administrative Record file for the Site
(https://semspub.epa.gov/src/collection/04/AR67444).
The EPA is the lead agency for site activities. The North Carolina Department of Environmental
Quality (NCDEQ) is the support agency. NCDEQ provided input during the remedial
investigation (Rl) and feasibility study (FS) and the remedy selection process. NCDEQ concurs
with the selected remedy.
3.0 ASSESSMENT OF SITE
The response actions selected in this ROD are necessary to protect public health and welfare or
the environment, from actual or threatened releases of hazardous substances into the
environment.
4.0 DESCRIPTION OF SELECTED REMEDY
The EPA is managing cleanup of the Site as two operable units (OUs). Contamination in surface
water bodies and sediments located downstream from the former Ward Transformer facility that
are also downstream of Interstate 540 are addressed in Operable Unit 1 (OlJ-1). Areas upstream
of Interstate 540 and including the former Ward Transformer facility, surrounding affected
properties and an unnamed tributary to Little Brier Creek (Reach A) are addressed in OlJ-2.
The EPA selected a remedy for OlJ-1 in a ROD issued in September 2008. The OU-1 remedial
action construction phase finished in 2023. Monitoring to confirm that fish tissue meets remedial
goals is ongoing.
OU-2, the subject of this ROD, addresses residual subsurface soil and groundwater
contamination remaining at the former Ward Transformer facility and surrounding areas after
completion of a removal action in 2014. It is the final response action for the Site.
The response action selected in this ROD is necessary to protect public health and the
environment from actual or threatened releases of site-related hazardous substances into the
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environment. Groundwater at the Site is a potential source of drinking water. It is contaminated
with volatile organic compounds (VOCs) above levels that present an unacceptable risk to a
hypothetical resident using groundwater as a source of drinking water and exposed via the vapor
intrusion pathway. Site groundwater is contaminated with VOCs above federal and state drinking
water standards. In addition, polychlorinated biphenyls (PCBs) remaining in soil after the OlJ-2
removal action, completed in 2014, exceed cleanup levels for low-occupancy areas, as specified
in the Toxic Substances Control Act (TSCA) PCB regulations at 40 CFR 761.61(a)(4) that are
considered relevant and appropriate requirements consistent with the NCP.
The selected remedy. Alternative 3, consists of the following major elements:
• Enhanced aerobic treatment of chemicals of concern (COCs) in groundwater through the
addition of oxygen in situ.
• Long-term groundwater monitoring to verify attainment of cleanup levels.
• Implementation of institutional controls to restrict land and groundwater use as well as
prevent disturbance of residual PCB contamination and the soil cover areas.
• Long-term monitoring and maintenance of the engineering controls such as the
geotextile/plastic liners, crushed stone, concrete, soil cover implemented during the OlJ-2
removal action.
A pre-design investigation will be performed to identify the area requiring groundwater
treatment and to select the treatment method for adding oxygen to the subsurface. The estimated
cost of the selected remedy ranges from $517,390 to $864,256, depending on the specific
vendor's technology selected during remedial design.
There are no principal threat wastes known to be present on site. The estimated timeframe for
construction completion is less than two years. Long-term monitoring is expected to continue
until groundwater cleanup goals are attained.
5.0 STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in Section 121 of
CERCLA, 42. U.S.C. § 9621, and the NCP at 40 CFR 300.430(f)(l)(ii) because it is protective of
human health and the environment, complies with federal and more stringent state environmental
requirements that are applicable or relevant and appropriate to the remedial action, is cost
effective, and utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable.
The selected remedy meets the statutory preference for treatment as a principal element of the
remedy. Although there are no principal threat wastes known to be present, the selected remedy
includes the addition of dissolved oxygen into the groundwater to enhance the natural breakdown
of contaminants, thus reducing the toxicity, mobility and volume of contaminants.
Because this remedy will result in hazardous substances, pollutants or contaminants remaining
on site above levels that allow for unlimited use and unrestricted exposure, a statutory review per
CERCLA Section 121(c) will be conducted within five years after initiation of the remedial
action to ensure that the remedy is, or will be, protective of human health and the environment.
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6.0 DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record file for the Site.
1
COCs and their respective concentrations.
Sections
5.5.1, 5.5.2, 5.5.4
2
Baseline risk represented by the COCs.
Section 7.1.4
3
Cleanup levels established for the COCs and the basis for these
levels.
Section 8.1
4
How source materials constituting principal threats are
addressed.
Section 11.0
5
Current and reasonably anticipated future land use
assumptions and current and potential future beneficial uses of
groundwater used in the baseline risk assessment and ROD.
Section 6.0
6
Potential land and groundwater use that will be available at the
Site as a result of the selected remedy.
Section 12.4.1
7
Estimated capital, annual operation and maintenance (O&M)
and total present worth costs, discount rate, and the number of
years over which remedy cost estimates are projected.
Section 12.3
8
Key factor(s) that led to selecting the remedy.
Section 12.1
7.0 AUTHORIZING SIGNATURE
RANDALL Digitally signed by RANDALL
CHAFFINS
CHAFFINS Date: 2023.09.28 07:19:43 -04'00'
Caroline Y. Freeman, Director
Superfund and Emergency Management Division
U.S. Environmental Protection Agency, Region 4
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PART 2: THE DECISION SUMMARY
1.0 SITE NAME, LOCATION AND BRIEF DESCRIPTION
The Site includes the former Ward Transformer facility, surrounding affected properties and surface
water bodies downstream from the facility. The former Ward Transformer facility property is on
Mount Herman Road in Raleigh, Wake County, North Carolina. It is about 600 feet south-southeast of
Interstate 540 (also known as the Northern Wake Expressway) in an area of industrial and commercial
land use and includes a portion of Raleigh Durham International Airport (RDU) property.
The EPA divided the Site into two OUs to manage the Site's cleanup. OU-1 addresses contamination in
surface water bodies downstream from the former Ward Transformer facility that are also downstream
of Interstate 540. The EPA previously selected a remedy for OU-1 in a ROD issued in 2008. The OU-1
remedial action construction phase finished in 2023. Monitoring of sediment and fish tissue in OlJ-1 is
ongoing.
OU-2, the subject of this ROD, is upstream of Interstate 540. It includes an unnamed tributary to
Little Brier Creek (Reach A), the former Ward Transformer facility and surrounding affected properties,
with an area of approximately 80 acres. Figure 1 shows the location of OlJ-2. OU-2 is in a commercial
and industrial area and includes part of the RDU property. The RDU property includes the lands recently
purchased for a planned runway expansion and includes the area where the selected remedy will be
implemented.
The EPA is the lead agency for site activities. The North Carolina Department of Environmental Quality
(NCDEQ) is the support agency. The remedy will be funded using funds collected from the Responsible
Parties and held in a special account managed by the EPA. The Superfund Site Identification Number is
NCD003 202603.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 History of Site Activities
The Ward Transformer facility was built on about 1 1 acres of previously undeveloped land in 1964.
From 1964 to 2006, Ward Transformer Company, Inc. and then Ward Transformer Sales and Service,
Inc. operated a facility that built, repaired, sold and reconditioned transformers, switchgear and similar
types of electrical equipment. Facility operations included the main building where transformers were
handled and offices were located, the transformer storage yard, a stormwater management lagoon
(lagoon) and a building that housed a stormwater treatment system. On the northern part of the Site, a
warehouse that was formerly part of Ward Transformer operations was leased to a lumber supply
business from 1976 to 2002.
In 1971, two lagoons were created on the southern part of the Ward Transformer property for
stormwater runoff. The upper lagoon had a pipe that drained to the lower lagoon. The lower lagoon had
a pipe that drained to the unnamed tributary to Little Brier Creek (Reach A). Around 1979, the
stormwater treatment system was added to the facility. Treated water from the stormwater treatment
system was discharged to a permitted outfall on the unnamed tributary to Little Brier Creek (Reach A).
Facility operations resulted in the release of PCBs and other PCB-related chemicals from transformers,
transformer parts and transformer oil into the environment, as well as smaller amounts of VOCs and
semi-VOCs. Contamination was found in the soil at the Ward Transformer facility and adjacent
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properties, in the water and sediment in the lagoon, and in the sediments along the surface water
pathway draining away from the plant.
2.2 History of Investigations and Cleanup Actions
2.2.1 Previous Investigations and Response Actions
In 1978, the EPA collected several samples on and downstream from the Ward Transformer facility.
Sampling found PCB and chlorinated benzene contamination in soil, in on-site storage tanks, in water
and sediment in the facility's lagoon, and in surface water and sediment along the surface water pathway
draining from the lagoon. PCBs were also found in sediment samples collected in tributaries, creeks and
lakes downstream of the facility, and in fish and crayfish tissue collected in those surface water bodies.
State agencies completed more investigations at the Site between 1994 and 1997. Sampling confirmed
contamination on and off the Ward Transformer facility property. Sampling of the facility's water
supply well and a nearby private drinking water well did not detect PCBs or VOCs.
The EPA proposed listing the Site on the Superfund program's National Priorities List (NPL) in
September 2002. The EPA finalized the Site's listing on the NPL in April 2003.
The EPA led a phased RI at the Site from April 2003 to April 2007. Areas included in the evaluation
included the Ward Transformer facility property, surrounding properties and more than 30 miles of
waterways downgradient of the Ward Transformer facility. The RI investigated the distribution of
pesticides/PCBs, PCB congeners, dioxins/furans, VOCs, semi-VOCs and metals in soil, surface water,
sediments and groundwater. In an initial evaluation of risk in 2004, PCBs were found to be the primary
contributor to the estimated total cancer risk for all exposure scenarios. The EPA judged the risk to be
sufficient to require a removal action to address direct contact and off-site surface water transport of
PCBs. The EPA issued an Enforcement Action Memorandum for a time-critical removal action in
September 2004. The EPA updated it with a Supplemental Enforcement Action Memorandum in
January 2013.
In September 2005, the EPA signed an Administrative Settlement Agreement and Order on Consent
with a group of potentially responsible parties (PRPs) to perform the time-critical removal action at the
Ward Transformer facility and some immediately surrounding areas, including Reach A. The EPA
subsequently identified this area as OlJ-2. The agreement required the removal of soil and sediment
containing PCBs and prevention of off-site migration of material that may contain PCBs. The OlJ-2
removal action began in 2007. It finished in 2014. Section 2.2.2 of this ROD presents more information
on the removal action.
In September 2008, the EPA issued a ROD to select a remedy for OU-1. The OU-1 remedy includes
excavation and off-site disposal of sediments and floodplain soil from Little Brier Creek (Reaches B
and C), Little Brier Creek (Reach D) and lower Brier Creek, monitored natural recovery in Brier Creek
Reservoir, Lake Crabtree and Lower Crabtree Creek, and institutional controls. The OU-1 remedial
action construction phase finished in 2023. Monitoring of sediment and fish tissue in OU-1 is ongoing.
2.2.2 OU-2 Removal Action
The OlJ-2 removal action, completed in 2014, included excavation of PCB-contaminated soil and
debris, demolition of site structures at the former Ward Transformer facility, low-temperature thermal
desorption treatment of soil with reuse of the treated soil as backfill, off-site disposal of untreated soil
and debris, backfilling of excavations, and site restoration. The soil treatment area primarily covered the
former lagoon. The removal action included the removal and thermal treatment or off-site disposal of
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over 480,000 tons of PCB-contaminated soil, sediment and debris. As part of the removal action,
uncontrolled runoff of PCB-contaminated sediment was eliminated. Affected sediment in the former
lagoon and its embankment was removed and treated or taken off site for disposal. Figure 2 shows the
removal extent and maximum excavation depths from the OlJ-2 removal action.
The soil cleanup level for PCBs was 1 milligram per kilogram (mg/kg). The EPA later approved a
revised cleanup level of 10 mg/kg for soil that was thermally treated or beneath the treated soil final
cover system (located within the footprint of the facility's former lagoon). The treated soil final cover
system included a geotextile fabric as a marker layer and a minimum of 1 foot of off-site soil covered
with vegetation or stone. Figure 3 shows the area of the treated soil final cover system in the northeast
part of OU-2.
Geotextile/plastic liners, crushed stone, concrete, soil or other engineering controls were also placed in
areas where PCB-contaminated soil above the 1 mg/kg cleanup level was left in place. Table 1 includes
a summary of the engineering controls in place. These areas include areas with excavation refusal, a
limited area close to Interstate 540, an embankment along Lutnley Road and the former Estes Express
Lines (Estes) property south of the former Ward Transformer property. Excavation at the former Estes
property was limited to a depth of two feet to avoid significant disruption of the then-operating business.
The 2013 Supplemental Enforcement Action Memorandum required implementation of land use
restrictions at the Estes property and other affected properties where complete removal is technically
impracticable.
Figure 4 shows the areas where PCBs above cleanup levels were left in place in OlJ-2. Land use
restrictions in the form of a restrictive covenant were recorded for the Estes property in November 2013,
before the removal action in this area began, for locations where it was expected that PCBs would
remain in place. At the time, it was anticipated that the restrictive covenant would be updated after
completion of the removal action. A revised restrictive covenant is being prepared. Draft restrictive
covenants were also prepared for five other properties in 2019 but they were not finalized and recorded.
The EPA decided to defer implementation of more institutional controls for affected properties until
after a supplemental RI for groundwater.
The removal action successfully met the requirements of the EPA's 2004 Enforcement Action
Memorandum, as updated by the 2013 Supplemental Enforcement Action Memorandum.
On August 26, 2019, the EPA issued a Notice of Completion of Work that all work had been fully
performed, in accordance with the removal settlement agreement.
2.2.3 OU-2 Post-Removal Action Supplemental Remedial Investigation (SRI)
Initial groundwater investigations at the Site in 2003 and 2005 and before the OlJ-2 removal action
indicated that concentrations of PCBs, benzene, chlorobenzene, 1,4-dichlorobenzene and 1,2,4-
trichlorobenzene were present above federal Safe Drinking Water Act (SDWA) primary drinking water
standards maximum contaminant levels (MCLs) and above the North Carolina (NC) groundwater
quality standards at 15A North Carolina Administrative Code (NCAC) 02L .0202 in one or more
monitoring wells at the Site. These compounds were primarily found in wells around the perimeter of
the former Ward Transformer facility lagoon. Most of the wells were abandoned prior to the removal
action because they were in excavated areas.
After the removal action, monitoring wells were re-installed at the Site. Groundwater sampling took
place on seven occasions from October 2014 to February 2016. PCBs, benzene, chlorobenzene,
1,4-dichlorobenzene and 1,2,4-trichlorobenzene were the chemicals of interest in the supplemental
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investigation. The March 2018 Final Supplemental Remedial Investigation Report, Revision 1 (2018
SRI Report) presents the results of the investigation.
2.2.4 OU-2 Focused Feasibility Study
A Focused Feasibility Study (FFS) Report for post-removal action conditions was finalized in February
2023. The FFS consisted of a series of assessments conducted during the SRI/FFS program to evaluate
remedial alternatives for achieving preliminary remediation goals for the limited contaminants
remaining in place after the removal action. The FFS included collection of additional groundwater
samples from monitoring well MW-03R in December 2019 for benzene, chlorobenzene,
1,4-dichlorobenzene and 1,2,4-trichlorobenzene as well as monitored natural attenuation (MNA)
analysis parameters. In addition, a microbial analysis was performed.
2.3 History of CERCLA Enforcement Activities
In August 2002, the EPA sent Ward Transformer Company, Inc. a general notice letter notifying the
company of its potential liability for the release or threatened release of hazardous substances at the Site.
In November 2003 and February 2004, the EPA sent information request letters to several hundred
companies that may have conducted business with Ward Transformer Company, Inc. or may have sent
hazardous materials to the Site.
In 2005, the EPA entered into an Administrative Settlement Agreement and Order on Consent with nine
PRPs for the performance of the time-critical removal action for OlJ-2 and the reimbursement of past
response costs.
In 2011, after unsuccessful attempts to negotiate a Consent Decree, the EPA issued a Unilateral
Administrative Order to 23 PRPs to perform the remedial design and remedial action for OU-1 selected
in the OU-1 ROD. In 2016, after additional negotiations, the EPA entered into a Consent Decree with
many parties to perform the OU-1 remedial design and remedial action.
3.0 COMMUNITY PARTICIPATION
The EPA conducted extensive community involvement activities as part of the OU-1 investigations and
remedy selection process from 2003 to 2007. These activities included mailing information fact sheets
and emails, press releases, availability sessions, presentations and public meetings. The EPA prepared a
Community Involvement Plan (CIP) for OU-1 in August 2020. The CIP is available online at
https://semspub.epa.gov/src/document/04
The EPA held a virtual public meeting on August 17, 2023, to present the Proposed Plan for OlJ-2 and
answer questions from meeting attendees. A 30-day public comment period on the Proposed Plan was
held from July 3 1, 2023, to August 30, 2023. Comments received by the EPA during the public
comment period are summarized and addressed in the Responsiveness Summary of this ROD.
The EPA established a location information repository for the Site's Administrative Record file at:
North Regional Library
7009 Harps Mill Road
Raleigh, North Carolina 27615
T: (919) 870-4000
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The materials are also available online at the EPA's site profile page:
http://www.epa.gov/superfund/ward-transformer. These digital documents are accessible on public
computers at North Regional Library at the address listed above.
4.0 SCOPE AND ROLE OF THE OPERABLE UNIT OR RESPONSE ACTION
The EPA is managing cleanup of the Site as two OUs. OU-1 addresses contamination in surface water
bodies downstream from the former Ward Transformer facility that are also downstream of Interstate 540.
OlJ-2 addresses areas upstream of the interstate and includes the former Ward Transformer facility,
surrounding affected properties and an unnamed tributary to Little Brier Creek (Reach A).
The EPA selected a remedy for OU-1 in a ROD issued in September 2008. The OU-1 remedy includes
excavation and off-site di sposal of sediments and floodplain soil from two unnamed tributaries to
Little Brier Creek (Reaches B and C), Little Brier Creek (Reach D) and lower Brier Creek, monitored
natural recovery in Brier Creek Reservoir, Lake Crabtree and lower Crabtree Creek, and institutional
controls. The OU-1 remedial action construction phase finished in 2023. Monitoring to confirm that fish
tissue meets remedial goals is now ongoing.
OU-2, the subject of this ROD, addresses residual subsurface soil and groundwater contamination
remaining at the former Ward Transformer facility and surrounding areas after completion of a removal
action in 2014. Documents describing the removal action in detail are included in the Site's
Administrative Record file, available online at (https://semspub.epa.gov/src/collection/04/AR67444).
The removal action included the removal and/or treatment of nearly a half-million tons of PCB-
contaminated soil, sediment and debris. The removal action addressed all surface contamination in
OU-2. After the removal action, PCB concentrations in soil remain in place at depths greater than two
(2) feet at levels above 10 mg/kg and above cleanup levels for low-occupancy areas, as specified in
40 CFR 761.61(a)(4), and for which further removal or treatment is impracticable. The 2013
Supplemental Enforcement Action Memorandum required institutional controls for areas where soil
contamination was expected to remain at depth. However, the EPA decided to defer implementation of
all required institutional controls for affected properties until after a supplemental R1 for groundwater.
The selected remedy in this ROD for OlJ-2 includes the updated institutional controls for certain areas
of the Site.
Concentrations of VOCs in groundwater at well MW-03R are greater than the MCLs for drinking water,
as specified in the Safe Drinking Water Act and North Carolina standards (15A NCAC 02L .0201).
Contamination remaining on site is considered a relatively low long-term threat (40 CFR
300.430(a)(l)(iii)(B)).
The response action for OlJ-2 will be consistent with the overall site strategy, which includes:
• Restoration and monitoring of Brier Creek and Lake Crabtree surface water and sediment
through the implementation of the OU-1 remedy.
• Selection and implementation of a remedy for OlJ-2 soils and groundwater.
• Coordination with the RDIJ Airport Authority and assistance with the Ward Transformer
property redevelopment and expansion of the RDIJ runway.
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5.0 SITE CHARACTERISTICS
5.1 Conceptual Site Model (CSM)
The CSM incorporates information on potential chemical sources, affected media, release mechanisms,
routes of migration, and known or potential human and ecological receptors. In this way, it illustrates the
physical, chemical and biological relationships between contaminant sources and affected resources.
The 2018 SRI Report includes diagrams that summarize how contamination moves from sources to
environmental media and to potential human receptors and ecological receptors. Figure 5 illustrates the
Site's human health CSM. Figure 6 illustrates the Site's ecological CSM.
5.2 Overview of the Site
5.2.1 Size of Site
OlJ-2 covers about 80 acres. The former Ward Transformer facility covered approximately 1 1 acres.
5.2.2 Topographic. Geologic and Hvdrogeologic Information
Site Topography and Drainage: The Site is on a local topographic high. Prior to 1972, site runoff
flowed overland or was carried in drainage ditches to intermittent streams west and southwest of the
facility. Some of the runoff entered a drainage ditch on the north side of the property, which conveyed
runoff to the west.
Final grading after the OlJ-2 removal action directs surface water flow approximately the same way as
pre-removal action conditions.
Site Geology/Hydrogeology: The Site is underlain by the Triassic sedimentary rocks of the
Chatham Group. The Chatham Group sediments range from mudstone, sandstone, fanglomerate and
conglomerate. Local bedrock outcrops (on RDU property and Little Brier Creek) show sandstone with
interbedded conglomerate.
The depth to bedrock underlying the Site ranges from 5 feet to 10 feet or more below the ground surface
and the Chatham Group bedrock encountered at the Site was observed to be siltstone and fine sandstone.
During the OlJ-2 removal action, bedrock was encountered from four (4) feet to 29 feet below the
ground surface.
Groundwater beneath the Site occurs in the underlying bedrock. It is stored and transmitted primarily
through a network of joints, fractures, faults and bedding planes, with little capacity to store and transmit
if unfractured. The permeability of the rock generally decreases with depth. Boring logs from the Site's
initial RI provide little information on groundwater source. However, the boring log for M W-01A
indicated a possible fracture zone at 35 feet below the ground surface.
During the RI, depth to groundwater at the Site was measured to be approximately five (5) feet to seven
(7) feet below the ground surface. However, during the OlJ-2 removal action, groundwater was not
encountered in the excavations, even in the deepest excavation at a depth of about 29 feet below the
ground surface (beneath the former Ward Transformer facility building).
During the SRI from 2014 to 2016, groundwater elevation measurements were collected and used to
develop potentiometric surface contour maps of the uppermost water-bearing unit. The potentiometric
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surface contour maps suggest a southwest direction of groundwater flow on the former Ward
Transformer facility and a westerly direction along Reach A (the downstream direction).
More information on the Site's geology and hydrogeology is in the Site's 2018 SRI Report and the
2023 FFS Report.
5.2.3 Surface and Subsurface Features
During the OlJ-2 removal action, surface and subsurface geology was modified. Substantial quantities
of off-site backfill were used to return excavated areas of OlJ-2 to the approximate pre-removal grades.
Off-site backfill was obtained from commercial sources and varied from silty sand to clayey sand to
clayey silt.
Thermally treated soil meeting the treatment criteria was used as backfill at the Ward Transformer
property within the approximate area of the facility's previous surface water management system.
The treated soil backfill was covered with a geotextile marker layer and 1 foot of off-site borrow soil to
support vegetation. Figure 3 shows the location of the treated soil cover area, which is in the
northeastern part of OlJ-2. A chain-link fence separates the treated soil area from Mount Herman Road.
South of the treated soil area is the former Estes property. It has two buildings no longer in use,
surrounded by paved and gravel parking areas.
There are several surface drainage features in OlJ-2, with Reach A of the unnamed tributary to
Little Brier Creek (Reach A) subject to cleanup. Figure 1 shows the surface drainage features. None of
the drainages are considered perennial water bodies.
5.3 Sampling Strategy
During the OlJ-2 removal action, confirmatory soil samples for PCBs were collected to determine if
removal action cleanup levels had been met. Results from the sampling are discussed in Section 5.4,
below.
The SRI completed in 2016 assessed groundwater conditions at the Site after the OlJ-2 removal action
had removed the primary sources of contamination. As part of the investigation, seven shallow
monitoring wells and one deep monitoring well were installed on site to supplement an existing
background monitoring well from an earlier investigation.
The SRI focused on those chemicals of interest detected in groundwater in 2003 and 2005 at
concentration above MCLs, prior to the removal action. PCBs, benzene, chlorobenzene,
1,4-dichlorobenzene and 1,2,4-trichlorobenzene were the chemicals of interest in the supplemental
investigation. Groundwater sampling took place on seven occasions from October 2014 to
February 2016. More groundwater samples were collected from MW-03R in December 2019.
5.4 Known or Suspected Sources of Contamination
Facility operations resulted in spills and accidental releases of PCBs and related chemicals from
transformers, transformer parts and transformer oil into the environment. Contamination was found in
the soil at the Ward Transformer facility and adjacent properties, in the water and sediment in the
lagoon, and in the sediments along the surface water pathway draining away from the plant.
Contaminated soil was the primary source of contamination to groundwater, prior to the OlJ-2
removal action.
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After the OlJ-2 removal action, the vast majority of contaminated soil has been removed, treated and
contained. Only small areas of PCB-impacted soil above cleanup goals remain in place (see Section 5.5
and Figure 4 of this ROD), which are not expected to act as ongoing sources of contamination due to
engineering controls in place that prevent further migration.
5.5 Nature and Extent of Contamination
5.5.1 Soil. Sediment and Debris
The OlJ-2 removal action, completed in May 2014, included the removal and/or treatment of nearly a
half-million tons of PCB-contaminated soil, sediment and debris. The Removal Action Completion
Reports (2012 and 2015) indicate that PCB-contaminated soil, sediment and debris were treated or
removed to the extent practicable and feasible. However, at some locations limited by excavation refusal
or surrounding land use restrictions, material with PCBs above the 1 mg/kg and 10 mg/kg cleanup levels
were left in place.1 The areas with PCBs remaining in place were marked with a geotextile/plastic layer
and covered with backfill. Figure 4 shows the areas where PCBs above the cleanup criteria remain in
place in OlJ-2.
The following areas in OlJ-2 have PCBs above the removal action cleanup levels:
• Areas of excavation refusal with PCB concentrations ranging from 1.1 mg/kg to 1,700 mg/kg,
with the maximum concentration located about 29 feet below ground surface (restored ground
surface). Along Reach A, PCBs at concentrations ranging from 1.1 mg/kg to 610 mg/kg remain
at bedrock refusal depths from 4 feet to 11 feet below ground surface.
• Near a short wall section (about 10 feet in length) along the fence line at Interstate 540, PCBs at
a concentration of 1.8 mg/kg were left in place from an excavation 3 feet below ground surface.
• At the former Estes property, PCBs at concentrations from 1 mg/kg to 1 1 mg/kg were left in
place below the loading dock floor. Part of the original storm water drainpipe beneath the front of
the former Estes building was also left in place after being plugged at both ends. In other areas
on the former Estes property, PCBs were left in place at concentrations from 1 mg/kg to
200 mg/kg. At these locations, the excavation was generally restricted to a depth of two (2) feet
and restored with a soil, crushed stone and/or concrete cover. The former Estes property has a
restrictive covenant in place to limit excavation and soil disturbance.
• At the North Carolina Department of Transportation (NCDOT) right of way (ROW) along
Lutnley Road, PCB concentrations above one (1) mg/kg remain in place.
Further details on the nature and extent of remaining soil contamination are in the Removal Action
Completion Reports and the 2023 FFS Report, which are available in the Site's Administrative Record
accessible on the EPA's site profile page (http://www.epa.gov/superfund/ward-transformer).
5.5.2 Groundwater
Of the nine wells sampled during the 2014 to 2016 SRI, only shallow monitoring well MW-03R had
concentrations of benzene, chlorobenzene, 1,4-dichlorobenzene and 1,2,4-trichlorobenzene above
federal SDWA primary drinking water standards maximum contaminant levels (MCLs) at 40 CFR
141.61 and North Carolina (NC) groundwater quality standards at 15A NCAC 02L .0202. The
detections of benzene that exceeded MCLs or NC 2L groundwater standards ranged from
1 Only Aroclors 1254 and 1260 were detected in the samples of remaining material. All other A roc lor results were noted with
a "U" qualifier, which arc concentrations not detected at the reporting limit.
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1.8 micrograms per liter ((.ig/L) to 9.8 (.ig/L. The chlorobenzene detections ranged from
53 (.ig/L to 110 (.ig/L. The 1,4-dichlorobenzene detections ranged from 18 (.ig/L to 120 (.ig/L.
The 1,2,4-trichlorobenzene detections ranged from 150 (.ig/L to 830 (.ig/L. These VOC compounds were
not detected above MCLs or NC 2L groundwater quality standards in any other well at any point prior
to, during or after the SRI. Figure 7 shows the groundwater sampling results from the February 2016
sampling event.
Results from samples collected during the SRI suggest that the VOC impacts are localized to the vicinity
of monitoring well MW-03R, which is near the former Ward Transformer lagoon, and at a depth similar
to the screened interval of MW-03R (i.e., 30 feet to 45 feet below ground surface).
Of all the results, PCBs were only detected during the July 2015 event (the third out of seven sampling
events) in monitoring well MW-03R at a concentration of 1.7 (.ig/L (Aroclor 1248), compared to the
MCL of 0.5 (.ig/L. The July 2015 PCB detections in MW-03R were determined to be anomalous results.
PCBs were not detected in the well in any other sampling event.
In December 2019, additional groundwater samples were collected from MW-03R. Because the
monitoring well had been inactive since February 2016, monitoring well MW-03R was redeveloped
prior to sampling.
The results for the December 2019 sampling event for COCs were as follows:
• Benzene: 8.5 (.ig/L.
• Chlorobenzene: 57 (.ig/L.
• 1,4-dichlorobenzene: 73 (.ig/L.
• 1,2,4-trichlorobenzene: 870 (.ig/L.
Per- and polyfluoroalkyl substances (PFAS) are emerging contaminants of concern. This class of
chemicals can be associated with fire-fighting foam commonly used at airports. Although the former
Ward Transformer facility is located near the RDU airport, the EPA does not consider PFAS a potential
concern for the Site due to the location of the existing airport facilities south of the Site and the
groundwater flow direction at the Site. Data from 2003 estimate groundwater flow at the Site to the
south/southwest, which was confirmed with data collected in 2015 and 2016. Groundwater
contamination, if it existed at the airport, would not be expected to impact the Site.
5.5.3 Quantity/Volume of Waste to be Addressed
Limited areas of soil contamination remain at depth after the OlJ-2 removal action and are discussed in
Section 5.5.1 of this ROD. The volume of contaminated soil remaining in place was not calculated
because engineering controls, consisting of at least 2 feet of backfill or existing covers, are already in
place to prevent future exposures (see Table 1). The remedial action selected in this ROD will update the
institutional control requirements for the limited areas of soil contamination that remain at depth.
The groundwater plume impacted by VOCs at concentrations above MCLs and NC 2L groundwater
quality standards has an estimated lateral area of about 1.1 acres. Based on the saturated interval
thickness of about 21 feet, it is estimated that the groundwater VOC plume occupies an approximate
bedrock volume of 1 million cubic feet. Considering that the bedrock is composed of approximately
10% void space, as would be expected based on rock type, the estimated volume of impacted
groundwater is approximately 100,000 cubic feet (or approximately 750,000 gallons).
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5.5.4 Concentrations of COCs in Each Medium
COCs for OlJ-2 include benzene, chlorobenzene, 1,2,4-trichlorobenzene and 1,4-dichlorobenzene in
groundwater and PCBs in soil.
Table 2 presents groundwater COC exposure point concentrations (EPCs) used in the baseline human
health risk assessment. Table 3 presents the EPCs for PCBs in deep soil remaining on site after the OlJ-2
removal action.
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5.6 Location and Potential Routes of Migration
5.6.1 Lateral and Vertical Extent of Contamination
Sections 5.5.1 and 5.5.2 of this ROD address the lateral and vertical extent of soil and groundwater
contamination.
5.6.2 Surface and Subsurface Routes of Exposure
Surface and subsurface routes of exposure include:
• Current and future occupational worker (adult) - vapor intrusion.
• Future construction, excavation or maintenance worker (adult) - incidental ingestion and dermal
contact with soil, dermal contact with groundwater and inhalation of vapors from groundwater.
• Future resident (child and adult) - ingestion and dermal contact with groundwater, inhalation of
tap water vapors and vapor intrusion.
5.6.3 Migration of COCs to Other Media
The potential migration pathways associated with the affected media include:
• Volatilization of VOCs from groundwater to air.
• Dissolution/desorption of PCBs from soil/sediment to groundwater.
o PCBs have not been persistently detected in groundwater at the Site since the removal
action. Therefore, di ssol uti on/desorpti on from soil to groundwater is not considered an
important fate-and-transport mechanism for PCBs under current conditions.
• Migration of VOCs in groundwater to surface water.
o MW-03R is the only well with VOC concentration exceeding the MCLs or NC 2L
groundwater quality standards. In general, groundwater flows across the Site from east to
west in the area downgradient from well MW-03R. The Reach A surface water feature is
downgradient of monitoring well MW-03R. However, with groundwater present only at
significant depths and a downward gradient at the MW-03R/MW-09 wells pair. Reach A
is not expected to receive contribution from Site groundwater. Well MW-09 is a deeper
well paired with MW-03R; contamination in samples collected from MW-09 have been
mostly non-detect or otherwise inconsequential.
5.6.4 Potentially Affected Populations
There are several receptor groups that may use the Site currently or in the future, including:
• Occupational workers (adult) - current and future.
• Trespasser (teenager, adult) - current and future.
• Construction, excavation or maintenance worker (adult) - future.
• Hypothetical resident (child, adult) - future.
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6.0 CURRENT AND POTENTIAL FUTURE USES
6.1 Land Use
Current land use in OlJ-2 includes undeveloped land, light industrial and commercial businesses, RDU
property and public roads. The light industrial and commercial businesses are along Mount Herman
Road. There are no residential properties in OlJ-2.
The OlJ-2 properties are either RDlJ-owned airport properties or are zoned for industrial use.
The properties zoned for industrial use are within the Airport Overlay District (AOD) and the
Special Highway Overlay District (SHOD-2). In the AOD, residential use is prohibited to protect the
public from aircraft noise. The SHOD-2 protects and reserves the area along the Interstate 540 corridor,
limiting points of access and providing setbacks for building and structures from the roadway.
Parts of OlJ-2 are also in the Federal Aviation Administration (FAA) runway protection zone (RPZ).
RPZs must be protected from obstructions and incompatible land use. RDU is planning a runway
expansion into parts of OlJ-2. Zoning in OlJ-2 will change to reflect the updated use by RDU. As part of
the expansion, Lutnley Road would be rerouted, and parts of the former Ward Transformer and Estes"
properties would be part of the RPZ.
Reasonably anticipated future land uses at OlJ-2 include industrial uses, highly restricted highway
district uses (subject to NCDOT limitations that will preclude residential/commercial use) and highly
restricted airport district uses (subject to limitations that will preclude residential/ commercial use).
6.2 Groundwater and Surface Water Uses
Groundwater at the Site is classified for existing or potential source of drinking water supply for humans
(Class GA or Class GSA) under NC groundwater classification regulations at 15ANCAC 02L .0201.
However, groundwater is not used for any purpose including drinking water at OlJ-2. Municipal
supplied drinking water is available.
Reach A, an unnamed tributary to Little Brier Creek, is located in OlJ-2. Reach A does not support
recreational fishing or swimming due to its small size and intermittent flow.
7.0 SUMMARY OF SITE RISKS
Risk assessments were conducted to determine the current and future effects of contaminants on human
health and the environment. The results of the risk assessment provide the basis for taking action and
identify contaminants and exposure pathways that need to be addressed by the remedial action.
After the SRI groundwater investigation, a Supplemental Baseline Risk Assessment (SBRA) was
conducted. It included a Supplemental Baseline Human Health Risk Assessment and a Supplemental
Baseline Ecological Risk Assessment. The SBRA updated risk assessments from the 2004 and 2007 RI
reports. It focused on potential current and future risks based on the post-removal action conditions for
OlJ-2. Risk assessment results can be found in the 2018 Final SRI Report. They are summarized below.
7.1 Human Health Risk Assessment
The human health risk assessment uses a four-step process to assess site-related human health risks.
• Hazard Identification uses the analytical data collected to identify the chemicals of potential
concern (COPCs) at the Site for each medium.
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• Exposure Assessment estimates the magnitude of actual and/or human exposures, the frequency
and duration of the exposures, and the pathways by which humans are potentially exposed.
• Toxicity Assessment determines the types of adverse health effects associated with chemical
exposures, and the relationship between magnitude of exposures (dose) and severity of adverse
health effect (response).
• Risk Characterization summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative assessment of site-related risks.
7.1.1 Hazard Identification
The Supplemental Baseline Human Health Risk Assessment considered groundwater and soil data
collected after the OlJ-2 removal action. COPCs included PCBs (by Aroclors) left in place in soil, and
benzene, chlorobenzene, 1,4-dichlorobenzene and 1,2,4-trichlorobenzene in groundwater. The risk
assessment evaluated the potential for excess lifetime cancer risks and noncancer hazards to current and
future receptors with exposure to the COPCs, as described further below.
Because MW-03R is the only well with VOC concentration exceeding the MCLs or NC 2L groundwater
standards, the detected concentrations in groundwater from MW-03R in the most recent sampling event
in 2016 were selected as the exposure point concentrations for groundwater COPC. The 95% upper
confidence limit (UCL) on the mean was selected as the exposure point concentration for the soil COPC
(PCBs) under a reasonable maximum exposure scenario.
Tables 2 and 3 present groundwater and soil EPCs, respectively.
7.1.2 Exposure Assessment
The Supplemental Baseline Human Health Risk Assessment evaluated several receptor groups that may
use the OlJ-2 area at the Site currently or in the future. The following exposure pathways were
evaluated:
• Current and future occupational worker (adult) - vapor intrusion.2
• Future construction, excavation or maintenance worker (adult) - incidental ingestion and dermal
contact with soil, dermal contact with groundwater and inhalation of vapors from groundwater.
• Future resident (child and adult) - ingestion and dermal contact with groundwater, inhalation of
tap water vapors and vapor intrusion.
Because OlJ-2 consists of property owned by RDU or property zoned for industrial use and is close to
the airport, residents are unlikely to be future receptors at the Site and are therefore removed from
further consideration. The Supplemental Baseline Human Health Risk Assessment evaluated residential
exposure to determine if institutional controls restricting residential land use are warranted for OlJ-2.
It also indicated that an adult or teenage trespasser could be a potential receptor in the area. However,
this receptor is present a minimal amount of time and is not expected to be exposed to soils at depth or
to groundwater, so the risk estimates for construction, excavation and maintenance workers would be
overly protective of any trespasser.
Default exposure parameters for site workers are from EPA guidance. They are summarized in Table 6-4
in the SRI Report. Exposure parameters for residents were default parameters.
2 The risk assessment assumed that occupational workers would obtain drinking water from the municipal supply and would
not be exposed to PCB contamination in soil at depth.
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7.1.3 Toxicity Assessment
The toxicity assessment summarizes the health effects that may be associated with exposure to
the COPCs selected for the risk assessment and identifies doses that may be associated with
those effects. It involves evaluating the potential for a constituent to cause an increase in the
incidence of adverse effects in exposed individuals and quantitatively characterizing the chemical dose
and the incidence of adverse health effects in the exposed receptor. The potential toxicological effects
induced by a given dose of a chemical are classified as either non-cancer effects or cancer effects.
Toxicity values typically employed to carcinogenic hazards include reference doses for oral and dermal
exposures and reference concentrations for inhalation exposures; oral and dermal cancer slope factors
and inhalation unit risks are typically toxicity values were used to calculate potential effects for these
two types of effects.
For soil exposures, toxicity factors for PCB Aroclors were based on the EPA Integrated Risk
Information System (IRIS) toxicological profile for PCBs.
For the groundwater assessment for vapor intrusion and use as tap water by a potential future resident,
toxicity values from the EPA IRIS database. Agency for Toxic Substances and Disease Registry reports,
California EPA and the provisional peer-re vie wed toxicity values were used. Table 6-7 in the 2018 Final
SRI Report summarizes the values used in the toxicity assessment.
7.1.4 Risk Characterization
The EPA considers two types of risk: cancer risk and noncancer risk. The likelihood of any kind of
cancer resulting from a Superfund site is generally expressed as an upper bound probability, for
example, a " 1 in 10,000 chance". In other words, for every 10,000 people that could be exposed, one
extra cancer may occur because of exposure to site contaminants. An extra cancer case means that one
more person could get cancer than would normally be expected to from all other causes. For noncancer
health effects, the EPA calculates a "hazard index". The key concept is that a "threshold level"
(measured as a hazard index of less than 1) exists below which noncancer health effects are no longer
predicted. A CERCLA response action is generally warranted when cancer risk is greater than 1 x 10"4
or when noncancer health effects are greater than a hazard index of 1.
Table 4 summarizes OlJ-2 risks based on post-removal action site conditions.
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Table 4: OU-2 Risks
Receptor
Media/Pathway
coc
Cancer Risk"
Noncancer
Hazard Index"
Future Adult
Construction/Excavation/Maintenance
Worker
Soil - ingestion,
inhalation, dermal
contact
PCBs
2.3 x 10"5
b
Future Adult Resident
Groundwater -
ingestion/derinal
contact
VOCs
4.5 x 10 4
92
Future Child Resident
Groundwater -
vapor intrusion
VOCs
C
94
Future Adult/Child Resident
Groundwater -
vapor intrusion
VOCs
1.5 x 10"5
5.7
Current/future Occupational Worker
Groundwater -
vapor intrusion
VOCs
2.9 x 10"6
1.3
Notes:
a) Based on reasonable maximum exposure (RME) assumptions.
b) Not calculated; noncancer toxicity data for soil COG Aroclor 1260 have not been established.
c) Cancer risk for future child resident not calculated separately.
Bold results indicate cancer risk exceeds the EPA's generally acceptable risk range or the noncancer hazard index
exceeds 1.
Source: Section 6.0, Supplemental Baseline Risk Assessment. SRI Report. 2018.
Future hypothetical use of groundwater as a potable water source results in cancer and non-cancer risk
above the EPA's acceptable risk range and hazard index of one (1). The noncancer risk for both adults
and children were driven by 1,2,4-trichlorobenzene, while the cancer risks were driven by both
1,2, 4-trichlorobenzene and 1,4- dichlorobenzene in monitoring well MW-03R. Potential risks of vapor
intrusion from groundwater to a hypothetical residential indoor air also exceeded the EPA's acceptable
risk range. Potential risks of vapor intrusion to indoor air for an occupational worker have a hazard
index of 1.3.
COCs for OlJ-2 include benzene, chlorobenzene, 1,2,4-trichlorobenzene and 1,4-dichlorobenzene in
groundwater and PCBs in soil. Although PCBs did not result in unacceptable risk based on current
and reasonably anticipated use, PCB concentrations in soil remain in place above cleanup levels for
low-occupancy areas, as specified in 40 CFR 761.61(a)(4) which is identified as a relevant and
appropriate requirement consistent with CERCLA section 121(d)(2) and the NCP.
7.2 Ecological Risk Assessment
The Supplemental Baseline Ecological Risk Assessment evaluated the pathways of exposure to general
community types found in and around the OlJ-2 area. Given the spatial scale, bioavailability and
magnitude of CO PC concentrations, exposures to COPCs were expected to be minimal. No ecological
risk was calculated. Soil in most areas of OlJ-2 was excavated, backfilled with clean soil and restored.
Most of the PCBs left in place in OlJ-2 (excluding the NCDOT ROW and the former Estes property
where PCBs are not exposed and are beneath either foundations or road grade materials) are at depths
greater than 16 to 20 feet below ground surface, with the majority at depths greater than 20 feet below
ground surface. PCBs at the former Estes property are covered with at least two (2) feet of clean soil,
crushed stone and/or concrete paving.
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7.3 Basis for Action
The response action selected in this ROD is necessary to protect public health and the environment from
actual or threatened releases of site-related hazardous substances into the environment. Groundwater at
the Site is a potential source of drinking water. It is contaminated with VOCs above levels that present
an unacceptable risk to a hypothetical resident using groundwater as a source of drinking water and
exposed via the vapor intrusion pathway. Concentrations of benzene, chlorobenzene,
1,4-dichlorobenzene and 1,2,4-trichlorobenzene in monitoring well MW-03R exceed federal MCLs, or
more stringent state drinking water standards or NC 2L groundwater quality standards that are
considered relevant and appropriate chemical-specific requirements.
PCBs remaining in soil after the OlJ-2 removal action exceed cleanup levels for low-occupancy areas, as
defined in the TSCA PCB regulations at 40 CFR 761.61(a)(4), which is identified as a relevant and
appropriate requirement consistent with CERCLA section 121(d)(2) and the NCP.
8.0 REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) provide a general description of what the cleanup will accomplish.
RAOs generally specify COCs, the environmental media, the exposure pathways and receptors to be
protected, and the levels of cleanup that need to be achieved by the remedy. They are based on
considerations of current and reasonably anticipated future land use, as well as groundwater and surface
water beneficial use designations.
The OlJ-2 removal action addressed most of the PCB-contaminated soil, sediment and debris on Site.
At some locations limited by excavation refusal or surrounding land use restrictions, material with PCBs
above the 1 mg/kg and 10 mg/kg removal cleanup criteria were left in place (Figure 4). In addition, the
PCB cleanup level for thermally-treated soil was 10 mg/kg. Therefore, the backfill in the treated soil
cover area shown in Figure 3 also has PCBs that remain in place above 1 mg/kg but below 10 mg/kg.
These areas affect portions of six parcels; only one of the six parcels (the former Estes property) has a
restrictive covenant in place, which was implemented prior to the OlJ-2 removal action. The areas with
PCBs remaining in place were marked with a geotextile/plastic layer and, where accessible, covered
with backfill. At the former Estes property, the areas with PCBs remaining place were covered with a
minimum two-foot-thick cover of vegetated soil, crushed stone and/or concrete paving.
The EPA has identified the following media-specific RAOs for the OlJ-2 cleanup:
Soil
• Prevent human ingestion of and contact with residual PCBs remaining in soil in the subsurface at
concentrations at or above 1 mg/kg outside the lateral limits of the treated soil, or at or above
10 mg/kg within the lateral limits of the treated soil cover.
Groundwater
• Prevent human ingestion of and contact with groundwater containing VOC COCs at
concentrations above the federal MCLs and the NC 2L groundwater quality standards, whichever
is more stringent.
• Restore groundwater quality to meet the federal MCLs or the NC 2L groundwater quality
standards, whichever is more stringent, based on the classification of the aquifer as a potential
source of drinking water (Class GA or Class GSA) under 15A NCAC 02L .0201.
• Prevent exposure to vapor intrusion for indoor workers from unacceptable levels of VOCs in
groundwater migrating to indoor air.
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8.1 Cleanup Levels
Table 5 lists the Site's groundwater cleanup levels, which are based on EPA Safe Drinking Water Act
MCLs or more stringent NC groundwater quality standards, established in Title 15A of NCAC Section 2L.
The removal action destroyed or removed the contaminant source and used institutional controls,
engineering controls or both to address PCB-impacted soils that remain above the removal action
cleanup criteria. Therefore, although this ROD includes an RAO for soil, that RAO will be met through
institutional controls and there are no additional cleanup levels for PCBs in soil. The selected remedy
includes long-term monitoring and maintenance of capped areas and implementation of institutional
controls to restrict land use.
Table 5: Groundwater Cleanup Levels
coc
EPA MCL;I
NC 2L Standard1*
Groundwater Cleanup
Level
(MJj/L)
(fi«/L)
Benzene
5
1
1
Chlorobcn/cne
100
50
50
1,4-Dichlorobenzene
75
6
6
1.2.4-T richlorobcnzcnc
70
70
70
Notes:
a) MCLs available at httDs://www.eDa.eov/ground-water-and-drinking-water/national-Drimarv-drinking-water-
regulations.
b) NC 2L standards available at httDs://www.dea.nc.gov/about/divisions/water-resources/water-
Dlanning/classification-standards/groundwater-standards.
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9.0 DESCRIPTION OF ALTERNATIVES
Section 12 l(b)( 1) of CERCLA, 42 U.S.C. § 9621 (b)( 1), mandates that remedial actions must be
protective of human health and the environment, cost effective, comply with applicable or relevant and
appropriate requirements (ARARs), and utilize permanent solutions and alternative treatment
technologies and resource recovery alternatives to the maximum extent practicable. Section 12 l(b)( 1) of
CERCLA also establishes a preference for remedial actions that employ, as a principal element,
treatment to reduce permanently and significantly the volume, toxicity or mobility of the hazardous
substances, pollutants and contaminants at a site. Section 121(d)(2) of CERCLA, 42 U.S.C. § 9621(d),
further specifies that a remedial action must attain a level or standard of control of the hazardous
substances, pollutants and contaminants that at least attains ARARs under federal and more stringent
environmental state laws, unless a waiver can be justified pursuant to Section 121(d)(4) of CERCLA,
42 U.S.C. § 9621(d)(4).
The 2023 FFS Report evaluated four remedial action alternatives for OlJ-2:
• Alternative 1: No Further Action
• Alternative 2: Institutional Controls and MNA
• Alternative 3: Institutional Controls and Enhanced Aerobic Treatment
• Alternative 4: Institutional Controls and Permeable Reactive Barrier (PRB) with PlumeStop®
Liquid Activated Carbon™
These alternatives are summarized below. Terminology used to describe and differentiate the
alternatives includes:
• Capital costs are those expenditures that are required to construct a remedial alternative.
• O&M costs are those post-construction costs necessary to ensure or verify the continued
effectiveness of a remedial alternative and are estimated on an annual basis.
• Total present value represents the amount of money which, if invested in the current year, would
be sufficient to cover all the costs over time associated with a project, calculated using a discount
rate of 7% and a 30-year time interval. This discount rate is based on Office of Management and
Budget Circular No. A-94, which states that constant-dollar benefit-cost analyses of proposed
investments and regulations should report net present value and other outcomes determined using
a real discount rate of 7%, because it approximates the marginal pretax rate of return on an
average investment in the private sector.
• Construction timeframe is the time required to construct and implement the alternative and does
not include the time required to design the remedy, negotiate performance of the remedy with
responsible parties, or procure contracts for design and construction.
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9.1 Alternative 1: No Further Action
• Capital Cost:
• O&M Cost:
$0
$0
$0
• Total Present Value:
• Estimated Construction Timeframe:
• Estimated Time to Achieve RAOs:
• ARARs Met:
none
not applicable; RAOs will not be met.
none
Regulations governing the Superfund program require consideration of a no action alternative as a
baseline to compare other alternatives. The no further action alternative means that no remedial action
would be undertaken, and that no institutional controls, containment, removal or other mitigating actions
would be implemented to control exposure to COCs. The engineering controls and institutional controls
implemented during the removal action would remain in place but would not be monitored or
maintained.
Institutional controls are legal restrictions that are typically used to prevent exposure to COCs or to
prevent activities that might interfere with the remedy at a site. Types of institutional controls that may
be considered include proprietary controls (e.g., covenants), governmental controls (e.g., zoning
restrictions), enforcement controls (e.g., administrative orders) and information devices (advisories).
Alternative 2 includes institutional controls to restrict land use and groundwater use. Land use
restrictions would limit future site uses, restrict access to PCB-contaminated soil, prohibit residential use
and/or require soil gas mitigation when soil disturbance occurs. They may also limit where buildings can
be built or require vapor mitigation measures if a building is built over an affected area.
Groundwater use restrictions would prohibit installation of groundwater wells to prevent contact with,
ingestion of or uncontrolled release of VOC-contaminated groundwater. In addition to institutional
controls to address remaining soil contamination, this alternative includes long-term monitoring
(inspections) and maintenance of the engineering controls implemented during the OlJ-2 removal action.
This includes the soil cover over the treated soil area, shown in Figure 3, as well as other caps/covers
that serve as barriers to soil contamination, shown in Figure 4.
MNA is a remedial strategy that relies on the use of natural processes already occurring in the
subsurface (including natural biodegradation) for contaminant reduction in groundwater. Alternative 2
would include groundwater monitoring for 30 years to confirm that natural attenuation is occurring, the
plume size is stable and contaminant concentrations are decreasing, with the goal of achieving the more
stringent of federal primary drinking water standards or NC 2L groundwater quality standards within a
reasonable timeframe. Sampling would be conducted annually for the first five years and biennially for
9.2 Alternative 2: Institutional Controls and MNA
• Capital Cost:
• O&M Cost:
$143,000
$160,251
$333,273
< 2 years
unknown
• Total Present Value:
• Estimated Construction Timeframe:
• Estimated Time to Achieve RAOs:
• ARARs Met:
This alternative meets action-specific ARARs but
may not comply with all chemical-specific ARARs;
more data would need to be collected to determine if all
chemical-specific ARARs can be met.
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years six through 30. For the cost estimate, samples would be collected from three existing monitoring
wells and two new monitoring wells.
MNA can only be selected when there are sufficient lines of evidence that demonstrate restoration can
be achieved in a reasonable timeframe. MNA sample results obtained during a December 2019 sampling
event indicated MNA may be a potentially viable remedy at the Site.
During SRI sampling events between 2014 to 2016, the groundwater conditions in well MW-03R
appeared to fluctuate between aerobic and anaerobic conditions. COC concentrations appeared to
decrease when groundwater conditions were aerobic (dissolved oxygen greater than 1 milligram per
liter), indicating that some aerobic biodegradation may be occurring during those times. Groundwater
monitoring conducted during December 2019 included analysis of the microbial populations and natural
attenuation parameters to evaluate whether site conditions are conducive to natural attenuation. The
December 2019 analysis for microbial populations indicated the most prevalent population was for the
anaerobic degradation of chlorinated benzenes. This analysis demonstrated that microbes were present
under anaerobic conditions that would degrade trichlorobenzenes, dichlorobenzenes and
chlorobenzenes. Although these results indicated that natural attenuation is occurring, it is likely
happening very slowly and is potentially inhibited by limited carbon supply, potentially by a high sulfate
concentration, and by high dissolved oxygen and oxidation-reduction potential (microbial analysis
suggests the anaerobic pathway is active at a low level).
To select MNA as a remedy, more data would need to be collected to confirm that there is a clear and
meaningful trend of decreasing concentrations over time.
9.3 Alternative 3: Institutional Controls and Enhanced Aerobic
Treatment
• Capital Cost: $306,475 to $572,650*
• O&M Cost: $164,308 to $213,752*
• Total Present Value: $517,390 to $864,256*
• Estimated Construction Timeframe: < 2 years
• Estimated Time to Achieve RAOs: 30' years
• ARARs Met: This alternative meets action-specific and chemical-
specific ARARs.
* Cost depends on the final enhanced aerobic treatment method selected; a range of costs is provided.
This alternative would include institutional controls and long-term monitoring and maintenance of
existing engineering controls, as described for Alternative 2. It would include enhanced aerobic
treatment to address groundwater contamination. Enhanced aerobic treatment would include the addition
of dissolved oxygen into the groundwater to enhance the rate of natural degradation of contaminants in
groundwater via enhanced microbial activity. The 2023 FFS Report evaluated three different proprietary
methods for delivering oxygen to the subsurface and generating an enhanced aerobic treatment zone:
in-situ Submerged Oxygen Curtain (iSOC®), Oxidant Candle* and Oxygen Socks*.
All three methods would require long-term implementation to be effective. This is due to the depth of
groundwater impact, the nature of groundwater flow through secondary porosity features and the very
slow rate of groundwater travel in OlJ-2. Long-term groundwater monitoring, similar to the monitoring
program for Alternative 2, would be conducted. A pre-design investigation would be needed to
determine the treatment area and radius of influence of individual oxygen delivery points. Selection of
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the specific enhanced aerobic treatment method will be determined during the remedial design phase of
the project.
Description of each enhanced aerobic treatment method considered is below.
• iSOC® (Alternative 3a): This is a patented gas infusion technology that achieves supersaturated
levels of dissolved gases in liquids. It features a structured polymer mass transfer device
containing a hydrophobic microporous hollow fiber that provides a large surface area (about
7,000 square feet of interface area per cubic feet of material) to increase mass transfer. An
internal control valve maintains proper gas pressure ensuring mass transfer without bubbles or
sparging. The technology would rely on the installation of wells across the width of the plume
and the connection of the iSOC®to an oxygen cylinder. Routine maintenance would include
cylinder replacement on a periodic basis.
• Oxidant Candle* (Alternative 3b): With this technology, a chemical oxidant such as sodium
persulfate or potassium permanganate is embedded in a slow-release wax formulation cylinder.
The cylinders can be placed in groundwater wells, a PRB or directly into boreholes. The oxidant/
paraffin mixtures are designed to allow the oxidant to gradually diffuse into the groundwater and
slowly oxidize COCs. The candles are slowly consumed and persist sufficiently to result in the
destruction of VOC COCs as a dilute plume that migrates through the treatment zone created by
these cylinders. For the cost estimate, it was assumed the candles would be replaced after 15 years.
• Oxygen Socks* (Alternative 3c): Oxygen socks® are a technology for the introduction of oxygen
release compound (ORC) and ORC Advanced. ORC and ORC Advanced filter socks are
designed to deliver controlled-release oxygen into a specific well or treatment area with the
purpose of creating a very limited and localized aerobic zone where accelerated biodegradation
can occur. After exhausting the oxygen supply (anywhere from nine to 12 months), the socks can
be removed, disposed of and replaced. Like the other enhanced biodegradation technologies, the
sock technology would rely on the installation of wells across the width of the plume. Socks
would be installed in each well and left in place. Routine maintenance would include sock
replacement on a periodic basis.
Implementation of this alternative will include the installation of injection and observation wells in areas
where PCBs have been left in place. An estimated 13 treatment wells would be installed for the
implementation of Alternative 3. PCB-containing waste may be generated during implementation of
these activities that will require characterization and disposal of PCB-containing waste pursuant to
applicable local, state and federal regulations.
9.4 Alternative 4: Institutional Controls and PRB with PlumeStop®
Liquid Activated Carbon™
This alternative would include institutional controls and maintenance/monitoring of existing engineering
controls as described for Alternative 2. It would provide for active groundwater treatment using
• Capital Cost:
• O&M Cost:
$1,105,000
$244,983
$1,483,632
< 2 years
20' years
This alternative meets action-specific and chemical-
specific ARARs.
• Total Present Value:
• Estimated Construction Timeframe:
• Estimated Time to Achieve RAOs:
• ARARs Met:
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PlumeStop® to clean up groundwater to the more stringent of federal primary drinking water standards
or North Carolina 2L groundwater quality standards within a reasonable timeframe.
PlumeStop* Liquid Activated Carbon™ (PlumeStop®) is a proprietary technology that involves injecting
an amendment into the aquifer, using a series of injection wells arranged in multiple PRBs that cover the
area of groundwater impact. PlumeStop® is a liquid activated carbon material that consists of a very fine
suspension of charged particles that resists clumping and has a water-like viscosity. Once injected, the
PlumeStop® binds to the aquifer matrix, and sorbs contaminants, immobilizing them and removing them
from groundwater. Biodegradation processes could then take place to destroy the sorbed contaminants.
For the cost estimate, installation of 76 injection wells and two monitoring wells was assumed. The cost
estimate also assumed a second round of injections would be needed after about 15 years.
Implementation of this technique would be difficult given the large number of permanent injection wells
that would be required and the potentially high injection pressures that would be needed. The installation
of the injection wells and potential difficulties getting the Liquid Activated Carbon™ into the formation
would also yield high costs. However, PlumeStop® was designed to be persistent in the aquifer and has
the potential to remediate the aquifer should back diffusion be of particular concern.
Implementation of this alternative will include the installation of injection and observation wells in areas
where PCBs have been left in place. PCB-containing waste may be generated during implementation of
these activities that will require characterization and disposal of PCB-containing waste pursuant to
applicable local, state and federal regulations.
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9.5 Common Elements and Distinguishing Features of Each Alternative
All alternatives, except for the No Further Action alternative, include institutional controls to restrict
land use and groundwater use. All alternatives also include long-term monitoring and maintenance of
the engineering controls in place (soil covers, or at the former Estes property, soil, crushed stone and/or
concrete paving covers) from the OlJ-2 removal action.
Under all alternatives, hazardous substances will remain at the Site above levels that allow for unlimited
use and unrestricted exposure and the EPA will continue to conduct a review of the Site every five years
(Superfund Five-Year Reviews) pursuant to CERCLA Section 121(c) and the NCP at 40 CFR
300.430(f)(4)(ii).
The primary distinguishing feature among the alternatives, except for Alternative 1 (No Further Action),
is that Alternative 2 relies on MNA to reduce COC concentrations in groundwater while Alternatives 3
and 4 include active treatment of groundwater contamination using various amendments or gases that
are injected or otherwise added to groundwater in situ. Additional distinguishing features of these
technologies are included in Sections 9.2 through 9.4.
9.6 Expected Outcomes of Each Alternative
All alternatives except for Alternative 1 ('No Further Action) will reduce human health and ecological
risks to acceptable levels for the anticipated future land uses at the Site. Reasonably anticipated future
land uses at OlJ-2 include industrial uses, highly restricted highway district uses (subject to NCDOT
limitations that will preclude residential/commercial use) and highly restricted airport district uses
(subject to limitations that will preclude residential/commercial use).
All alternatives, except for Alternative 1 (No Further Action) and possibly Alternative 2 (MNA), are
expected to restore groundwater to its beneficial use as a potential drinking water source by reducing
COC concentrations below federal MCLs and NC state standards. More data would need to be collected
to determine if Alternative 2 (MNA) could restore groundwater to the cleanup levels selected in this
ROD in a reasonable timeframe.
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives summarized in this ROD have been evaluated against the nine decision criteria
set forth in the NCP, 40 CFR 300.430(e)(9)(iii). These nine criteria are organized into three categories:
threshold criteria, primary balancing criteria and modifying criteria. Threshold criteria must be satisfied
in order for an alternative to be eligible for selection. Primary balancing criteria are used to weigh major
trade-offs among alternatives. Modifying criteria are taken into account after public comments have
been received.
The NCP criteria are:
Threshold Criteria
1) Overall Protection of Human Health and the Environment addresses whether or not an
alternative provides adequate protection of human health and the environment and describes how
risks posed through each exposure pathway are eliminated, reduced or controlled, through
treatment, engineering controls and/or institutional controls.
2) Compliance with ARARs considers whether or not an alternative will meet all federal or state
standards required by environmental laws or whether there is justification for waiving the
standards.
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Primary Balancing Criteria
3) Reduction of Toxicity. Mobility and Volume through Treatment indicates the EPA" s preference
for alternatives that include treatment processes to lower or eliminate the hazardous nature of
material, its ability to move in the environment, and the amount left after treatment.
4) Long-Term Effectiveness and Permanence considers the long-term effectiveness and
permanence of maintaining the protection of human health and the environment after
implementing each alternative.
5) Short-Term Effectiveness considers the effect of each remedial alternative on the protection of
human health and the environment during the construction and implementation phase.
6) Implementability considers the technical and administrative feasibility of implementing each
alternative and the availability of the services and materials required during implementation.
7) Cost considers construction costs as well as long-term O&M costs of each alternative by
considering whether costlier alternatives provide additional public health benefits for the
increased cost.
Modifying Criteria
8) State Acceptance considers whether the state agrees with, disagrees with, or has no comment on
the EPA's preferred alternative.
9) Community Acceptance considers the concerns or support the public may offer regarding each
alternative.
The EPA uses the nine criteria to evaluate the remedial alternatives individually and against each other
to select a remedy. This section of the ROD profiles the relative performance of each alternative against
the nine criteria, noting how it compares to the other options under consideration. Table 6 presents a
relative comparison of each of the alternatives. The 2023 FFS Report includes a detailed evaluation of
the remedial alternatives.
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Table 6: Relative Comparison of Alternatives 1, 2, 3 and 4
CERCLA Criteria
Alternative 1:
No Further Action
Alternative 2:
Institutional
Controls and MNA
Alternative 3:
Institutional
Controls and
Enhanced Aerobic
Treatment
Alternative 4:
Institutional Controls
and PRB with Plume
Stop*
Protection of human
health and the
environment
Q
•
•
•
Compliance with
ARARs
Q
O*
•
•
Long-term
effectiveness and
permanence
o
•
•
•
Reduction in toxicity,
mobility or volume
through treatment
o
o
•
•
Short-term
effectiveness
o
o
O
O
linpleinentability
•
•
•
O
Present-value cost
No cost
o
o
•
Ranking: • High ©Moderate OLow
Rankings arc provided as qualitative descriptions of the relative compliance of each alternative with the criteria.
* Based on the current data. Alternative 2 may not meet all ARARs, so this has been changed since the Proposed Plan.
10.1 Overall Protection of Human Health and the Environment
Alternative 1 (No Further Action) would not be protective of human health and the environment.
It would not achieve RAOs and all estimated risks to human health and the environment would continue.
Because Alternative 1 does not meet this threshold criterion, it will not be assessed further in the
comparative analysis.
Alternatives 2 through 4 would be protective of human health and the environment through
implementation of institutional controls to prevent exposures to contaminated groundwater and soil,
and long-term groundwater monitoring. Alternative 2 would rely on MNA to reduce contaminant
concentrations in groundwater. Alternatives 3 and 4 would use active treatment technologies to reduce
contaminant concentrations in groundwater and meet cleanup levels.
10.2 Compliance with ARARs
Section 121(d) of CERCLA and the NCP at 40 CFR 300.430(f)(l)(ii)(B) require that remedial actions at
CERCLA sites attain legally applicable or relevant and appropriate federal and more stringent state
environmental requirements, standards, criteria and limitations collectively referred to as "ARARs",
unless such ARARs are waived under CERCLA section 121(d)(4). See NCP definitions of "applicable
requirements" and "relevant and appropriate requirements" at 40 CFR 300.5.
Alternative 2 is expected to meet action-specific ARARs but may not comply with all chemical-specific
ARARs. More data would need to be collected to determine if all chemical-specific ARARs can be met
with the MNA alternative. At this time. Alternative 2 does not meet this threshold criterion, and
therefore, cannot be selected as a remedy.
Alternatives 3 and 4 are expected to meet the chemical-specific and action-specific ARARs identified in
the 2023 FFS Report, including EPA and North Carolina groundwater well construction standards.
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injection well criteria and monitoring well installation requirements as well as the cleanup levels for
groundwater based on MCLs or more stringent NC 2L groundwater quality standards.
10.3 Long-Term Effectiveness and Permanence
Alternatives 2 through 4 would provide long-term effectiveness and permanence using institutional
controls to manage access to contaminated soil and groundwater, and long-term groundwater monitoring
to confirm long-term effectiveness. Alternatives 3 and 4 would provide the greatest degree of long-term
effectiveness and permanence through in-situ treatment of groundwater to permanently reduce COC
concentrations in groundwater to meet groundwater cleanup levels.
These remedial alternatives and the OlJ-2 area are not vulnerable to impacts from climate change. The
contamination is in groundwater and in the deep subsurface. The remedial components associated with
the alternatives are not vulnerable to storms, floods, fires, droughts or other climate change impacts.
10.4 Reduction of Toxicity, Mobility and Volume
Alternative 2 would not reduce the toxicity, mobility or volume of contamination in groundwater
through treatment. Alternatives 3 and 4 provide active means for the reduction of the toxicity, mobility
or volume of groundwater contamination. Both include in situ measures to treat groundwater COCs.
The OlJ-2 removal action removed substantial amounts of PCB-contaminated source material some of
which was considered principal threat waste under EPA policy and guidance. The completed OlJ-2
removal action reduced the toxicity, mobility and volume of PCB-impacted soil and debris to the degree
practicable. Contamination remaining on site is a relatively low long-term threat (40 CFR
300.430(a)(l)(iii)(B)) and not considered principal threat waste. The institutional controls of
Alternatives 2, 3 and 4 will prevent disturbance of the PCBs left in place by requiring that the OlJ-2
removal action engineering controls are not bypassed or destroyed.
10.5 Short-Term Effectiveness
Alternatives 2 through 4 would have minimal short-term impacts on the community and workers during
implementation. Institutional controls could be completed within two years and would be effective
immediately once implemented. Construction activities for Alternatives 2 through 4 (i.e., monitoring
well and injection well installation) should be complete within one to two years, with Alternative 2
requiring the least amount of time to implement (only two new monitoring wells are planned with the
MNA alternative) followed by Alternative 3, which includes installation of two monitoring wells and
13 treatment wells. Alternative 4 would have the longest construction timeframe and disruption on site
since it would require up installation of up to 76 injection wells in addition to two monitoring wells.
The potential for short-term exposures to workers and the community will be addressed through proper
design and execution of the remedial design, including the use of well-established best management
practices and engineering controls.
10.6 IM PLEMENTABILITY
Alternative 2 is straightforward to implement, as most of the monitoring network for MNA is already in
place at the Site. Groundwater sampling and analysis to monitor contaminant concentrations in
groundwater is a proven monitoring technology. More data will need to be collected to determine if
MNA can reduce COCs in groundwater to cleanup levels in a reasonable timeframe.
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Two additional monitoring wells would be needed for groundwater monitoring for Alternatives 2, 3
and 4. An estimated 13 treatment wells would be installed for the implementation of Alternative 3.
For Alternative 4, an estimated 76 injection wells would need to be installed. The technologies in
Alternatives 3 and 4 are readily available, although the technologies are proprietary and would require
contracting with specific vendors.
It is possible that most of the property where the remedial alternatives would be implemented will be
within the FAA-required RPZ. Obtaining site access for implementation of Alternatives 3 and 4 may be
a hindrance because of the RDU expansion plans and accompanying FAA regulations. Obtaining
permission to install monitoring wells during the SRI was time-consuming and delayed work for
extended periods, which could also occur during remedy implementation. Alternatives 3 and 4, which
both involve adding oxygen or other additives into the subsurface to enhance degradation, may also be
limited by the heterogeneous nature of the subsurface and the efficiency of the additive delivery process.
Alternative 4 may be able to address back-diffusion in aquifers with variable permeability.
Alternative 4 is projected to provide the shortest timeframe to achieve groundwater cleanup levels.
Alternative 2, which includes MNA, is expected to take the longest to achieve groundwater cleanup
levels when compared to the active remedial approaches.
Services to prepare and implement the institutional controls for Alternatives 2, 3 and 4 are readily
available.
10.7 Cost
Table 7, included below and repeated in the Tables section of this ROD, summarizes costs for each
alternative, except for Alternative 1 ('No Further Action). These costs are estimates based on the best
available information and have an expected accuracy of +50% to -30%.
Table 7: Cost Summary, Alternatives 2 through 4
Cost Category
Alternative 2:
Institutional Controls
and MNA
Alternative 3:
Institutional Controls
and Enhanced Aerobic
T reatment
Alternative 4:
Institutional Controls
and PRB with
PlumeStop"
Capital Cost
$143,000
$306,475 to $572,650a
$1,105,000
O&M Cost
$160,251
$164,308 to $213,752a
$244,983
Total Present Value
$333,273
$517,390 to $864,256a
$1,483,632
Notes:
a) Cost depends on the final enhanced aerobic treatment method selected; a range of costs is provided.
Alternative 2 has the lowest net present value estimate. Alternative 4 has the highest net present value
cost.
The potential cost impact of RDU access restrictions has not been included in the cost estimates because
the details are not known at this time, although because of the construction equipment required for
Alternative 3 and Alternative 4, the cost impacts would likely be higher compared to Alternative 2.
The cost of long-term maintenance and monitoring of the existing engineering controls is also not
included in the cost estimates. It would be expected to be the same for Alternatives 2, 3 and 4.
10.8 State Acceptance
NCDEQ, as the support agency, reviewed all site-related documents and provided the EPA with
comments. NCDEQ reviewed the Proposed Plan and a draft version of this ROD. The state of
North Carolina concurs with the selected remedy.
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10.9 Community Acceptance
The EPA did not receive any public comments on the EPA's Proposed Plan during the virtual public
meeting held August 17, 2023, or during the 30-day public comment period from July 31, 2023 to
August 30, 2023.
11.0 PRINCIPAL THREAT WASTES
The NCP establishes an expectation that the EPA will use treatment to address the principal threats
posed by a site wherever practicable (40 CFR 300.430(a)(l)(iii)(A)). The "principal threat" concept is
applied to the characterization of source materials at a Superfund site. A source material is material that
includes or contains hazardous substances, pollutants or contaminants that act as a reservoir for
migration of contamination to groundwater, surface water or air, or acts as a source for direct exposure.
Contaminated groundwater generally is not considered to be a source material.
The OlJ-2 removal action removed substantial amounts of PCB-contaminated source material as
principal threat waste from the Site. All principal threat waste was removed, to the extent practicable.
There are relatively small, isolated areas where soil at depths generally greater than two (2) feet contain
PCB concentrations greater than the 10 mg/kg cleanup criterion, primarily in areas with excavation
refusal. However, the EPA considers this residual contamination a low-level threat and not principal
threat waste. Groundwater data from multiple post-removal sampling events show that groundwater is
not affected by PCB contamination.
12.0 SELECTED REMEDY
12.1 Summary of the Rationale for the Selected Remedy
Based on available information, the EPA has determined that Alternative 3, Institutional Controls and
Enhanced Aerobic Treatment, meets the threshold criteria and provides the best balance of tradeoffs
among the other alternatives with respect to the balancing and modifying criteria. The EPA expects the
selected remedy to satisfy the following statutory requirements of CERCLA § 121(b): 1) be protective of
human health and the environment; 2) comply with ARARs; 3) be cost effective; 4) utilize permanent
solutions and alternative treatment technologies or resource recovery technologies to the maximum
extent practicable; and 5) satisfy the preference for treatment as a principal element.
The EPA selected Alternative 3 over the other alternatives because it has the highest potential for
reducing toxicity, mobility and/or volume of contamination through in-situ treatment of VOC
contaminated groundwater. Alternative 1 does not meet either threshold criteria. Alternative 2 provides
much less treatment and there is significant uncertainty as to if and when the RAOs and ARARs would
be attained. Alternative 3 meets the threshold criteria and provides the best balance of tradeoffs among
the criteria with respect to the balancing and modifying criteria. Both Alternatives 3 and 4 satisfy the
statutory preference to use treatment as a principal element of the remedy and will take 20 years or more
to meet RAOs. However, Alternative 3 is more implementable than Alternative 4, requiring installation
of an estimated 13 treatment wells for Alternative 3 versus 76 injection wells for Alternative 4.
Alternative 3 is also lower in cost than Alternative 4.
12.2 Detailed Description of the Selected Remedy
The selected remedy. Alternative 3, consists of the following elements:
• Enhanced aerobic treatment of COCs in groundwater through the addition of oxygen in situ.
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• Long-term groundwater monitoring to verify attainment of cleanup levels.
• Implementation of institutional controls to restrict land and groundwater use as well as prevent
disturbance of residual PCB contamination and the soil cover areas.
• Long-term monitoring and maintenance of the engineering controls such as the geotextile/plastic
liners, crushed stone, concrete and soil covers implemented during the OlJ-2 removal action.
A pre-design investigation will be performed to identify the area requiring groundwater treatment and to
select the treatment method for adding oxygen to the subsurface. The estimated cost of the selected
remedy ranges from $517,390 to $864,256, depending on the treatment technology selected during
remedial design (iSOC®, Oxidant Candle® or Oxygen Socks®).
The OlJ-2 removal action included excavation of PCB-contaminated soil some of which, due to elevated
concentrations, was considered principal threat waste, and treatment and disposal of the material to the
extent practicable. While some soil contamination above removal action cleanup criteria will remain in
place indefinitely, it is not easily accessible at depth. The selected remedy includes periodic inspections
and long-term maintenance of the soil cover over the treated soil area (Figure 3) and other cover areas
that serve as barriers to residual PCB subsurface soil contamination. Long-term monitoring and
maintenance requirements will be determined during the remedial design.
The selected remedy also includes adding institutional controls for the properties where PCBs remain in
place above the removal action cleanup criteria selected in the 2004 Enforcement Action Memorandum,
as updated by the 2013 Supplemental Enforcement Action Memorandum. The institutional controls will
restrict contaminated soil disturbance or disturbance of engineering controls (soil cover and other
barriers) or remedial components (e.g., groundwater monitoring wells), minimize the potential for direct
contact with residual contaminated soil and ensure that residential use of the Site does not occur without
approval from NCDEQ and EPA.
A restrictive covenant is currently in place for the former Estes property. The EPA anticipates updating
this restrictive covenant to reflect Site conditions after the removal action. In addition, restrictive
covenants or other institutional controls will be implemented for all areas where PCBs remain in place
above the removal action cleanup criteria. Currently, the EPA anticipates restrictive covenants for five
additional properties, although the number and type of institutional controls for each affected area,
including the NCDOT ROW along Lutnley Road, will be determined during remedial design.
The selected remedy also includes groundwater use restrictions to prohibit installation of water wells at
the Site and to prevent contact with or ingestion of groundwater with contaminant concentrations above
cleanup levels. The institutional controls may also require soil gas mitigation when soil disturbance
occurs or may limit where buildings can be built. They may require vapor mitigation measures, if a
building is built over areas with VOC groundwater contamination. VOC impacts in groundwater are
localized to the vicinity of monitoring well MW-03R, which is near the former Ward Transformer
lagoon.
Zoning and land use restrictions in place for the Site, through local or FAA restrictions, will be an
additional layer of institutional controls for the Site.
12.3 Cost Estimate for the Selected Remedy
The total present worth of the selected remedy ranges from $517,390 to $864,256, depending on the
treatment technology selected during remedial design (iSOC®, Oxidant Candle® or Oxygen Socks®).
Estimated capital costs range from $306,475 to $572,650 and O&M costs range from $164,308 to
32
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
$213,752. Table 8 to Table 10 include the cost breakdown for the selected remedy, depending on the
treatment technology selected.
The information in this cost estimate and summary table is based on the best available information
regarding the anticipated scope of the remedial alternative. Changes in the cost elements are likely to
occur as a result of new information and data collected during the remedial design. Major changes may
be documented in the form of a memorandum in the Administrative Record file, an Explanation of
Significant Differences or a ROD Amendment. This is an order-of-magnitude engineering cost estimate
that is expected to be within +50% to -30% of the actual project cost.
12.4 Estimated Outcomes of Selected Remedy
12.4.1 Available Land and Groundwater Use
After completion of the selected remedy, OlJ-2 will be available for industrial use. Residential land use
will be prohibited. The Site will be available for the RDlJ-planned runway expansion into parts of OlJ-2.
The selected remedy is expected to restore groundwater to its beneficial use as a potential drinking water
source by reducing COC concentrations below federal MCLs and NC 2L groundwater quality standards.
12.4.2 Final Cleanup Levels
Table 5 lists the final cleanup levels for groundwater.
13.0 STATUTORY DETERMINATIONS
Under CERCLA §121 and the NCP, the EPA must select remedies that are protective of human health
and the environment, comply with ARARs (unless a statutory waiver is justified), are cost effective, and
utilize permanent solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. In addition, CERCLA includes a preference for remedies that employ
treatment that permanently and significantly reduces the volume, toxicity or mobility of hazardous
wastes as a principal element and a bias against off-site disposal of untreated wastes. The following
sections discuss how the selected remedy meets these statutory requirements.
13.1 Protection of Human Health and the Environment
The selected remedy. Alternative 3, will achieve protection of human health and the environment and
meet all RAOs. It will address unacceptable site-related human health risks primarily by using in-situ
treatment of groundwater exceeding the cleanup levels, which are based on EPA Safe Drinking Water
Act MCLs or more stringent NC groundwater quality standards, established in Title 15A of NCAC
Section 2L. Institutional controls will restrict the use of groundwater in order to prevent unacceptable
exposure until cleanup levels are achieved.
In a few areas where PCBs remain in place above removal action cleanup criteria, engineering controls
(soil covers) are in place to prevent exposures. Institutional controls will also be implemented to prevent
disturbance and ensure the long-term integrity of the covers and that the remedy is and remains fully
protective.
13.2 Compliance with ARARs
Section 121(d) of CERCL A and the NCP at 40 CFR 300.430(f)(l)(ii)(B) require that remedial actions at
CERCLA sites attain legally applicable or relevant and appropriate federal and more stringent state
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
environmental requirements, standards, criteria and limitations collectively referred to as "ARARs",
unless such ARARs are waived under CERCLA section 121(d)(4). See NCP definitions of "applicable
requirements" and "relevant and appropriate requirements" at 40 CFR 300.5.
Alternative 3 is expected to comply with the chemical-specific and action-specific ARARs identified in
the ROD's ARARs tables and a waiver of an ARAR is not necessary. The action-specific ARARs
include EPA and North Carolina groundwater well construction standards, injection well criteria and
monitoring well installation requirements as well as RCRA requirements for characterization of solid
and hazardous waste. The chemical-specific ARARs include the MCLs or more stringent NC 2L
groundwater quality standards that are the basis for the groundwater cleanup levels.
Chemical-specific AR ARs would eventually be met through the in-situ treatment of groundwater.
Action-specific ARARs will also be satisfied while conducting the remedial action. No location-specific
ARARs were identified for the selected remedial action. Table 11 and Table 12 present the chemical-
specific and action-specific ARARs and to-be-considered criteria for the Site, respectively.
13.3 Cost Effectiveness
The EPA has determined that the selected remedy is cost effective and represents a reasonable value for
the funds to be spent. In making this determination, the following definition was used: "A remedy shall
be cost-effective if its costs are proportional to its overall effectiveness" (NCP, CFR
300.430(f)(l)(ii)(D)). This was accomplished by evaluating the "overall effectiveness" of those
alternatives that satisfied the threshold criteria (i.e., were both protective of human health and the
environment and ARAR-com pliant). Overall effectiveness was evaluated by assessing three of the five
balancing criteria in combination (long-term effectiveness and permanence, reduction in toxicity,
mobility and volume through treatment, and short-term effectiveness). Overall effectiveness was then
compared to costs to determine cost effectiveness. The relationship of the overall effectiveness of the
selected remedy was determined to be proportional to its costs. Therefore, it represents a reasonable
value for the money to be spent.
The selected remedy is cost effective because it satisfies the criteria above and offers a permanent
solution through active treatment of groundwater contaminants. The selected remedy will create short-
term impacts in the community that are similar to the other alternatives, except for Alternative 1 (No
Further Action), which does not meet the threshold criteria. The estimated present worth cost of the
selected remedy ranges from $517,390 to $864,256, depending on the treatment technology selected
during remedial design, compared to $ 1,483,632 for the other active treatment alternative (Alternative
4).
13.3.1 Use of Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable
The EPA has determined that the selected remedy represents the maximum extent to which permanent
solutions can be utilized in a practical manner at the Site. In-situ treatment of groundwater will
permanently reduce COCs in groundwater and eventually achieve RAOs and thereby permanently
prevent an unacceptable risk to human health through exposure to groundwater.
13.3.2 Preference for Treatment as a Principal Element
The selected remedy satisfies the statutory preference to use treatment as a principal element of the
remedy. The selected remedy includes injecting reagents (oxygen) directly into the groundwater to treat
contaminants, thus reducing the toxicity, mobility and volume of contaminants.
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Ward Transformer Superfund Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
13.4 Five-Year Review Requirements
Because the selected remedy will result in hazardous substances, pollutants or contaminants remaining
on site above levels that allow for unlimited use and unrestricted exposure, statutory reviews pursuant to
CERCLA section 121(c) will be conducted every five years after remedial action initiation. Five-year
reviews will ensure that the selected remedies are, or will be, protective of human health and the
environment.
14.0 DOCUMENTATION OF SIGNIFICANT CHANGES FROM PREFERRED
ALTERNATIVE OF PROPOSED PLAN
Pursuant to CERCLA Section 1 17(b) and NCP § 300.430(f)(3)(ii), the ROD must document any
significant changes made to the preferred alternative discussed in the Proposed Plan.
The EPA held a virtual public meeting on August 17, 2023, to present the Proposed Plan to the
community. The EPA also held a 30-day public comment period to accept comments on the Proposed
Plan. The EPA received no written or oral comments during the public comment period or at the public
meeting. Based on this review, there are no significant changes from the preferred alternative discussed
in the Proposed Plan.
15.0 REFERENCES
EPA. July 2023. Region 4. Proposed Plan for Record of Decision, Ward Transformer Superfund Site,
Operable Unit 1, Raleigh, Wake County, North Carolina.
EPA. February 2021. Region 4, Ward Transformer Site Strategy: Version 1.0.
EPA. August 2020. Community Involvement Plan, Ward Transformer Superfund Site, Operable Unit 1,
Raleigh, Wake County, North Carolina.
EPA. January 2013. Supplemental Enforcement Action Memorandum. Change in Removal Activities.
Ward Transformer Superfund Site, Raleigh, Wake County, North Carolina.
EPA. September 2008. Record of Decision, Ward Transformer Superfund Site, Operable Unit 1,
Raleigh, Wake County, North Carolina.
EPA. September 2004. Enforcement Action Memorandum. Request for a Removal Action at the Ward
Transformer Site in Raleigh, North Carolina.
Colder Associates. March 2018. Final Remedial Investigation Report, Revision 1, Ward Transformer
Superfund Site, Operable Unit 2, Supplemental Remedial Investigation/Focused Feasibility Study.
Colder Associates. July 2015. Removal Action Completion Report, Ward Transformer Superfund Site,
Phase 2, Raleigh, North Carolina.
Colder Associates. June 2012. Removal Action Completion Report, Ward Transformer Superfund Site,
Phase 1, Raleigh, North Carolina.
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
WSP Colder. February 2023. Focused Feasibility Study, Revision 1, Ward Transformer Superfund Site
Operable Unit 2, Supplemental Remedial Investigation/Focused Feasibility Study.
PART 3: RESPONSIVENESS SUMMARY
The EPA released the Proposed Plan for public comment on July 31, 2023, by posting a publicly-
accessible link on the EPA's site profile page at http://www.epa.gov/superfund/ward-transformer.
From July 31, 2023, to August 30, 2023, the EPA held a 30-day public comment period to accept public
comments on the remedial alternatives and the EPA's preferred alternative, as presented in the Proposed
Plan. On August 17, 2023, the EPA held a virtual public meeting to present the Proposed Plan and
answer questions from meeting attendees.
The EPA did not receive any comments during the public meeting or during the 30-day comment period.
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
TABLES
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Ward Transformer Superfund Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Table 1: Engineering Controls in Place
Property
Location of PCBs Left-in-Place
Engineering Controls
Comments
Estes
Facility dock
Presence of building with concrete floor
A deed restriction in the form of a restrictive covenant has
been imposed on the Estes property to prevent disturbance of
restricted areas known to be impacted with PCBs.
Maintenance building
Presence of building with concrete floor
Old pipe beneath property
The ends of the section of old pipe that .vas
inaccessible was plugged with concrete to
eliminate risk of uncontrolled runoff of PCBs that
may remain in the pipe. The replacement pipe
was installed in clean sol' at a different alignment
Track apron/roao.'parking
Areas covered «rth a geotextile marker layer and
at least 2 ft of backfill jvith a vegetated, stone or
concrete surface.
NCDOTROW
Mi Herman Rtf
Areas covered >vith a geotextile marker layer and
approximately 14 to f 7 ft of backfill witn a
vegetated or stone surface.
North of Lumley Rd
Areas covered with a geotextile marker layer and
at least 2 ft of backfill with a stone surface.
South of Lumley Rd
Areas covered with a geotextile marker layer and
at least 2 ft of backfill with a stone surface.
S 0-foot wall section along [-540 fenceline
(adjacent to VVT TOW property)
Wall covered with plastic sheeting as a marker
layer. Excavation area was backfilled and
vegetated.
PCB concentration of i 6 ppm remaining in place from a grab
sample taken af t.5 feet below the ground surface from the
side wall of the 10-foot long 3-foot deep excavation
ROU
West of Ward Transformer property
Areas covered with a geotextile marker layer and
approximately 6 to 1 i ft of backfill with a vegetated
or stone surface.
Ward Trarssformer
Former transformer yard and storm water
lagoon
Areas covered with a geotextile marker layer and
approximately 1 Ho 3 1 ft of backfill with a
vegetated or stone surface
Treated soil was used as backfilled within the approximate
footprint of Ward facility's original surface water
management system {including the former transformer yard
and storm water lagoon). The treated soil area was covered
with a geotextile marker layer and a minimum of one foot of
clean soil covered with vegetation or crushed stone. The
property is also fenced along Mt Herman Road.
Ward Venture=
Along Reach A *est of RDU property
Areas covered with a geotextile marker layer and
at least 4 ft of backfill with a stone surface.
Source: Table 4-1. SRI Report. 2018.
38
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Table 2: Groundwater EPCs
coc
EPC"
(MW-03R)
(mu/l)
EPA MCL
NC 2L Standard
(fifl/L)
Benzene
6.5
5
1
Chlorobcnzcnc
53
100
50
1,4-Dichlorobenzene
54
75
6
1.2.4-T richlorobcnzcnc
370
70
70
Notes:
a) Represent concentrations from the most recent sampling event in February 2016.
Source: Table 6-6. SRI Report. 2018.
Table 3: Deep Soil EP
Cs
COC
EPCs
(m«/kg)
CTE - Mean
RME - 95% UCL
Aroclor 1260
115.611
194.199
Notes:
CTE = central tendency estimate
95% UCL = 95% upper confidence limit on the mean
Source: Table 6-5. SRI Report. 2018.
Table 4: OU-2 Risks
Receptor
Media/Pathway
COC
Cancer Risk"
Noncancer
Hazard Index"
Future Adult
Construction/Excavation/Maintenance
Worker
Soil - ingestion,
inhalation, dermal
contact
PCBs
2.3 x 10"5
b
Future Adult Resident
Groundwater -
ingestion/derinal
contact
VOCs
4.5 x 10 4
92
Future Child Resident
Groundwater -
vapor intrusion
VOCs
C
94
Future Adult/Child Resident
Groundwater -
vapor intrusion
VOCs
1.5 x 10"5
5.7
Current/future Occupational Worker
Groundwater -
vapor intrusion
VOCs
2.9 x 10"6
1.3
Notes:
a) Based on RME assumptions.
b) Not calculated; noncancer toxicity data for soil COC Aroclor 1260 have not been established.
c) Cancer risk not calculated separately for child resident.
Bold result indicates cancer risk exceeds the EPA's generally acceptable risk range or the noncancer hazard index
exceeds 1.
Source: Section 6.0, Supplemental Baseline Risk Assessment. SRI Report. 2018.
39
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Table 5: Groundwater Cleanup Levels
coc
EPA MCL"
NC 2L Standard1*
Groundwater Cleanup
Level
(MK/L)
(m«/l)
Benzene
5
1
1
Chlorobcn/cne
100
50
50
1,4-Dichlorobenzene
75
6
6
1.2.4-T richlorobcnzene
70
70
70
Notes:
a) MCLs available at https://www.epa.eov/ground-water-and-drinking-water/national-primarv-drinking-water-
regulations.
b) NC 2L standards available at httDs://www.dea.ne.gov/about/divisions/water-resources/water-
Dlanning/classification-standards/groundwater-standards.
Table 6: Relative (
Comparison of Alternatives 1, 2, 3 and 4
Alternative 3:
Alternative 4:
Institutional Controls
Alternative 1:
Alternative 2:
Institutional
Controls and MNA
Institutional
Controls and
Enhaneed Aerobic
CERCLA Criteria
No Further Aetion
and PRB with Plume
Stof)"
Treatment
Protection of human
health and the
Q
•
•
•
environment
Compliance with
ARARs
o
O*
•
•
Long-term
effectiveness and
o
•
•
•
permanence
Reduction in toxicity,
mobility or volume
o
o
•
•
through treatment
Short-term
effectiveness
o
o
O
O
linpleinentability
•
•
•
o
Present-value cost
No cost
o
o
•
Ranking: • High ©Moderate OLow
Rankings arc provided as qualitative descriptions of the relative compliance of each alternative with the criteria.
* Based on the current data. Alternative 2 may not meet all ARARs, so this has been changed since the Proposed
Plan.
Table 7: Cost Summary, Alternatives 2 through 4
Cost Category
Alternative 2:
Institutional Controls
and MNA
Alternative 3:
Institutional Controls
and Enhaneed Aerobic
Treatment
Alternative 4:
Institutional Controls
and PRB with
PlumeStop"
Capital Cost
$143,000
$306,475 to $572,650a
$1,105,000
O&M Cost
$160,251
$164,308 to $213,752a
$244,983
Total Present Value
$333,273
$517,390 to $864,256a
$1,483,632
Notes:
a) Cost depends on the final enhanced aerobic treatment method selected; a range of costs arc provided.
40
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Ward Transformer Superfund Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Table 8: Cost Estimate Breakdown for Alternative 3a - Institutional Controls and
Enhanced Aerobic Treatment - iSOC® / Waterloo Emitter™
ITEM
mer Superfund Site - OU2 - fi
QUANTITY UNITS
aleigh, NC
ESTIMATED
UNIT
COST
ESTIMATED
CAPITAL
COSTS
ESTIMATED
MONITORING
COSTS
PRESENT
WORTH
Capital Costs
Monitoring Wei Installation
1C Development and Implementation
Oversight
RA Report
1
2
13
13
1
1
1
LS
EA
EA
EA
LS
LS
LS
$20,000
57.500
57,500
$5,500=
550.000
525,000
525 000
520,000
515,000
587.500
$71,500
$50,0D0
$25,000
525,000
Subtotal
$304,000
$384,000
Engineering and General Contingency
Enginwing (10% of Capital}
Contingency (20% of Capita))
530,400
560,800
Subtotal
$91,200
$91,200
Estimated Total Capital Cost
S395JOO
Operation S Maintenance Costs (first 5 vearsl
Groundwater Monitoring
Analytical-VOCs
Analytical - MNA
Collection (lata and expenses!
OTanl Swap Out
Repcrtng
5
2
1
4
1
EA
EA
LS
LS
LS
51 CO
$750
IS.DOO
$1,500
v: coo
5500
$1,500
55,000
56,000
f 10,000
Subtotal (Annual)
$23,000
5100.906
Operation & Maintenance Costs. (Year 1 - 301
Analytical - VOCs'
OTar* Swop Out
Codecton (later and expenses)
Reporting
4
1
1
EA
LS
LS
LS
5100
$1,500=
55,000
$10,000
5500
56.000
55.D00
510 000
Subtotal {Biennial)
$21,510
$100,264
Decommissioning (Year 30)
1
LS
527.500
527.500
i
$3,«5
Estimated Total Operation and Maintenance Cost
$205,036
ESTIMATED TOTAL -ICs and Enhanced Aerobic Treatment- Waterloo Emittw™
5600.236
Inflation Adjustment (March 2821 - August 2022}
ADJUSTED ESTIMATED TOTAL - Its and IMA
9 sm
$659,859
41
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Ward Transformer Superfund Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Table 9: Cost Estimate Breakdown for Alternative 3b - Institutional Controls and
Enhanced Aerobic Treatment - Oxidant Candle®
Ward Transfoi
ITEM
~mer Superfund
QUANTITY
site - OU2 - f
urns
taietgh, NC
ESTIMATED
UMfT
COST
ESTIMATED
CAPITAL
COSTS
ESTIMATED
MONITORfNG
COSTS
PRESENT
WORTH
Capital Costs
MoMizalion
Monitoring Well Instillation
Injection Well Installation (Midi)
System mctaMion
IC Development and Implementation
Owsnagm
RA Report
1
2
13
13
1
1
1
LS
EA
EA
EA
LS
LS
LS
$22, COO
$7,500
$'1.C00
y:,50o
%5Z jOO
$25. COO
$25.COO
$20,000
$15,000
$143,000
$162,500
SSCI^OOO
$25,000
$25,000
Subtotal
$440,500
$440,500
Engineering and General Contingency
Engineering (10% of Capitol)
Caiiwprtcy {20%' of Capital)
S44 Z50
$?? 100
Subtotal
$132,150
$132,150
Estimated Total Capital C rat
$571,651
Ctaeratioii 8. HMntawc. CosC HM 5
Analytical - VOCs*
Analytical - M Hk
C&ection (labor and expenses)
Reporting
5
2
1
1
EA
E4
L3
Lxj
stoo
S750
$5.:ao
$'C.:oo
5500
5! .500
ss.:oo
$i:.:oo
Subtotal (Annual)
$17,000
$74,583
Operation & Maintenance Costs (Year 6 - 30}
Groundwater Monitoring
Analytical - VOCs
QJeefoft (labor m4 expenses)
Repotting
S
1
1
EA
LS
LS
SI CO
ss.coo
$-:.coo
§50€l
$5,000
$10,000
Subtotal {Biennial)
$15,500
$72,284
Candle Replacement (Year 15)
13
EA
$12,500
f162,S}0
$162,500
$€3,020
Decommissioning (Year 30)
1
LS
$27,500
$27,500
$27,500
$3,866
Estimated Total Operation and Maintenance Cost
$213,752
ESTIMATED TOTAL - ICs aid Enhanced Aerobic Treatment - Oxidant Candte*
$786,402
Inflation Adjustment {March 2021 - August 2022S
ADJUSTED ESTIMATED TOTAL - ICs and MNA
9.90%
$864,256
42
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Ward Transformer Superfund Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Table 10: Cost Estimate Breakdown for Alternative 3c - Institutional Controls and
Enhanced Aerobic Treatment - Regenesis Oxygen Socks®
Ward Transfer
Hi -V
roer Superfund 5
QUANTITY
lite - ULM i
UMTS
MC
ESTIMATED
UNIT
COST
ESTIMATED
CAPITAL
COSTS
ESTIMATED
MONITORING
COSTS
PRESENT
WORTH
Capital C< osts
Mobilization
Mattering Well totatlaioti
InijeeSori Well Instalr. :r O-inch)
Sptem Insialafon
IC Development and topleiT«ntalicin
Gveraight
RA Report
Subtotal
1
2
13
13
1
1
1
LS
EA
EA
EA
LS
LS
LS
520,000
$7,500
$7,500
I2S0
150.000
$25,000
$25,000
520 000
515.000
S&7 500
$3,250
550.000
525,000
$25,000
$236,750
$235,7£>0
Engineering an
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Table 11: Chemical-Specific ARARs and TBCs for Ward Transformer Superfund Site - OIJ-2 Record of Decision
CHEMICAL-SPECIFIC ARARs
Action/Media
Requirements
Prerequisite
Citation(s)
Bulk PCB remediation
waste left in place (self-
implementing option)
Bulk Polychlorinated Biphenyl (PCB) remediation waste in low
occupancy areas must be cleaned up to < 25 ppm, unless
otherwise specified.
Bulk PCB remediation waste remaining in a
low occupancy area (as defined in 40 C.F.R.
§ 761.3) at concentrations < 25 — Relevant
and Appropriate
40 C.F.R. § 761.61(a)(4)(i)(B)(l)
May remain on-site if the site is secured by a fence and
marked with a sign including the ML mark.
Bulk PCB remediation waste remaining in a
low occupancy area (as defined in 40 C.F.R.
§ 761.3) at concentrations > 25 ppm and <
50 ppm —¦ Relevant and Appropriate
40 C.F.R. § 761.61(a)(4)(i)(B)(2)3
Classification of
contaminated
groundwater
Groundwaters in the state naturally containing 250 mg/L or
less of chloride are classified as GA under 15A NCAC 02L
.0201(1)
Best usage: Existing or potential source of drinking water
supply for humans.
Groundwaters located within the
boundaries or under the extraterritorial
jurisdiction of the State of North Carolina -
Applicable
15A NCAC 02L .0201(1)
Groundwater Classifications
Groundwaters in the state naturally containing greater than
250 mg/L of chloride are classified as GSA under 15A NCAC
02L .0201(2)
15A NCAC 02L .0201(2)
Best usage: Existing or potential source of water supply for
potable mineral water and conversion to fresh waters.
Restoration of
Groundwater
Shall not exceed the groundwater quality standards4 for
contaminants specified as the site related contaminants of
concern.
• Benzene (1 ng/L)
• Chlorobenzene (50 ng/L)
• 1,4-Dichlorobenzene (6 ng/L)
• 1,2,4-Trichlorobenzene (70 ng/L)
Class GA or GSA groundwaters with
contaminant(s) concentrations exceeding
standards listed in 15A NCAC 02L .0202 -
Relevant and Appropriate
15A NCAC 02L .0202(a) and (b)
Groundwater Quality Standards
3 Bulk PCB remediation wastes may remain at a cleanup site at concentrations > 25 ppm and < 100 ppm if the site is covered with a cap meeting the requirements of paragraphs (a)(7) and
(a)(8) of 40 C.F.R. §761.61.
4 Unless otherwise indicated, the standard refers to the total concentration in micrograms per liter of any constituent in a dissolved, colloidal or particulate form which is mobile in
groundwater. This does not apply to sediment or other particulate matter which is preserved in a groundwater sample as a result of well construction or sampling procedures.
44
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Table 12: Action-Specific ARARs and TBCs for Ward Transformer Superfund Site - OU-2 Record of Decision
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
General construction standards - All land-disturbing activities (i.e., excavation for well installation, trenching, grading etc.)
Managing storm water
runoff from land-disturbing
activities
Shall install erosion and sedimentation control devices and
practices sufficient to retain the sediment generated by the
land-disturbing activity within the boundaries of the tract
during construction.
Land-disturbing activity (as defined in N.C.G.S.
Ch. 113A-53) of more than 1 acre of land -
Applicable
N.C.G.S. Ch.ll3A-57(3)
Mandatory standards for land-
disturbing activity
Shall plant or otherwise provide permanent ground cover
sufficient to restrain erosion after completion of construction.
N.C.G.S. Ch.ll3A-57(3)
The land-disturbing activity shall be conducted in accordance
with the approved erosion and sedimentation control plan.
NOTE: Plan which meets the objectives of ISA NCAC 4B .0106
would be included in the CERCLA Remedial Design or
Remedial Action Work Plan
N.C.G.S. Ch.ll3A-57(5)
Shall follow the measures specified in the Chapter and Act to
protect all public and private property from sedimentation and
erosion damage caused by land-disturbing activities.
Land-disturbing activity (as defined in N.C.G.S.
Ch. 113A-52) of more than 1 acre of land -
Applicable
15ANCAC4B .0105
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Managing storm water
runoff from land-
disturbing activities con't
Erosion and sedimentation control plan must address the
following:
(1) Identify areas subject to accelerated erosion, and
off-site areas vulnerable to damage from erosion and
sedimentation.
15ANCAC4B .0106
(2)
Limit the size of the area exposed at any one time.
(3)
Limit exposure to the shortest time specified in the
Rules or as directed by approving authority.
(4)
Control surface water originating upgrade of
exposed areas
(5)
Plan and conduct land-disturbing activity to prevent
off-site sedimentation damage.
(6)
Include measures to ensure any increase in velocity
of stormwater runoff will not result in accelerated
erosion of the conveyance, at the point of discharge,
and within project boundary.
Erosion and sedimentation control measures, structures, and
devices shall be planned, designed, and constructed to provide
protection from the run-off of 10-year storm.
Land-disturbing activity (as defined in N.C.G.S.
Ch. 113A-52) of more than 1 acre of land -
Applicable
15ANCAC4B .0108
Shall provide a design for the land-disturbing activity so that
the post-construction velocity of the 10-year storm runoff in
the receiving stormwater conveyance to, and including, the
discharge point does not exceed the parameters provided in
this Rule.
15ANCAC4B .0109
Shall install and maintain all temporary and permanent erosion
and sedimentation control measures.
15ANCAC4B .0113
Control of fugitive dust
emissions
The owner/operator of a facility shall not cause fugitive dust
emissions to cause or contribute to the substantive complaints
or visible emissions.
Activities potentially generating fugitive dust as
defined in 15A NCAC 02D .0540 (a)(2) - Relevant
and Appropriate
15A NCAC 02D .0540
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Waste characterization - primary wastes (contaminated media such as soil from well cuttings)
and secondary wastes (wastewaters, contaminated equipment, etc.)
Characterization of solid
waste (all primary and
secondary wastes) and
Listed hazardous waste
determination
Must make an accurate determination as to whether that
waste is a hazardous waste in order to ensure wastes are
properly managed according to applicable RCRA regulations. A
hazardous waste determination is made using the following
steps:
• The hazardous waste determination for each solid waste
must be made at the point of waste generation, before any
dilution, mixing, or other alteration of the waste occurs,
and at any time in the course of its management that it
has, or may have, changed its properties as a result of
exposure to the environment or other factors that may
change the properties of the waste such that the RCRA
classification of the waste may change.
• Must determine whether the waste is excluded from
regulation under 40 C.F.R. 261.4; and
• Must use the knowledge of the waste to determine
whether waste meets any of the listing descriptions under
subpart D of 40 C.F.R. Part 261. Acceptable knowledge that
may be used in making an accurate determination as to
whether the waste is listed may include waste origin,
composition, the process producing the waste, feedstock,
and other reliable and relevant information.
Generation of solid waste as defined in 40 C.F.R.
§ 261.2 - Applicable
40 C.F.R. § 262.11(a), (b) and (c)
15A NCAC 13A .0107(a)
Determination of
characteristic hazardous
waste
The person then must also determine whether the waste
exhibits one or more hazardous characteristics as identified in
subpart C of 40 C.F.R. part 261 by following the procedures in
paragraph (d)(1) or (2) of this section, or a combination of
both.
Generation of solid waste which is not excluded
under40 C.F.R. § 261.4(a)-Applicable
40 C.F.R. §262.11(d)
15A NCAC 13A .0107
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September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Determination of
characteristic hazardous
waste through knowledge
The person must apply knowledge of the hazard characteristic
of the waste in light of the materials or the processes used to
generate the waste. Acceptable knowledge may include
process knowledge (e.g., information about chemical
feedstocks and other inputs to the production process);
knowledge of products, by-products, and intermediates
produced by the manufacturing process; chemical or physical
characterization of wastes; information on the chemical and
physical properties of the chemicals used or produced by the
process or otherwise contained in the waste; testing that
illustrates the properties of the waste; or other reliable and
relevant information about the properties of the waste or its
constituents.
A test other than a test method set forth in subpart C of 40
C.F.R. part 261, or an equivalent test method approved by the
Administrator under 40 C.F.R. 260.21, may be used as part of a
person's knowledge to determine whether a solid waste
exhibits a characteristic of hazardous waste. However, such
tests do not, by themselves, provide definitive results. Persons
testing their waste must obtain a representative sample of the
waste for the testing, as defined at 40 C.F.R. 260.10.
40 C.F.R. §262.11(d)(1)
15A NCAC 13A .0107
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Determination of
characteristic hazardous
waste through testing
When available knowledge is inadequate to make an accurate
determination, the person must test the waste according to
the applicable methods set forth in subpart C of 40 C.F.R. part
261 or according to an equivalent method approved by the
Administrator under 40 C.F.R. 260.21 or and in accordance
with the following:
(i) Persons testing their waste must obtain a
representative sample of the waste for the testing, as
defined at 40 C.F.R. 260.10.
(ii) Where a test method is specified in subpart C of 40
C.F.R. part 261, the results of the regulatory test, when
properly performed, are definitive for determining the
regulatory status of the waste.
Generation of solid waste which is not excluded
under 40 C.F.R. § 261.4(a) - Applicable
40 C.F.R. §262.11(d)(2)
15A NCAC 13A .0107
Must refer to Parts 261, 262, 264, 265, 266, 268, and 273 of
Chapter 40 for possible exclusions or restrictions pertaining to
management of the specific waste.
Generation of solid waste which is determined to
be hazardous - Applicable
40 C.F.R. §262.11(e)
15A NCAC 13A .0107
Identifying hazardous
waste numbers for small
and large quantity
generators
Must identify all applicable EPA hazardous waste numbers
(EPA hazardous waste codes) in subparts C and D of part 261
of this chapter. Prior to shipping the waste off site, the
generator also must mark its containers with all applicable EPA
hazardous waste numbers (EPA hazardous waste codes)
according to § 262.32.
40 C.F.R. §262.11(g)
15A NCAC 13A .0107
General Waste Analysis
Must obtain a detailed chemical and physical analysis on a
representative sample of the waste(s), which at a minimum
contains all the information that must be known to treat,
store, or dispose of the waste in accordance with pertinent
sections of 40 C.F.R. 264 and 268.
Generation of RCRA hazardous waste or
nonhazardous wastes if applicable under
§ 264.113(d) for storage, treatment or disposal -
Applicable
40 C.F.R. §264.13(a)(1)
15A NCAC 13A .0109(c)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Special rules for
characteristic hazardous
waste
Must determine each EPA Hazardous Waste Number (waste
code) applicable to the waste in order to determine the
applicable treatment standards under subpart D of this part.
This determination may be made concurrently with the
hazardous waste determination required in § 262.11 of this
chapter. For purposes of part 268, the waste will carry the
waste code for any applicable listed waste (40 C.F.R. part 261,
subpart D). In addition, where the waste exhibits a
characteristic, the waste will carry one or more of the
characteristic waste codes (40 C.F.R. part 261, subpart C),
except when the treatment standard for the listed waste
operates in lieu of the treatment standard for the
characteristic waste, as specified in paragraph (b) of this
section.
Generation of characteristic hazardous waste for
storage, treatment or disposal - Applicable
40 C.F.R. § 268.9(a)
15A NCAC 13A .0112(a)
Must determine the underlying hazardous constituents [as
defined in 40 C.F.R. 268.2(i)] in the characteristic waste.
Generation of RCRA characteristic hazardous
waste (and is not D001 non-wastewaters treated
by CMBST, RORGS, or POLYM of § 268.42 Table 1)
for storage, treatment or disposal - Applicable
40 C.F.R. § 268.9(a)
15A NCAC 13A .0112(a)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Determinations for land
disposal of hazardous
waste
Must determine if the waste has to be treated before it can be
land disposed. This is done by determining if the hazardous
waste meets the treatment standards in §268.40, 268.45, or
§268.49. This determination can be made concurrently with
the hazardous waste determination required in §262.11 of this
chapter, in either of two ways: testing the waste or using
knowledge of the waste. If the generator tests the waste,
testing would normally determine the total concentration of
hazardous constituents, or the concentration of hazardous
constituents in an extract of the waste obtained using test
method 1311 in "Test Methods of Evaluating Solid Waste,
Physical/Chemical Methods," EPA Publication SW-846,
(incorporated by reference, see §260.11 of this chapter),
depending on whether the treatment standard for the waste is
expressed as a total concentration or concentration of
hazardous constituent in the waste's extract. (Alternatively,
the generator must send the waste to a RCRA-permitted
hazardous waste treatment facility, where the waste
treatment facility must comply with the requirements of
§264.13 of this chapter and paragraph (b) of this section.)
Generation of hazardous waste for storage,
treatment or disposal - Applicable
40 C.F.R. § 268.7(a)
15A NCAC 13A .0112(a)
Must comply with the special requirements of 40 C.F.R. § 268.9
in addition to any applicable requirements in 40 C.F.R. § 268.7.
Generation of waste or soil that displays a
hazardous characteristic of ignitability,
corrosivity, reactivity, or toxicity for storage,
treatment or disposal - Applicable
40 C.F.R. § 268.7(a)(1)
15A NCAC 13A .0112(a)
Characterization of
industrial wastewater
Industrial wastewater discharges that are point source
discharges subject to regulation under section 402 of the CWA,
as amended, are not solid wastes for the purpose of hazardous
waste management.
[Comment: This exclusion applies only to the actual point
source discharge. It does not exclude industrial wastewaters
while they are being collected, stored or treated before
discharge, nor does it exclude sludges that are generated by
industrial wastewater treatment.]
Generation of industrial wastewater and
discharge into surface water-Applicable
40 C.F.R. § 261.4(a)(2)
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Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Management of PCB
waste (e.g., contaminated
PPE, equipment,
wastewater)
Any person cleaning up and disposing of PCBs shall do so based
on the concentration at which the PCBs are found.
Generation of PCB remediation waste as defined
in 40 C.F.R. § 761.3-Applicable
40 C.F.R. §761.61
Waste Storage - primary wastes (contaminated media such as soil from well cuttings)
and secondary wastes (wastewaters, contaminated equipment, etc.)
Storage of solid waste
All solid waste shall be stored using safe and sanitary practices
for the preservation of the public health and welfare and the
environment that prevents the generation of leachate, the
attraction of vectors, the release of odors, and the release of
waste or leachate to the environment.
Generation of solid waste which is determined
not to be hazardous - Relevant and Appropriate
15A NCAC 13B .0104(d)
Temporary on-site
accumulation of
hazardous waste in
containers
A small quantity generator may accumulate hazardous waste
on site without a permit or interim status, and without
complying with the requirements of parts 124, 264 through
267, and 270 of this chapter, or the notification requirements
of section 3010 of RCRA, provided that all the substantive
conditions for exemption listed in this section are met.
Accumulation of RCRA hazardous waste on site
as defined in 40 C.F.R. § 260.10-Applicable
40 C.F.R. §262.16(a)
Condition of containers
If a container holding hazardous waste is not in good
condition, or if it begins to leak, the small quantity generator
must immediately transfer the hazardous waste from this
container to a container that is in good condition, or
immediately manage the waste in some other way that
complies with the conditions for exemption of this section.
40 C.F.R. §262.16(b)(2)(i)
Compatibility of waste
with container
Must use a container made of or lined with materials that will
not react with, and are otherwise compatible with, the
hazardous waste to be accumulated, so that the ability of the
container to contain the waste is not impaired.
Accumulation of 55 gal. or less of RCRA
hazardous waste or one quart of acutely
hazardous waste listed in §261.33(e) at or near
any point of generation - Applicable
40 C.F.R. §262.16(b)(2)(ii)
Management of
containers
(A) A container holding hazardous waste must always be
closed during accumulation, except when it is necessary to add
or remove waste.
(B) A container holding hazardous waste must not be opened,
handled, or accumulated in a manner that may rupture the
container or cause it to leak.
40 C.F.R. §262.16(b)(2)(iii)
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Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Special conditions for
accumulation of
incompatible wastes
(A) Incompatible wastes, or incompatible wastes and
materials, (see appendix V of part 265 for examples) must not
be placed in the same container, unless § 265.17(b) of this
chapter is complied with.
(B) Hazardous waste must not be placed in an unwashed
container that previously held an incompatible waste or
material (see appendix V of part 265 for examples), unless §
265.17(b) of this chapter is complied with.
(C) A container accumulating hazardous waste that is
incompatible with any waste or other materials accumulated
or stored nearby in other containers, piles, open tanks, or
surface impoundments must be separated from the other
materials or protected from them by means of a dike, berm,
wall, or other device.
Accumulation of incompatible wastes, or
incompatible wastes and materials on site -
Applicable
40 C.F.R. §262.16(b)(2)(v)
Labeling and marking of
containers
A small quantity generator must mark or label its containers
with the following:
(A) The words "Hazardous Waste";
(B) An indication of the hazards of the contents (examples
include, but are not limited to, the applicable hazardous waste
characteristic(s) (i.e., ignitable, corrosive, reactive, toxic);
hazard communication consistent with the Department of
Transportation requirements at 49 C.F.R. part 172 subpart E
(labeling) or subpart F (placarding); a hazard statement or
pictogram consistent with the Occupational Safety and Health
Administration Hazard Communication Standard at 29 C.F.R.
1910.1200; or a chemical hazard label consistent with the
National Fire Protection Association code 704); and
(C) The date upon which each period of accumulation begins
clearly visible for inspection on each container.
Accumulation of RCRA hazardous waste on site
as defined in 40 C.F.R. § 260.10 - Applicable
40 C.F.R. §262.16(b)(6)(i);
15A NCAC 13A .0106, .0107
Condition of container
If a container holding hazardous waste is not in good
condition, or if it begins to leak, the owner or operator must
transfer the hazardous waste from this container to a
container that is in good condition or manage the waste in
some other way that complies with the requirements of this
part.
Storage of RCRA hazardous waste in containers -
Applicable
40 C.F.R. §265.171
15A NCAC 13A .0109
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Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Compatibility of waste
with container
Must use a container made of or lined with materials which
will not react with, and are otherwise compatible with, the
hazardous waste to be stored, so that the ability of the
container to contain the waste is not impaired.
40 C.F.R. §265.172
15A NCAC 13A .0109
Containers must be closed during storage, except when
necessary to add/remove waste.
Container must not be opened, handled and stored in a
manner that may rupture the container or cause it to leak.
40 C.F.R. § 265.173(a) and (b)
15A NCAC 13A .0109
Storage of hazardous
waste in container area
Area must have a containment system designed and operated
in accordance with 40 C.F.R. §264.175(b).
Storage of RCRA-hazardous waste in containers
with free liquids - Applicable
40 C.F.R. §264.175(a)
15A NCAC 13A ,0109(j)
Area must be sloped or otherwise designed and operated to
drain liquid from precipitation, or
Containers must be elevated or otherwise protected from
contact with accumulated liquid.
Storage of RCRA-hazardous waste in containers
that do not contain free liquids (other than F020,
F021, F022, F023,F026 and F027) - Applicable
40 C.F.R. § 264.175(c)(1) and (2)
15A NCAC 13A ,0109(j)
Closure performance
standard for RCRA
container storage unit
Must close the facility (e.g., container storage unit) in a
manner that:
• Minimizes the need for further maintenance;
• Controls minimizes or eliminates to the extent necessary
to protect human health and the environment, post-
closure escape of hazardous waste, hazardous
constituents, leachate, contaminated run -off, or
hazardous waste decomposition products to the ground
or surface waters or the atmosphere; and
• Complies with the closure requirements of subpart, but
not limited to, the requirements of 40 C.F.R. 264.178 for
containers.
Storage of RCRA hazardous waste in containers -
Applicable
40 C.F.R. §264.111
15A NCAC 13A .0109(h)
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Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Closure of RCRA container
storage unit
At closure, all hazardous waste and hazardous waste residues
must be removed from the containment system. Remaining
containers, liners, bases, and soils containing or contaminated
with hazardous waste and hazardous waste residues must be
decontaminated or removed.
[Comment: At closure, as throughout the operating period,
unless the owner or operator can demonstrate in accordance
with 40 C.F.R. 261.3(d) of this chapter that the solid waste
removed from the containment system is not a hazardous
waste, the owner or operator becomes a generator of
hazardous waste and must manage it in accordance with all
applicable requirements of parts 262 through 266 of this
chapter].
Storage of RCRA hazardous waste in containers in
a unit with a containment system - Applicable
40 C.F.R. § 264.178
15A NCAC 13A ,0109(j)
Storage of PCB waste in a
RCRA-regulated container
storage area
Does not have to meet storage unit requirements in 40 C.F.R.
761.65(b)(1) provided unit:
• is permitted by EPA under RCRA § 3004, or
• qualifies for interim status under RCRA § 3005; or
• is permitted by an authorized state under RCRA §
3006 and,
• PCB spills cleaned up in accordance with Subpart G
of 40 C.F.R. 761.
Storage of PCBs and PCB Items designated for
disposal - Applicable
40 C.F.R. §761.65(b)(2)(i)-(iv)
Temporary storage of
bulk PCB remediation
waste or PCB bulk product
waste in a waste pile
Waste must be placed in a pile that:
• is designed and operated to control dispersal by
wind, where necessary, by means other than
wetting;
• does not generate leachate through decomposition
or other reactions.
Storage of PCB remediation waste or PCB bulk
product waste at cleanup site or site of
generation for up to 180 days - Applicable
40 C.F.R. § 761.65(c)(9)(i) and (ii)
Waste pile liner
performance
The storage site must have a liner designed, constructed, and
installed to prevent any migration of wastes off or through
liner into adjacent subsurface soil, groundwater or surface
water at any time during active life (including closure period)
of the storage site.
40 C.F.R. §761.65(c)(9)(iii)(A)
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Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Construction of storage
pile liner
Liner must be:
• constructed of materials that have appropriate chemical
properties and sufficient strength and thickness to prevent
failure because of pressure gradients, physical contact with
waste or leachate to which they are exposed, climatic
conditions, the stress of installation, and the stress of daily
operation;
• placed on foundation or base capable of providing support
to liner and resistance to pressure gradients above and
below the liner to present failure because of settlement
compression or uplift;
• installed to cover all surrounding earth likely to be in
contact with waste.
40 C.F.R. § 761.65(c)(9)(iii)(A)(l)-(3)
Construction of storage
pile cover
The storage site must have a cover that:
• meets the requirements of 40 C.F.R. 761.65(c)(9)(iii)(A);
• is installed to cover all of the stored waste likely to be
contacted by precipitation; and
• is secured so as not to be functionally disabled by winds
expected under normal weather conditions; and
Storage of PCB remediation waste or PCB bulk
product waste at cleanup site or site of
generation for up to 180 days-Applicable
40 C.F.R. §761.65(c)(9)(iii)(B)
Construction of storage
pile run-on control system
The storage site must have a run-on control system designed,
constructed, operated and maintained such that it:
• prevents flow on the stored waste during peak discharge
from at least a 25-year storm;
• collects and controls at least the water volume resulting
from a 24-hour, 25-year storm. Collection and holding
facilities (e.g., tanks or basins) must be emptied or
otherwise managed expeditiously after storms to
maintain design capacity of the system.
40 C.F.R. § 761.65(c)(9)(iii)(C)(l) and
(2)
Modification of waste pile
requirements
Requirements of 40 C.F.R. 761.65(c)(9) may be modified under
the risk-based disposal option of 40 C.F.R. 761.61(c).
40 C.F.R. § 761.65(c)(9)(iv)
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Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Treatment/disposal of wastes - primary wastes (contaminated media such as soil from well cuttings)
and secondary wastes (wastewaters, contaminated equipment, etc.)
Disposal of solid waste
Shall ensure that waste is disposed of at a site or facility which
is permitted to receive the waste.
Generation of solid waste intended for off-site
disposal - Relevant and Appropriate
15A NCAC 13B .0106(b)
Disposal of RCRA-
hazardous waste in a
land-based unit
May be land disposed if it meets the requirements in the table
"Treatment Standards for Hazardous Waste" at 40 C.F.R.
268.40 before land disposal.
Land disposal, as defined in 40 C.F.R.268.2, of
restricted RCRA waste - Applicable
40 C.F.R. § 268.40(a)
15A NCAC 13A .0112(d)
All underlying hazardous constituents [as defined in 40 C.F.R.
268.2(i)] must meet the Universal Treatment Standards, found
in 40 C.F.R. 268.48 Table UTS prior to land disposal.
Land disposal of restricted RCRA characteristic
wastes (D001 - D043) that are not managed in a
wastewater treatment system that is regulated
under the CWA, that is CWA equivalent, or that is
injected into a Class 1 nonhazardous injection
well - Applicable
40 C.F.R. §268.40(e)
15A NCAC 13A .0112(d)
To determine whether a hazardous waste identified in this
section exceeds the applicable treatment standards of 40
C.F.R. 268.40, the initial generator must test a sample of the
waste extract or the entire waste, depending on whether the
treatment standards are expressed as concentration in the
waste extract or waste, or the generator may use knowledge
of the waste.
Land disposal of RCRA toxicity characteristic
wastes (D004 - D011) that are newly identified
(i.e., wastes, soil, or debris identified by the TCLP
but not the Extraction Procedure) - Applicable
40 C.F.R. § 268.34(f)
15A NCAC 13A .0112(c)
If the waste contains constituents (including UHCs in the
characteristic wastes) in excess of the applicable UTS levels in
40 C.F.R. 268.48, the waste is prohibited from land disposal,
and all requirements of part 268 are applicable, except as
otherwise specified.
Disposal of RCRA-
hazardous waste soil in a
land-based unit
Must be treated according to the alternative treatment
standards of 40 C.F.R.268.49(c) or according to the UTSs
[specified in 40 C.F.R.268.48 Table UTS] applicable to the listed
and/or characteristic waste contaminating the soil prior to
land disposal.
Land disposal, as defined in 40 C.F.R. § 268.2, of
restricted hazardous soils - Applicable
40 C.F.R. § 268.49(b)
15A NCAC 13A .0112(d)
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September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Disposal of bulk PCB
remediation waste off-
site
(self-implementing
option)
Shall be disposed of in accordance with the provisions for
cleanup wastes at 40 C.F.R. 761.61(a)(5)(v)(A).
Bulk PCB remediation waste which has been de-
watered and with a PCB concentration < 50 ppm
- Relevant and Appropriate
40 C.F.R. § 761.61(a)(5)(i)(B)(2)(ii)
Performance-based
disposal of PCB
remediation waste
Shall dispose by one of the following methods:
• in a high-temperature incinerator approved under 40
C.F.R. 761.70(b);
• by an alternate disposal method approved under 40 C.F.R.
761.60(e);
• in a chemical waste landfill approved under 40 C.F.R.
761.75;
• in a facility with a coordinated approval issued under 40
C.F.R. 761.77; or
• through decontamination in accordance with 40 C.F.R.
761.79.
Disposal of non-liquid PCB remediation waste (as
defined in 40 C.F.R. 761.3) - Applicable
40 C.F.R. §761.61(b)(2)
40 C.F.R. §761.61(b)(2)(i)
40 C.F.R. §761.61(b)(2)(ii)
Shall be disposed according to 40 C.F.R. 761.60(a) or (e) or
decontaminate in accordance with 40 C.F.R. 761.79.
Disposal of liquid PCB remediation waste -
Applicable
40 C.F.R. §761.61(b)(1)
Disposal of PCB cleanup
wastes (e.g., PPE, rags,
non-liquid cleaning
materials)
(self- implementing
option)
Shall be disposed of either:
• in a facility permitted, licensed or registered by a State to
manage municipal solid waste under 40 C.F.R. 258 or non-
municipal, non-hazardous waste subject to 40 C.F.R. 257.5
thru 257.30; or
• in a RCRA Subtitle C landfill permitted by a State to accept
PCB waste; or
• in an approved PCB disposal facility; or
• through decontamination under 40 C.F.R. 761.79(b) or (c).
Generation of non-liquid PCBs at any
concentration during and from the cleanup of
PCB remediation waste - Applicable
40 C.F.R. § 761.61(a)(5)(v)(A)(l)-(4)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Discharge of Wastewater from De-watering of soil and sediments, and Monitoring Well purge-water
Discharge into POTW
General prohibitions
A User may not introduce into a POTW any pollutant(s) which
cause Pass Through or Interference. These general prohibitions
and the specific prohibitions in paragraph (b) of this section
apply to each User introducing pollutants into a POTW
whether or not the User is subject to other National
Pretreatment Standards or any national, State, or local
Pretreatment Requirements.
Indirect discharge of pollutants into POTW from
Industrial User as defined 40 C.F.R. § 403.3 -
Applicable
40 C.F.R. §403.5 (a)(1)
National pretreatment standards:
Prohibited discharges
15ANCAC 02H .0909
Specific prohibitions
In addition, the following pollutants shall not be
introduced into a POTW:
(1) Pollutants which create a fire or explosion hazard in the
POTW, including, but not limited to, waste streams with a
closed cup flashpoint of less than 140 degrees Fahrenheit or
60 degrees Centigrade using the test methods specified in 40
C.F.R. §261.21;
40 C.F.R. §403.5 (b)(1)
15ANCAC 02H .0909
(2) Pollutants which will cause corrosive structural damage
to the POTW, but in no case Discharges with pH lower than
5.0, unless the works is specifically designed to
accommodate such Discharges;
Indirect discharge of pollutants into POTW from
Industrial User as defined 40 C.F.R. §403.3 -
Applicable
40 C.F.R. §403.5 (b)(2)
15ANCAC 02H .0909
(3) Solid or viscous pollutants in amounts which will cause
obstruction to the flow in the POTW resulting in
Interference;
40 C.F.R. §403.5 (b)(3)
15ANCAC 02H .0909
(4) Any pollutant, including oxygen demanding pollutants
(BOD, etc.) released in a Discharge at a flow rate and/or
pollutant concentration which will cause Interference with
the POTW.
40 C.F.R. §403.5 (b)(4)
15ANCAC 02H .0909
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Discharge into POTW
con't
(5) Heat in amounts which will inhibit biological activity in
the POTW resulting in Interference, but in no case heat in
such quantities that the temperature at the POTW
Treatment Plant exceeds 40 °C (104 °F) unless the Approval
Authority, upon request of the POTW, approves alternate
temperature limits.
40 C.F.R. §403.5 (b)(5)
15ANCAC02H .0909
(6) Petroleum oil, nonbiodegradable cutting oil, or products
of mineral oil origin in amounts that will cause interference
or pass through;
40 C.F.R. §403.5 (b)(6)
15ANCAC02H .0909
(7) Pollutants which result in the presence of toxic gases,
vapors, or fumes within the POTW in a quantity that may
cause acute worker health and safety problems;
40 C.F.R. §403.5 (b)(7)
15ANCAC02H .0909
(8) Any trucked or hauled pollutants, except at discharge
points designated by the POTW.
40 C.F.R. §403.5 (b)(8)
15ANCAC02H .0909
(d) Local limits. Where specific prohibitions or limits on
pollutants or pollutant parameters are developed by a POTW
in accordance with 40 C.F.R. § 403.5 (c), such limits shall be
deemed Pretreatment Standards for the purposes of section
307(d) of the CWA.
Indirect discharge of pollutants into POTW from
Industrial User as defined 40 C.F.R. §403.3 -
Applicable
40 C.F.R. § 403.5(d)
15ANCAC02H .0909
Groundwater Remediation Wells - injection wells, extraction wells, re-injection wells and UIC wells
General standard for
recovery well (e.g., multi-
phase extraction well)
Recovery wells shall be located, designed, constructed,
operated and abandoned with materials and by methods that
are compatible with the chemical and physical properties of
the contaminants involved, specific site conditions and specific
subsurface conditions.
Design, construction, or operation of any
recovery well - Applicable
15ANCAC 02C .0108(c)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
General standard for
recovery well (e.g., multi-
phase extraction well)
con't
Recovery well boreholes shall not penetrate to a depth greater
than the depth to be monitored or the depth from which
contaminants are to be recovered. Any portion of the borehole
that extends to a depth greater than the depth to be
monitored or the depth from which contaminants are to be
recovered shall be grouted completely to prevent vertical
migration of contaminants.
15ANCAC 02C .0108(d)
Standards for pumps and
equipment for extraction
well
The pumping capacity of the pump shall be consistent with the
intended use and yield characteristics of the well.
Design, construction, or operation of any
extraction well (not used for water supply) -
Applicable
15ANCAC 02C .0109(a)
The pump and related equipment for the well shall be located
to permit easy access and removal for repair and maintenance.
15ANCAC 02C .0109(b)
The base plate of a pump placed directly over the well shall be
designed to form a watertight seal with the well casing or
pump foundation.
15ANCAC 02C .0109(c)
In installations where the pump is not located directly over the
well, the annular space between the casing and pump intake
or discharge piping shall be closed with a watertight seal.
15ANCAC 02C .0109(d)
The well head shall be equipped with a screened vent to allow
for the pressure changes within the well unless a suction lift
pump or single-pipe jet pump is used or artesian, flowing well
conditions are encountered.
15ANCAC 02C .0109(e)
A priming tee shall be installed at the well head in conjunction
with offset jet pump installations.
15ANCAC 02C .0109(g)
Joints of any suction line installed underground between the
well and pump shall be tight under system pressure.
Design, construction, or operation of any
extraction well (not used for water supply) -
Applicable
15ANCAC 02C .0109(h)
The drop piping and electrical wiring used in connection with
the pump shall meet all applicable underwriters' specifications.
15ANCAC 02C ,0109(i)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Design criteria for all
injection wells
No person shall construct, operate, maintain, convert, plug,
abandon, or conduct any other injection activity in a manner
that allows the movement of fluid containing any contaminant
into underground sources of drinking water if the presence of
that contaminant would cause a violation of any applicable
groundwater quality standard specified in Subchapter 02L or
would otherwise adversely affect human health.
Design, construction, or operation of any
injection well - Applicable
40 C.F.R. § 144.12
15ANCAC 02C .0211(b)
Injection of remediation
amendments into
groundwater
An injection activity cannot allow the movement of fluid
containing any contaminant into underground sources of
drinking water, if the presence of that contaminant may cause
a violation of the primary drinking water standards under 40
C.F.R. part 141 or other health-based standards or may
otherwise adversely affect the health of persons.
Class V wells [as defined in 40 C.F.R. § 144.6(e)] -
Relevant and Appropriate
40 C.F.R. § 144.82(a)(1)
This prohibition applies to well construction, operation,
maintenance, conversion, plugging, closure, or any other
injection activity.
Wells must be closed in a manner that complies with the
above prohibition of fluid movement. Also, any soil, gravel,
sludge, liquids, or other materials removed from or adjacent to
the well must be disposed or otherwise managed in
accordance with substantive applicable federal, state, and
local regulations and requirements.
40 C.F.R. § 144.82(b)
Injection of substances into
underground well
Groundwater remediation wells used to inject additives,
treated groundwater, or ambient air for treatment of
contaminated soil or groundwater may inject only additives
determined by Department of Health and Human services not
to adversely affect human health.
Injection of fluids into or air into an underground well
for the purposes of groundwater remediation -
Applicable
15ANCAC 02C .0225(a)
Other Wells shall meet the requirements of that injection well
type describe in Rule .0209(5)(b) that most closely resembles
the proposed Other Well's hydrogeologic complexity and
potential to adversely affect groundwater quality.
Injection of substances into an underground well
other than liquids or air-TBC
15ANCAC 02C .0230
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Injection of substances into
underground well con't
Multi-screened wells shall not connect aquifers or zones
having differences in water quality that would result in a
degradation of any aquifer or zone.
15A NCAC 02C ,0225(h)(17)
Construction of air
injection well [as defined
in 15A NCAC 02C.0224(2)]
The air injected shall not exceed ambient air quality standards
set forth in 15A NCAC 2D.0400 and shall not contain petroleum
or any constituent that would cause a violation of groundwater
standards specified in Subchapter 2L.
Shall be constructed in accordance with the well construction
standards applicable to monitoring wells specified in Rule
.0108 of this Subchapter.
Installation of groundwater remediation wells for
the subsurface injection of ambient air for the
treatment of contaminated soil or groundwater
(permitted by Rule)- Applicable
15A NCAC 02C .0225(c)(4)(A) and (B)
Injection zone
determination
Shall specify the horizontal and vertical portion of the injection
zone within which the proposed injection activity shall occur
based on the hydraulic properties of that portion of the
injection zone specified.
No violation of groundwater quality standards specified in
Subchapter 02L resulting from the injection shall occur outside
the specified portion of the injection zone as detected by a
monitoring plan approved by the Division.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15A NCAC 02C .0225(f)(3)
Location of groundwater
remediation wells
Wells shall not be located where:
(A) surface water or runoff will accumulate around the well
due to depressions, drainage ways, or other landscapes that
will divert water to the well;
(B) a person would be required to enter confined spaces to
perform sampling and inspection activities; and
(C) injectants or formation fluids would migrate outside the
approved injection zone as determined by the applicant in
accordance with Subparagraph (f)(3) of this Rule.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15A NCAC 02C .0225(h)(1)
Construction of
remediation wells
The methods and materials used in construction shall not
threaten the physical and mechanical integrity of the well
during its lifetime.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15A NCAC 02C .0225(h)(3)
The well shall be constructed in a manner that surface water
or contaminants from the land surface cannot migrate along
the borehole annulus either during or after construction.
15A NCAC 02C .0225(h)(4)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Construction of
remediation wells con't
The borehole shall not penetrate to a depth greater than the
depth at which injection will occur unless the purpose of the
borehole is the investigation of the geophysical and
geochemical characteristics of an aquifer. Following
completion of the investigation the borehole beneath the zone
of injection shall be grouted completely to prevent the
migration of any contaminants.
15ANCAC 02C .0225(h)(5)
Grouted Wells
Only allowable grout listed under Rule .0107 of this Subchapter
shall be used however, bentonite grout shall not be used:
(A) to seal zones of water with a chloride concentration of
1,500 milligrams per liter or greater as determined by tests
conducted at the time of construction; or
(B) in areas of the State subject to saltwater intrusion that may
expose the grout to water with a chloride concentration of
1,500 milligrams per liter or greater at any time during the life
of the well.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15ANCAC 02C .0225(h)(8)
Grouted Wells
The annular space between the borehole and casing shall be
grouted:
(A) with a grout that is non-reactive with the casing or screen
materials, the formation, or the injectant;
(B) from the top of the gravel pack to land surface and in a way
that there is no interconnection of aquifers or zones having
differences in water quality that would result in the
degradation of the groundwater quality of any aquifer or zone;
and
(C) so that the grout extends outward from the casing wall to a
thickness equal to either one-third of the diameter of the
outside dimension of the casing or two inches, whichever is
greater. In no case shall a well be required to have an annular
grout seal thickness greater than four inches.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15ANCAC 02C .0225(h)(9)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Construction of
remediation wells con't
Grouted Wells
Grout shall be emplaced around the casing by one of the
following methods:
(A) Pressure. Grout shall be pumped or forced under pressure
through the bottom of the casing until it fills the annular space
around the casing and overflows at the surface;
(B) Pumping. Grout shall be pumped into place through a hose
or pipe extended to the bottom of the annular space which
can be raised as the grout is applied. The grout hose or pipe
shall remain submerged in grout during the entire application;
or
(C) Other. Grout may be emplaced in the annular space by
gravity flow in such a way to ensure complete filling of the
space. Gravity flow shall not be used if water or any visible
obstruction is present in the annular space at the time of
grouting.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15ANCAC 02C ,0225(h)(10)
Grouted Wells
All grout mixtures shall be prepared prior to emplacement per
the manufacturer's directions with the exception that
bentonite chips or pellets may be emplaced by gravity flow if
water is present or otherwise hydrated in place.
If an outer casing is installed, it shall be grouted by either the
pumping or pressure method.
The well shall be grouted within seven days after the casing is
set or before the drilling equipment leaves the site, whichever
occurs first. If the well penetrates any water-bearing zone that
contains contaminated or saline water, the well shall be
grouted within one day after the casing is set.
No additives that will accelerate the process of hydration shall
be used in grout for thermoplastic well casing.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15A NCAC 02C ,0225(h)(ll)-(14)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Construction of
remediation wells con't
Well casings
A casing shall be installed that extends from at least 12 inches
above land surface to the top of the injection zone.
Wells with casing extending less than 12 inches above land
surface and wells without casing shall be approved when one
of the following conditions is met:
(A) site specific conditions directly related to business
activities, such as vehicle traffic, would endanger the physical
integrity of the well; or
(B) it is not operationally feasible for the well head to be
completed 12 inches above land surface due to the
engineering design requirements of the system.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15A NCAC 02C ,0225(h)(15) and (16)
Prior to removing the equipment from the site, the top of the
casing shall be sealed with a water-tight cap or well seal, as
defined in G.S. 87-85, to preclude contaminants from entering
the well.
15ANCAC 02C ,0225(h)(18)
Gravel and sand
packed wells
Packing materials for gravel and sand packed wells shall be:
(A) composed of quartz, granite, or other hard, non-reactive
rock material;
(B) clean, of uniform size, water-washed and free from clay,
silt, and toxic materials;
(C) disinfected prior to subsurface emplacement;
(D) emplaced such that it will not connect aquifers or zones
having differences in water quality that would result in the
deterioration of the water quality in any aquifer or zone; and
(E) evenly distributed around the screen and shall extend to a
depth at least one foot above the top of the screen. A one foot
thick or greater seal comprised of bentonite clay, shall be
emplaced directly above and in contact with the packing
material.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15ANCAC 02C ,0225(h)(19)
A hose bibb, sampling tap, or other collection equipment shall
be installed on the line entering the injection well such that a
sample of the injectant can be obtained prior to it entering the
injection well.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15ANCAC 02C ,0225(h)(21)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Construction of
remediation wells con't
If applicable, all piping, wiring, and vents shall enter the well
through the top of the casing unless it is based on a design
demonstrated to preclude surficial contaminants from
entering the well.
15ANCAC 02C ,0225(h)(22)
Well head
The well head shall be completed in a manner to preclude
surficial contaminants from entering the well and well head
protection shall include:
(A) an accessible external sanitary seal installed around the
casing and grouting; and
(B) a water-tight cap or well seal compatible with the casing
and installed so that it cannot be removed without the use of
hand or power tools.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15ANCAC 02C ,0225(h)(23)
Unless permitted by this rule, pressure at the well head shall
be limited to a maximum which will ensure that the pressure in
the injection zone does not initiate new fractures or propagate
existing fractures in the injection zone, initiate fractures in the
confining zone, or cause the migration of injected or formation
fluids outside the injection zone or area.
15A NCAC 02C ,0225(j)(l)-(3)
Injection between the outermost casing and the well borehole
is prohibited.
Well owner shall monitor the operating processes at the well
head and shall protect the well head against damage during
construction and use.
Mechanical integrity of
wells
All permanent injection wells shall be tested for mechanical
integrity, which shall be conducted in accordance with Rule
.0207 of this Section.
An injection well has internal mechanical integrity, meaning
there is no leak in the casing, tubing, or packer. An injection
well has external mechanical integrity, meaning there is no
fluid movement into groundwaters through vertical channels
adjacent to the injection well bore.
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15ANCAC 02C ,0225(i)
15A NCAC 02C .0207(a) and (b)
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Monitoring of injection
wells co n't
Monitoring wells shall be of sufficient quantity and location to
detect any movement of injection fluids, injection process
byproducts or formation fluids outside the injection zone as
determined by the applicant in accordance with Subparagraph
(f)(3) of this Paragraph. The monitoring schedule shall be
consistent with the proposed injection schedule, pace of the
anticipated reactions, and rate of transport of the injectants
and contaminants.
NOTE: The Monitoring will be specified in a monitoring plan
included as part of a CERCLA document (e.g., Remedial
Design or Remedial Action Work Plan).
Installation of groundwater remediation wells
(other than permitted by Rule) for injection of
additives - Applicable
15ANCAC 02C ,0225(f)(ll)
If affected, may require additional monitor wells located to
detect any movement of injection fluids, injection process
byproducts, or formation fluids outside the injection zone as
determined by the applicant in accordance with Subparagraph
(f)(3) of this Rule.
If the operation is affected by subsidence or catastrophic
collapse, any other required monitoring wells shall be located
so that they will not be physically affected and shall be of an
adequate number to detect movement of injected fluids,
process byproducts, or formation fluids outside the injection
zone or area.
Installation of monitoring wells in (or adjacent to)
the injection zone that may be affected by
injection operations - Applicable
15A NCAC 02C ,0225(k)(3)
Monitoring Well Installation, Operation, and Abandonment
implementation of
groundwater monitoring
system
install and implement a monitoring program to evaluate the
effects of the discharge upon the environment or waters of the
state, including the effect of any actions taken to restore
groundwater quality, and the efficiency of any treatment
facility.
NOTE: The Monitoring will be specified in a monitoring plan
included as part of a CERCLA document (e.g., Remedial
Design or Remedial Action Work Plan).
Groundwater remediation activities - Applicable
15ANCAC 02L .0110(a)
68
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Implementation of
groundwater monitoring
system con't
Shall be constructed in a manner that will not result in
contamination of waters of the State.
Installation of monitoring system to evaluate
effects of any actions taken to restore
groundwater quality, as well as the efficacy of
treatment - Applicable
15ANCAC 02L .0110(b)
Construction of
groundwater monitoring
well(s)
No well shall be located, constructed, operated, or repaired in
any manner that may adversely impact the quality of
groundwater.
Installation of wells (including temporary wells,
monitoring wells) other than for water supply -
Applicable
15ANCAC 02C .0108(a)
Shall be located, designed, constructed, operated and
abandoned with materials and by methods which are
compatible with the chemical and physical properties of the
contaminants involved, specific site conditions, and specific
subsurface conditions.
Installation of wells (including temporary wells,
monitoring wells) other than for water supply -
Applicable
15ANCAC 02C .0108(c)
Monitoring well and recovery well boreholes shall meet the
construction requirements set forth in the cited regulations
related to:
• Borehole depth and hydraulic connectivity
Installation of wells (including temporary wells,
monitoring wells) and boreholes other than for
water supply - Applicable
15A NCAC 02C .0108(d) thru
15ANCAC 02C ,0108(p)
Standards of Construction
• Construction materials, packing material, well screen
and seals
• Grout placement and contents
• Well construction
• Locking well cap
• Well casing and covers
• Identification
• Wellhead protection
Shall be constructed in such a manner as to preclude the
vertical migration of contaminants within and along the
borehole channel.
Installation of temporary wells and all other non-
water supply wells - Applicable
15A NCAC 02C ,0108(t)
Monitoring well
development
Shall be developed such that the level of turbidity or settleable
solids does not preclude accurate chemical analyses of any
fluid samples collected or adversely affect the operation of any
pumps or pumping equipment.
Installation of wells (including temporary wells,
monitoring wells) other than for water supply-
Applicable
15A NCAC 02C ,0108(q)
69
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Maintenance of
groundwater monitoring
well(s)
A well that is not maintained by the owner to conserve and
protect the groundwater resources or that constitutes a source
or channel of contamination to the water supply or any aquifer
shall be permanently abandoned in accordance with Rule
.0113(b) of this Section.
Installation of wells (including temporary wells
and monitoring wells) other than for water
supply-Applicable
15A NCAC 02C .0112(a)
All materials used in the maintenance, replacement, or repair
of any well shall be in accordance with 15A NCAC 02C .0107
and .0108.
15A NCAC 02C .0112(c)
Broken, punctured, or otherwise defective or unserviceable
casing, screens, fixtures, seals, or any part of the well head
shall be repaired or replaced, or the well shall be permanently
abandoned pursuant to 15A NCAC 02C .0113
Permanent abandonment of wells (including
temporary wells, monitoring wells, and test
borings) other than for water supply less than 20
feet in depth and which do not penetrate the
water table - Applicable
15A NCAC 02C .0112(d)
No well shall be repaired or altered such that the well head is
completed less than 12 inches above land surface. Any grout
excavated or removed as a result of the well repair shall be
replaced in accordance with Rule .0107(f) of this Section.
15A NCAC 02C .0112(f)
Abandonment of
groundwater monitoring
and remediation well(s)
Shall be abandoned by filling the entire well up to land surface
with grout, dry clay, or material excavated during drilling of the
well and then compacted in place; and
Permanent abandonment of wells (including
temporary wells, monitoring wells, and test
borings) other than for water supply less than 20
feet in depth and which do not penetrate the
water table - Applicable
15A NCAC 02C .0113(d)(1)
Shall be abandoned by completely filling with a bentonite or
cement - type grout.
Permanent abandonment of wells (including
temporary wells, monitoring wells, and test
borings) other than for water supply greater than
20 feet in depth and which do not penetrate the
water table - Applicable
15A NCAC 02C .0113(d)(2)
70
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Abandonment of
groundwater monitoring
and remediation well(s)
con't
Any well that acts as a source or channel of contamination
shall be repaired or permanently abandoned within 30 days of
receipt of notice from the Department.
NOTE: Notice would be provided to NCDEQ as part of the
oversight of the CERCLA remedial action.
15A NCAC 02C .0113(e)
All wells shall be permanently abandoned in which the casing
has not been installed or from which the casing has been
removed, prior to removing drilling equipment from the site.
Permanent abandonment of wells (including
temporary wells) other than for water supply -
Applicable
15A NCAC 02C .0113(f)
Transportation of Wastes - Primary and Secondary Wastes
Transportation of
hazardous materials
Shall be subject to and must comply with all applicable
provisions of the HMTA and HMR at 49 C.F.R. 171-180.
Any person who, under contract with a
department or agency of the federal
government, transports "in commerce," or
causes to be transported or shipped, a hazardous
material - Applicable
49 C.F.R. § 171.1(c)
Transportation of
hazardous waste off site
Must comply with the generator standards established in this
part (e.g., 40 C.F.R. Sect. 262.20-23 for manifesting, Sect.
262.24-25 for electronic manifesting; Sect. 262.30 for
packaging, Sect. 262.31 for labeling, Sect. 262.32 for marking,
Sect. 262.33 for placarding and Sect. 262.40 and 262.41(a) for
record keeping requirements, and Sect. 262.18 to obtain EPA
ID number)
Preparation of shipment of RCRA hazardous
waste off-site - Applicable
40 C.F.R. §262.10(h)
15A NCAC 13A .0107
Transportation of
hazardous waste on-site
The generator manifesting requirements of 40 C.F.R. Sect.
262.20-262.32(b) do not apply. Generator or transporter must
comply with the requirements set forth in 40 C.F.R. § 263.30
and § 263.31 in the event of a discharge of hazardous waste on
a private or public right-of-way.
Transportation of hazardous wastes on a public
or private right-of-way within or along the
border of contiguous property under the control
of the same person, even if such contiguous
property is divided by a public or private right-of-
way - Applicable
40 C.F.R. § 262.20(f)
15A NCAC 13A .0107
71
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Transportation of samples
(i.e., contaminated soils
and wastewaters)
Are not subject to any requirements of 40 C.F.R. Parts 261
through 268 or 270 when:
• The sample is being transported to a laboratory for the
purpose of testing.
• The sample is being transported back to the sample
collector after testing.
• The sample is being stored by sample collector before
transport to a lab for testing.
Generation of samples of hazardous waste for
purpose of conducting testing to determine its
characteristics or composition - Applicable
40 C.F.R. § 261.4(d)(l)(i)-(iii)
15A NCAC 13A .0106(a)
In order to qualify for the exemption in 40 C.F.R. 261.4 (d)(l)(i)
and (ii), a sample collector shipping samples to a laboratory
must:
• Comply with U.S. Department of Transportation, U.S.
Postal Service, or any other applicable shipping
requirements.
• Assure that the information provided in (1) thru (5) of
this section accompanies the sample.
• Package the sample so that it does not leak, spill, or
vaporize from its packaging.
40 C.F.R. § 261.4(d)(2)
40 C.F.R. § 261.4(d)(2) (ii)(A) and (B)
15A NCAC 13A .0106(a)
Transportation of PCB
wastes off-site
Must comply with the manifesting provisions at 40 C.F.R.
761.207 through 218.
Relinquishment of control over PCB wastes by
transporting, or offering for transport -
Applicable
40 C.F.R. § 761.207(a)
Institutional Controls for Contamination Left in Place
Notice of Contaminated
Site
Prepare and certify by professional land surveyor a survey plat
which identifies contaminated areas which shall be entitled
"NOTICE OF CONTAMINATED SITE".
Notice shall include a legal description of the site that would
be sufficient as a description in an instrument of conveyance
and meet the requirements of N.C.G.S. 47-30 for maps and
plans.
Contaminated site subject to current or future
use restrictions included in a remedial action plan
as provided in N.C.G.S. 143B-279.9(a) - TBC
N.C.G.S. 143B-279.10(a)
72
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Notice of Contaminated
Site con't
The Notice (survey plat) shall identify:
• the location and dimensions of any disposal areas and areas
of potential environmental concern with respect to
permanently surveyed benchmarks;
• the type location and quantity of contamination known to
exist on the site; and
•any use restriction on the current or future use of the site.
N.C.G.S. 143B-279.10(a)(l)-(3)
The Notice (survey plat) shall be filed in the register of deeds
office in the county or counties in which the land is located.
N.C.G.S. 143B-279.10(b)
The deed or other instrument of transfer shall contain in the
description section, in no smaller type than used in the body of
the deed or instrument, a statement that the property is a
contaminated site and reference by book and page to the
recordation of the Notice.
Contaminated site subject to current or future
use restrictions as provided in N.C.G.S. 143B-
279.9(a) that is to be sold, leased, conveyed or
transferred — TBC
N.C.G.S. 143B-279.10(e)
Deed restrictions for caps,
fences and low occupancy
areas
Must maintain the fence or cap, in perpetuity.
Use of a cap or fence at PCB remediation waste
cleanup site — Relevant and Appropriate
40 C.F.R. §761.61(a)(8)
Within 60 days of completion of cleanup activity shall record,
in accordance with State law, a notation on the deed to the
property, or on some other instrument which is normally
examined during a title search, that will in perpetuity notify
any potential purchaser of the property:
Use of a cap or fence at low occupancy PCB
remediation waste cleanup site — Relevant and
Appropriate
40 C.F.R. §761.61(a)(8)(i)(A)
- that land has been used for PCB remediation waste disposal
and is restricted to use as a low occupancy area as defined in
40 C.F.R. 761.3.
40 C.F.R. § 761.61(a)(8)(i)(A)(l)
- of the existence of the fence or cap and the requirements to
maintain the fence or cap.
40 C.F.R. § 761.61(a)(8)(i)(A)(2)
- the applicable cleanup levels left at the site, inside the fence,
and/or under the cap.
40 C.F.R. § 761.61(a)(8)(i)(A)(3)
73
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
ACTION-SPECIFIC ARARs and TBC
Action
Requirements
Prerequisite
Citation(s)
Deed restrictions for caps,
fences and low occupancy
areas con't
May remove a fence or cap after conducting additional
cleanup activities and achieving levels specified in 40 C.F.R.
761.61(a)(4) which do not require a cap or fence and remove
the notice on the deed no earlier than 30 days after achieving
these levels.
40 C.F.R. §761.61(a)(8)(ii)
ARAR = applicable or relevant and appropriate requirement
C.F.R. = Code of Federal Regulations
CWA = Clean Water Act of 1972
DOT = U.S. Department of Transportation
EPA = U.S. Environmental Protection Agency
NCAC = North Carolina Administrative Code
N.C.G.S. = North Carolina General Statutes
NPDES = National Pollutant Discharge Elimination System
PCB = polychlorinated biphenyl
POTW = Publicly Owned treatment Works
HMR = Hazardous Materials Regulations
HMTA = Hazardous Materials Transportation Act
RCRA = Resource Conservation and Recovery Act of 1976
TSCA = Toxic Substances Control Act of 1976
TBC = to be considered
UTS = Universal Treatment Standard
WWTU = wastewater treatment unit
74
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
FIGURES
75
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Ward Transformer Superfund Site. Wake County., North Carolina OU-2
Record of Decision
September 2023
Approximate OU2 Boundary
Surface Water Drainage
Raleigh Durham
International Airport
felC SGI A. WxarJ
N Ward TranSfOrmGf SUpGrfund SitG Disclaimer: This map and any boundary lines within the map are approximate and subject to ik
A" change. The map is not a survey. The map is for informational purposes only regarding EPA's
City of Raleigh, Wake County, North Carolina refonf acfo"s at TJFJZtffF* ***e„ fteiim^propeny of Esn and is used herein OlOO
J ^ J under license. Copyright © 2023 Esri and Its licensors. All rights reserved. Sources: Esn, NC v
I I CGIA, Maxar, Microsoft, and the 2023 Focused Feasibility Study. Last Modified: 7/17/2023
^^Skeo
400 Feet
Figure 1: Site Location
76
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Ward Transformer Superfimd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
M reward
PROPERTIES LLC
OVERTON
O y^Raleigh:durham|_^S
^ AIRPORT'AUTHORITyJP^
FMR WARD/TRANSFORMER CO INC
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AIRPORT-AUTHORITY
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INTERNATIONAL
Surface Water Drainage
Pre-Removal Action Topographic Contour
Pipe Abandoned in Phase 2
| Phase 1 Removal Action
Phase 2 Removal Action
\ Property Boundary
Maximum Excavation Depth
| 1 - S' Depth
^6-10' Depth
11 -15'Depth
16-20'Depth
H 21 - 29' Depth
Wafce County GIS, 2010
Fleming Engreenng. Inc.. 2QW - 2QM
Projection: North Carolina State Plane Datum: NAD 83
PRDJECT Ward Transformer Superfund Site
Raleigh, North Caroina
nut
Removal Extent anc
Maximum Exc
avation Depths
\\S|> COLDER
JT1 1 HPS-M*
Figure 2-4
c-it:*
:ts:
mmfw
DM
Figure 2: Removal Extent and Maximum Excavation Depths
77
-------
Ward Transformer Superfund Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
HEreward^%^
iPROPERTIES LLu
OVERTC
RALEIGH-DURHAM
JJ^^AIRPORT AUTHORtTY^%5
FMR WARD TRANSFORMER CO INC:
'RALEIGH DURHAM
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JJ - RALEIGH-DURHAM
AIRPORT AUTHORITY J
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FMR ESTES EXPRESS LINES
Surface Water Drainage
_] Property Boundaries
\ H Treated Soil Cove- Limits
J Extent of Treated Soil Backfill
10U2 Boundary
Ward Transformer Superfund Site
Raleigh. North Carolina
Extent of Treated Soil Backfill and Cover
run
Y\V|) GOLDER
Figure 2-5
Figure 3: Extent of Treated Soil Backfill and Cover
78
-------
Ward Transformer Superfimd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
n ' REWARD
PROPERTIES LLC
OVERTON
ft I ^
/ RALEIGH-DURHAM)
V AIRPORT AUTHORITY '([)
FMR WARD TRANSFORMER CO INC
/RALEIGH DURHAM
AIRPORT AUTHORITY
RALEIGH DURHAM
"INTERNATIONAL
RALEIGH-DURHAM . f\
AIRPORT AUTHORITY rr^
FMR WARD TRANSFORMER CO INC
WARD VENTURES LLC
BREACH AN
3®? RALEIGH-DURHAMAg
BAIRPORT AUTHORITY*
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Removal PCBs Left-ln-Place
\\S|) GOLDER
Figure 2-6
Surface Water Drainage
¦"v" Pipe Abandoned in Phase 2
Post Removal Action Index Contours
Post Removal! Acton Intermediate Contours
I Property Boundary
Phase 1 Removal Action
Phase 2 Removal Action
PCB Concentrations Left-ln-Place - Soil
' -5" Depth
Y//A 6 -10' Depth
V/A '6 - 'B'Depth
PCB Concentrations Left-ln-Place - Rock
1 - 5* Depth
11 6 -10' Depth
I | 11 -15" Depth
I | 16 - 20' Depth
I | 21 -25'Depth
I I 26 - 30' Depth
IT! 31 - 32' Depth
Oeptn sTiown Is depth oe ow restored ground surface (a: post-RA
conditions)
REFERENCE
wane County G!S, 2D1D
Fleming Engineering, Inc., 20C6 - 2014
Projection: Norm Carolina state Pane Datum: NAD 33
250 125 0 250
Ward Transformer Superfund Site
Raleigh, North Carolina
INDEX MAP
LEGEND
Figure 4: PCBs Left in Place After the OU-2 Removal Action
79
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Ward Transformer Superfimd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Primary
Sources
Primary
Release
Mechanisms
Secondary
Sources
Secondary
Release
Mechanisms
Tertiary Sources
Exposure Pathway
Occupational-
Current/Future2
Receptors
Construction I
Maintenance
Worker - Future2
Resident -
Future2
Trespasser-
Current/Future
Ingestion
Dermal Contact
Inhalation
Ingestion
Dermal Contact
Inhalation of Vapors
Vapor Intrusion
X
•
X
X
X
•
X
X
X
o
X
X
X
X
•
X
X
o
•
X
X
o
0
X
o
X
o
X
Potentially major contribution to overall exposure
Potentially minor contribution to overall exposure
Incomplete exposure pathway
Notes:
1. There are no chemicals of concern assumed to remain in treated soil, therefore no connections are shown to other release mechanisms, sources, exposure pathways, or receptors.
2. These pathways will include infant exposures to dioxin-like PCBs via ingestion of their mother's breast milk.
Figure 5: Human Health Conceptual Site Exposure Model for OU-2
80
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Ward Transformer Superfimd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
Primary
Sources
Primary
Release
Mechanisms
Secondary
Sources
Secondary
Release
Mechanisms
Exposure Soil Avian Mammalian Avian Mammalian Mammalian
Tertiary Sources Pathway Plants Invertebrates Invertivores Invertivores Omnivores Omnivores Raptors Carnivores
1 Spills-
Treated Soils1
| Untreated Soils
Leaching and
Infiltration
Food Chain
Uptake
Deep Soil
Groundwater
Exposures
Ingestion
Direct Contact
Ingestion
Direct Contact
Ingestion
Legend
Notes:
1 - There are no chemicals of concern assumed to remain in treated soil, therefore no connections are shown to other release mechanisms, sources, exposure pathways, or receptors.
Potentially major contnbution to overall exposure
Potentially minor contnbution to overall exposure
Incomplete exposure pathway
Figure 6: Ecological Conceptual Site Exposure Model for Exposure to PCBs in OU-2
81
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Ward Transformer Superfund Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
2/10/2016
MW-10
2/11/2016
MW-9
2/10/2016
MW-13
2/9/2016
MW-1S
Analyte
Benzene
Triangle Well
2/9/2016
MW-8
1,2.4-TCB
1,2,4-TCB
WARD /
¦mw-io'^transformer
*404.55. \\ V /
--WARD
VENTURES'
2/10/2016
MW-11
2/11/2016
MW-3R
2/11/2016
MW-3R PUP
2/11/2016
MW-12
2/9/2016
MW-14
Benzene
1 Z4-TCB
LEGEND
REFERENCE
Ward Transformer Superfund Site
Raleigh, North Carolina
February 2016 Groundwater Sampling Results
and Potentiometric Surface
i I gy i
vf Gulder
w Associates
Figure 3-8
/¦K Background
^ Monitoring Well
~ Shallow Monitoring
^ Well
Deep Monitoring
Well
Post Removal
Action Index
Contours
Post Removal
Action
Intermediate
Contours
_____ Equipotential
Contour
_ Surface Water
Drainage
|_J OU2 Boundary
I 1 Property
' ' Boundaries
I I Building
Groundwater Elevation
(Feet Above Mean Sea
NOTES
Figure 7: Groundwater Sampling Results and Potentiometric Surface, February 2016
82
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Ward Transformer Super&nd Site, Wake County, North Carolina OU-2
Record of Decision
September 2023
APPENDIX A
State of North Carolina Concurrence
A-l
-------
Ward Transformer Superfimd Site, Wake County, Sorth Carolina OU-2
Record of Decision
September 2023
ROY COOPER
Gwemor
ELIZABETH S. B1SER
Secretary
MICHAEL SCOTT
Ofrvctor
NORTH CAROLINA
Fnvrrcnmentat Quality
September 19. 2023
Mr. Hilary Thornton
Superfund Bl anch. Waste Management Division
US EPA Region IV
61 Forsyth Street. 5UT
Atlanta. Georgia 30303
SUB JECT: C incurrence with Record of Decision (ROD)
Ward Transformer. OU2
Raleigh. Wake County
Dear Mr. Thornton:
The State of North Carolina by and through it: Department of Environmental Quality, Division of Waste Management
(herein after referred to as "the state""), reviewed the Record of Decision received by the Division September 14. 2023.
for lie Ward Transformer OU2 Superftmd Site and concurs with the ROD subject to the following conditions :
1. State concurrence on the ROD for this site is based solely on the information contained in the
ER.OD received by the State September 14, 2023. Should the State receive new or additional
information which significantly affects the conclusions or remedy contained m the ROD. it may
modify' or withdraw this concurrence with written notice to EPA Region IV.
2. State concurrence on this ROD in no way binds the State to concur'm future decisions or commits
the State to participate, financially or otherwise, in the cleanup of the site. The State reserves the
right to review, overview comment, and make independent assessment of all future work relating
to this site.
3. If. after remediation is complete, the total residual risk level exceeds 10"*, the State may require
deed recordation restriction to document the presence of residual c ontammation and possibly limit
future use of the property as specified in NCGS 130A-310.8.
The State appreciates the opportunity to comment on the ROD and looks forward to working with EPA on the
remedy for the subject site. If you have any questions or comments, please call Ms. Beth HaitzeU (919) 707-8335.
Sincerely,
William t. Hiinneke. Chief
Superfimd Section
Division of Waste Management
Qu Qi, NC Supeifund
North Caroima Department: of Environmental Quality I Division of Waste Management
217 We*t Jones 51reel I 1646 Mall Service Center I Raleigh, North Carolina 27&9lM64b
9IW078200
A-2
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